⚡ 91 FREDETTE ST

MEMORANDUM

TO: Sunland America Corp. Investment 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 the subject property. The analysis covers key development pillars including site characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives under the Inflation Reduction Act (IRA).

1. Site Access & Topography

Road Access: The property benefits from direct access via Fredette Street, which is a public road. Given the site's zoning as "Heavy Industrial" and its historical use as a "Truck Terminal," Fredette Street is presumed to be constructed to a standard capable of handling heavy truck traffic. This is a significant advantage for the delivery of large and heavy BESS equipment.

Terrain & Equipment Feasibility: While a formal topographic survey is required, the "Good" buildability rating and visual inspection of the area via satellite imagery suggest the site is relatively flat with minimal grade changes, consistent with properties developed for industrial use. This indicates that site preparation and civil work costs should be manageable. Access for oversized and overweight vehicles, including flatbed trucks for battery containers, a crane for setting the main power transformer, and concrete trucks for foundations, appears to be straightforward.

Easement Concerns: A primary advantage is the "POI Onsite" data point, which suggests the grid interconnection point is at the property boundary. This would eliminate the need for complex and costly off-site access easements for a new distribution line. However, a full title report is a necessary next step to verify that there are no existing utility easements, access restrictions, or other encumbrances that could conflict with the proposed BESS layout.

2. Environmental Constraints

Flood Zone & Wetlands: The FEMA flood zone and presence of wetlands are currently marked as "Unknown." These represent the most significant environmental risks. Immediate verification is required. A site located within a Special Flood Hazard Area (e.g., Zone A, AE) would necessitate elevating all equipment above the Base Flood Elevation, adding substantial cost and complexity. Similarly, the presence of state or federally regulated wetlands could trigger significant setback requirements (typically 50-100 feet in Massachusetts), which would reduce the buildable area on this relatively small 2.12-acre parcel. A desktop screening using FEMA and National Wetlands Inventory (NWI) maps is the immediate next step.

Brownfield/Superfund Status: The data indicates 13 Brownfield or Superfund sites within a two-mile radius. This presents both a potential opportunity and a risk.

• Opportunity: If this specific parcel can be classified as a "brownfield site" under the IRA's definition, the project could be eligible for a 10% ITC adder. This would require a Phase I Environmental Site Assessment (ESA) to confirm historical contamination.
• Risk: If the Phase I ESA identifies Recognized Environmental Conditions (RECs), a Phase II ESA may be required. Discovery of significant contamination could lead to costly remediation requirements and project delays. Given the industrial history, this risk is moderate to high.

Other Constraints: The site is favorably clear of Critical Habitat, Protected Areas, and nearby pipelines, significantly de-risking the project from a species and safety perspective. The project is not located in the Chesapeake Bay Critical Area.

3. Grid Infrastructure & Interconnection

Interconnection Point & Feeder: The data presents a critical conflict that must be resolved. It indicates "POI Onsite" but also lists the nearest substation (Crystal Lake) as 1.7 miles away. The most likely and favorable scenario is that a 13.8 kV distribution feeder originating from Crystal Lake Substation runs directly along Fredette Street, making the Point of Interconnection (POI) truly "onsite." This would dramatically reduce interconnection costs. The alternative, a 1.7-mile line extension, would likely render a project of this scale economically unviable. The interconnecting utility (ID: 38cc5e9a-3437-4974-ba4f-eb0a6dceb1f6) is presumed to be National Grid, the incumbent utility for Gardner, MA. The likely feeder configuration is a 3-phase overhead line.