Professional report, Dimension D1, Site and constraints

Deal: Collemurgia 14 MW photovoltaic 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 core) Mode: offensive, buyer side Evidence base: 14 records from 14 P1 documents extracted from the VDR (landscape reports ED_07, landscape determinations, constraints analysis EG_02/03/04), consolidated archivio/D1_consolidato.json, integrated with the outcome of the geo engine (golden Collemurgia, docs/specs/2026-06-03-golden-geo-collemurgia-report.md)

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1. Engagement and scope

I am entrusted with the first question that arises on any energy dossier: where is the plant really located, on which cadastral 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 Cluster Collemurgia is located in a regime of real suitability and whether the constraints weighing on the areas are prohibitive, managed or still open.

The question that governs my analysis, from a buyer's perspective, is this: is a plant in the heart of Murgia dei trulli, a context with a very 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 matters?

I stay within the boundaries of D1. I do not calculate 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 level to the environmental opinion I activate A12 (Remo Bacchetti); where the site depends on the cabin and the connection route I activate 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 the first 20: framing and constraints summary), the three landscape determinations, 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 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 determinations.

On this documentary reading I overlaid the outcome of the geo engine already run on the case (national level P3/P4). The site falls within Serremonti locality, sheets 51 and 66 of the Municipality of Collemurgia, Murgia dei trulli context. The three SPV sit on land burdened by Ulteriori Contesti Paesaggistici of the PPTR Puglia (dry-stone walls, trulli, olive groves) and near Rete Natura 2000 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 that I ask the Tavolo to be allowed to 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 GeoDB of the geo engine is national: it knows the art.142 constraints, the woodland, the PAI ISPRA, the Rete Natura 2000, 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). For this reason I work on two levels:

1. National level (geo engine, P3/P4). I queried the intersection of the national constraints with the geometry of the site. The national layer matches the project declarations: PAI, woodland, art.142 and Natura 2000 are consistent with what is declared in the documents.
2. Regional per-case level (documentary verification). The constraint that really matters here, the UCP PPTR “Paesaggi rurali”, 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 on 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, 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 set out, because it is exactly the opposite of the synthetic golden Collemurgia (which was a NO-GO under V002).

V002 is the intersection veto: it triggers when the site demonstrably overlaps 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 does exist. But the three SPV have already obtained the favourable landscape permit 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 D.Lgs 199/2021. The site falls within a suitable-area regime (Db land, not of high value): the location is in the correct regime, suitability is assessed and not merely declared.
• National and regional levels converge. The P3 did not flag a 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 on nothing: I have a coherent national level plus a regional one resolved by an administrative measure.

For this reason, on D1, I do not propose V002. I do, however, hold firm the caution of offensive mode: compatibility holds as long as the determinations 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 burden of conditions.

5. Specific risks that concern me

1. Cable route and Natura 2000, the point still open. This is the real residual of D1. The VIA application declares interference of the cable route (PoC 10.881 km) with the ZSC Murgia di Sud-Est, while the field reports declare no interference: the two documents do not agree, and no appropriate assessment (VINCA) appears on file. The field landscape constraints are resolved; the compatibility of the connection route with Natura 2000 is not. Mandatory cross-flag with A5 (connection) and A12 (environmental opinion).
2. Real burden of conditions (intersects D6/D7). The landscape conditions are not formalities: reinstatement of dry-stone walls with traditional techniques by hand (without mechanical means or binders, PPTR Guidelines 4.4.4), spacing of panels to preserve the trulli, hedges and native species that are not Xylella hosts. They are multi-year construction and maintenance burdens with an impact on CAPEX/OPEX and on the usable layout. To be quantified by A6/A8.
3. Olive groves and L.R. 14/2007 (intersects D6). On Giallo the trees are declared non-monumental with the removal permit obtained. But the agronomic report for Verde (ED_10, A12 finding) flags olive trees with monumental characteristics, in tension with the landscape declaration. Monumentality 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 located outside the floodable areas with a 200-year return period, possibly subdividing the field. Constraint managed, but with operational conditions on the layout.
5. Giallo application more fragile. The landscape commission had requested integrations for Giallo (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 sensitivity on D1, but it confirms a more fragile Giallo application, consistent with the corrupted ED_03 flagged in D3.

6. Formal findings (for R1a scoring)

The findings below are already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. 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 ZSC Murgia SE, VINCA missing	yellow	58	0.60	open question

The lower confidence on the cable route (0.60) honestly reflects that I have an interference declaration in the VIA application contradicted by the field reports and no VINCA on file: it is a point to verify, not a settled 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 my own.

7. Q-list and conditions at closing

To ask the counterparty (Q-list): 1. Final cable route and interference with the ZSC Murgia SE: is there an approved appropriate assessment (VINCA), or a reasoned exclusion? With what mitigations? 2. Confirmation of the non-monumentality of the removed olive trees (agronomic report) and removal permits for all three SPV, not only for Giallo. 3. Estimate of the costs of compliance with the landscape conditions (hand-built dry-stone walls, hedges, trulli spacing) and impact on the layout and on output (towards D6/D7). 4. Time validity of the landscape permits (DET 1487/2451/2132) relative to the construction schedule.

Conditions precedent to closing (CP) that I ask to be put in the contract: 1. Landscape permits (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 reasons. 3. Olive tree removal permits on file for the plots concerned, with confirmation of non-monumentality.

8. Conclusion

The location of the Cluster Collemurgia is strong in terms of suitability and field 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 determinations: on this real case V002 does not trigger, and this is the strength 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 ZSC Murgia SE, which is the only declared Natura 2000 interference and today without VINCA on file, and it remains to quantify the landscape burden of conditions 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 determinations are confirmed intact at closing. On this I do not compromise.

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

Professional report, Dimension D2, Grid connection

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

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1. Engagement and scope

I was tasked with verifying the grid connection of the three SPVs in the cluster: to establish whether the plant, at closing, holds a realistic, perfected connection title consistent with the declared power, or a bundle of accepted quotes that remain paper until the works are in the ground. The question that governs my analysis is a single one, 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. To me a plant without a realistic connection is a drawing, not an investment. I stay within the boundaries of D2. I do not calculate 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 the permitting process (cumulation, V001), the land availability (cable-line easements) or the business plan (grid cost), I flag the intersection and activate the relevant colleagues without intruding on their remit: A1/R1 for the qualification of the veto, A3 for the easements, A8 for the economic impact.

2. What I examined

I read, application by application, the three STMG (minimum general technical solutions) and the related E-Distribuzione connection quotes, the acceptance letters and the validations: STMG and quotes 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 feed-in power and, above all, the shared-works clause reside. The construction detail in the appendices remains in the P2s. Single operator E-Distribuzione, connection voltage 20 kV (MT) for all three SPVs, three separate applications:

SPV	STMG application	POD	Connection point	Feed-in 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 MT line (different point)	2.25 MW	~€186,000	validated, works pending

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

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

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

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

• STMG/connection quote Blu (347144045): “Shared works with connection application 345008933” (Verde), with shared construction of the buried Al 185 mmq cable line.
• Connection quote Verde (345008933): “Shared works with another connection application 347144045” (Blu).
• Both indicate the exact same point: Cabina Primaria di Noci, CP DW00-1-383589 TR VE, 20 kV.

Giallo (389125280) connects instead to a different point (new antenna substation on an existing MT line) and the record reports shared = no.

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

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

4. Findings and red flags from an offensive angle

Beyond the decisive fact, 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 quotes are validated and accepted, but the works are pending delivery. The effective availability of the connection is a commitment, not an accomplished fact. As these are COMPLEX works (art. 10.1 TICA), the risk is twofold: timing (a long E-Distribuzione schedule) and cost adjustment (complex works are by definition subject to balancing payments). Whoever buys RTB buys an available connection, not a promise of availability.

2. Cable-line easements not established. The Blu quote flags the need to establish a specific easement for the buried line over public road and private access ways. It is an additional land dependency, not perfected, that intersects D5/D8 (A3 and A2): without the easement, the shared cable line cannot be laid. I pass it to A3 as a connection fact that generates a land burden.

3. Connection cost heavily weighted onto Verde. About €1.74M on Verde against ~€286k on Blu and ~€186k on Giallo. Verde bears, in effect, 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 quote charges it to Verde. Total cluster connection cost ~€2.2M. The client notes anticipate a reduction by self-performing the works (Enel cost ~€1.8M compressible to ~€1.2M with TICA rebate ~€300k): it is a credible lever, but it remains to be proven and must be incorporated into the business plan, which is currently absent (cross D7, A8).

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

5. POD-site-power consistency. The three PODs are separate and consistent with the three delivery points; the feed-in 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 sound. 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 knot.

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

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

I establish a high-confidence fact: the connection point is shared, the works are common, the fact is written in the E-Distribuzione quotes, 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 the qualification of cumulation depends on elements that are not within my technical remit but within the legal-permitting one: the soundness of the PAS regime art. 22-bis, the regional reversal that brought the projects back under that regime, the publication of the titles in the BUR Puglia (April 2025) and the running of the 120 days for objections.

On this last point I loyally record the mitigating element that the consolidation has taken up: the titles have been published and the 120 days for objections have run, so the evasion is no longer ascertainable against the project by an authority. This, in the consolidation (Reading A), has lowered the confidence of the evasive substrate below the trigger threshold (0.45 against 0.55). I do not agree to cancel 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 explicitly remitted to A1/R1/Panel and subject to an independent legal opinion on the soundness of the PAS regime. If that opinion confirms the soundness, it falls to a condition; if it casts doubt on it, the veto returns 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 conform to tools/rilievo.schema.json and have flowed into aggregated findings. I report them for traceability; the rationale of each is in sections 3-5.

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

The lower confidence on the second finding (0.45) does not reflect uncertainty on the technical fact (shared point, which is certain), but the aggregated confidence of the evasive substrate after the BUR + 120 days mitigation, which is the matter of A1/R1. The technical fact, on its own, is high confidence.

7. Q-list and closing conditions

To ask the counterparty (Q-list): 1. Independent legal opinion on the soundness of the PAS regime art. 22-bis 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-adjustment 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 route of the shared cable line and the interference with ZSC Murgia SE (cross D1/D6): does the shared cable line 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 rebate): E-Distribuzione confirmation and impact on the schedule.

Conditions precedent to closing (CP) that I ask to put into the contract: 1. Legal opinion confirming the non-reopenability of the PAS regime with respect to the shared connection (a cornerstone condition, intersected with V001). 2. STMG and acceptances valid and current at closing; cable-line easements established or binding commitments from the land owners crossed. 3. Consolidated connection cost picture (~€2.2M, or ~€1.2M + €300k in the self-performance scenario) incorporated into the business plan (cross D7).

8. Conclusion

The cluster connection is well designed but not perfected: MT 20 kV on E-Distribuzione, three applications accepted and validated, consistent powers, but works not yet built, cable-line easements not established, a heavy grid cost (~€2.2M) weighted onto Verde, works classified as COMPLEX with the consequent cost-adjustment 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.

What remains is the fact I fix most strongly, as an engineer: Blu and Verde share the same connection point at the Cabina Primaria di Noci and the same grid works, and this is exactly the textual criterion that the Region had indicated for cumulation. I have fixed the technical fact, documented and high confidence. Its qualification as 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 remit, but it carries the technical building block of the most delicate knot of the entire transaction, and it is at the same time one of the most costly closing conditions. 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 core, Agent A5

Professional report, Dimension D3, Permitting process

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

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1. Engagement and scope

I was tasked with verifying the permitting process of the cluster: to establish whether the buyer, at closing, acquires three solid and unchallengeable enabling titles, or three formally perfected titles that are precautionarily fragile, exposed to annulment or to reopening of the procedure under 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 a single one: do these three titles hold if someone attacks them, and in particular does the PAS classification of a plant hold which, in aggregate, is worth 14.05 MWp?

I stay within the boundaries of D3. I do not calculate the verdict, I do not aggregate other dimensions, I do not issue a regulated legal opinion: I produce decision support for the investor. Where the regime depends on the environmental outcome or on the title-land nexus, I flag the intersection and activate the colleagues (A12 environmental, A3 real estate, A5 connections) without intruding on their merit. 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 place on record myself, and it is the heart of this report.

2. What I examined

I read, act by act, the three PAS titles (Giallo n. 1/2023, Blu n. 2/2023, Verde n. 3/2023, all in the name of Solaria Sviluppo S.r.l.), the PAS clearance letters, the VIA screening measure (DD 341/2025 of the Citta Metropolitana di Bari, exclusion with 17 conditions), the landscape compatibility assessment under art. 91 NTA PPTR (favourable with conditions), the endoprocedural opinions of the Autorita di Bacino dell’Appennino Meridionale, and above all the full correspondence on the cumulation, reconstructed from Giallo's “clearance letter” (Comune di Collemurgia, prot. 0070645 of 07/10/2024), which summarises the entire procedure.

One document would not let itself be read: Giallo's technical sworn statement ED_03 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. Giallo's title was nonetheless 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 do not see.

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

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

The cluster obtained the titles under the simplified regime (PAS under art. 22-bis D.Lgs. 199/2021), on areas classified as suitable, despite a cumulated power of 14.05 MWp, well beyond the 10 MW threshold which, according to the initial stance of the Regione Puglia itself, would have required single authorisation under art. 12 D.Lgs. 387/2003 and VIA within ministerial competence. This is not my conjecture: the sensitivity was raised by the authorities themselves. I reconstruct the chronology because that is where the fragility shows.

On 05/02/2024 the Comune asks the Region whether the three interventions, individually below 10 MW but cumulatively ~14.05 MW, held by the same company on adjoining fields, should follow the more onerous procedure. On 30/05/2024 the Region (Energy Transition Section, prot. 38325) replies with an opinion unfavourable to the simplified regime: the interventions must be subjected to single authorisation “if relating to the same connection point on the grid or located on the same cadastral parcel or on contiguous parcels and attributable to the same legal representative”; adding the powers exceeds 10 MW, therefore ministerial VIA. Solaria Sviluppo objects (13/06/2024, citing the MASE prot. 131744/2023 ruling request), files an appeal to the TAR Puglia (28/08/2024, prot. 58848), and on 23/08/2024 the Region performs a reversal (prot. 57821): the interventions “may be considered attributable to the simplified procedure under art. 22-bis”, but with a reservation that I have underlined and that weighs: it will be necessary to consider “all the elements pertinent to the specific case, at present unknown and not falling within the competence of this Administration”. The Comune declares Giallo perfected (07/10/2024), followed by the VIA screening exclusion (DD 341/2025, on the blu-verde 10.20 MW perimeter) and the PAS clearance letters (20/02/2025).

The fact I place on record: the PAS classification rests on a reversal which, by the Region's textual admission, did not assess the very 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 it explicitly reserved what it did not know. On the administrative plane this means that the title is not bulletproof: it is a classification 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. Qualification of the V001 veto (splitting): why I do NOT close it as a veto

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

V001 is artificial splitting: the breaking-up of a unitary plant into several titles to stay below the single authorisation and VIA thresholds. The case law I apply (Cons. Stato 5465/2022, substantialist orientation 2024-2026) does not look at the single index, but at the convergence of several indices: single subject, same connection point, contiguity, same cable line, close chronology. It is the same grid that the Regione Puglia used. Let us see how it applies here:

• Single subject: confirmed. The three PAS are held by a single vehicle, Solaria Sviluppo S.r.l. (cross D8/A2, finding A2-D8-20260604-002). Index present.
• Cadastral contiguity: confirmed. Adjoining land in localita Serremonti. Index present.
• Close chronology: the three procedure starts are from 2023 (07/06, 29/09, 03/11). Index present.
• Common connection point: index 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 that the Region had set as decisive.

The convergence of the indices, on the plane 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 move 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 is (section 3), it is an act of the administration that holds the power, not a party's opinion. The evasion has not been established by any measure: it has, on the contrary, been formally neutralised by a regional act.
2. The titles have stabilised over time. The client notes, verified, document the publication of the titles in the BUR Puglia (Apr. 2025) and the running of the 120 days for objections. Once that term has run, the evasion, even if one wanted to argue it, is no longer easily ascertainable against the project by way of ordinary remedies: the window of ordinary administrative attack has largely closed. This is the fact that, honestly, lowers the real risk compared to the theoretical fragility of the title.

For this reason I downgrade V001 from veto to a strong condition precedent to closing, and I qualify it as Reading A (below threshold). I keep firm, however, the caution of offensive mode: the risk does not disappear, 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 judgment, withdrawal or decree of extinguishment. It is not documented whether the appeal was abandoned after the reversal or is still pending. Live litigation, even if brought by Solaria Sviluppo itself and not against Solaria Sviluppo, is an open variable on the stability of the picture (a potential nascent V007 finding, which I do not close in the absence of a measure adverse to the project). I put it as a condition, not a veto.

I note for transparency to the Panel: variant B of this qualification (V001 as 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. Soundness of the PAS regime against cumulation. It is the parent risk. If the Region's initial cumulative reading were to prevail, the titles would have to be brought back to single authorisation + ministerial VIA, with reopening of the procedure. The de-risking (BUR + 120 days) mitigates but does not zero the exposure, because the powers of self-redress and the initiatives of adverse third parties remain.
2. Misalignment of perimeter and level of the VIA. The screening was carried out at provincial level (Citta Metropolitana) on a blu-verde 10.20 MW perimeter, 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 perimeter. It is the most direct technical-administrative argument for any challenge.
3. Giallo outside the screening and unverifiable sworn statement. 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 is not verifiable. A documentary gap that weighs on the completeness of the file of a single SPV.
4. TAR appeal of unknown outcome. Already treated in section 4: an unknown over the stability of the litigation picture.
5. Burden of conditions (refer to D6). DD 341/2025 (17 conditions) and the art. 91 PPTR assessment impose real burdens of construction and maintenance (dry-stone walls, trulli, Xylella, T200, foundations without concrete). It is not a defect of the title, but it is a compliance burden whose breach can undermine 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 conform to tools/rilievo.schema.json and have flowed into aggregated findings. I report them faithfully, without altering scores or confidence; the rationale of each is in sections 3-5.

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

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

7. Q-list and closing conditions

To ask the counterparty (Q-list): 1. Connection point: do the three SPVs share a connection point or a common cable line? (decisive for the soundness of the PAS regime; coordinate with D2/A5, already documented for Blu-Verde). 2. TAR Puglia appeal (prot. 58848/2024): status and outcome (judgment, withdrawal, extinguishment). Any other litigation on the measures. 3. ED_03 Giallo: complete copy of the technical sworn statement (corrupted VDR file). 4. VIA perimeter: rationale for the exclusion of Giallo from the screening and soundness of the provincial screening against the initial regional thesis of ministerial VIA on 14.05 MW. 5. Conditions: compliance plan for the 17 conditions of DD 341/2025 and the landscape ones, with cost estimate (towards D6/D7).

Conditions precedent to closing (CP) that I ask to put into the contract: 1. Independent legal opinion on the soundness of the PAS regime art. 22-bis 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 acquiescence of the bodies, of the TAR appeal. 3. Complete Giallo ED_03 sworn statement on file. 4. Written confirmation of the VIA classification (exclusion not reopenable on the cumulated perimeter).

8. Conclusion

The permitting process of the cluster is formally concluded but substantially challengeable: three perfected PAS titles, VIA screening excluded, landscape favourable, and yet a classification under the simplified regime that rests on an avowedly partial regional reversal, on a plant that in aggregate is worth 14.05 MWp and that presents a full convergence of splitting indices (single subject, contiguity, chronology, shared connection point Blu-Verde).

My judgement on the dimension: D3 is not a veto, and the V001 profile remains in Reading A, below threshold, because the competent authority brought it back to PAS and the titles have stabilised with publication in the BUR and the running of the 120 days of objection. But it is one of the most qualifying conditions of the transaction: whoever buys does not acquire a bulletproof title, they acquire a title that has held and that must be safeguarded with an independent legal opinion on the soundness of the regime and with the documented closure of the TAR litigation front. On this I do not compromise: the price of the permitted project is not paid until the PAS regime is confirmed as not reopenable.

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

Professional report, Dimension D4, Engineering and plant

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

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1. Mandate and scope

I was instructed to assess the technical robustness of the plant: to establish whether the cluster being acquired is a project defined, frozen and capable of producing as declared, or a bundle of alternative design solutions still to be consolidated, on which the revenue basis cannot yet rest. The question that governs my analysis is the one I always pose, because it is the trade: has this energy yield been measured and reconstructed from site data, or is it a brochure figure? I do not trust a yield that is not anchored to a single authorised configuration and to a probabilistic estimate.

I stay within the bounds 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 engineering touches the connection (size, voltage, grid injection) I flag the intersection and activate A5; where it touches the layout over the olive tree removals I refer to D6 (A12) without intruding on the merits.

2. What I examined

I read, SPV by SPV, the technical descriptive reports (ED_01), the project summaries (ED_04), the specialist energy 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 across the first 30 pages, where the nameplate data, the layout, the energy balance and the specific yields live. The presence of multiple 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 nameplate picture I reconstructed is this:

SPV	Peak power	Grid injection	Structure	Specific energy yield
Blu	5.96 MWp	5.1 MW	fixed or tracker	1535-1741 kWh/kWp
Verde	5.96 MWp	5.1 MW	fixed or tracker	1535-1741 kWh/kWp
Giallo	2.21 MWp	2.2 MW	fixed or tracker	1548-1747 kWh/kWp
Cluster	~14.13 MWp	~12.4 MW	MV 20 kV	internal gap ~13%

I note the structural fact straight away: no storage system (BESS). All the reports and all the PVSYST files record BESS as absent. The cluster is a ground-mount photovoltaic plant that is pure, despite the deal label “FV+BESS” and the scoring mode fv_bess. I address it in section 5, because it is a consistency issue with the investment thesis before being a technical fact.

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

This is the heart of my report, and it is the point at which the project’s 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 ~1535-1548 kWh/kWp. On Blu this is about 9,155 MWh/year. It is the version described in the technical reports ED_01/04/06.
• Tracker version (PVSYST report “R”): Risen 740 Wp bifacial modules, N-S single-axis tracker, GCR 47.7%, ILR ~1.05, Huawei inverters (SUN2000-330KTL-H1), specific yield ~1741-1747 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, energy yield and CAPEX.

On the energy yield front: the revenue basis of a twenty-year investment cannot rest on a 13% range. 1535 and 1741 kWh/kWp are not “roughly the same plant within 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, own power consumption (derating for the tracker’s self-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 turnover 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. As long as the configuration is not frozen, the plant cost remains undetermined, and this propagates directly into D7 (business plan, A8), where the plant CAPEX is already absent. An unconsolidated dual configuration is therefore not only a technical problem: it is a gap upstream of the economic valuation.

I add the inverter mismatch as internal evidence that the design is not frozen: the reports say SMA, the PVSYST files say Huawei. It is not an isolated typo, it is the consistent symptom of a project that exists in two parallel variants. To this is added a self-reported power inconsistency in the ED_04 for Blu (the report itself flags a “technical inconsistency between 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 a matter to be clarified, not as negligible.

In offensive mode, my rule is to recompute to the worst credible scenario. Here the worst credible scenario is that one buys, and pays, on the tracker yield (the higher one) a plant that will be built fixed (the lower one), taking in 13% less energy yield relative to the price paid. I have no proof that this is so: I have proof that the document does not exclude it. It is precisely this that makes the finding full.

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

The second crux, intertwined with the first. No document in the VDR reports a probabilistic P50/P90 estimate. The energy yield is given as a point value, not as a confidence interval. To this is added a discrepancy I could not reconcile: the ED_06 energy yield report for Verde indicates 1,181.68 kWh/kWp, a yield markedly lower than the 1535-1741 kWh/kWp of the PVSYST files. Three numbers for the same thing (1,181 ED_06, 1535 fixed, 1741 tracker), without a documented hierarchy stating which governs.

I explain why the absence of P50/P90 weakens the business case, and it is not engineering pedantry. A point value of energy yield is an assertion without declared uncertainty: it does not say how much probability there is of falling 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 the void, and any business plan built on top inherits that fragility. With the business plan entirely absent (D7, already a red finding by A8), this figure becomes critical to consolidate before the economic numbers can even be discussed: one cannot value what has no confidence interval.

I hold my threshold firm: without a verifiable energy 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 figure to a fact.

5. BESS absent: consistency with the investment thesis

I isolate it because it is different in nature from the two cruxes above. Technically, the absence of storage is not a defect: a pure ground-mount PV on suitable Db land is a legitimate and 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 an FV+BESS (as suggested by the deal label and the scoring mode), 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 (BESS of significant size on the retained industrial land, ~23.38 ha Db/Da suitable), not as part of the current plant. I record it thus: no technical risk, but a fact of consistency with the thesis that the Table must bring out explicitly.

6. Formal findings (for R1a scoring)

The findings below are already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. 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 PVSYST family 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 satisfy the measurable recognition rule of a V001-V007. The technical risk here is not one of blocking, it is one of energy yield and CAPEX not yet reliable, which is different from a veto.

7. Q-list and conditions at closing

To ask the counterparty (Q-list): 1. What 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 SPVs. 2. Energy yield: provide the final PVSYST with P50/P90 and reconcile the gap of the ED_06 for Verde (1,181 kWh/kWp) against the PVSYST files (1535-1741 kWh/kWp). 3. Clarify the power inconsistency self-reported in the ED_04 for Blu. 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 tree removals and with the cable route (cross D6/D2).

Conditions precedent to closing (CP) that I ask to be put into the contract: 1. A single and frozen detailed design for each SPV, consistent with the authorisation permit. 2. Final PVSYST with P50/P90 yield incorporated into the business plan (D7). 3. Component schedule (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 grid injection, MV 20 kV, on suitable land, well typified as ground-mount PV. But it rests on two alternative design configurations not reconciled (fixed with SMA versus tracker with Huawei, ~13% yield gap), on an inverter mismatch that is the proof of it, and on an energy yield given as a point value without any P50/P90 estimate, with an internal discrepancy (ED_06 1,181 versus PVSYST 1535-1741) still open.

My judgement: D4 is not a veto, but it is one of the heaviest conditions on the energy yield and CAPEX side of the whole operation. The price is not paid on a yield that is not anchored to a single authorised configuration and to a measured P50/P90. As long as the detailed design is not single and frozen, and the probabilistic curve is not in the buyer’s hands and incorporated into the business plan, the revenue basis remains an assertion, not a fact. On this, as an engineer, I do not budge.

Gloria Rivetti, Plant Engineer Ultimate Big 5 Energy Squad, Engineering core, Agent A6

Professional report, Dimension D5, Land availability

Deal: Collemurgia photovoltaic cluster 14 MW, 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 core) Mode: offensive, buyer side Date: 4 June 2026 Evidence base: 47 records across 50 contractual documents extracted from the VDR (folders 03 CONTRATTI, 05 CDU, 07 TITOLI), consolidated archivio/D5_consolidato.json

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1. Mandate and scope

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

I stay within the bounds 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 link, I flag the intersection and activate the competent colleagues (A2 corporate, A1 authorisation) without intruding on their merits.

2. What I examined

I read, parcel by parcel, the preliminary agreements, the amending agreements, the urban planning certificates and the parcel lists: 15 preliminary agreements, 27 amending deeds (one or two per parcel), 3 CDU. Three documents would not extract from the pipeline (the preliminary agreements Proprietario 02 and Proprietario 13, an amending agreement Proprietario 08), but the relevant parcels are covered by the related records of the same holding: the gap is documentary, not substantive. Twenty-eight documents were signed scans, read via local OCR: I treated anomalous dates as suspect (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 at which the commercial presentation and the documentary reality diverge.

The land availability of the three SPVs does not rest on final agreements nor on established surface rights. It rests on a cascade of three deeds that recurs, with few variations, on almost every parcel:

1. Preliminary agreement (March-May 2023), signed for the buyer by Demo director (AU of Solaria Sviluppo) or by proxy Francesco. Deadline for the conditions precedent of 30/05/2024, final agreement “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 proxy a proxy: deadline of 31/12/2025, with the option to extend to 31/12/2026.

The fact I put on the record: more than two years after the preliminary agreement, and after two successive extensions, the final agreements do not appear to have been executed. For me a preliminary agreement 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. A buyer of an RTB project is not paying for the faculty to ask a judge to transfer the land: it is paying for the land. Here that step has not yet taken place.

This is, in my trade, the typical contradiction: the actual maturity of the deal is below the declared one. The pattern has a name in our framework, V005 (ready-to-build on preliminary-agreement 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 set out at length, because it is neither more nor less than the rationale I ask the Table to be able to defend.

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

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

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

I note, and I say it clearly to the Table: this element is part of the substrate of another crux, V001 (fragmentation). The three SPVs sit on a contiguous holding and report to a single vehicle. The land data feeds that reasoning, but the qualification of V001 is not mine: I refer it to A1, R1 and the Chamber.

5. Specific risks that concern me

1. Ownership fragmentation and hold-up risk. Several holdings are held by 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). It is enough for one not to execute to block or force a re-scoping of the lot. At the final agreement 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. Preliminary agreements signed by Demo director or a proxy, first AMs by Proprietario 06, second AMs by a proxy with a special power of attorney dated 15/01/2025; on the ownership side, representatives appear (Proprietario 01 for Proprietario 16, Proprietario 14 for Proprietario 17). The signing powers of Proprietario 05 and the proxy, 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 plots under option fully cover the authorised layout: this remains an open question.
4. Extension of terms. The term moved “from six to twenty-four months”: this signals that the final agreements are expected only after the authorisation is consolidated. Consistent with practice, but it exposes the deal to price renegotiation.

6. Formal findings (for R1a scoring)

The findings below are already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. 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 ask the counterparty (Q-list): 1. Status of execution of the final agreements for each parcel of the 3 SPVs: how many signed, how many pending. 2. Validity and scope of the special powers of attorney of Proprietario 05 Donato and a proxy. 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 (plots sufficient relative to the project). 5. CDU updated and not expired at the closing date.

Conditions precedent to closing (CP) that I ask to be put into the contract: 1. Execution of the final agreements (sale or surface right) over all the plots of the 3 SPVs. 2. Proof of the signing powers (powers of attorney) of those signing for the buyer. 3. Written confirmation of the consent of all the co-owners in the estates.

8. Conclusion

The land availability of the cluster is contractually secured but not perfected: preliminary agreements valid, conditions satisfied, path towards the final agreement open, but final agreements not yet executed after more than two years and after two extensions. It is not “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 whole operation. The price is not paid at RTB value until the final agreements are in the buyer’s hands, with proof of the powers of attorney and the consent of all the co-owners. On this I do not budge.

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

Professional report, Dimension D6, Environmental profile

Deal: Collemurgia photovoltaic cluster 14 MW, 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 records out of 25 P1 documents in the VDR (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 pipeline OCR pipeline + language model, the 3 very large documents (SIA 174 pp, GARDEN 203 pp, cumulative impacts 365 pp) read head+tail.

Scope note: this D6 chapter is shared. My colleague the agronomist A11, Selma Ughetti, signs the agronomic profile separately (olive groves L.R. 14/2007, olive-tree monumentality on Verde, soil quality). I deal with the environmental profile. Where the two profiles meet, I flag the intersection and refer the agronomic merits to A11.

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1. Engagement and scope

I was tasked with verifying the environmental profile of the cluster: to establish whether this plant, on an agricultural holding in Puglia that touches the hydrographic network, hydrogeological protection zones and a cable route over ten kilometres long, has an environmental dossier that genuinely holds, or a compatibility declared and built through prescriptions that leaves risks open downstream of closing. The question that governs my analysis is a single one, and I put it as I always put it, as a guardian of the constraint: is the environmental compatibility of this plant established on the record, or is it presumed on reports from the party?

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 a regulated environmental opinion: 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 active permitting process 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 River Basin Authority. For the three very large documents (SIA, GARDEN, cumulative impacts) the record covers framing and conclusions, not the central body of calculation: the outcome (compatibility, nil cumulative impacts within the buffer, land use) I consider reliable, but the numerical detail remains in the documents and I do not promote it to a fact verified by me.

One documentary gap I put on record: the Giallo lot hydrological ED_02 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 attestation (see D3, A1). It is not a gap that undermines the overall outcome, but it is a copy to demand in complete form before closing.

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

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

The screening for EIA concluded with exclusion, managerial determination 341/2025 (see D3). The cumulative figure relevant to the threshold, Blu plus Verde, is 10.20 MW, and the competent authority deemed that the full environmental impact assessment procedure was not required, stopping at screening with an outcome of exclusion and prescriptions.

For me this is a real strength, 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 manner not consistent with the national framework is a classic red flag: splitting the project to stay below the threshold is the avoidance that my trade looks for first. Here, however, the exclusion is not a procedural shortcut. It is a reasoned outcome, reached downstream of a round of additions required by ARPA Puglia (opinion of 02/09/2024), which had flagged three precise things: risk of being subject to VIA, missing assessment of the cumulative impact on land use, incompleteness in the management of soil and rock. These findings were overcome with additions and a compliance note. The authority looked at the cumulative figure, assessed it, and excluded.

The technical consequence I draw, and which I am keen to state at the Table, is this: on the environmental side the V002 veto (site in a non-eligible area) does not trigger and I do not propose it. The site does not intersect any established prohibitive environmental constraint; the VIA was neither denied nor does it negatively condition the permit, and the 341/2025 exclusion is a fact on the record, not a presumption. A7 itself (owner D1) finds no V002 on the landscape side: the landscape authorisations are favourable with prescriptions 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 the compatibility is "built through prescriptions". The dossier required several rounds, ARPA had to request additions, and the positive outcome comes with a broad prescriptive load (DD 341/2025 with 17 prescriptions, 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 financial model (D7, A8).

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

While the VIA exclusion closes the structural risk, three open technical crux points remain that, in offensive mode, I do not concede as resolved on the party 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 supplemented, but the topic is not a mere paper matter: the chemical characterisation of the soil and the excavation balance may produce disposal charges for the surplus that are not trivial, and a risk of unforeseen costs if the characterisation returns parameters above threshold. 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 prescriptions, but these are not words: they are real technical constraints on the anchoring solution of the plant. They must be verified for consistency with the structural design (cross D4, A6) and for costs (cross D7). On the hydraulic side, the areas are bordered by the hydrographic network and buffer strips; the River Basin Authority requires siting outside the T200 floodable areas. The Blu ED_02 declares the area not at hazard but bordered by the network. For Giallo, as noted, the hydrological ED_02 is unreadable: a complete copy to be demanded.

c) Cable route and ZSC Murgia (Natura 2000). Here I have the finding that most troubles 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 submission declares an interference of the cable route (PoC 10.881 km) with the ZSC Murgia SE (see geo finding A7-D1-002). And the record is missing the evidence of an appropriate assessment (VINCA) on the cable route alignment. Here I apply 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 the appropriate assessment by law; if the VINCA is not on the record, I do not declare the interference overcome, I hold it as an open question with stated confidence. It is a mandatory deep-dive before closing, not a detail.

I note, for the sake of completeness and so as not to encroach on the merits of others, that the fourth crux of this chapter, the olive trees with monumentality characteristics flagged on the Verde lot (ED_10) in tension with the landscape declaration of non- monumentality, is agronomic profile: A11 signs it. I cite it because it is part of the same dossier and because a confirmed monumentality would trigger reinforced protections under L.R. 14/2007 with a possible re-definition of the layout, but the judgement on the merits is theirs, not mine.

5. Specific risks that concern me

1. Compatibility "built through prescriptions". The outcome is positive, but it arrived downstream of ARPA findings and with a broad compliance programme. The risk is not denial, it is the cost and the multi-year management charge of the unquantified compliance (DD 341/2025, PTA, AdB, landscape, GARDEN). It is a risk that is offloaded onto D7.
2. Missing cable-route VINCA. An interference with a ZSC declared in the VIA submission and not closed by an appropriate assessment on the record is my most serious residual environmental risk. It suspends, in principle, the constructability of the interfering section.
3. Unquantified soil and rock. 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 prescription is to be verified.
5. Agricultural land use (about 22.7 ha overall). Although on a Db area of no particular value and arable, it is agricultural land removed from use: an acceptability and reputational topic, a potential lever for local opposition. Mitigated by the absence of other renewables within the 5 km buffer and by the GARDEN system, but not eliminated.

6. Formal findings (for the R1a scoring)

The findings below already comply with tools/rilievo.schema.json and have flowed into rilievi aggregati. 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	Theme	Severity	Score	Confidence	Veto
A12-D6-20260604-001	Environmental dossier, VIA excluded, cumulative impacts nil, 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 pivotal finding is 001 (green, confidence 0.80): complete dossier, VIA excluded, cumulative impacts within the 5 km buffer nil, PTA and hydraulic compatibility with prescriptions. The 003 (amber, 0.65) keeps soil and rock and the ZPSI construction constraints open. The 0.60 confidence on 002 honestly reflects that the agronomic merits of the monumentality are not within my remit and await the survey. The cable route/VINCA crux is tracked in the geo finding A7-D1-002 of Nestore Calandra, with whom it is coordinated: I confirm it as an open environmental question, I do not duplicate it.

7. Q-list and conditions at closing

To ask the counterparty (Q-list): 1. Cable route and Natura 2000: is there an appropriate assessment (VINCA) on the cable route alignment at the ZSC Murgia SE, 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 prescriptions: schedule and cost estimate for the overall programme (DD 341/2025, PTA, AdB, landscape, GARDEN), towards the financial model (D7). 4. Giallo hydrological ED_02: a complete copy of the defective VDR file. 5. ZPSI B and foundations: confirmation of the consistency between the anchoring solution of the design and the prescription of point foundations without concrete.

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

8. Conclusion

The environmental profile of the cluster is solid in its result and prohibitive in nothing: the screening for EIA closed with a reasoned exclusion (DD 341/2025, cumulative Blu plus Verde 10.20 MW), downstream of the remedied ARPA findings; the cumulative impacts within the 5 km buffer are nil; the compatibility with the Water Protection Plan and with the hydraulic framework is established with prescriptions. On the environmental side V002 does not trigger, and I do not propose it. This, in a transaction where other dimensions bring heavy conditions, is a genuine strength for the buyer.

However, three technical crux points remain open that in offensive mode I do not concede on the party report alone: the appropriate assessment of the cable route on the ZSC Murgia, which I require on the record; the soil and rock plan to be quantified; the ZPSI B construction constraints to be verified in the design. And a broad prescriptive load remains, compatible but not free, which is offloaded onto 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 an established compatibility with a compliance programme to be quantified and three checks to be closed before closing. The environmental dossier 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 begins.

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

Professional report, Dimension D6, Agronomic profile

Deal: Collemurgia photovoltaic cluster 14 MW, 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 P1 documents in the VDR: agronomic reports ED_10, 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. Engagement and scope

I was tasked with the agronomic profile of dimension D6: to establish whether the land the plant removes from use is genuine agricultural land, what happens to the olive groves on the fields, and whether this project is, in terms of the plant-crop relationship, a pure ground-mounted photovoltaic or an agrivoltaic with residual crop value. The question that governs my reading is the one I always bring to the Table: is there or is there not real agricultural activity under the panels, and at what cost to the soil and to the olive groves is it removed?

I state it at once, because it changes the weight of my report: this is not an agrivoltaic deal. The project is a pure ground-mounted PV (fixed structure, ground-mounted modules, no crop plan under the modules, see D4 and teaser). My unit, Collateral, is fully activated only on agrivoltaic deals; here my contribution is not that of measuring a crop yield under the panels, which does not exist, but to read the agronomic profile of the site removed 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 a regulated agronomic opinion. I produce decision support.

An attribution clarification that I require to be put on record: the formal findings for the D6 scoring are owned by 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 findings, in particular the olive-grove crux, and I indicate where my agronomic judgement supports or qualifies the A12 finding.

2. What I examined

I read, in the shared D6 chapter and in the records from which it derives, the agronomic material in the VDR: the agronomic reports of the three lots (in particular the Verde 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 very large 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 figures that I was unable to read line by line.

3. Agricultural vocation of the soils, and why it matters

The land use of the cluster is dimensionally significant: 19.58 ha on the blue-green (Blu 9.18 ha, Verde 10.40 ha) plus 3.12 ha of Giallo, for an overall order of magnitude of about 22.7 ha. The prevailing crops are arable and tree-planted arable. The land is classified as agricultural land of no particular value, in planning zone Db (industrial settlements), eligible under art. 20 D.Lgs 199/2021.

Here I make the distinction that is proper to my trade and that I ask not to be flattened. "Agricultural land of no particular value" and "Db zone" are two qualifications that reduce the problem, but do not eliminate it under the agronomic profile. It remains cultivated agricultural land removed from use in a manner that is not instantly reversible: tree-planted arable, in particular, is not bare earth, and the tree-planted part is precisely where the olive groves live. The Db zone lowers the planning conflict and eligibility under 199/2021, but it does not turn arable into land without vocation. I note it as an acceptability topic and a lever for local opposition, consistent with what the chapter flags, and I keep it distinct from the environmental compatibility judgement, which belongs to A12.

On the agrivoltaic front my conclusion is clear-cut and must be stated precisely because we are in offensive mode: there is no agrivoltaic value to bring out. There is no crop plan under the modules, no expected yield, no agronomic monitoring. Anyone presenting this project as "agricultural" because it sits on agricultural land would commit the error that my role exists to expose: the agrivoltaic classification rests on real crop 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 land is removed from use, not shared.

4. The olive groves, the central agronomic crux

This is the point on which my expertise 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 removal and transplanting, authorisation obtained), Verde 50 olive trees (6 specimens subject to intervention). On these figures the management is governed by L.R. Puglia 14/2007, which protects olive groves and regulates uprooting and replanting.

The sensitivity is a single one and I put it on record: the Verde agronomic report (ED_10) flags the presence of trees with MONUMENTALITY characteristics, whereas in the landscape proceedings the olive trees of the holding had been declared "all non-monumental". The two statements cannot coexist. Under the agronomic profile the difference is not formal: a monumental olive tree under L.R. 14/2007 triggers reinforced protections, relocation is restricted when not prohibited, and where allowed it requires specific regional authorisation with stringent uprooting and replanting prescriptions (root ball, timing, guaranteed rooting). If even a single specimen on Verde were confirmed as monumental, two things happen: the authorisation regime for the intervention on the olive grove changes, and the layout of the plant may change, because the monumental olive tree that cannot be moved becomes a physical constraint around which the field must be re-defined.

Here I apply my confidence threshold, and I explain it because it is the rationale I ask to be allowed to defend. I do not declare the monumentality confirmed: 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 a fact what is flagged but not surveyed. So I do not close, but I do not minimise: I hold the topic at medium confidence and bring it as a binding open question, because the stake, if confirmed, is a change of constraints and of layout. This is exactly the agronomic merit that supports finding A12-D6-20260604-002 (Verde olive trees, amber, score 55, confidence 0.6): I share the A12 qualification and reinforce it from the agronomic side.

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

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 end of life of the plant.

First, the hydrogeological prescriptions from ZPSI type B: point foundations without concrete and without waterproofing, an obligation to maintain soil permeability and aquifer recharge. Under the agronomic profile this is a fact favourable to reversibility: a point anchoring without concrete slabs leaves the soil in a condition to return to being cultivable at end of life much better than a continuous foundation. I treat it as a positive element for the soil, distinct from the technical-structural constraint that belongs to A6 and from the hydrogeology that belongs to A12.

Second, the excavated soil and rock (INT_11) for cable routes and levelling: the topic, which remains owned by A12 for the environmental profile and by A8 for costs, has an agronomic reflection in the handling 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 of trees, biodiversity, green management) my agronomic reading is that it is a real mitigation measure, not a token one, but it must be said honestly: it is green management accompanying a ground-mounted PV, it is not productive agriculture under the modules. It supports the compatibility and the landscape quality of the site, 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 the R1a scoring)

I do not open findings under my own ID: the agronomic profile of D6 flows into the A12 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	Vocation and agricultural land use (~22.7 ha, arable): removal of no particular value but real
A12-D6-20260604-002	Verde	amber	55	0.60	Monumental olive groves crux 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 state explicitly that there are no findings with ID A11 in rilievi aggregati for this deal, consistent with the fact that the project is not agrivoltaic and my unit operates as a contributor, not as the owner of a D6 finding.

7. Q-list and conditions at closing

To ask the counterparty (Q-list), agronomic profile: 1. Verde olive groves: an independent agronomic survey on the monumentality status of the olive trees that ED_10 flags, to resolve the contradiction with the landscape declaration. 2. Uprooting-replanting: for the plants authorised for transplanting (29 on Giallo, specimens on Verde), replanting site, uprooting protocol and commitment to maintenance and rooting. 3. Topsoil: in the soil and rock plan, methods for removal, stockpiling and relocation of the fertile surface 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 the monumentality is confirmed, regional authorisation L.R. 14/2007 with any re-definition of the layout). This CP coincides with that of A12 and I endorse it from the agronomic side. 2. Confirmation that the authorised uproots are accompanied by actual and monitored replanting.

8. Conclusion

Under the agronomic profile the Collemurgia Cluster is a pure ground-mounted photovoltaic on agricultural land of no particular value, with no agrivoltaic value: no crops under the modules, no yield, no monitoring. The removal of about 22.7 ha of arable and tree-planted land is real but mitigated by the classification of the soil, by the Db zone, by the absence of other renewables within the 5 km buffer, by the GARDEN system and by a point anchoring that preserves reversibility.

The real agronomic crux is a single one, and it is the olive grove: the contradiction on the monumentality of the olive trees on Verde must be resolved before closing, because if confirmed it changes the protection regime under L.R. 14/2007 and potentially the layout. I do not declare it confirmed, 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 the A12 findings (green severity on the cluster, amber on the olive-grove crux), and places at closing the survey on the monumental olive groves 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 photovoltaic cluster 14 MW, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D7, economic and financial (CAPEX, OPEX, revenues, capital structure, IRR/DSCR) Professional: Olga Tarsia, Financial Analyst (Agent A8, Financial unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence basis: chapter archivio/D7-economico-finanziaria.md; 3 cost estimates present in the VDR (decommissioning and reinstatement); cost data reconstructed from D2 (connection) and D5 (land); domain benchmark knowledge/fontiA8economici.md. Records in archivio/D7/. No business plan in the VDR.

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1. Engagement and scope

I was tasked with establishing the economic and financial sustainability of the cluster: whether a buyer, at closing, is purchasing a project whose returns are modellable and defensible, or a bundle of expected revenues that no one has ever put into a spreadsheet. The question that governs my analysis is a single one, and I put it as I always put it: 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/TUF): I produce decision support for the investor, the decision remains theirs. Where the cost of an item originates in another dimension (connection is A5 in D2, land is A3 in D5, production yield is A6 in D4), I record its incidence on the cost and revenue side without intruding on the colleague's technical merits.

I must say it straight away, because it is the point around which everything else revolves: my primary evidence basis 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 EUR, Verde ~172,627 EUR, Giallo ~65,550 EUR at 29.69 EUR/kWp), total ~410,804 EUR. They cover equipment, structures, prefabricated units, fencing and video surveillance, and for Giallo the mechanical ploughing of the land. No surety or related financial guarantee is cited in the estimates. - Connection costs (from D2, A5): Blu ~286,000 EUR, Verde ~1,741,000 EUR, Giallo ~186,000 EUR, cluster total ~2.2 M EUR, compressible to ~1.2 M by self-executing the works with TICA reversion ~300K (A5-D2-001). COMPLEX works under art. 10.1 TICA, subject to cost top-ups. - Land costs (from D5, A3): rents and prices of the preliminary agreements not consolidated, charges from final deeds still to be executed, possible price renegotiations. Order of magnitude ~2.45-2.88 M EUR, not firm.

What I looked for and did NOT find, and whose absence weighs more than what I found: - Plant CAPEX: no bill of quantities for the works, no economic framework. The largest item of a utility PV, that of the modules, structures, inverters, civil works, is unknown. - Operating OPEX: no estimate of O&M, insurance, ongoing rents, charges. - The entire revenue side: no energy price assumption (no PPA, no PUN curve, no zonal capture price, no feed-in 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 every temptation to fill these gaps with a benchmark passed off as deal data. I did not do it: 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 expressly on record.

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

This is the heart of my report. In an investment the economic and 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 judgement of price.

I explain it in the terms in which I would put it to the Table. Without a business plan four things together cannot be determined, 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 (~2.2 M, compressible to ~1.2 M) and the decommissioning (~0.41 M). By domain benchmark (fontiA8economici.md) a ground-mounted utility PV sits indicatively at ~0.6-0.9 M EUR/MW of all-in CAPEX: for ~14 MWp an order of magnitude of ~8-12 M EUR. I write it as an estimate band to be confirmed with real documents, not as a plan figure: I do not have the bill of quantities for the works, 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 that A4 flags in D10 (uncovered price exposure, D10-001): without a price curve any revenue is built on thin 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 revenues it would rest on are missing. I do not have an optimistic IRR to dismantle: I have the void in place of the model.

Why is this decisive for the buyer, and not for the seller? Because the buyer would be purchasing unmodelled revenues. In offensive mode this is the greatest obstacle to a GO: one does not pay at the value of an asset whose cost of construction 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 the buyer who puts the capital at risk on figures they have not seen.

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

Here I apply my confidence threshold, and I motivate it at length because it is the rationale I ask the Table to allow me to defend.

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

I keep, however, firm the caution of offensive mode, and I translate it into a RED finding at low confidence. This 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 and financial judgement on the documents, and it is deliberately below 0.5. This is not by chance: below 0.5 the gate of the deterministic engine (R1a) flags D7 as a critical open dimension, and keeps the overall verdict at CONDITIONAL until the dimension remains not assessable. It is exactly the behaviour I want: the absence of the model must not be allowed 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 ~2.2 M total, of which ~1.74 M concentrated on Verde alone, are COMPLEX works with cost top-up risk (cross D2, A5). Even in the favourable scenario (self-execution at ~1.2 M + ~300K of reversion) it remains an item that on its own weighs on a CAPEX I do not know: in relation to a plant CAPEX estimated at ~8-12 M, the connection is a good 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 estimates quantify the cost (~0.41 M) but the related financial guarantee, often required by the permit, is not on record. It is a contingent liability that a serious BP would set aside as a reserve: today it is neither modelled nor guaranteed.
3. Land costs not consolidated. The prices of the preliminary agreements are not final (D5, A3), and with co-owned compendiums subject to hold-up the price of the plot can be renegotiated under leverage precisely because it is authorised. The land item of CAPEX is therefore itself a range, not a figure.
4. Uncovered price exposure. Pure PV in a zone of high photovoltaic 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 might 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 the R1a scoring)

The finding below is already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. 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 contradiction)

Content: dimension not assessable due to absence of business plan. Plant CAPEX unknown, revenues without P50/P90 or price. Available only connection (~2.2 M, compressible to ~1.2 M) and decommissioning (~0.41 M) costs; land ~2.45-2.88 M not consolidated. Confidence < 0.5 to trigger the critical open dimension gate. fonte_dossier of the business plan deliberately null: the document does not exist. Open question: plant CAPEX and revenue curve. Condition: complete business plan (non-waivable 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 and financial judgement, and it is precisely the signal that keeps the gate open.

7. Q-list and conditions at closing

To be requested from the counterparty (Q-list): 1. Complete business plan: CAPEX (bill of quantities for the plant and economic framework), OPEX, capital structure, debt/equity ratio, IRR, DSCR, sensitivity on price and production yield. 2. Revenue curve: PPA or price assumptions (PUN, zonal capture price), any incentives, with term and counterparty. 3. Definitive PVSYST P50/P90 as revenue basis (cross D4, A6). 4. Decommissioning surety: existence, amount, beneficiary. 5. Connection costs final 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 (D4) and cost (D2/D5) evidence, as a non-waivable condition precedent. Without it, the dimension remains not assessable and the verdict cannot exceed the 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 has never been written.

8. Conclusion

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

My judgement: D7 is not a veto, because there is no hidden contradiction to dismantle. It is the open critical issue of the dossier, an 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 gate on critical dimensions keeps the verdict at CONDITIONAL until a complete business plan, consistent with the technical and cost evidence, is in the hands of the buyer. One does not buy a return that no one 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 photovoltaic cluster 14 MW, 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 basis: 4 P1 documents from the VDR (company registry extract Solaria Sviluppo S.r.l. + 3 bundles ATTI_SOLARIA), local pipeline pdftotext -> language model; records in archivio/D8/, consolidated archivio/D8_consolidato.json

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1. Engagement and scope

I was tasked with establishing 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 before. In a transaction on SPVs the risk is not in the financial statements, 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 link in the control chain not documented: these are the defects that derail a transaction, 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 a regulated legal opinion: I produce decision support for the investor. Ownership is proved with registry extracts and deeds of the VDR, it is not presumed from the commercial narrative. Where the corporate structure touches the permitting, the land or the open sources, I flag the intersection and engage the competent colleagues (A1 permitting, A3 land, A10 OSINT) without intruding on their merits.

2. What I examined

I read the company registry extract of Solaria Sviluppo S.r.l. in its entirety: it is the most reliable source for ownership structure 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 state the limitation straight away, because it is a limitation that weighs on my judgement and I do not hide it: the head and tail reading of the bundles is sufficient to confirm name, office and director, but does not guarantee having intercepted the extraordinary deeds placed in the central body of the collections: share transfers, share pledges, guarantees in favour of lenders, capital increases. A complete inventory requires a targeted full reading, which remains to be done before closing. Below the documentary proof, I do not declare a structure clean.

3. The structural correction, and why it reclassifies the entire dossier

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

The “three SPVs” Blu, Verde and Giallo are not three distinct 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 company details I record from the registry extract:

• Form S.r.l.; share capital 10,000 euros; 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 operational 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. And here is where my professional distrust is aroused: 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 link of good faith.

4. The three implications I ask the Table to consider

First implication, on the qualification of the deal. The share capital is 10,000 euros 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 transaction: one purchases a vehicle without its own asset substance beyond the projects and the 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 transfer, remaining with the same legal entity. This is the merit of the single structure. But it brings with it the reverse: by buying the shares of Solaria Sviluppo one inherits all the liabilities of the vehicle, known and unknown, including supervening events and undisclosed encumbrances. In an asset deal that risk is left behind; in a share deal it is bought. The choice between the two structures is not neutral and must be decided with awareness, not borne passively.

Second implication, on the singularity of the entity and on V001. This is the point where my dimension feeds a node of 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 prerequisites of the aggregation are documented: same company and same legal representative (Solaria Sviluppo, Demo director, and this I ascertain 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 aggregation criteria, and it closes it with documentary proof, not by inference. I want to be precise about what is mine and what is not: I ascertain a high-confidence fact, the singularity of the entity. The qualification of V001 as a veto or as a strong condition is not mine: it is a matter for the Floor and the squad lead. I bring the documentary building block to the Table, not the verdict.

Third implication, on the non-separability of the risk. A single company for three PAS cuts in two ways. If the acquisition targets the three projects together, the singularity of the vehicle helps: a single share transfer, no fragmentation. But if the PAS regime of Blu and Verde were contested (V001), the risk is not isolable 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 they cannot compartmentalise.

5. Specific risks that concern me

1. Upstream UBO not documented. Above Meridian Capital S.r.l. the chain is interrupted in the VDR. In offensive mode I do not assume good faith: the ownership structure of Meridian Capital and the final UBO must be ascertained via OSINT (cross D9, A10), also for the anti-money-laundering aspects, and the possible links with the signatories of the preliminary agreements must be verified (Demo director, attorney-in-fact, Owner 05), already flagged by A3 in D5. An apparent control different from the effective control is precisely what I look for.
2. Extraordinary deeds not fully inventoried. The ATTI_SOLARIA bundles were read head and tail. In the central body share transfers, share pledges, guarantees to lenders, capital increases, shareholder loans may be nested. Until I inventory them in full, I cannot exclude a pledge on the shares which is exactly the type of encumbrance that, in a share deal, follows the vehicle into the hands of the buyer.
3. Consistency with the signatories of the preliminary agreements. A3 passed me in D5 a chain of signatories and powers of attorney (Demo director, attorney-in-fact, Owner 05, with special power of attorney of 15 January 2025) whose powers must be proved with the deed. The validity of those powers of attorney and their attributability to the control structure of Solaria Sviluppo touch my dimension: a deed signed by someone who did not have the powers is a defect that carries over to closing.
4. Litigation on the vehicle. Beyond the TAR appeal already known in D3, I do not have elements to exclude other pending disputes that involve Solaria Sviluppo or Meridian Capital. Without a registry extract updated to closing and without an inventory of the deeds, it is a grey area that remains open.

6. Formal findings (for the R1a scoring)

The findings below are already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. I report them for traceability; the rationale of each is in sections 3-5.

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

The higher confidence (0.85) sits on the most solid fact, the singularity of the entity: it is ascertained from the registry extract, read in full. The lower confidence (0.70) on the structure honestly reflects that UBO and extraordinary deeds are not yet closed, not a more severe assessment.

I note, and I say it clearly: I do not propose V006. My rule is firm, and I respect it even when offensive mode would push me to lower the threshold. V006 triggers on an ascertained mismatch between the holder of the permits and the SPV sold. Here the permits turn out to be 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 aspect, holds.

7. Q-list and conditions at closing

To be requested from the counterparty (Q-list): 1. Ultimate beneficial owner: ownership structure of Meridian Capital S.r.l. and final UBO, with the links towards Demo director, attorney-in-fact, Owner 05 (signatories of the preliminary agreements, D5). 2. Complete inventory of the extraordinary deeds in ATTI_SOLARIA (share transfers, pledges, guarantees, capital increases, financings), with full reading. 3. Pledges or encumbrances 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 transaction: 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 absence of pledges or encumbrances not agreed on the shares. 3. Complete inventory and clearance of the extraordinary corporate deeds before closing.

8. Conclusion

The corporate structure of the cluster 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, modest capital and inactive company. On this formal framework I have no pathological findings, and I do not propose vetoes. But the control chain is not resolved above Meridian Capital, the extraordinary deeds are not inventoried, and the transaction is in effect a purchase of assets and permits dressed up as a share deal, with all the liabilities of the vehicle following whoever buys the shares.

My judgement: D8 is not a veto, but it brings to the Table the fact that closes the first criterion of the aggregation (singularity of the entity), and that is part of the substrate of V001. 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 UBO and extraordinary deeds are documented and until the registry extract at closing is free from pledges on the shares. Below that proof, the linearity of the structure is appearance, not certainty.

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

Professional report, Dimension D9, Counterparty and intelligence

Deal: Collemurgia photovoltaic cluster 14 MW, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D9, counterparty and intelligence (profiling, reputation, narrative vs reality) Professional: Ivano Trezza, OSINT Investigator (Agent A10, Intelligence unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence basis: chapter archivio/D9-controparte-intelligence.md; corporate registry data derived from D8 (A2); entities and roles identified in D5 (A3) and D3 (A1). No external OSINT source consulted at this stage.

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1. Engagement and scope

I was tasked with establishing the counterparty: establishing who really sells this cluster, what track record it brings, and whether the seller's narrative holds up against the open sources. The question that governs my craft is always the same, and I put it also here: does whoever buys a vehicle that contains three permits know who they are dealing with, down to the last link of the control chain, and does that entity have a history that confirms what the deal promises?

I stay within the boundaries of D9. I do not compute the verdict, I do not aggregate the other dimensions, I do not issue a regulated reputational judgement: I produce decision support for the investor. Where the control chain or the ownership touches the corporate or the permitting, I flag the intersection and engage the competent colleagues (A2 on D8, A1 on D3) without intruding on their merits. And I treat the data on natural persons with the minimum necessary for the DD, for discipline and for GDPR.

2. What I examined, and what I could NOT examine

This is the point from which I must start with honesty, because it is the fact that conditions everything else in the report. The VDR does not contain any document dedicated to the counterparty: no intelligence note, no profile of the proponent, no reputational evidence. The D9 dimension is not covered with the documents of the seller, by its nature: it is covered with external OSINT, that is with the interrogation of the open sources (companies register, press, public deeds, public databases, public litigation).

That external OSINT was not performed at this stage. The methodological choice of the DD privileged local extraction of the VDR documents; external verification on the counterparty was deferred to a dedicated step. So what I have before me are not investigation results: it is an investigation perimeter still open. I worked by derivation, gathering from the colleagues' reports the entities and roles that will need to be verified, and I ordered them in a list to be interrogated. But I do not have a single open source consulted and dated to put on record, and my rule of conduct is clear: without a verifiable and dated source I do not assert a fact about the counterparty. For this the gap is not an omission that I hide: the gap IS my finding.

3. The entities to be verified, and why they matter

From the other dimensions a network of entities emerges that in a share deal must be profiled, not presumed. I list them with the role that makes them relevant:

1. Solaria Sviluppo S.r.l. (tax code 00000000000, (office omitted)). It is the single vehicle being sold: sole shareholder, holder of the three PAS, inactive, capital 10,000 euros (D8). In a share deal I do not buy a plot of land, I buy this box with all it contains and all it carries with it, including any latent liabilities. I must know whether Solaria Sviluppo has precedents, litigation, exposures.
2. Meridian Capital S.r.l., 100% sole shareholder of Solaria Sviluppo (D8). It is the screen between the vehicle and the ultimate beneficial owner. UBO and structure are not documented. Until I know who controls Meridian Capital ultimately, I do not know who the real counterparty is, and this is a matter of adequate anti-money-laundering verification even before being reputational.
3. Demo director, sole director of Solaria Sviluppo and signatory of the preliminary agreements (D5, D8). It is the operative signature of the deal: their track record as a PV developer (projects built versus projects merely announced) is the most direct signal on the reliability of whoever sells.
4. an attorney-in-fact and Owner 06, signatories and attorneys of the preliminary agreements and of the amending deeds (D5). They appear and reappear in the contractual cascade. Their signing powers and their links with Demo director and with the land counterparties must be mapped, to exclude related parties and signatures without authority.
5. The land counterparties with fragmentation and hold-up (Owner 26, Owner 15, Owner 19-Owner 10-Owner 08, up to 7 co-owners on a compendium, from D5). Here OSINT serves to understand whether behind the opposition or the price renegotiations there are linked entities or conflicts.
6. The outcome of the TAR appeal of Solaria Sviluppo against the Municipality (D3). It is the only known litigation, but its status is unknown: OSINT must recover it from the TAR Bari docket.

4. Why counterparty verification is due precisely here (rationale)

This is the heart of my reasoning, and I want to motivate it at length, because it is the rationale I ask the Table to allow me to defend.

In an asset deal the counterparty matters less: one buys a thing, and the thing is verified for what it is. In a share deal, and here we are precisely in a share deal on Solaria Sviluppo (A2 confirms it in D8), one buys the entity: one takes on its history, its potential liabilities, its litigation, its reputation. The commercial narrative presents the cluster as ready to build with permits in hand; but A3 in D5 has already documented that the real maturity is lower than declared (final deeds not executed after two years and two extensions). When the narrative is already disproved on a verifiable dimension, in offensive mode my duty is to ask myself whether it holds up on the others, and the counterparty is the first to deserve that question.

There is then an upstream node that troubles me in a specific way: the control chain is opaque. Meridian Capital is a screen and the UBO is not documented. In offensive mode this is not a formal detail: it is a hole in the knowledge of who I am paying, with anti-money-laundering implications. I do not turn it into a suspicion of wrongdoing, that would be incorrect and contrary to my confidence threshold; but I flag it as an open precautionary risk until verification closes it.

The open sources that will need to be interrogated are, in order of priority: the companies register (complete registry extracts of Solaria Sviluppo and Meridian Capital, shareholder chain up to the UBO, extraordinary deeds, any pledges on the shares in coordination with A2); the TAR Bari docket for the status of the appeal; the sector and local press for the track record of Demo director and for committee opposition to the project; the public databases on litigation and insolvency proceedings against the entities; the public lists GSE/disputes where relevant. They are interrogable with search tools with citations (such as /pplx or /exa), which return the dated source that my discipline requires.

5. Why the confidence is low, and why it is not a severe judgement

Here I apply my confidence threshold, and it is the most delicate part of the judgement. I set the confidence at 0.4, and I want it to be understood what it means: it is not a negative assessment of the counterparty. It is the honest measure of my ignorance. I have not consulted a single open source, so everything I might say about Solaria Sviluppo, Meridian Capital, Demo director, attorney-in-fact, Owner 05 would be uncorroborated, and my anti-hallucination rule forbids me from promoting to fact what I have not verified. The confidence is low by construction, because the dimension has not been investigated, not because I have found something rotten.

From this follows the most important thing: I do not invent OSINT results. I do not write that Demo director is a serial developer of projects never built, nor that he is a solid operator: I do not know, and I will not know until I have the sources. What I put on record is that verification is due and has not been done. The severity I keep in the red/yellow band precisely for this: in offensive mode a counterparty dimension not investigated, on a share deal with an opaque UBO, is an open risk, not a green light.

6. Formal findings (for the R1a scoring)

The finding below is already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. I report it for traceability; the rationale is in sections 2-5.

Finding	Subject	Severity	Score	Confidence	Veto
A10-D9-20260604-001	Counterparty not investigated (OSINT not performed)	yellow (red/yellow band)	40	0.40	none

The 0.40 confidence honestly reflects that the dimension is covered only by the corporate registry data of D8 and that no OSINT was performed: UBO of Meridian Capital, track record of Solaria Sviluppo/Demo director, outcome of the TAR appeal and related parties among the signatories (attorney-in-fact, Owner 05) remain not verified. It is to be raised after OSINT. I am not the owner of a structural veto; if OSINT were to bring to light an inconsistency on ownership, I would feed A2's D8 finding (potential V006), citing only existing vetoes in tools/veti.yaml.

7. Q-list and conditions at closing

To be requested from the counterparty and to be verified via OSINT (Q-list): 1. Complete ownership structure of Meridian Capital S.r.l. up to the UBO (ultimate beneficial owner), with anti-money-laundering declaration. 2. Track record of Solaria Sviluppo/Meridian Capital/Demo director in PV development: plants built and in operation versus pipeline merely announced. 3. Status of the TAR appeal of Solaria Sviluppo against the Municipality (TAR Bari docket): pending, decided, withdrawn. 4. Litigation, payment orders, insolvency proceedings against Solaria Sviluppo, Meridian Capital and the signatories. 5. Links and related parties between Demo director, attorney-in-fact, Owner 05 and between these and the land counterparties. 6. Local reputation of the project: committee opposition, local press, third-party appeals.

Condition precedent to closing (CP) that I ask to put in the contract: 1. Counterparty OSINT completed pre-closing on Solaria Sviluppo, Meridian Capital, Demo director, attorney-in-fact, Owner 05 and on the TAR outcome, with UBO of Meridian Capital ascertained. The dimension cannot remain not investigated in a share deal: either the verification is closed, or the risk remains open and must be priced.

8. Conclusion

The counterparty dimension is today not investigated: the VDR contains no dedicated material and the external OSINT was not performed. This, and nothing else, is my finding. In a share deal on a vehicle with an opaque control chain upstream (Meridian Capital, UBO unknown) and with a narrative already disproved elsewhere on the maturity of the deal, the reputational and counterparty verification is not an extra: it is due, and until it is done it remains an open risk.

My judgement: D9 is not a veto, but it is a gap that asks to be closed before closing, not after. I keep the confidence at 0.40 to say with precision that I do not yet know who the counterparty really is, and I refuse to fill that void with results I have not verified. The OSINT must be launched as a dedicated step before the final verdict: it is the only thing that can turn this low confidence into a fact, in one sense or the other. On this I do not compromise.

Ivano Trezza, OSINT Investigator Ultimate Big 5 Energy Squad, Intelligence unit, Agent A10

Professional report, Dimension D10, Market and regulatory framework

Deal: Collemurgia photovoltaic cluster 14 MW, SPV Giallo, Verde, Blu (single vehicle Solaria Sviluppo S.r.l.) Dimension: D10, market and revenue exposure, FER regulatory framework Professional: Bianca Orsenigo, Regulatory Lawyer (Agent A4, Legal unit) Mode: offensive, buyer side Date: 4 June 2026 Evidence basis: chapter D10 (archivio/D10-mercato-regolatorio.md); technical-descriptive report (PAS regime, suitable areas), teaser and client notes; updated domain knowledge (fontiA4*, fontiA1autorizzativo.md). The VDR contains no documents dedicated to market and regulation, nor a business plan: medium confidence declared.

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1. Engagement and scope

I was tasked with establishing the market risk and regulatory framework of the cluster: establishing whether the return of this investment rests on a stable context and on documented revenues, or on an uncovered price exposure and on a simplified regime that might not hold. The question that governs my analysis is the one I always put: how fragile is the framework that holds up the return, and how much of this revenue is actually contracted rather than assumed?

I stay within the boundaries of D10. I do not compute the verdict, I do not aggregate other dimensions, I do not recompute the IRR (A8 does that), I do not issue a legal or regulated investment opinion: I produce decision support for the investor. Where the regulatory risk transfers onto the revenue, I feed A8's financial merits without intruding; where it touches the permitting climate, I coordinate with A1.

2. What I examined, and what I could not examine

I read the regulatory framework reconstructible from the dossier: the permitting regime (PAS under art. 22-bis Legislative Decree 199/2021 on an area classified suitable under art. 20, Db zone), the national context TU-FER (Legislative Decree 190/2024 and corrective decree 178/2025), the suitable areas regime (Legislative Decree 199/2021 and implementing Ministerial Decree) with its Puglia regional implementation. I read the design data from the teaser (cluster of about 14.13 MWp, about 12.4 MW fed in, MV 20 kV, fixed structure) and the client notes.

I must say it clearly, because it is the limitation that weighs most on my judgement: on the revenue side I had nothing to read. In the VDR there is no business plan (A8 certifies it in D7), there is no PPA, there is no price curve, there is no zonal price assumption. My craft is to place the revenue in the correct mechanism and measure its stability; here the revenue is not placed in any mechanism, because the mechanism is not documented. For this my assessment is a domain assessment, not from dedicated documents, and I mark it at medium confidence (0.5).

3. The revenue node, and why it matters

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

The deal is tagged fv_bess, but the plant on sale today is pure photovoltaic: no storage in the authorised project (A6 ascertains it in D4). The BESS is not part of this asset: it is a client thesis, a future upside on the industrial land retained. For market risk this distinction is decisive, and I put it on record: a pure PV cannot shift energy to the hours when it is worth most, and therefore is structurally exposed to the price of the moment in which it produces.

On that price, the framework I have before me is the worst possible for the buyer:

1. The price exposure is total and uncovered. Without a PPA and without any assumption in the VDR, the revenue falls entirely on the market (PUN, today zonal prices). It is not a mitigated risk: it is a risk not documented. Without a price curve it is not technically possible to estimate the revenues, and it is for this that my finding ties to A8's red on D7.

2. Capture, not only production yield, decides the revenue. We are in the South, in a zone of very high photovoltaic penetration. The high penetration compresses the capture price in the central hours, precisely when a PV produces. The value of a photovoltaic kWh in the South zone in solar peak hours is not the average price: it is a cannibalised price. A pure PV, without storage that shifts the energy to the evening hours at full price, takes this discount in full. It is a market positioning issue, not only a technical choice.

3. Curtailment is a growing and concrete risk. In areas of strong renewable concentration the limitation of feed-in is increasing. It must be discounted in the production yield assumptions, the net not the gross. Added to low capture, it erodes expected revenues more than rated production yield alone would suggest.

In my craft this is the typical contradiction: an asset sold as ready, whose return rests on a revenue that no one has yet put on paper. The future BESS thesis, if realised, would mitigate capture and curtailment, but it is precisely a conditional upside, not a fact of the current deal, and in offensive mode I do not endorse it as acquired.

4. The regulatory risk, and why it is also a market risk

Here I apply my lens, which is that of the stability of the framework. Two planes.

The regulatory value of the cluster rests on the maintenance of the PAS. The simplified regime is the key to the rapid process, but it is also the attackable point: the aggregation beyond 10 MW is the node V001 (cross D2, D3, D8). I say it for what is within my competence: the robustness of the cluster's regulatory framework depends on the qualification of that node. The qualification of V001 is not mine, I refer it to A1, R1 and the Floor; but I note that the aggregation risk is not only permitting, it is also regulatory, because it strikes the title on which the entire economics of the deal rests. I note, and it reassures me in part, the de-risk already documented (publication in the Puglia BUR April 2025, the 120 days for objections having elapsed, the Region having brought it back to art. 22-bis): it makes the fact no longer ascertainable against the project, but it does not zero out the residual litigation risk.

The risk of regulatory change, here, is contained but not nil. The FER context is in evolution (TU-FER, corrective decree 178/2025, suitable areas regime being settled in Puglia). My rule is clear: a change of the suitability criteria or of the thresholds affects similar future projects, less so a title already perfected like this one, save for the case of litigation. I do not see, as things stand, a dependence of the revenue on an announced incentive not yet in force, nor on an auction not awarded: it is a positive fact, and I record it as such. But precisely because of my confidence threshold, where I do not have proof I do not assume stability: the Puglia climate on renewables is highly attentive to landscape and hydraulics, and the regional suitable areas regime is still being settled. This is a context risk to be kept open, not to be filed away.

5. Specific risks that concern me

1. Revenue not contracted in an asset sold as mature. It is the main risk. The price paid today implicitly discounts a revenue that is neither contracted (no PPA) nor estimated (no price curve, no business plan). In offensive mode, an undocumented revenue is a full risk, not a detail to be defined at closing.

2. Technology-market misalignment (pure PV in a saturated zone). The choice of pure PV in the South zone of high penetration maximises exposure to low capture and curtailment. Without storage, the revenue profile is the worst possible for the zone. The future BESS thesis is not within the perimeter of this asset.

3. Dependence on the robustness of the PAS regime. The economic framework of the cluster hangs on the simplified regime, and therefore on the node V001. An unfavourable outcome on the title (cross D3, TAR appeal of Solaria Sviluppo cited by A1) is not only a permitting problem: it is a problem of revenue, because without the title there is no plant and there is no market.

4. Absence of a specific capture and zonal basis analysis. No document estimates the capture price and the basis for the connection point and the market zone of the plant. It is a missing assumption that, on its own, can shift the revenue estimate significantly.

6. Formal findings (for the R1a scoring)

The finding below is already compliant with tools/rilievo.schema.json and merged into rilievi aggregati. I report it for traceability; the rationale is in sections 3-5.

Finding	Scope	Severity	Score	Confidence	Veto
A4-D10-20260604-001	Market and regulatory	yellow	50	0.50	none (feeds A8's V003 if relevant)

The confidence at 0.50 is a conscious and honest choice: it reflects that it is a domain assessment in the absence of dedicated documents and of a business plan, not an attenuated judgement on the merits. Consistent with my threshold, I do not quantify as certain a revenue that no documented mechanism holds, and I do not endorse the BESS upside as acquired. I am not the owner of a structural veto on D10: where the market risk makes the return implausible, I feed A8's finding (V003, inflated return), I do not propose a veto of my own.

7. Q-list and conditions at closing

To be requested from the counterparty (Q-list): 1. Strategy for selling the energy: PPA (counterparty, term, price, structure) or merchant? Are there price hedges, even partial? 2. Capture and curtailment analysis specific to the market zone and to the connection point, with declared zonal basis. 3. Robustness of the PAS regime against regulatory developments on suitable areas: independent regulatory opinion (cross D3, V001). 4. If the BESS thesis is part of the valuation: permitting status, sizing and timing of the future storage, today outside the asset.

Conditions precedent to closing (CP) that I ask to put in the contract: 1. Market and/or PPA strategy defined and reflected in the business plan (cross D7, a condition that ties to A8's red). 2. Independent opinion on the stability of the regulatory framework of the title (cross D3, V001), in particular on the robustness of the PAS against the aggregation.

8. Conclusion

The regulatory framework of the cluster is consistent but not self-sufficient: PAS on a suitable area, FER context in evolution that affects little a title already perfected, but the whole thing hanging on the robustness of the simplified regime and therefore on the node V001. On the market side, instead, the judgement is clear: the revenue is not covered and not documented. No PPA, no price curve, a pure PV in the most exposed zone in Italy to low capture and curtailment, and a BESS that exists only as a future thesis outside the perimeter sold.

My judgement: D10 is not a veto, but it is one of the heaviest areas of uncertainty of the operation, because it touches directly the figure on which an investment is decided, the revenue. In offensive mode I do not endorse a return hanging on a revenue that no one has yet put on paper. The price is not paid on the presumption of a favourable market until the energy sale strategy is defined and the regulatory framework of the title is confirmed stable by an independent opinion. On this I do not compromise.

Bianca Orsenigo, Regulatory Lawyer Ultimate Big 5 Energy Squad, Legal unit, Agent A4