⚡ 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.

1. Site Access & Topography

Road Access & Feasibility: The property benefits from public road access on Fredette Street. A preliminary review of satellite imagery indicates Fredette Street is an industrial-grade road connected to major local arteries, suggesting it is well-suited for heavy vehicle traffic. The current land use designation as a "Truck Terminal" strongly supports the conclusion that the access infrastructure is robust and capable of handling the delivery of heavy BESS equipment.

Terrain & Equipment Access: Located in central Massachusetts, the regional topography can be varied. However, given the parcel's history as a truck terminal and its "Good" buildability rating, it is highly probable that the 2.12-acre site is already graded and relatively flat, minimizing the need for extensive civil work. Access for large cranes, transformers, and containerized battery systems appears to be straightforward, which is a significant advantage for construction logistics and cost control.

Easement Concerns: The provided data does not include information on existing easements. This is a critical unknown. A full title search must be commissioned to identify any utility, access, or conservation easements that could encumber the property and constrain the BESS layout. The presence of an on-site Point of Interconnection (POI) suggests a utility easement likely already exists.

2. Environmental Constraints

Flood & Wetlands: The FEMA Flood Zone and Wetlands status are both listed as "Unknown." These are critical, potentially fatal-flaw risks. Immediate desktop analysis using FEMA's Map Service Center and the U.S. Fish and Wildlife Service's National Wetlands Inventory (NWI) is required. If either screening indicates risk, a formal field-level flood elevation certificate and/or wetland delineation will be necessary. Development within a designated floodway is typically prohibited, and development within a floodplain or wetland buffer area would trigger significant permitting hurdles and costly mitigation under both federal and Massachusetts state law (e.g., the Massachusetts Wetlands Protection Act).

Habitat & Species: The site is clear of designated critical habitats and protected areas, which significantly de-risks the project from a wildlife and ecological permitting perspective. A final check with the MA Natural Heritage & Endangered Species Program (NHESP) database is recommended as a final confirmation.

Brownfield/Superfund Status: The presence of 13 brownfield or superfund sites within a two-mile radius presents both a risk and a major opportunity.

• Risk: The subject parcel could have legacy contamination from its industrial use or from migrating contaminants from nearby sites. A Phase I Environmental Site Assessment (ESA) is non-negotiable to assess this risk.
• Opportunity: If the Phase I ESA identifies recognized environmental conditions on our parcel, it may qualify as a "brownfield site" under IRA guidelines. This would make the project eligible for a 10% Investment Tax Credit