⚡ 91 FREDETTE ST

MEMORANDUM

TO: Sunland America Corp. Development Team

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 analysis evaluates the site's suitability for a distribution-scale (≤5MW) Battery Energy Storage System (BESS) project based on key development criteria. The findings indicate a highly promising site, primarily due to its exceptional grid access and favorable zoning, though critical environmental diligence is required.

1. Site Access & Topography

Road Access: The property benefits from direct access via Fredette Street, which is listed as a public road. A preliminary review of aerial imagery confirms this is a paved, industrial-grade road capable of supporting heavy truck traffic. This is a significant advantage for both construction and long-term operations and maintenance (O&M).

Equipment Delivery: The existing road infrastructure appears adequate for the delivery of heavy and oversized equipment, including BESS containers (typically 40-53 ft), medium-voltage transformers, and switchgear. The site's prior use as a truck terminal suggests that turning radii and road capacity are unlikely to be constraints. However, a formal route survey should be conducted prior to financial close to confirm bridge weight limits and clearance heights from the nearest major highway (likely MA Route 2).

Topography & Buildability: The site is rated as having "Good" buildability and is located in a developed industrial area. This strongly suggests the terrain is predominantly flat and cleared, minimizing the need for extensive civil work and grading. The 2.12-acre parcel size is sufficient for a 5 MW / 10 MWh BESS, including required balance-of-plant, access roads, and potential stormwater management features. The exact buildable area is pending environmental review.

Easements: The data indicates "POI Onsite," which implies the point of interconnection is on the parcel itself, likely via an overhead utility pole. This dramatically reduces or eliminates the need for a lengthy and complex gen-tie easement negotiation with third parties. Standard access and utility easements should still be confirmed via a title search.

2. Environmental Constraints

Flood & Wetlands: FEMA Flood Zone and wetlands status are both listed as "Unknown." This represents a primary diligence risk. Any presence of a designated floodway, 100-year floodplain (Zone AE), or state/federal jurisdictional wetlands could significantly reduce the buildable acreage and increase permitting complexity and costs. A desktop environmental screening and subsequent wetland delineation are immediate priorities.

Brownfield/Superfund Status: The presence of 13 known brownfield or superfund sites within a two-mile radius is a critical finding. This presents both a risk and a significant opportunity.

• Risk: The subject parcel itself could have legacy contamination from its past industrial use (truck terminal), which could trigger costly remediation requirements under the Massachusetts Contingency Plan (MCP).
• Opportunity: If the site can be officially classified as a "brownfield site" per IRA guidelines, the project would be eligible for the 10% Brownfield ITC adder. This potential financial upside warrants immediate investigation.

Habitat & Protected Species: The data indicates no critical habitat or protected areas on or immediately adjacent to the site. Given its location in a developed industrial park, the risk of encountering endangered species that would halt development is considered very low. This should be confirmed via the MassGIS OLIVER mapping tool and a consultation with the MA Natural Heritage & Endangered Species Program (NHESP).

Other Considerations: The site is not within the Chesapeake Bay Critical Area (N/A for Massachusetts). No pipelines or gas wells are in the immediate vicinity, eliminating setback and safety concerns related to those features.

3. Grid Infrastructure & Interconnection

Interconnection Point: This is the site's strongest attribute. The data confirms a "POI Onsite" at a distribution voltage of 13.8 kV. This is ideal for a distribution-scale BESS project, as it avoids the high costs, long timelines, and complex studies associated with transmission-level or substation-level interconnections.

Feeder & Substation: The 13.8 kV line is likely a distribution feeder originating from the nearest substation, Crystal Lake (1.7 miles away, 69 kV max voltage). The project would interconnect directly to this feeder. The utility is not named but is almost certainly National Grid, which is the incumbent provider in Gardner, MA.

Cost & Timeline: A direct 13.8 kV feeder tap is the most cost-effective interconnection method. Estimated costs would primarily be for the utility-required recloser, switchgear, metering, and SCADA integration. This could range from $300,000 to $750,000, a fraction of a multi-million-dollar substation build. Timelines are also significantly shorter, typically 12-18 months from application submission to commercial operation, compared to 3-5+ years for transmission.

Utility Process: In Massachusetts, National Grid's interconnection process is governed by the state's tariff (ESB 756). The queue is managed on a timeline basis. Given the high volume of applications in Massachusetts, queue position is critical. A pre-application report should be filed immediately to get a preliminary assessment of feeder capacity and potential upgrade costs before committing to a full Interconnection Application.

4. Regulatory & Zoning Analysis

Authority Having Jurisdiction (AHJ): The City of Gardner, MA.

Zoning: The parcel is zoned IND2 (Heavy Industrial), and its current land use is listed as "Truck Terminal." This is highly favorable for BESS development. Industrial zones are generally the most permissive for utility and energy infrastructure.

Permitting Pathway: The specific pathway requires verification with the Gardner Planning Department. Given the zoning, the likely pathways are:

• By-Right: If BESS is considered a permitted use under "utility facility" or a similar category. This is the best-case scenario.
• Special Permit: More likely, the project will require a Special Permit from the Planning Board. This involves a public hearing process but is a standard and predictable pathway for well-designed projects in an industrial zone.

A variance is highly unlikely to be needed. We must review the City of Gardner's Zoning Bylaws to determine if they have specific ordinances for Battery Energy Storage Systems. Many Massachusetts municipalities have adopted or are adopting such bylaws, often based on the state's model bylaw.

Setbacks & Restrictions: Setback requirements for the IND2 zone must be confirmed. Additionally, we must check for any local moratoriums on BESS development, though none are publicly known for Gardner at this time. Compliance with Massachusetts fire safety regulations, including NFPA 855, will be a key component of the permit application.

5. IRA/ITC Incentive Analysis

Base ITC: The project is eligible for the 30% base Investment Tax Credit.

Adders:

• Opportunity Zone: No (0% adder).
• Energy Community: No (0% adder).
• Low-Income Community: No (0% adder).

The site does not qualify for the location-based 10% adders for Energy Communities or the 10-20% adders for Low-Income Communities.

Brownfield Adder: The key potential incentive is the 10% Brownfield adder. As noted in the environmental section, the site's proximity to numerous brownfields and its own industrial history make this a plausible opportunity. To qualify, the site must meet the definition in 42 U.S.C. § 9601(39). This requires, at a minimum, a Phase I Environmental Site Assessment (ESA).

Potential Cumulative ITC:

• Without Brownfield Adder: 30%
• With Confirmed Brownfield Status: 40%

This 10% delta represents a significant impact on project economics and must be a top diligence priority.

6. BESS Score & Rationale

Overall BESS Suitability Score: 75/100

• Location (15/20): Sited in an ideal industrial zone, minimizing community opposition. Lack of community-based IRA adders prevents a higher score.
• Grid Access (24/25): Near-perfect score. A 13.8 kV POI on the parcel itself is a massive de-risking factor, saving millions in cost and years in schedule compared to a typical site. The only unknown is feeder capacity.
• Environmental (10