AECOM Environment 1220 Avenida Acaso, Camarillo, CA 93012

T 805.388.3775 F 805.388.3577 www.aecom.com

AECOM Environment March 31, 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:

AECOM Environment, on behalf of the City of Pa lmdale and Inland Energy, Inc., is submitting an application for a Prevention of Significant Dete rioration (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 so lar arrays for a combined nominal output of 570 MW. Enclosed please find three copies of the PSD Application, as directed by Ms. Shirley Rivera of your staff.

The City and Inland Energy anticipate that the U.S. Environmen tal Protection Agency (EPA) will
initiate consultation with the U.S. Fish and Wild life Service (USFWS), purs uant to Section 7 of the Endangered Species Act of 1973, as amended, regarding potentia l impacts to listed species resulting from EPA’s issuance of a PSD permit for the PHPP. We have enclosed three copies of a
Draft 1 Biological Assessment for the Project to as sist you with that c onsultation, which we anticipate will seek c oncurrence from the USFWS that the Project may affect but is not likely to adversely affect federally listed species.

We also have included CD’s with electronic copies of the PSD Applicati on, modeling files and the Draft Biological Assessment. An air quality impact analysis has been conducted to demonstrate
that the PHPP will not cause or contribute to violations of the National Ambient Air Quality Standards (NAAQS) during routine operations. The enclosed PSD Applicati on includes the details of this impact analysis.

The City of Palmdale submitted its Application for Certification (AFC) to the California Energy Commission (CEC) on August 4, 2008, and was deemed Data Adequate on October 8, 2008. The Application for a Determination of Compliance (DOC) to the Antelope Valley Air Quality Management

1 

### The document is a “Draft” since we consider it up to the agencies to finalize. However, from our standpoint, this is a Final document.Mr. Gerardo Rios March 31, 2009 Page 2

District has also been deemed complete, and the Dist rict issued its Preliminary DOC on February 12,
2009.

The contacts at these agencies for the PHPP include:

Ms. Felicia Miller, Project Manager, CEC, 916-654-4640, fmiller@ energy.state.ca.us Mr. Bret Banks, AVAQMD, 661-723-8070, bbanks@avaqmd.ca.gov Mr. Ray Bransfield, USFWS, 805-644-1766 , Ray_Bransfield@fws.gov

At the request of Ms. Shirley Rive ra of your staff, we are also se nding a copy of the PSD permit application to the U.S. Forest Service for thei r review, as the Federal Land Manager of the San Gabriel and Cucamonga Wilderness Class I Areas. We will also verify it the National Park Service would like a copy of the application.

We request that EPA work with these other agencies to coordinate the timeline for permit approvals and requirements.

Please call me at (805) 388-3775 if you have any questions or need additional information. We appreciate your assistance with this matter.

Sincerely

Sara J. Head, QEP Vice President, AECOM Environment Sara.head@aecom.com

Attachments: PSD Application (3) Draft Biological Assessment (3) Compact Disk (CD) with documents and modeling files (3)

cc: Ms. Shirley Rivera, EPA Ms. Felicia Miller, California Energy Commi ssion (with 1 copy of the attachments) Mr. Trent Procter, U.S. Forest Serv ice (with 1 copy of the attachments) Mr. Alan De Salvio, Antelope Valley Air Quality Management District 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