⚡ 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 Rd, Oxford, MA. The analysis evaluates the site's suitability based on key development criteria, including physical characteristics, environmental constraints, grid access, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, which is a public, two-lane local road. Initial desktop review indicates this road is paved and appears suitable for standard construction traffic. However, a formal road survey will be required to confirm weight limits and turning radii for the delivery of heavy equipment, such as a main power transformer and containerized BESS units.

Topography & Equipment Feasibility: The site is currently undeveloped and heavily wooded, with terrain characteristic of central Massachusetts, featuring rolling hills. A formal topographical survey is a critical next step. Significant tree clearing and grading will be required to create a level pad for the BESS compound, switchgear, and access roads. While access from the public road to the property boundary is straightforward, constructing a stable, all-weather internal access road capable of supporting a 100-ton crane and fully loaded tractor-trailers will be a notable site work cost.

Easements: The data indicates "POI Onsite," which strongly suggests a pre-existing utility easement crossing the property. This is a significant advantage for grid connection but requires careful review. A title search is mandatory to identify the easement's exact location, width, and any usage restrictions that could conflict with BESS placement. We must also verify the existence and terms of any other access, drainage, or conservation easements that could encumber the parcel and reduce the buildable area.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The status for both FEMA flood zone and wetlands is currently Unknown. These are critical, potentially fatal-flaw data gaps. Massachusetts has stringent environmental regulations, particularly the Wetlands Protection Act. Given the site's undeveloped and wooded nature, the presence of state or federally regulated wetlands is highly probable. A wetlands delineation must be performed immediately to determine the buildable envelope, as 100-foot buffer zones are common and can severely restrict development. Similarly, a FEMA Flood Insurance Rate Map (FIRM) review is needed to ensure the project is sited in Zone X (minimal risk). Siting in a Special Flood Hazard Area (e.g., Zone A) would add substantial cost and complexity.

Habitat & Contamination: The site shows no signs of being within a designated critical habitat, protected area, or near a brownfield/superfund site. This is positive, as it reduces the risk of endangered species conflicts and environmental remediation liabilities. However, the absence of brownfield status means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a financial disadvantage. A Phase I Environmental Site Assessment (ESA) is still recommended to formally document the site's clean history for financing and permitting purposes.

Other Constraints: The site is not within the Chesapeake Bay Critical Area (N/A for Massachusetts). The absence of pipelines or gas wells within several miles is a significant safety and layout advantage, eliminating concerns about explosion risk and associated setbacks.

3. Grid Infrastructure & Interconnection

Point of Interconnection (POI): The site's most compelling feature is the "POI Onsite" at a 13.2 kV distribution voltage. This is an ideal scenario for a ≤5MW project, potentially saving millions of dollars and years of development time compared to a site requiring a lengthy line extension (gen-tie). The likely infrastructure is a 3-phase overhead distribution feeder running along Millbury Road or through an existing easement on the property.

Substation & Utility: The nearest substation, North Oxford (2.7 miles away), is less relevant for the physical interconnection but is the source of the feeder. The key factor is the available hosting capacity on the specific 13.2 kV circuit serving the site. The interconnecting utility is not named but is almost certainly National Grid, the incumbent provider in Oxford. National Grid's interconnection queue