⚡ 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 potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS) at the subject property. The analysis identifies significant risks related to zoning, environmental constraints, and interconnection that must be addressed before committing further capital. While the site has a potentially game-changing feature in its reported on-site Point of Interconnection (POI), this is unverified and offset by numerous challenges.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a public, two-lane local road. A preliminary review of aerial imagery indicates this road appears adequate for standard construction traffic. However, a formal transportation study will be required to confirm its suitability for oversized/overweight deliveries, such as the main power transformer and battery containers. Turning radii from Millbury Road onto the site will need to be carefully engineered.

Topography & Site Conditions: The 12.58-acre parcel is currently undeveloped, heavily wooded, and appears to have rolling terrain typical of central Massachusetts. Significant tree clearing, grubbing, and grading will be required, adding considerable cost and time to the site preparation phase. A formal topographic survey is essential to quantify the extent of earthwork needed to create a level pad for the BESS equipment. The forested nature also increases the risk of encountering ledge or unsuitable soils.

Heavy Equipment Feasibility: Access for heavy equipment is feasible from the public road, but a new, robust access road will need to be constructed onto the property. The design must accommodate low-boy trailers and heavy cranes. The cost of this access road, including any necessary culverts or drainage, must be factored into the project budget.

Easement Concerns: Requires Verification. A preliminary title report must be ordered immediately to identify any existing utility, access, or conservation easements that may encumber the property. An unknown easement could conflict with the proposed equipment layout and render the site unusable.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap. Any portion of the site located within a Special Flood Hazard Area (SFHA), such as Zone A or AE, would be subject to significant development restrictions and would likely be undevelopable for critical infrastructure like a BESS. This must be investigated via FEMA's Map Service Center as a first step.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly probable given the site's undeveloped, forested condition in this region. Development in Massachusetts is governed by the stringent Massachusetts Wetlands Protection Act and administered locally by the Oxford Conservation Commission. Any state or federally delineated wetlands will trigger substantial buffer zones (typically 100 feet or more), which could severely constrain or eliminate the buildable area. A formal wetlands delineation is a critical and immediate next step.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a positive finding. This should be confirmed via a query of the MA Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-level concerns exist.

Site Contamination: The absence of any nearby brownfield or superfund sites is a net positive. It eliminates risks of environmental liability and costly remediation. However, it also means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a minor financial disadvantage.

Pipeline Proximity: The lack of any major gas pipelines within three miles is a significant safety and permitting advantage, eliminating the need for specialized impact studies and consultations.

3. Grid Infrastructure & Interconnection

Grid Proximity: