Professional report, Dimension D1, Site and constraints

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D1, site location, suitable areas and landscape-environmental constraints Professional: Nestore Calandra, Land Surveyor (Agent A7, Technical unit) Mode: offensive, buyer side Evidence base: 14 record sheets across 14 P1 documents extracted from the VDR (ED_07 landscape reports, landscape decisions, EG_02/03/04 constraints analyses), consolidated in archivio/D1_consolidato.json, combined with the output of the geo engine (Collemurgia golden, docs/specs/2026-06-03-golden-geo-collemurgia-report.md)

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1. Mandate and scope

I am entrusted with the first question that arises on any energy dossier: where does the plant really sit, on which parcels, and inside or outside the constraints? I am the first to touch the site on the territorial level, and my task on D1 is to establish whether the Collemurgia Cluster is located within a real suitability regime and whether the constraints burdening the areas are prohibitive, managed or still open.

The question that governs my analysis, from a buyer perspective, is this: is a plant set squarely in the Murgia dei trulli, a context with an extremely high density of protected assets, located on a suitable area and with constraints resolved, or is the project sold as compatible without compatibility having been assessed where it counts?

I stay within the boundaries of D1. I do not compute the verdict, I do not aggregate the other dimensions, I do not issue regulated landscape advice: I produce decision support for the investor. I query the geo engine only via motore_api. Where the constraint moves from the cartographic plane to the environmental opinion I bring in A12 (Remo Bacchetti); where the site depends on the substation and the connection route I bring in A5 (Dario Pestarino). The merits of those dimensions are not mine.

2. What I examined

I read the ED_07 landscape reports (43-50 pages, read in their first 20: framing and constraints summary), the three landscape decisions, the EG_02/EG_03/EG_04 constraints analyses and the suitable-areas picture. Fourteen P1 documents out of fourteen extracted, one via local OCR. EG.02 PPTR “compressed” is an image-only PDF and its record sheet remains thin: I treated it as such and did not promote to fact what I could not read, because the constraints outcome is in any case covered by the three decisions.

On top of this documentary reading I overlaid the output of the geo engine already run on the case (national level P3/P4). The site falls within the Serremonti locality, sheets 51 and 66 of the Municipality of Collemurgia, Murgia dei trulli context. The three SPV sit on land burdened by Additional Landscape Contexts of the PPTR Puglia (dry-stone walls, trulli, olive groves) and close to Natura 2000 Network areas and PAI hazard.

3. The two-level method, and why it is the heart of D1

This is the point on which the whole dimension turns, and it is the rationale I ask the Panel to let me defend at length, because it is here that a superficial analysis produces a false GO or a false veto.

I never close a suitability judgement on the national level alone. The geo engine GeoDB is national: it knows the art.142 constraints, the woodland, the ISPRA PAI, the Natura 2000 Network, but it is blind to the regional landscape plans. An absence in the national database is not an absence of constraint (Collemurgia lesson, ADR-002). That is why I work on two levels:

1. National level (geo engine, P3/P4). I queried the intersection of the national constraints on the site geometry. The national layer agrees with the project declarations: PAI, woodland, art.142 and Natura 2000 are consistent with what is declared in the documents.
2. Per-case regional level (documentary verification). The constraint that really matters here, the UCP PPTR “Rural landscapes”, is not present in the national GeoDB. I do not assert it from memory and I do not treat it as absent: I verify it per-case against the VDR. And the documentary verification found the constraint, and found it already resolved.

The two-level method is validated on the real case: the national level did not see the UCP, the per-case coverage filled the gap and confirmed compatibility. Without this second level I would have given a blind GO; with a poorly set-up second level I would have reproduced the false veto of the synthetic golden.

4. Why V002 does NOT trigger on this case

Here I apply my threshold, and it is the part of the judgement I am keen to justify, because it is exactly the opposite of the synthetic Collemurgia golden (which was a NO-GO from V002).

V002 is the intersection veto: it triggers when the site is shown to overlap an unsuitable area or a prohibitive constraint. On the real case, it does not trigger, for documented reasons:

• The landscape constraint exists, but has been assessed compatible. The UCP PPTR (dry-stone walls, trulli, olive groves) really is there. But the three SPV have already obtained the favourable landscape authorisation with conditions: DET 1487 (R.C.G. 3201/2023) of 04/12/2023 for Blu, DET 1622 (R.C.G. 3540/2023) of 21/12/2023 for Verde, DET 1330 of 16/11/2023 for Giallo. All three favourable. The constraint is not prohibitive: it is managed, with the permit in hand.
• The area is suitable under art.20 of Legislative Decree 199/2021. The site falls within a suitable-area regime (non-prime Db land): the location is in the correct regime, suitability is assessed and not merely declared.
• The national and regional levels converge. P3 flagged no prohibitive intersection, and the per-case regional verification confirmed compatibility, not conflict. I do not have a single national “no intersection” on which to close in a vacuum: I have a consistent national level plus a regional one resolved by a decision.

For this reason, on D1, I do not propose V002. I do, however, hold firm to the caution of offensive mode: compatibility holds as long as the decisions remain intact, valid and not expired at closing, and as long as the landscape conditions are actually complied with. Compatibility is not free: it is a real compliance burden.

5. Specific risks that concern me

1. Cable route and Natura 2000, the still-open point. This is the real residual of D1. The VIA application declares interference of the cable route (PoC 10.881 km) with the Murgia di Sud-Est SAC, while the field reports declare no interference: the two documents do not agree, and no appropriate assessment (VINCA) appears on file. The landscape constraints of the field are resolved; the compatibility of the connection route with Natura 2000 is not. Mandatory cross-flag with A5 (grid connection) and A12 (environmental opinion).
2. Real compliance burden (intersects D6/D7). The landscape conditions are not formalities: restoration of the dry-stone walls by hand using traditional techniques (no mechanical means or binders, PPTR Guidelines 4.4.4), panel spacing to preserve the trulli, hedges and native species that are not Xylella hosts. They are construction and multi-year maintenance charges with an impact on CAPEX/OPEX and on the usable layout. To be quantified on the A6/A8 side.
3. Olive groves and Regional Law 14/2007 (intersects D6). On Giallo the trees are declared non-monumental with an uprooting authorisation obtained. But the Verde agronomic report (ED_10, A12 finding) flags olive trees with monumental characteristics, in tension with the landscape declaration. Monumental status must be confirmed plot by plot, not presumed.
4. PAI on Verde. The constraints analysis flags flood and landslide hazard on Verde; the opinions of the river-basin authority (D3) require the plant to be sited outside the areas floodable with a 200-year return period, splitting the field if necessary. Constraint managed, but with operational conditions on the layout.
5. Giallo file more fragile. The landscape commission had asked Giallo for additional submissions (opinion 41-A/2023 of 17/08/2023) with a risk of dismissal within 60 days; the process closed favourably with DET 1330. No residual issue on D1, but it confirms that the Giallo file is more fragile, consistent with the corrupted ED_03 flagged in D3.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale for each is in sections 3-5.

Finding	Subject	Severity	Score	Confidence	Veto
A7-D1-20260604-001	PPTR/PAI constraints assessed compatible (DET 1487/2451/2132)	green	72	0.80	no V002
A7-D1-20260604-002	Cable route vs Murgia SE SAC, VINCA missing	amber	58	0.60	open question

The lower confidence on the cable route (0.60) honestly reflects that I have a declaration of interference in the VIA application contradicted by the field reports and no VINCA on file: it is a point to verify, not a closed fact. On the cluster finding (0.80) confidence is high because it rests on three documented favourable landscape decisions, not on a cartographic reading of mine.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Final cable-route alignment and interference with the Murgia SE SAC: is there an approved appropriate assessment (VINCA), or a reasoned exclusion? With what mitigations? 2. Confirmation of the non-monumental status of the olive trees uprooted (agronomic report) and uprooting authorisations for all three SPV, not just Giallo. 3. Estimate of the costs of compliance with the landscape conditions (manual dry-stone walls, hedges, trulli spacing) and impact on the layout and on yield (towards D6/D7). 4. Time validity of the landscape authorisations (DET 1487/2451/2132) against the construction schedule.

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Landscape authorisations (DET 2287/2451/2132) intact, valid and not expired at the closing date. 2. Appropriate assessment of the cable route on Natura 2000 concluded positively, or excluded with traceable reasoning. 3. Olive-uprooting authorisations on file for the parcels concerned, with confirmation of non-monumental status.

8. Conclusion

The location of the Collemurgia Cluster is strong in terms of suitability and field-level landscape constraints, with a single open node on the connection route. The area is suitable under art.20, the UCP PPTR and PAI constraints exist but have been assessed compatible with three favourable landscape decisions: on this real case V002 does not trigger, and this is the strong point of D1, exactly the opposite of the synthetic golden.

My judgement: D1 is not a veto, but neither is it closed. It remains to verify the compatibility of the cable route with the Murgia SE SAC, which is the only declared Natura 2000 interference and today lacks a VINCA on file, and it remains to quantify the landscape compliance burden that weighs on CAPEX, OPEX and layout. Landscape compatibility exists and is documented; in offensive mode I do not endorse full suitability until the connection route is cleared of the Natura 2000 risk and until the decisions are confirmed intact at closing. On this I do not compromise.

Nestore Calandra, Land Surveyor Ultimate Big 5 Energy Squad, Technical unit, Agent A7

Professional report, Dimension D2, Grid connection

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D2, electrical connection and network technical solution Professional: Dario Pestarino, Electrical Engineer (Agent A5, Technical unit) Mode: offensive, buyer side Evidence base: 9 record sheets across 9 VDR P1 documents (STMG, connection quotations, acceptance letters and validations, folder 08 CONNESSIONI), consolidated in archivio/D2_consolidato.json, supplemented by the client notes on TICA

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1. Mandate and scope

I was entrusted with assessing the grid connection of the three cluster SPV: establishing whether the plant, at closing, has a realistic, perfected connection title consistent with the declared power, or merely a bundle of accepted quotations that remain paper until the works are in the ground. The question that governs my analysis is one only, and it is the one I put before every dossier: this project is sold as ready to build; is the connection up to that qualification, or is it still a drawing?

I count the kilometres of cable and the megawatts. For me a plant without a realistic connection is a drawing, not an investment. I stay within the boundaries of D2. I do not compute the verdict, I do not aggregate other dimensions, I do not issue regulated technical advice: I produce decision support for the investor. Where the technical fact of the connection touches permitting (cumulation, V001), land availability (cable-route easement) or the business plan (network cost), I flag the intersection and bring in the competent colleagues without invading their merits: A1/R1 for qualifying the veto, A3 for the easements, A8 for the economic impact.

2. What I examined

I read, application by application, the three general minimum technical solutions and the related E-Distribuzione connection quotations, the acceptance letters and the validations: STMG and quotations as native PDFs (E-Distribuzione documents, no OCR needed), 44-47 pages each, of which I read in depth the first 30 where the delivery point, the application codes, the export power and, above all, the shared-works clause reside. The construction detail of the appendices remains in the P2. Single operator E-Distribuzione, connection voltage 20 kV (MV) for all three SPV, three separate applications:

SPV	STMG application	POD	Connection point	Export power	Connection cost	Status
Blu	347144045	IT001E110616902	CP Noci DW00-1-383589 (antenna)	5.10 MW	~€286,000	accepted/validated, works pending
Verde	345008933	IT001E110496800	CP Noci DW00-1-383589	5.05 MW	~€1,741,000	accepted/validated, works pending
Giallo	389125280	IT001E114215431	new antenna substation, existing MV line (different point)	2.25 MW	~€186,000	validated, works pending

Total export power ~12.4 MW, lower than the declared peak power (~14.05 MWp) due to inverter/ILR limit: consistent, it is a project figure, not an anomaly. All connections are classified COMPLEX-type works (art. 10.1 TICA): longer and more costly delivery process, subject to cost top-ups.

3. The decisive point: shared connection point Blu+Verde

This is the heart of my report, and it is a technical fact that I put on record with the utmost clarity because I do not deduce it, I read it in the quotations.

The E-Distribuzione quotations for Blu and Verde explicitly declare “shared works” with each other's application, reciprocally:

• STMG/quotation Blu (347144045): “Works shared with connection application 345008933” (Verde), with joint construction of the Al 185 sqmm buried-cable line.
• Quotation Verde (345008933): “Works shared with other connection application 347144045” (Blu).
• Both indicate the exact same point: Noci Primary Substation, CP DW00-1-383589 TR VE, 20 kV.

Giallo (389125280), by contrast, connects to a different point (new antenna substation on an existing MV line) and the record sheet states sharing = no.

The technical fact, fixed as an engineer: the Blu+Verde pair shares the grid connection point and physically shares the network works (the common Al 185 sqmm cable route towards CP Noci), for about 10.15 MW in total. It is not a generic contiguity: it is the same antenna on the same primary substation, with a single cable line built only once to serve two applications.

And here I stop, and I mark the boundary precisely. The Puglia Region (opinion 30/05/2024, see D3) had indicated as a cumulation criterion, for the purposes of Single Authorisation plus ministerial VIA, plants “if they refer to the same grid connection point… the total combined power would exceed 10 MW”. The shared connection point I establish is exactly that criterion. But I stop at the fact: shared point, shared works, 10.15 MW. Qualifying the V001 veto, that is whether that fact triggers cumulation and with what confidence, is NOT mine: it is the responsibility of A1, R1 and the offensive Panel. I provide them the technical brick, I do not build the permitting wall.

4. Findings and red flags from an offensive angle

Beyond the decisive point, I set out the findings that weigh on the connection regardless of V001, because a prudent buyer must see them all.

1. Connections not yet built. The STMG and the quotations are validated and accepted, but the works are pending delivery. The actual availability of the connection is a commitment, not a completed fact. Since these are COMPLEX works (art. 10.1 TICA), the risk is twofold: schedule (long E-Distribuzione programme) and cost top-up (complex works are by definition subject to balancing charges). Whoever buys RTB buys an available connection, not a promise of availability.

2. Cable-route easements not established. The Blu quotation flags the need to enter into a dedicated easement for the buried line over public road and private access. It is an additional land dependency, not perfected, that intersects D5/D8 (A3 and A2): without the easement, the shared cable route is not laid. I pass it to A3 as a connection data point that generates a land charge.

3. Connection cost heavily skewed to Verde. About €1.74M on Verde against ~€286k on Blu and ~€186k on Giallo. Verde effectively bears the new substation and the shared works: it is the technical reading consistent with the fact that Blu and Verde share the work but the quotation charges it to Verde. Total connection cost of the cluster ~€2.2M. The client notes suggest a reduction by self-performing the works (Enel cost ~€1.8M reducible to ~€1.2M with a TICA refund ~€300k): it is a credible lever, but it remains to be proven and must be reflected in the business plan, today absent (cross D7, A8).

4. Time validity of the technical solutions. The Giallo STMG has limited validity (210 days). The non-expiry and the currency of the documents must be verified at closing: an expired quotation is a connection to renegotiate from scratch.

5. POD-site-power consistency. The three POD are distinct and consistent with the three delivery points; the export powers (5.10 + 5.05 + 2.25 MW) are consistent with the peak power and with the inverter limit. On this I have no finding: the connection design is solid. The problem is not how the connection is designed, it is that it is not yet in the ground and that its geometry feeds a permitting node.

5. Rationale on the threshold and on the scope of my finding

I want to give at length the reasons why my technical finding, on this dossier, stops where it stops, because it is the part of the judgement I ask the Panel to let me defend.

I establish a high-confidence fact: the connection point is shared, the works are shared, the data is written in the E-Distribuzione quotations, not inferred. On this my confidence is full. What I do NOT do, and must not do, is decide whether that fact is enough to trigger V001. The rule of our framework is clear: A5 PROPOSES, it does not trigger the veto (only R1a does). And qualifying the cumulation depends on elements that are not within my technical competence but legal-permitting: whether the PAS regime under art. 22-bis holds, the regional reversal that brought the projects back to that regime, the publication of the permits in the BUR Puglia (April 2025) and the running of the 120 days for objections.

On this last point I honestly record the mitigating element that the consolidation has taken on board: the permits have been published and the 120 days for objections have run, so the circumvention is no longer verifiable against the project by an authority. This, in the consolidation (Reading A), lowered the confidence in the circumventing substrate below the trigger threshold (0.45 against 0.55). I do not agree with cancelling the risk, and I do not cancel it: I downgrade it from veto to heavy condition. In offensive mode my duty is not to underestimate: the technical fact remains documented and coincides textually with the Region's criterion. For this reason my second finding carries the V001 veto as a candidate, with the final qualification expressly remitted to A1/R1/Panel and subject to an independent legal opinion on whether the PAS regime holds. If that opinion confirms it holds, it drops to a condition; if it casts doubt, the veto comes back into play. On this I do not compromise: the technical fact must be brought to the Panel whole, not tamed.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale for each is in sections 3-5.

Finding	Subject	Severity	Score	Confidence	Veto
A5-D2-20260604-001	Technical connection (3 SPV): MV 20 kV accepted, works not built, easements not established, cost ~€2.2M skewed to Verde	amber	63	0.80	none
A5-D2-20260604-002	Shared connection point Blu+Verde (CP Noci, shared works): documented cumulation substrate	amber	40	0.45	V001 candidate

The lower confidence on the second finding (0.45) does not reflect uncertainty about the technical fact (shared point, which is certain), but the aggregated confidence in the circumventing substrate after the BUR + 120-day mitigation, which is a matter for A1/R1. The technical fact, on its own, is high-confidence.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Independent legal opinion on whether the PAS regime under art. 22-bis holds in light of the shared connection point Blu+Verde (CP Noci) and the shared works: does it meet the Region's cumulation criterion? 2. Delivery status of the connection works (the three applications are pending): E-Distribuzione schedule and cost top-up risk on the COMPLEX works. 3. Easements for the buried lines: identification of the land parcels crossed, status of establishment, costs (cross D5). 4. Current validity of the STMG and of the technical solutions (Giallo 210 days) at the closing date. 5. Consistency between the shared cable route and the interference with the Murgia SE SAC (cross D1/D6): does the shared cable route cross the Natura 2000 area? 6. Real feasibility of the cost reduction by self-performing the works (from ~€1.8M to ~€1.2M + ~€300k TICA refund): E-Distribuzione confirmation and impact on the schedule.

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Legal opinion confirming that the PAS regime cannot be reopened in respect of the shared connection (cardinal condition, intersected with V001). 2. STMG and acceptances valid and current at closing; cable-route easements established or binding commitments from the properties crossed. 3. Consolidated connection-cost picture (~€2.2M, or ~€1.2M + €300k in the self-performance scenario) reflected in the business plan (cross D7).

8. Conclusion

The cluster connection is well designed but not perfected: MV 20 kV on E-Distribuzione, three applications accepted and validated, consistent powers, but works not yet built, cable-route easements not established, heavy network cost (~€2.2M) and skewed to Verde, works classified COMPLEX with the consequent cost top-up risk. It is not an “available” connection in the sense that the RTB qualification would require, and in offensive mode I do not endorse that qualification.

The data point I fix most firmly, as an engineer, remains: Blu and Verde share the same connection point at the Noci Primary Substation and the same network works, and this is exactly the textual criterion the Region had indicated for cumulation. I have fixed the technical fact, documented and high-confidence. Its qualification as a V001 veto I remit to A1, R1 and the Panel, where it must be brought whole. My judgement: D2 is not a veto within my competence, but it carries the technical brick of the most delicate node of the entire operation, and is at the same time one of the most costly conditions at closing. The connection is not paid at RTB value until the works are in the ground, the easements in hand and the PAS regime confirmed. On this I do not compromise.

Dario Pestarino, Electrical Engineer Ultimate Big 5 Energy Squad, Technical unit, Agent A5

Professional report, Dimension D3, Permitting process

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D3, permitting process and authorisation regime Professional: Corrado Falqui, Administrative Lawyer (Agent A1, Legal unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence base: 19 record sheets across 20 P1 documents extracted from the VDR (folders 10 DOC PROGETTO, 12 TITOLO AUTORIZZATIVO, 13 PARERI E NULLA OSTA, extracted p7m), consolidated in archivio/D3_consolidato.json

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1. Mandate and scope

I was entrusted with assessing the permitting process of the cluster: establishing whether the buyer, at closing, acquires three solid, unchallengeable permits, or three formally perfected but precautionarily fragile permits, exposed to annulment or to reopening of the procedure in a more onerous regime. I read this file as I read a case before the TAR: I look for the defect in the procedure before the merit in the project. The question that governs my analysis is one only: do these three permits hold if someone attacks them, and in particular does the PAS framing hold for a plant that, when added up, is worth 14.05 MWp?

I stay within the boundaries of D3. I do not compute the verdict, I do not aggregate other dimensions, I do not issue regulated legal advice: I produce decision support for the investor. Where the regime depends on the environmental outcome or on the permit-land nexus, I flag the intersection and bring in the colleagues (A12 environmental, A3 real estate, A5 connections) without invading their merits. The final qualification of the V001 veto is not mine exclusively: I remit it to the deterministic R1a engine and to the Panel, but the technical-administrative rationale I put on record myself, and it is the heart of this report.

2. What I examined

I read, act by act, the three PAS permits (Giallo no. 1/2023, Blu no. 2/2023, Verde no. 3/2023, all in the name of Solaria Sviluppo S.r.l.), the PAS clearance letters, the VIA screening decision (DD 341/2025 of the Metropolitan City of Bari, exclusion with 17 conditions), the landscape compatibility assessment under art. 91 PPTR NTA (favourable with conditions), the in-procedure opinions of the Southern Apennine Basin Authority, and above all the complete correspondence on the cumulation, reconstructed from the Giallo “clearance letter” (Municipality of Collemurgia, prot. 0070645 of 07/10/2024), which summarises the whole procedure.

One document would not let itself be read: the technical sworn statement ED_03 for Giallo is a corrupted file in the VDR (non-PDF magic bytes, feb5 0358), not a limitation of the pipeline but a defect of the data room. The Giallo permit was in any case recovered from the p7m 12 TITOLO AUTORIZZATIVO/Collemurgia- Lettera libera.PDF.P7M. I treat as a documentary gap, not as a presumed fact, everything that the VDR does not prove: in offensive mode I do not grant a presumption of legitimacy to an act I cannot see.

3. The structure of the regime, and why it matters

This is the point on which the commercial presentation and the administrative substance diverge, and it is where I practise my craft.

The cluster obtained the permits under the simplified regime (PAS under art. 22-bis of Legislative Decree 199/2021), on areas classified suitable, despite a combined power of 14.05 MWp, well beyond the 10 MW threshold that, according to the initial position of the Puglia Region itself, would have required Single Authorisation under art. 12 of Legislative Decree 387/2003 and a VIA within ministerial competence. It is not my inference: the issue was raised by the authorities themselves. I reconstruct the chronology because it is there that the fragility is visible.

On 05/02/2024 the Municipality asks the Region whether the three projects, individually under 10 MW but cumulatively ~14.05 MW, in the hands of the same company on adjoining fields, must follow the more onerous procedure. On 30/05/2024 the Region (Energy Transition Section, prot. 38325) responds with an opinion unfavourable to the simplified regime: the projects must be subjected to AU “if they refer to the same connection point to the grid or located on the same cadastral parcel or on contiguous parcels and attributable to the same legal representative”; adding the powers together exceeds 10 MW, therefore ministerial VIA. Solaria Sviluppo objects (13/06/2024, citing the MASE ruling prot. 131744/2023), files an appeal to the TAR Puglia (28/08/2024, prot. 58848), and on 23/08/2024 the Region makes a reversal (prot. 57821): the projects “may be regarded as attributable to the simplified procedure under art. 22-bis”, but with a caveat I have underlined and which weighs: it will be necessary to consider “all the elements relevant to the specific case, currently unknown and not falling within the competence of this Administration”. The Municipality declares Giallo perfected (07/10/2024), followed by the excluded VIA screening (DD 341/2025, on a blu-verde 10.20 MW scope) and the PAS clearance letters (20/02/2025).

The data point I put on record: the PAS framing rests on a reversal that, by the Region's own textual admission, did not assess precisely the decisive elements that the Region itself had indicated in the unfavourable opinion, namely the connection point and the cadastral contiguity. The Region changed its view on a party's counter-arguments, but explicitly reserved what it did not know. On the administrative level this means the permit is not bulletproof: it is a framing that is substantially challengeable by anyone with an interest, and the central argument of any challenge is already written in the regional opinion of 30/05/2024.

4. Qualifying the V001 veto (splitting): why I do NOT close it as a veto

Here I apply my threshold, and it is the part of the judgement I want to justify at length, because it is the rationale I ask the Panel to let me defend.

V001 is artificial splitting: the breaking-up of a unitary plant into several permits to stay below the AU and VIA thresholds. The case law I apply (Council of State 5465/2022, substance-based orientation 2024-2026) does not look at the single indicator, but at the convergence of several indicators: single party, same connection point, contiguity, same cable route, close chronology. It is the same grid the Puglia Region used. Let us see how it applies here:

• Single party: confirmed. The three PAS belong to a single vehicle, Solaria Sviluppo S.r.l. (cross D8/A2, finding A2-D8-20260604-002). Indicator present.
• Cadastral contiguity: confirmed. Adjoining land in the Serremonti locality. Indicator present.
• Close chronology: the three procedure starts are from 2023 (07/06, 29/09, 03/11). Indicator present.
• Common connection point: indicator present and heavy. The D2 check (A5-D2-20260604-002) documents that Blu and Verde share a connection point (CP Noci, identical PoC 10.881 km) with shared works. It is exactly the “same connection point” criterion the Region had set as decisive.

The convergence of the indicators, on the level of fact, is there and is robust. The splitting pattern is substantial and, I repeat, was raised by the authorities themselves, not by the DD. If I stopped at the fact, I would propose V001 as a veto in offensive mode.

I do not do so, and I explain why, because it is here that my anti-false-positive rule meets a supervening documentary de-risking. Two elements shift my confidence below the offensive threshold of 0.55 required to close the veto:

1. The competent authority ultimately brought the case back to PAS art. 22-bis. However argumentatively fragile the reversal may be (section 3), it is an act of the administration that holds the power, not a party's opinion. The circumvention was not established by any decision: on the contrary, it was formally sterilised by a regional act.
2. The permits have stabilised over time. The client notes, verified, document the publication of the permits in the BUR Puglia (Apr. 2025) and the running of the 120 days for objections. Once that term has run, the circumvention, even if one wanted to argue it, is no longer readily verifiable against the project through the ordinary remedies: the window for ordinary administrative attack has largely closed. This is the fact that, honestly, lowers the real risk relative to the theoretical fragility of the permit.

For this reason I downgrade V001 from veto to a strong condition precedent to closing, and I qualify it under Reading A (below threshold). I do, however, hold firm to the caution of offensive mode: the risk does not vanish, it changes nature. In particular, the appeal to the TAR Puglia filed by Solaria Sviluppo (prot. 58848/2024) against the municipal note remains live: the VDR does not contain a judgement, withdrawal or order striking out the case. It is not documented whether the appeal was abandoned after the reversal or is still pending. A live dispute, even if brought by Solaria Sviluppo itself and not against Solaria Sviluppo, is an open variable on the stability of the framework (a potential nascent V007 finding, which I do not close for lack of a decision prohibiting the project). I make it a condition, not a veto.

I note for transparency to the Panel: variant B of this qualification (V001 as a veto, NO-GO) exists and is traceable. My recommendation is Reading A, but the rationale of both must remain readable, because the difference is not in the facts, which are the same, but in the weight given to the supervening de-risking.

5. Specific risks that concern me

1. Robustness of the PAS regime against the cumulation. It is the mother risk. If the Region's initial cumulative reading prevailed, the permits would have to be brought back to AU + ministerial VIA, with reopening of the procedure. The de-risking (BUR + 120 days) mitigates but does not eliminate the exposure, because the powers of self-review and the initiatives of opposing third parties remain.
2. Misalignment in the scope and level of the VIA. The screening was carried out at provincial level (Metropolitan City) on a blu-verde 10.20 MW scope, excluding Giallo. The initial thesis was ministerial VIA on 14.05 MW. If the cumulative reading prevails, the screening would have been done at the wrong level and on the wrong scope. It is the most direct technical-administrative argument for any challenge.
3. Giallo outside the screening and sworn statement not verifiable. Giallo (2.21 MW) remained outside the VIA screening and its ED_03 sworn statement is a corrupted file in the VDR: the technical sworn statement of the project cannot be verified. A documentary gap that weighs on the completeness of the file of a single SPV.
4. TAR appeal of unknown outcome. Already addressed in section 4: an unknown on the stability of the litigation picture.
5. Compliance burden (referred to D6). DD 341/2025 (17 conditions) and the art. 91 PPTR assessment impose real construction and maintenance charges (dry-stone walls, trulli, Xylella, T200, foundations without concrete). It is not a defect of the permit, but it is a compliance charge whose breach may impair the legitimacy of the downstream acts: I flag it as an intersection with D6/A12 and D7.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them faithfully, without altering scores or confidence; the rationale for each is in sections 3-5.

Finding	Area	Severity	Score	Confidence	Veto
A1-D3-20260604-001	cluster (3 SPV)	amber	62	0.75	V001 considered, below threshold (Reading A)
A1-D3-20260604-002	Giallo	amber	52	0.60	open question on VIA scope

Traceability notes: - A1-D3-20260604-001: PAS permits perfected for the 3 projects, VIA screening excluded (DD 341/2025), landscape favourable; publication in the BUR Puglia Apr. 2025 and the 120 days for objections passed, permits stabilised. V001 profile documented but below threshold (see A5-D2-20260604-002). Mitigation: 120 days for objections elapsed, permits published in the BUR. Condition: favourable outcome or withdrawal of the Solaria Sviluppo TAR appeal. - A1-D3-20260604-002: Giallo, permit perfected (p7m clearance letter) but ED_03 sworn statement a corrupted VDR file and SPV excluded from the blu-verde VIA screening. Open question: Giallo's VIA scope. Condition: provide an intact Giallo ED_03.

The lower confidence on Giallo (0.60) honestly reflects the documentary gap (sworn statement not readable, SPV outside screening), not a harsher judgement on the merits of the permit.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Connection point: do the three SPV share a connection point or a common cable route? (decisive for the robustness of the PAS regime; coordinate with D2/A5, already documented for Blu-Verde). 2. TAR Puglia appeal (prot. 58848/2024): status and outcome (judgement, withdrawal, striking out). Any other litigation on the decisions. 3. Giallo ED_03: intact copy of the technical sworn statement (corrupted VDR file). 4. VIA scope: reasoning for excluding Giallo from the screening and the robustness of the provincial screening against the Region's initial thesis of ministerial VIA on 14.05 MW. 5. Conditions: compliance plan for the 17 DD 341/2025 conditions and the landscape ones, with cost estimate (towards D6/D7).

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Independent legal opinion on whether the PAS regime under art. 22-bis holds against the 14.05 MWp cumulation and the elements (connection point, contiguity) not assessed by the Region in the reversal. 2. Final and favourable outcome, or withdrawal with the bodies' acquiescence, of the TAR appeal. 3. Intact Giallo ED_03 sworn statement on file. 4. Written confirmation of the VIA framing (exclusion not reopenable on the cumulated scope).

8. Conclusion

The permitting process of the cluster is formally concluded but substantially challengeable: three perfected PAS permits, VIA screening excluded, landscape favourable, and yet a framing in the simplified regime that rests on a declaredly partial regional reversal, on a plant that cumulated is worth 14.05 MWp and that presents a full convergence of splitting indicators (single party, contiguity, chronology, shared Blu-Verde connection point).

My judgement on the dimension: D3 is not a veto, and the V001 profile remains under Reading A, below threshold, because the competent authority brought it back to PAS and the permits have stabilised with publication in the BUR and the running of the 120 days for objections. But it is one of the most qualifying conditions of the operation: the buyer acquires not a bulletproof permit, but a permit that has held and that must be guarded with an independent legal opinion on the robustness of the regime and with documented closure of the TAR litigation front. On this I do not compromise: the price of the authorised project is not paid until the PAS regime is confirmed as not reopenable.

Corrado Falqui, Administrative Lawyer Ultimate Big 5 Energy Squad, Legal unit, Agent A1

Professional report, Dimension D4, Technical and plant engineering

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D4, technical and plant engineering (sizing, yield, configuration) Professional: Gloria Rivetti, Plant Engineer (Agent A6, Technical unit) Mode: offensive, buyer side Evidence base: 15 record sheets across 15 VDR P1 documents (ED_01 technical-descriptive reports, ED_04 summaries, ED_06 specialist/yield, PVSYST “Project.VCx” reports base and “R”), local pdftotext -> language model pipeline, consolidated in archivio/D4_consolidato.json

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1. Mandate and scope

I was entrusted with assessing the technical robustness of the plant: establishing whether the cluster being acquired is a defined, frozen and producible-as-declared project, or a bundle of alternative design solutions still to be consolidated, on which the revenue basis cannot yet be founded. The question that governs my analysis is the one I always put, because it is the craft: has this yield been measured and reconstructed from site data, or is it a brochure yield? I do not believe a yield that is not anchored to a single authorised configuration and to a probabilistic estimate.

I stay within the boundaries of D4. I do not compute the verdict, I do not aggregate other dimensions, I do not issue regulated technical advice: I produce decision support for the investor. Where the technical aspect touches the connection (size, voltage, export) I flag the intersection and bring in A5; where it touches the layout on the olive uprootings I refer to D6 (A12) without invading the merits.

2. What I examined

I read, SPV by SPV, the technical-descriptive reports (ED_01), the project summaries (ED_04), the specialist yield reports (ED_06) and the PVSYST reports in their two families (“base” and “R”). 15 documents out of 15 extracted, no OCR: they were native PDFs, read in their first 30 pages, where the rating data, the layout, the energy balance and the specific yields live. The presence of several revisions of the same document (Giallo ED_01 revLeo and rev01, ED_06 and ED_06 rev01) and of two PVSYST families is not an archival detail: it is itself the finding, and I keep it as such.

The rating picture I reconstructed is this:

SPV	Peak power	Export	Structure	Specific yield
Blu	5.96 MWp	5.1 MW	fixed or tracker	1,535-1,741 kWh/kWp
Verde	5.96 MWp	5.1 MW	fixed or tracker	1,535-1,741 kWh/kWp
Giallo	2.21 MWp	2.2 MW	fixed or tracker	1,548-1,747 kWh/kWp
Cluster	~14.13 MWp	~12.4 MW	MV 20 kV	internal gap ~13%

I note the structural point straight away: no storage system (BESS). All the reports and all the PVSYST state BESS absent. The cluster is a pure ground-mounted PV plant, despite the deal label “PV+BESS” and the scoring mode fv_bess. I address it in section 5, because it is a consistency node against the investment thesis even before being a technical fact.

3. The technical node: the unconsolidated dual configuration, and why it matters

This is the heart of my report, and it is the point on which the project presentation and the documentary reality diverge.

For each SPV the VDR does not contain one project, but two materially different solutions, both simulated, never reconciled into a single detailed design:

• Fixed version (sheds): Longi 585 / Trina 700 Wp bifacial modules, fixed structure, GCR 52.2%, ILR ~1.1, SMA inverters (MV Power Station 2660 / Sunny Central 760CP), specific yield ~1,535-1,548 kWh/kWp. On Blu it is worth about 9,155 MWh/year. It is the version described in the technical reports ED_01/04/06.
• Tracker version (PVSYST “R” report): Risen 740 Wp bifacial modules, N-S single-axis tracker, GCR 47.7%, ILR ~1.05, Huawei inverters (SUN2000-330KTL-H1), specific yield ~1,741-1,747 kWh/kWp. On Blu about 10,381 MWh/year.

Between the two solutions there is a yield gap of about 13% (tracker vs fixed), and with it the module, structure and inverter change. I explain why, as an engineer, this is not a revision detail but an open risk on two fronts, yield and CAPEX.

On the yield front: the revenue basis of a twenty-year investment cannot rest on a 13% range. 1,535 and 1,741 kWh/kWp are not “roughly the same plant with tolerance”: they are two different plants, with two generation profiles, two degradation curves and two maintenance regimes. The tracker yields more on paper but introduces moving parts, self-consumption (derating for the tracker's own consumption), mechanical maintenance and an exposure to faults that the fixed plant does not have. The fixed plant, with GCR 52.2%, is penalised by inter-row shading, which the PVSYST itself flags as high: it is an aggressive shed density that erodes the real PR. The buyer must know which of the two profiles is being acquired, because the revenue follows from it.

On the CAPEX front: tracker and fixed do not cost the same. A single-axis tracker adds structure, motorisation and maintenance that the fixed plant does not carry. Until the configuration is frozen, the plant cost remains indeterminate, and this propagates directly into D7 (business plan, A8), where the plant CAPEX is already absent. An unconsolidated dual config is therefore not only a technical problem: it is a hole upstream of the economic valuation.

I add the inverter mismatch as internal proof that the design is not frozen: the reports say SMA, the PVSYST say Huawei. It is not an isolated typo, it is the coherent symptom of a project that exists in two parallel variants. To this is added a self-flagged power inconsistency in Blu's ED_04 (the report itself flags a “technical inconsistency in the overall power” of the components): it may be a string/inverter mismatch or a revision typo, but in offensive mode I treat it as to be clarified, not as negligible.

In offensive mode, my rule is to recompute at the worst credible scenario. Here the worst credible scenario is that one acquires, and pays, on the tracker yield (the highest) a plant that will be built fixed (the lowest), receiving 13% less yield relative to the price paid. I have no proof that this is so: I have proof that the document does not rule it out. It is exactly this that makes the finding full.

4. The absence of P50/P90, and why it weakens the business case

The second node, intertwined with the first. No VDR document reports a probabilistic P50/P90 estimate. The yield is given as a point value, not as a confidence interval. To this is added a discrepancy I could not reconcile: the Verde ED_06 yield report indicates 1,181.68 kWh/kWp, a yield clearly lower than the 1,535-1,741 kWh/kWp of the PVSYST. Three numbers for the same thing (1,181 ED_06, 1,535 fixed, 1,741 tracker), without a documented hierarchy saying which governs.

I explain why the absence of P50/P90 weakens the business case, and it is not engineer's pedantry. A point value of yield is an assertion with no declared uncertainty: it does not say how much probability there is of being below that number in any given year. A lender, and a prudent investor, does not underwrite a twenty-year deal on the optimistic P50: it sizes the debt and the covenants on the P90, that is on the yield exceeded in 90% of years. Without the probabilistic curve, the revenue basis is a point suspended in a vacuum, and any business plan built on top inherits that fragility. In the total absence of the business plan (D7, already an A8 red finding), this figure becomes critical to consolidate even before the economic numbers can be discussed: one cannot value what does not have a confidence interval.

I hold firm to my threshold: without a verifiable yield anchored to a single configuration and to a P50/P90 estimate, I do not close D4 as solid. It is not severity: it is the refusal to promote a brochure yield to fact.

5. BESS absent: consistency with the investment thesis

I isolate it because it is of a different nature from the two nodes above. Technically, the absence of storage is not a defect: a pure ground-mounted PV on suitable Db land is a legitimate, well-typified plant, and it does not carry any technical risk in itself. The point is one of consistency, not of engineering. If the buyer expected a PV+BESS (as the deal label and the scoring mode suggest), the size and the storage must be renegotiated, because what the VDR describes is something else. The client notes place the storage as a future lever (a sizeable BESS on the retained industrial land, ~23.38 ha suitable Db/Da), not as part of the current plant. I record it thus: no technical risk, but a consistency fact against the thesis that the Panel must bring out explicitly.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale for each is in sections 3-5.

Finding	Subject	Severity	Score	Confidence	Veto
A6-D4-20260604-001	Plant: unconsolidated dual config + no P50/P90	amber	62	0.72	none
A6-D4-20260604-002	BESS absent (thesis consistency, no technical risk)	green	65	0.90	none

The confidence on the first finding (0.72) honestly reflects that I read the first 30 pages of 15 documents and that the dual family of PVSYST leaves me a margin: the fact is established, the final configuration is not. On the second, the high confidence (0.90) reflects that the absence of BESS is unambiguous across all sources. I propose no veto: D4 does not meet the measurable recognition rule of a V001-V007. The technical risk here is not one of a block, it is one of yield and CAPEX not yet reliable, which is a different thing from a veto.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Which is the final configuration consistent with the PAS permit: fixed with SMA inverters or tracker with Huawei inverters? Provide the single as-built/detailed design for the 3 SPV. 2. Yield: provide the final PVSYST with P50/P90 and reconcile the gap of Verde's ED_06 (1,181 kWh/kWp) against the PVSYST (1,535-1,741 kWh/kWp). 3. Clarify the power inconsistency self-flagged in Blu's ED_04. 4. Confirm the absence of BESS in the current plant and any future provision (space, connection, expected size). 5. Consistency of the layout with the authorised olive uprootings and with the cable route (cross D6/D2).

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Single, frozen detailed design for each SPV, consistent with the permit. 2. Final PVSYST with P50/P90 yield reflected in the business plan (D7). 3. Bill of materials (modules, inverters, structures) consistent across reports, PVSYST and the bill of quantities.

8. Conclusion

The cluster is technically defined but not frozen: 14.13 MWp of peak, ~12.4 MW export, MV 20 kV, on suitable land, well typified as ground-mounted PV. But it rests on two alternative design configurations not reconciled (fixed with SMA against tracker with Huawei, ~13% yield gap), on an inverter mismatch that is the proof of it, and on a yield given as a point value with no P50/P90 estimate, with an internal discrepancy (ED_06 1,181 against PVSYST 1,535-1,741) still open.

My judgement: D4 is not a veto, but it is one of the heaviest conditions on the yield and CAPEX side of the entire operation. One does not pay the price on a yield that is not anchored to a single authorised configuration and to a measured P50/P90. Until the detailed design is single and frozen, and the probabilistic curve is in the buyer's hands and reflected in the business plan, the revenue basis remains an assertion, not a fact. On this, as an engineer, I do not compromise.

Gloria Rivetti, Plant Engineer Ultimate Big 5 Energy Squad, Technical unit, Agent A6

Professional report, Dimension D5, Land availability

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D5, availability and real rights over the land Professional: Tullio Maffei, Real Estate Lawyer (Agent A3, Legal unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence base: 47 record sheets across 50 contractual documents extracted from the VDR (folders 03 CONTRATTI, 05 CDU, 07 TITOLI), consolidated in archivio/D5_consolidato.json

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1. Mandate and scope

I was entrusted with assessing the real rights over the land of the cluster: establishing whether the buyer, at closing, acquires a land holding that is actually available and consistent with the authorised layout, or a bundle of contractual expectations still to be perfected. The question that governs my analysis is one only, and I put it as I always do: this project is sold as ready to build; are the land rights up to that qualification?

I stay within the boundaries of D5. I do not compute the verdict, I do not aggregate other dimensions, I do not issue regulated legal advice: I produce decision support for the investor. Where the holding of the right touches the corporate chain or the permit-land nexus, I flag the intersection and bring in the competent colleagues (A2 corporate, A1 permitting) without invading their merits.

2. What I examined

I read, plot by plot, the preliminary contracts, the amending agreements, the land-use certificates and the parcel lists: 15 preliminaries, 27 amending deeds (one or two per plot), 3 CDU. Three documents would not let themselves be extracted by the pipeline (the preliminaries Proprietario 02 and Proprietario 13, one amending agreement Proprietario 08), but the relevant plots are covered by the related record sheets for the same holding: the gap is documentary, not substantial. Twenty-eight documents were signed scans, read via local OCR: I treated as suspect the anomalous dates (e.g. “Proprietario 18 16/04/2014”, likely 2024) and did not promote them to fact.

3. The structure of the right, and why it matters

This is the heart of my report, and it is the point on which the commercial presentation and the documentary reality diverge.

The land availability of the three SPV does not rest on final contracts nor on established surface rights. It rests on a cascade of three deeds that repeats, with few variations, on almost every plot:

1. Preliminary contract (March-May 2023), signed for the buyer by Demo director (managing director of Solaria Sviluppo) or by an attorney. Deadline for the conditions precedent at 30/05/2024, final contract “within six months, extendable”.
2. First Amending Agreement (April 2024), signed by Proprietario 06: deadline moved to 31/01/2025, term extended “from six to twenty-four months”.
3. Second Amending Agreement (January-May 2025), signed by the special attorney an attorney: deadline at 31/12/2025, with the option of extension to 31/12/2026.

The data point I put on record: more than two years after the preliminary, and after two successive extensions, the final contracts are not shown to be executed. For me a preliminary is not a right. It is a promise to contract, enforceable (art. 2932 of the Civil Code) but not equivalent to the ownership or surface right that a plant with a twenty-year useful life requires. Whoever buys an RTB project is not paying for the right to ask a judge to transfer the land: they are paying for the land. Here that step has not yet happened.

This is, in my craft, the typical contradiction: the real maturity of the deal is lower than declared. The pattern has a name in our framework, V005 (ready-to-build on preliminary-contract land), and I considered it as a veto.

4. Why I do NOT propose V005 as a veto (and what I propose instead)

Here I apply my confidence threshold, which is the most delicate part of the judgement and which I want to justify at length, because it is no more, no less than the rationale I ask the Panel to let me defend.

V005 triggers when land availability is structurally uncertain. This is not the case, for three documented reasons:

• The preliminaries are valid and current, not expired: the terms have been extended by agreement up to 31/12/2025 (2026 option). The right to obtain the final contract exists and is live.
• The conditions precedent are largely fulfilled. The conditions of the preliminaries (suitability of the land and of the project, acceptance of the connection quotation within €60,000 per MW, obtaining the permits) are today satisfied: PAS issued, VIA excluded, landscape favourable. With the conditions removed, the final contracts can be executed, not blocked.
• There is a documented path to the final contract. My own rule of conduct says that I do not close V005 as a certainty when a binding path to the final contract is traceable. Here it is.

For this reason I downgrade V005 from veto to a strong condition precedent to closing. I do, however, hold firm to the caution that offensive mode imposes on me: in offensive mode the preliminary is a full risk, not a formal detail, and the buyer must not pay the price of RTB until the final contracts are in hand. The risk does not vanish: it changes nature, from veto to a condition precedent to the price and the closing.

I note, and I say it clearly to the Panel: this element is part of the substrate of another node, V001 (splitting). The three SPV sit on a contiguous holding and belong to a single vehicle. The land data feeds that reasoning, but the qualification of V001 is not mine: I remit it to A1, R1 and the Panel.

5. Specific risks that concern me

1. Owner fragmentation and hold-up risk. Several holdings belong to estates with multiple co-owners: Proprietario 26 (5), Proprietario 15 (3), Proprietario 09 (3), and above all Proprietario 19-Proprietario 10-Proprietario 08 (7 co-owners). A single one failing to execute is enough to block or force a re-shaping of the lot. At the final-contract stage this is the point where the land price can be renegotiated with leverage, and the land is worth more today precisely because authorised.
2. Chain of signatories and powers of attorney to verify. Preliminaries signed by Demo director or an attorney, first AM by Proprietario 06, second AM by an attorney with a special power of attorney of 15/01/2025; on the owner side, representatives appear (Proprietario 01 for Proprietario 16, Proprietario 14 for Proprietario 17). The signing powers of Proprietario 05 and the attorney and the validity of the powers of attorney must be proven with the deed, not presumed. It is a legal risk that intersects D8 (A2).
3. Coverage of the Giallo layout. For the Giallo lot I mapped only two contracts (Proprietario 07, Proprietario 21). I must verify that the optioned parcels fully cover the authorised layout: it remains an open question.
4. Extension of terms. The term went “from six to twenty-four months”: it signals that the final contracts are expected only after the permitting is consolidated. Consistent with practice, but it exposes to price renegotiation.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale for each is in sections 3-5.

Finding	SPV	Severity	Score	Confidence	Veto
A3-D5-20260604-001	Verde	amber	46	0.85	V005 considered, below threshold
A3-D5-20260604-002	Blu	amber	45	0.85	V005 considered, below threshold
A3-D5-20260604-003	Giallo	amber	48	0.70	open question on layout coverage

The lower confidence on Giallo (0.70) honestly reflects that I have fewer contracts mapped on that lot, not a harsher judgement.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Execution status of the final contracts for each plot of the 3 SPV: how many signed, how many pending. 2. Validity and scope of the special powers of attorney of Proprietario 05 Donato and an attorney. 3. For the jointly-owned holdings (Proprietario 26, Proprietario 15, Proprietario 09, Proprietario 19-Proprietario 10-Proprietario 08): written consent of all the co-owners. 4. Full coverage of the Giallo layout (sufficient parcels relative to the project). 5. CDU updated and not expired at the closing date.

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Execution of the final contracts (sale or surface right) on all parcels of the 3 SPV. 2. Proof of the signing powers (powers of attorney) of whoever signs for the buyer. 3. Written confirmation of the consent of all co-owners in the estates.

8. Conclusion

The cluster's land availability is contractually safeguarded but not perfected: valid preliminaries, conditions fulfilled, path to the final contract open, but final contracts not yet executed after more than two years and two extensions. It is not a “full” availability in the sense that the RTB qualification would require, and in offensive mode I do not endorse that qualification.

My judgement: D5 is not a veto, but it is one of the heaviest conditions of the entire operation. The price is not paid at RTB value until the final contracts are in the buyer's hands, with proof of the powers of attorney and the consent of all co-owners. On this I do not compromise.

Tullio Maffei, Real Estate Lawyer Ultimate Big 5 Energy Squad, Legal unit, Agent A3

Professional report, Dimension D6, Environmental profile

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D6, environmental and agronomic, ENVIRONMENTAL profile (VIA/screening, soil and rock, Natura 2000, water) Professional: Remo Bacchetti, Environmental Specialist (Agent A12, Collateral unit, environmental owner) Mode: offensive, buyer side Evidence base: 24 record sheets across 25 VDR P1 documents (preliminary environmental study SIA ED.01, cumulative impacts INT_03/INT_3, GARDEN system INT_08, soil and rock INT_11, hydrological/PTA reports, ARPA/AdB opinions), consolidated in archivio/D6_consolidato.json. Local OCR + language model pipeline, the 3 huge documents (SIA 174 pp, GARDEN 203 pp, cumulative impacts 365 pp) read head+tail.

Scope note: this D6 chapter is shared. My agronomist colleague A11, Selma Ughetti, separately signs the agronomic profile (olive groves Regional Law 14/2007, monumental olive trees on Verde, soil quality). I cover the environmental profile. Where the two profiles touch, I flag the intersection and remit the agronomic merits to A11.

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1. Mandate and scope

I was entrusted with assessing the environmental profile of the cluster: establishing whether this plant, on a Puglia agricultural holding that touches the hydrographic network, hydrogeological protection zones and a cable route over ten kilometres long, has an environmental file that really holds, or a declared compatibility built on conditions that leaves risks open downstream of closing. The question that governs my analysis is one only, and I put it as I always do, as a guardian of the constraint: is the environmental compatibility of this plant established on the documents, or is it presumed on the parties' own reports?

I stay within the boundaries of D6, environmental profile. I do not compute the verdict, I do not aggregate other dimensions, I do not query the geo engine (A7 does that), I do not issue regulated environmental advice: I produce decision support for the investor. The cartographic landscape constraint has already been mapped by A7 (D1), and I read its findings; the agronomic merits of the olive groves I leave to A11. Where the environmental topic touches the permitting process I bring in A1, where it touches the electrical works and the cable route I liaise with A5.

2. What I examined

I read, topic by topic, the preliminary environmental study (SIA ED.01), the reports on cumulative impacts within 5 km (INT_03/INT_3), the GARDEN mitigation system (INT_08), the excavated soil and rock report (INT_11), the hydrological reports and the compatibility reports with the Water Protection Plan, the opinions of ARPA Puglia and of the Basin Authority. Of the three huge documents (SIA, GARDEN, cumulative impacts) the record sheet covers framing and conclusions, not the central body of calculation: the outcome (compatibility, nil cumulative impacts in the buffer, land take) I consider reliable, but the numerical detail remains in the documents and I do not promote it to a fact verified by me.

I put one documentary gap on record: the ED_02 hydrological report of the Giallo lot is a defective VDR file (pdfinfo does not read the pages, empty even after OCR). It is the second gap on Giallo after the ED_03 sworn statement (see D3, A1). It is not a gap that undermines the overall outcome, but it is a copy to demand intact before closing.

3. The environmental node, and why it matters: the VIA exclusion

This is the heart of my report, and it is the point on which, for once in this operation, the documentation works in favour of the buyer.

The VIA screening concluded with exclusion, managerial decision 341/2025 (see D3). The cumulation relevant for the threshold, Blu plus Verde, is 10.20 MW, and the competent authority held that the full environmental impact assessment procedure was not required, stopping at screening with an outcome of exclusion and conditions.

For me this is a real strong point, not a formality, and I want to explain why. In offensive mode I treat the absence of VIA with suspicion, because a screening handled in a way inconsistent with the state framework is a classic red flag: the splitting of the project to stay below threshold is the circumvention that my craft looks for first. Here, however, the exclusion is not a procedural shortcut. It is a reasoned outcome, reached downstream of a round of additional submissions requested by ARPA Puglia (opinion of 02/09/2024), which had flagged three precise things: risk of being subject to VIA, failure to assess the cumulative impact on land take, incompleteness in the management of soil and rock. These findings were overcome with additional submissions and a compliance note. The authority looked at the cumulation, assessed it, and excluded.

The technical consequence I draw, and which I am keen to declare to the Panel, is this: on the environmental side the V002 veto (site in an unsuitable area) does not trigger and I do not propose it. The site does not intersect an established prohibitive environmental constraint; the VIA was not denied nor does it negatively condition the permit, and the 341/2025 exclusion is a fact on the documents, not a presumption. A7 itself (owner D1) finds no V002 on the landscape side: the landscape authorisations are favourable with conditions for all three lots. On this point confidence is high and the judgement is firm: the environmental profile is not prohibitive.

I add, because it is honest to say so, that compatibility is “built on conditions”. The file required several rounds, ARPA had to request additional submissions, and the positive outcome arrives with a broad compliance burden (DD 341/2025 with 17 conditions, plus PTA, AdB, landscape). Compatible does not mean painless: it means compliable at a cost and with a multi-year programme. That cost must be quantified, and I refer it to the economic model (D7, A8).

4. What remains open: soil and rock, hydrographic network, Natura 2000

If the VIA exclusion closes the structural risk, three technical nodes remain open that in offensive mode I do not concede as resolved on the parties' declaration alone.

a) Excavated soil and rock (INT_11). The excavations for the cable routes and the levelling generate soil to be managed. ARPA had found the management incomplete, later addressed, but the topic is not mere paper: the chemical characterisation of the soil and the excavation balance can produce non-trivial disposal charges for the surplus, and a risk of unforeseen costs if the characterisation returns out-of-threshold parameters. This is a direct impact on CAPEX (towards D7). I do not accept the soil and rock plan as compatible until it is quantified.

b) Special Hydrogeological Protection Zones of type B (ZPSI B) and hydrographic network. The lots fall within ZPSI B: this imposes severe restrictions on the water regime, the obligation to maintain soil permeability and aquifer recharge, and point foundations without concrete and without waterproofing. The PTA opinions are favourable or compatible with conditions, but these are not words: they are real technical constraints on the plant's anchoring solution. They must be verified for consistency with the structural design (cross D4, A6) and for the costs (cross D7). On the hydraulic front, the areas are bordered by the hydrographic network and by buffer strips; the Basin Authority requires siting outside the T200 floodable areas. Blu's ED_02 declares the area not at hazard but bordered by the network. For Giallo, as said, the ED_02 hydrological report is unreadable: an intact copy to demand.

c) Cable route and Murgia SAC (Natura 2000). Here I have the finding that most disquiets me, and it is a documentary contradiction. The field reports (GARDEN, agronomic) conclude that the fields do not interfere with the protected areas, which are at a considerable distance from the lots. But the VIA application declares an interference of the cable route (PoC 10.881 km) with the Murgia SE SAC (see the geo finding A7-D1-002). And there is no evidence on the documents of an appropriate assessment (VINCA) on the cable route. I apply here the rule of my category: the absence of the document is not the absence of the impact. A linear work that crosses or borders a Natura 2000 site requires an appropriate assessment by law; if the VINCA is not on the documents, I do not declare the interference overcome, I keep it as an open question at a declared confidence. It is a mandatory further investigation before closing, not a detail.

I note, for completeness and so as not to invade others' merits, that the fourth node of this chapter, the olive trees with monumental characteristics flagged on the Verde lot (ED_10) in tension with the landscape declaration of non-monumental status, is an agronomic profile: A11 signs it. I cite it because it is part of the same file and because an established monumental status would activate reinforced protections under Regional Law 14/2007 with possible re-shaping of the layout, but the merits judgement is hers, not mine.

5. Specific risks that concern me

1. Compatibility “built on conditions”. The outcome is positive, but it came downstream of ARPA findings and with a broad compliance programme. The risk is not the denial, it is the cost and the multi-year management charge of compliance, not quantified (DD 341/2025, PTA, AdB, landscape, GARDEN). It is a risk that falls on D7.
2. Missing cable-route VINCA. An interference with the SAC declared in the VIA application and not closed by an appropriate assessment on the documents is my most serious residual environmental risk. It suspends, in principle, the buildability of the interfering stretch.
3. Soil and rock not quantified. The chemical characterisation may return surprises; the excavation balance and the disposal costs are a lever of unforeseen CAPEX.
4. ZPSI B as a construction constraint. The point foundations without concrete are not a formula: they condition the structural solution and the costs. The actual consistency of the design with the condition must be verified.
5. Agricultural land take (about 22.7 ha overall). Although on non-prime Db land and arable, it is agricultural soil taken away: an acceptability and reputational topic, a potential lever for local objections. Mitigated by the absence of other FER in the 5 km buffer and by the GARDEN system, but not eliminated.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale for each is in sections 3-4. None proposes a veto: on the environmental side V002 does not trigger.

Finding	Topic	Severity	Score	Confidence	Veto
A12-D6-20260604-001	Environmental file, VIA excluded, nil cumulative impacts, PTA/hydraulic	green	66	0.80	none
A12-D6-20260604-002	Monumental olive trees Verde (agronomic profile, merits to A11)	amber	55	0.60	none
A12-D6-20260604-003	Excavated soil and rock + ZPSI B foundations	amber	58	0.65	none

On the environmental side, the cardinal finding is 001 (green, confidence 0.80): complete file, VIA excluded, cumulative impacts in the 5 km buffer nil, PTA and hydraulic compatibility with conditions. 003 (amber, 0.65) keeps open soil and rock and the ZPSI construction constraints. The 0.60 confidence on 002 honestly reflects that the agronomic merits of monumental status are not within my competence and await the survey. The cable route/VINCA node is traced in the geo finding A7-D1-002 by Nestore Calandra, with whom I am in liaison: I confirm it as an open environmental question, I do not duplicate it.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Cable route and Natura 2000: is there an appropriate assessment (VINCA) on the cable route at the Murgia SE SAC, concluded positively, or a reasoned exclusion? 2. Excavated soil and rock: management plan, chemical characterisation of the soil, excavation balance and estimate of the disposal costs for the surplus. 3. Compliance with conditions: schedule and cost estimate of the overall programme (DD 341/2025, PTA, AdB, landscape, GARDEN), towards the economic model (D7). 4. Giallo ED_02 hydrological report: intact copy of the defective VDR file. 5. ZPSI B and foundations: confirmation of the consistency between the project's anchoring solution and the condition of point foundations without concrete.

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Appropriate assessment of the cable route concluded positively, or reasoned exclusion on the documents. 2. Excavated soil and rock plan approved and quantified. 3. Complete and quantified picture of the environmental conditions, reflected in the business plan (D7). 4. Documented resolution of the monumental olive trees topic on Verde (survey and any Regional Law 14/2007 authorisation), in coordination with A11 who holds the merits.

8. Conclusion

The cluster's environmental profile is solid in its result and prohibitive in nothing: the VIA screening closed with a reasoned exclusion (DD 341/2025, cumulation Blu plus Verde 10.20 MW), downstream of the resolved ARPA findings; the cumulative impacts in the 5 km buffer are nil; compatibility with the Water Protection Plan and with the hydraulic framework is established with conditions. On the environmental side V002 does not trigger, and I do not propose it. This, in an operation where other dimensions carry heavy conditions, is a real strong point for the buyer.

Three technical nodes remain open, however, that in offensive mode I do not concede on the parties' report alone: the appropriate assessment of the cable route on the Murgia SAC, which I demand on the documents; the soil and rock plan to be quantified; the ZPSI B construction constraints to be verified in the design. And a broad compliance burden remains, compatible but not free, that falls on the costs and must be reflected in the business plan.

My judgement: D6, environmental side, is not a veto and is not a structural brake; it is a compatibility established with a compliance programme to be quantified and three checks to close before closing. The environmental file is the most mature point of this deal, but mature does not mean closed: the cable-route VINCA I want in hand before any digging.

Remo Bacchetti, Environmental Specialist Ultimate Big 5 Energy Squad, Collateral unit, Agent A12

Professional report, Dimension D6, Agronomic profile

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D6, environmental and agronomic, AGRONOMIC profile (land use, olive groves, agricultural vocation) Professional: Selma Ughetti, Agronomist (Agent A11, Collateral unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence base: shared D6 chapter archivio/D6-ambientale-agronomica.md (24/25 VDR P1 documents: ED_10 agronomic reports, SIA ED.01, GARDEN system INT_08, soil and rock INT_11, PTA/ARPA opinions), consolidated in archivio/D6_consolidato.json. The environmental profile of D6 is signed separately by my colleague A12, Remo Bacchetti.

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1. Mandate and scope

I was entrusted with the agronomic profile of dimension D6: establishing whether the soil that the plant takes is real agricultural soil, what happens to the olive groves present on the fields, and whether this project is, from the angle of the plant-crop relationship, a pure ground-mounted PV or an agrivoltaic with residual cropping value. The question that governs my reading is the one I always bring to the Panel: under the panels is there or is there not real agricultural activity, and at what cost to the soil and to the olive groves is it taken away?

I declare it straight away, because it changes the weight of my report: this is not an agrivoltaic deal. The project is a pure ground-mounted PV (fixed structure, modules on the ground, no cropping plan under the modules, see D4 and teaser). My unit, Collateral, is fully activated only on agrivoltaic deals; here my contribution is not to measure a cropping yield under the panels, which does not exist, but to read the agronomic profile of the site taken from agriculture: soil vocation, olive groves, reversibility. I stay within the boundaries of D6 agronomic profile: I do not compute the verdict, I do not aggregate other dimensions, I do not issue regulated agronomic advice. I produce decision support.

An attribution point I insist be put on record: the formal findings for D6 scoring belong to A12 (A12-D6-001, A12-D6-002, A12-D6-003). I do not open findings with new IDs: I discuss the agronomic merits of the chapter's findings, in particular the olive groves node, and I indicate where my agronomic judgement supports or qualifies A12's finding.

2. What I examined

I read, on the shared D6 chapter and on the record sheets from which it derives, the VDR agronomic material: the agronomic reports for the three lots (in particular Verde's ED_10), the olive grove census, the land-use framing of the SIA ED.01, the GARDEN system as a green-management measure, the soil and rock report INT_11. The three huge documents (SIA 174 pp, GARDEN 203 pp, cumulative impacts 365 pp) were read with a head-tail strategy by the local pipeline: for these the overall agronomic outcome is reliable, the calculation detail remains in the documents. I treat the outcomes as reliable, not the detailed numbers I could not read line by line.

3. Agricultural soil vocation, and why it matters

The cluster's land take is dimensionally significant: 19.58 ha on the blu-verde (Blu 9.18 ha, Verde 10.40 ha) plus 3.12 ha for Giallo, for an overall order of magnitude of about 22.7 ha. The prevailing crops are arable and tree-arable. The soil is classified non-prime agricultural, in Db planning zone (industrial use), suitable under art. 20 of Legislative Decree 199/2021.

Here I make the distinction that is proper to my craft and that I ask not to be flattened. “Non-prime agricultural” and “Db zone” are two qualifications that reduce the problem, but do not eliminate it on the agronomic level. It remains cultivated agricultural soil taken in a way that is not instantly reversible: tree-arable, in particular, is not bare earth, and the tree component is precisely where the olive groves live. The Db zone lowers the planning conflict and the suitability under 199/2021, but it does not turn arable into a soil without vocation. I note it as an acceptability topic and a lever for local objections, consistent with what the chapter flags, and I keep it distinct from the environmental compatibility judgement, which is A12's.

On the agrivoltaic front my conclusion is clear-cut and must be said precisely because we are in offensive mode: there is no agrivoltaic value to capture. There is no cropping plan under the modules, no expected yield, no agronomic monitoring. Whoever presented this project as “agricultural” because it sits on agricultural soil would commit the error my role exists to unmask: the agrivoltaic qualification rests on real cropping activity under the panels, not on the agricultural origin of the land. Here there is none, and it must be said without ambiguity: it is a pure ground-mounted PV, and the agricultural soil is taken, not shared.

4. The olive groves, the central agronomic node

This is the point on which my competence bears most, and it is where the documentation presents a contradiction that cannot remain open at closing.

The olive grove census on the three lots is: Blu 4 olive trees (none monumental), Giallo 35 olive trees (29 subject to uprooting and transplanting, authorisation obtained), Verde 50 olive trees (6 specimens subject to intervention). On these numbers the management is governed by Puglia Regional Law 14/2007, which protects olive groves and regulates uprooting and replanting.

The issue is one only and I put it on record: the Verde agronomic report (ED_10) flags the presence of trees with MONUMENTAL characteristics, whereas in the landscape process the olive trees of the holding had been declared “all non-monumental”. The two statements cannot coexist. On the agronomic level the difference is not formal: a monumental olive tree under Regional Law 14/2007 activates reinforced protections, relocation is constrained when not prohibited, and where it is allowed it requires a specific regional authorisation with stringent uprooting and replanting conditions (root ball, period, guaranteed establishment). If even a single specimen on Verde were confirmed monumental, two things happen: the authorisation regime of the intervention on the olive grove changes, and the layout of the plant may change, because a monumental olive tree that cannot be moved becomes a physical constraint around which the field must be re-shaped.

I apply here my confidence threshold, and I justify it because it is the rationale I ask to be able to defend. I do not declare monumental status established: I have an agronomic report (ED_10) that flags it as a characteristic and a landscape declaration that denies it. I have a documentary contradiction, not a certainty. My rule of conduct prevents me from promoting to fact what is flagged but not surveyed. So I do not close, but I do not minimise: I keep the topic at medium confidence and I bring it as a binding open question, because the stake, if confirmed, is a change of constraints and layout. This is exactly the agronomic merit that supports the finding A12-D6-20260604-002 (Verde olive trees, amber, score 55, confidence 0.6): I share A12's qualification and reinforce it from the agronomic side.

On the uprooting-replanting of the rest of the census the picture is more settled but not eliminated: for Giallo the 29 trees for uprooting and transplanting have authorisation obtained, and this is a positive fact. It remains that olive transplanting, even authorised, carries an agronomic establishment risk: a tree uprooted and replanted is not a tree saved by definition. I ask that the authorisation be accompanied by proof of the replanting site and by a maintenance commitment, because the agronomic and landscape value of the olive trees is preserved only if the trees survive the transplant.

5. Reversibility and soil quality over time

Two elements of the chapter touch my profile and I note them because they bear on the agronomic quality of the soil over the life cycle and at the end of life of the plant.

First, the hydrogeological conditions from ZPSI type B: point foundations without concrete and without waterproofing, obligation to maintain soil permeability and aquifer recharge. On the agronomic level this is a fact favourable to reversibility: a point anchoring without concrete slabs leaves the soil in conditions to return to cultivation at end of life much better than a continuous foundation. I value it as a positive element for the soil, distinct from the technical-structural constraint, which is A6's, and from the hydrogeology, which is A12's.

Second, the excavated soil and rock (INT_11) for cable routes and levelling: the topic, which remains with A12 for the environmental profile and with A8 for the costs, has an agronomic reflection in the movement and relocation of the surface layer of the soil. I ask that the management plan preserve and relocate the agronomic topsoil, because it is the fertile layer and its loss compromises the residual cultivability and the final agricultural reinstatement.

On the GARDEN system (rows, biodiversity, green-space management) my agronomic reading is that it is a real mitigation measure, not a facade, but it must be said honestly: it is green-space management accompanying a ground-mounted PV, it is not productive agriculture under the modules. It supports the site's compatibility and landscape quality, it entails multi-year maintenance charges (towards D7), but it does not shift the nature of the project from pure PV to agrivoltaic.

6. Formal findings (for R1a scoring)

I do not open findings under my own ID: the agronomic profile of D6 flows into A12's findings, which are the formal channel for scoring. I recall them for traceability, indicating where my agronomic judgement supports them.

Finding (owner A12)	SPV	Severity	Score	Confidence	A11 agronomic contribution
A12-D6-20260604-001	cluster	green	66	0.80	Agricultural soil vocation and take (~22.7 ha, arable): non-prime but real loss
A12-D6-20260604-002	Verde	amber	55	0.60	Monumental olive groves node on Verde: I reinforce the finding from the agronomic side
A12-D6-20260604-003	cluster	amber	58	0.65	Soil and rock: preservation of the agronomic topsoil

I declare explicitly that there are no A11-ID findings in aggregated findings for this deal, consistent with the fact that the project is not agrivoltaic and my unit operates in a contributing capacity, not as the owner of a D6 finding.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list), agronomic profile: 1. Verde olive groves: independent agronomic survey on the monumental status of the olive trees that ED_10 flags, to resolve the contradiction with the landscape declaration. 2. Uprooting-replanting: for the trees authorised for transplanting (29 on Giallo, specimens on Verde), replanting site, uprooting protocol and a maintenance and establishment commitment. 3. Topsoil: in the soil and rock plan, the manner of removal, set-aside and relocation of the surface fertile layer.

Conditions precedent to closing (CP) that I ask to support: 1. Documented resolution of the monumental olive groves topic on Verde (survey and, if monumental status is confirmed, regional authorisation under Regional Law 14/2007 with any re-shaping of the layout). This CP coincides with A12's and I subscribe to it from the agronomic side. 2. Confirmation that the authorised uprootings are accompanied by actual and monitored replanting.

8. Conclusion

On the agronomic level the Collemurgia Cluster is a pure ground-mounted PV on non-prime agricultural soil, with no agrivoltaic value: no crop under the modules, no yield, no monitoring. The loss of about 22.7 ha of arable and tree-arable is real but mitigated by the soil classification, by the Db zone, by the absence of other FER in the 5 km buffer, by the GARDEN system and by a point anchoring that preserves reversibility.

The real agronomic node is one only, and it is the olive grove: the contradiction on the monumental status of the olive trees on Verde must be resolved before closing, because if confirmed it changes the protection regime under Regional Law 14/2007 and potentially the layout. I do not declare it established, but in offensive mode I do not let it pass as a detail: it is a condition precedent, not a formality. On the rest of the census I require that the authorised uprooting be a transplant that survives, not a number on a file.

My judgement: the agronomic profile does not introduce a veto, it confirms and reinforces A12's findings (green severity on the cluster, amber on the olive groves node), and it puts at closing the survey on the monumental olive trees as the agronomic condition on which I do not compromise.

Selma Ughetti, Agronomist Ultimate Big 5 Energy Squad, Collateral unit, Agent A11

Professional report, Dimension D7, Economic and financial

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D7, economic and financial (CAPEX, OPEX, revenue, capital structure, IRR/DSCR) Professional: Olga Tarsia, Financial Analyst (Agent A8, Financial unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence base: chapter archivio/D7-economico-finanziaria.md; 3 cost quantities present in the VDR (decommissioning and reinstatement); cost data reconstructed from D2 (grid connection) and D5 (land); domain benchmark knowledge/fontiA8economici.md. Record sheets in archivio/D7/. No business plan in the VDR.

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1. Mandate and scope

I was entrusted with assessing the economic-financial sustainability of the cluster: establishing whether a buyer, at closing, buys a project whose returns are modellable and defensible, or a bundle of expected revenue that nobody has ever put in a spreadsheet. The question that governs my analysis is one only, and I put it as I always do: an IRR is reconstructed from the VDR assumptions, it is not quoted from the brochure; here where are the assumptions?

I stay within the boundaries of D7. I do not compute the verdict, I do not aggregate other dimensions, I do not issue a regulated investment recommendation (MiFID II/Consolidated Finance Act): I produce decision support for the investor, the decision remains theirs. Where the cost of an item arises in another dimension (the connection is A5's in D2, the land A3's in D5, the yield A6's in D4), I record its impact on the cost and revenue side without invading the colleague's technical merits.

I must say it straight away, because it is the point around which everything else turns: my primary evidence base does not exist. The VDR contains no business plan, financial model, revenue plan or financing term sheet. This does not make my report empty: it makes it a report on the gap. The gap is the finding.

2. What I examined (and what I looked for without finding)

I looked, one by one, for the items that make up an investment case and I separated what is documented from what is absent.

What is in the VDR and quantified: - Decommissioning and reinstatement costs: three bills of quantities (Blu ~€172,627, Verde ~€172,627, Giallo ~€65,550 at €29.69/kWp), total ~€410,804. They cover equipment, structures, prefabs, fencing and CCTV, and for Giallo the mechanical ploughing of the land. No surety or related financial guarantee appears cited in the quantities. - Connection costs (from D2, A5): Blu ~€286,000, Verde ~€1,741,000, Giallo ~€186,000, cluster total ~€2.2M, reducible to ~€1.2M by self-performing the works with a TICA refund ~€300k (A5-D2-001). COMPLEX works under art. 10.1 TICA, subject to cost top-ups. - Land costs (from D5, A3): unconsolidated preliminary rents and prices, charges from final contracts still to be executed, possible price renegotiations. Order of magnitude ~€2.45-2.88M, not firm.

What I looked for and did NOT find, and whose absence weighs more than what I did find: - Plant CAPEX: no bill of quantities or cost estimate for the works, no economic framework. The largest line item of a utility-scale PV plant, that of the modules, structures, inverters, civil works, is unknown. - Operating OPEX: no estimate of O&M, insurance, ongoing rents, charges. - The whole revenue side: no energy price assumption (no PPA, no PUN curve, no zonal capture price, no incentive tariff), and on the technical side no P50/P90 estimate (D4, A6). - Capital structure: no debt/equity ratio, no DSCR, no sensitivity, no IRR.

I treated as suspect any temptation to fill these voids with a benchmark passed off as a deal figure. I did not do it: the domain benchmarks serve to measure the uncertainty, not to fabricate a plan that the seller did not produce. The fonte_dossier of my finding, where it concerns the business plan, is deliberately null, because the document is not there. I put it on record expressly.

3. The structural gap, and why it is decisive for a buyer

This is the heart of my report. In an investment the economic-financial dimension is central: it is the synthesis in which every other dimension translates into euros and into return. Here that synthesis does not exist, and the absence is not a formal detail to be filled at closing with an email: it is the point on which a prudent buyer cannot form a price judgement.

I explain it in the terms in which I would say it to the Panel. Without a business plan four things cannot be determined together, and all four are needed to decide how much to pay:

1. The overall CAPEX, hence the total outlay. Today I know only the connection (~€2.2M, reducible to ~€1.2M) and the decommissioning (~€0.41M). By domain benchmark (fontiA8economici.md) a utility-scale ground-mounted PV sits indicatively at ~€0.6-0.9M/MW of all-in CAPEX: for ~14 MWp an order of magnitude ~€8-12M. I write it as an estimate band to be confirmed with actual documents, not as a plan figure: I do not have the bill of quantities, and I do not invent it.
2. The revenue profile, hence the cash flow. Here the uncertainty is double: the probabilistic yield is absent (P50/P90 missing, D4) and the energy price is never assumed. A merchant PV in the South is exposed to capture and cannibalisation of the zonal price, a risk A4 flags in D10 (uncovered price exposure, D10-001): without a price curve any revenue is built on air.
3. The capital structure and debt service (debt/equity, DSCR): entirely absent.
4. Consequently the IRR, which I cannot reconstruct because both the costs and the revenue on which it would rest are missing. I do not have an optimistic IRR to dismantle: I have a void in place of the model.

Why is this decisive for the buyer, and not for the seller? Because the buyer would be buying unmodelled revenue. In offensive mode this is the greatest obstacle to a GO: one does not pay at the value of an asset whose realisation cost and revenue curve are both unknown. The seller can afford to keep the investment case in their own head; the buyer cannot, because it is they who put the capital at risk on numbers they have not seen.

4. Why I do NOT propose V003 (and what I propose instead)

Here I apply my confidence threshold, and I justify it at length because it is the rationale I ask the Panel to let me defend.

V003 is the veto on inflated returns: it triggers when a declared IRR or yield exceeds the benchmark range for the technology without evidence to justify it. Here I do not propose it, for a clear reason: there is no inflated number to challenge, because there is no number at all. V003 presupposes an optimistic BP to bring back into line; this BP does not exist. I cannot object to a return out of range on a return never declared.

I do, however, hold firm to the caution of offensive mode, and I translate it into a RED finding at low confidence. It is not a contradiction: the red severity measures how much the gap weighs on the decision (maximum, it is the synthesis dimension that is blind); the confidence 0.45 measures how certain I am of the economic-financial judgement on the documents, and it is deliberately below 0.5. This is not by chance: below 0.5 the deterministic engine gate (R1a) flags D7 as a critical open dimension, and holds the overall verdict at CONDITIONAL while the dimension remains not assessable. It is exactly the behaviour I want: the absence of the model must not be able to pass for “absorbed risk”, it must remain visible as a gate.

In short: it is not a veto, because there is no hidden contradiction. It is a decisive information gap, and it must be treated as such.

5. Specific risks that concern me

1. The connection cost is heavy and still open. The ~€2.2M overall, of which ~€1.74M concentrated on Verde alone, are COMPLEX works with cost top-up risk (cross D2, A5). Even in the favourable scenario (self-performance at ~€1.2M + ~€300k refund) it remains an item that on its own weighs on a CAPEX I do not know: relative to an estimated plant CAPEX ~€8-12M, the connection is well over a tenth of the outlay, and precisely the part still not final. In offensive mode I count it gross, at the worst credible scenario, until it is final.
2. Decommissioning surety not evidenced. The quantities quantify the cost (~€0.41M) but the related financial guarantee, often required by the permit, does not appear. It is a potential liability that a serious BP would set aside as a reserve: today it is neither modelled nor guaranteed.
3. Unconsolidated land costs. The preliminary prices are not final (D5, A3), and with jointly-owned holdings subject to hold-up the land price can be renegotiated with leverage precisely because authorised. The land item of the CAPEX is therefore itself a range, not a number.
4. Uncovered price exposure. Pure PV in a zone with high PV penetration in the South: without a PPA or a capture-price assumption, the revenue side is the most fragile of the entire case (cross D10, A4). The client's future BESS thesis could mitigate, but it is outside the perimeter of the asset on sale today and outside any model: I do not count it as revenue.

6. Formal findings (for R1a scoring)

The finding below already complies with tools/rilievo.schema.json and has flowed into aggregated findings. I report it for traceability; the rationale is in sections 3-5.

Finding	Severity	Score	Confidence	Veto
A8-D7-20260604-001	red	34	0.45	none (information gap, not a contradiction)

Content: dimension not assessable due to the absence of a business plan. Plant CAPEX unknown, revenue without P50/P90 or a price. Available are only connection costs (~€2.2M, reducible to ~€1.2M) and decommissioning (~€0.41M); land ~€2.45-2.88M not consolidated. Confidence < 0.5 to activate the critical-open-dimension gate. The business plan's fonte_dossier deliberately null: the document does not exist. Open question: plant CAPEX and revenue curve. Condition: complete business plan (non-derogable condition precedent).

The low confidence (0.45) is not a hesitation, it is a choice: it honestly reflects that I do not have the documents to express a full economic-financial judgement, and it is precisely the signal that keeps the gate open.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Complete business plan: CAPEX (plant bill of quantities and economic schedule), OPEX, capital structure, debt/equity ratio, IRR, DSCR, sensitivity on price and yield. 2. Revenue curve: PPA or price assumptions (PUN, zonal capture price), any incentives, with term and counterparty. 3. Final PVSYST P50/P90 as the revenue basis (cross D4, A6). 4. Decommissioning surety: existence, amount, beneficiary. 5. Final connection costs and quantification of the top-up risk (cross D2, A5).

Condition precedent to closing (CP) that I ask to put in the contract: 1. Complete business plan consistent with the technical evidence (D4) and cost evidence (D2/D5), as a non-derogable condition precedent. Without it, the dimension remains not assessable and the verdict cannot exceed CONDITIONAL due to the critical gate. On this I do not compromise: it is the point at which the price takes shape, and one does not sign a price on an investment case that was never written.

8. Conclusion

The cluster's economic-financial dimension is not assessable on the documents, because the documents that would make it up are not in the VDR. I do not have a plan to challenge: I have the absence of the plan to certify. I know with reasonable approximation only three cost items, connection (~€2.2M), land (~€2.45-2.88M, not firm) and decommissioning (~€0.41M), and I do not know the largest item, the plant CAPEX (benchmark estimate ~€8-12M, to be confirmed), and the whole revenue side.

My judgement: D7 is not a veto, because there is no hidden contradiction to dismantle. It is the open issue of the dossier, a decisive information gap that, in offensive mode, is the greatest obstacle to a GO. I record it as a red finding at confidence 0.45 so that the critical-dimensions gate holds the verdict at CONDITIONAL until a complete business plan, consistent with the technical and cost evidence, is in the buyer's hands. One does not buy a return that nobody has ever modelled. On this I do not compromise.

Olga Tarsia, Financial Analyst Ultimate Big 5 Energy Squad, Financial unit, Agent A8

Professional report, Dimension D8, Corporate and legal structure

Deal: Collemurgia 14 MW PV cluster, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D8, corporate structure, control chain, ownership of the vehicle Professional: Renata Vimercati, Corporate Lawyer (Agent A2, Legal unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence base: 4 VDR P1 documents (Solaria Sviluppo S.r.l. registry extract + 3 ATTI_SOLARIA bundles), local pdftotext -> language model pipeline; record sheets in archivio/D8/, consolidated in archivio/D8_consolidato.json

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1. Mandate and scope

I was entrusted with assessing the corporate structure of the vehicle and the upstream control chain: establishing who really owns the company being sold, what that vehicle contains, and whether what the buyer pays corresponds to what they receive. My method is always the same: I follow the control chain until I find who really owns the permits and the land, and I do not stop sooner. In an SPV operation the risk is not in the accounts, it is in the structure. A permit registered to the wrong company, a share encumbered by a pledge that does not emerge from the teaser narrative, a ring of control not documented: these are the defects that make a transaction fall through, not the figures of a profit and loss account of a company that is in any case inactive.

I stay within the boundaries of D8. I do not compute the verdict, I do not aggregate other dimensions, I do not issue regulated legal advice: I produce decision support for the investor. Ownership is proven with registry extracts and deeds from the VDR, it is not presumed from the commercial narrative. Where the corporate structure touches permitting, land or open sources, I flag the intersection and bring in the competent colleagues (A1 permitting, A3 land, A10 OSINT) without invading their merits.

2. What I examined

I read the Solaria Sviluppo S.r.l. registry extract in its entirety: it is the most reliable source for ownership and current offices, and it is a current snapshot. I then examined the three ATTI_SOLARIA bundles, collections of notarial deeds (132 and 115 pages the two largest), read head and tail by the local pipeline. 4 documents out of 4 extracted, no OCR needed.

I declare the limitation straight away, because it is a limitation that weighs on my judgement and I do not hide it: head-and-tail reading of the bundles is sufficient to confirm name, office and director, but does not guarantee that the extraordinary deeds placed in the central body of the collections have been intercepted: share transfers, share pledges, guarantees in favour of lenders, capital increases. A complete inventory requires a full targeted reading, which remains to be done before closing. Without documentary proof, I do not declare a structure clean.

3. The structural correction, and why it reframes the whole dossier

This is the heart of my report, and it is a point that corrects the representation with which the deal was presented.

The “three SPV” Blu, Verde and Giallo are not three separate companies. They are three projects, three PAS, of a single company: Solaria Sviluppo S.r.l. All the documents report the same name, the same tax code and VAT number (00000000000), the same registered office ((office anonymised)) and the same director. The Blu, Verde, Giallo segmentation is by project, not corporate. Whoever read the dossier as “three vehicles” read it wrong: there is a single vehicle.

The corporate details I put on record from the registry extract:

• Form S.r.l.; share capital €10,000; incorporated on 6 October 2022.
• Registered office in (office anonymised).
• Sole shareholder Meridian Capital S.r.l., at 100 per cent.
• Director and legal representative Demo director.
• Company status: inactive, no operating activity started.

The control chain I was able to reconstruct stops at Meridian Capital S.r.l. Above Meridian Capital, the ultimate beneficial owner is not documented in the VDR. It is here that my professional wariness is triggered: the chain is not resolved until I find the final UBO, and I have not found it. I flag it as an open question, not as a ring taken in good faith.

4. The three implications I ask the Panel to consider

First implication, on the qualification of the deal. The share capital is €10,000 and the company is inactive. It is normal for a pre-construction development SPV, and I do not flag it as a pathology. But I draw from it a consequence that changes the nature of the operation: one acquires a vehicle with no asset substance of its own beyond the projects and permits it contains. It is in effect a deal on assets and permits, dressed up as a share deal. The share deal here is not a tax whim of the counterparty: it is the mechanism by which the permits registered to the SPV pass to the buyer without re-registration, remaining with the same legal entity. This is the merit of the single structure. But it carries the reverse: by buying the shares of Solaria Sviluppo one inherits all the vehicle's liabilities, known and unknown, including supervening events and undisclosed charges. In an asset deal that risk is left behind; in a share deal one buys it. The choice between the two structures is not neutral and must be decided knowingly, not endured.

Second implication, on the single entity and on V001. It is the point where my dimension feeds a node belonging to others. The regional opinion of 30 May 2024 (see D3) required AU and ministerial VIA if the plants were attributable to the same legal representative, as well as to the same connection point and on contiguous parcels. Today all three conditions for cumulation are documented: same company and same legal representative (Solaria Sviluppo, Demo director, and this I establish here), same connection point (Blu and Verde on CP Noci with shared works, D2), contiguous parcels (adjoining land at Serremonti, D3 and D5). The corporate fact closes the first of the three cumulation criteria, and closes it with documentary proof, not by inference. I want to be precise about what is mine and what is not: I establish a high-confidence fact, the single entity. The qualification of V001 as a veto or as a strong condition is not mine: it is a matter for the Panel and the squad lead. I bring to the Panel the documentary brick, not the verdict.

Third implication, on the non-separability of the risk. A single company for three PAS cuts both ways. If the acquisition targets the three projects together, the single vehicle helps: a single share transfer, no fragmentation. But if the PAS regime of Blu and Verde were challenged (V001), the risk cannot be isolated by project, because it belongs to the same entity. Giallo cannot be saved by amputating Blu and Verde: they are in the same vehicle. The buyer must know they are buying a risk that cannot be compartmentalised.

5. Specific risks that concern me

1. Upstream UBO not documented. Above Meridian Capital S.r.l. the chain breaks off in the VDR. In offensive mode I do not assume good faith: Meridian Capital's ownership structure and the final UBO must be established via OSINT (cross D9, A10), also for the anti-money-laundering profiles, and any links with the signatories of the preliminaries (Demo director, the attorney, Proprietario 05), already flagged by A3 in D5, must be verified. Apparent control different from actual control is exactly what I look for.
2. Extraordinary deeds not fully inventoried. The ATTI_SOLARIA bundles were read head and tail. In the central body there may lurk share transfers, share pledges, guarantees to lenders, capital increases, shareholder loans. Until I inventory them in full, I cannot rule out a share pledge, which is exactly the type of charge that, in a share deal, follows the vehicle into the buyer's hands.
3. Consistency with the signatories of the preliminaries. A3 passed me in D5 a chain of signatories and powers of attorney (Demo director, the attorney, Proprietario 05, with a special power of attorney of 15 January 2025) whose powers must be proven with the deed. The validity of those powers of attorney and their attribution to Solaria Sviluppo's control structure touch my dimension: a deed signed by someone without the powers is a defect that carries through to closing.
4. Litigation on the vehicle. Beyond the TAR appeal already known in D3, I have no elements to rule out other pending disputes involving Solaria Sviluppo or Meridian Capital. Without a registry extract updated at closing and without an inventory of the deeds, it is a grey area that remains open.

6. Formal findings (for R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale for each is in sections 3-5.

Finding	Subject	Severity	Score	Confidence	Veto
A2-D8-20260604-001	Corporate structure (single vehicle, UBO and deeds open)	amber	62	0.70	none proposed
A2-D8-20260604-002	Single-company structure, feeds V001 (cross D2/D3)	amber/note	50	0.85	V001 substrate, qualification at the Panel

The higher confidence (0.85) sits on the most solid fact, the single entity: it is established by the registry extract, read in full. The lower confidence (0.70) on the structure honestly reflects that the UBO and extraordinary deeds are not yet closed, not a harsher assessment.

I note, and I say it clearly: I do not propose V006. My rule is ironclad, and I respect it even when offensive mode would push me to lower the threshold. V006 triggers on an established mismatch between the holder of the permits and the SPV sold. Here the permits are held by the same Solaria Sviluppo that is being sold: there is no mismatch, there is in fact coincidence. Without documentary proof of an ownership misalignment, I do not close V006. The structure, on this specific profile, holds.

7. Q-list and conditions at closing

To be asked of the counterparty (Q-list): 1. Ultimate beneficial owner: ownership structure of Meridian Capital S.r.l. and final UBO, with the links to Demo director, the attorney, Proprietario 05 (signatories of the preliminaries, D5). 2. Complete inventory of the extraordinary deeds in ATTI_SOLARIA (share transfers, pledges, guarantees, capital increases, financings), with a full reading. 3. Pledges or charges on shares in favour of banks or lenders: do they exist? 4. Litigation: beyond the TAR appeal (D3), any pending disputes involving Solaria Sviluppo or Meridian Capital. 5. Structure of the operation: share deal (purchase of Solaria Sviluppo shares) or asset deal (purchase of projects)?

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Control chain and UBO documented and verified, also for anti-money-laundering purposes. 2. Registry extract updated to the closing date, with the absence of unagreed pledges or charges on the shares. 3. Complete inventory and clearance of the extraordinary corporate deeds before closing.

8. Conclusion

The cluster's corporate structure is simple and linear in form, but not yet transparent in substance: a single vehicle, Solaria Sviluppo S.r.l., sole shareholder Meridian Capital, one director, small capital and inactive company. On this formal framework I have no pathological findings, and I propose no vetoes. But the control chain is not resolved above Meridian Capital, the extraordinary deeds are not inventoried, and the operation is in effect a purchase of assets and permits dressed up as a share deal, with all the vehicle's liabilities following whoever buys the shares.

My judgement: D8 is not a veto, but it brings to the Panel the fact that closes the first cumulation criterion (single entity), and that is part of the V001 substrate. The qualification of that node is not mine. What is mine, and on which I do not compromise, is that the structure is not declared clean until the UBO and extraordinary deeds are documented and until the registry extract at closing is free of pledges on the shares. Without that proof, the linearity of the structure is appearance, not certainty.

Renata Vimercati, Corporate Lawyer Ultimate Big 5 Energy Squad, Legal unit, Agent A2