⚡ 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: The property has direct frontage on Fredette Street, which is a public road within an established industrial park. Initial review of aerial imagery indicates this road is paved and appears capable of supporting heavy truck traffic. This is a significant advantage for the delivery of heavy equipment.

Topography & Equipment Feasibility: The site's current use as a truck terminal and its location in an industrial area suggest that the terrain is likely flat and graded, which is ideal for BESS construction. The "Good" buildability rating in the provided data supports this assessment. We anticipate no major issues with delivering and placing heavy equipment such as 40-foot battery containers, medium-voltage transformers, and switchgear. A formal geotechnical survey will be required to confirm soil bearing capacity, but initial indicators are positive.

Easement Concerns: The data indicates "POI Onsite," which strongly suggests a utility easement already exists on or abutting the property. This is highly favorable. However, a full title search is a critical next step to identify the exact location and rights associated with this easement, and to uncover any other potential encumbrances (e.g., access easements for other parcels, drainage easements) that could constrain the site layout.

2. Environmental Constraints

FEMA Flood Zone & Wetlands: The flood zone and wetlands status are currently marked as "Unknown." These are the most significant near-term environmental risks. Any presence of FEMA-designated floodplains (especially Zone AE) or state/federal jurisdictional wetlands would introduce substantial permitting challenges, costly civil engineering work (e.g., raising all equipment pads above the Base Flood Elevation), and potentially fatal flaws if required setbacks cannot be met on the 2.12-acre parcel. Immediate desktop screening using MassGIS and FEMA's Map Service Center is required, followed by a field delineation if initial screening indicates risk.

Brownfield/Superfund Status: The presence of 13 known brownfield or superfund sites within a two-mile radius is a major flag. While the subject property is not explicitly listed, its location in a heavy industrial zone and proximity to other contaminated sites creates a moderate to high risk that it may have Recognized Environmental Conditions (RECs). This presents both a risk and an opportunity.

• Risk: Potential soil or groundwater contamination could require costly remediation and create project delays and long-term liability.
• Opportunity: If the site qualifies as a brownfield per IRA guidelines, the project would be eligible for the 10% Energy Community ITC adder, significantly improving project economics. A Phase I Environmental Site Assessment (ESA) is an urgent priority to assess this.

Other Constraints: The site has no identified critical habitats, protected areas, or nearby pipelines, which are all positive findings that de-risk the project from these specific environmental perspectives. The Chesapeake Bay Critical Area is not applicable in Massachusetts.

3. Grid Infrastructure & Interconnection

Grid Proximity & Voltage: This site exhibits exceptional grid access characteristics. The Point of Interconnection (POI) is listed as "Onsite" at a voltage of 13.8 kV. This is an ideal distribution-level voltage for a project of this scale (≤5MW). The presence of an onsite POI eliminates the need for a costly and time-consuming line extension, which is often a primary driver of interconnection cost. The nearest substation, Crystal Lake (1.7 miles, 69 kV), is reasonably close, suggesting the local distribution network is robust.

Interconnection Cost & Timeline: With an onsite POI, the direct interconnection costs could be significantly lower than average, potentially in the $400k - $900k range for protection upgrades, reclosers, and switchgear, as opposed to the $1.5M+ often seen with line extensions. The primary risk is not cost, but timeline. The interconnecting utility (Requires Verification, but likely National Grid in this area) and ISO-New England have notoriously long interconnection queues. Even with a simple interconnection, the study process can take 18-36 months. Submitting an Interconnection Application to secure a queue position is paramount.

Feeder Configuration: The 13.8 kV POI is almost certainly a 3-phase distribution feeder running along Fredette Street, either overhead or underground. This is the standard and preferred configuration for a BESS project of this size.

4. Regulatory & Zoning Analysis

Jurisdiction & Zoning: The Authority Having Jurisdiction (AHJ) is the City of Gardner. The property is zoned IND2 (Heavy Industrial), and its prior use is listed as a truck terminal. This is highly favorable zoning for a BESS project, which is often considered a light industrial or public utility use. Compatibility issues are expected to be minimal.

Permitting Pathway: Given the IND2 zoning, the likely permitting pathway is either by-right (least burdensome) or, more likely, requiring a Special Permit from the Gardner Planning Board. A Special Permit process involves public hearings but is a standard and predictable process for compatible uses. A variance should not be required. We must obtain and review the