⚡ 40 MILLBURY RD

CONFIDENTIAL - BESS SITE DILIGENCE ANALYSIS

Prepared for: Sunland America Corp. Development Committee

Property: 40 MILLBURY RD, Oxford, Worcester County, MA

APN: 16_D03

Site Size: 12.58 Acres

Analysis Date: October 26, 2023

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, which is a public, two-lane local road. Initial review via satellite imagery indicates the road is paved and appears suitable for standard construction traffic. However, a formal road survey should be conducted to confirm weight limits and turning radii for oversized loads, such as a main power transformer (MPT) and battery containers.

Topography & Site Conditions: The site is located in central Massachusetts, a region characterized by rolling hills and dense forestation. Satellite imagery confirms the parcel is heavily wooded and appears to have moderate to significant topographic relief. This presents a buildability challenge, as extensive tree clearing, grubbing, and grading will be required. These activities will substantially increase site preparation costs and may trigger additional environmental review or stormwater management requirements. The "Buildable Acres" are currently unknown and will be significantly less than the total 12.58 acres after accounting for topography, environmental setbacks, and zoning setbacks.

Heavy Equipment Feasibility: Access from Millbury Road is likely feasible, but an internal access road, constructed with an appropriate gravel base to handle crane and delivery vehicle loads, will need to be built. The primary concern is the site's internal slope; a geotechnical study is essential to assess soil stability and determine the extent of grading needed to create a level pad for the BESS equipment.

Easements: The data indicates "POI Onsite," which strongly suggests an existing utility easement crosses the property. A full title search is required to identify the location, width, and restrictions of this and any other easements (e.g., access, conservation). The existing utility easement could be advantageous for interconnection but may also constrain the site layout.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is listed as "Unknown." This is a critical data gap and a high-priority risk. Development within a Special Flood Hazard Area (e.g., Zone AE) would require all equipment to be elevated above the Base Flood Elevation, dramatically increasing structural costs and potentially rendering the project uneconomical. Immediate review of FEMA Flood Insurance Rate Maps (FIRMs) is required.

Wetlands: The presence of wetlands is "Unknown." Given the forested, undeveloped nature of the site in Massachusetts, there is a high probability of state or federally regulated wetlands, streams, or vernal pools. Massachusetts has one of the strictest wetlands protection acts in the country, which enforces a 100-foot buffer zone where activity is heavily restricted. The presence of wetlands could severely reduce or eliminate the buildable area. A formal wetland delineation by a certified professional is a critical and immediate next step.

Critical Habitat / Species: The data indicates no critical habitat on site. This is a positive finding. However, as a standard diligence practice, a desktop review using the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database should be performed to ensure no state-listed species or priority habitats are impacted, which could trigger a lengthy review process.

Brownfield/Superfund Status: The site is not a brownfield. While this avoids environmental liability and cleanup costs, it also means the project is ineligible for the 10% IRA Brownfield Adder, which is a significant disadvantage to project economics.

Other Considerations: The site is not within the Chesapeake Bay Critical Area. No pipelines or gas wells are in the immediate vicinity, which minimizes safety and setback concerns from those sources.

3. Grid Infrastructure & Interconnection

Substation & Feeder: The nearest substation, North Oxford, is 2.7 miles away. For a