⚡ 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, for the potential development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS). The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access: The site has frontage on Millbury Road, a publicly maintained, two-lane local road. Initial desktop review indicates this road is paved and appears suitable for standard construction traffic. However, a formal route survey is required to confirm the absence of low-clearance bridges, sharp turns, or weight-limited infrastructure between the site and major state highways that could impede the delivery of oversized/overweight equipment like transformers or battery containers.

Topography & Site Conditions: Based on aerial and topographic imagery, the 12.58-acre parcel is heavily wooded and appears to have moderate elevation changes, consistent with the terrain of central Massachusetts. Significant tree clearing and grading will be required to establish a level pad for the BESS compound, switchgear, and access roads. This will increase site preparation costs and may trigger local tree removal ordinances. The "Buildability: OK" assessment is considered preliminary until a geotechnical survey and detailed civil engineering review are completed.

Heavy Equipment Feasibility: Access for heavy equipment is considered feasible from the public road, but internal site access will need to be constructed. The primary challenge will be the cost associated with clearing and grading the undeveloped, forested land.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests an existing utility easement for a distribution line either crosses the property or runs along its road frontage. A full title commitment is an immediate next step to identify the location, width, and restrictions of this and any other easements (e.g., access, conservation) that could limit the placement of the BESS facility.

2. Environmental Constraints

FEMA Flood Zone: Requires Verification. A preliminary check using the FEMA Flood Map Service Center indicates the parcel is located entirely within Zone X, an area of minimal flood hazard. This is a significant positive, as it should preclude the need for costly flood mitigation measures or elevated construction. This must be confirmed with a formal report.

Wetlands: Requires Verification. The provided data lists wetlands as "Unknown," which presents a material risk. A review of the US FWS National Wetlands Inventory and MassGIS data layers indicates the potential presence of forested and riverine wetlands associated with a small stream system on or near the property. Development in Massachusetts is subject to the stringent Massachusetts Wetlands Protection Act, which mandates significant buffer zones (typically 100 feet) and a complex permitting process through the local Conservation Commission. A formal wetland delineation by a certified professional is a critical, immediate step to determine the actual buildable area, which may be substantially less than the total 12.58 acres.

Habitat & Species: While the data indicates no critical habitat, this must be verified via the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database. The heavily wooded nature of the site increases the risk that state-listed rare species or their habitats could be present, potentially triggering time-of-year restrictions on construction or other mitigation requirements.

Brownfield/Superfund Status: The site is not a brownfield. This simplifies the environmental liability assessment but makes the project ineligible for the 10% IRA Brownfield Adder, a notable economic disadvantage.

Pipeline Proximity: No gas transmission pipelines are located near the site, eliminating a key safety and setback concern.

3. Grid Infrastructure & Interconnection

Grid Proximity & POI: This is the site's strongest attribute. The "POI Onsite" designation at a 13.2 kV distribution voltage is ideal for a ≤5MW project. This implies a three-phase distribution feeder, likely operated by National Grid (Requires Verification), is directly on or adjacent to the property. This eliminates the need for a costly and time-consuming line extension from the substation.

Substation & Feeder: The nearest substation, North Oxford, is 2.7 miles away. While the physical distance is now less critical for line extension costs, it remains relevant for the electrical system impact studies. The capacity of the specific 13.2 kV feeder that constitutes the POI is a critical unknown. We must immediately request feeder load data from the utility to assess its ability to handle the bi-directional power flow of a 5MW BESS without requiring major substation upgrades.

Interconnection