⚡ 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 12.58-acre parcel presents a mix of a highly attractive interconnection attribute with significant regulatory and environmental risks that must be carefully evaluated.

1. Site Access & Topography

Road Access: The property has frontage on Millbury Road, a two-lane, paved public road. Initial desktop review indicates this road is sufficient for standard construction traffic. However, a formal route survey is required to confirm its suitability for oversized and overweight vehicles, such as a main power transformer (MPT) and prefabricated battery enclosures. We must verify bridge weight limits, turning radii, and any low-hanging overhead lines on the delivery route.

Terrain & Equipment Access: As is typical for central Massachusetts, the parcel is heavily wooded with potentially rolling topography. This will necessitate significant tree clearing, grubbing, and grading, increasing site preparation costs. The "Buildability: OK" data point is vague and requires substantiation with a formal topographical survey. The primary challenge will be constructing a stable, level pad for the BESS containers and substation equipment. A gravel construction entrance and access road from Millbury Road onto the site will need to be built.

Easement Concerns: With direct frontage on a public road, a primary access easement is likely not required. However, utility easements will be critical. If the Point of Interconnection (POI) is on the far side of the property, an easement may be needed to run conduit from the BESS to the utility pole. This must be verified during the title search and survey process.

2. Environmental Constraints

This category presents significant unknowns and potential "fatal flaws."

• FEMA Flood Zone: The flood zone status is currently Unknown. This is a critical data gap. Any designation within a 100-year floodplain (e.g., Zone AE) would impose severe constraints, requiring equipment to be elevated above the Base Flood Elevation (BFE) or potentially rendering the site economically unviable. A FEMA FIRMette must be generated immediately.
• Wetlands: The presence of wetlands is Unknown but highly probable on a wooded, undeveloped parcel in this region. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet). A desktop screening using the National Wetlands Inventory (NWI) is a necessary first step, but a formal field delineation by a certified wetland scientist will be required to determine the precise boundaries and establish the buildable area. This is a major risk to the project schedule and layout.
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• Critical Habitat / Species: The data indicates no critical habitat, which is a positive initial finding. This should be verified via the USFWS IPaC tool and the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database to ensure no state-listed species or sensitive areas are present.
• Brownfield/Superfund Status: The site is not a brownfield, meaning it does not qualify for the 10% IRA brownfield tax credit adder. However, the lack of nearby superfund sites or known contamination reduces potential environmental liability and remediation costs.
• Pipeline Proximity: No major pipelines are located nearby, which eliminates a significant safety, setback, and co-location risk.

3. Grid Infrastructure & Interconnection

The grid access presents the most compelling, yet uncertain, aspect of this site.

Interconnection Point: The data indicates "POI Onsite" at a target voltage of 13.2 kV. This is an