⚡ 257-265 GARDNER RD

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for Project "Templeton Grid"

PROPERTY: 257-265 Gardner Rd, Templeton, Worcester County, MA (APN: 6-12_19)

FINAL RECOMMENDATION: MAYBE

This report provides a comprehensive due diligence analysis for the potential acquisition and development of a distribution-scale Battery Energy Storage System (BESS) on the 4.89-acre parcel at 257-265 Gardner Rd in Templeton, MA. The site presents a compelling grid-access opportunity counterbalanced by significant environmental, regulatory, and financial incentive uncertainties. The final recommendation is MAYBE, contingent on favorable outcomes from the critical next steps outlined below. The project's viability hinges almost entirely on clarifying interconnection costs and its potential qualification for the IRA Brownfield tax credit adder.

1. Site Access & Topography

• Road Access & Equipment Delivery: The site has excellent frontage on Gardner Road (MA Route 101), a two-lane state highway. Based on satellite imagery review, access appears direct and unobstructed. This road should be sufficient for the delivery of all major equipment, including tractor-trailers carrying battery containers, transformers, and switchgear.
• Terrain Characteristics: The property appears to be relatively flat and largely cleared, consistent with its prior use as a commercial/automotive business. This is highly favorable, as it will minimize grading costs and site preparation complexity. The buildable area seems concentrated in the front two-thirds of the parcel.
• Heavy Equipment Access: Existing curb cuts and a paved/gravel lot facilitate easy entry for construction vehicles. Heavy cranes required for setting transformers and other equipment should have no issue accessing and maneuvering within the site boundaries.
• Easement Concerns: No immediate access easement concerns for the property itself are apparent. However, a significant utility easement will be required for the 1.4-mile distribution line extension to the substation. The route for this line must be assessed for potential right-of-way acquisition challenges and costs from other landowners.

2. Environmental Constraints

• FEMA Flood Zone: Requires Verification. Initial desktop analysis using the FEMA Flood Map Service Center indicates the property is located in Zone X, an area of minimal flood hazard. This is a positive finding, as it would likely not require significant elevation of equipment or costly flood-proofing measures. This must be confirmed with a formal report.
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• Wetlands: Requires Verification. This is a primary environmental risk. State GIS layers (MassGIS) suggest the potential for wetlands near the rear (western) portion of the parcel. Massachusetts has stringent wetland protection laws, including a 100-foot buffer zone from Bordering Vegetated Wetlands (BVW) where development is heavily restricted. A formal wetland delineation is a critical and immediate next step to determine the actual buildable area.
• Critical Habitat / Endangered Species: The provided data indicates no critical habitat or protected areas on site, which significantly de-risks this aspect of environmental permitting.
• Brownfield/Superfund Status: The data notes 11 contamination sites within a 2-mile radius, and the property's past commercial use suggests a potential for on-site contamination. This is both a risk and a major opportunity.
  • Risk: Potential for soil/groundwater contamination that could require costly remediation.
  • Opportunity: If the site meets the IRA's broad definition of a "brownfield site," the project could qualify for a 10% ITC adder. This is potentially the most critical factor for the project's financial viability. A Phase I Environmental Site Assessment (ESA) is required to assess this.
• Pipeline Proximity: No major gas transmission pipelines are identified nearby, eliminating risks associated with pipeline setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

• Nearest Substation: The site is located 1.4 miles from substation "UNKNOWN133570," which has a 69 kV bus. This is a highly favorable distance and indicates a robust point of interconnection. The presence of a 69 kV bus suggests it is a transmission-fed substation with multiple distribution feeders, increasing the likelihood of available capacity.
• Transmission Line Proximity: The absence of transmission lines within 3 miles confirms this project is a distribution-level interconnection, which aligns with our ≤5MW project strategy.
• Recommended Interconnection Voltage: The most feasible interconnection will be to a 3-phase distribution feeder originating from the nearby substation, likely at a standard voltage such as 13.2 kV or 13.8 kV.
• Estimated Cost & Timeline: A 1.4-mile distribution line extension is a significant undertaking. A preliminary cost estimate is in the $1.5M - $3.0M range, highly dependent on the number of poles, terrain, road crossings, and whether sections must be placed underground. The timeline for interconnection in Massachusetts with the likely utility, National Grid, can be lengthy, often 24-36 months from application submission to Commercial Operation.
• Utility & IX Process: The interconnecting utility is almost certainly National Grid. The project will be subject to the Massachusetts Department of Public Utilities (DPU) interconnection tariff and potentially review by ISO