⚡ 91 FREDETTE ST

MEMORANDUM

TO: Sunland America Corp. Development Team

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 the property located at 91 Fredette Street in Gardner, Worcester County, Massachusetts. The 2.12-acre parcel, currently zoned for heavy industrial use, presents a mix of significant opportunities and substantial risks for the development of a distribution-scale (≤5MW) Battery Energy Storage System (BESS).

1. Site Access & Topography

Road Access: The site has direct frontage on Fredette Street, which appears to be a paved, two-lane industrial road. Based on satellite imagery, the road seems adequate for heavy truck traffic, including flatbeds for battery container delivery and cranes for equipment placement. The surrounding area is industrial, suggesting local roads are built to accommodate commercial vehicle loads and turning radii.

Terrain & Equipment Access: The parcel appears to be previously developed, graded, and relatively flat, which is highly advantageous for BESS development as it minimizes the need for extensive civil work. The existing curb cut and open lot configuration suggest that heavy equipment, including transformers, switchgear, and containerized battery systems, can be delivered and staged on-site with minimal issue.

Easement Concerns: While direct road frontage is a positive, a full title search is required to identify any potential access, utility, or drainage easements that could encumber the property and restrict the buildable area. Given its industrial history, subsurface utility easements are a possibility. Action Item: Commission a title report.

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 100-year floodplain (e.g., Zone AE), development costs would increase significantly due to the need to elevate all critical equipment above the Base Flood Elevation (BFE). A location within a floodway would likely render the site undevelopable. Action Item: Immediate verification using the FEMA Flood Map Service Center is required.

Wetlands: The presence of wetlands is unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act) with significant buffer zones (typically 100 feet) that can severely limit or prohibit development. A desktop screening using MassMapper GIS is the first step, to be followed by a formal wetland delineation by a certified professional if any indicators are present.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site, which is a significant de-risking factor. Standard due diligence still requires cross-referencing with the USFWS IPaC tool and the MA Natural Heritage & Endangered Species Program (NHESP) database to confirm.

Brownfield/Superfund Status: The parcel is not listed as a brownfield, but there are 13 known contaminated sites within a two-mile radius. This presents both a risk and a major opportunity. The risk is potential on-site contamination requiring costly remediation. The opportunity is that if the site can be officially designated as a "brownfield site" under federal CERCLA definitions, it could qualify for the 10% Energy Community ITC adder under the Inflation Reduction Act (IRA). This potential adder is a major driver for project economics. Action Item: A Phase I Environmental Site Assessment (ESA) is essential to assess contamination risk and determine brownfield eligibility.

Pipeline Proximity: The absence of major gas pipelines within three miles is a significant safety and layout advantage, eliminating concerns related to pipeline setbacks and explosion risk assessments.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation (UNKNOWN133570) is 1.1 miles away and has a maximum voltage of 69 kV. The absence of transmission lines within three miles confirms that a direct transmission-level interconnection is not feasible. The project must interconnect to the distribution system. The 1.1-mile distance to the substation is a major concern for a distribution-scale project, as it implies a potentially long and expensive line extension.

Interconnection Recommendation: The recommended pathway is a distribution