⚡ 91 FREDETTE ST

MEMORANDUM

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 the property located at 91 Fredette Street in Gardner, Worcester County, Massachusetts. The 2.12-acre parcel presents a mix of highly favorable attributes and potentially fatal flaws. The analysis concludes that while the zoning and physical characteristics are strong, significant challenges related to grid interconnection and financial incentives place the project's viability in question.

1. Site Access & Topography

The subject property exhibits favorable characteristics for physical development. Based on aerial and street-level imagery, the site has direct frontage on Fredette Street, a paved, two-lane industrial road. This access appears sufficient for the delivery of heavy and oversized equipment, including tractor-trailers carrying battery containers, medium-voltage transformers, and switchgear. No immediate obstructions such as low-clearance bridges or tight turning radii are apparent on the primary access routes.

• Equipment Delivery: Access appears feasible. Heavy haul routes from major highways (like Route 2) to the site should be confirmed, and a review of municipal road weight limits is required.
• Terrain: The parcel appears to be relatively flat and cleared, consistent with its current use as a truck terminal. This is highly advantageous, as it will minimize civil engineering and grading costs, which can be substantial on sloped sites.
• Easements: As the property has direct road frontage, an access easement is not anticipated to be required for construction ingress/egress. However, a critical unknown is the route for the generator lead line to the point of interconnection (POI). A 1.1-mile line will almost certainly require securing new utility easements from multiple third-party landowners, a process that can be time-consuming and costly.

2. Environmental Constraints

The environmental profile of the site presents both risks and a potential, albeit uncertain, opportunity.

• FEMA Flood Zone & Wetlands: Requires Verification. The FEMA flood zone designation and the presence of jurisdictional wetlands are currently unknown. A desktop screening using FEMA maps and the National Wetlands Inventory (NWI) is an immediate next step. Given the industrial nature of the area, channelized drainage is expected, but any presence of wetlands could significantly reduce the buildable area and require state and federal permits (e.g., ANRAD, 401 Water Quality Certification).
• Critical Habitat: The data indicates no critical habitat or protected species on or near the site. This is a significant positive, removing a common source of permitting delays and mitigation costs.
• Brownfield/Superfund Status: The presence of 13 Brownfield or Superfund sites within a two-mile radius is a major concern. This indicates a high potential for historic industrial contamination in the area. While the subject property is not listed, there is a risk of migrating contaminants from adjacent properties. A Phase I Environmental Site Assessment (ESA) is non-negotiable and should be commissioned immediately.
  • Advantage/Risk: This is a double-edged sword. If the Phase I ESA identifies Recognized Environmental Conditions (RECs) on our site, it introduces potential cleanup liability and costs. However, if the site meets the specific IRS definition of a "brownfield site," it could become eligible for the 10% Brownfield ITC adder, which would be a critical financial enhancement. This potential must be weighed against the risk of uninsurable cleanup liabilities.
• Pipeline Proximity: No gas transmission pipelines are located near the site, eliminating risks associated with pipeline-related setbacks and safety protocols.

3. Grid Infrastructure &