⚡ 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 2.12-acre parcel presents a compelling opportunity due to its grid infrastructure and zoning, but carries notable risks related to environmental unknowns and project economics.

1. Site Access & Topography

Road Access & Feasibility: The property has direct frontage on Fredette Street, which is a public road within an established industrial park. Based on satellite imagery review, the road appears to be paved and sufficiently wide to accommodate heavy haul trucks. Access from major regional routes, such as MA-2, is straightforward, which is critical for minimizing transportation logistics costs and complexities.

Terrain & Equipment Access: The site's historical use as a "Truck Terminal" and its "Good" buildability rating strongly suggest the terrain is predominantly flat, graded, and likely compacted. This is a significant advantage, as it will minimize the need for extensive civil work and site preparation. We anticipate no major issues with delivering and placing heavy equipment, including multi-ton transformers, switchgear, and containerized BESS units. The existing curb cuts and potential for a wide construction entrance are favorable.

Easement Concerns: While the Point of Interconnection (POI) is listed as "Onsite," a title search is required to identify any existing utility or access easements that may encumber the property. An unknown easement could conflict with the optimal BESS layout, potentially sterilizing buildable area or complicating construction access. This must be verified before finalizing site design.

2. Environmental Constraints

FEMA Flood Zone: The property's flood zone designation is currently Unknown. This represents a critical data gap and a potential fatal flaw. A desktop review using the FEMA Flood Map Service Center must be conducted immediately. If the site is located within a Special Flood Hazard Area (e.g., Zone A or AE), development costs would increase substantially due to requirements for elevating all equipment above the Base Flood Elevation, and permitting could become significantly more complex.

Wetlands: The presence of wetlands is also Unknown. Massachusetts has stringent wetland protection regulations under the Wetlands Protection Act, which typically enforces a 100-foot buffer zone from delineated wetland resources. Given the industrial nature of the area, the risk may be lower, but a desktop screening using MassGIS (MassMapper) is an essential first step. If potential wetlands are identified, a formal wetland delineation by a certified professional will be required, which could impact the buildable area and project timeline.

Habitat & Contamination: The site shows no evidence of critical habitat, protected species, or proximity to protected areas, which is a significant positive. Furthermore, its location outside of any known brownfield or superfund sites (within a 2-mile radius) mitigates environmental liability risks. However, this also means the project is ineligible for the 10% IRA Brownfield ITC adder, which is a commercial disadvantage. A Phase I Environmental Site Assessment (ESA) is still recommended as standard practice for any industrial property to ensure no unrecognized environmental conditions exist from its past use as a truck terminal.

Other Constraints: The site is not within the Chesapeake Bay Critical Area (N/A for MA). The lack of any pipelines within a 3-mile radius is a major safety and design benefit, eliminating concerns related to pipeline setbacks and explosion risk.

3. Grid Infrastructure & Interconnection

Grid Proximity & Voltage: This is the site's most compelling attribute. The data indicates the Point of Interconnection is Onsite at a voltage of 13.8 kV. This is an ideal distribution-level voltage for a project of our target size (≤5MW). It implies a 3-phase distribution feeder runs along Fredette Street or directly abuts the property line. The nearest substation, Crystal Lake (1.7 miles away), has a 69 kV bus, confirming it is a source for the local 13.8 kV distribution network. The absence of transmission lines within 3 miles confirms this is exclusively a distribution-interconnection opportunity.

Interconnection Cost & Timeline: An onsite POI dramatically reduces interconnection risk and cost. It eliminates the need for a costly and time-consuming line extension, which can often run into millions of dollars. The primary interconnection costs will be for the project-side switchgear, protection and control systems, and utility-side upgrades at the POI. We estimate a preliminary cost range of $300,000 - $850,000, subject to the utility's system impact study. The interconnecting utility is National Grid. The interconnection process will follow the Massachusetts DPU and ISO-New England (ISO-NE) tariffs. Queue times for distribution projects in MA can be lengthy, often 18-36 months from application to commercial operation. A key unknown is the available hosting capacity on the specific feeder; a pre-application report is essential to assess this.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the City of Gardner. The parcel is zoned IND2 (Heavy Industrial), with a current land use designation of "Truck Terminal." This zoning is highly advantageous for a BESS project, as energy infrastructure is typically a compatible use in heavy industrial districts. This should streamline the permitting process and reduce the risk of opposition from abutters, as the surrounding area is of a similar