1043-00002 · Ironhaven Data Centers LLC · Entitlements & Land Use

pre-application-conference-letter.docx DOCUMENT Real Estate

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CALDERWOOD & HARKNESS LLP 425 Lexington Avenue, New York, NY 10017	1900 K Street NW, Suite 800, Washington, DC 20006 Tel: (202) 555-7100	Fax: (202) 555-7101	www.calderwoodharkness.com
Local Zoning Counsel: ASHCROFT & WYNN, P.C. 25 West Market Street, Leesburg, VA 20176 Tel: (703) 555-4420	Fax: (703) 555-4421	www.ashcroftwynn.com

April 28, 2025

Calderwood & Harkness LLP Matter No. 1043-00002

VIA HAND DELIVERY AND ELECTRONIC MAIL

Director Department of Planning and Zoning Loudoun County Government 1 Harrison Street SE Leesburg, Virginia 20175

Re: Request for Pre-Application Conference — Proposed Zoning Modification Application (ZMOD) — Stonebridge Data Center Campus — Loudoun County Tax Map Parcels /95-4A-1/// and /95-4A-2///

Dear Director:

I. Introduction and Purpose of This Letter

Calderwood & Harkness LLP and Ashcroft & Wynn, P.C. serve as counsel and local zoning counsel, respectively, to Ironhaven Data Centers LLC ("IHDC" or the "Applicant"), a Delaware limited liability company with its principal offices located at 44680 Prentice Drive, Suite 200, Ashburn, Virginia 20147. IHDC is the prospective developer of the Stonebridge Data Center Campus (the "Project"), a state-of-the-art, multi-building data center campus proposed to be developed on approximately 81.4 acres of land situated at the northeast corner of Belmont Ridge Road and Stonebridge Boulevard in unincorporated Loudoun County, Virginia.

The purpose of this letter is to formally request a pre-application conference with the Loudoun County Department of Planning and Zoning (the "Department") in advance of the filing of a Zoning Modification Application ("ZMOD") under the Loudoun County Zoning Ordinance (the "Zoning Ordinance"). The Applicant intends to file its ZMOD application on or before May 30, 2025, and respectfully requests an opportunity to meet with Department staff as soon as practicable to discuss the scope and substance of the proposed application, the required submissions and supporting documentation, and the anticipated review process and timeline.

We note that IHDC has retained Cornerstone Land Use Consulting, LLC as its land use and entitlements consultant for the Project. Alan Mercer, principal of Cornerstone Land Use Consulting, LLC, will participate in the pre-application conference alongside counsel and the Applicant's development team. Mr. Mercer has extensive experience with land use entitlements in Loudoun County and will serve as the day-to-day coordinator for the ZMOD application process.

To facilitate the Department's review and preparation for the pre-application conference, this letter provides a detailed overview of the Applicant, the subject property, the proposed Project, the zoning modification being sought, concurrent due diligence activities, and the specific topics the Applicant wishes to discuss with staff. In addition, certain preliminary materials are enclosed for the Department's reference, as described in greater detail below.

II. Description of the Applicant

Ironhaven Data Centers LLC is a Delaware limited liability company registered to transact business in the Commonwealth of Virginia (Virginia State Corporation Commission Entity ID: S7491283; Federal Employer Identification Number: 84-3291057). IHDC operates in the digital infrastructure sector and currently owns and operates three existing data center facilities in Northern Virginia, collectively representing approximately 42 megawatts ("MW") of critical information technology load. These existing facilities have established IHDC as a credible and experienced operator within the Northern Virginia data center market, which remains the largest and most active data center market in the world.

IHDC is a portfolio company of Ridgeline Capital Partners Fund IV, LP ("Ridgeline Fund IV"), a private equity fund focused on investments in digital infrastructure and real estate assets. Ridgeline Fund IV holds its interest in IHDC through its intermediate holding entity, RCP Digital Holdings LLC. The financial sponsorship of Ridgeline Fund IV provides IHDC with the capital resources and institutional support necessary to undertake a project of the scale and complexity contemplated by the Stonebridge Data Center Campus.

The key personnel of IHDC relevant to this application are as follows:

• Marcus Thorne — Chief Executive Officer, responsible for overall corporate strategy and management of IHDC's data center portfolio.

• Priya Dasgupta — Chief Financial Officer, responsible for financial planning, capital markets activity, and fiscal oversight of development projects.

• Leonard Castellano — Executive Vice President, Development, responsible for the identification, entitlement, design, and construction of new data center facilities.

Mr. Castellano will serve as the primary IHDC representative for all land use and entitlement matters pertaining to the Project and will attend the pre-application conference. He may be reached directly at the Applicant's principal offices at the address set forth above.

III. Description of the Subject Property

The Project will be developed on two adjacent parcels of land located in unincorporated Loudoun County, Virginia, as described in detail below. Together, these parcels comprise a contiguous campus site of approximately 81.4 acres.

A. Stonebridge Parcel

The first parcel (the "Stonebridge Parcel") consists of approximately 62.0 acres of land located at the northeast corner of Belmont Ridge Road (Route 659) and Stonebridge Boulevard, in unincorporated Loudoun County, Virginia 20148. The Stonebridge Parcel is identified on the Loudoun County Tax Map as Parcel /95-4A-1///. The Stonebridge Parcel is currently owned by Blackthorn Realty Group, Inc., a Virginia corporation (Virginia SCC Entity ID: 0412876-3). IHDC has entered into a Purchase and Sale Agreement with Blackthorn Realty Group, Inc. dated April 15, 2025, pursuant to which IHDC will acquire fee simple title to the Stonebridge Parcel at a purchase price of Fifty-Eight Million Five Hundred Thousand Dollars ($58,500,000.00), subject to the satisfaction of customary due diligence, title, and zoning contingencies.

B. Meridian Parcel

The second parcel (the "Meridian Parcel") consists of approximately 19.4 acres of land adjacent to and immediately east of the Stonebridge Parcel. The Meridian Parcel is identified on the Loudoun County Tax Map as Parcel /95-4A-2///. The Meridian Parcel is currently owned by Meridian Acres LLC, a Virginia limited liability company (Federal Employer Identification Number: 84-6120983), managed by Theodore Ashford. IHDC has entered into a Purchase and Sale Agreement with Meridian Acres LLC dated April 22, 2025, pursuant to which IHDC will acquire fee simple title to the Meridian Parcel at a purchase price of Nineteen Million Four Hundred Thousand Dollars ($19,400,000.00), subject to the satisfaction of customary due diligence, title, and zoning contingencies.

C. Total Campus Acreage and Zoning

The combined acreage of the Stonebridge Parcel and the Meridian Parcel is approximately 81.4 acres (62.0 acres + 19.4 acres), which together will constitute the Stonebridge Data Center Campus site. Both parcels are currently zoned PD-IP (Planned Development – Industrial Park) under the Loudoun County Zoning Ordinance. Land closings for both parcels are targeted for September 15, 2025, following the completion of due diligence, the receipt of satisfactory zoning assurances, and the satisfaction of other conditions precedent under the respective Purchase and Sale Agreements.

IV. Description of the Proposed Project

A. Project Overview

The Stonebridge Data Center Campus will be a purpose-built data center campus designed for colocation and enterprise data center operations. The Project represents a total capital investment of approximately Six Hundred Million Dollars ($600,000,000.00), inclusive of land acquisition costs, hard construction costs, soft costs, and infrastructure improvements. At full build-out, the campus will deliver approximately 96 MW of critical IT load capacity distributed across four data center buildings.

B. Building Configuration

The campus will consist of four data center buildings, designated as Buildings A through D, each designed to support approximately 24 MW of critical IT load. Each building will have a gross floor area of approximately 120,000 square feet of shell space, for a total campus gross floor area of approximately 480,000 square feet. The buildings will be designed and constructed to Tier III-equivalent standards, consistent with the Harborview Corporation's design and operational topology requirements for concurrent maintainability.

C. Supporting Infrastructure

In addition to the four data center buildings, the campus will include the following supporting infrastructure:

• Central Utility Plant ("CUP"): A centralized mechanical plant providing chilled water distribution for cooling across all four data center buildings, sized to support the full 96 MW build-out.

• Structured Parking: A surface parking facility with adequate capacity to serve the campus's operational, maintenance, and visitor parking needs.

• Site Civil Improvements: Comprehensive site grading, internal roadway construction, stormwater management facilities, perimeter landscaping, and security infrastructure, including perimeter fencing, controlled access gates, and surveillance systems.

• Dedicated Electrical Substation: A 230kV/34.5kV electrical substation to be constructed on the Meridian Parcel for the purpose of stepping down high-voltage transmission power to distribution voltage for delivery to the data center buildings. Upon completion of construction, the substation will be owned and operated by Vantage Power Cooperative ("VPC"). The Applicant will grant an appropriate easement in favor of VPC for the substation site and associated transmission interconnection facilities.

• Backup Power Generation: Each of the four data center buildings will be equipped with a 2N diesel backup generator configuration, providing full redundancy for critical IT load in the event of a utility power interruption. Generator enclosures will be located adjacent to each building and will be designed with appropriate sound attenuation measures.

D. Power Supply

Primary utility power for the campus will be supplied by Vantage Power Cooperative pursuant to a Large Load Service Agreement with a contracted demand of 120 megavolt-amperes ("MVA"), corresponding to VPC Service Application No. LSA-2025-0091. IHDC and VPC have been in active discussions regarding the power supply arrangements, and IHDC anticipates that the Large Load Service Agreement will be fully executed prior to the commencement of construction.

E. EPC Contractor

Titan-McAllister Construction Group, LLC, a Maryland limited liability company specializing in the construction of mission-critical facilities, has been selected to serve as the engineering, procurement, and construction ("EPC") general contractor for the Project. Titan-McAllister will perform its services under a Guaranteed Maximum Price ("GMP") contract with a total contract value of Four Hundred Twelve Million Dollars ($412,000,000.00). The GMP contract is currently in the process of negotiation and is expected to be executed by October 2025.

F. Construction Timeline

The Applicant anticipates the following construction schedule for the Project:

• Notice to Proceed: November 2025

• Substantial Completion of Building A: August 1, 2027

• Substantial Completion of Buildings B, C, and D: November 1, 2027

This timeline is contingent upon the timely receipt of all required land use entitlements, building permits, and utility service commitments.

G. Stabilization Target

IHDC projects that the campus will achieve a stabilized occupancy of approximately 85% leased capacity by the second quarter of 2028, based on current market conditions and IHDC's existing pipeline of prospective enterprise and colocation tenants.

H. Project Team Consultants

IHDC has assembled a team of experienced consultants to support the development, entitlement, design, and construction of the Project. The key project team members are as follows:

• Lumen Ridge Engineering, PLLC — Carlos Esteban, PE, Principal — Civil engineering and site design.

• Brannigan Geotechnical Engineering, LLC — Neil Brannigan, PE, Principal — Geotechnical investigation and foundation design consulting.

• Pendleton Environmental Associates, Inc. — Dr. Renata Volkov, Principal — Environmental consulting, including Phase I and Phase II Environmental Site Assessments.

• Kestrel Infrastructure Advisors, LLC — Diane Prescott, Principal — Owner's representative services during design and construction.

• Greystone Appraisal Partners, LLC — Janet Choi, MAI, Principal — Real property appraisal services.

• Cornerstone Land Use Consulting, LLC — Alan Mercer, Principal — Land use and entitlements consulting.

V. Existing Zoning and Requested Zoning Modification

A. Current Zoning

As noted above, both the Stonebridge Parcel (Tax Map Ref. /95-4A-1///) and the Meridian Parcel (Tax Map Ref. /95-4A-2///) are currently zoned PD-IP (Planned Development – Industrial Park) under the Loudoun County Zoning Ordinance. The PD-IP district was established to accommodate a range of industrial, office, and technology-related uses, subject to the conditions and proffers approved at the time of the original planned development rezoning.

B. Need for Zoning Modification

Under the existing PD-IP zoning applicable to the subject parcels, data center use is not currently permitted by right. Accordingly, a Zoning Modification Application (ZMOD) is required to authorize data center use on the Stonebridge Parcel and the Meridian Parcel. The ZMOD application will request modification of the existing zoning conditions applicable to both parcels to permit data center use, together with the associated infrastructure necessary to support such use, including the dedicated 230kV/34.5kV electrical substation, backup diesel generators, cooling systems, and structured parking.

The Applicant anticipates that the ZMOD application will be assigned Docket No. ZMOD-2025-0038 upon filing. The application will be prepared in accordance with all applicable submission requirements set forth in the Zoning Ordinance and the Department's administrative guidelines for ZMOD applications.

C. Anticipated Review Process

The Applicant understands that the ZMOD application will be subject to review and recommendation by the Loudoun County Planning Commission and will thereafter proceed to the Loudoun County Board of Supervisors for final action. The Applicant's target for the Board of Supervisors public hearing is October 2025, and the Applicant is committed to working diligently with Department staff to meet the submission deadlines and procedural requirements necessary to achieve that timeline.

D. Proffers. The Applicant is prepared to submit a proffer statement in connection with the ZMOD application. Based on the estimated gross floor area of 480,000 square feet, the Applicant anticipates an aggregate proffer contribution of approximately Two Million Four Hundred Thousand Dollars ($2,400,000.00), calculated at a rate of Five Dollars ($5.00) per square foot of gross floor area. The proffer statement will address fiscal impacts, transportation improvements, noise mitigation, landscaping and visual screening, and other community benefits, as appropriate. The Applicant welcomes the opportunity to discuss the proffer framework with Department staff at the pre-application conference to ensure alignment with the Department's expectations and the Board of Supervisors' proffer guidelines.

VI. Concurrent Due Diligence Activities

In parallel with the ZMOD application process, IHDC is conducting comprehensive due diligence on both parcels comprising the Project site. The following is a summary of the principal due diligence activities currently underway:

A. Environmental Assessments

Phase I Environmental Site Assessments ("Phase I ESAs") are being conducted on both the Stonebridge Parcel and the Meridian Parcel by Pendleton Environmental Associates, Inc. (Dr. Renata Volkov, Principal). The Phase I ESAs are being performed in accordance with ASTM Standard E1527-21 and are targeted for completion by June 1, 2025.

In addition, a Phase II Environmental Site Assessment ("Phase II ESA") has been authorized for the Stonebridge Parcel. The Phase II ESA is necessitated by the parcel's former agricultural use and the potential for residual pesticide contamination in the northwest quadrant of the parcel, an area comprising approximately 4.2 acres. The Phase II ESA will include soil sampling, laboratory analysis, and risk assessment, with completion targeted for July 1, 2025. The results of the Phase II ESA will be made available to the Department to the extent relevant to the ZMOD application review.

B. Surveys. ALTA/NSPS Land Title Surveys for both parcels are being prepared by Lumen Ridge Engineering, PLLC (Carlos Esteban, PE, Principal). The surveys are being performed in accordance with the 2021 Minimum Standard Detail Requirements for ALTA/NSPS Land Title Surveys and will include all applicable Table A optional survey items. Completion of the surveys is targeted for June 15, 2025.

C. Geotechnical Investigations

Geotechnical investigations are being performed on both parcels by Brannigan Geotechnical Engineering, LLC (Neil Brannigan, PE, Principal). The geotechnical program includes test borings, laboratory testing, and the preparation of a geotechnical engineering report with foundation design recommendations for the data center buildings, central utility plant, and substation. Results of the geotechnical investigations will inform the detailed site design and structural engineering for the Project.

D. Title. Title commitments have been issued for both parcels by Fidelitas Title & Escrow, Inc., underwritten by Sovereign Title Insurance Company. The effective dates of the title commitments are April 3, 2025 for the Stonebridge Parcel and April 10, 2025 for the Meridian Parcel. The title commitments are currently under review by counsel, and any title exceptions requiring curative action will be addressed during the due diligence periods.

E. Due Diligence Periods

The contractual due diligence periods under the respective Purchase and Sale Agreements are as follows:

• Stonebridge Parcel: Ninety (90) days from April 15, 2025, expiring July 14, 2025.

• Meridian Parcel: Seventy-five (75) days from April 22, 2025, expiring July 7, 2025.

The Applicant notes that the pre-application conference and subsequent ZMOD filing are important milestones for purposes of evaluating the feasibility of the Project and informing the Applicant's decision to proceed to closing on both parcels.

VII. Topics for Discussion at Pre-Application Conference

The Applicant respectfully requests that the pre-application conference address the following topics, which are central to the preparation and filing of a complete and responsive ZMOD application:

1. Procedural Requirements and Submission Checklist. The Applicant requests confirmation of the current procedural requirements and submission checklist applicable to ZMOD applications under the Loudoun County Zoning Ordinance, including any recent amendments or updates to the Department's administrative guidelines.

2. Required Application Materials. The Applicant wishes to discuss the specific application materials and supporting documentation required for the ZMOD filing, including but not limited to site plans, transportation impact analyses, noise studies, fiscal impact analyses, and architectural renderings. The Applicant seeks guidance on the scope, format, and level of detail expected for each submission component.

3. Comprehensive Plan Compatibility. The Applicant requests preliminary feedback from staff regarding the compatibility of the proposed data center use with the surrounding PD-IP district and the goals, policies, and land use designations of the Loudoun County Comprehensive Plan, including the Suburban Policy Area policies applicable to the subject parcels.

4. Proffer Framework. The Applicant wishes to discuss the appropriate categories and amounts for proffers to be submitted in connection with the ZMOD application, including the phasing of proffer payments tied to the issuance of building certificates of occupancy for each of Buildings A through D. The Applicant welcomes staff's guidance on the Board of Supervisors' current proffer expectations and any applicable proffer guidelines or policies.

5. Environmental Considerations. The Applicant requests an opportunity to discuss stormwater management requirements applicable to the Project, as well as any environmental review considerations arising from the ongoing Phase II ESA for the northwest quadrant of the Stonebridge Parcel (approximately 4.2 acres of former agricultural land with potential residual pesticide contamination).

6. Utility Infrastructure. The Applicant seeks to discuss the placement and permitting of the dedicated 230kV/34.5kV electrical substation on the Meridian Parcel, including the proposed easement in favor of Vantage Power Cooperative, and any coordination required with county utility requirements, public utility easements, or franchise agreements.

7. Review Timeline and Scheduling. The Applicant requests information regarding the anticipated review timeline following submission of the ZMOD application, including the scheduling of Planning Commission referral and the Board of Supervisors public hearing. The Applicant's target for the Board of Supervisors hearing is October 2025, and the Applicant seeks to understand the milestones and deadlines necessary to achieve that timeline.

8. Public Notification and Community Engagement. The Applicant requests guidance on the public notification requirements applicable to the ZMOD application, including notice to adjacent property owners, signage requirements, and any opportunities or obligations for community engagement, such as community meetings or informational sessions in advance of the Planning Commission and Board of Supervisors hearings.

9. Transportation Access. The Applicant wishes to discuss the proposed points of ingress and egress for the campus from Belmont Ridge Road and Stonebridge Boulevard, including any requirements for turn lanes, traffic signal modifications, or transportation demand management measures.

10. Noise Mitigation and Visual Screening. The Applicant seeks to discuss proposed commitments for noise mitigation and visual screening of mechanical equipment, including backup diesel generators and cooling towers. The Applicant is prepared to incorporate sound attenuation enclosures, landscaped berms, and enhanced perimeter screening into the campus design, and welcomes staff's input on the appropriate standards and metrics.

11. Preliminary Staff Concerns. The Applicant requests any preliminary feedback or concerns from Department staff regarding the proposed use, intensity, site design, or any other aspect of the Project that would be beneficial for the Applicant to address in the ZMOD application.

VIII. Proposed Meeting Availability

The Applicant, its counsel, local zoning counsel, and land use consultant are available for a pre-application conference at the Department's earliest convenience. To allow sufficient time for the conference to occur and for the Applicant to incorporate any staff feedback into the ZMOD application prior to the May 30, 2025 filing target, the Applicant respectfully suggests that the conference be scheduled during the period of mid-to-late May 2025, ideally during the weeks of May 12 or May 19, 2025.

The following individuals are expected to attend the pre-application conference on behalf of the Applicant:

• Thomas Ashcroft, Partner, Ashcroft & Wynn, P.C. — Local Zoning Counsel

• Alan Mercer, Principal, Cornerstone Land Use Consulting, LLC — Land Use and Entitlements Consultant

• Leonard Castellano, Executive Vice President, Development, Ironhaven Data Centers LLC — Applicant's Representative

• Carlos Esteban, PE, Principal, Lumen Ridge Engineering, PLLC — Civil/Site Engineer

• Douglas Fairchild and/or Cynthia Ho, Calderwood & Harkness LLP — Outside Counsel (attendance to be confirmed)

For purposes of scheduling, please direct all communications to either of the following:

Thomas Ashcroft, Esq. Ashcroft & Wynn, P.C. 25 West Market Street Leesburg, Virginia 20176 Telephone: (703) 555-4420

Email: tashcroft@ashcroftwynn.com

Alan Mercer Cornerstone Land Use Consulting, LLC 19 Cornwall Street NW, Suite 210 Leesburg, Virginia 20176 Telephone: (703) 555-8830

Email: amercer@cornerstoneluc.com

IX. Preliminary Submissions Enclosed

To facilitate the Department's preparation for the pre-application conference, the following preliminary materials are enclosed with this letter for staff review:

Enclosure 1: Conceptual Site Plan — An illustrative conceptual site plan showing the 81.4-acre campus layout, the footprints and approximate locations of Buildings A through D, the central utility plant, the dedicated electrical substation on the Meridian Parcel, structured parking areas, internal roadways, and stormwater management areas. The conceptual site plan was prepared by Lumen Ridge Engineering, PLLC (Carlos Esteban, PE, Principal).

Enclosure 2: Vicinity Map — A vicinity map showing the Stonebridge Parcel and the Meridian Parcel in relation to Belmont Ridge Road, Stonebridge Boulevard, and surrounding parcels and land uses.

Enclosure 3: Loudoun County Tax Map Excerpts — Excerpts from the Loudoun County Tax Map depicting Parcels /95-4A-1/// (Stonebridge Parcel) and /95-4A-2/// (Meridian Parcel), including parcel boundaries, acreage, and tax map reference numbers.

Enclosure 4: One-Page Project Summary — A brief narrative summary providing a high-level overview of the Stonebridge Data Center Campus, including the proposed use, capacity, building configuration, supporting infrastructure, estimated capital investment, and anticipated construction timeline.

The Applicant notes that the enclosed materials are preliminary and are provided solely for the purpose of facilitating a productive pre-application conference. The full ZMOD application materials — including the ZMOD Application Narrative and Statement of Justification, the proffer statement, detailed site plans, transportation impact analysis, noise study, fiscal impact analysis, architectural renderings, and all other required supporting studies and documentation — are currently in preparation and will be submitted with the formal ZMOD application filing targeted for May 30, 2025.

Closing

We appreciate the Department's time and consideration in reviewing this request and the enclosed materials. The Applicant looks forward to a productive dialogue with Department staff and is committed to working collaboratively with the Department, the Planning Commission, and the Board of Supervisors throughout the ZMOD review process to ensure that the Project is developed in a manner that is consistent with the Zoning Ordinance, the Comprehensive Plan, and the best interests of the Loudoun County community.

We wish to emphasize the significant economic development benefits that the Stonebridge Data Center Campus will bring to Loudoun County. The Project represents approximately $600,000,000 in total capital investment, will generate substantial construction employment during the approximately two-year construction period, and will create permanent, high-quality operational employment upon completion. In addition, data center equipment assessments will provide meaningful and ongoing tax revenue to the County, contributing to the fiscal health of the community. The Applicant is committed to being a responsible corporate neighbor and to delivering a project that reflects the highest standards of design, environmental stewardship, and community engagement.

Should the Department require any additional information in advance of the pre-application conference, or at any time during the ZMOD application process, please do not hesitate to contact the undersigned or any member of the Applicant's team identified in this letter. We are at the Department's disposal and are eager to move forward collaboratively toward a successful outcome.

We thank you for your attention to this matter and look forward to your response regarding the scheduling of the pre-application conference.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Douglas Fairchild, Partner 1900 K Street NW, Suite 800 Washington, DC 20006 Telephone: (202) 555-7124

Email: dfairchild@calderwoodharkness.com

ASHCROFT & WYNN, P.C.

By: ________

Thomas Ashcroft, Partner 25 West Market Street Leesburg, Virginia 20176 Telephone: (703) 555-4420

Email: tashcroft@ashcroftwynn.com

cc:

Marcus Thorne, Chief Executive Officer, Ironhaven Data Centers LLC Leonard Castellano, Executive Vice President, Development, Ironhaven Data Centers LLC Priya Dasgupta, Chief Financial Officer, Ironhaven Data Centers LLC Alan Mercer, Principal, Cornerstone Land Use Consulting, LLC Cynthia Ho, Associate, Calderwood & Harkness LLP Grace Nakamura, Associate, Calderwood & Harkness LLP

Enclosures:

Enclosure 1: Conceptual Site Plan (prepared by Lumen Ridge Engineering, PLLC) Enclosure 2: Vicinity Map Enclosure 3: Loudoun County Tax Map Excerpts — Parcels /95-4A-1/// and /95-4A-2/// Enclosure 4: One-Page Project Summary — Stonebridge Data Center Campus

CALDERWOOD & HARKNESS LLP 425 Lexington Avenue, New York, NY 10017 | 1900 K Street NW, Suite 800, Washington, DC 20006 Tel: (202) 555-7100 | Fax: (202) 555-7101 | www.calderwoodharkness.com
Local Zoning Counsel: ASHCROFT & WYNN, P.C. 25 West Market Street, Leesburg, VA 20176 Tel: (703) 555-4420 | Fax: (703) 555-4421 | www.ashcroftwynn.com
April 28, 2025
Calderwood & Harkness LLP Matter No. 1043-00002
VIA HAND DELIVERY AND ELECTRONIC MAIL
Director Department of Planning and Zoning Loudoun County Government 1 Harrison Street SE Leesburg, Virginia 20175
Re: Request for Pre-Application Conference — Proposed Zoning Modification Application (ZMOD) — Stonebridge Data Center Campus — Loudoun County Tax Map Parcels /95-4A-1/// and /95-4A-2///
Dear Director:
I. Introduction and Purpose of This Letter
Calderwood & Harkness LLP and Ashcroft & Wynn, P.C. serve as counsel and local zoning counsel, respectively, to Ironhaven Data Centers LLC ("IHDC" or the "Applicant"), a Delaware limited liability company with its principal offices located at 44680 Prentice Drive, Suite 200, Ashburn, Virginia 20147. IHDC is the prospective developer of the Stonebridge Data Center Campus (the "Project"), a state-of-the-art, multi-building data center campus proposed to be developed on approximately 81.4 acres of land situated at the northeast corner of Belmont Ridge Road and Stonebridge Boulevard in unincorporated Loudoun County, Virginia.
The purpose of this letter is to formally request a pre-application conference with the Loudoun County Department of Planning and Zoning (the "Department") in advance of the filing of a Zoning Modification Application ("ZMOD") under the Loudoun County Zoning Ordinance (the "Zoning Ordinance"). The Applicant intends to file its ZMOD application on or before May 30, 2025, and respectfully requests an opportunity to meet with Department staff as soon as practicable to discuss the scope and substance of the proposed application, the required submissions and supporting documentation, and the anticipated review process and timeline.
We note that IHDC has retained Cornerstone Land Use Consulting, LLC as its land use and entitlements consultant for the Project. Alan Mercer, principal of Cornerstone Land Use Consulting, LLC, will participate in the pre-application conference alongside counsel and the Applicant's development team. Mr. Mercer has extensive experience with land use entitlements in Loudoun County and will serve as the day-to-day coordinator for the ZMOD application process.
To facilitate the Department's review and preparation for the pre-application conference, this letter provides a detailed overview of the Applicant, the subject property, the proposed Project, the zoning modification being sought, concurrent due diligence activities, and the specific topics the Applicant wishes to discuss with staff. In addition, certain preliminary materials are enclosed for the Department's reference, as described in greater detail below.
II. Description of the Applicant
Ironhaven Data Centers LLC is a Delaware limited liability company registered to transact business in the Commonwealth of Virginia (Virginia State Corporation Commission Entity ID: S7491283; Federal Employer Identification Number: 84-3291057). IHDC operates in the digital infrastructure sector and currently owns and operates three existing data center facilities in Northern Virginia, collectively representing approximately 42 megawatts ("MW") of critical information technology load. These existing facilities have established IHDC as a credible and experienced operator within the Northern Virginia data center market, which remains the largest and most active data center market in the world.
IHDC is a portfolio company of Ridgeline Capital Partners Fund IV, LP ("Ridgeline Fund IV"), a private equity fund focused on investments in digital infrastructure and real estate assets. Ridgeline Fund IV holds its interest in IHDC through its intermediate holding entity, RCP Digital Holdings LLC. The financial sponsorship of Ridgeline Fund IV provides IHDC with the capital resources and institutional support necessary to undertake a project of the scale and complexity contemplated by the Stonebridge Data Center Campus.
The key personnel of IHDC relevant to this application are as follows:
• Marcus Thorne — Chief Executive Officer, responsible for overall corporate strategy and management of IHDC's data center portfolio.
• Priya Dasgupta — Chief Financial Officer, responsible for financial planning, capital markets activity, and fiscal oversight of development projects.
• Leonard Castellano — Executive Vice President, Development, responsible for the identification, entitlement, design, and construction of new data center facilities.
Mr. Castellano will serve as the primary IHDC representative for all land use and entitlement matters pertaining to the Project and will attend the pre-application conference. He may be reached directly at the Applicant's principal offices at the address set forth above.
III. Description of the Subject Property
The Project will be developed on two adjacent parcels of land located in unincorporated Loudoun County, Virginia, as described in detail below. Together, these parcels comprise a contiguous campus site of approximately 81.4 acres.
A. Stonebridge Parcel
The first parcel (the "Stonebridge Parcel") consists of approximately 62.0 acres of land located at the northeast corner of Belmont Ridge Road (Route 659) and Stonebridge Boulevard, in unincorporated Loudoun County, Virginia 20148. The Stonebridge Parcel is identified on the Loudoun County Tax Map as Parcel /95-4A-1///. The Stonebridge Parcel is currently owned by Blackthorn Realty Group, Inc., a Virginia corporation (Virginia SCC Entity ID: 0412876-3). IHDC has entered into a Purchase and Sale Agreement with Blackthorn Realty Group, Inc. dated April 15, 2025, pursuant to which IHDC will acquire fee simple title to the Stonebridge Parcel at a purchase price of Fifty-Eight Million Five Hundred Thousand Dollars ($58,500,000.00), subject to the satisfaction of customary due diligence, title, and zoning contingencies.
B. Meridian Parcel
The second parcel (the "Meridian Parcel") consists of approximately 19.4 acres of land adjacent to and immediately east of the Stonebridge Parcel. The Meridian Parcel is identified on the Loudoun County Tax Map as Parcel /95-4A-2///. The Meridian Parcel is currently owned by Meridian Acres LLC, a Virginia limited liability company (Federal Employer Identification Number: 84-6120983), managed by Theodore Ashford. IHDC has entered into a Purchase and Sale Agreement with Meridian Acres LLC dated April 22, 2025, pursuant to which IHDC will acquire fee simple title to the Meridian Parcel at a purchase price of Nineteen Million Four Hundred Thousand Dollars ($19,400,000.00), subject to the satisfaction of customary due diligence, title, and zoning contingencies.
C. Total Campus Acreage and Zoning
The combined acreage of the Stonebridge Parcel and the Meridian Parcel is approximately 81.4 acres (62.0 acres + 19.4 acres), which together will constitute the Stonebridge Data Center Campus site. Both parcels are currently zoned PD-IP (Planned Development – Industrial Park) under the Loudoun County Zoning Ordinance. Land closings for both parcels are targeted for September 15, 2025, following the completion of due diligence, the receipt of satisfactory zoning assurances, and the satisfaction of other conditions precedent under the respective Purchase and Sale Agreements.
IV. Description of the Proposed Project
A. Project Overview
The Stonebridge Data Center Campus will be a purpose-built data center campus designed for colocation and enterprise data center operations. The Project represents a total capital investment of approximately Six Hundred Million Dollars ($600,000,000.00), inclusive of land acquisition costs, hard construction costs, soft costs, and infrastructure improvements. At full build-out, the campus will deliver approximately 96 MW of critical IT load capacity distributed across four data center buildings.
B. Building Configuration
The campus will consist of four data center buildings, designated as Buildings A through D, each designed to support approximately 24 MW of critical IT load. Each building will have a gross floor area of approximately 120,000 square feet of shell space, for a total campus gross floor area of approximately 480,000 square feet. The buildings will be designed and constructed to Tier III-equivalent standards, consistent with the Harborview Corporation's design and operational topology requirements for concurrent maintainability.
C. Supporting Infrastructure
In addition to the four data center buildings, the campus will include the following supporting infrastructure:
• Central Utility Plant ("CUP"): A centralized mechanical plant providing chilled water distribution for cooling across all four data center buildings, sized to support the full 96 MW build-out.
• Structured Parking: A surface parking facility with adequate capacity to serve the campus's operational, maintenance, and visitor parking needs.
• Site Civil Improvements: Comprehensive site grading, internal roadway construction, stormwater management facilities, perimeter landscaping, and security infrastructure, including perimeter fencing, controlled access gates, and surveillance systems.
• Dedicated Electrical Substation: A 230kV/34.5kV electrical substation to be constructed on the Meridian Parcel for the purpose of stepping down high-voltage transmission power to distribution voltage for delivery to the data center buildings. Upon completion of construction, the substation will be owned and operated by Vantage Power Cooperative ("VPC"). The Applicant will grant an appropriate easement in favor of VPC for the substation site and associated transmission interconnection facilities.
• Backup Power Generation: Each of the four data center buildings will be equipped with a 2N diesel backup generator configuration, providing full redundancy for critical IT load in the event of a utility power interruption. Generator enclosures will be located adjacent to each building and will be designed with appropriate sound attenuation measures.
D. Power Supply
Primary utility power for the campus will be supplied by Vantage Power Cooperative pursuant to a Large Load Service Agreement with a contracted demand of 120 megavolt-amperes ("MVA"), corresponding to VPC Service Application No. LSA-2025-0091. IHDC and VPC have been in active discussions regarding the power supply arrangements, and IHDC anticipates that the Large Load Service Agreement will be fully executed prior to the commencement of construction.
E. EPC Contractor
Titan-McAllister Construction Group, LLC, a Maryland limited liability company specializing in the construction of mission-critical facilities, has been selected to serve as the engineering, procurement, and construction ("EPC") general contractor for the Project. Titan-McAllister will perform its services under a Guaranteed Maximum Price ("GMP") contract with a total contract value of Four Hundred Twelve Million Dollars ($412,000,000.00). The GMP contract is currently in the process of negotiation and is expected to be executed by October 2025.
F. Construction Timeline
The Applicant anticipates the following construction schedule for the Project:
• Notice to Proceed: November 2025
• Substantial Completion of Building A: August 1, 2027
• Substantial Completion of Buildings B, C, and D: November 1, 2027
This timeline is contingent upon the timely receipt of all required land use entitlements, building permits, and utility service commitments.
G. Stabilization Target
IHDC projects that the campus will achieve a stabilized occupancy of approximately 85% leased capacity by the second quarter of 2028, based on current market conditions and IHDC's existing pipeline of prospective enterprise and colocation tenants.
H. Project Team Consultants
IHDC has assembled a team of experienced consultants to support the development, entitlement, design, and construction of the Project. The key project team members are as follows:
• Lumen Ridge Engineering, PLLC — Carlos Esteban, PE, Principal — Civil engineering and site design.
• Brannigan Geotechnical Engineering, LLC — Neil Brannigan, PE, Principal — Geotechnical investigation and foundation design consulting.
• Pendleton Environmental Associates, Inc. — Dr. Renata Volkov, Principal — Environmental consulting, including Phase I and Phase II Environmental Site Assessments.
• Kestrel Infrastructure Advisors, LLC — Diane Prescott, Principal — Owner's representative services during design and construction.
• Greystone Appraisal Partners, LLC — Janet Choi, MAI, Principal — Real property appraisal services.
• Cornerstone Land Use Consulting, LLC — Alan Mercer, Principal — Land use and entitlements consulting.
V. Existing Zoning and Requested Zoning Modification
A. Current Zoning
As noted above, both the Stonebridge Parcel (Tax Map Ref. /95-4A-1///) and the Meridian Parcel (Tax Map Ref. /95-4A-2///) are currently zoned PD-IP (Planned Development – Industrial Park) under the Loudoun County Zoning Ordinance. The PD-IP district was established to accommodate a range of industrial, office, and technology-related uses, subject to the conditions and proffers approved at the time of the original planned development rezoning.
B. Need for Zoning Modification
Under the existing PD-IP zoning applicable to the subject parcels, data center use is not currently permitted by right. Accordingly, a Zoning Modification Application (ZMOD) is required to authorize data center use on the Stonebridge Parcel and the Meridian Parcel. The ZMOD application will request modification of the existing zoning conditions applicable to both parcels to permit data center use, together with the associated infrastructure necessary to support such use, including the dedicated 230kV/34.5kV electrical substation, backup diesel generators, cooling systems, and structured parking.
The Applicant anticipates that the ZMOD application will be assigned Docket No. ZMOD-2025-0038 upon filing. The application will be prepared in accordance with all applicable submission requirements set forth in the Zoning Ordinance and the Department's administrative guidelines for ZMOD applications.
C. Anticipated Review Process
The Applicant understands that the ZMOD application will be subject to review and recommendation by the Loudoun County Planning Commission and will thereafter proceed to the Loudoun County Board of Supervisors for final action. The Applicant's target for the Board of Supervisors public hearing is October 2025, and the Applicant is committed to working diligently with Department staff to meet the submission deadlines and procedural requirements necessary to achieve that timeline.
D. Proffers. The Applicant is prepared to submit a proffer statement in connection with the ZMOD application. Based on the estimated gross floor area of 480,000 square feet, the Applicant anticipates an aggregate proffer contribution of approximately Two Million Four Hundred Thousand Dollars ($2,400,000.00), calculated at a rate of Five Dollars ($5.00) per square foot of gross floor area. The proffer statement will address fiscal impacts, transportation improvements, noise mitigation, landscaping and visual screening, and other community benefits, as appropriate. The Applicant welcomes the opportunity to discuss the proffer framework with Department staff at the pre-application conference to ensure alignment with the Department's expectations and the Board of Supervisors' proffer guidelines.
VI. Concurrent Due Diligence Activities
In parallel with the ZMOD application process, IHDC is conducting comprehensive due diligence on both parcels comprising the Project site. The following is a summary of the principal due diligence activities currently underway:
A. Environmental Assessments
Phase I Environmental Site Assessments ("Phase I ESAs") are being conducted on both the Stonebridge Parcel and the Meridian Parcel by Pendleton Environmental Associates, Inc. (Dr. Renata Volkov, Principal). The Phase I ESAs are being performed in accordance with ASTM Standard E1527-21 and are targeted for completion by June 1, 2025.
In addition, a Phase II Environmental Site Assessment ("Phase II ESA") has been authorized for the Stonebridge Parcel. The Phase II ESA is necessitated by the parcel's former agricultural use and the potential for residual pesticide contamination in the northwest quadrant of the parcel, an area comprising approximately 4.2 acres. The Phase II ESA will include soil sampling, laboratory analysis, and risk assessment, with completion targeted for July 1, 2025. The results of the Phase II ESA will be made available to the Department to the extent relevant to the ZMOD application review.
B. Surveys. ALTA/NSPS Land Title Surveys for both parcels are being prepared by Lumen Ridge Engineering, PLLC (Carlos Esteban, PE, Principal). The surveys are being performed in accordance with the 2021 Minimum Standard Detail Requirements for ALTA/NSPS Land Title Surveys and will include all applicable Table A optional survey items. Completion of the surveys is targeted for June 15, 2025.
C. Geotechnical Investigations
Geotechnical investigations are being performed on both parcels by Brannigan Geotechnical Engineering, LLC (Neil Brannigan, PE, Principal). The geotechnical program includes test borings, laboratory testing, and the preparation of a geotechnical engineering report with foundation design recommendations for the data center buildings, central utility plant, and substation. Results of the geotechnical investigations will inform the detailed site design and structural engineering for the Project.
D. Title. Title commitments have been issued for both parcels by Fidelitas Title & Escrow, Inc., underwritten by Sovereign Title Insurance Company. The effective dates of the title commitments are April 3, 2025 for the Stonebridge Parcel and April 10, 2025 for the Meridian Parcel. The title commitments are currently under review by counsel, and any title exceptions requiring curative action will be addressed during the due diligence periods.
E. Due Diligence Periods
The contractual due diligence periods under the respective Purchase and Sale Agreements are as follows:
• Stonebridge Parcel: Ninety (90) days from April 15, 2025, expiring July 14, 2025.
• Meridian Parcel: Seventy-five (75) days from April 22, 2025, expiring July 7, 2025.
The Applicant notes that the pre-application conference and subsequent ZMOD filing are important milestones for purposes of evaluating the feasibility of the Project and informing the Applicant's decision to proceed to closing on both parcels.
VII. Topics for Discussion at Pre-Application Conference
The Applicant respectfully requests that the pre-application conference address the following topics, which are central to the preparation and filing of a complete and responsive ZMOD application:
1. Procedural Requirements and Submission Checklist. The Applicant requests confirmation of the current procedural requirements and submission checklist applicable to ZMOD applications under the Loudoun County Zoning Ordinance, including any recent amendments or updates to the Department's administrative guidelines.
2. Required Application Materials. The Applicant wishes to discuss the specific application materials and supporting documentation required for the ZMOD filing, including but not limited to site plans, transportation impact analyses, noise studies, fiscal impact analyses, and architectural renderings. The Applicant seeks guidance on the scope, format, and level of detail expected for each submission component.
3. Comprehensive Plan Compatibility. The Applicant requests preliminary feedback from staff regarding the compatibility of the proposed data center use with the surrounding PD-IP district and the goals, policies, and land use designations of the Loudoun County Comprehensive Plan, including the Suburban Policy Area policies applicable to the subject parcels.
4. Proffer Framework. The Applicant wishes to discuss the appropriate categories and amounts for proffers to be submitted in connection with the ZMOD application, including the phasing of proffer payments tied to the issuance of building certificates of occupancy for each of Buildings A through D. The Applicant welcomes staff's guidance on the Board of Supervisors' current proffer expectations and any applicable proffer guidelines or policies.
5. Environmental Considerations. The Applicant requests an opportunity to discuss stormwater management requirements applicable to the Project, as well as any environmental review considerations arising from the ongoing Phase II ESA for the northwest quadrant of the Stonebridge Parcel (approximately 4.2 acres of former agricultural land with potential residual pesticide contamination).
6. Utility Infrastructure. The Applicant seeks to discuss the placement and permitting of the dedicated 230kV/34.5kV electrical substation on the Meridian Parcel, including the proposed easement in favor of Vantage Power Cooperative, and any coordination required with county utility requirements, public utility easements, or franchise agreements.
7. Review Timeline and Scheduling. The Applicant requests information regarding the anticipated review timeline following submission of the ZMOD application, including the scheduling of Planning Commission referral and the Board of Supervisors public hearing. The Applicant's target for the Board of Supervisors hearing is October 2025, and the Applicant seeks to understand the milestones and deadlines necessary to achieve that timeline.
8. Public Notification and Community Engagement. The Applicant requests guidance on the public notification requirements applicable to the ZMOD application, including notice to adjacent property owners, signage requirements, and any opportunities or obligations for community engagement, such as community meetings or informational sessions in advance of the Planning Commission and Board of Supervisors hearings.
9. Transportation Access. The Applicant wishes to discuss the proposed points of ingress and egress for the campus from Belmont Ridge Road and Stonebridge Boulevard, including any requirements for turn lanes, traffic signal modifications, or transportation demand management measures.
10. Noise Mitigation and Visual Screening. The Applicant seeks to discuss proposed commitments for noise mitigation and visual screening of mechanical equipment, including backup diesel generators and cooling towers. The Applicant is prepared to incorporate sound attenuation enclosures, landscaped berms, and enhanced perimeter screening into the campus design, and welcomes staff's input on the appropriate standards and metrics.
11. Preliminary Staff Concerns. The Applicant requests any preliminary feedback or concerns from Department staff regarding the proposed use, intensity, site design, or any other aspect of the Project that would be beneficial for the Applicant to address in the ZMOD application.
VIII. Proposed Meeting Availability
The Applicant, its counsel, local zoning counsel, and land use consultant are available for a pre-application conference at the Department's earliest convenience. To allow sufficient time for the conference to occur and for the Applicant to incorporate any staff feedback into the ZMOD application prior to the May 30, 2025 filing target, the Applicant respectfully suggests that the conference be scheduled during the period of mid-to-late May 2025, ideally during the weeks of May 12 or May 19, 2025.
The following individuals are expected to attend the pre-application conference on behalf of the Applicant:
• Thomas Ashcroft, Partner, Ashcroft & Wynn, P.C. — Local Zoning Counsel
• Alan Mercer, Principal, Cornerstone Land Use Consulting, LLC — Land Use and Entitlements Consultant
• Leonard Castellano, Executive Vice President, Development, Ironhaven Data Centers LLC — Applicant's Representative
• Carlos Esteban, PE, Principal, Lumen Ridge Engineering, PLLC — Civil/Site Engineer
• Douglas Fairchild and/or Cynthia Ho, Calderwood & Harkness LLP — Outside Counsel (attendance to be confirmed)
For purposes of scheduling, please direct all communications to either of the following:
Thomas Ashcroft, Esq. Ashcroft & Wynn, P.C. 25 West Market Street Leesburg, Virginia 20176 Telephone: (703) 555-4420
Email: tashcroft@ashcroftwynn.com
Alan Mercer Cornerstone Land Use Consulting, LLC 19 Cornwall Street NW, Suite 210 Leesburg, Virginia 20176 Telephone: (703) 555-8830
Email: amercer@cornerstoneluc.com
IX. Preliminary Submissions Enclosed
To facilitate the Department's preparation for the pre-application conference, the following preliminary materials are enclosed with this letter for staff review:
Enclosure 1: Conceptual Site Plan — An illustrative conceptual site plan showing the 81.4-acre campus layout, the footprints and approximate locations of Buildings A through D, the central utility plant, the dedicated electrical substation on the Meridian Parcel, structured parking areas, internal roadways, and stormwater management areas. The conceptual site plan was prepared by Lumen Ridge Engineering, PLLC (Carlos Esteban, PE, Principal).
Enclosure 2: Vicinity Map — A vicinity map showing the Stonebridge Parcel and the Meridian Parcel in relation to Belmont Ridge Road, Stonebridge Boulevard, and surrounding parcels and land uses.
Enclosure 3: Loudoun County Tax Map Excerpts — Excerpts from the Loudoun County Tax Map depicting Parcels /95-4A-1/// (Stonebridge Parcel) and /95-4A-2/// (Meridian Parcel), including parcel boundaries, acreage, and tax map reference numbers.
Enclosure 4: One-Page Project Summary — A brief narrative summary providing a high-level overview of the Stonebridge Data Center Campus, including the proposed use, capacity, building configuration, supporting infrastructure, estimated capital investment, and anticipated construction timeline.
The Applicant notes that the enclosed materials are preliminary and are provided solely for the purpose of facilitating a productive pre-application conference. The full ZMOD application materials — including the ZMOD Application Narrative and Statement of Justification, the proffer statement, detailed site plans, transportation impact analysis, noise study, fiscal impact analysis, architectural renderings, and all other required supporting studies and documentation — are currently in preparation and will be submitted with the formal ZMOD application filing targeted for May 30, 2025.
Closing
We appreciate the Department's time and consideration in reviewing this request and the enclosed materials. The Applicant looks forward to a productive dialogue with Department staff and is committed to working collaboratively with the Department, the Planning Commission, and the Board of Supervisors throughout the ZMOD review process to ensure that the Project is developed in a manner that is consistent with the Zoning Ordinance, the Comprehensive Plan, and the best interests of the Loudoun County community.
We wish to emphasize the significant economic development benefits that the Stonebridge Data Center Campus will bring to Loudoun County. The Project represents approximately $600,000,000 in total capital investment, will generate substantial construction employment during the approximately two-year construction period, and will create permanent, high-quality operational employment upon completion. In addition, data center equipment assessments will provide meaningful and ongoing tax revenue to the County, contributing to the fiscal health of the community. The Applicant is committed to being a responsible corporate neighbor and to delivering a project that reflects the highest standards of design, environmental stewardship, and community engagement.
Should the Department require any additional information in advance of the pre-application conference, or at any time during the ZMOD application process, please do not hesitate to contact the undersigned or any member of the Applicant's team identified in this letter. We are at the Department's disposal and are eager to move forward collaboratively toward a successful outcome.
We thank you for your attention to this matter and look forward to your response regarding the scheduling of the pre-application conference.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Douglas Fairchild, Partner 1900 K Street NW, Suite 800 Washington, DC 20006 Telephone: (202) 555-7124
Email: dfairchild@calderwoodharkness.com
ASHCROFT & WYNN, P.C.
By: ________
Thomas Ashcroft, Partner 25 West Market Street Leesburg, Virginia 20176 Telephone: (703) 555-4420
Email: tashcroft@ashcroftwynn.com
cc:
Marcus Thorne, Chief Executive Officer, Ironhaven Data Centers LLC Leonard Castellano, Executive Vice President, Development, Ironhaven Data Centers LLC Priya Dasgupta, Chief Financial Officer, Ironhaven Data Centers LLC Alan Mercer, Principal, Cornerstone Land Use Consulting, LLC Cynthia Ho, Associate, Calderwood & Harkness LLP Grace Nakamura, Associate, Calderwood & Harkness LLP
Enclosures:
Enclosure 1: Conceptual Site Plan (prepared by Lumen Ridge Engineering, PLLC) Enclosure 2: Vicinity Map Enclosure 3: Loudoun County Tax Map Excerpts — Parcels /95-4A-1/// and /95-4A-2/// Enclosure 4: One-Page Project Summary — Stonebridge Data Center Campus

April 28, 2025

VIA HAND DELIVERY AND ELECTRONIC MAIL

CALDERWOOD & HARKNESS LLP

ASHCROFT & WYNN, P.C.

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