⚡ 40 MILLBURY RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 40 Millbury Rd, Oxford, MA (APN: 16_D03)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid interconnection, regulatory hurdles, and financial incentives. While the site possesses a critical advantage with an on-site Point of Interconnection (POI), it faces significant challenges related to zoning and a lack of federal incentive adders that present substantial risk to project viability.

1. Site Access & Topography

• Road Access & Feasibility: The property has frontage on Millbury Road, a publicly maintained, two-lane local road. A preliminary review via satellite imagery suggests the road is paved and in reasonable condition, likely sufficient for construction traffic, including standard semi-trailers carrying battery containers and other components. However, a formal road survey or confirmation from the Oxford Department of Public Works is recommended to verify weight limits and suitability for heavy-haul loads like the main power transformer.
• Terrain Characteristics: As is typical for Central Massachusetts, the 12.58-acre parcel is heavily wooded. Satellite imagery and topographic maps indicate moderately rolling terrain with potential for significant grade changes across the parcel. Extensive tree clearing and civil work, including grading and soil stabilization, will be required. The cost and timeline for this site preparation work could be substantial and will reduce the net buildable area.
• Heavy Equipment Access: Access from Millbury Road onto the site itself will require the construction of a new permanent access drive. The design must accommodate a wide turning radius for lowboy trailers delivering transformers and containerized BESS units. The feasibility of constructing this entrance will depend on slope, sight lines, and any roadside drainage or wetlands.
• Easement Concerns: While road access is public, a construction and access easement will need to be established across the frontage of the parcel. No other access easement concerns are immediately apparent, but a title search is required to confirm no other encumbrances exist that could restrict access or development.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap and a high-priority risk. Any portion of the site located within a 100-year floodplain (e.g., Zone A, AE) would likely render it undevelopable for critical infrastructure like a BESS or require costly mitigation (e.g., building up pads), which may be impermissible. A FEMA FIRMette review must be conducted immediately.
• Wetlands Presence: The wetlands status is Unknown. Given the undeveloped, wooded nature of the site in this region, there is a high probability of jurisdictional wetlands, streams, or vernal pools being present. Development would be subject to significant setbacks (e.g., 100-foot buffer zones) under the Massachusetts Wetlands Protection Act and the Oxford Wetlands Protection Bylaw, which would severely constrain the buildable area. A desktop screening using MassGIS OLIVER is the immediate next step, to be followed by a formal field delineation by a certified wetland scientist.
• Habitat & Species Risk: The data indicates no designated Critical Habitat. This is a positive finding. However, a check of the MA Natural Heritage & Endangered Species Program (NHESP) database is still required to screen for state-listed rare or endangered species whose presence could trigger further studies and mitigation requirements.
• Brownfield/Superfund Status: The site is not a brownfield. This eliminates potential environmental liability and complex remediation issues. However, it also means the project is ineligible for the 10% IRA Brownfield Adder, which is a financial disadvantage.
• Pipeline Proximity: No major gas pipelines are located nearby, mitigating risks associated with pipeline-related setbacks, safety protocols, and potential co-location conflicts.

3. Grid Infrastructure & Interconnection

• Nearest Substation & POI: The data presents a contradiction. It lists the North Oxford Substation (115 kV) as 2.7 miles away, yet also states "POI Onsite" at an "IX Voltage: 13.2 kV". The "POI Onsite" information is the most critical factor for a distribution-scale project. This implies a 13.2 kV, 3-phase distribution feeder is either on the property or directly adjacent along Millbury Road. This is the site's single greatest asset, as it avoids the multi-million-dollar cost of a new 2.7-mile feeder extension. Verification of this feeder's location, available capacity, and configuration is the highest technical priority.
• Transmission Proximity: A 345 kV transmission line is 0.9 miles away. This is irrelevant for a ≤5MW project, as interconnecting at transmission voltage would be technically and financially infeasible.
• Recommended Interconnection: The project should interconnect directly to the adjacent 13.2 kV distribution feeder, as indicated by the provided data.
• Estimated Cost & Timeline: Assuming the on-site POI is confirmed, interconnection costs would be relatively low for this asset class, likely in the $400,000 to $900,000 range. This would cover switchgear, protection and control systems, a utility-side disconnect, and potential local upgrades (e.g., re-conductoring a short segment). The interconnecting utility is likely National Grid. The Massachusetts interconnection process can be lengthy, with timelines from application submission to Permission to Operate (PTO) often ranging from 18 to 36 months.
• Utility & Feeder: The utility is Requires Verification but is presumed to be National Grid. A formal pre-application report must be filed with the utility to confirm the feeder identification, its thermal capacity, and any known constraints (e.g., high penetration of other DERs).

4. Regulatory & Zoning Analysis

• Authority Having Jurisdiction (AHJ): The Town of Oxford, MA. Permitting will involve the Oxford Planning Board, Zoning Board of Appeals (ZBA), and Conservation