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
comb ined

- 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 includ ed 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 Appl ication 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 t o 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 . T 

### he 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 speci es.

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

s ara.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 Palmd ale Mr. Tom Barnett, Inland Energy, Inc. Mr. Mike Carroll, Latham & Watkins Ms. Kim McCormick, Law Offices of Kim McCormick