⚡ 110 S MAIN ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for APN 52-0-38 (110 S MAIN ST, Milford, MA)

1. Site Access & Topography

The subject property, located at 110 S Main Street, benefits from excellent road access. As the address implies, it has direct frontage on a primary arterial road, which is expected to be paved, well-maintained, and capable of supporting heavy vehicle traffic. The site's prior use as a bowling alley strongly suggests it is a previously graded, cleared, and largely flat parcel, which is highly advantageous for construction, minimizing the need for extensive earthwork and civil engineering costs. This existing commercial development profile indicates that access for large delivery vehicles and heavy construction equipment, such as cranes for transformer placement and trucks delivering containerized battery systems, is likely feasible without significant modification. A desktop review confirms a wide entrance from S Main St. However, a formal site visit is required to verify the absence of low-hanging overhead utility lines or other vertical clearance obstructions. A title report must be commissioned to confirm that access is direct and unencumbered by shared easements or other restrictions that could complicate construction logistics.

2. Environmental Constraints

The environmental profile of the site presents a mix of positive attributes and critical data gaps. The absence of any known Brownfield or Superfund sites within a two-mile radius significantly reduces the risk of legacy contamination and associated cleanup liabilities. Similarly, the lack of nearby pipelines, critical habitats, or protected areas removes major safety and permitting hurdles. However, the "Unknown" status for both FEMA flood zones and wetlands are significant risks that must be addressed immediately. A desktop review using the FEMA Flood Map Service Center and the National Wetlands Inventory (NWI) is the immediate next step. Given the developed nature of the parcel, it is likely situated in FEMA Zone X (minimal risk), and on-site jurisdictional wetlands may be limited. Still, verification is mandatory, as the presence of a floodway or delineated wetlands could render a significant portion of the 2.26-acre parcel undevelopable or require costly mitigation and extensive setbacks. The site is not eligible for the 10% IRA Brownfield tax credit adder, which is a commercial disadvantage but is offset by the reduced environmental risk. The property is not located within the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

The site’s proximity to grid infrastructure is its single most compelling feature. An electrical substation (UNKNOWN136368) with a 115 kV bus is located just 0.1 miles from the parcel boundary. This extreme proximity dramatically reduces the potential cost and complexity of the generator tie-line (gen-tie). For a distribution-scale project (≤5MW), the recommended interconnection pathway would be to a distribution feeder (likely 13.8 kV) originating from this substation, not a direct tap to the 115 kV transmission line, which would be prohibitively expensive. The key unknown is the available capacity on the local distribution feeders.

A critical data discrepancy exists: the transmission line is listed as owned by Fitchburg Gas and Electric (Unitil), while the electrical distribution utility for Milford, MA is National Grid. It is almost certain that National Grid owns and operates the substation and will be the counterparty for the interconnection. This must be verified immediately. Assuming National Grid is the utility, we anticipate a lengthy interconnection queue process (potentially 24-36+ months) under the Massachusetts DPU tariffs. While the physical gen-tie cost may be low (estimated $300k - $800k), the cost of utility-side system upgrades to accommodate the project is a major unknown and could be substantial. A formal Interconnection Application is the only way to determine these costs definitively.

4. Regulatory & Zoning Analysis

The Authority Having Jurisdiction (AHJ) is the Town of Milford. The property is zoned "CC" - Central Commercial. A review of Milford's zoning bylaws is required to determine the viability of a BESS facility. It is highly unlikely that "Battery Energy Storage" is a defined, by-right use in this district. The most probable permitting pathway will be a Special Permit from the Milford Planning Board or a variance from the Zoning Board of Appeals (ZBA). This introduces significant discretionary review, public hearings, and potential for community opposition, creating both timeline and outcome risk. Key diligence steps include a pre-application meeting with the Milford Planning Department to gauge their initial reaction and understand the procedural requirements. We must also investigate if the town has enacted or is considering any BESS-specific ordinances or moratoriums, which are becoming increasingly common in Massachusetts municipalities. Standard commercial setbacks for the CC district will apply at a minimum, and fire-safety-related setbacks (per NFPA 855) will also dictate the final site layout.

5. IRA/ITC Incentive Analysis

The site's eligibility for Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA) is extremely poor. The data confirms the property is not located in an Opportunity Zone, an Energy Community, or a Low-Income Community. This is a major financial drawback. The project will only be eligible for the 30% base ITC