⚡ 10 MILLBURY ST

MEMORANDUM

TO: Sunland America Corp. Development Team
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for 10 Millbury St, Auburn, MA (APN: 41_11)

This report provides a comprehensive due diligence analysis for the property located at 10 Millbury Street in Auburn, Worcester County, Massachusetts. The 2.31-acre parcel, currently zoned for General Industrial use, presents a compelling opportunity due to its exceptional proximity to grid infrastructure. However, significant environmental uncertainties and a lack of readily available IRA incentives require a cautious and methodical approach. The following analysis details the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project.

1. Site Access & Topography

• Road Access & Feasibility: The property is located directly on Millbury Street, a well-maintained, paved road within an established industrial park. Preliminary desktop analysis using satellite imagery indicates sufficient road width and turning radii to accommodate heavy haul trucks. Access appears to be directly from the public right-of-way, which is a significant advantage.
• Terrain Characteristics: As an industrial-zoned parcel in this region, the site is presumed to be relatively flat and previously graded, which would minimize civil engineering costs. Requires Verification: A formal topographic survey is necessary to confirm grades and identify any potential challenges.
• Heavy Equipment Access: Access appears feasible for standard delivery vehicles, including lowboy trailers required for transporting 40-foot battery containers, switchgear, and a main power transformer (MPT). No obvious overhead line obstructions or tight corners are visible on the primary access route.
• Easement Concerns: The property's frontage on a public road is positive. However, a full ALTA survey and title report are required to identify any potential utility easements (drainage, sewer, gas, electric) that could cross the property and sterilize buildable area. Given the industrial setting, such easements are common.

2. Environmental Constraints

• FEMA Flood Zone: The FEMA flood zone designation is currently unknown and represents a critical data gap. If the site is in a Special Flood Hazard Area (e.g., Zone AE), development costs would increase substantially due to the need to elevate all equipment above the Base Flood Elevation, or the site could be deemed undevelopable. A determination is required immediately.
• Wetlands Presence: The presence of wetlands is unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act). The presence of jurisdictional wetlands would trigger significant setbacks (typically 50-100 feet) and a lengthy review process with the local Conservation Commission, severely impacting the 2.31-acre site's buildable area. A wetland delineation is a high-priority next step.
• Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a significant positive. This reduces the risk of lengthy consultations with US Fish & Wildlife Service (USFWS) or state wildlife agencies. A desktop screening should still be performed to confirm.
• Brownfield/Superfund Status: The presence of three superfund/brownfield sites within a two-mile radius is a double-edged sword. It presents a risk of potential contaminant migration onto our target parcel, which must be assessed via a Phase I Environmental Site Assessment (ESA). Conversely, if the subject property itself can be classified as a brownfield under IRA guidelines (requiring a Phase I ESA to confirm contamination), it could unlock a valuable 10% ITC adder. This is the only potential incentive adder identified for this site.
• Pipeline Proximity: No major gas transmission pipelines are identified within a three-mile radius. This is a major safety and development advantage, eliminating concerns related to pipeline operator restrictions, setbacks, and explosion risks.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The PONDVILLE substation is located only 0.5 miles from the site. This is an exceptional proximity that drastically reduces the cost and complexity of the generator lead line. The substation's 69 kV maximum voltage indicates it is a significant node on the grid, likely with multiple distribution feeders originating from it. Requires Verification: The interconnecting utility is presumed to be National Grid, but this must be confirmed.
• Transmission Line Proximity: A 115kV transmission line is also nearby (0.6 miles), but interconnection at this voltage level would be financially unviable for a ≤5MW project.
• Recommended Interconnection Voltage: The recommended point of interconnection (POI) is a 13.2 kV or 13.8 kV distribution feeder originating from the PONDVILLE substation. This is the most cost-effective and technically appropriate method for a project of this scale.
• Estimated Cost & Timeline: A 0.5-mile distribution line extension could range from $500,000 to $1.5 million, depending on whether it is overhead or underground and the number of road/rail crossings. The interconnection process in ISO-New England, managed by National Grid, is rigorous. Timelines from application submission to Commercial Operation can range from 24 to 36 months, including study periods and construction.
• Feeder Configuration: A site visit and review of utility maps are required to confirm the presence of 3-phase power along Millbury Street. The absence of 3-phase power at the road would significantly increase interconnection costs.

4. Regulatory & Zoning Analysis

• Authority Having Jurisdiction (AHJ): The Town of Auburn Planning Board and other associated departments (Building, Conservation) will be the primary AHJ.
• Zoning Compatibility: The "Industrial (General)" (GI) zoning is highly favorable for BESS development. This use is generally considered compatible with industrial activities and is less likely to face public opposition compared to commercial or residential