⚡ 40 MILLBURY RD

MEMORANDUM

TO: Sunland America Corp. Development Team
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for "Project Oxford" (40 Millbury Rd, Oxford, MA)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at 40 Millbury Rd, Oxford, Worcester County, Massachusetts (APN: 16_D03). The 12.58-acre parcel presents a compelling grid access opportunity but faces significant, potentially fatal flaws related to zoning and regulatory approval.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a public, two-lane paved road. Initial desktop review indicates this road is suitable for standard construction traffic, including dump trucks and concrete mixers.

Equipment Delivery: The primary concern for heavy equipment delivery (e.g., multi-ton transformers, 40-foot battery containers) will be the turning radius from Millbury Road onto the site and the on-site access road condition. The parcel is currently undeveloped and heavily wooded. A new access road capable of supporting heavy axle loads (80,000 lbs+) will need to be constructed from Millbury Road to the project pad.

Topography & Site Work: Based on aerial and topographic imagery, the site is characteristic of central Massachusetts: wooded with rolling terrain. Significant tree clearing and grading will be required to create a level pad for the BESS equipment and access road. This will increase site preparation costs and may trigger local tree removal ordinances. The extent of grading will depend on the final project location within the parcel, which will be dictated by environmental and zoning setbacks.

Easements: While primary access is public, a full title report is required to identify any existing utility, conservation, or access easements that may cross the property. Such easements could conflict with the proposed BESS layout and constrain the buildable area.

2. Environmental Constraints

The environmental profile of this site is characterized by significant unknowns that represent a primary project risk.

• FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap. Any designation within a 100-year floodplain (e.g., Zone A or AE) would impose severe design constraints, require elevating all equipment, and could make the project financially or technically infeasible. Immediate verification using the FEMA Flood Map Service Center is required.
• Wetlands: The presence of wetlands is Unknown but highly likely given the site is undeveloped and wooded in Massachusetts. The Massachusetts Wetlands Protection Act imposes a 100-foot buffer zone around delineated wetlands, within which development is heavily restricted. A formal wetland delineation by a certified professional will be a mandatory and early-stage due diligence item to determine the actual buildable area.
• Critical Habitat / Species: The data indicates no critical habitats or protected areas on site, which is a positive initial finding. However, a Phase I Environmental Site Assessment (ESA) should be conducted to confirm the absence of state-listed endangered or threatened species whose habitats could be impacted by development.
• Brownfield/Superfund Status: The site is not a brownfield, and no superfund sites are located nearby. While this mitigates environmental liability risk, it also means the project is ineligible for the 10% IRA Brownfield tax credit adder, a notable economic disadvantage.
• Pipeline Proximity: No gas transmission pipelines are located within three miles, mitigating risks associated with pipeline-related safety setbacks and potential explosions.

3. Grid Infrastructure & Interconnection

This site's primary advantage is its potential for a low-cost distribution-level interconnection.

• Point of Interconnection (POI): The data indicates a "POI Onsite" at a voltage of 13.2 kV. This is an ideal distribution voltage for a ≤5MW BESS project. This suggests a 3-phase feeder from the interconnecting utility (presumed to be National Grid) runs along the property frontage on Millbury Road. This is the single most attractive feature of the site and must be verified immediately.
• Nearest Substation: The North Oxford substation is 2.7 miles away. While this substation has a 115 kV bus, a direct interconnection there would be cost-prohibitive. The 13.2 kV feeder likely originates from this substation, and its distance suggests that voltage drop and capacity could be concerns.
• Transmission Lines: A