⚡ 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 a potential distribution-scale Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property has frontage on Millbury Road, which is a public, two-lane paved road. This provides direct and seemingly straightforward access for personnel and standard construction vehicles. Initial review of aerial imagery suggests the road is suitable for deliveries of major equipment, including battery containers, inverters, and the main power transformer.

Terrain & Buildability: The parcel is currently undeveloped, heavily wooded, and appears to have moderate topographical variation, which is characteristic of this region in Central Massachusetts. The "Buildability: OK" designation in the source data is optimistic and requires significant verification. Substantial tree clearing, grading, and site preparation will be necessary, increasing civil engineering costs and potentially impacting stormwater management design. The total 12.58 acres offer ample space, but the actual buildable envelope is unknown and will be constrained by topography, environmental setbacks, and zoning requirements.

Heavy Equipment Access: While the public road is adequate, access onto the parcel itself will require construction of a new, stabilized access drive with an appropriate turning radius for low-boy trailers carrying transformers and containerized BESS units. The cost for this entrance and an internal road network should be factored into the project budget.

Easement Concerns: Requires Verification. No easements are noted in the provided data. A full title search is a critical next step to identify any existing utility, access, or conservation easements that could encumber the property and restrict the BESS layout.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is unknown. This is a critical data gap. Any location within a Special Flood Hazard Area (e.g., Zone A, AE) would likely render the site undevelopable for critical infrastructure like a BESS or require costly mitigation measures such as elevating all equipment above the Base Flood Elevation.

Wetlands: Requires Verification. The presence of wetlands is unknown but highly probable on an undeveloped, wooded parcel in Massachusetts. Development will be subject to the Massachusetts Wetlands Protection Act and local bylaws administered by the Oxford Conservation Commission. A formal wetlands delineation will be required to determine the extent of jurisdictional areas and their associated buffer zones (typically 100 feet), which will directly impact the buildable area.

Habitat & Species: The data indicates no critical habitat or protected areas on site, which is a significant positive. This should be confirmed with a preliminary screening using the US Fish & Wildlife Service's IPaC tool and a review of the MA Natural Heritage & Endangered Species Program (NHESP) database.

Brownfield/Superfund Status: The site is not a brownfield. While this avoids potential contamination risks and costly remediation, it also means the project is not eligible for the 10% IRA Brownfield ITC adder, a notable financial disadvantage.

Pipeline Proximity: No major gas pipelines are located within three miles, mitigating risks associated with pipeline-related safety setbacks and potential operational constraints.

3. Grid Infrastructure & Interconnection

Substation & POI Analysis: There is a critical conflict in the provided data. The nearest substation, North Oxford, is 2.7 miles away, yet the data also states "POI Onsite" at an interconnection voltage of 13.2 kV. A 2.7-mile, 3-phase distribution line extension would cost an estimated $1.5M - $3M, making a ≤5MW project financially non-viable. The working assumption, which requires immediate verification, is that a 13.2 kV distribution feeder, originating from the North Oxford substation, runs along the property's frontage on Millbury Road. This would be the Point of Interconnection (POI).

Transmission Lines: A 345 kV transmission line is located 0.9 miles away. This is not a viable interconnection point for a distribution-scale project due to the extreme cost and complexity of a transmission-level tap.

Interconnection Voltage & Cost: The proposed 13.2 kV is a standard distribution voltage. Assuming the feeder is on-site, interconnection costs would be primarily for switchgear, protection and control systems, and potential utility upgrades to the local feeder. A preliminary cost estimate for this scope is $400,000 - $900,000. However, the capacity of this rural feeder is a major unknown and could be a fatal flaw. It may not have the thermal capacity or fault duty to accommodate a 5 MW injection without extensive and costly upgrades.

Utility & Process: The interconnecting utility is likely National Grid. The Massachusetts interconnection process can be lengthy, with timelines of 18-36 months from application submission to Commercial Operation Date (