⚡ 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 analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The property has frontage on Millbury Road, which is designated as a public road. A preliminary review of aerial imagery indicates Millbury Road is a two-lane, paved road, which should be sufficient for construction traffic, including standard trucks and concrete mixers. However, a formal road survey would be required to confirm weight limits and the condition of any bridges or culverts along the primary transport route.

Terrain Characteristics: As is typical for central Massachusetts, the 12.58-acre parcel appears to be heavily wooded with potentially significant topographic relief. Satellite imagery suggests rolling hills. This will likely necessitate substantial clearing, grubbing, and grading to create a level pad for the BESS equipment, increasing site preparation costs. The exact buildable area is currently unknown and will be heavily influenced by the site's slope and environmental constraints.

Heavy Equipment Access: While the public road is adequate, access from the road onto the parcel itself is a concern. A new curb cut and a dedicated gravel or paved access road will need to be constructed from Millbury Road to the project pad. The design of this road must accommodate low-boy trailers for delivering heavy equipment like the main power transformer and containerized battery enclosures. The turning radii from Millbury Road onto the new access drive must be carefully engineered.

Easement Concerns: No specific access easement concerns are noted, as the property appears to have direct public road frontage. However, a title search is required to identify any existing utility easements (e.g., for the onsite distribution line) or other encumbrances that could restrict the placement of equipment or the new access road.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This represents a critical data gap. Any portion of the site located within a 100-year floodplain (Zone A or AE) would be functionally unbuildable for critical infrastructure like a BESS without extremely costly mitigation. A priority next step is to review FEMA Flood Insurance Rate Maps (FIRMs) for this parcel.

Wetlands: The presence of wetlands is Unknown. Given the wooded nature of the site in this region, there is a high probability of state-jurisdictional (MA DEP) and/or federally-jurisdictional wetlands, vernal pools, or intermittent streams. Massachusetts has stringent wetlands protection regulations, including significant buffer zones (typically 100 feet) where development is heavily restricted. A formal wetlands delineation is an absolute necessity and could severely limit the buildable acreage.

Critical Habitat / Endangered Species: The initial screening indicates no critical habitat or protected areas on site, which is a positive finding. However, we recommend a desktop screening using the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to confirm there are no state-listed rare species habitats that could trigger a lengthy review process.

Brownfield/Superfund Status: The site is not a brownfield, and there are no superfund sites within a two-mile radius. While this minimizes environmental liability risk, it also means the project is not eligible for the 10% IRA Brownfield ITC adder, which is a financial disadvantage.

Pipeline Proximity: No gas transmission pipelines are located within three miles of the site. This is a significant safety and permitting advantage, eliminating the need for complex pipeline proximity risk assessments and consultations.

3. Grid Infrastructure & Interconnection

Grid Proximity: The site's primary strength is its grid access. The data indicates a Point of Interconnection (POI) is Onsite at a voltage of 13.2 kV. This implies a 3-phase distribution feeder, operated by National Grid (the primary utility in Oxford, MA), runs along Millbury Road or directly across the property. This is an ideal scenario for a distribution-scale BESS, as it eliminates the need for a costly and time-consuming line extension.

Substation & Transmission: The nearest substation, North Oxford, is 2.7 miles away. While this substation (with a 115 kV bus) is too distant for a direct connection, the onsite 13.2 kV feeder likely originates from it. The proximity of a 345 kV transmission line (0.9 miles) is irrelevant for a project of this scale, as a transmission-level interconnection would be economically and technically infeasible.

Interconnection Recommendation & Cost: The recommended and only feasible interconnection is at the onsite 13.2 kV distribution line. With the POI onsite, interconnection costs should be on the lower end of the spectrum, estimated in the $350,000 to $850,000 range. This would primarily cover the utility-required protection and communication studies, a three-phase recloser/interrupter, metering equipment, and utility oversight. This is a significant cost saving compared to projects requiring miles of new line construction.

Utility Process: Interconnecting with National Grid in Massachusetts involves a formal application process through the ISO-