⚡ 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 the property located at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The 12.58-acre parcel presents a mix of significant challenges and a few potential advantages. The primary risks identified are related to restrictive zoning, uncertain and potentially high interconnection costs, and a complete lack of eligibility for IRA/ITC incentive adders. The following sections provide a detailed breakdown of our findings and recommendations.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, which is a publicly maintained road. A preliminary review via satellite imagery indicates Millbury Road is a two-lane, paved local road. This level of access is generally sufficient for construction traffic, including standard trucks and personnel vehicles.

Equipment Delivery: The key challenge will be the delivery of oversized and overweight equipment, such as the main power transformer and containerized battery enclosures. While the road is paved, its width, turning radii at intersections, and any potential weight-limited bridges between the site and major highways must be verified through a formal route survey. Access directly from the road onto the parcel appears feasible, but the driveway entrance would need to be constructed to support heavy loads.

Topography & Buildability: The site is located in Central Massachusetts, a region characterized by rolling hills and potentially rocky soil conditions. Satellite imagery suggests the parcel is heavily wooded with moderate elevation changes. While the data notes "Buildability: OK," this is a preliminary assessment. A formal topographic survey and geotechnical study are essential. Significant grading and tree clearing will be required, increasing site preparation costs. The presence of bedrock near the surface could further complicate foundation work for equipment pads.

Easements: No access easement concerns are immediately apparent given the direct public road frontage. However, a title search is required to identify any existing utility or conservation easements that could encumber the property and restrict the buildable area. An easement will be required from the landowner for the utility interconnection line if it crosses their property to reach the Point of Interconnection (POI).

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical data gap. Development within a Special Flood Hazard Area (e.g., Zone A, AE) would trigger significant design constraints, requiring all equipment to be elevated above the Base Flood Elevation, dramatically increasing civil engineering and construction costs. Development may be prohibited entirely in a floodway. Verification via the FEMA Map Service Center is a priority action item.

Wetlands: The presence of wetlands is "Unknown." Given the wooded nature of the site in Massachusetts, it is highly probable that state or federally jurisdictional wetlands and/or vernal pools are present. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around most wetland resource areas where development is heavily restricted. A formal wetland delineation is required to determine the actual buildable area, which could be substantially less than the total 12.58 acres.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this must be confirmed through a review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or priority habitats are present.

Contamination Status: The site has no known brownfield or superfund sites within a two-mile radius. While this avoids potential remediation liabilities and costs, it also means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a disadvantage for project economics.

Pipeline Proximity: No gas pipelines are located within three miles of the site, eliminating risks associated with pipeline safety setbacks, explosion hazards, and coordination with pipeline operators.

3. Grid Infrastructure & Interconnection

Substation & POI Conflict: There is a critical conflict in the provided data. The nearest substation, North Oxford, is 2.7 miles away, while the "POI Access" is listed as "Onsite." A 2.7-mile line extension for a 13.2 kV distribution feeder would be prohibitively expensive, likely in the $2.5M - $4M range, rendering a ≤5MW project economically unviable. The most optimistic and likely interpretation is that "POI Onsite" refers to an existing 1