⚡ 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, Massachusetts. The analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria.

1. Site Access & Topography

Road Access & Feasibility: The property benefits from public road access via Fredette Street. A review of aerial imagery indicates Fredette Street is a paved, industrial-grade road with direct connections to major local thoroughfares and proximity to the MA-2 highway. This access appears more than adequate for the delivery of heavy and oversized loads, including tractor-trailers carrying battery containers, medium-voltage transformers, and switchgear.

Terrain & Equipment Access: The site is located within an established industrial area and appears to be relatively flat and cleared, consistent with its prior use as a truck terminal. The "Good" buildability rating in the provided data supports this assessment. This topography is highly favorable, as it will minimize the need for extensive civil work and grading, thereby reducing construction costs and timelines. Heavy equipment, including large cranes required for setting transformers and enclosures, should have no issue accessing and maneuvering on the 2.12-acre parcel.

Easement Concerns: While the Point of Interconnection (POI) is listed as "Onsite," which is a significant advantage, a full title search is required. This step is critical to verify the absence of any restrictive access or utility easements that could conflict with the proposed BESS layout and internal access roads.

2. Environmental Constraints

FEMA Flood Zone: The site's FEMA flood zone designation is currently Unknown. This represents a critical data gap and a potential fatal flaw. If the property is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs would increase substantially due to the need for elevated foundations and flood-proofing measures, and permitting could become untenable. An immediate review of FEMA's Flood Insurance Rate Maps (FIRMs) is required.

Wetlands: The presence of regulated wetlands is also Unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act) that typically enforce a 100-foot "buffer zone" where development is restricted. A desktop screening using MassGIS data is the first priority, to be followed by a formal wetland delineation by a certified professional if any potential wetlands are identified on or near the parcel. The lack of buildable acres data makes this a higher risk.

Brownfield/Superfund Status: The data indicates 13 Brownfield or Superfund sites within a two-mile radius. This presents both a risk and an opportunity. The risk is that this specific parcel may have historical contamination from its industrial use, which could necessitate costly remediation. However, if the site meets the specific definition of a "brownfield project" under the Inflation Reduction Act (IRA), it would be eligible for a 10% Investment Tax Credit (ITC) adder. A Phase I Environmental Site Assessment (ESA) is non-negotiable to clarify this status.

Other Constraints: The site has a low risk profile for other common environmental constraints. There is no critical habitat or protected areas on site, no nearby gas wells, and no major pipelines within a three-mile radius. The site is not located in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Substation & Transmission: The nearest substation is National Grid's Crystal Lake Substation, located 1.7 miles away. Its 69 kV maximum voltage indicates it is a substantial node on the grid, likely with capacity to support a 5 MW BESS. The absence of transmission lines within three miles confirms that a distribution-level interconnection is the only viable path.