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 Palmdale and Inland Energy, Inc., is submitting an 

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. 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. Environmental Protection Agency (EPA) will 

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. We have enclosed three copies of a 

Draft1

 Biological Assessment for the Project to assist you with that consultation, which we 

anticipate will seek concurrence 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 Application, 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 Application 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 District 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 Rivera of your staff, we are also sending a copy of the PSD permit 

application to the U.S. Forest Service for their 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 Commission (with 1 copy of the attachments) 

 Mr. Trent Procter, U.S. Forest Service (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