⚡ 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 is being evaluated for its suitability for a distribution-scale Battery Energy Storage System (BESS) of up to 5MW. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory pathways, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property benefits from direct frontage on Fredette Street, which is a publicly maintained road. A preliminary review of aerial imagery indicates Fredette Street is an industrial-grade road, sufficiently wide and paved to handle heavy truck traffic. It connects readily to major local thoroughfares, suggesting a straightforward route for equipment delivery from regional highways.

Terrain & Equipment Access: Located within an established industrial area, the site appears to be relatively flat and graded, which is highly advantageous for minimizing civil engineering costs. The "Good" buildability rating supports this assessment. Access for oversized and overweight vehicles, such as flatbeds carrying battery containers, inverters, and medium-voltage transformers, appears feasible. However, a detailed logistics plan should confirm turning radii from public roads onto the site entrance. The 2.12-acre lot size provides adequate space for staging and construction laydown, assuming setbacks are manageable.

Easement Concerns: The data indicates the Point of Interconnection (POI) is "Onsite," which significantly reduces the need for off-site access easements for electrical infrastructure. Nonetheless, a full title report is a critical next step to identify any pre-existing utility, access, or drainage easements that could encumber the buildable area or restrict equipment placement.

2. Environmental Constraints

Flood & Wetlands: The FEMA flood zone and wetlands status are currently marked as "Unknown." These represent the most significant environmental data gaps and potential fatal flaws. Requires Verification: An immediate desktop review using the FEMA Flood Map Service Center and MassGIS OLIVER wetlands layer is required. If the site is within a Special Flood Hazard Area (e.g., Zone A, AE), all equipment pads would need to be elevated above the Base Flood Elevation, adding substantial cost. If state or federal jurisdictional wetlands are present, development would be constrained by mandatory buffer zones (typically 100 feet in MA), which could severely limit the buildable envelope on a 2.12-acre parcel.

Brownfield/Superfund Status: The presence of 13 known brownfield or superfund sites within a two-mile radius is a major finding. This presents both a risk and a potential opportunity. The risk is that the subject parcel itself may have historical contamination from surrounding industrial uses, which would require costly remediation. A Phase I Environmental Site Assessment (ESA) is non-negotiable. Conversely, if the site meets the federal definition of a brownfield, it could qualify as an "Energy Community" under the Inflation Reduction Act (IRA), unlocking a valuable 10% Investment Tax Credit (ITC) adder. This potential must be investigated thoroughly.

Habitat & Other Factors: The site is clear of designated critical habitats and protected areas, which is a positive screening result. Proximity to pipelines and gas wells is not a concern. The property is not located within the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Grid Proximity & Voltage: This site is exceptionally well-positioned for a distribution-scale project. The data confirms an "Onsite" Point of Interconnection at a voltage of 13.8 kV. This indicates a three-phase distribution feeder, likely operated by National Grid (the primary utility in Gardner), is immediately adjacent to or crosses the property. This eliminates the need for a costly primary distribution line extension, which is often a major barrier for BESS development. The nearest substation, Crystal Lake (69 kV max voltage), is 1.7 miles away, which is a reasonable feeder length that suggests available capacity may exist, though this must be confirmed through a formal study.

Interconnection Pathway & Cost: The interconnection will be at the distribution level (13.8 kV), aligning perfectly with our company's