2021-03-18 IID Ltrt1r•-y of-0114ce.
March 18, 2021
Nicole Sauviat Criste
Consulting Planner
Design and Development Department
City of La Quinta
78495 Calle Tampico
La Quinta, California 92253
www.iid.com
Sincc 1911
SUBJECT: NOP of an EIR for the Coral Mountain Resort Specific Plan and Tentative
Tract Map in La Quinta, CA
Dear Ms. Sauviat Criste:
On February 23, 2021, the Imperial Irrigation District received from the City of La Quinta,
a Notice of Preparation of an Environmental Impact Report for the Coral Mountain
Specific Plan and Tentative Tract Map. The applicant, CM Wave Development, LLC;
proposes the development of approximately 386 acres located south of Avenue 58, north
of Avenue 60, and east and west of Madison Street in la Quinta, California to build 600
dwelling units, 150-room resort facility, 57,000 sq. ft. for tourist commercial uses, 60,000
sq. ft. of neighborhood commercial space, 23.6 acres for open space recreational uses
and a 16.62-acre artificial wave basin for recreational purposes.
The Imperial Irrigation District has reviewed the project information and has the following
comments:
Based on the preliminary information provided to the IID for phase 1 and
subsequent phases, the installation of a new distribution substation 1-40MVA
92/13.2kV transformer bank at the existing Avenue 58 Substation, including the
reconfiguration of the 92kV transmission lines and all bank addition infrastructure,
will be required to accommodate the power requirements of the project.
2. Applicant will be required to install a double conduit/vault system from the new
Avenue 58 substation bank to the project for a minimum of six (6) distribution
backbone feeders. The proposed route for this system is planned to come out of
the Avenue 58 Substation, cross Avenue 58 and continue on the south side of
Avenue 58 going west all the way to the project. The whole conduit system will be
required to be in place prior to extending the new feeders/backbone line extensions
(conduit, cable) from the Avenue 58 Substation's new 40MVA transformer circuit
breakers to the project for phase 1 and subsequent phases.
IMPERIAL IRRIGATION DISTRICT • P.O. BOX 937 • IMPERIAL, CA 92251
Nicole Sauviat Criste
March 18, 2021
Page 2
3. Applicant will be required to extend six (6) distribution backbone feeders as part of
the new substation transformer implementation, including the associated
backbone cable/terminations from Avenue 58 Substation's new 40MVA
transformer circuit breakers to the project's load centers, all which are at the
expense of the applicant.
4. The applicant shall bear the cost of the substation infrastructure to serve the
project but would be reimbursed for any oversizing required, subject to approval
by the IID Board of Directors.
5. Applicant (and other developers in the area) shall bear all costs associated with
providing electrical service to the project, including but not limited to the
construction of new substation facilities, transmission line extensions or upgrades,
distribution backbone feeders, conduit/vault systems, distribution overhead and/or
underground line extensions, the reconfiguration of distribution circuits,
transmission line extensions or other upgrades as well as applicable permits,
zoning changes, landscaping (if required by the City) and rights -of -way and
easements.
6. Applicant should be advised that pursuant to IID process, the standard timeframe
for the implementation of a new substation transformer (engineering, equipment
procurement and construction) is 18 months at minimum. As a result, Applicant
should adjust its project's in-service dates accordingly. The procurement of the
new substation bank would start upon receipt of a customer project application for
the substation bank acquisition including payment for the full cost of the required
equipment.
7. Applicant is encouraged to submit a new Will Serve letter request with updated
loading and construction phasing schedule to prepare a required full impact study
for a revised Plan of Service. To avoid ambiguity and delays, this information will
be required for all phases of the project. The information should be submitted well
in advance of any required in-service date to ensure sufficient time for procurement
and construction.
8. The district's ability to provide electrical service is based on currently available
capacity as of this date, which may be impacted by future development in the area.
It is important to note that a detailed and final study will be developed once a
customer project application and loading calculations are received. This detailed
information will allow IID to perform an accurate assessment and provide a full
report of any potential impacts and mitigation measures. However, other projects
could impact existing resources which may affect IID's ability to serve this load, if
the buildout of the mitigation measures are not completed in a timely manner The
conditions of service could change as a result of the additional studies.
Nicole Sauviat Criste
March 18, 2021
Page 3
9. IID will not begin any studies, engineering or estimate costs to provide electrical
service to the project until the applicant submits a customer project application
(available at the website.http://www.iid.com/home/showdocument?id=12923) and
detailed loading information, panel sizes, project schedule and estimated in-
service date, etc. are submitted as well.
10. Underground infrastructure that includes trenching, conduits, pull boxes, switch
boxes and pads should be installed following IID approved plans. Physical field
installation of underground infrastructures should be verified and approved by an
IID inspector prior to cable installation as per IID Developer's Guide (available at
the district website https://www.iid.com/home/showdocument?id=l4229).
11. IID Regulations governing line extensions can be found at:
No.2
(http://www.iid.com/home/showdocument?id=2540),
No.13
(http://www.iid.com/home/showdocument?id=2553),
No.15
(http://www.iid.com/home/showdocument?id=2555),
No. 20
(http://www.iid.com/home/showdocument?id=2560)
and
No.23
(https://www.iid.com/home/showdocument?id=l7897).
12. For additional information regarding electrical service for the project, the applicant
should be advised to contact the IID Energy - La Quinta Division Customer
Operations, 81-600 Avenue 58 La Quinta, CA 92253, at (760) 398-5841 and speak
with the project development planner assigned to the area.
13.It is important to note that IID's policy is to extend its electrical facilities only to
those projects that have obtained the approval of a city or county planning
commission and such other governmental authority or decision -making body
having jurisdiction over said developments.
14.The applicant will be required to provide rights -of -way and easements for
substation, transmission and distribution line extensions and overhead or
underground infrastructure needed to serve the project.
15.Any construction or operation on IID property or within its existing and proposed
right of way or easements including but not limited to: surface improvements such
as proposed new streets, driveways, parking lots, landscape; and all water, sewer,
storm water, or any other above ground or underground utilities; will require an
encroachment permit, or encroachment agreement (depending on the
circumstances). A copy of the IID encroachment permit application and instructions
for its completion are available at https://www.iid.com/about-iid/department-
directory/real-estate. The IID Real Estate Section should be contacted at (760)
339-9239 for additional information regarding encroachment permits or
agreements.
Nicole Sauviat Criste
March 18, 2021
Page 4
16. Relocation of existing IID facilities to accommodate the project and/or to
accommodate street widening improvements imposed by the City will be deemed
project -driven and all costs, as well as securing of rights of way and easements for
relocated facilities, shall be borne by the applicant.
17. Public utility easements over all private public roads and additional ten (10) feet in
width on both side of the private and public roads shall be dedicated to IID for the
construction, operation, and maintenance of its electrical infrastructure.
18.Any new, relocated, modified or reconstructed IID facilities required for and by the
project (which can include but is not limited to electrical utility substations, electrical
transmission and distribution lines, etc.) need to be included as part of the project's
CEQA and/or NEPA documentation, environmental impact analysis and mitigation.
Failure to do so will result in postponement of any construction and/or modification
of IID facilities until such time as the environmental documentation is amended and
environmental impacts are fully mitigated. Any mitigation necessary as a result
of the construction, relocation and/or upgrade of lID facilities is the
responsibility of the project proponent.
19. Dividing a project into two or more pieces and evaluating each piece in a separate
environmental document (Piecemealing or Segmenting), rather than evaluating
the whole of the project in one environmental document, is explicitly forbidden by
CEQA, because dividing a project into a number of pieces would allow a Lead
Agency to minimize the apparent environmental impacts of a project by evaluating
individual pieces separately, each of which may have a less -than -significant impact
on the environment, but which together may result in a significant impact.
Segmenting a project may also hinder developing comprehensive mitigation
strategies. In general, if an activity or facility is necessary for the operation of a
project, or necessary to achieve the project objectives, or a reasonably foreseeable
consequence of approving the project, then it should be considered an integral
project component that should be analyzed within the environmental analysis. The
project description should include all project components, including those that will
have to be approved by responsible agencies. The State CEQA Guidelines define
a project under CEQA as "the whole of the action" that may result either directly or
indirectly in physical changes to the environment. This broad definition is intended
to provide the maximum protection of the environment. CEQA case law has
established general principles on project segmentation for different project types.
For a project requiring construction of offsite infrastructure, the offsite infrastructure
must be included in the project description. San Joaquin Raptor/Wildlife Rescue
Center v. County of Stanislaus (1994) 27 Cal.App. 4th 713.
20.Applicant should be advised that landscaping can be dangerous if items are
planted too close to IID's electrical equipment. In the event of an outage, or
equipment failure, it is vital that IID personnel have immediate and safe access to
Nicole Sauviat Criste
March 18, 2021
Page 5
its equipment to make the needed repairs. For public safety, and that of the
electrical workers, it is important to adhere to standards that limit landscaping
around electrical facilities. IID landscaping guidelines are available at
https://www.iid.com/energy/vegetation-management.
Should you have any questions, please do not hesitate to contact me at (760) 482-3609
or at dvargas@iid.com. Thank you for the opportunity to comment on this matter.
Respe Ily,
Donald Vargas
Compliance Administrator II
Enrique B. Martinez -General Manager
Mike Pacheco - Manager, Water Dept.
Marilyn Del Bosque Gilbert - Manager, Energy Dept.
Constance Bergmark - Mgr. of Planning & Eng./Chief Elect. Engineer, Energy Dept.
Enrique De Leon - Asst. Mgr., Energy Dept., Distr., Planning, Eng. & Customer Service
Jamie Asbury -Assoc. General Counsel
Vance Taylor -Asst. General Counsel
Michael P. Kemp - Superintendent, Regulatory & Environmental Compliance
Laura Cervantes - Supervisor, Real Estate