⚡ 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 – Project Gardner (91 Fredette St, Gardner, MA)

This report provides a comprehensive due diligence analysis for the property located at 91 Fredette Street in Gardner, Worcester County, Massachusetts (APN: M22-11-7). The 2.12-acre parcel is being evaluated for its suitability as a distribution-scale Battery Energy Storage System (BESS) project. The analysis covers key development pillars including site access, environmental constraints, grid infrastructure, regulatory approvals, and incentive eligibility.

1. Site Access & Topography

The subject property benefits from excellent physical access. It is served by a public road, Fredette Street, which appears to be a well-maintained, paved industrial road capable of supporting heavy vehicle traffic. The site's historical and current land use as a "Truck Terminal" strongly suggests that the local road network is designed for semi-trailer trucks and other oversized vehicles.

• Equipment Delivery: Feasibility for delivering heavy equipment, including multi-ton transformers and containerized BESS units, is considered high. The industrial zoning and existing infrastructure are significant advantages. Action Item: A desktop route analysis should be conducted to verify bridge weight limits and turning radii from the nearest state highway to the site.
• Terrain Characteristics: Based on aerial imagery and the site's industrial nature, the topography is presumed to be relatively flat and graded, which is ideal for BESS construction. The "Good" buildability rating supports this assumption, minimizing the need for extensive civil work and associated costs.
• Easement Concerns: While road access is public, a full title search is required to identify any potential access, utility, or restrictive easements that could encumber the property and constrain the developable area. The "POI Onsite" designation is positive but does not preclude the existence of other utility easements that must be accounted for in the site layout.

2. Environmental Constraints

Environmental factors present the most significant unknowns and potential risks for this site. The industrial history of the area requires careful and immediate investigation.

• FEMA Flood Zone: The flood zone designation is currently "Unknown." This is a critical data gap. Development within a Special Flood Hazard Area (e.g., Zone AE) would trigger significant design changes, such as elevating all equipment above the Base Flood Elevation, leading to substantial cost increases. A location within a floodway would likely render the site undevelopable. This must be verified immediately via the FEMA Flood Map Service Center.
• 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 the buildable area. A desktop screening using MassGIS OLIVER is the first step, to be followed by a formal wetland delineation by a certified professional if any indicators are present.
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• Brownfield/Superfund Status: The presence of 13 known brownfield or superfund sites within a two-mile radius is a major concern. It increases the likelihood that this parcel, a former truck terminal, may have soil or groundwater contamination (e.g., from fuel spills or hydraulic fluid leaks). This poses a significant liability and potential for costly remediation. However, this risk is coupled with an opportunity: if the site itself qualifies as a brownfield under IRA guidelines, the project could be eligible for a 10% ITC adder. A Phase I Environmental Site Assessment (ESA) is non-negotiable and should be commissioned immediately.
• Critical Habitat & Pipelines: The data indicates no critical habitats or protected areas on or near the site, which is a positive finding. The absence of pipelines within a three-mile radius eliminates risks associated with explosion hazards and setback requirements.

3. Grid Infrastructure & Interconnection

The site's grid infrastructure characteristics are exceptionally strong and represent its primary advantage.

• Point of Interconnection (POI): The data indicates the POI is "Onsite" at the target distribution voltage of 13.8 kV. This is a best-case scenario, potentially saving hundreds of thousands to over a million dollars in line extension costs and significantly simplifying the engineering and permitting process. The likely configuration is a 3-phase overhead or underground distribution feeder running along the property boundary or