⚡ 65-R RIVERSIDE RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 65-R RIVERSIDE RD, Gardner, MA (APN: H22-3-11)

This report provides a comprehensive due diligence analysis for the subject property, a 3.4-acre parcel in Gardner, Worcester County, Massachusetts, for its potential as a distribution-scale Battery Energy Storage System (BESS) site. The analysis concludes that the site faces multiple critical, likely insurmountable, challenges related to zoning, grid access, and physical buildability.

1. Site Access & Topography

Overall Assessment: Critical Flaw Identified. The property's designation as "65-R" strongly indicates it is a rear, landlocked parcel without direct frontage on Riverside Road. This presents a severe, potentially fatal, impediment to development.

• Road Access Quality: Requires Verification. Based on GIS review, there is no visible established, all-weather road leading to the parcel. Access appears to be across adjacent privately-owned residential lots. Any existing path is likely unsuited for heavy commercial traffic.
• Equipment Delivery Feasibility: Extremely low. Delivery of multi-ton battery containers, a power conversion system (PCS) skid, and a main power transformer would require a wide, stable access road with sufficient turning radii and vertical clearance. Without a dedicated, engineered access road, delivery is not feasible.
• Terrain Characteristics: The site is located in Central Massachusetts and is likely characterized by rolling hills and dense tree cover. Site clearing and significant grading would almost certainly be required, adding to construction costs and potential environmental permitting complexity (e.g., stormwater pollution prevention plan - SWPPP).
• Easement Concerns: This is the primary risk. A new, permanent, and wide access and utility easement would need to be negotiated and purchased from one or more adjacent residential property owners. This process is often expensive, time-consuming, and has a high risk of failure due to landowner opposition.

2. Environmental Constraints

Overall Assessment: High Risk due to multiple unknowns. While the site avoids some key constraints, the lack of critical data on wetlands and flood risk, combined with nearby contamination sites, presents significant uncertainty.

• FEMA Flood Zone: Requires Verification. The FEMA status is unknown. Any designation within a Special Flood Hazard Area (e.g., Zone A, AE) would impose significant design constraints, requiring elevated foundations for all critical equipment, which increases costs and may be prohibited by the local AHJ.
• Wetlands Presence: Requires Verification. The presence of wetlands is unknown but highly probable given the regional geography. Massachusetts has stringent wetlands protection regulations (Massachusetts Wetlands Protection Act). Any identified wetlands would require significant setbacks (typically 100-foot buffer zones) that could render the 3.4-acre parcel unbuildable for a project of this scale. A formal wetlands delineation is a critical next step.
• Critical Habitat / Endangered Species: The data indicates no critical habitat or protected areas on site, which is a positive initial finding. However, this should be confirmed with a state-level database review (MA Natural Heritage & Endangered Species Program).
• Brownfield/Superfund Status: The presence of 8 sites within a 2-mile radius is a material risk. While this could present an opportunity for the 10% IRA Brownfield adder if the site itself qualified, it is more likely a risk of on-site or migrating contamination. A Phase I Environmental Site Assessment (ESA) would be mandatory to assess potential liability and cleanup requirements.
• Pipeline Proximity: No gas transmission pipelines are located nearby, which eliminates a significant safety and setback concern.

3. Grid Infrastructure & Interconnection

Overall Assessment: Very Poor. The distance to the nearest viable Point of Interconnection (POI) makes this site financially uncompetitive for a distribution-scale project.

• Nearest Substation: The nearest substation (UNKNOWN133570) is 1.4 miles away. This is a substantial distance for a new distribution feeder line. The substation's 69 kV bus indicates it is a transmission/sub-transmission asset, meaning capacity is likely available, but the cost to access it will be high.
• Interconnecting Utility: The utility for Gardner, MA is National Grid. Interconnection would be processed through their Massachusetts tariff under the jurisdiction of ISO New England (ISO-NE).
• Recommended Interconnection: A distribution-level interconnection at 13.8 kV is the only feasible path for a ≤5MW project. This would require a dedicated feeder line to be constructed for 1.4 miles from the substation to the site, likely via a combination of new pole sets and undergrounding.
• Estimated Cost & Timeline: The cost for a 1.4-mile dedicated feeder is prohibitive. A rough order-of-magnitude (ROM) estimate would be $1.5M - $3.0M+. This cost alone would likely make a 5MW BESS project economically unviable. The National Grid interconnection queue in Massachusetts is known to be congested, with study timelines often exceeding 18-24 months before an Interconnection Service Agreement (ISA) is issued.
• Feeder Configuration: The project would require a new, dedicated 3-phase distribution feeder from the substation. Tapping an existing residential feeder is not an option for a project of this size.

4. Regulatory & Zoning Analysis

Overall Assessment: Critical Flaw Identified. The site's residential zoning presents a major, likely insurmountable, permitting barrier.

• Authority Having Jurisdiction (AHJ): The City of Gardner Planning Board and Zoning Board of Appeals (ZBA).
• Zoning Compatibility: The parcel is zoned RR2 (Rural Residential 2). BESS facilities are an industrial use and are fundamentally incompatible with this zoning designation. It is almost certain that BESS is not a permitted use "by-right."
• Permitting Pathway: The most likely pathway would be to seek a Use Variance from the ZBA, which requires proving a legal hardship unique to the property—a very high bar to clear. A Special Permit or Site Plan Review might be possible if the city has a specific bylaw for renewable or energy storage facilities, but this is unlikely in a residential district. This path is fraught with political risk and a high likelihood of denial due to community opposition.
• Setback Requirements: Requires Verification. Specific BESS setbacks are likely not defined. The AHJ would probably apply the most restrictive industrial or utility setbacks, in addition to standard residential property line setbacks (e.g., 50-100 feet), further constraining the buildable area.
• Moratorium Risk: Given the rise of energy projects, there is a moderate risk that an AHJ like Gardner could enact a moratorium on BESS development to study the issue, causing significant project delays.

5. IRA/ITC Incentive Analysis

Overall Assessment: Poor. The project does not qualify for any of the key Investment Tax Credit (ITC