⚡ 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 (≤5MW) Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis covers key development pillars including site access, environmental constraints, grid infrastructure, regulatory hurdles, and federal incentives. While the site possesses a potentially significant advantage with an on-site Point of Interconnection (POI), this is heavily outweighed by substantial zoning, environmental, and financial incentive challenges.

1. Site Access & Topography

• Road Access & Feasibility: The property has frontage on Millbury Road, a public, two-lane local road. Initial desktop review indicates this road is paved and appears suitable for standard construction traffic. However, a formal route survey is required to confirm the absence of low-clearance bridges, sharp turns, or seasonal weight restrictions that could impede the delivery of heavy equipment like transformers, switchgear, and containerized battery enclosures.
• Terrain & Site Preparation: Satellite imagery shows the 12.58-acre parcel is heavily wooded and appears to have some moderate elevation changes, which is typical for this region of central Massachusetts. Significant tree clearing, grading, and earthwork will be required to create a level pad for the BESS compound. This will increase site preparation costs and may trigger additional scrutiny under local tree removal or earthwork bylaws. The "Buildable Acres" are currently unknown and must be determined after accounting for environmental and zoning setbacks.
• Equipment Access: Access for heavy equipment from Millbury Road onto the project site itself is feasible but will require the construction of a new, engineered access road. The cost and design of this road will depend on the final BESS location on the parcel, topography, and any required wetland crossings.
• Easement Concerns: A formal access easement will need to be secured if the optimal buildable area is set back significantly from the public road frontage. A title search and ALTA survey are required to identify any existing utility or access easements that may encumber the property and conflict with development.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap and a potential fatal flaw. A desktop review using FEMA's Flood Insurance Rate Map (FIRM) database must be conducted immediately. If any portion of the planned equipment pad falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would necessitate elevating all equipment, significantly increasing costs and potentially making the project uninsurable or un-financeable.
• Wetlands: The presence of wetlands is Unknown. Given the wooded nature of the site in Massachusetts, the presence of state-jurisdictional wetlands is highly probable. Massachusetts has a stringent Wetlands Protection Act, which establishes a 100-foot buffer zone around delineated wetlands where development is heavily restricted. A formal wetland delineation by a certified professional is an urgent next step. The presence of significant wetlands could severely limit the buildable area and potentially render the site undevelopable.
• Critical Habitat / Species: The data indicates no known critical habitat on site. However, this must be verified through a desktop screening of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database. If the site falls within a Priority Habitat, consultations and potentially time-of-year restrictions on construction could be required.
• Brownfield/Superfund Status: The site is not a brownfield. While this avoids potential environmental liability, it also means the project is not eligible for the 10% IRA Brownfield ITC adder, which is a significant financial disadvantage.
• Pipeline Proximity: No gas transmission pipelines are located in the immediate vicinity, which is a positive from a safety and risk perspective.

3. Grid Infrastructure & Interconnection

• Substation & Feeder: The nearest substation, North Oxford, is 2.7 miles away. For a distribution-scale project, this distance confirms that the interconnection will not be at the substation but rather on a local distribution feeder. The most promising data point for this site is "POI Onsite" at a voltage of 13.2 kV. This suggests a three-phase distribution line runs along the property's road frontage or through the parcel via an easement. This is a major advantage, as it eliminates the cost of a long, dedicated line extension (gen-tie).
• Interconnection Voltage & Cost: The 13.2 kV distribution voltage is ideal for a ≤5MW BESS project. Interconnection costs will primarily consist of protection and control upgrades at the feeder level, a recloser, and metering equipment. Assuming the feeder has sufficient capacity, costs could be in the range of $750,000 to $2,000,000. However, the feeder's distance from the substation raises the risk of thermal or voltage constraints, which could trigger more extensive and costly system upgrades.
• Utility & Process: The interconnecting utility (likely National Grid or Eversource) must be confirmed. The project will follow the Massachusetts Department of Public Utilities (DPU) standardized interconnection process. Queue times in Massachusetts are notoriously long, and the full study process (Feasibility, System