AECOM Environment 

1220 Avenida Acaso, Camarillo, CA 93012 

T 805.388.3775 F 805.388.3577 www.aecom.com

AECOM Environment 

August 7, 2009 

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) Application for PSD Permit and 

Request for Endangered Species Act Consultation and Concurrence

Dear Mr. Rios: 

On March 31, 2009, AECOM Environment, on behalf of the City of Palmdale and Inland Energy, Inc., 

submitted an application for a Prevention of Significant Deterioration (PSD) permit for the Palmdale 

Hybrid Power Project (PHPP). The PHPP is a hybrid power plant to be located in Palmdale, CA, that 

will consist of a combined-cycle power plant integrated with 50 megawatts (MW) of solar arrays for a 

combined nominal output of 570 MW. As indicated in that submittal, the City and Inland Energy 

anticipated that the U.S. Environmental Protection Agency (EPA) would initiate consultation with 

the U.S. Fish and Wildlife Service (USFWS), pursuant to Section 7 of the Endangered Species Act 

of 1973, as amended, regarding potential impacts to listed species resulting from EPA’s issuance 

of a PSD permit for the PHPP. A Draft Biological Assessment (BA) for the PHPP was submitted 

along with the PSD application to assist the EPA with it’s consultation with the USFWS. A copy of 

the Draft BA was also provided to the USFWS. 

Subsequent to submittal of these documents, the Applicants’ consultants have been in frequent 

contact with Mr. Ray Bransfield of the USFWS regarding the Draft BA. Focused breeding season 

surveys for the federally listed species, arroyo toad, were conducted from April 21, 2009 to June 

25, 2009 in the Little Rock Creek area (where transmission line segment 2 crosses Little Rock 

Creek), and no arroyo toad adults, juveniles, eggs, or larvae were detected. A copy of the arroyo 

toad survey report was provided to Mr. Carl Benz of the USFWS on July 23, 2009. Based on Mr. 

Bransfield’s review of and input on the Draft BA, an Addendum to the PHPP Biological Assessment is 

attached. This BA Addendum more clearly supports a finding from the USFWS that the Project 

may affect but is not likely to adversely affect desert tortoise and will have no effect on arroyo 

toads. 

The PHPP BA Addendum identifies where changes should be made to the original Draft BA 

submitted on March 31, 2009. If desired, we would be happy to re-submit the entire BA with 

these changes incorporated. 
Mr. Gerardo Rios 

August 7, 2009 

Page 2 

With this submittal we believe that the information needed for EPA’s consultation with the 

USFWS is complete and it is our understanding that the USFWS agrees with the finding as 

stated above. 

Please call me at (805) 388-3775 if you have any questions or need additional information. We look 

forward to seeing the draft PSD permit issued shortly. 

Sincerely 

Sara J. Head, QEP 

Vice President, AECOM Environment 

Sara.Head@aecom.com 

Attachments: Addendum to the PHPP Biological Assessment (3) 

cc: Mr. Ray Bransfield, USFWS 

Ms. Shirley Rivera, EPA 

 Mr. Manny Aquitania, EPA 

Ms. Felicia Miller, California Energy Commission 

 Ms. Misa Milliron, California Energy Commission 

 Ms. Erinn Wilson, California Dept. of Fish & Game 

 Ms. Laurie Lile, City Manager, Palmdale 

 Mr. Tom Barnett, Inland Energy, Inc. 

Mr. Tony Penna, Inland Energy, Inc. 

 Mr. Mike Carroll, Latham & Watkins 

 Ms. Kim McCormick, Law Offices of Kim McCormick