⚡ 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 potential acquisition and development of a Battery Energy Storage System (BESS) project at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, grid infrastructure, environmental and regulatory constraints, and financial incentives.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a public, two-lane paved road. A preliminary review of aerial imagery indicates this road is sufficient for standard construction traffic. However, a formal transportation study or consultation with the local Department of Public Works would be required to confirm its suitability for oversized/overweight loads associated with heavy equipment delivery, such as transformers and battery containers. The feasibility of creating a new curb cut and construction entrance will need to be assessed during the permitting process.

Topography & Equipment Access: The site is currently undeveloped and appears heavily wooded with moderate elevation changes typical of central Massachusetts. Significant tree clearing and grading will be required to create a level pad for the BESS compound, switchgear, and access roads. This will increase civil engineering and construction costs. While road access to the parcel boundary is good, the internal topography presents a buildability challenge. A detailed geotechnical and topographical survey is essential to determine the extent of earthwork required and to ensure heavy equipment can safely navigate the site during construction.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests an existing utility easement crosses or is adjacent to the property. While this is excellent for interconnection, the easement's specific location and any associated restrictions on construction within its boundaries must be confirmed via a title search and an ALTA survey. We must ensure that the proposed BESS footprint does not conflict with the rights of the easement holder. No other access easement concerns are noted, given the direct public road frontage.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are listed as "Unknown." These are critical data gaps representing significant potential risk. Massachusetts has stringent environmental regulations, particularly the Massachusetts Wetlands Protection Act, which establishes a 100-foot buffer zone around delineated wetland resource areas where development is heavily restricted. Given the site's undeveloped and wooded nature, the presence of wetlands is highly probable. A desktop screening using MassGIS and National Wetlands Inventory (NWI) data is an immediate next step, to be followed by a formal field-based wetlands delineation by a certified professional. Any presence of Flood Zone A or AE would severely constrain buildable area and dramatically increase site development costs due to requirements for elevating equipment.

Habitat & Species: The data indicates no critical habitat or protected areas on site. This is a positive initial finding. However, this must be verified through a desktop review of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare or endangered species habitats are present, which could trigger lengthy and costly consultations.

Brownfield/Superfund Status: The site is not a brownfield, which avoids potential contamination risks and remediation costs. However, this also means the project is ineligible for the 10% IRA Brownfield Adder, a notable disadvantage to project economics.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and design advantage, eliminating the need for specialized risk assessments and setback considerations associated with such infrastructure.

3. Grid Infrastructure & Interconnection

Grid Proximity & Voltage: The site's most compelling feature is its grid access. The data indicates "POI Onsite" with a target interconnection voltage of 13.2 kV. This is an ideal distribution voltage for a project in the ≤5MW range. This suggests a 3-phase distribution feeder is directly on or adjacent to the property line, which is a major strategic advantage. The nearest substation, North Oxford (2.7 miles, 115 kV), likely serves as the transmission source for this distribution feeder. The proximity of a 345 kV transmission line is noted but is not relevant for this project's intended scale.

Interconnection Cost & Timeline: With the Point of Interconnection (POI) located onsite, the costs for line extension are eliminated. The primary interconnection costs will be associated with the utility's required studies (System Impact Study, Facilities Study), protection system upgrades at the substation or on the feeder, and the project's own switchgear and protective devices. A preliminary budget of $400,000 - $900,000 should be allocated for these direct interconnection costs. Requires Verification: The interconnecting utility's identity is not provided. Assuming it is National Grid or Eversource, the interconnection queue in Massachusetts is notoriously long and complex. We should anticipate a timeline of 24-36 months from application submission to receiving Permission to Operate (