⚡ 40 MILLBURY RD

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 covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives to determine project viability.

1. Site Access & Topography

Road Access & Feasibility: 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. However, a formal route survey is required to confirm its ability to accommodate oversized and overweight loads, such as a main power transformer (MPT) and prefabricated battery enclosures. The key concern will be turning radii from main thoroughfares onto Millbury Road and into the site entrance.

Terrain & Buildability: As is typical for Worcester County, the site appears to be heavily wooded with potentially significant topographic relief. Satellite imagery suggests rolling hills. This presents a buildability risk, as extensive tree clearing and civil work (grading, cut-and-fill) would be required to create a level pad for the BESS equipment. This will increase site preparation costs and may trigger additional local review under tree removal or earthwork ordinances. The "Buildable Acres" are currently unknown and must be determined after accounting for topography, environmental setbacks, and zoning setbacks.

Heavy Equipment Access: While the public road seems adequate, access from the road onto the parcel itself is the primary challenge. A new, robust access road will need to be constructed from Millbury Road to the project pad. The design must support the weight of a crane, a fully loaded transformer, and multiple containerized BESS units. The cost of this access road could be substantial depending on the distance and terrain.

Easement Concerns: A new utility easement will be required for the interconnection line, granting the utility 24/7 access. We must also conduct a title search to identify any existing easements (e.g., conservation, drainage, or third-party access) that could encumber the property and restrict the developable area.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is listed as Unknown. This is a critical data gap. A review of the FEMA Flood Insurance Rate Maps (FIRMs) is an immediate next step. If any portion of the planned equipment pad falls within a Special Flood Hazard Area (e.g., Zone A, AE), it would necessitate elevating all equipment above the Base Flood Elevation, adding significant cost and complexity. Siting within a floodway is typically prohibited and would render the site unviable.

Wetlands: The presence of wetlands is Unknown but highly likely given the site's undeveloped, forested nature. Massachusetts has a stringent Wetlands Protection Act, which requires significant buffers (typically 100 feet) from delineated wetland resources. A formal wetland delineation by a certified professional is mandatory. The presence of wetlands could severely constrain the buildable area and potentially trigger a lengthy review process with the Oxford Conservation Commission.

Habitat & Species: The data indicates no designated critical habitat. However, a desktop screening using MassGIS Natural Heritage & Endangered Species Program (NHESP) data is necessary to check for state-listed rare or endangered species. A positive screening could require time-of-year restrictions on construction or further habitat studies.

Brownfield/Superfund Status: The site is not a brownfield, which means it does not qualify for the 10% IRA brownfield tax credit adder. On the positive side, this indicates a lower risk of encountering soil or groundwater contamination, which would require costly remediation and introduce liability.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating concerns related to explosion risk and associated setback requirements.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is National Grid's North Oxford substation, located 2.7 miles away. This is a considerable distance for a new distribution feeder, and the associated cost would likely be prohibitive (potentially $3-5M+). A 345kV transmission line is closer (0.9 miles), but interconnecting a small ≤5MW BESS at transmission voltage is technically and financially infeasible.

Point of Interconnection (POI) & Voltage: The data states "POI Onsite" at 13.2 kV. This is the single most critical assumption to validate. If a 3-phase, 13.2 kV distribution feeder with sufficient thermal and fault-duty capacity truly crosses the property or is adjacent to it, the project's grid access profile improves dramatically. If "POI Onsite" is inaccurate and a 2.7-mile line extension is required, this site is not viable. The interconnecting utility is presumed to be National Grid, which serves Oxford, MA, but this requires verification.

Estimated Costs & Timeline:

• Scenario A (POI is truly Onsite): Interconnection costs could be in the range of $750,000 - $2,000,000 for local poles, re-conductoring, and protection upgrades at the substation.
• Scenario B (New 2.7-mile Feeder Required): Costs would likely exceed $5,000,000, rendering the project uneconomical.

Feeder Configuration: The likely POI would be an overhead 3-phase distribution line. A pre-application report must be filed immediately to confirm the line's voltage, hosting capacity, and whether it is part of a networked system, which can complicate BESS integration.