⚡ 74 OLD SOUTHBRIDGE RD

MEMORANDUM

TO: Sunland America Corp. Development Committee
FROM: Senior BESS Site Evaluation Analyst
DATE: October 26, 2023
SUBJECT: Comprehensive Site Diligence Analysis for Oxford, MA (APN: 10A_B25)

This report provides a comprehensive due diligence analysis for the property located at 74 Old Southbridge Road, Oxford, MA, for its potential as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory hurdles, and financial incentives.

1. Site Access & Topography

The subject property is located directly on Old Southbridge Road, a paved, two-lane public road. Based on aerial imagery review, access appears to be well-established and suitable for passenger vehicles and light commercial trucks. The current use as an auto repair garage suggests the site entrance can accommodate commercial traffic.

• Equipment Delivery: The primary access from Old Southbridge Road appears adequate for the delivery of major equipment, including battery containers, inverters, and medium-voltage transformers. However, a detailed route survey is required to confirm the absence of low-clearance overhead lines, bridge weight limits, or tight turning radii on the approach from major highways like I-395.
• Terrain Characteristics: Given its current commercial use, the front portion of the 5.19-acre parcel is likely graded and relatively flat. The rear of the parcel appears undeveloped and wooded, and may have more variable topography. A formal topographic survey is essential to confirm site grades and minimize earthwork costs.
• Heavy Equipment Access: On-site maneuverability for cranes and delivery trucks appears feasible on the developed portion of the lot. Access to the undeveloped rear of the parcel would require clearing and grading.
• Easement Concerns: A significant concern is the lack of a direct Point of Interconnection (POI) on-site. An interconnection route of 0.7 to 1.0 miles will be required to reach the nearest transmission line or substation. This will necessitate securing off-site easements from multiple private landowners and/or a franchise agreement with the Town of Oxford for use of the public right-of-way. This process can be costly and time-consuming, representing a major project risk.

2. Environmental Constraints

The site presents several significant environmental unknowns and one major risk associated with its historical land use. Diligence in this area is critical.

• FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. A desktop review using the FEMA Flood Insurance Rate Map (FIRM) is an immediate next step. If the site is within a Special Flood Hazard Area (e.g., Zone A or AE), development costs will increase due to requirements for elevating equipment, and portions of the site may be undevelopable.
• Wetlands: The presence of wetlands is unknown. Massachusetts has stringent wetland protection regulations under the Wetlands Protection Act. A desktop screening using MassGIS (MassMapper) is required, to be followed by a formal wetland delineation by a certified professional if potential resources are identified. Any jurisdictional wetlands will require a 100-foot buffer zone, which could severely constrain the buildable area on the 5.19-acre parcel.
• Critical Habitat / Endangered Species: The initial screening shows no critical habitat or protected areas on site, which is a positive finding. This should be confirmed via a query of the Massachusetts Natural Heritage & Endangered Species Program (NHESP) database.
• Brownfield/Superfund Status: While no official Superfund or state-listed hazardous sites are noted within a two-mile radius, the property's long-standing use as an "Auto Repair (& Related), Garage" presents a high risk of on-site contamination from petroleum products, solvents, and other hazardous materials. A Phase I Environmental Site Assessment (ESA) is mandatory. If Recognized Environmental Conditions (RECs) are identified, a Phase II ESA (soil and groundwater sampling) will be necessary. This is a dual-edged sword: while remediation can be costly and delay the project, confirmed contamination could qualify the site for the 10% IRA Brownfield tax credit adder, partially offsetting cleanup costs and improving project economics.
• Pipeline Proximity: No gas transmission pipelines are located in the immediate vicinity, mitigating risks associated with pipeline setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

The site's proximity to robust grid infrastructure is its strongest attribute, though the interconnection process itself will be a major undertaking.

• Substation & Transmission: The North Oxford substation (11