⚡ 91 FREDETTE ST

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 91 Fredette St, Gardner, MA (APN: M22-11-7)

This report provides a comprehensive due diligence analysis for a potential distribution-scale Battery Energy Storage System (BESS) project at the subject property. The analysis covers key development pillars including site characteristics, environmental constraints, grid interconnection, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property has direct frontage on Fredette Street, which appears to be a paved, industrial-grade road capable of supporting heavy truck traffic. Based on aerial imagery analysis, the street connects directly to major local thoroughfares, suggesting a straightforward route from regional highways for equipment delivery. The current land use as a "Truck Terminal" strongly supports the conclusion that the site is designed to accommodate semi-trailers and other large vehicles.

Terrain & Buildability: The site's current use implies it is already graded, compacted, and relatively flat, likely with a gravel or paved surface. This is a significant advantage, as it will dramatically reduce the need for extensive civil engineering and earthwork, lowering site preparation costs. The 2.12-acre parcel size is adequate for a distribution-scale BESS project (typically requiring 0.5-1.5 acres for a 5MW system), leaving room for required setbacks, access roads, and stormwater management features.

Heavy Equipment Access: Access for critical heavy equipment, including a large crane for setting transformers and switchgear, as well as flatbed trucks delivering battery containers and inverters, appears to be excellent. The existing wide entrance aprons designed for truck terminals will facilitate easy ingress and egress during construction.

Easement Concerns: While direct road frontage is a positive, a full title report is required to identify any potential access, utility, or drainage easements that may encumber the property and constrain the buildable area. This requires verification.

2. Environmental Constraints

FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. If the site is located within a Special Flood Hazard Area (e.g., Zone AE), development costs could increase substantially due to requirements for elevating all equipment above the Base Flood Elevation, or the site could be rendered undevelopable. A FEMA FIRMette map must be reviewed immediately.

Wetlands: The presence of wetlands is unknown. Massachusetts has stringent wetland protection regulations, including significant buffer zones (typically 100 feet) under the Wetlands Protection Act. A desktop screening using MassGIS and National Wetlands Inventory (NWI) data is the immediate next step, to be followed by a formal wetland delineation by a certified professional if any indicators are present.

Critical Habitat / Endangered Species: The initial screening shows no critical habitat or protected areas on site, which is a significant positive. This should be confirmed by cross-referencing the site location with the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Priority Habitat maps to ensure no state-level concerns exist.

Brownfield/Superfund Status: The property is not listed as a brownfield or superfund site, but the presence of 13 such sites within a two-mile radius, combined with its heavy industrial zoning and use, suggests a moderate to high probability of on-site contamination. This presents both a risk and an opportunity. The risk is potential cleanup liability and cost. The opportunity is the potential to qualify for the 10% IRA Brownfield ITC adder if a Phase I Environmental Site Assessment (ESA) identifies recognized environmental conditions, and a subsequent Phase II confirms contamination. This potential incentive warrants further investigation.

Pipeline Proximity: No gas transmission pipelines are located within three miles, eliminating risks and setback constraints associated with high-pressure pipeline infrastructure.

3. Grid Infrastructure & Interconnection

Nearest Substation & Feeder: The nearest substation (UNKNOWN133570) is located approximately 1.1 miles from the site and has a maximum voltage of 69 kV. This is a favorable distance. For a ≤5MW BESS, interconnection will not be at 69 kV but rather at the distribution voltage (likely 13.8 kV or 23 kV) available from a feeder circuit out of this substation. The interconnecting utility is almost certainly National Grid. The available capacity on existing feeders and at the substation transformer requires immediate verification via a pre-application report.

Recommended Interconnection: A new, dedicated 3-phase distribution line extension from the substation to the project site is the most probable point of interconnection (POI). It is unlikely that an existing feeder with sufficient capacity runs adjacent to this relatively isolated industrial parcel.

Estimated Cost & Timeline: A 1.1-mile distribution line extension represents a significant project cost. A preliminary rough order of magnitude (ROM) cost estimate is $1.2M - $2.5M, highly dependent on the number of poles, terrain, road/rail crossings, and whether sections must be placed underground. The full interconnection process with National Grid in Massachusetts, from application to commercial operation, can be lengthy, typically ranging from 18 to 36 months. This timeline is a critical path item for the project schedule.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of Gardner, Massachusetts.

Zoning Compatibility: The parcel is zoned IND2 (Heavy