⚡ 40 MILLBURY RD

CONFIDENTIAL - BESS SITE DILIGENCE ANALYSIS

To: Sunland America Corp. Development Committee

From: Senior BESS Site Evaluation Analyst

Date: October 26, 2023

Subject: Comprehensive Site Analysis for 40 Millbury Rd, Oxford, MA (APN: 16_D03)

1. Site Access & Topography

Road Access: The site has frontage on Millbury Road, a public, two-lane paved road. This provides direct legal and physical access, which is a significant advantage. A preliminary review of aerial imagery indicates the road appears suitable for standard construction traffic, including flatbed trucks for battery container delivery.

Topography & Site Conditions: Based on aerial and topographical maps, the 12.58-acre parcel is undeveloped, heavily wooded, and features moderately rolling terrain characteristic of central Massachusetts. This presents a buildability challenge. Significant tree clearing, stumping, and grading will be required to create a level pad for the BESS compound, increasing site work costs and potentially triggering additional environmental review under local tree removal ordinances.

Heavy Equipment Feasibility: While the public road access is good, an internal access road will need to be constructed from Millbury Road to the project pad. The rolling topography may require substantial cut-and-fill operations to create a road with a suitable grade for heavy equipment, particularly the large crane required for setting the main power transformer and battery enclosures. A geotechnical survey will be essential to assess soil stability and subsurface conditions.

Easement Concerns: No primary access easement is required due to public road frontage. However, we will need to secure a utility easement from the property line to the Point of Interconnection (POI) for the interconnecting utility, which is likely National Grid. Construction and temporary laydown area easements may also be necessary depending on the final site layout.

2. Environmental Constraints

FEMA Flood Zone: The flood zone designation is currently Unknown. This is a critical data gap. A review of the FEMA Flood Insurance Rate Map (FIRM) for this location is a top priority. If any portion of the planned equipment pad falls within a 100-year floodplain (e.g., Zone A or AE), it would necessitate elevating all equipment above the Base Flood Elevation, adding significant cost and complexity, or could render the site unusable.

Wetlands: The presence of wetlands is Unknown but considered highly likely given the site's undeveloped, wooded nature in this region. The Massachusetts Wetlands Protection Act and the Oxford Conservation Commission impose strict regulations, including significant buffer zones (typically 100 feet or more) around any delineated wetland resources. The presence of wetlands could severely constrain the buildable area, potentially reducing the 12.58-acre parcel to an unworkably small envelope. A formal wetlands delineation is a mandatory and immediate due diligence step.

Habitat & Species Risk: Initial data indicates no critical habitats or protected areas on site. This is a positive finding. However, it is prudent to run a screening using the USFWS IPaC tool and the state's Natural Heritage & Endangered Species Program (NHESP) database to confirm no state or federally listed species habitats are present, as this could trigger lengthy consultations or time-of-year restrictions on construction.

Brownfield/Superfund Status: The site is not a brownfield and is not near any Superfund sites. While this means the project is ineligible for the 10% IRA