AECOM (805)388-3775 tel

1220 Avenida Acaso (805)388-3577 fax

Camarillo, CA 93012

May 9, 2011

Mr. Gerardo Rios

Chief, Permits Office (AIR 3)

U.S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA 94105

RE: Palmdale Hybrid Power Project (PHPP) –

Greenhouse Gas BACT Analysis and Request For Draft PSD Permit

Dear Mr. Rios:

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

enclosed Greenhouse Gas Best Available Control Technology (BACT) Analysis as a supplement to 

the Prevention of Significant Deterioration (PSD) permit application for the Palmdale Hybrid Power 

Project (PHPP). 

The PHPP is a 570 MW state-of-the art, “hybrid” natural gas-fired combined-cycle power plant 

integrated with 50 MW of solar thermal generation. The combined-cycle equipment utilizes two 

state-of-the-art natural gas-fired combustion turbine generators, two heat recovery steam generators, 

and one steam turbine generator. The solar thermal component of the PHPP has the potential to 

produce up to almost 10 percent of facility total generation. PHPP will also employ General Electric 

Power Systems (GE) Rapid Start Process (RSP) to minimize emissions during startup and increase 

the efficiency of the power plant. 

As we demonstrate in the enclosed document, the advanced thermal efficiency achieved by the 

PHPP constitutes BACT for greenhouse gases. Our analysis was prepared in accordance with the 

EPA’s PSD And Title V Permitting Guidance For Greenhouse Gases, issued March 11, 2011. With 

this submittal, the PHPP application for a PSD permit is fully complete. Accordingly, we respectfully 

request issuance of the draft PSD permit as soon as possible, and, for the reasons described below, 

no later than June 20, 2011. 

The City of Palmdale submitted a PSD permit application to EPA Region 9 for the PHPP on April 1, 

2009, more than two years ago. Based on verbal and email communications with the EPA and to 

address new standards, we responded to a number of informal EPA data requests and provided a

substantial application supplement on July 21, 2010 in response to a conference call on March 14, 

2010. Subsequent to that submittal, we have submitted several additional modeling supplements to 

address the 1-hour NO2 ambient air quality standard, including memorandums on October 7, 2010, 

December 14, 2010 and March 30, 20111

 

1 Note, some of the analyses requested by EPA were subsequently determined not to be needed under the 

guidance on the new 1-hour NO2 NAAQS that was issued on March 1, 2011.

. The March 30 supplement resolved all outstanding issues 

identified by the EPA except for the greenhouse gas BACT analysis, which we are providing today. 
AECOM 2

The City of Palmdale requests that the EPA issue a draft PSD permit as soon as possible. The City 

has expended significant time and tax-payer expenses during the PHPP’s permitting process. The 

City has cooperatively responded to each of EPA’s requests to date. The length of time in the 

permitting process, in particular the entire year between submittal of the PSD application on April 1, 

2009 and the conference call with EPA on March 14, 2010 when completeness items were relayed,

has lead to the need for additional analyses which have been burdensome to the City. This delay 

has led to the need to address new requirements related to PM2.5 analyses, new national ambient 

air quality standards, and now GHG requirements – none of which would have been required if the 

PSD permit were issued within the EPA target one year PSD processing timeframe. We now have 

another date approaching -- the effective date of the new PM2.5 increment on October 20, 20112

The City requests that the EPA issue the draft PSD permit no later than June 20, 2011. This date 

will provide adequate time for public review, responses, and permit issuance before October 20, 

2011. We believe this is a reasonable schedule because the EPA has had a substantial period of

time to review the PHPP’s PSD application and supplements. The GHG BACT analysis submitted 

today should not cause further substantial delay. Given the importance of this matter to the City, we 

will contact your office to set up an in-person meeting to address any remaining questions. We look 

forward to working with the EPA to finalize this PSD permit.

. 

Addressing this requirement would involve potentially expensive and time-consuming additional 

analysis. The continued need to address one new requirement after the other will threaten the 

feasibility of the project. The final approvals of the PHPP are expected to be issued by the California 

Energy Commission in the next couple of months, and further delay of the PSD permit will severely 

hamper the ability of the project to obtain financing and move forward. PHPP is the type of power 

generation project that EPA should be encouraging, due to its high efficiency and lack of significant 

impacts. 

If you have any questions about this letter, please do not hesitate to contact me. 

Sincerely

Sara J. Head, QEP

Vice President, AECOM Environment

Sara.Head@aecom.com

Attachment: Palmdale Hybrid Power Plant Greenhouse Gas BACT Analysis 

cc: Ms. Shirley Rivera, EPA

Ms. Laurie Lile, Assistant City Manager, Palmdale

Mr. Tom Barnett, Inland Energy, Inc.

Mr. Mike Carroll, Latham & Watkins

 

2 See Prevention of Significant Deterioration (PSD) for Particulate Matter Less Than 2.5 Micrometers (PM2.5)—

Increments, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC), 75 Fed. Reg. 

64,864, 64,887 (Oct. 20, 2010).