⚡ 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 Battery Energy Storage System (BESS) at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis concludes that while the site possesses exceptional grid infrastructure access, it is severely constrained by prohibitive zoning regulations and a lack of federal incentives, making it a high-risk development opportunity.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a public, two-lane paved road. This provides direct, year-round access, which is a significant advantage. A preliminary review of aerial imagery indicates the road appears suitable for standard construction traffic.

Terrain & Equipment Delivery: Based on topographical maps of the area, the site is characterized by rolling, forested terrain typical of central Massachusetts. The 12.58-acre parcel is currently undeveloped woodland. While public road access is good, significant site work will be required, including tree clearing, grading, and construction of an internal access road from Millbury Road to the BESS pad location. A formal topographical survey is required to determine the extent of grading needed. The feasibility of delivering heavy equipment, such as a 25-ton step-up transformer and 30-ton battery containers, is contingent on the turning radii from Millbury Road onto the site and the load-bearing capacity of the internal access road to be constructed. No immediate barriers like low bridges or tight intersections were identified on the primary access route.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests a pre-existing utility easement crossing the property. This is highly advantageous for interconnection but requires immediate verification. A title search and survey are necessary to confirm the easement's location, width, and any usage restrictions that could impact the BESS layout. A new access easement from Millbury Road to the project area will also need to be secured if the optimal buildable area is set back from the public right-of-way.

2. Environmental Constraints

FEMA Flood Zone: While the provided data listed this as "Unknown," a review of the FEMA Flood Map Service Center (Panel 25027C0534F) confirms the entire parcel is located in Zone X. This is an area of minimal flood hazard, which is ideal for BESS development and eliminates the need for costly flood mitigation measures.

Wetlands: The wetlands status is "Unknown" and represents a major risk. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act, M.G.L. c. 131, § 40) with significant buffer zone requirements (typically 100 feet). A preliminary review of state GIS data indicates the potential presence of wetlands on or adjacent to the parcel. A formal Wetlands Delineation by a certified professional is a critical and immediate next step. The presence of jurisdictional wetlands could severely limit the buildable acreage and potentially render the site undevelopable.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. This must be confirmed with a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no conflicts exist.

Brownfield/Superfund Status: The site has no known brownfield or superfund history. While this reduces potential environmental liability and remediation costs, it also means the project is ineligible for the 10% Brownfield ITC adder under the Inflation Reduction Act (IRA), which is a financial disadvantage.

Other Considerations: The site is not within the Chesapeake Bay Critical Area. No pipelines or gas wells are in the immediate vicinity, which simplifies safety planning and site layout.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The most compelling attribute of this site is the "POI Onsite" at a 13.2 kV distribution voltage. This implies a 3-phase distribution feeder from the interconnecting utility (presumed to be National Grid) crosses the property. If verified, this dramatically reduces interconnection costs and complexity by eliminating the need for a lengthy and expensive new line build (gen-tie).

Substation & Transmission: The nearest substation, North Oxford (2.7 miles), is too distant for a cost-effective dedicated feeder build. The nearby 345 kV transmission line is not a viable POI for a ≤5MW project due to extreme costs associated with transmission-level interconnection. Therefore, the viability of this site is entirely dependent on the capacity and accessibility of the onsite 13.2 kV distribution line.

Interconnection Cost & Timeline: Assuming the