AECOM Environment (805)388-3775 tel 

1220 Avenida Acaso (805)388-3577 fax 

Camarillo, CA 93012 

July 21, 2010 

Mr. Gerardo Rios 

Chief, Permits Office (AIR 3) 

U.S. Environmental Protection Agency 

75 Hawthorne Street 

San Francisco, CA 94105 

RE: Palmdale Hybrid Power Project (PHPP) – Supplemental Information for the 

Application for PSD Permit 

Dear Mr. Rios: 

AECOM Environment, on behalf of the City of Palmdale and Inland Energy, Inc., is submitting 

the enclosed Supplemental Information on the application for a Prevention of Significant 

Deterioration (PSD) permit for the Palmdale Hybrid Power Project (PHPP). The PHPP is a 

hybrid power plant consisting of combined-cycle power plant integrated with 50 megawatts 

(MW) of solar arrays for a combined nominal output of 570 MW. The PSD application for 

PHPP was submitted to EPA on April 1, 2009. This supplemental information is being provided 

in response to a conference call held between EPA Region 9 staff, Inland Energy, Latham & 

Watkins, and AECOM on March 14, 2010. EPA indicated that the PHPP PSD Application 

would be complete if the following items were addressed: 

1. An expanded cumulative fine particulate matter (PM2.5) impact analysis to demonstrate 

compliance with the National Ambient Air Quality Standard (NAAQS). The EPA also 

requested additional analysis regarding the potential applicability of PM2.5 increment 

thresholds proposed in the Federal Register on September 21, 2007; 

2. A 1-hour Nitrogen Dioxide (NO2) NAAQS modeling analysis; 

3. An expanded Soils and Vegetation analysis based on the Environmental Appeals Board 

case In re: Indeck-Elwood, LLC; PSD Appeal No. 03-04; PSD Permit No. 197035AAJ 

(decided September 27, 2006); 

4. A Visibility analysis at local sensitive state or federal Class II areas; 

5. Additional justification/documentation that the receptor grids used in the PSD modeling 

analysis out to 20 kilometers (km) are sufficient to identify the maximum impacts; and 

6. A more detailed growth analysis than was submitted with the PSD application. 
AECOM 

 OC\1073055.1 

2

In addition to the above items, the EPA requested the following item, that was not a 

“completeness” item, but which would expedite the issuance of the permit: 

7. Additional detail regarding the Best Available Control Technology (BACT) analysis 

Enclosed please find three copies of the PSD Application Supplement. Since these 

supplemental materials do not change our Class I area analyses, we have not provided a copy 

to the National Park Service or the U.S. Forest Service. 

We request that EPA review the supplemental information in a timely manner and move forward 

with processing the PSD permit application. Please let me know (by phone 805-388-3775 or 

email sara.head@aecom.com) if you or your staff have questions or need further supplemental 

information. 

Sincerely 

Sara J. Head, QEP 

Vice President, AECOM Environment 

Sara.head@aecom.com 

Attachments: PSD Application Supplemental Information (3 copies) 

 DVD with modeling files (3 copies) 

cc: Ms. Shirley Rivera, EPA 

Ms. Felicia Miller, California Energy Commission (with 1 copy of the attachments) 

 Mr. Alan De Salvio, Antelope Valley Air Quality Management District 

 Ms. Laurie Lile, Assistant City Manager, Palmdale 

 Mr. Tom Barnett, Inland Energy, Inc. 

Mr. Tony Penna, Inland Energy, Inc. 

 Mr. Mike Carroll, Latham & Watkins