⚡ 91 FREDETTE ST

MEMORANDUM

TO: Sunland America Corp. Investment 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 91 Fredette St in Gardner, Worcester County, Massachusetts. The 2.12-acre parcel presents a mix of significant advantages, particularly in zoning, and considerable challenges related to interconnection costs and project economics. The following sections detail the findings of our initial evaluation.

1. Site Access & Topography

Road Access & Feasibility: The site has direct frontage on Fredette Street, which appears to be a paved, two-lane industrial road capable of supporting heavy truck traffic. A desktop review via satellite imagery confirms the presence of multiple industrial and commercial facilities in the immediate vicinity, including truck terminals and warehouses. This existing infrastructure strongly suggests that access for lowboy trailers carrying battery containers, transformers, and other heavy equipment is feasible without requiring significant road upgrades.

Terrain & Buildability: The parcel's current land use is listed as a "Truck Terminal," indicating it is likely graded, compacted, and relatively flat. This is highly advantageous, as it should minimize the need for extensive civil work and site preparation, thereby reducing construction costs and timelines. The 2.12-acre size is adequate, though potentially tight, for a standard 5 MW / 10 MWh BESS project once setbacks and access roads are accounted for.

Access Easements: While direct access from a public road is likely, a full title search is required to confirm there are no restrictive easements, covenants, or access limitations that could impede development. We do not anticipate major issues here given the industrial nature of the location.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The FEMA flood zone and wetlands status are currently marked as Requires Verification. This is a critical data gap. An immediate desktop screening using the FEMA Flood Map Service Center and MassGIS OLIVER is necessary. Any designation within a 100-year floodplain (Zone A/AE) or the presence of jurisdictional wetlands would introduce significant siting challenges, potentially requiring costly mitigation, elevated foundations, or rendering a portion of the site undevelopable. A formal wetlands delineation will be required if initial screening indicates a potential presence.

Brownfield/Superfund Status: The data indicates 13 brownfield or superfund sites within a two-mile radius. While the subject parcel itself is not listed, this proximity raises two key points. First, there is a risk of on-site contamination from historical industrial use or migration from adjacent properties. A Phase I Environmental Site Assessment (ESA) is a mandatory and immediate next step. Second, if the site can be classified as a brownfield under IRA guidelines, the project could qualify for the 10% Brownfield ITC adder. This potential financial upside warrants thorough investigation via the Phase I ESA.

Habitat & Pipelines: The site is clear of critical habitats and protected areas, which is a significant de-risking factor, simplifying environmental permitting. The absence of major gas pipelines within three miles eliminates risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure & Interconnection

Substation & Point of Interconnection (POI): The nearest substation is located 1.1 miles from the site and has a maximum voltage of 69 kV. This distance is a primary concern for project viability. The interconnecting utility is presumed to be National Grid.

Interconnection Strategy & Cost: A 1.1-mile line extension for a distribution-level interconnection (e.g., at 13.8 kV) will be substantial. A preliminary, high-level cost estimate for this scope would be in the range of $1.5M - $3.0M, encompassing engineering, materials, labor, and potential road crossing or easement acquisition costs. This represents a major capital expenditure that could render the project uneconomical. The absence of transmission lines nearby confirms this is purely a distribution-grid opportunity.

Utility Process & Timeline: Interconnecting with National Grid in Massachusetts follows the state's DPU-mandated process. A project of this size will require a Standard Process application, including detailed system impact and facilities studies. Queue times can be lengthy, and the full interconnection process from application to commercial operation can often take 24-36 months. Submitting a pre-application report is a crucial first step to receive an initial, non-binding cost and timeline estimate from the utility.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the City of Gardner. The parcel is zoned IND2 (Heavy Industrial), which is ideal for BESS development. This zoning classification is the single strongest attribute of the site.

Permitting Pathway: A review of Gardner's municipal code reveals the city has proactively adopted a specific zoning bylaw for Battery Energy Storage Systems (Chapter 675, Article XIII). This is a major advantage, as it provides a clear and predictable permitting path. The bylaw indicates that BESS is an allowed use in the IND2 district upon the issuance of a Special Permit by the City Council. This eliminates ambiguity and significantly reduces entitlement risk compared to jurisdictions without specific BESS regulations.

Requirements & Risks: The bylaw outlines specific requirements for site plan review, safety and decommissioning plans, setbacks (consistent with the IND2 district), and screening. The existence of this bylaw makes a future moratorium highly unlikely. We should schedule a pre-application meeting with Gardner's Planning Department to confirm their interpretation of the bylaw and the expected review timeline.

5. IRA/ITC Incentive Analysis

The project's eligibility for Investment Tax Credit (ITC) adders under the Inflation Reduction Act (IRA) is extremely poor.

• Opportunity Zone: No (0% adder)
• Energy Community: No (0% adder)
• Low-Income Community: No (0% adder)