AECOM (805)388-3775 tel

1220 Avenida Acaso (805)388-3577 fax

Camarillo, CA 93012

PHPP BA Addendum

July 21, 2011

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) Biological Assessment Addendum

Dear Mr. Rios:

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) in March 2009. The PHPP is a hybrid power plant consisting of a 

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

nominal output of 570 MW. Our team recently (June 27, 2011) met with U. S. Environmental 

Protection Agency (EPA) Region 9 representatives to discuss the status of the PSD permit for 

PHPP. One of the items that was requested at the meeting by EPA was that the Applicant 

provide an Addendum to the Biological Assessment (BA) for the PHPP. 

The initial BA for the PHPP was submitted to the EPA on March 31, 2009, along with the 

application for the PSD permit, and included a request that the EPA initiate consultation for the 

Project with the U.S. Fish and Wildlife Service (USFWS) under Section 7 of the Endangered 

Species Act. As noted in the cover letter for the PSD Application and BA in March 2009, the 

City of Palmdale (the Applicant) anticipated that EPA would seek USFWS concurrence that

issuance of the PSD permit for the PHPP “may affect but is not likely to adversely affect” 

federally listed species.

Subsequent to the submittal of the PSD application and BA to the EPA in March 2009, the 

licensing/permitting of the Project has progressed under the California Energy Commission’s 

(CEC’s) siting process. This Addendum to the BA is needed to address two additional potential 

components of the Project identified during this CEC process: 1) an alternative transmission line 

route that was developed and assessed by the CEC; and 2) a list of road segments in and 

around the City of Palmdale that may be paved to create emission reduction credits for the 

PHPP. The proposed alternative transmission line and road paving were both added to the 

Project scope subsequent to the completion of the BA. This BA Addendum contains the 

description of these additional Project components and provides analyses in support of a 

determination that issuance of the PSD permit may affect but is not likely to adversely affect for 

the federally listed desert tortoise (Gopherus agassizii) and a determination of no effect for the 

federally listed arroyo toad (Anaxyrus californicus).
AECOM

PHPP BA Addendum

2

The CEC has fully analyzed the impacts of the PHPP under its California Environmental Quality 

Act (CEQA)-equivalent environmental review process. The Presiding Member’s Proposed 

Decision (PMPD) for the PHPP was issued in June 2011. The PMPD as well as previous 

Staff Assessments determined that the PHPP can be constructed and operated with no 

significant impacts, including no significant impacts to biological resources – and including 

the additional components that are the subject of this BA Addendum. The PHPP is 

expected to be fully approved by the Energy Commission in August 2011. 

Similar to the initial BA for the PHPP, the City of Palmdale requests that EPA include this BA 

Addendum in its consultation with USFWS and in its request for USFWS concurrence that 

issuance of the PSD permit for the Project may affect but is not likely to adversely affect 

federally listed species. 

We look forward to EPA’s issuance of the proposed PSD permit for the PHPP in the near term. 

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: PHPP Biological Assessment Addendum (3)

cc: Ms. Shirley Rivera, EPA

Ms. Lisa Beckham, EPA

Mr. Ray Bransfield, USFWS

Ms. Laurie Lile, Assistant City Manager, City of Palmdale

Mr. Tom Barnett, Inland Energy, Inc.

Mr. Mike Carroll, Latham & Watkins

Ms. Kim McCormick, Law Offices of Kim McCormick