⚡ 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 a potential distribution-scale Battery Energy Storage System (BESS) project at 91 Fredette St in Gardner, Worcester County, Massachusetts. The analysis evaluates the site's suitability based on key development criteria, including access, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Evaluation: Overall site access is rated as excellent. The property is served by Fredette Street, a public road within an established industrial area. Preliminary review of aerial imagery suggests the road is paved and sufficiently wide to accommodate heavy truck traffic typical for industrial zones. The property's prior use as a "Truck Terminal" strongly indicates that the access infrastructure is robust and designed for large vehicles.

Actionable Insights:

• Equipment Delivery: Feasibility for delivering heavy equipment, including 40-foot battery containers, switchgear, and a medium voltage transformer, appears high. The primary delivery route from major highways should be surveyed for any potential constraints such as low-clearance bridges or tight turning radii, but significant issues are not anticipated.
• Terrain: While the broader Worcester County region has varied topography, this specific parcel appears to be relatively flat and cleared, consistent with its industrial zoning and "Good" buildability rating. A formal topographic survey will be required for detailed engineering, but significant grading costs are not expected.
• Easements: The Point of Interconnection (POI) is listed as "Onsite," which mitigates the need for complex off-site access easements for electrical infrastructure. However, a full title report must be commissioned to identify any existing utility, access, or drainage easements that could encumber the 2.12-acre parcel and constrain the BESS layout.

2. Environmental Constraints

Evaluation: The environmental profile presents both significant risks and a potential financial opportunity. The presence of "Unknown" data for critical items like wetlands and flood zones represents a major diligence gap that must be addressed immediately.

Actionable Insights:

• FEMA Flood Zone: Requires Verification. The flood zone status is unknown. Siting within a Special Flood Hazard Area (e.g., Zone A, AE) would introduce substantial design challenges, requiring elevated foundations and potentially rendering the project financially unviable. This must be confirmed via FEMA's Flood Insurance Rate Maps (FIRMs) as a first-priority desktop task.
• Wetlands: Requires Verification. The presence of wetlands is unknown. Massachusetts has stringent wetland protection regulations (Massachusetts Wetlands Protection Act) with significant buffer zones (typically 100 feet). A desktop screening using MassGIS Oliver data is the immediate next step, to be followed by a formal field delineation by a certified wetland scientist if any indicators are present.
• Brownfield/Superfund Status: The presence of 13 known contamination sites within a two-mile radius is a notable risk. A Phase I Environmental Site Assessment (ESA) is mandatory to assess potential contamination on the subject parcel from historic uses or migration from nearby sites. Crucially, if the Phase I ESA determines this specific parcel meets the definition of a brownfield, it could qualify the project for the 10% IRA brownfield tax credit adder, turning a potential risk into a significant financial advantage.
• Other Considerations: The site is clear of critical habitat, protected areas, and nearby pipelines, which are significant positives that de-risk the project from a wildlife and public safety perspective.

3. Grid Infrastructure & Interconnection

Evaluation: The grid infrastructure is the single most compelling attribute of this site. The availability of an onsite POI at a suitable distribution voltage is a critical and rare advantage that dramatically reduces project cost, timeline, and complexity.

Actionable Insights:

• Interconnection Point: The POI is "Onsite" at 13.8 kV. This is an ideal distribution voltage for a project of our target size (≤5MW). This eliminates the need for a costly and time-consuming line extension from a substation, which is a primary driver of project failure.
• Substation & Feeder: The feeder likely originates from the Crystal Lake substation (1.7 miles away). While the substation distance is noted, the key factor is the capacity of the specific 13.8 kV feeder at the project location. A pre-application report must be filed with the interconnecting utility (likely National Grid) to obtain data on feeder load, fault duty, and hosting capacity.
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• Cost & Timeline: With an onsite POI, interconnection costs will be dominated by the main transformer, switchgear, and any required utility upgrades (e.g., re-conductoring, protection system updates) identified in the system impact study, rather than line construction. A preliminary cost estimate is in the $750k - $2.0M range. The interconnection queue process in Massachusetts (ISO-NE territory) is notoriously long; we should budget for a 24-36 month timeline from application to commercial operation.
• Utility: The utility is not named but is almost certainly National Grid. We must engage their interconnection team early to understand their specific requirements and current queue backlog.

4. Regulatory & Zoning Analysis

Evaluation: The site's zoning is highly favorable, suggesting a straightforward permitting path. However,