⚡ 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 Street in Gardner, Worcester County, Massachusetts. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

Road Access & Feasibility: The property benefits from public road access via Fredette Street, an industrial thoroughfare. A preliminary review of satellite imagery indicates this road is paved and appears sufficiently wide to accommodate oversized and overweight vehicles, including flatbed trucks for battery containers, switchgear, and a main power transformer. Access to major regional highways, such as MA-2, is straightforward, which is a significant logistical advantage for both construction and long-term operations and maintenance.

Terrain & Buildability: Located in an established industrial area, the 2.12-acre parcel is expected to be relatively flat and previously graded, consistent with the "Good" buildability rating in the provided data. This significantly reduces the need for extensive civil work, lowering site preparation costs. The site appears clear of major obstructions, though a physical site walk is required for confirmation.

Heavy Equipment & Easements: Given the industrial zoning and favorable topography, access for critical heavy equipment like a 100-ton crane for transformer placement is anticipated to be feasible. The "POI Onsite" designation suggests utility infrastructure is immediately adjacent, minimizing the need for extensive on-site trenching or overhead line construction. A critical next step is to perform a title search to identify any existing utility or access easements that could encumber the property and constrain the BESS layout.

2. Environmental Constraints

Flood Zone & Wetlands: The FEMA flood zone and wetlands status are currently marked as "Unknown." These represent the most significant environmental risks to the project.

• Flood Risk: A high-priority action is to review FEMA's Flood Insurance Rate Maps (FIRMs) for this parcel. If located within a Special Flood Hazard Area (e.g., Zone A or AE), development could be prohibited or require costly mitigation, such as elevating all equipment pads above the Base Flood Elevation, severely impacting project economics.
• Wetlands Risk: Massachusetts has stringent wetland regulations under the Wetlands Protection Act. A desktop screening using MassGIS data is required immediately, to be followed by a formal wetland delineation by a certified professional if potential wetlands are identified. The presence of jurisdictional wetlands could impose 100-foot buffer zones, which would substantially reduce the buildable area of this 2.12-acre site.

Contamination & Brownfield Status: The presence of 13 known brownfield/superfund sites within a two-mile radius is a notable concern. This elevates the risk that the subject parcel may have historical contamination from prior industrial use. However, it also presents a significant opportunity.

• Risk: Undiscovered contamination could lead to costly remediation and project delays.
• Opportunity: If the site can be officially classified as a "brownfield site" per IRA guidelines, the project would be eligible for a 10% ITC adder. A Phase I Environmental Site Assessment (ESA) is a mandatory, near-term due diligence item to assess this risk and opportunity.

Other Constraints: The data indicates no critical habitats, protected areas, or pipelines nearby, which are all positive findings that de-risk the project from these specific environmental and safety standpoints.

3. Grid Infrastructure & Interconnection

Interconnection Feasibility: Grid access is the single strongest attribute of this site. The designation of "POI Onsite" at a 13.8 kV distribution voltage is exceptionally favorable for a distribution-scale (≤5MW) project. This implies a 3-phase distribution feeder is directly on or adjacent to the property line, potentially eliminating the need for any significant and costly line extension work.

Substation & Utility: The nearest substation, Crystal Lake (1.7 miles), is a 69 kV/distribution substation. The interconnecting utility is almost certainly National Grid, the incumbent utility for