⚡ 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 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 12.58-acre parcel presents a mix of significant advantages and critical risks. The primary positive attribute is the reported onsite Point of Interconnection (POI) at a favorable distribution voltage. However, this is severely counterbalanced by highly problematic zoning, a complete lack of IRA incentive adders, and major unknown environmental constraints. The following detailed analysis outlines these factors to inform our go/no-go decision.

1. Site Access & Topography

• Road Access & Feasibility: The site benefits from access via Millbury Road, a publicly maintained road. A desktop review indicates Millbury Road is a two-lane local road. While public access is a positive, a physical inspection is required to assess its condition, width, turning radii, and any weight-limited bridges or culverts between the site and major state highways (like I-395 or Route 20) that would be used for equipment delivery.
• Terrain Characteristics: As is typical for Worcester County, the terrain is likely to be rolling hills with moderate slopes. A formal topographical survey is essential. Significant grading could be required to create a level pad for the BESS containers, switchgear, and transformer, which would increase civil engineering costs. The forested nature of the lot will also require substantial clearing and grubbing.
• Heavy Equipment Access: The primary concern for delivering heavy equipment, such as a 50-ton main power transformer and 30-ton battery containers, is the final approach from Millbury Road onto the site itself. A new, robust construction entrance capable of handling heavy truck loads will need to be engineered and permitted. The 12.58-acre parcel size provides ample space for staging and construction laydown, assuming environmental constraints do not limit the usable area.
• Easement Concerns: Requires Verification. A full title report must be commissioned to identify any existing utility, access, or conservation easements that may encumber the property. An unseen pipeline or drainage easement could bisect the most logical buildable area, severely impacting the project layout.

2. Environmental Constraints

• FEMA Flood Zone: Requires Verification. The FEMA flood zone designation is currently unknown. This is a critical data gap. Any portion of the site within a 100-year (AE) or 500-year (X-shaded) flood zone would likely be unusable for critical infrastructure like BESS, or would require costly mitigation measures such as elevating equipment pads. A FEMA FIRMette map must be generated immediately.
• Wetlands Presence: Requires Verification. The presence and extent of wetlands are unknown. Massachusetts has extremely stringent wetland protection regulations under the Massachusetts Wetlands Protection Act (WPA). Given the site's undeveloped and forested nature, the presence of wetlands is highly probable. A desktop screening using MassGIS OLIVER is the first step, but a formal wetland delineation by a certified professional will be non-negotiable. This is the single most important factor in determining the actual "Buildable Acres" and could be a fatal flaw.
• Critical Habitat / Endangered Species: The initial screen shows no critical habitat on site, which is a positive. However, we must verify this by cross-referencing the site location with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or priority habitats are present, which could trigger lengthy and complex reviews.
• Brownfield/Superfund Status: The site is not a brownfield. While this avoids potential cleanup liabilities and complexities, it also means the project is ineligible for the 10% IRA Brownfield Adder, a significant financial disadvantage compared to competing projects.
• Pipeline Proximity: The absence of major gas pipelines within a 3-mile radius is a significant safety and layout advantage, eliminating the need for specialized setbacks and safety consultations.

3. Grid Infrastructure & Interconnection

• Substation & Transmission: The nearest substation, North Oxford, is 2.7 miles away and has a max voltage of 115 kV. A 345 kV transmission line is closer at 0.9 miles. However, for a distribution-scale project (≤5MW), interconnecting at transmission voltage would be prohibitively expensive and complex.
• Point of Interconnection (POI): The most compelling attribute of this site is the reported "POI Onsite" at an "IX Voltage: 13.2 kV". This strongly implies that a 3-phase, 13.2 kV distribution feeder, operated by National Grid (the likely utility for this area), runs along the property frontage on Millbury Road. This is the ideal scenario for a project of this scale.
• Recommended Interconnection: The clear recommendation is to pursue a 13.2 kV distribution-level interconnection by tapping the adjacent feeder. This avoids the high cost of building a new 2.7-mile line to the substation.
• Estimated Cost & Timeline: Assuming the onsite feeder has sufficient capacity, the direct interconnection cost could be in the $750,000 to $2,000,000