Exhibit X - Ecological Impact Assessment by Doug Herling

Ecological Impact Assessment

Morrow County, Ohio

Prepared for:

Crossroads Solar I, LLC

1105 Navasota Street

Austin, Texas 78702

Prepared by:

Verdantas

6397 Emerald Parkway, Suite 200

Dublin, Ohio 43016

262-707-9092

Verdantas Project No: 17078

August 2025

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Tables (In-Text)

Table 1 Summary of Estimated Stream Impacts During Construction

Table 2 Summary of Estimated Vegetation Clearing During Construction

Table 3 Summary of Estimated Operational Impacts

Appendices

Appendix A Preliminary Horizontal Directional Drill Inadvertent Return Response and Contingency Plan

1. Introduction

This Ecological Impact Assessment (“Report”) has been prepared for the Crossroads Solar Grazing Center (“Crossroads”) Crossroads is proposing to construct a combined utility-scale solar energy and sheep grazing facility in Cardington, Lincoln, and Westfield Townships in Morrow County, Ohio (the “Project” or the “Facility”). The Project will use rows of ground-mounted solar panels to supply up to 94 megawatts AC (MWac) of wholesale power to the existing electric grid while also providing pasture for livestock. All of the Project’s above-ground structures will be located within agricultural-style fences, which also will confine the livestock and protect them from predators. The fenced area will be up to 559 acres (the “Solar & Grazing Area”) of an area totaling approximately 726 acres (the “Project Area”).

Verdantas LLC (Verdantas) was contracted by Crossroads Solar I, LLC (Crossroads Solar) to analyze the potential impacts to sensitive natural resources and describe the methods by which such impacts can be avoided or minimized. This assessment summarizes and builds upon the results of the Wildlife and Habitat Assessment Report and Surface Water Delineation Report prepared for the Project. This assessment includes a quantification of the impacts to sensitive land covers and a summary of certain planned avoidance and minimization strategies. This report complies with the requirements of the Ohio Power Siting Board (OPSB) rules set forth in Ohio Administrative Code (OAC) 4906-4-08(B) and 4906-4-09(A). This report provides the text of each part of that provision, below, followed by the responsive information.

2. Ecological Information

2.1 Map of Ecological Resources

Section OAC 4906-4-08(B)(1)(a) requires a map with a 1,000-foot radius around the Project, showing information regarding ecological resources including but not limited to undeveloped or abandoned land subject to mining activities, wildlife areas, natural preserves, and other conservation areas, surface bodies of water and wetlands, highly erodible soils, slopes of 12 percent or greater, areas of proposed vegetative clearing, naturally occurring woody or herbaceous vegetation land, and areas identified as sensitive habitat, including that used for breeding, of species that may be impacted by the Project, and identified through coordination with Ohio Department of Natural Resources (ODNR) and U.S. Fish and Wildlife Service (USFWS). The Ecological Features Map is included as a figure within the Project’s Application.

2.2 Vegetation Survey and Surface Water Delineation

Section OAC 4906-4-08(B)(1)(b) requires a field study of vegetation and surface waters within 100 feet of potential construction areas. Section 4 of the Wildlife Habitat Assessment and Section 3 of the Surface Water Delineation Report submitted with the Project’s Application address, respectively, these criteria for the proposed fenced boundary of the Project (Project Area). The Surface Water Delineation Report identifies the locations and boundaries of potentially jurisdictional wetlands and streams and includes a detailed explanation of delineated features. The Wildlife Habitat Assessment identifies field-verified cover types, including vegetation within the Project Area.

2.3 Probable Impact to Vegetation and Surface Waters

Section OAC 4906-4-08(B)(1)(c) requires a description of anticipated impacts of the construction of the Project on vegetation and surface waters, including impacts from clearing and grading, as well as the proposed crossing methodology of each stream and wetland that would be crossed by any part of the Facility during construction. Probable impacts, including but not limited to those resulting from vegetation removal, grading, and surface water crossings, are included in Section 4 of this report.

2.4 Plant and Animal Literature Review

Section OAC 4906-4-08(B)(1)(d) requires a literature survey of the plant and animal life within a 0.25-mile area around the Project Area. Verdantas ecologists conducted a desktop assessment and literature review to assess the types of plant and animal life that would be likely to occur within 0.25 miles of the Project Area. The work addresses species of commercial or recreational value, as well as those designated as threatened or endangered. Discussion of the results of the plant and animal literature review is provided in Section 3 of the Wildlife and Habitat Assessment, submitted with the Project’s Application.

2.5 Plant and Animal Field Surveys

Section OAC 4906-4-08(B)(1)(e) requires field surveys of the resources identified in the literature review, an evaluation of anticipated impacts to those species, and proposed impact avoidance and minimization efforts. Verdantas ecologists performed field surveys to identify types, locations, and extents of potentially suitable habitats for threatened and endangered species and species of commercial and recreational value within the Project Area plus a survey buffer (Ecological Study Area). While on-site, ecologists recorded all wildlife observations. Refer to the Sections 46 of the Wildlife and Habitat Assessment Report, included with the Project’s Application, for additional detail.

2.6 Other Studies

Section OAC 4906-4-08(B)(1)(f) requires a summary of any additional studies which have been made by or for the Applicant addressing the ecological impact of the proposed Facility. No further studies have been completed with regard to potential ecological impacts of the Project.

3. Construction Impacts

3.1 Temporary Impacts During Construction

With regard to the potential impacts to ecological resources during construction, Section OAC 4906-4-08(B)(2)(a) requires the following:

“

(i) A table displaying the report name, linear feet and acreage impacted, quality, flow regime, and the proposed crossing methodology of each stream that would be crossed by or within the footprint of any part of the facility or construction equipment.

(ii) A table displaying the report name, acreage impacted, quality, Cowardin classification, and the proposed crossing methodology of each delineated wetland that would be crossed by or within the footprint of any part of the facility or construction equipment.

(iii) A table displaying the extent of clearing of each vegetative community type, including a clearing total.

(iv) A description of how such clearing work will be done so as to minimize removal of woody vegetation and minimize forest fragmentation.

(v) A description of impacts to wildlife, including listed species identified through coordination with the Ohio Department of Natural Resources and/or the United States Fish and Wildlife Service, will be avoided or minimized.”

Impact descriptions are displayed in accordance with these requirements in this section of the report. A description of how the Project will minimize removal of woody vegetation and minimize forest fragmentation is included in Section 3.1 of the Preliminary Vegetation Management Plan; additionally, a discussion of forested areas in the context of species habitat is included in Section 4.1.2 of the Wildlife and Habitat Assessment Report. These documents are provided with the Project’s Application.

3.1.1 Stream and Wetland Crossings

Throughout the design process, efforts to minimize ecological impacts have resulted in reduced stream and wetland impacts, confined only to those areas which cannot be avoided while maintaining the constructability of the Project. Construction-related stream crossings are summarized in Table 1 and wetland crossings are summarized in Tabel 2, below. Streams and wetlands delineated within the Ecological Study Area are detailed in Section 4 of the Surface Water Delineation Summary Report, provided with the Project’s Application.

Note that fences depicted within the Preliminary Maximum Site Plan as crossing streams are shown for illustrative purposes only; no temporary or permanent impacts from fences are proposed to occur within streams or wetlands. As Project design progresses, if impacts to streams occur due to culverted crossings or open cut crossings, Crossroads is expected to obtain all necessary permits from U.S. Army Corps of Engineers (USACE) and/or the Ohio Environmental Protection Agency (Ohio EPA).

Stream 1

Table 1. Summary of Estimated Stream Impacts During Construction

Crossroads Solar Grazing Center

Stream 2

Branch Alum Creek)

1. Determined by Verdantas based on current regulatory guidance, subject to verification by USACE

2. Determine by Verdantas, subject to verification by the Ohio EPA

3. Horizontal Directional Drilling.

As currently designed, all above-ground Project infrastructure will avoid crossing wetlands. As Project design progresses, if impacts to wetlands are proposed, Crossroads is expected to obtain all necessary permits from the USACE, and/or Ohio EPA.

Table 2. Summary of Estimated Wetlands Impacts During Construction

1. Determined by Verdantas based on current regulatory guidance, subject to verification by USACE

2. Horizontal Directional Drilling.

3.1.2

Vegetation Clearing

Vegetation clearing is necessary to facilitate construction of the Project, including those areas where infrastructure will be placed, as well as in areas requiring temporary equipment access. The Project is sited within an area comprising primarily previously disturbed agricultural land. As such, vegetation clearing impacts will largely be avoided. Potential clearing impacts to various vegetation types are summarized in Table 3, below.

It should be noted that because this assessment assumes the maximum potential area of clearing, the values in Table 3 are anticipated to be over-estimates of the actual clearing that will be required. Within the Project’s above-ground buildable area, the maximum estimated acreage of tree clearing (primarily fence rows) was estimated to be approximately 3.31 acres based on fieldverified habitat delineated during habitat surveys and described in Section 4 of the Wildlife and Habitat Assessment, included with the Project’s Application. Further, wetlands within the Ecological Study Area have been field delineated and, as currently designed, no wetland vegetation clearing is proposed. As Project design progresses, if impacts to wetlands are proposed, Crossroads is expected to obtain all necessary permits from USACE, and/or Ohio EPA.

Crossroads Solar Grazing Center Ecological Impact Assessment

Source: Field Verified Land Cover Types

1Temporary fence construction area assumed to be 20 feet wide

Table 3. Summary of Estimated Vegetation Clearing During Construction

3.1.3 Construction-Related Impacts to Wildlife

As currently designed, the Project is avoiding impacts to wetlands and is largely avoiding impacts to areas that may support protected wildlife such as forested areas. Refer to the Wildlife and Habitat Assessment, provided with the Project’s Application, for additional detail related to sensitive wildlife and habitat in the vicinity of the Project, the Project’s ongoing coordination with wildlife agencies, and additional discussion on measures that may be implemented to avoid or minimize impacts to sensitive species.

3.2 Mitigation of Impacts During Construction

With regard to the mitigation procedures to be utilized to minimize potential construction impacts, Section OAC 4906-4-08(B)(2)(b) requires a description of the following:

“(i) Plans for post-construction site restoration and stabilization of disturbed soils, especially in riparian areas and near wetlands. Restoration plans should include details on the removal and disposal of materials used for temporary access roads and construction staging areas, including gravel.

(ii) A detailed frac out contingency plan for stream and wetland crossings that are expected to be completed via horizontal directional drilling detailing environmental specialist presence, monitoring of drilling procedures and discharges within surface water resources, containment measures, cleanup and vacuum truck availability, and timelines and methods of restoration.

(iii) Methods to demarcate surface waters and wetlands to protect them, including any proposed buffers, from entry of construction equipment and material storage or disposal.

(iv) Procedures for inspection and repair of erosion control measures, especially after rainfall events.

(v) Methods to protect and plans for restoration of vegetation in proximity to any project facilities from damage, particularly mature trees, wetland vegetation, and woody vegetation, in riparian areas.

(vi) Options for disposing of downed trees, brush, and other vegetation during initial clearing for the project, and clearing methods that minimize the movement of heavy equipment and other vehicles within the project area that would otherwise be required for removing all trees and other woody debris off site.

(vii) Avoidance measures for state or federally listed and protected species and their habitat, in accordance with paragraph (D) of rule 4906-4-09 of the Administrative Code.

(viii) Measures to divert storm water runoff away from fill slopes and other exposed surfaces.

(ix) A description of any expected use of herbicides for maintenance.”

Each of the above items is discussed below.

3.2.1 Post-Construction Soils

The majority of proposed impacts will occur in previously disturbed agricultural lands, with only limited impacts to sensitive natural resources. The preservation of agricultural soils, however, is important to Crossroads, Morrow County, and the State of Ohio. For information regarding the Project’s expected impacts to agricultural soils and planned methods to minimize such impacts during construction, operation, and decommissioning, including plans for post-construction site restoration and stabilization of disturbed soils, refer to the Preliminary Agricultural Soils Management Plan, provided with the Project’s Application.

3.2.2 Frac-Out Contingency Plan

For information about the contingency plan for stream and wetland crossings that are expected to be completed via horizontal directional drilling, please refer to the Preliminary Horizontal Directional Drilling Inadvertent Return Response and Contingency Plan (Appendix A).

3.2.3 Methods to Demarcate Waters

Wetlands and waterbodies that are planned for avoidance should be clearly marked with construction fencing, or similar method, in the field prior to the start of construction. Construction crews should be informed of the locations, boundaries, and demarcation methods for each protected surface water. All required state, federal, and local permits will be obtained prior to beginning work within any of these features. Furthermore, as currently designed, all above-ground Project infrastructure has been sited to include a 120-foot non-disturbance buffer from avoided wetlands and a 50-foot non-disturbance buffer from delineated streams.

3.2.4 Inspection and Repair of Erosion and Sediment Control Measures

The Project plans to implement erosion and sediment control measures, including installation of devices prior to the start of construction, and regular inspection and repair of those measures throughout construction. An Erosion and Sediment Control (ES&C) Plan and Stormwater Pollution Prevention Plan (SWPPP) will be developed in later stages of Project design to support obtaining a construction stormwater permit under the National Pollution Discharge Elimination System (NPDES). During construction, it is anticipated that the ES&C Plan, SWPPP, and NPDES permits will be followed to minimize potential impacts to vegetation outside of the construction footprint.

Disturbed soils will be managed according to the ES&C Plan, SWPPP, and NPDES permits. Areas of exposed soil will be stabilized with cover crops to prevent significant erosion and sedimentation into nearby waterways. During construction, trained inspectors will be tasked with monitoring proper installation and effectiveness of erosion control measures.

3.2.5 Vegetation Protection

3.2.6 Vegetation Disposal and Clearing

Selective clearing of vegetation will be limited to the necessary construction and operation areas. Methods include manual clearing with hand tools for small, hard-to-reach areas, clearing with herbicides for dense growth, and mechanical clearing with heavy machinery for large areas and debris. Vegetation should be separated from other construction debris and disposed of according to legal guidelines. Refer to Section 3.1 of the Preliminary Vegetation Management Plan, provided with the Project’s Application, for additional information about clearing and removal of vegetation.

3.2.7 Protected Species Avoidance

The majority of natural forest stands and forested wildlife corridors are avoided by Project infrastructure, as currently designed. Project impacts are primarily within cultivated croplands that provide low-quality habitat for wildlife. Significant impacts to protected wildlife are therefore not expected as a result of the proposed Project. For additional information related to potential wildlife impacts and recommendations from USFWS and ODNR to minimize potential impacts to state and federally listed and protected species, including aquatic organisms, and their habitats, refer to the Wildlife and Habitat Assessment Report, provided with the Project’s Application.

3.2.8 Stormwater Runoff Diversion

The Project plans to implement erosion and sediment control measures, including installation of devices prior to the start of construction, and regular inspection and repair of those measures throughout construction. The Preliminary Grading Plan, provided with the Project’s Application, includes descriptions of measures used to control stormwater runoff during construction. Furthermore, an ES&C Plan and SWPPP will be developed in later stages of Project design to support obtaining a construction stormwater permit, as required under the NPDES general permit During construction, it is anticipated that the ES&C Plan, SWPPP, and NPDES permits will be followed to minimize potential impacts to vegetation outside of the construction footprint.

3.2.9 Maintenance and Herbicide Use

In general, vegetation within the Project will be managed by grazing sheep, supplemented with mechanical vegetation management, as needed. Thus, use of herbicides to manage vegetation within the Project is expected to be minimal. Refer to the Preliminary Vegetation Management Plan and the Preliminary Agricultural Soils Management Plan, provided with the Project’s Application, for additional detail regarding proposed management of vegetation.

4. Operational Impacts

4.1 Impacts During Operation

With regard to the potential impacts to ecological resources during operation, Section OAC 49064-08(B)(3)(a) requires the following:

(a) An evaluation of impact of operation and maintenance on the undeveloped areas shown in response to paragraph (B)(1) of this rule.

Note that no Project-related impacts to undeveloped areas subject to past or present mine activities, wildlife areas, nature preserves, or other conservation areas, areas containing highly erodible soils or soils with 12 percent slopes or greater are anticipated. Note also that coordination with USFWS and ODNR did not identify areas of critical habitat in the vicinity of the Project. Potentially suitable habitat for protected species is discussed in Section 3-5 of the Wildlife and Habitat Assessment Report, provided with the Project’s Application. A summary of the estimated operational impacts to undeveloped areas is included in Table 4, below.

Within the Project’s above-ground buildable area, the operational impacts are based on fieldverified habitat delineated during habitat surveys and described in Section 4 of the Wildlife and Habitat Assessment, included with the Project’s Application. As currently designed, no temporary or permanent impacts to wetlands are proposed. As Project design progresses, if impacts to wetlands are proposed, Crossroads is expected to obtain all necessary permits from the USACE, and/or Ohio EPA These impacts have been estimated based on the Preliminary Maximum Site Plan, provided with the Project’s Application.

Table 4. Summary of Estimated Operational Impacts

Source: Field Verified Land Cover Types 1

4.2 Minimization of Impacts During Operation, Maintenance and Use

With regard to the mitigation procedures to be utilized to minimize the potential operation impacts, Section OAC 4906-4-08(B)(3)(b) and (c) and Section OAC 4906-4-08(B)(4) and (5) require the following:

“(b)(i) The procedures to be utilized to avoid, minimize, and mitigate both the short-and long-term impacts of operation and maintenance.

(ii) Methods for protecting streams, wetlands, and vegetation, particularly mature trees, wetland vegetation, and woody vegetation in riparian areas.

(iii) A description of any expected use of herbicides for maintenance.

“(4) A description of any mitigation procedures to be used during construction, operation, and maintenance of the proposed facility to minimize the impact on vegetation, surface waters, and species identified in paragraph (B) of this rule.

(5) A description of anticipated actions to prevent establishment and/or propagation of noxious weeds identified in Chapter 901:5-37 of the Administrative Code and invasive species identified in rule 901:5-30-01 of the Administrative Code during implementation of any pollinator-friendly plantings. Additionally, a description of the commitment to comply with any public orders concerning the abatement of noxious weeds. “

In addition, Section OAC 4906-4-09(A)(3)(c)-(f) requires the following:

(A)(3)(c) The applicant shall have a vegetation management plan. The plan must identify all areas of proposed vegetation clearing for the project, specifying the extent of the clearing, and describing how such clearing work will be done so as to minimize removal of woody vegetation. The plan must also describe how trees and shrubs around structures, along access routes, at construction staging areas, during maintenance operations, and in proximity to any other project facilities will be protected from damage. Priority should be given to protecting mature trees throughout the project area, and all woody vegetation in wetlands and riparian areas, both during construction and during subsequent operation and maintenance of all facilities; low-growing trees and shrubs in particular should be protected wherever possible within the proposed right-of-way. The vegetation management plan should also explore various options for disposing of downed trees, brush, and other vegetation during initial clearing for the project, and recommend methods that minimize the movement of heavy equipment and other vehicles within the right-ofway that would otherwise be required for removing all trees and other woody debris off site.

(d) For both construction and future right-of-way maintenance, the applicant shall limit, to the greatest extent possible, the use of herbicides in proximity to surface waters, including wetlands along the right-of-way. Individual treatment of tall-growing woody plant species is preferred, while general, widespread use of herbicides during initial clearing or future right-of-way maintenance should only be used where no other options exist, and with prior approval from the Ohio environmental protection agency. Prior to commencement of construction, the applicant shall describe the planned herbicide use for all areas in or near

any surface waters during initial project construction and/or future right-of-way maintenance.

(e) The applicant shall prevent the establishment and propagation of noxious weeds identified in Chapter 901:5-37 of the Administrative Code in the project, including its setback areas, during construction, operation, and decommissioning via procedures and processes specified and required by the project's vegetation plan. The applicant shall provide annual proof of weed control for the first four years of operation, with the goal of weed eradication significantly completed by year three of operation.

(f) Within its plans for post-construction site restoration and stabilization of disturbed soils, such restoration plans shall include:

(i) The applicant shall remove all temporary gravel and other construction staging area and access road materials after completion of construction activities, as weather permits, unless otherwise directed by the landowner.

(ii) The applicant shall not dispose of gravel or any other construction material during or following construction of the facility by spreading such material on agricultural land. All construction debris and all contaminated soil shall be promptly removed and properly disposed of in accordance with Ohio environmental protection agency regulations.

Each of the above items is addressed below.

Overall, the Project is anticipated to have limited impacts to sensitive natural resources. The Project is situated in agricultural fields that experience regular disturbance and provide minimal habitat for wildlife.

During the life of the Project, operations and management (O&M) teams are expected to periodically conduct inspections, repair damaged equipment, and manage vegetation. These activities are anticipated to have minimal impacts on ecological resources and to generate a minimum amount of waste. Waste that is generated from these activities will be disposed of in accordance with all applicable federal, state, and local regulations.

4.2.1 Surface Water and Wetland Vegetation Protection

As currently designed, all above-ground Project infrastructure has been sited to include a 120foot non-disturbance buffer from avoided wetlands and a 50-foot non-disturbance buffer from avoided streams. In addition, during operation, grazing sheep are expected to be kept out of wetlands and streams by temporary or permanent fencing, to avoid contamination of water and impacts to sensitive wetland and riparian vegetation. Thus, wetlands and streams and associated sensitive vegetation areas should be protected throughout the operation of the Project. Mitigation and avoidance measures for potential construction impacts are discussed in Section 3.2, above.

4.2.2 Maintenance and Herbicide Use

As described above, vegetation within the Project is expected to be primarily managed by grazing sheep, supplemented with mechanical vegetation management, as needed. As such, use of herbicides to manage vegetation, and specifically for the management of noxious weeds, in accordance with Section OAC 901:5-30 and 901:5-37, is discussed in Sections 3.4 and 4 of the Preliminary Vegetation Management Plan. Additional details regarding management of vegetation via grazing is included within the Preliminary Agricultural Soils Management Plan.

4.2.3 Post-Construction Wildlife Monitoring

Based on the results of the wildlife surveys described in the Wildlife and Habitat Assessment Report, there are no plans proposed for post-construction monitoring of impacts to wildlife. The Project will avoid delineated wetlands and immediately adjoining uplands by implementing a 120foot non-disturbance buffer around delineated wetlands. As Project design progresses, Crossroads is expected to continue to coordinate with the USFWS to determine if a habitat assessment or other avoidance measures, such as post-construction monitoring, are necessary. Refer to the Wildlife and Habitat Assessment Report, provided with the Project’s Application, for additional information.

4.2.4 Vegetation Management and Control of Noxious Weeds

As currently designed, the majority of potential impacts to identified grasslands and upland forests will be avoided by Project activities. Additional detail regarding how the Project will protect woody vegetation is included in Section 3.1 of the Preliminary Vegetation Management Plan Additionally, control of noxious weeds in accordance with Section OAC 901:5-30 and 901:5-37 C 5-37 is discussed in Sections 3.4 and 4 of the Preliminary Vegetation Management Plan, provided with the Project’s application. The Applicant plans to comply with public orders concerning the abatement of noxious weeds, should it be necessary.

4.2.5 Vegetation Disposal and Clearing

To prepare for the construction and operation of the Facility, scattered trees, shrubs, and windrows will be cleared and grubbed, as needed. Implementation of vegetation clearing will involve utilizing appropriate tools for each specific task, such as chainsaws for small trees, bulldozers for larger areas, and stump grinders for stump removal Environmental protection measures will be implemented as well. To prevent erosion and protect surface waters from runoff, silt fencing or other barriers will be installed, with consideration given to wildlife habitats and nesting seasons. Additionally, cleared vegetation may be repurposed to minimize waste, with wood chipped for use as mulch or temporary ground cover and logs sent to mills for lumber production. Any necessary disposal and offsite transport of wood material will be handled in compliance with local, state, and federal regulations. Upon completion of construction, cleared trees, excess excavated material, and other vegetative debris will be removed from the site and disposed of in accordance with applicable local, state, and federal guidelines. Refer to Section 3.1 of the Preliminary Vegetation Management Plan, provided with the Project’s Application, for additional detail.

4.2.6 Post-Construction Site Restoration

Upon completion of construction, areas that were temporarily disturbed will be restored to their near-original contours. To stabilize exposed soils, methods such as seeding and mulching will be employed. Additional information about the Project’s post-construction site restoration plans is discussed in Section 4 of the Preliminary Vegetation Management Plan and Section 4 of the Preliminary Agricultural Soils Management Plan, provided with the Project’s Application.

Appendix A

Preliminary Horizontal Directional Drill Inadvertent Return Response and Contingency Plan

Crossroads Solar Grazing Center Morrow County, Ohio

Austin, TX 78702

Document Number: 17078.0005

1.0 INTRODUCTION

This Horizontal Directional Drilling (HDD) Inadvertent Return (IR) Response and Contingency Plan (Plan) provides procedures to address an IR of drilling fluid used in HDD crossings for the Crossroads Solar Grazing Center (“Project”) being developed in Morrow County, Ohio. The Plan was prepared for Crossroads Solar I, LLC to satisfy Section 4906-408(B)(2)(b)(ii) of the Ohio Administrative Code, which requires an application for an electric generation facility to include, as part of its description of mitigation procedures to minimize construction impacts, “a detailed frac out contingency plan for stream and wetland crossings that are expected to be completed via” HDD.

The majority of the buried lines for the Project are expected to be installed by open-ditch trenching While the placement of utility lines in an open trench is the most economical and practicable means of installation, trenching may not be feasible or allowed in situations that require avoidance of sensitive environmental or cultural resources and other obstacles on the surface or near surface In such situations, the Project is expected to employ HDD to install the line below the resource or obstacle

HDD is a proven technique for the installation of subsurface utility lines with minimal surface disturbance. It is a trenchless, steerable method that has been successfully used in the United States since the 1960s. HDD has been successfully utilized to limit surface disturbance for decades, and modern technology and best management practices have been developed by industry and regulatory authorities over decades of experience.

However, HDD does present some potential environmental risk, primarily in the form of IRs. IRs typically occur when pressurized drilling fluid follows a path of least resistance outside of the borehole annulus through natural or manmade voids in subsurface materials such as soil and rock. When IRs occur in sensitive areas such as streams and wetlands, environmental impact may result. Adequate pre-drill investigation and planning, and operational process controls can reduce the risk of IR occurrence. Likewise, adequate IR contingency planning, preparation and rapid response can limit the spatial and temporal impact if an IR does occur. The Plan provides the framework for reducing the risk of IR during construction of the project and planning, preparation and response for one should it occur.

Document Number: 17078.0005

2.0

DESCRIPTION OF HORIZONTAL DIRECTIONAL DRILLING

The HDD method requires establishing staging areas at both ends of the proposed crossing, typically known as the entry and exit points, or workspaces. The process commences with the drilling of a pilot hole along a predetermined path beneath the area to be crossed. The drilling head is tracked and guided by a telemetry system that controls its depth and lateral position to ensure that the borehole is installed in the predetermined route. IRs most commonly occur during the installation of the pilot hole primarily due to the small aperture of the hole and relative lack of space for the drilling fluid and soil cuttings to be returned to the entry point. However, because the pilot hole has a relatively small diameter compared to the diameter of the borehole necessary to accept the utility line, far less drilling fluid is required, thus reducing the overall risk of a problematic IR. The pilot hole is also critically important to ensure that the final borehole meets design specifications thereby limiting overall subsurface activity.

Once the pilot hole has been completed, the borehole is enlarged with one or more passes of a reamer until the diameter of the borehole is adequate to complete the installation of the utility line Installation typically includes feeding the line into the borehole from the entry point while pulling the line through the exit point. This process limits the forces exerted on the subsurface and prevents unwanted conditions, such as borehole collapse, which would require additional reaming and/or drilling.

2.1 DRILLING FLUID ROLE

Drilling fluid is a critical component of HDD, without which avoidance of sensitive receptors would not be possible. Drilling fluid has several important roles in HDD operations:

• Clearing Soil and Rock Cuttings – Excavated soil and rock are suspended in the drilling fluid and transported back to the entry or exit points via fluid flow. It is crucial to achieve adequate viscosity and pressure to maintain circulation of cuttings to prevent blockages that can lead to pressure spikes.

• Friction Reduction – Drilling fluid lubricates, cools, and cleans the cutting head to ensure efficient drilling.

• Borehole Stabilization – Drilling fluid mixes with subsurface materials to form a “wall cake” against the walls of the boring. The wall cake can be thought of as a grout that seals fissures or voids through which drilling fluid could be lost, possibly resulting in an IR. The wall cake also adds strength to the borehole walls, and along with the drilling fluid filling the bore, prevents collapse of the bore.

• Drilling Power – Drilling fluid is used to transmit hydraulic power from the surface to operate the cutting bit in the borehole.

The drilling fluid is mixed and prepared at the surface and then introduced through a pipe to the cutting head in the borehole. The fluid is then circulated through the borehole annulus back to the entry or exit point, where it is collected into the drilling fluid recycling

Document Number: 17078.0005

system. The recycling system, through a series of mechanical operations, separates the drilling fluid from soil and rock cuttings and adjusts water content to ensure proper viscosity, before the fluid is recycled back into circulation. Excess drilling fluid is expected to be stored for recycling and reused or transported off-site for disposal

2.2 DRILLING FLUID COMPOSITION

Fresh water is the main component of drilling fluid. Bentonite clay (sodium montmorillonite) is added to the fresh water to increase viscosity, which affords the drilling fluid its beneficial properties. Bentonite clay is a naturally occurring clay typically mined in a very pure form in Wyoming; however, bentonite is somewhat ubiquitous in the environment. It is non-toxic and can be found as an ingredient in many skin care products and dietary supplements, is a common soil supplement used in farming, and is frequently used to seal freshwater ponds and earthen dams. Bentonite is not a hazardous material as defined by federal laws implemented by the United States Environmental Protection Agency (USEPA), including the Emergency Planning and Community Right-to-Know Act (EPCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Bentonite is non-toxic, and due to regulation, it is classified as a nonhazardous waste when used in a process such as HDD. Bentonite is not toxic to the aquatic environment; however, if introduced to a stream, wetland, lake, or other water body in a large quantity, it can be temporarily disruptive, particularly to benthic organisms.

Depending on the subsurface conditions encountered during an HDD operation, certain drilling fluid additives, such as loss circulation materials (LCM), may be added to the drilling fluid mixture. LCMs may be used during inadvertent return events and/or in certain cases when drilling fluid circulation is diminished or completely lost. If naturally-occurring preferential flow paths (faults, fractures, voids, large pores etc.) intersect the HDD path, LCMs may be used to seal around the borehole and prevent drilling fluid from escaping into the formation and allow for the reestablishment of drilling fluid circulation. Many types of LCMs available for use during HDD operations are inert and environmentally benign.

Only those drilling fluid additives and LCMs that are not petroleum-based, meet NSF/ANSI Standard 60 (NSF 60) or food additive standards, and are consistent with materials used in the drinking water distribution industry will be available for use by the company performing the HDD for the project (HDD Contractor) NSF 60 establishes health and safety criteria for the chemical treatment of drinking water. Most drilling fluid additives used in the HDD industry are NSF 60 compliant, as these products are also used in other rotary drilling applications such as water well drilling and completion. Other drilling fluid additives may not have NSF compliant requirements but will meet U.S. food additive standards.

Number: 17078.0005

3.0 HDD FEASIBILITY ANALYSIS

3.1 NECESSITY OF HDD

The first step in determining HDD feasibility is identifying the need for an HDD. As stated previously, open cut trenching is the most economical and efficient method for installing subsurface utility lines. HDD is utilized when an environmental, infrastructure, or cultural asset must be avoided, or when open cut trenching is otherwise not possible or practicable.

3.2 PHYSICAL CHARACTERISTICS OF CROSSING LOCATIONS

After determining the necessity of employing HDD at a proposed crossing, the suitability and accessibility of each location based on topographic and physical characteristics are evaluated. This part of the feasibility analysis determines whether each proposed crossing can accommodate the HDD work, necessary equipment, contractors, and permit-required controls. Determining the difference in elevation between entry and exit locations is crucial in planning the minimum recommended depth of cover required for each HDD. The results of this evaluation are used to determine if additional evaluations are necessary, such as geotechnical investigations

Public and private utility investigations, including One-Call notifications, at each crossing are conducted and document that the HDD alignment and depth do not interfere with any pre-existing utilities. The bore alignments and profiles are designed to maintain adequate lateral and vertical separation from all existing underground utilities and pipelines.

Document Number: 17078.0005

4.0 INADVERTENT RETURN PREVENTION AND MINIMIZATION

The application of HDD methods for avoiding sensitive environmental, infrastructure, and cultural assets during utility line installation has been proven effective over decades of practice. The feasibility analysis summarized in the previous section is the first measure of prevention by reducing the probability of an IR through an understanding of subsurface conditions to the extent practicable, identifying and avoiding proximate sensitive receptors, and identifying construction design controls. The following section details operational controls that are employed during HDD operations to further reduce the probability of IR occurrence, and the scale of an IR should one occur.

4.1 DRILLING FLUID MANAGEMENT AND CONTROL

Maintaining drilling fluid circulation from the cutting head through the borehole annulus and back to the entry or exit point is the primary operational control used to reduce both the probability of an IR occurrence, and the scale of an IR should one occur. The HDD Contractor has overall control of the HDD operation and is responsible for maintaining drilling fluid circulation

4.1.1

Drilling Fluid Composition

The drilling fluid is mixed in accordance with the manufacturer’s recommendations and physical characteristics of the crossing. The most effective composition for a given soil/rock condition is established, monitored, and maintained throughout the drilling process. The HDD Contractor ensures that the drilling fluid composition is adequate for each application for the duration of HDD activities.

4.1.2 Drilling Fluid Management Equipment

The HDD Contractor conducts regular inspections and maintenance of all drilling fluid handling equipment including, but not limited to hoses, pumps, valves, tanks, recycling equipment, cutting heads, reamers, etc. All equipment should be clean and functioning properly to facilitate uninterrupted operation. The HDD Contractor confirms that all equipment is sized properly to accommodate the actual volume and flow rate of drilling fluid and provide capacity for increased volume or flow rate of returns throughout HDD operations.

4.1.3 Process Monitoring Instrumentation

The HDD Contractor is prepared and able to measure borehole annular pressure, drilling fluid discharge rate, the drill string axial and torsional loads and the lateral and vertical position of the drilling bit or reamer bit.

4.1.4 Loss of Drilling Fluid Circulation

Loss of drilling fluid circulation is defined as a significant reduction in the volume of drilling fluid returning to the entry or exit point through the borehole annulus, relative to the

Document Number: 17078.0005

volume of drilling fluid that is being transmitted into the borehole from the cutting head. This condition can result from several issues which may include blockages at the cutting head, blockages in the borehole annulus, and loss of drilling fluids to the formation through natural or manmade voids. A loss of circulation concurrent with an increase in annular pressure typically indicates a blockage in the circulation system. A loss of circulation absent an increase in annular pressure or concurrent with a decrease in annular pressure may indicate a loss of drilling fluid to a formation, which increases the probability of an IR. Increased annular pressure due to a blockage in the circulation system, or due to non-ideal drilling fluid composition, can also increase the probability of losing drilling fluid to the formation. The HDD Contractor is expected to use best practices, some of which are listed below, to reduce the probability of drilling fluid loss:

• Maintain clean and unobstructed drilling fluid handling equipment;

• Maintain clean and unobstructed borehole annular space;

• Closely monitor and adjust annular pressure to use the minimum necessary pressure for HDD operations;

• Reduce “plunger effect” by cleaning cutting heads and reamers, and minimizing the speed of drill string advancement and retraction; and

• Monitor and adjust drilling fluid viscosity as necessary to maintain minimum required annular pressure, while still allowing circulation back to the HDD entry point.

If a loss of drilling fluid occurs, the HDD Contractor is expected to use appropriate methods to regain full drilling fluid circulation to prevent an IR, such as:

• Decrease pump pressure;

• Decrease penetration rate;

• Retract the drill string sufficiently to restore circulation (“swab” the hole);

• Introduce additional drilling fluid flow along the borehole using “weeper” subs; and

• Utilize bentonite plugs, grout, and/or LCM to seal voids and eliminate loss of drilling fluid to the formation. Confirm that seals are effective before continuing HDD operations.

4.2 HDD MONITORING AND INSPECTION PROTOCOLS

HDD activities are expected to be closely and continually monitored by the HDD Contractor as necessary to meet the objectives of this plan. Monitoring and inspection procedures may include, but are not limited to:

• Visual and pedestrian field inspection along the HDD route, to the extent allowable by the terrain, including monitoring drainage features and surface waters for evidence of an IR. The HDD route is expected to be inspected prior to the beginning of an HDD, and any condition that impedes the ability to conduct the visual inspections of any portion of the bore route are expected to be identified and a site-specific modification to the inspection routine at that location is expected to be developed.

Document Number: 17078.0005

• Monitoring of the HDD fluid composition, drilling pressures, and return flows.

• Monitoring of drill status information regarding drill conditions, pressures, returns, and progress during the course of drilling activities.

Upon the discovery of a sustained loss of drilling fluid circulation and/or a sustained drop in annular pressure, the HDD Contractor is expected to notify the on-site project representative, reduce downhole pressure, and conduct a detailed inspection of the HDD equipment and performance, and inspect the HDD route and surrounding area for evidence of an IR. If an IR is not observed, and based on a consultation with the project representative, the HDD contractor may elect to continue drilling. In these cases, the corrective action may include altering the viscosity of the drilling mud, adding an approved LCM, or slightly altering the drill path profile to avoid unsuitable subsurface materials. If an IR is identified or suspected, HDD operations are expected to immediately cease and response actions are expected to be initiated, as described in Section 5.

Document Number: 17078.0005

5.0 RESPONSE TO INADVERTENT RETURNS

These response protocols have been developed with full consideration of the potential risk posed by IRs to the aquatic environment. While upland IRs are generally not associated with environmental risk due to the lack of drilling fluid toxicity, upland IRs can impact the aquatic environment if the drilling fluid is transported to surface water via runoff through natural or man-made drainage features. The HDD contractor is expected to strictly adhere to this Plan and the overall goal of IR prevention and mitigation through rapid response, containment, and recovery.

Releases of drilling fluid in upland areas typically can be contained to prevent further migration and are cleaned up during and following completion of the crossing. Inadvertent returns into watercourses, however, can present greater risks and clean-up challenges. In large quantities or in sensitive environments, bentonite slurry may pose a threat particularly to benthic macroinvertebrates (e.g., aquatic larval insects). The threat to aquatic life is typically acute, although the long term impact of IRs on aquatic life appears to be negligible. Prompt and thorough removal of bentonite deposits in streams, coupled with normal stream hydrology and sediment dynamics, should disperse the bentonite to levels where aquatic faunal communities can recover quickly The rapidity of the response to an IR is dependent on several elements:

• Prompt detection and communication of the IR;

• Training and adequate number of response staff;

• Access to needed materials and equipment that are present in sufficient quantity and ready for use; and

• Clear and timely direction regarding measures to be taken by the HDD Contractor (e.g., suspending drill operations), and where IR response materials, equipment, and labor should be deployed, depending on the location of the IR and the sensitive resource potentially affected.

5.1 RESPONSE PROTOCOL FOR IR IN UPLANDS

Upland areas are generally located above and away from surface waters. Releases to upland areas are most likely to occur within the limits of disturbance (LOD) near the HDD entry and/or exit points; however, IRs are also possible in upland areas outside the LOD. The primary focus of the response action is to stop and contain the IR to prevent further surface migration, especially to surface water receptors. If an upland IR is identified, the protocol described in this section is expected to be followed.

Upland IR Within the Limit of Disturbance

Upland IRs typically occur at the HDD entry and exit points within the (LOD) as defined in the project Storm Water Pollution Prevention Plan (SWPPP or SWP3). These IRs, referred to as “punch out” returns, generally occur at shallow depths where overburden soils are weak. Response actions are expected to focus on containing the release and preventing migration outside the LOD. If the punch out return is fully contained within the LOD, and surface water features and water supplies are not threatened, HDD operations may continue.

Document Number: 17078.0005

In the event of an upland IR within the LOD, the HDD Contractor is expected to notify the project representative, determine the approximate volume of the IR, and oversee and document the containment and recovery operations. If at any time the IR threatens to migrate beyond the LOD, the IR exceeds the SWPPP controls, or the rate of return exceeds the capacity of response operations, HDD operations are expected to be suspended until such time that the IR is completely contained. Released drilling fluid can be recovered and reused in HDD operations. Excess drilling fluid, if it is to be disposed of, is expected to be managed as waste in accordance with applicable regulations After the IR is contained and recovered, the area is expected to be restored in accordance with applicable requirements.

Upland IR Outside the Limits of Disturbance

While uncommon, upland IRs can occur outside the LOD when drilling fluid is pushed through natural or manmade voids to the surface. These IRs are sometimes preceded by ground swelling and groundwater seepage and can occur anywhere along the HDD alignment. Diligent inspections are necessary to identify evidence of an upland IR so response protocols can be initiated quickly.

Upland IRs do not generally pose significant risk to the environment if they are contained and prevented from migrating to surface water via natural and man-made drainage features. If an upland IR occurs outside the LOD, the response protocols may include, but are not be limited to:

• HDD operations immediately cease which immediately reduce borehole annular pressure. Resumption of HDD operations is contingent upon approval of the project representative, and, if required, applicable regulatory agencies.

• The HDD Contractor obtains the coordinate location and estimates the volume of the release and determines whether surface water, natural or man-made drainage features, or any other sensitive receptors are impacted or threatened.

• The project representative confirms access rights to enter the affected property for containment and recovery operations. If access is not granted, the project representative notifies and works with applicable regulatory agencies to gain access.

• The HDD Contractor initiates containment and collection of the drilling fluid.

o Contain the IR to the smallest area possible with physical barriers such as hay bales, sandbags, silt fencing, silt socks, all of which are expected to be installed in accordance with best management practices as defined in the project SWPPP Small, excavated pits, dikes and diversion ditches may also be used.

o If recovery equipment is not immediately available due to the location of the IR, especially if precipitation is expected, use plastic sheeting to cover the IR to minimize contact with stormwater.

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o The IR is recovered to the maximum extent practicable. All necessary erosion and sediment control protocols are utilized during recovery operations.

o All recovered material is managed as a residual waste in accordance with applicable regulations, including the retention of all disposal documentation

• The impacted area is restored to pre-existing conditions, including reestablishment of vegetation. All necessary erosion and sediment control protocols are expected to be utilized until site restoration is complete.

5.2 RESPONSE PROTOCOL FOR IR IN SURFACE WATER

HDD techniques are often employed to cross streams and wetlands without physically impacting the watercourse. Due to the typical morphology of streams (association with bedrock fractures), IRs can occur within a surface stream. Likewise, natural and manmade drainage features, wetlands, springs, and riparian zones can also be susceptible to IRs that migrate through the subsurface, or from upland areas. Wetlands generally occur in depositional environments, and consequently wetland biological systems are highly resilient to acute inputs of sediments. The biological systems of riparian zones and springs are also much less susceptible to damage from IRs than streams, and the lack of moving water reduces the extent to which drilling fluid can be transported. However, rapid containment and recovery of IRs in these areas is critical to reducing the possibility of environmental impact to adjacent streams or other sensitive areas. For these reasons, if an IR threatens a surface water feature, the focus of the response should be stopping the release of drilling fluid, containing the fluid to the smallest possible area, and quickly removing as much drilling fluid as possible.

Aquatic life is typically concentrated in stream riffles (shallow areas of fast-moving water between natural stream pools). Aquatic macroinvertebrates live in the oxygen-rich stream riffles and are especially susceptible to increased sedimentation associated with IRs. Accordingly, response actions should be designed to prevent sediment accumulation in stream riffles to the extent possible. While aquatic biological systems are sensitive, streams are effective at clearing excess sediment. Accordingly, response actions also should be tempered to prevent additional harm. Response actions such as power washing and artificial flushing, while effective at removing drilling fluid, may cause additional or even greater harm than the IR, and so should be avoided In the event of a surface water IR, a person with experience with or professional certification relevant to stream dynamics, morphology and aquatic ecology is expected to approve and oversee in-stream response actions.

Specific permits may be required prior to entering a surface water body to conduct IR assessment, containment, and recovery operations. The HDD Contractor is not expected to place, or allow the placement of, equipment or materials in the water course without direct approval of the project representative. The project representative should coordinate with applicable federal, state and local regulatory agencies to ensure that any necessary permits are in place prior to conducting containment and recovery operations in surface water.

Document Number: 17078.0005

With consideration given to specific permit requirements, the general response protocols in the event of an IR to surface water can include, but are not limited:

• HDD operations immediately cease, and the HDD Contractor is expected to immediately reduce borehole annular pressure to the extent practicable. Resumption of HDD operations is contingent upon approval of the project representative and applicable regulatory agencies.

• The HDD Contractor immediately notifies the project representative and provides the coordinate location and estimated volume of the release

• The Ohio EPA Spill Hotline is notified within 30 minutes of the discovery of an IR at 1-800-282-9378.

• The Ohio Department of Natural Resources – Division of Wildlife is notified within 30 minutes of the discovery of an IR in surface waters known to contain endangered species at 614-265-6300.

• The designated contact at the Staff of the Ohio Power Siting Board is promptly notified.

• An attempt to contact all property owners that may be affected by the IR is made.

• The project representative and HDD Contractor is expected to work with internal resources, consultants and federal, state, and local regulatory agencies in an expeditious manner to prepare, submit, and gain approval of any permits as might be required prior to entering a water course for containment and recovery operations.

• The HDD Contractor determines the need for containment and clean-up personnel, including whether third-party contractors and equipment are necessary.

• Once access to enter the surface water feature has been granted by the property owner, and/or via permit approval, the HDD Contractor initiates, oversees, and documents containment and recovery operations A qualified professional oversees all corrective actions associated with a surface water IR including:

o Contain the IR as close to the release point as possible using sediment control devices such as silt fencing, silt curtains, mulch tubes, hay bales, and sandbags

o Immediately recover drilling fluids as close to the release point as possible using vacuum trucks, pumps, and manual methods, as applicable.

o Install sediment control devices downstream of the release point. Avoid installing sediment control devices immediately downstream of riffles, as the resulting accumulation of sediment can harm these sensitive areas at the following locations:

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▪ Immediately downstream of the release point.

▪ Upstream of riffles.

▪ Downstream side of existing natural pools.

o Once sediment control features are installed, sediment is likely to begin to accumulate in the natural stream pools, which may allow efficient recovery. Natural pools typically offer more convenient access for recovery operations.

o A qualified professional is expected to determine the need for additional actions

o All recovered material is expected to be managed as a waste in accordance with applicable regulations, including document retention

• If necessary, the project representative designs and implements a monitoring program consistent with permit requirements, regulatory agency requirements, and the scale of the IR and response actions.

5.3 CONTAINMENT AND RECOVERY MATERIALS AND EQUIPMENT

The HDD Contractor is expected to provide adequate IR containment and recovery equipment and materials at the HDD location prior to the initiation of HDD activities. Prior to the start of HDD operations and at the beginning of each workday, the HDD Contractor should verify the inventory and condition of equipment and materials as part of the daily pre-drill checklist. This equipment is expected to be on standby and ready for use for the entirety of the drilling process. Depending on the specific HDD activity, the materials and equipment may include:

• Compost filter sock

• Silt fence, hay bales, sandbags, and wood stakes for installation

• Hand tools (shovels, rakes, brooms, buckets, etc.)

• Centrifugal, trash, and sump pumps with associated hoses

• Pump water filter bags

• Vacuum truck

• Mini backhoe/loader (rubber tire or wide track to minimize surface disturbance)

• Equipment mats and timbers

• Aqua barriers/floating turbidity curtains and mounting hardware

• Plastic sheeting (6 mil minimum)

After an IR response, all equipment should be cleaned, inspected, repaired and/or replaced, and be fit for use before HDD operations resume. Likewise, consumable materials (silt fence, hay bales, etc.) should be properly disposed of and replaced before resuming HDD operations.

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6.0 HDD CONTINGENCY PLAN

6.1 CONTINGENCY PLAN FOR A FAILED HDD

In the event that corrective measures are not sufficient to maintain the integrity of an HDD borehole, the HDD Contractor is expected to abandon the borehole and in consultation with the project representative consider alternate crossing locations and/or techniques. If necessary, the project representative is expected to consult with applicable regulatory agencies to determine if an HDD failure has occurred and evaluate alternate, site-specific remedies.

In the event of borehole failure, the borehole is expected to be properly abandoned, and a decision should be made regarding whether to re-attempt the HDD crossing, or use another crossing method, as described below:

• Grout should be used to seal the bore hole;

• The top 5 feet should be filled with topsoil; and

• The location should be graded to the original contour and re-vegetated.

The above abandonment procedures should be discussed with all appropriate permitting and regulatory agencies prior to implementation.

6.2 ALTERNATIVE CROSSING LOCATIONS AND METHODS

If the HDD bore cannot be completed at the proposed location, the HDD crossing may be re-attempted at an alternate location. Before a determination is made on an alternate crossing location, an effort is expected to be made to identify and assess the reason for the HDD failure. This may be critical for the selection of the alternate crossing. Considerations of alternative locations include, but are not limited to:

• Horizontal relocation of the drill hole;

• Changing of the drill profile (depth of bore);

• Changing drill procedures (slurry viscosity/pressure/flow velocity, bit rotation/velocity, etc.); and

• Geotechnical considerations.

If the entry and exit points must be relocated, consideration should be given to:

• Proximity to surface water, wetlands, sensitive habitats, cultural resources, and existing utilities;

• Surrounding topography;

• Entry and exit angles for the HDD path; and

• Permitting considerations.

These and other factors should be considered and discussed with appropriate regulatory agencies to secure any necessary approvals. Alternate crossing methods may also be evaluated.