⚡ 40 MILLBURY RD

MEMORANDUM

TO: Sunland America Corp. Development Team

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 development of a distribution-scale Battery Energy Storage System (BESS) at 40 Millbury Road in Oxford, Worcester County, Massachusetts. The analysis identifies significant challenges, primarily related to zoning and a lack of financial incentives, which are weighed against a potentially highly favorable interconnection point.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a public, two-lane paved road. Initial review via satellite imagery indicates the road is in good condition and suitable for standard construction traffic, including flatbed trucks for battery container delivery and cranes for equipment placement.

Terrain & Site Conditions: The 12.58-acre parcel is currently undeveloped and heavily wooded. Topography in this region of Worcester County is typically characterized by rolling hills. A formal topographical survey is required to assess grading requirements, which are expected to be moderate to significant due to the tree cover and potential for uneven terrain. The need for extensive clearing and grading will be a notable line item in the construction budget.

Heavy Equipment Feasibility: Access from Millbury Road onto the site itself is a key unknown. There does not appear to be an existing improved curb cut or access drive. A new access road will need to be constructed, requiring a permit from the Oxford Department of Public Works. The entrance must be designed with sufficient width and turning radii to accommodate lowboy trailers carrying transformers and BESS enclosures.

Easements: The data point "POI Onsite" suggests a utility right-of-way may already exist on the property. A full title search is a critical next step to identify all existing easements (access, utility, conservation) that could constrain the site layout and reduce the buildable area.

2. Environmental Constraints

FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. A FEMA Flood Insurance Rate Map (FIRM) analysis must be conducted immediately. If the site falls within a Special Flood Hazard Area (e.g., Zone A, AE), development costs will increase substantially due to requirements for elevating all equipment above the Base Flood Elevation, and significant portions of the site may be undevelopable.

Wetlands: The presence of wetlands is Unknown but highly probable on a wooded parcel of this size in Massachusetts. A formal wetland delineation is required. Under the Massachusetts Wetlands Protection Act, development is heavily restricted within wetland resource areas and their associated 100-foot buffer zones, which could severely limit the usable acreage.

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

Site Contamination: The property is not a known brownfield or superfund site. While this avoids potential remediation costs and liabilities, it also means the project is ineligible for the 10% IRA brownfield tax credit adder, which is a competitive disadvantage.

Other Constraints: The site is clear of pipeline and gas well proximity risks. The Chesapeake Bay Critical Area designation is not applicable in Massachusetts.

3. Grid Infrastructure & Interconnection

Interconnection Point (POI): The provided data presents a conflicting but potentially highly advantageous scenario. While the nearest substation (North Oxford) is 2.7 miles away—a distance that would likely render a new feeder build cost-prohibitive—the data also states "POI Onsite" with a target interconnection voltage of 13.2 kV. This strongly implies a 3-phase, 13.2 kV distribution feeder runs along the property's road frontage or through an on-site easement. This is the single most compelling attribute of the site and must be verified immediately.

Recommended Interconnection: Interconnection at the 13.2 kV distribution level is the only viable path for a ≤5MW project. The nearby 345 kV transmission line is not a feasible POI for a project of this scale.

Cost & Timeline:

• Best Case Scenario (On-site POI confirmed): If a suitable feeder with adequate capacity is adjacent to the site, interconnection costs could be in the range of $500,000 to $1.5 million for switchgear, protection upgrades, and a short line extension.
• Worst Case Scenario (No suitable on-site POI): If a new 2.7-mile feeder from the North Oxford substation is required, costs would likely exceed $4 million, making the project financially non-viable.