AECOM Environment 1220 Avenida Acaso, Camarillo, CA 93012

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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 Signific ant 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), purs uant 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 prov ided to the USFWS.

Subsequent to submittal of these documents, t he 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 B enz 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, Californi a 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