⚡ 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 covers key site attributes, risks, and recommended next steps to determine project viability.

1. Site Access & Topography

• Road Access: The property has frontage on Millbury Road, a public, two-lane paved road. Initial desktop review suggests this road is sufficient for standard construction traffic. However, a formal transportation study will be required to confirm its suitability for oversized/overweight loads, such as a main power transformer and containerized BESS units. We must verify if there are any low-clearance bridges, sharp turns, or weight-limited roads on the likely delivery route from major highways.
• Terrain Characteristics: Based on aerial imagery and regional topography, the 12.58-acre parcel is heavily wooded and appears to have some moderate elevation changes. It is undeveloped land. Significant clearing, grubbing, and grading will be required to create a level pad for the BESS equipment. A detailed topographical survey is essential to quantify the required earthwork, which could be a significant cost driver. The lack of specified "Buildable Acres" is a major data gap.
• Heavy Equipment Feasibility: Access from Millbury Road onto the site itself is a key unknown. There does not appear to be an existing improved entrance or curb cut. A new, heavy-duty access road will need to be constructed from the public right-of-way into the project area. The feasibility and cost depend entirely on the site's slope and soil conditions at the entrance.
• Easement Concerns: The data point "POI Onsite" suggests a utility right-of-way may already exist on the property. A preliminary title report is immediately required to confirm the existence, location, and terms of any utility or access easements. Unfavorable easement terms could restrict our development envelope or grant broad access rights to third parties.

2. Environmental Constraints

• FEMA Flood Zone: The flood zone status is listed as "Unknown." This is a critical risk. Any portion of the site within a 100-year floodplain (e.g., Zone A or AE) would be highly problematic, potentially requiring all equipment to be elevated above the Base Flood Elevation, adding substantial cost. Verification via the FEMA Flood Map Service Center is a priority first step.
• Wetlands: The presence of wetlands is "Unknown." In Massachusetts, this is arguably the single greatest environmental risk. The Massachusetts Wetlands Protection Act imposes stringent regulations, including a 100-foot buffer zone around delineated wetlands where development is heavily restricted. Given the site's wooded and undeveloped nature, the presence of wetlands is highly probable. A formal wetlands delineation is non-negotiable and will be the primary determinant of the actual buildable area.
• Habitat/Species Risk: The data indicates no critical habitat or protected areas, which is a positive initial screen. However, this must be formally verified through the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed rare species or priority habitats are present.
• Brownfield/Superfund Status: The site is not a brownfield, which means it does not qualify for the 10% IRA brownfield tax credit adder. While this simplifies the environmental liability assessment, it is a disadvantage from a project finance perspective.
• Pipeline Proximity: No major pipelines within three miles is a significant safety and layout advantage, eliminating the need for specialized setbacks and safety protocols related to pipeline hazards.

3. Grid Infrastructure & Interconnection

• Substation & Transmission: The nearest substation is North Oxford, 2.7 miles away. This is a considerable distance for a new distribution line extension, which would likely render a project financially unviable (costs could exceed $1M/mile). A 345kV transmission line is closer (0.9 miles), but this voltage is far too high for a distribution-scale project and the interconnection costs would be astronomical.
• Point of Interconnection (POI): The most critical and promising data point is "POI Onsite" at an "IX Voltage" of 13.2 kV. If a 3-phase, 13.2kV distribution feeder with sufficient capacity truly runs along the property frontage or through an on-site easement, this is a major advantage that could make the project viable. However, this requires immediate and absolute verification. If this data point is incorrect, the project is likely a fatal flaw due to the distance to the substation.