⚡ 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 evaluates the site's suitability based on key development criteria, identifies significant risks, and recommends a path forward.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a publicly maintained, two-lane paved road. Initial desktop review indicates this road is suitable for standard construction traffic.

Equipment Delivery: While the public road is adequate, the primary challenge will be accessing the developable area within the 12.58-acre parcel. The site is heavily wooded with no existing driveway or access road from Millbury Road. A new, engineered access road will need to be constructed, requiring significant tree clearing, grading, and potentially culverts for drainage. The feasibility of delivering heavy equipment, including a 30-50 ton transformer and 20-30 ton battery containers, is contingent on the design and construction of this new access road. A thorough topographic survey is required to assess slopes and determine the optimal route.

Terrain Characteristics: Based on aerial imagery and regional topography, the site is presumed to have moderately rolling terrain, characteristic of Central Massachusetts. The heavily forested nature will necessitate extensive clearing and grubbing, followed by significant civil work to create a level pad for the BESS equipment. These site work costs are expected to be substantial.

Easement Concerns: While direct access from a public road mitigates the need for an off-site access easement, a title search is required to identify any existing utility, conservation, or other easements that may encumber the property and restrict the placement of the BESS facility and its access road.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently Unknown. This is a critical data gap. Any portion of the site located within a 100-year floodplain (Zone A/AE) would be functionally undevelopable for a BESS without costly mitigation measures like elevating all equipment, which could render the project uneconomical. Immediate verification via FEMA's Flood Insurance Rate Map (FIRM) is necessary.

Wetlands: The presence of wetlands is Unknown but is considered highly likely given the undeveloped, forested nature of the parcel in this region. Development will be subject to the Massachusetts Wetlands Protection Act and review by the Oxford Conservation Commission. A formal wetlands delineation will be required to identify jurisdictional areas and determine applicable buffer zones (typically 100 feet), which will directly impact the buildable acreage. This is a significant potential constraint.

Habitat & Species: The data indicates no critical habitat or protected areas on site. However, this must be verified through a desktop screening with the MA Natural Heritage & Endangered Species Program (NHESP) to ensure no state-listed rare species or priority habitats are present.

Contamination Status: The site has no known brownfield or superfund sites within a two-mile radius. While this minimizes environmental liability risk, it also means the project is ineligible for the 10% IRA Brownfield ITC adder, a competitive disadvantage.

Pipeline Proximity: No gas pipelines are located within three miles, which is a positive finding that eliminates a major safety and setback risk.

3. Grid Infrastructure & Interconnection

Grid Proximity: The data presents a critical contradiction. It lists the nearest substation (North Oxford) as 2.7 miles away, yet also states "POI Onsite" with an interconnection voltage of 13.2 kV.

• Scenario A (Optimistic - POI Onsite): If a 3-phase, 13.2 kV distribution feeder from National Grid (the likely utility) is truly present on-site or along the property's road frontage, this is a major advantage. The feeder configuration and available hosting capacity must be verified immediately.
• Scenario B (Pessimistic - No Onsite POI): If the nearest 13.2 kV feeder is 2.7 miles away at the substation, the project is likely non-viable. The cost to construct a new 2.7-mile dedicated feeder would be in the millions of dollars ($3M - $6M+), far exceeding the budget for a ≤5MW BESS project.

Interconnection Details:

• Recommended Voltage: 13.2 kV (distribution) is appropriate for a project of this scale. Interconnecting to the nearby 345kV transmission line is not financially feasible.
• Estimated Cost: Assuming Scenario A (POI Onsite), interconnection costs could range from $500,000 to $1,500,000, covering the switchgear, transformer, line tap, and minor utility upgrades. In Scenario B, costs would be prohibitive.
• Utility & Timeline: The interconnecting utility is likely National Grid. The Massachusetts interconnection process (governed by DPU) can be lengthy. From application submission to Commercial Operation Date (COD), a timeline of 24-36 months is a realistic estimate, assuming the project passes the system impact studies.

4. Regulatory & Zoning Analysis

Authority Having