⚡ 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, Massachusetts. The site is a 2.12-acre parcel currently zoned for heavy industrial use. The analysis indicates a promising candidate for a distribution-scale BESS project (≤5MW), primarily due to exceptional grid access and favorable zoning. However, significant environmental unknowns must be resolved before committing further resources.

1. Site Access & Topography

Road Access: The site benefits from public road access via Fredette Street. Given the parcel's zoning as "Heavy Industrial" and "Truck Terminal," existing road infrastructure is presumed to be robust and designed to accommodate heavy commercial vehicles, including semi-trucks. This is a significant advantage for the delivery of large, heavy equipment such as battery containers, pad-mount transformers, and switchgear.

Topography & Feasibility: Based on aerial imagery and the industrial nature of the area, the site is expected to be relatively flat and previously graded, consistent with its "Good" buildability rating. This should minimize civil engineering costs associated with site preparation. The 2.12-acre lot provides adequate space for a 5MW/10MWh BESS footprint, including necessary setbacks, access roads, and stormwater management features, though a detailed site layout is required to confirm. The primary constraint will be optimizing the layout on a relatively compact parcel.

Equipment Access & Easements: Direct access from Fredette Street appears straightforward. The "POI Onsite" data point suggests that no off-site easements for electrical conduit will be necessary, which dramatically simplifies development. However, a full title report is required to verify that no restrictive covenants or prohibitive access or utility easements encumber the property. We must confirm clear, unencumbered access for both construction and ongoing operations and maintenance.

2. Environmental Constraints

Flood & Wetlands: The FEMA flood zone and wetlands status are both listed as "Unknown." These represent the most significant near-term risks. Development within a designated floodway (AE) or floodplain (A) could render the project infeasible or add substantial costs for elevating equipment. Similarly, the presence of state or federally protected wetlands could impose prohibitive setbacks, reducing the buildable area below what is required. A desktop screening using FEMA FIRM panels and the National Wetlands Inventory (NWI) is an immediate priority, to be followed by a formal wetland delineation if screening indicates potential risk.

Brownfield/Superfund Status: The presence of 13 known brownfield or superfund sites within a two-mile radius is a critical finding. While this could indicate a risk of on-site contamination requiring remediation, it also presents a major opportunity. Under the Inflation Reduction Act (IRA), a project sited on a qualifying brownfield can receive a 10% Investment Tax Credit (ITC) adder. The proximity of other sites increases the likelihood that this parcel may qualify. A Phase I Environmental Site Assessment (ESA) is essential to determine if the site meets the federal definition of a brownfield (per 42 U.S.C. § 9601(39)), which is a crucial step for the project's financial model.

Other Constraints: The site shows no risk related to critical habitats, protected areas, or proximity to pipelines or gas wells. As the site is in Massachusetts, the Chesapeake Bay Critical Area regulations do not apply. Overall, the environmental profile is manageable, pending resolution of the flood, wetland, and brownfield questions.

3. Grid Infrastructure & Interconnection

Interconnection Point: The data indicates a "POI Onsite" at a voltage of 13.8 kV. This is an ideal scenario for a distribution-scale BESS. It signifies that a three-phase distribution feeder from the local utility (National Grid, which serves Gardner, MA) is directly on or adjacent to the property boundary. This eliminates the need for costly line extensions, which can often kill project economics. The likely configuration is an overhead line running along Fredette Street.

Substation & Capacity: The nearest substation, Crystal Lake, is 1.7 miles away with a max voltage of 69 kV. This is a reasonable distance, suggesting the 13.8 kV feeder originating from this substation may have available capacity. However, feeder capacity is not guaranteed. The key risk is whether the circuit can accommodate a 5MW injection of power without requiring significant and expensive upgrades at the substation or on the feeder itself (e.g., reconductoring). A formal interconnection application and subsequent System Impact Study (SIS) from National Grid will be required to confirm this.

Cost & Timeline: With an onsite POI, interconnection costs should be on the lower end, estimated between $350,000 and $850,000. This would cover the utility-required switchgear, protection and control systems, SCADA integration, and study fees. This is substantially lower than projects requiring multi-mile line extensions. The interconnection process in ISO-New England, managed by utilities like National Grid, can be lengthy, often taking 18-24 months from application to an Interconnection Service Agreement (ISA). Early engagement with the utility is critical.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the City of Gardner. The parcel is zoned IND2 (Heavy Industrial), which is highly compatible with a BESS facility, often considered a light industrial or utility use. The existing land use designation of "Truck Terminal" further supports the appropriateness of this location for industrial infrastructure.

Permitting Pathway: Given the IND2 zoning, a BESS is unlikely to be permitted "by-right." The most probable pathway is a Special Permit or Site Plan Review from the Gardner Planning Board. This process is generally manageable and predictable, involving public hearings and review of site plans, safety protocols (including NFPA 855 compliance), and environmental impacts. A zoning variance should not be required. We must engage a local permitting consultant to review the City of Gardner's zoning bylaws to confirm the exact process, setback requirements, and any specific ordinances related to battery storage.

Risks: While the zoning is favorable, there is always a risk of local opposition or the future imposition of a municipal moratorium on BESS development, although this is less likely