20131200 Ver 3_More Info Received_20151123

CLearWaLer
C1earWater Environmental Consultants, Inc. D
November 18 2015 www.cwenv.com L
°� ?�,,
Mr. Steve Kichefski ao NR 2
US Army Corps of Engineers 1 $ e wgrF %
151 Patton Avenue, Room 208 UFFFR EkM�UR
Asheville, North Carolina 28801 ��Nc
RE: Response to Corps Comments
Tryon International Equestrian Center
Polk County, North Carolina
Action ID SAW- 2013 - 00262; DWQ Project # 13 -1200 v3
Dear Mr. Kichefski,
Please reference the letter dated October 2, 2015 (Attachment A) sent by the US Army
Corps of Engineers (Corps) in response to the permit application submitted by
C1earWater Environmental Consultants, Inc. (CEC), on behalf of Tryon Equestrian
Partners, LLC represented by Mr. Jeff Brown. The permit application requested written
authorization for the impacts associated with development of the Tryon International
Equestrian Center. The comments provided by the Corps are listed and discussed below.
Comments Provided by the US Fish and Wildlife Service (FWS)
The FWS offered several recommendations regarding stormwater management,
invasive exotic species, sediment and erosion control, stream and wetland
protection, and mitigation. Responses to each of the FWS's concerns are
discussed in a separate letter addressed to the Corps dated November 18, 2015.
Comments Provided by the Wildlife Resources Commission (WRC)
The WRC offered several recommendations regarding jurisdictional impacts,
mitigation, and stormwater. Responses to each of the WRC's concerns are
discussed in a separate letter addressed to the Corps dated November 18, 2015.
Comments Provided by the Environmental Protection Agency (EPA)
The EPA had several questions regarding proposed mitigation for the project.
Responses to each of the EPA's concerns are discussed in a separate letter
addressed to the Corps dated November 18, 2015. Corps comments raising the
same concerns are discussed below.
32 Clayton Street
Asheville, NC 28801
828 - 698 -9800 Tel

Mr. Steve Kichefski
11.18.15
Page 2 of 7
Comments Provided by the State Historic Preservation Office (SHPO)
The SHPO indicated that based on the topographic and hydrological situation and
density of archaeological sites in the area, there is a high probability for the
presence of prehistoric or historic archaeological sites. The SHPO recommended
that a comprehensive survey be conducted at the site. The applicant has
contracted with TRC Garrow for additional archaeological services at the site. An
archaeological report will be submitted to the Corps upon completion.
Comments Provided by the Public
Two citizens with property adjacent to the project site provided comments.
Responses to public comments are discussed in a separate letter addressed to the
Corps dated November 18, 2015.
Comments Provided by the Corps
Corps Comment #1 - "In order to effectively evaluate potential alternatives for this
project, additional information regarding potential alternatives is needed. In prior
meetings regarding the equestrian center, a much broader region than Polk County was
evaluated by the applicant prior to site selection. Provide more detailed information
regarding the criteria used in property selection and other areas that were considered to
justify that no off` -site alternatives would meet the least environmentally damaging
practicable alternative (LEDPA)."
An updated Alternatives Analysis which takes the place of Section 6.0 of the
Individual Permit Application has been included for review (Attachment B).
Corps Comment #2 — "A portion of the proposed impacts are associated with further
development of the equestrian center (E] and E2). Elaborate as to why these impacts are
needed, why they cannot be further avoided or minimized and provide details (including
plans) as to the impacts proposed. How would the design of the proposed impact area
direct existing flow of the jurisdictional stream and will any flow be reduced to
downstream waters."
An Updated Site Plan has been included for review (Figure 1). Impact E1 is more
directly associated with the Equestrian Center infrastructure. A Site Plan
detailing this area is included for review (Figure 2). These impacts are for a derby
field, a 50 -foot grassed bridle path which will connect the Equestrian Center to
the farmettes, parking, an access road, and the development fill slope. Original
plans for this area included significantly more impacts (1,234 linear feet for
Impact El). A site plan from April of 2015 (Figure 3), used at the pre - application
meeting, included one additional farmette lot in the location of the stream charnel
and approximately 840 linear feet of additional stream impacts for E1. These
impacts were eliminated prior to permit application submittal and equate to a 68%
reduction in impacts for that location. Impact E2 is the only impact solely

Mr. Steve Kichcfski
11.18.15
Page 3 of 7
associated with farmette development. Fifty -three feet is all that is required to
develop farmettes on site.
The applicant has avoided and minimized impacts to streams and wetlands to the
greatest extent practicable and feasible while still accomplishing the overall
project purpose. As stated in the permit application, avoidance and minimization
at the equestrian facility, including the "farmettes," reduced impacts by 8,513
linear feet of stream and 0.33 acres of wetland when compared to previous site
plans. A summary of the avoidance and minimization that has taken place on site
is as follows:
Feature On -Site Totals Proposed Impacts Percent Avoided and
Minimized
Stream
66,132
1,463
97.7
Wetland
21.40
0.02
99.9
Open Water
4.04
0
100
The alternatives analysis in the permit application clearly demonstrates the
proposed expansion is designed to avoid and minimize impacts to the site to the
maximum extent practicable while maintaining a rational project design.
Stream impacts in the location of E1 would be comprised of French drains that
would discharge into the existing stream at the base of the fill slope. Stormwater
would also be discharge adjacent to the stream. No water would be routed out of
the watershed; therefore, stream flow should not be reduced.
Corps Comment #3 — "Provide detail as to the need for impact RC2 1UC2 and why it
cannot be further avoided /minimized (avoided, moved to only cross one stream channel
or bridged)."
RC2 cannot be shifted to utilize the existing crossing because of an existing gas
line right -of -way. The existing gas line runs perpendicular to the existing
crossing. If the proposed road were shifted south, the road would be in the right -
of -way which is prohibited. Therefore, the proposed road is just north of the
existing right -of -way.
Two crossings are needed to access two different sections of development: a
residential portion and a commercial portion. After further consideration, the
loop road has been removed so that residential and commercial traffic remain
separate.
Corps Comment #4 — "Road crossings 1 -5 do not appear to cross at perpendicular
angles to the stream and thereby are not providing further minimization of impacts.
Provide detail as to why they cannot be designed to cross at a more perpendicular
angle... Provide further information as to the existing stream slopes for these streams and
why additional channel scour or headcutting will not occur as currently proposed."

Mr. Steve Kichefski
11.18.15
Page 4 of 7
Roads are required to have 2:1 side slopes and are not permitted to exceed 18%
slope on the driving surface. Due to terrain at the site and the location of some
streams in deep valleys, it is not possible to cross all streams at a perpendicular
angle. Proposed stream crossings are the minimum necessary to cross the stream
while maintaining an 18% slope driving surface and 2:1 side slopes.
Pipe slopes were designed to match existing stream slopes. Culverts installed at
the site will be HDPE corrugated pipes. Corrugation would slow water velocity
and contain stream substrate.
Corps Comment #5 — "Will any of the newly proposed development areas on the property
require storm water treatment? If yes, will the storm water treatment impact any
jurisdictional features on the property or significantly reduce normal stream flow due to
the relocation of catchment drainage ?"
Residential areas will not exceed 24% impervious surface area, and therefore, will
not require stormwater management beyond vegetated conveyances. A
Stormwater Management Plan for the Equestrian Center was approved on April
10, 2015 (Attachment C). Stormwater features do not impact stream channels on
site.
Corps Comment #6 — "The application package notes that the proposed utility lines will
be `trenched in and upon completion, the stream beds, and banks will be returned to their
pre- impact condition'. Will any hard armoring be involved in the utility crossings and
will the original channel substrate be returned to the impact area post channel
restoration ?"
Upon completion of utility line installation, stream bed substrate will be returned
to the stream channel and restored slopes will be planted with native woody
vegetation (Figure 4). Hard armoring will not be used on the stream banks.
Corps Comment #7 — "Preservation to 7,9 79 linear feet of stream channel onsite has
been proposed to help compensate for the proposed project impacts. Provide further
clarification to the following aspects of that proposal for further consideration:"
Corps Comment #7a — "Make sure all components of a mitigation plan are provided as
required by 33 CFR 332.4(c) such as a long term management plan, an adaptive
management plan, financial assurances, etc."
The applicant has updated the mitigation plan to include enhancement. A
Preservation and Enhancement Plan is provided for review (Attachment D) and
contains all components as required by 33 CFR 332.4(c).

Mr. Steve Kichefski
11.18.15
Page 5 of 7
Corps Comment #7b — "As a part of the mitigation plan for this project, clarify how the
site protections will be enforced over the long term and the financial assurances that will
guarantee this long term protection."
As stated in the permit application, restrictive covenants would be used to protect
the preservation (and enhancement) reaches. Model language provided by the
Corps will be followed. Covenants are intended to ensure continuing compliance
with mitigation conditions in the- issued 404 permit authorization. As such,
restrictive covenants may be enforced by the Corps. The site will be owned by
Tryon Equestrian Partners, LLC for the duration of implementation of the
preservation plan.
The applicant is requesting that the financial assurances be waived because the
project is comprised primarily of preservation. Permit compliance would be
linked to success of the proposed Preservation and Enhancement Plan
(Attachment D); therefore, the applicant has strong incentive for the project to be
successful or risk violating permit conditions.
Corps Comment #7c — "Provide further information as to why the permittee- responsible
mitigation proposed would be environmentally preferable to credit provided by a
mitigation bank or in -lieu fee program."
The watershed of the proposed preservation and enhancement reaches is
approximately 165 acres and all but approximately 600 linear feet of the streams
in the watershed will be preserved and/or enhanced. Establishing upland riparian
buffers around stream resources limits indirect and cumulative impacts associated
with ongoing development activities. Streams on site would have no protections
should the mitigation plan be determined unacceptable. Preserving and enhancing
streams now is more beneficial than funding restoration at a later date. As
proposed, streams would be preserved within the project site. Although
mitigation provided by a mitigation bank or in -lieu fee program would provide
mitigation within the same watershed, stream reaches used for mitigation could be
many miles from the project site and would not directly benefit the streams on
site.
Permittee responsible mitigation is an accepted means of providing compensatory
mitigation. When properly designed and implemented, and appropriately
monitored, this approach offers a predictable and tested way of achieving
compensatory mitigation as well as the opportunity to protect unique, on -site
natural features.
Corps Comment #7d — "Provide information or-a figure depicting the range and average
buffer widths that will be preserved within the proposed restrictive covenant. Will any
proposed buffer areas be less than l5 feet in width on one side of the channel? Are there
any existing /proposed utility lines /easements or culverts within the proposed preservation
stream or buffer areas ?"

Mr Steve Kichefski
11.18.15
Page 6 of 7
Buffers on proposed preservation reaches have been increased to 60 feet where
possible. Please reference the Preservation and Enhancement Plan (Attachment
D) for an explanation of buffer width and a map showing the location of buffers.
Sections of P4 and E2 would have buffers of less than 15 feet on one site of the
stream channel and the mitigation ratio has been adjusted accordingly. One
existing culvert is located in PI; however, the culvert length was not included in
the stream preservation calculation; "all other crossings and utilities have been
eliminated from the buffer.
Corps Comment #7e — "The proposed impacts shown on Figure 4 of the application
package depict several potential residential areas without lot lines, including around the
proposed preservation area. Provide clarification as to how these areas will be
developed from the perspective of whether any future impacts might occur and how the
development of these areas might degrade the function of the proposed preservation
area."
The existing road crossing is the only jurisdictional impact needed to access and
develop the property south of Sandy Plains Road. The development would be low
density with no concentrated discharge of stormwater. If each lot had 5,000
square feet of impervious surface area, the impervious surface area at the site
would be a minimal 6 %. Considering the width of stream buffers and low density
of future development, stream channels functions should not be degraded.
Corps Comment #7f — "The proposed preservation area has an existing perched road
crossing. Are improvements planned for this crossing as a part of the proposed
development or for the perched culvert as part of the mitigation proposal ?"
The existing road crossing is comprised of a box culvert with a rock step -pool.
The drop on the existing step is approximately 2.4 feet. Enhancement Area E1
includes the installation of 2 step -pools to lessen the existing 2.4 -foot drop on the
existing step. Please reference the Preservation and Enhancement Plan
(Attachment D) for additional details.
Corps Comment #7g — "In conjunction with question 5 above, will a storm water features
impact the natural drainage and therefore the normal channel flows to streams that are
part of the proposed preservation areas? If yes, how would the storm water features be
designed to prevent any reduced function to the proposed preservation areas ?"
Residential areas will not exceed 24% impervious surface area, and therefore, will
not require stormwater management beyond vegetated conveyances. A
Stormwater Management Plan for the Equestrian Center was approved on April
10, 2015 (Attachment C). Stormwater features do not impact stream channels on
site, and stormwater from the Equestrian Center is in a different watershed than
the preservation reaches.

Mr. Steve Kichefski
11.18.15
Page 7 of 7
Corps Comment #7h — "Provide further detail of the type and abundance of invasive
species in the proposed preservation area. Is there a presence of the same invasive
species in the adjacent forested area that would decrease the likelihood of long term
success keeping them out of the buffer area ?"
Generally, the preservation reaches do not contain exotic invasive species;
therefore, preservation reaches would not be treated. Exotic invasive species
removal would be reserved for the enhancement reaches which comprise
approximately 7% of the total mitigation area. Please reference the Preservation
and Enhancement Plan (Attachment D) for additional details.
The applicant believes the information submitted in this package addresses all issues set
forth by the Corps in their letter dated October 2, 2015. Should you have any questions
or comments concerning this project please do not hesitate to contact me at 828 -698-
9800.
Sincerely, _
Rebekah L. Newton R. Clement Riddle, P.W.S.
Senior Project Manager Principal
Cc: NC Division -of Watgr Resources - Jennifer B_��u�Cr etteT
NOV 2 3 2015 1`
D- MR . WATER R� OURCE
ESOURCES
401 & BUFFER PERMITTING

Tryon International Equestrian Center ( +/- 1,276 AC
Impact RC2 - 185LF (2 crossings)
_lmmpect_ 1)02_ 30LF (1-1
J
Previously Penrited Culvert
4OLF
Action I D 2006-32154 -375
Previously Pe iced CuNen -
4oLF '4...
Action ID 2008- 32154375 '
Non -Wedic lonal Pond
O
Inpad RC -GOLF arW 0.02AC
Ingest UCS - 3OLF (bmp)
PROJECT DATA
TOTAL PROJECT AREA
+/- 1,276 ac
JURISDICTIONAL WATERS OF THE US
Streams
66,132 If
Wetlands
s r
`
404 ac
JURISDICTIONAL IMPACTS
Streams
Proposed Permanent Impacts
\'
-
WWI\
Previously Permitted Impacts
405 If
GRAND TOTAL
1,463 If
Wetlands
Impact RC2 - 185LF (2 crossings)
_lmmpect_ 1)02_ 30LF (1-1
J
Previously Penrited Culvert
4OLF
Action I D 2006-32154 -375
Previously Pe iced CuNen -
4oLF '4...
Action ID 2008- 32154375 '
Non -Wedic lonal Pond
O
Inpad RC -GOLF arW 0.02AC
Ingest UCS - 3OLF (bmp)
PROJECT DATA
TOTAL PROJECT AREA
+/- 1,276 ac
JURISDICTIONAL WATERS OF THE US
Streams
66,132 If
Wetlands
21.40 ac
Open Water
404 ac
JURISDICTIONAL IMPACTS
Streams
Proposed Permanent Impacts
9081f
Proposed Temporary Impacts
150 If
Previously Permitted Impacts
405 If
GRAND TOTAL
1,463 If
Wetlands
Proposed Permanent Impacts
0.02 ac
Open Water
0 ac
A VOIDANCE /MINIMIZATION
Streams
64,669 If
Wetlands
21.38 ac
Open Water
n/a
MITIGATION
Streams
Mitigation Credits Required
2,046 If
Proposed Preservation
6,697 If
Proposed Enhancement
1,274 If
Proposed Preservation of Upland Buffer
17.6 ac
Previously Mitigated
2901f
DM S
1,023 If
Previously Pen itted Culvert 1 -
35LF - Impact R(A - 02LF -
- Acton ID 2006 -32154 -375 Impact L)C4 - 31XF (lamp) 1
, W w
NOV 2 3 2015.
_ O00 DENR 'WATER Ra.
L Legend °o 401 b �WFFER PERMIJ -'i;r N
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Steens Plated Lots 1 ""
f
Linear Weiland Enhancement Arses
lotVssttend Preservation Areas
C_ °Pen Water Property eerardary
0 1,000 2,000 4,000
Drawn by: RLN 10.27.15; CEC Project# 747 Feet
Polk County, CLearWal:er 11, Updated Impact Ma
P P P
North Carolina 32 Clayton Street Figure 1
Asheville, North Carolina 28801

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Attachment A
Corps Comments
(dated August 28, 2015)

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS C(DD
151 PATTON AVENUE ROOM 208
Lr
ASAEVILLE, NORTH CAROLINA 28801 -5006
October 2, 2015
Regulatory Division
Action ID: SAW- 2013 -02262
Mr. Jeff Brown
Tryon Equestrian Partners, LLC
2659 Sandy Plains Road
Tryon, North Carolina 28782
Dear Mr. Brown:
Reference is made to your application of June 24, 2015, for Department of the Army (DA)
permit authorization to impact 1,463 linear feet (if) of unnamed tributaries (UT) of White Oak
Creek and 0.02 acres (ac) of jurisdictional wetlands, associated with the proposed development
of 1,276 acres for a resort, equestrian center, and residential community known as the Tryon
International Equestrian Center (TIEC) southeast of the intersection of Pea Ridge Road and U.S.
Highway 74, northeast of Tryon in Polk County, North Carolina.
After review of your proposal, the United States Fish and Wildlife Services (USFWS)
submitted comments dated August 4, 2015. They determined that the project "may affect, not
likely to adversely affect" based upon the information submitted, including the commitment to
avoid forest clearing during the Northern Long -eared Bat (Myotis septentrionalis) May 15 —
August 15 maternity roosting period. They offered several recommendations should the permit
be issued and a copy of their letter is enclosed for your consideration.
Written comments were also received from the North Carolina Wildlife Resources
Commission (WRC) on August 7, 2015. The WRC commented, "The project should not impact
trout and activities do not need to be avoided during the trout spawning moratorium." They
offered several recommendations regarding the proposed impacts and mitigation should the
permit be issued. A copy of this correspondence is enclosed for your consideration and response.
By letter dated August 4, 2015, the United States Environmental Protection Agency
( USEPA) provided comments from their project evaluation. Specifically the USEPA discusses
the avoidance, minimization, alternatives analysis and mitigation of the applicant's proposed
plan. A copy of this correspondence is enclosed for your consideration and response.
Written comments on the project were received on August 7, 2015, from the State Historic
Preservation Office (SHPO). They have determined that the project as proposed will not have an
effect on any historic structures. The SHPO noted one previously recorded site within the project
that was evaluated as ineligible for listing in the National Register of Historic Places. They felt

- 2 -
that there was a high probability for the presence of prehistoric or historic archaeological sites
and recommended a comprehensive survey be conducted to evaluate potential effects on
unknown resources prior to the initiation of construction activities. A copy of this
correspondence is enclosed for your consideration and response.
We received a comment letter, via email on July 17, 2015, from Pat Larsen, an adjacent/area
property owner, in response to the PN advertising this project. In her comments, Ms. Larsen
expressed concern regarding the partial ownership of the Larsen Lane Right -Of -Way (ROW) and
how development plans would affect that ROW. She also stated a general concern about the
development and potential impacts to wildlife. A copy of this correspondence is enclosed for
your consideration and response.
We also received comments via email on August 4, 5 & 7, 2015, from Ms. Mary Hay, an
adjacent/area property owner. Ms. Hay raised concerns over plans to utilize Larsen Lane for the
development, traffic /road reconfiguration of John Shehan Road, public interest considerations,
and correctly identifying Columbus as the nearest town instead of Tryon. A copy of this
correspondence is enclosed for your consideration and response.
Written comments received on July 22, 2015, from the National Marine Fisheries Service
stating "the proposed project would not occur in the vicinity of essential fish habitat," therefore
they are "neither supportive of or in opposition to authorization of the proposed work ". While no
response is necessary, their correspondence is attached for your records.
The Corps has also reviewed your request for Department of the Army authorization and
request that you provide a response to the following items:
1. In order to effectively evaluate potential alternatives for this project additional
information regarding potential alternatives is needed. In prior meetings regarding the equestrian
center a much broader region than Polk County was evaluated by the applicant prior to site
selection. Provide more detailed information regarding the criteria used in property selection and
other areas that were considered to justify that no off -site alternatives would meet the least
environmentally damaging practicable alternative (LEDPA). For example licensing constraints,
acreage needed for the equestrian center component, acreage /units needed for residential
component, existing residential versus new build criteria, potential wetland/stream impacts, other
recreational possibilities associated with the residential component and other potential project
considerations /constraints associated with the equestrian center layout.
2. A portion of the proposed impacts are associated with further development of the
equestrian center (E] & E2). Elaborate as to why these impacts are needed, why they cannot be
further avoided or minimized and provide details (including plans) as to the impacts proposed.
How would the design of the proposed impact area direct the existing flow of the jurisdictional
stream and will any flow be reduced to downstream waters?

- 3 -
3. Provide detail as to the need for impact RC2/UC2 and why it cannot be fuuther
avoided/minimized (avoided, moved to only cross one stream channel or bridged). For example,
in this impact area there appear to be multiple other access points, the proposed crossing is not
utilizing an existing culvert in the immediate area, the proposed crossing is not utilizing the
proposed fill to the southwest where it would only cross one channel and it is proposed in a
location just before the confluence of two stream channels.
4. Road crossings 1 -5 do not appear to cross at perpendicular angles to the stream and
thereby are not providing further minimization of impacts. Provide detail as to why they cannot
be designed to cross at a more perpendicular angle. Also, these road crossings vary from 2.42-
8% in slope and 57.75 -110 linear feet in length. While the plans appropriately mention pipe
burial of either 20% or 1 foot in depth (depending on the pipe diameter) there is concern over
scour to both the pipe's substrate and the downstream channel based on the slope and lengths.
Provide further information as to the existing stream slopes for these streams and why additional
channel scour or head cutting will not occur as currently proposed. Would other measures (sills,
baffles, grade control or dissipater pads) be needed to help ensure retention of the buried pipe
substrate or prevent head cutting/scour either up or downstream of the channel.
5. Will any of the newly proposed development areas on the property require storm water
treatment? if yes, will the storm water treatment impact any additional jurisdictional features on
the property or significantly reduce normal stream flow due to the relocation of catchment
drainage?
6. The application package notes that the proposed utility lines will be "trenched in and
upon completion, the stream beds, and banks will be returned to their pre - impact condition."
Will any hard armoring be involved in the utility crossings and will the original channel substrate
be returned to the impact area post channel restoration?
7. Preservation to 7,979 linear feet of stream channel onsite has been proposed to help
compensate for the proposed project impacts. Provide further clarification to the following
aspects of that proposal for further consideration:
a. Make sure all components of a mitigation plan are provided as required by 33 CFR
332.4 (c) such as a long term management plan, an adaptive management plan, financial
assurances, etc.
b. As stated under 33 CFR332.7, "To provide sufficient site protection, a conservation
easement or restrictive covenant should, where practicable, establish in an appropriate third party
the right to enforce site protections and provide the third party the resources necessary to monitor
and enforce these site protections." For this reason the Wilmington District prefers the use of a
conservation easement as the site protection instrument. As part of the mitigation plan for this
project clarify how the site protections will be enforced over the long term and the financial
assurances that will guarantee this long term protection.

- 4 -
c. In our evaluation of compensatory mitigation options, we will consider what would
be environmentally preferable. Are enough of the appropriate credits available to provide
compensatory mitigation through a mitigation bank or in -lieu fee program? Provide further
information as to why the permittee - responsible mitigation proposed would be environmentally
preferable to credit provided by a mitigation bank or in -lieu fee program.
d. Several areas of the preservation proposed seem to have limited buffer widths due to
adjacent roads. Provide information or a figure depicting the range and average buffer widths
that will be preserved within the proposed restrictive covenant. Will any proposed buffer areas
be less than 15 feet in width on one side of the channel? Are there any existing/proposed utility
lines /easements or culverts within the proposed preservation stream or buffer areas?
c. The proposed impacts shown on Figure 4 of the application package depict several
potential residential areas without lot lines, including around the proposed preservation area.
Provide clarification as to how these areas will be developed from the perspective of whether any
future impacts might occur and how the development of these areas might degrade the function
of the proposed preservation area.
f. The proposed preservation area has an existing perched road crossing. Are
improvements planned for this crossing as part of the proposed development or for the perched
culvert as part of the mitigation proposal?
g. In conjunction with question 5 above, will any storm water features impact the natural
drainage and therefore the normal channel flows to streams that are part of the proposed
preservation areas? If yes, how would the storm water features be designed to prevent any
reduced function to the proposed preservation areas?
h. Provide further detail of the type and general abundance of invasive species in the
proposed preservation area. Is there a presence of the same invasive species in the adjacent
forested area that would decrease the likelihood of long term success keeping them out of the
buffer area?
Your response to the comments identified above must be given full consideration before we
Pan make a final decision on your application. We need your information to address the
concerns /issues raised over the proposed project. You may submit additional information, revise
your plans to help resolve the issues, rebut the issues made or request a decision based on the
existing record.
We request that you provide responses to all comments in this letter by November 2, 2015. If
you fail to respond by November 2, 2015, we will administratively withdraw your application.
We will reopen your application and continue to process it once you have submitted all of the
information we have requested in this letter. if you have questions or comments, please contact
me at my Asheville Regulatory Field Office address, telephone [phone] extension 234.

- 5 -
Sincerely,
Steve Kichefski
Project Manager
Asheville Regulatory Field Office
Enclosures
cc: w /enclosures
Mr. Clement Riddle
Clearwater Environmental Consultants, Inc.
32 Clayton Road
Asheville, North Carolina 28801
cc: w/o enclosures
Ms. Karen Higgins
North Carolina Division of Water Resources
Wetlands, Buffers, Stormwater, Compliance
and Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 -1617
Asheville Field Office
U.S. Fish and Wildlife Service
160 Zillicoa Street
Asheville, North Carolina 28801
Mr. Todd Bowers, Permit Review Specialist
Wetlands Regulatory Section
USEPA — Region 4
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303 -8960
Ms.-Shari Bryant, Piedmont Region Coordinator
North Carolina Wildlife Resource Commission
Habitat Conservation Program
Post Office Box 129
Sedalia, North Carolina 27342 -0129

Attachment B
Updated Alternatives Analysis

Alternatives Analysis
This discussion of alternatives is submitted by the applicant to assist the Wilmington District,
Corps in evaluating the application for authorization to discharge dredged or fill material into
waters of the United States, including wetlands, under Section 404 of the Clean Water Act, 33
U.S.C. § 1344 at the proposed project site.
An analysis of the Section 404(b)(1) Guidelines (Guidelines) requirements for consideration of
alternatives as required by 40 C.F.R. 230.10(a) is set forth below.
The Guidelines' alternatives requirements provide that "no discharge of dredged or fill material
shall be permitted if there is a practicable alternative to the proposed discharge which would
have less adverse impact on the aquatic ecosystem, so long as the alternative does not have other
significant adverse environmental consequences." [See 40 C.F.R. 230.10(a) (emphasis added).]
The record must contain "sufficient information to demonstrate that the proposed discharge
complies with the requirements of Section 230.10(a) of the Guidelines. The amount of
information needed to make such a determination and the level of scrutiny required by the
Guidelines is commensurate with the severity of the environmental impact (as determined by the
functions of the aquatic resource and the nature of the proposed activity) and the scope /cost of
the project." [See Corps/EPA Memorandum to the Field "Appropriate Level of Analysis
Required for Evaluating Compliance with Section 404(b)(1) Guidelines Alternatives
Requirements," p. 2, dated August 23, 1994, hereinafter the "Memorandum. "] As noted in the
Memorandum on pages 3 -4, the 404(b)(1) Guidelines "only prohibits discharges when a
practicable alternative exists which would have less adverse impact on the aquatic ecosystem."
[See Memorandum.] "If an alleged alternative is unreasonably expensive to the applicant, the
alternative is not practicable." [See Guidelines Preamble, "Economic Factors," 45 Federal
Register 85343 (December 24, 1980).]
Practicable alternatives for the project are those alternatives that are "available and capable of
being done after taking into consideration costs, existing technology, and logistics in light of
overall project purposes." [See 40 C.F.R. 230.10(a)(2).] Clarification is provided in the Preamble
to the Guidelines on how cost is to be considered in the determination of practicability. An
alternative site is considered "available" if it is presently owned by the applicant or "could
reasonably be obtained, utilized, expanded or managed in order to fulfill the basic purpose of the
proposed activity." 40 C.F.R. § 230. 1 0(a)(2).
The intent is to consider those alternatives, which are reasonable in terms of the overall scone
and cost of the proposed project. The term economic [for which the term "costs" was substituted
in the final rule] might be construed to include consideration of the applicant's financial
standing, or investment, or market share, a cumbersome inquiry which is not necessarily material
to the objectives of the Guidelines.
The Environmental Protection Agency (EPA) 404(b)(1) Guidelines state that, "we have chosen
instead to impose an explicit, but rebuttable presumption that alternatives to discharges in special
aquatic sites are less damaging to the aquatic ecosystem, and are environmentally preferable."
Of course, the general requirements that impacts to the aquatic system not be acceptable also

applies. This presumption "...contains sufficient flexibility to reflect circumstances of unusual
cases" (249 Fed. Reg., 85339, December 24, 1980). It is clear from these stipulations that a
preferable alternative may allow filling in certain wetland areas and subsequent mitigation and/or
management of other areas.
6.0 Avoidance
Tryon Equestrian Partners, LLC. was willing to considered sites other than the proposed project
site for development of the Tryon International- Equestrian Center (TIEC). A set of criteria was
developed to aid in the search for a site and ultimate selection of a site.
6.1 Site Criteria
6.1.1 Licensing (Criteria A)
The United States Equestrian Federation (USEF) requires competition licensing in the
United States. Location, dates, rating, level, and prize money are reviewed and approved
by the USEF Competitions Department for each competition. Subchapter 3 -13 of the
112015 United States Equestrian Federation, Inc. Rule Book" outlines licensing
requirements. The USEF seeks to provide for financially and otherwise viable
competitions to meet the needs of the sport within a geographic area. Additionally, the
USEF recognizes and acknowledges that mileage is an important factor for shows to keep
their standards high, thus enabling them to better meet the rules and requirements for a
given rating or level. General Rule 308 outlines mileage restrictions between
competitions depending on the level of competition. Separation generally ranges from
50 -250 miles with higher level shows requiring greater separation. The TIEC conducts
approximately 30 shows each year. To prevent competition conflicts, equestrian centers
where USEF competitions are occurring must maintain the required mileage separation
and each show must be licensed. Instead of obtaining new licenses, it is beneficial to
purchase or lease existing licenses from other facilities.
6.1.2 Access to Transportation Routes (Criteria B)
Horses are transported to equestrian centers via semi -truck and trailer. A trailer can reach
50 feet in length and require a large turning radius. Because of the size of the trailers
required to transport horses and large turning radii required for 90 degree or tighter turns,
equestrian centers are generally not sited in urban areas or rural areas requiring traveling
on narrow, winding roads.
Horses, riders, officials, and spectators are also transported via plane; therefore, the
chosen site should be located with relatively easy access to airports.
6.1.3 Residential Component (Criteria C)
Tryon Equestrian Partners, LLC wants an equestrian center to be the central amenity of
the- development; however, they do not want these areas to overshadow the rest of the
development or encompass the majority of the land mass at the chosen site. The ability
to provide residential housing allows for recuperation of the initial investment made for
the development of the equestrian center.

6.1.4 Community Infrastructure (Criteria D)
The property should be adequately served by community infrastructure. The ability to
tap into existing sources of utility (water and sewer) is important in determining the
feasibility and practicability of a project.
6.1.5 Weather (Criteria E)
The property should be in located in a temperate region with relatively stable weather
patterns. A mild climate allows for maximization of the show season which is generally
May — September but can be extended depending on the location of the facility.
6.1.6 Established Equine Community (Criteria F)
The property should be in a location with an established equine community and an
existing "horse" culture.
6.2 Alternatives
6.2.1 As- Proposed
The project site is located in Polk County and bisected by White Oak Creek. The site is
easily accessible and is in close proximity to major highways (1 -85, I -26, US Highway
221, etc.), airports, urban centers, and facilities that can provide fundamental goods and
services. The site is located adjacent to US Highway 74 (a divided highway) and is
centrally located to the Charlotte- Douglas International Airport (70 miles), the Asheville
Regional Airport (35 miles), the Greenville - Spartanburg International Airport (45 miles),
and the Rutherford County Airport (12 miles) (Criteria B).
The equine culture in Tryon started in 1917 when the Pine Crest Inn was opened by
Carter Brown. The Pine Crest Inn was a place where wealthy northerners could stay and
ride horses during the winter months. In 1925, Mr. Brown founded the Tryon Riding and
Hunt Club. Mr. Brown developed the Tryon Horse Show and the Block House
Steeplechase in 1929 and 1934, respectively. The Tryon Horse Show was so popular that
the schools were let out and most businesses closed for the afternoon. In 1956, the US
Equestrian Team prepared and trained for the 1956 Olympics in Tryon. The Tryon Horse
Show, held at the Foothills Equestrian Nature Center (FENCE), is the third oldest horse
show and a rated USEF event. Smaller shows are held at Harmon Field in Tryon. Many
local organizations such as the Carolina Carriage Club, the Blue Ridge Hunter Jumper
'Association, Foothills Riding Club, and River Valley Pony Club hold shows and events
in Tryon. Tryon is considered one of the "equi- centers" of the United States, with a
broad and deep history of equestrian culture and sport. Therefore, the proposed location
is the prime setting for the TIEC (Criteria F).
Tryon Equestrian Partners, LLC was able to purchase four existing show licenses from
the Tryon Riding and Hunt Club. The ability to purchase a group of licenses provided a
base of established shows for the TIEC to begin operation. The majority of the licenses
held by TIEC are for hunter /jumper shows (Criteria A). Shows that have established
licenses are known as "priority date holders" and any similar show has to abide by the
mileage restrictions, receive permission from the priority date holder to host the show, or
ask for an exemption from the mileage restrictions. Licenses can be leased or purchased,

and can be moved within their existing mileage. TIEC was able to purchase additional
existing licenses and establish new shows due to the location of the facility and lack of
existing priority date holders. TIEC was also able to move some licenses and receive
exemptions for other dates. TIEC was capable of establishing a full season of events due
to its unique location. This would not have been possible anywhere else in the eastern
United States.
Tryon Equestrian Partners, LLC purchased the defunct White Oak Plantation development
and obtained additional parcels to assemble a tract that is approximately 1,276 contiguous
acres. This acreage allows enough area for the equestrian and golf course amenities
while still providing adequate opportunity for residential housing (Criteria Q. Real
estate within White Oak Plantation was largely unsold; however, the site retained
development rights under the previous Polk County Subdivision Ordinance. In addition,
the site has approximately 3 miles of paved roads and underground utilities (water, sewer,
and electric). Having vested development rights at the site allows maximization of
residential lots which would be restricted by new Subdivision Ordinances. Real estate is
needed to offset the initial capital investment required to develop the equestrian center.
Community infrastructure is difficult to find in rural areas; however, the TIEC will be able
to connect to the local municipal water supply (Polk County) and municipal sewer system
(Town of Rutherfordton) that was installed throughout portions of the former White Oak
Plantation development in 2007 and 2008 (Criteria D). Peak water demand last summer
was 70,000 gallons per day. It would be difficult, if not impossible, to supply this
amount of water from groundwater wells and treat wastewater via on -site septic.
Tryon is located in a "thermal belt ". These areas are generally warmer in the winter and
cooler in the summer than surrounding areas. Additionally, western North Carolina is
generally free of tornados, hurricanes, blizzards, flooding, and other extreme weather that
could impact the show season (Criteria F). In accordance with USEF General Rule 832,
shows are not allowed to continue during. adverse weather conditions that could affect the
safety and welfare or a horse or rider. Because of location and weather, the TIEC is able
to provide an extended show season from April to November.
Master planning and permitting of large and long term development projects depends
highly upon having flexibility to implement sound land planning and engineering design
principles which are often conceptual at the time of permitting. These designs must
include enough land for the project to be economically justified, reasonable site access,
construction of utilities and stormwater systems, and appropriate locations of various land
use amenities.
It has been determined that other properties of similar size located in North Carolina
would likely contain comparable streams, wildlife, and cultural resources, presenting
similar engineering and land planning challenges and opportunities. The applicant has
expended significant resources to conduct intensive surveys and site assessments,
including land surveys, stream and wetland delineations, and threatened and endangered
species surveys. Intensive land planning and market analysis has also been conducted for

the development. The information gathered from these tasks has been considered in
preparation of the master plan submitted with this permit application. Market analysis
conducted by the applicant confirms the aptness of the project site for the intended
purpose. However, for the project to be economically viable, enough land must be made
available for amenities and residential development to cover development costs and
provide a reasonable profit. Since the land area is finite, development costs, particularly
construction costs, must be limited for the project to be successful.
6.2.2 Off -Site Options
There are few, if any, single tracts of land in Polk County large enough to accommodate a
development such as the TIEC. For this reason, Tryon Equestrian Partners, LLC was not
able to find a single tract of land in Polk County that met the project needs. Additionally,
development of large portions of the site was started or completed as a part of the original
White Oak Plantation project by a different developer. This provided for a unique
opportunity to purchase a large portion of partially developed land for a discounted price.
The chosen site is compiled of many individual parcels. This compilation of parcels has
taken approximately two years to complete. Due to the lack of large parcels in Polk
County and the amount of time and effort it has taken to compile such a large number of
parcels, all energies had to be focused on assembling a tract large enough to sustain a
development of substantial size. For this reason, Tryon Equestrian Partners, LLC
considered no other group of parcels for this development.
6.2.3 No Action
The proposed project would not be able to be completed without impacts to jurisdictional
streams and wetlands.
The Corps requires that a No- Action Alternative be analyzed which takes into account
the "predictable actions," if any, that may occur should the Corps decide not to act. If the
Corps chose not to act, a Section 404 permit would not be authorized for the site. For the
project to continue, the footprint of the buildings and grading would need to be decreased
so that the existing buildings and topography could accommodate site infrastructure.
Additional development of the equestrian facilities would likely be eliminated from the
project design due to limited space. Existing roads on site would need to be used as
primary assess; and existing utilities would need to service the site. Currently, existing
roads and utilities are not comprehensive enough to service the entire development. Lot
owners would be left without road access or utility services; and the equestrian facilities
would not be constructed to the fullest potential. The project purpose and need would not
be met.
6.3 Avoidance and Minimization
In preparing the master plan, Tryon Equestrian Partners, LLC considered a variety of
constraints, including impacts to streams and wetlands. The applicant has avoided and
minimized impacts to streams and wetlands to the greatest extent practicable and feasible
while still accomplishing the overall project purpose. It has been determined that most
large properties in western North Carolina contain similar streams, springs, and seeps as
those found on the project site.

During design of the equestrian facilities, the applicant considered several site layouts,
which included impacts to significantly more streams than the proposed plan depicts.
Prior to the submittal of this application, the applicant conducted meetings with
regulatory agency personal. Plan changes and reduction of impacts were in response to
consultant and agency comments. Two additional equestrian center plans were
considered (Figures 5 and 6 in the permit application). The plan developed in June of
2013 and represented in Figure 5 of the permit application includes the same basic
equestrian components; however, proposed impacts were 9,249 linear feet of stream and
0.33 acres of wetlands. A second site plan was completed for this area in July of 2013
and is represented in Figure 6 of the permit application. This plan also includes the same
basic equestrian components; however, impacts were reduced. Impacts associated with
the plan in Figure 6 of the permit application include 4,022 linear feet of stream and 0.06
acres of wetland. The proposed site plan for the equestrian facilities in this application
includes 736 linear feet of stream impact (including previous impacts) and no wetland
impacts. Avoidance and minimization at the equestrian facility, including the
" farmettes," reduced impacts by a total of 8,513 linear feet of stream (a decrease of 92 %)
and 0.33 acres of wetland (a decrease of 100 %).
Impact El of the current site plan is directly associated with the equestrian facility
infrastructure. These impacts are for a derby field, a 50 -foot grassed bridle path which
will connect the equestrian facility to the farmettes, parking, an access road, and the
development fill slope. Original plans for this area included significantly more impacts
(1,234 linear feet for Impact E1). A site plan from April of 2015, used at the pre -
application meeting, included one additional farmette lot in the location of the stream
channel and approximately 840 linear feet of additional stream impacts for E1. These
impacts were eliminated prior to permit application submittal and equate to a 68%
reduction in impacts for that location.
Although additional impacts will be needed, roads and utilities will utilize existing
infrastructure that was previously constructed as a part of the White Oak Plantation
project. Bridges will also be used for road and cart path crossings in some locations.
The golf course will be completed with no new impacts to jurisdictional waters.
Because the site is covered in long linear stream segments, it would be impossible to
avoid all streams while continuing to maintain a rational project design and the flexibility
needed to construct a large -scale master planned community with a lengthy build out
period.

A summary of the avoidance and minimization that has taken place on site is as follows:
Feature On -Site Totals Proposed Impacts percent Avoided and
Minimized
Stream
66,132
1,463
97.7
Wetland
21.40
0.02
99.9
—Open Water
4.04
0
100
While the project will impact streams and wetlands, the overall impact to stream
resources on site for the project is minimal (impacts to 34% of streams on site) and is
offset by adequate mitigation. The result is the permanent preservation of approximately
6,697 linear feet of streams, enhancement of 1,274 linear feet of stream, and
approximately 17.6 acres of upland buffers on -site. These preserved streams will be
subject to restrictive covenants to ensure permanent preservation. Because these streams
perform valuable water quality functions, the preservation of these important areas will
contribute in perpetuity to wetlands, stream, fish and wildlife protection, and improved
water quality.
6.4 Alternatives Conclusion
This discussion of avoidance and minimization, together with the documents submitted
by the applicant in support of the 404 Permit, show that the project is in compliance with
the Guidelines. As this analysis clearly demonstrates, the proposed expansion is designed
to avoid and minimize impacts to the site to the maximum extent practicable while
maintaining a rational project design.

Attachment C
SMP Approval
(dated April 10, 2015)

-.�...
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 10, 2015
Mr. Jeff Brown
2659 Sandy Plains Road
Tryon, North, Carolina 28782
Mr. Roger Smith, Registered Agent
Tryon Equestrian Partners, LLC
360 Ken Miller Road
Rutherfordton, North Carolina 28139
Subject: STORMWATER MANAGEMENT PLAN
TRYON EQUESTRIAN CENTER
Dear Messrs. Brown and Smith:
Donald R. van der Vaart
Secretary
DWR Project # 13 -1200
Polk County
On February 17, 2014, the Division of Water Resources (DWR) issued a 401 Water Quality
Certification to impact 0.49 acre of wetland and 150 linear feet of stream or waters in order to
construct the proposed development in Polk County. In order to meet Condition 6 of the 401
Certification for this project, a stormwater management plan was submitted to the DWR on
October 1, 2014. Because you propose to use a proprietary stormwater management system
known as the "Isolator Row," the DWR has delegated the review of the stormwater management
plan to the NC Division of Energy, Mineral and Land Resources (DEMLR), the agency that handles
reviews of these types of devices.
The first stormwater management plan submittal was received by DEMLR on October 1, 2014. The
deficiencies in that stormwater management plan were communicated to your consultant, Mr.
David Odom, PE, of Odom Engineering, PLLC, on October 20, 2014. On October 27, 2014, DEMLR
received a revised stormwater management plan. DEMLR has determined that the revised
stormwater management plan remains incomplete. On February 1, 2015, DEMLR received a
revised stormwater management plan, dated January 5, 2015.
DEMLR has determined that the revised stormwater management plan meets Condition 6 of the
401 Certification for this project.
Division of Energy, Mineral, and Land Resources
Energy Section - Geological Survey Section - Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699 - 1612.919- 707 -9200 I FAX: 919 - 715 -8801
512 North Salisbury Street, Raleigh, North Carolina 27604 - Internet: http: / /portal.ncdenr.org /webAr/
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

Mr. Jeff Brown
April 10, 2015
Page 2 of 3
Conditions of Approval:
1. The SMP approved by DEMLR consists of the following:
Drainage
area
Type of practice
Impervious surface
draining to practice
(square ft)
Total drainage area
of practice
(square feet)
2 & 3B
Isolator Row
338,897
977,922
3A
Isolator Row
83,200
554.954
4
Isolator Row
138,521
368,953
6
Isolator Row
202,118
642,074
7
Wet Pond /Level Spreader
157,167
8
Isolator Row
467,399
1,335,114
The stormwater control measures listed above and all associated stormwater conveyances,
inlet and outlet structures, and the grading and drainage patterns depicted on plan sheets
dated October 16, 2014. The plans and specifications approved by DEMLR are
incorporated by reference into this approval and are enforceable by DEMLR and DWR
provided however that any modification of the design for the stormwater management
system that is accepted by DEMLR or DWR shall take precedence over the original plans
and specifications.
2. The maximum allowable drainage and the maximum impervious areas for the stormwater
control measures shall be per the table above. Any changes to these maximum areas shall
require the applicant to submit and receive approval for a revised stormwater
management plan by DEMLR or DWR.
3. The footprint of all stormwater management devices as well as an additional 10 -foot wide
area on all sides of the devices shall be located in public rights -of -way, dedicated common
areas or recorded easement areas. The final plats for the project showing all such rights -
of -way, common areas and easement areas shall be in accordance with the approved
plans.
4. Maintenance activities for the wet pond shall be performed in accordance with the
notarized 0 &M agreements signed by Mr. Jeff Brown on January 5, 2015. Maintenance
activities for the Isolator Row shall be performed in accordance with the notarized O &M
agreements signed by Mr. Jeff Brown on October 15, 2014. The O &M agreements shall
transfer with the sale of the land or transfer of ownership /responsibility for the BMP
facility. DWR shall be notified promptly of every transfer.
5. The applicant and /or authorized agent shall provide a completed Certificate of Completion
form to the DWR within thirty (30) days of project completion (available at
http: / /portal.ncdenr.org /web /wq /swp /ws /401 /certs and permits /apply /forms).

Mr. Jeff Brown
April 10, 2015
Page 3 of 3
Thank you for your attention to this matter. If you have any questions or wish to discuss these
matters further, please do not hesitate to contact me at (919) 807 -6381.
Sincerely,
Annette M. Lucas, PE
Environmental Engineer
AMLIoml
cc: USACE Asheville Regulatory Field Office
Mr. David Odom, PE, Odom Engineering, PLCC (via email)
Mr. Kelly Hefner, PE, Advanced Drainage Systems, Inc. (via email)
Dr. Bill Hunt, PE, PhD, NCSU -BAE (via email)
Mr. Andrew Anderson, El, NCSU -BAE (via email)
Mr. Ken Pickle, PE, DEMLR (via email)
Mr. Boyd DeVane (via email)
401 & Buffer Permitting Unit file, DWR
ARO 401 file (via email)
Filename: 232200rryonHorseFarm(Polk)_ Approve SW.docx

Attachment D
Preservation and Enhancement Plan

Preservation and Enhancement Plan
Objectives: The applicant proposes to preserve approximately 6,697 linear feet and enhance
approximately 1,274 linear feet of unnamed tributaries to White Oak Creek within the Tryon
International Equestrian Center (TIEC) residential development in Polk County, North Carolina
(Figure 1). Preservation and enhancement in conjunction with payment into the Division of
Mitigation Services in -lieu fee program will offset environmental losses resulting from
unavoidable impacts associated with the proposed project.
Site Selection: The applicant has chosen on -site, in -kind mitigation in the form of preservation
and enhancement to fulfill a portion of the mitigation requirements associated with the proposed
project. The proposed site is a part of the TIEC residential development and proposed stream
buffers would likely be developed for second homes if the land is not preserved. Preserving and
enhancing streams now is more beneficial than funding restoration at a later date. The watershed
of the proposed reaches is approximately 165 acres and all but approximately 600 linear feet of
the streams in the watershed will be preserved and/or enhanced.
Preservation and enhancement reaches will include 60 -foot upland riparian buffers where
possible for a total of 17.6 acres of upland riparian buffers. Approximately 94% of the
preservation and enhancement reaches will have 60 -foot buffers. Riparian areas typically
comprise a small percentage of the landscape, often less than 1 percent, yet they frequently
harbor a disproportionately high number of wildlife species and perform a disparate number of
ecological functions compared to most upland habitats. These strips of vegetation can provide
habitat for a wide variety of plants and animals, provide a visual and noise buffer that reduces the
disturbance of human developments on breeding and nesting birds, and provide corridors for
movement from one habitat area to another. Vegetation adjacent to streams also provides shading
that moderates stream temperatures, and provides input of woody debris and other organic
material important to aquatic organisms. Downed woody vegetation in the riparian area also
provides microhabitats for reptiles, amphibians, and small mammals, and provides substrates for
insects. Snags within riparian areas provide cavities for a variety of birds and mammals.
Encroachment into the riparian area during developments can negatively affect any or all of these
important functions.
Site Protection Instrument: Restrictive covenants would be used to protect the preservation and
enhancement reaches. Model language provided by the Corps will be followed (Attachment A).
Covenants are intended to ensure continuing compliance with mitigation conditions in the issued
404 permit authorization. As such, restrictive covenants may be enforced by the Corps. The site
will be owned by Tryon Equestrian Partners, LLC for the duration of implementation of the
preservation and enhancement plan.
All site protection instruments require 60 -day advance notification to the Corps and the State
prior to any action to void, amend, or modify the document. No such action shall take place
unless approved by the Corps and State.

Baseline Information: Clearwater Environmental Consultants, Inc. (CEC) reviewed the
preservation and enhancement reaches on October 21, 2015. Existing conditions of proposed
preservation and enhancement reaches are discussed below:
Preservation Areas PI and P2 — Preservation areas PI and P2 have very similar characteristics.
The stream channels are first order and good quality. Stream channel widths range from 3 -4 feet
and bank heights range from 1 -2 feet. Existing riparian areas are wide and contiguous with
significant canopy coverage over the stream. -No exotic invasive species were observed along
these reaches. Stream forms and representative photographs for streams located in P 1 and P2 are
included for review (Attachment B and Attachment Q.
Preservation Area P3 — The stream channel located in P3 is second order and good quality.
Stream channel width is approximately 6 feet and bank height is approximately 1.5 feet.
Existing riparian areas are wide and 'contiguous with significant canopy coverage over the
stream. No exotic invasive species were observed along the upstream 2/3`d of the reach. The
downstream UP of the reach contains some Lespedeza sp. but at a density of less than 20 %.
Stream forms and representative photographs for the stream located in P3 are included for review
(Attachment B and Attachment Q.
Preservation Area P4 - The stream channel located in P4 is second order and good quality.
Stream channel width is approximately 6 feet and bank height is approximately 3 feet. Existing
riparian areas are mostly wide and contiguous with significant canopy coverage over the stream.
Approximately 398 linear feet of the left bank would have a less than 60 -foot buffer. Exotic
invasive species are limited in this section with only isolated individuals of privet observed.
Representative photographs for the stream located in P3 are included for review (Attachment Q.
Preservation Area P5 - The stream channel located in P5 is second order and good quality.
Stream channel width is approximately 6 feet and bank height is approximately 1.5 feet.
Existing riparian areas are wide and contiguous with significant canopy coverage over the
stream. No exotic invasive species were observed along these reaches. One side tributary along
P5 has large amounts of surface debris and household trash. Stream forms and representative
photographs for the stream located in P5 are included for review (Attachment B and Attachment
C).
Enhancement Area E1 — Area E1 is immediately downstream of the existing culvert crossing that
was installed by previous owners. The crossing is comprised of a box culvert with a rock step -
pool. The drop on the existing step is approximately 2.4 feet. A well- defined pool with a depth
of approximately 1.7 feet is below the step. Some kudzu is located in this section. Photographs
of the step -pool are included for review (Attachment C).
Enhancement Area E2 — Area E2 is in the location of remnants of an old house and/or barn, and
includes two stream segments. Stream channel widths are approximately 6 feet and bank height
ranges from 1.5 -3 feet. The stream channels are good quality; however, the understory of the
riparian areas is dominated by exotic invasive species. Wisteria and privet provide 50 -80%
cover in the understory. Approximately 247 linear feet of left bank of the main stem and
approximately 244 linear feet of the right bank of the side tributary would have a less than 60-
2

foot buffer. Stream forms and representative photographs for the stream located in E2 are
included for review (Attachment B and Attachment C).
Determination of Credits: The applicant proposes to preserve 6,697 linear feet of stream at a
10:1 -20:1 preservation ratio and enhance 1,274 linear feet of stream at a 2.5:1 -5:1 ratio yielding
1,061 linear feet of total mitigation credits. The table below summarizes the mitigation credit
calculation:
Stream
Segment
Type of
Mitigation
Linear
Feet
Buffer
Width (LF)
Mitigation Activity
Ratio (x:1)
Total
Credit
P1
Preservation
1,027
60
10
103
P2
Preservation
972
60
10
97
P3
Preservation
2,433
60
10
243
P4
Preservation
246
60
10
25
P4
Preservation
398
<60
20
20
P5
Preservation
1,621
60
10
162
E 1
Enhancement
46
60
2.5
18
E2
Enhancement
737
60
2.5
295
E2
Enhancement
491
<60
5 :::F
98
Total
1 7,971
1
1,061
Preservation and enhancement credits will off -set unavoidable stream impacts by providing the
following services:
1. Aquatic Habitat — Riparian vegetation occurs at the edge of streams, and therefore, is a
source of food and structural habitat for aquatic organisms. Preservation of riparian areas
ensures stream productivity remains intact, and provides diversity to streambed habitats.
2. Bank Stability and Erosion Protection — Vegetation and woody buffers stabilize stream
banks and reduce the likelihood of stream erosion. Reduction of erosion helps maintain
stream depth and width. Vegetated riparian buffers reduce upland erosion and ensure that
soil located in the riparian area does not become a source of sediment in streams.
3. Alteration of Stream Climate — Vegetated buffers help to reduce stream temperatures and
maintain high levels of dissolved oxygen.
4. Wildlife Habitat — Riparian areas are important habitat for a number of wildlife species,
and also provide travel corridors for terrestrial wildlife.
Mitigation Work Plan and Maintenance Plan: The preservation and enhancement reaches will be
preserved with restrictive covenants prior to or concurrent with impacts associated with Phase l
of the project.
The proposed preservation reaches will be preserved as -is with no modification to riparian
upland buffers or the stream channels. Photo stations documenting the condition of preservation
reaches will be established and monitoring photographs will be taken each year for 5 years.
3

One side tributary along P5 has large amounts of surface debris and household trash (Figure 1).
Surface debris will be removed by hand to the extent that the stream bed is not disturbed (i.e.
there will be no digging in the stream channel).
Enhancement Area E1 includes the installation of 2 step -pools (Figure 2) to lessen the existing
2.4 -foot drop on the existing step. Each step, including the existing step, would have a drop no
greater than 0.8 foot. Kudzu will also be chemically treated in this area.
Enhancement Area E2 will be mechanically and chemically treated for exotic and invasive
species in the spring of year 1. The same reaches will be treated chemically during years 2, 3,
and 5. Any stream banks disturbed during mechanical removal will be graded to original
contours and matted. Any bare soil area comprising 10% or more of the treated area will be
replanted with native woody species. Herbicide application will be performed in accordance
with NC Department of Agriculture (NCDA) rules and regulations. Photo stations documenting
the condition of enhancement reaches will be established and monitoring photographs will be
taken each year for 5 years. Vegetation plots documenting the condition of the upland riparian
areas will be established and monitored each year for 5 years.
Performance Standards:
Preservation:
1. Less than 20% exotic invasive species at year 5, based on measurements of aerial extent.
2. No change to stream bed and bank stability (visual observation and photographs).
3. No encroachment on preservation reaches by property owners.
Enhancement:
1. Less than 20% exotic invasive species at year 5, based on measurements of aerial extent.
2. No change to stream bed and bank stability (visual observation and photographs).
3. No encroachment on enhancement reaches by property owners.
4. Density of 260 live, planted stems at year 5.
5. Four dominant native species at year 5.
Monitoring Requirements: Annual monitoring data will be reported to the Corps and State by
October of each year. Data will include:
1. Estimation and documentation of percentage of exotic and invasive species.
2. Visual observation and documentation of stream bed and bank stability
(photographs).
3. Evaluation of preservation boundaries and documentation regarding condition (i.e.
encroachment).
4. Documentation of planted tree density in enhancement areas.
Long -Term Management Plan: Upon close out by the Corps, the site will remain owned by
Tryon Equestrian Partners, LLC or transferred to a Home Owners Association if one has been
established. The designated party will be responsible for periodic inspection of the site to ensure
that restrictions required in the restrictive covenant document(s) are upheld. Endowment funds
4

required to uphold restrictive covenants would be negotiated prior to site transfer to the
responsible party.
Adaptive Management Plan: Project maintenance will be performed as described above. If,
during the course of annual monitoring it is determined the site's ability to achieve site
performance standards are jeopardized, the applicant will notify the Corps of the need to develop
a Corrective Action Plan. Once the Corrective Action Plan is prepared and finalized the
applicant will:
1. Notify the Corps.
2. Revise performance standards, maintenance requirements, and monitoring
requirements as necessary and/or required by the Corps.
3. Obtain other permits as necessary.
4. Implement the Corrective Action Plan.
5. Provide the Corps with documentation of corrective action. This report would depict
the extent and nature of the work performed.
Financial Assurances: The applicant is requesting that the financial assurances be waived
because the project is comprised primarily of preservation. Permit compliance would be linked
to success of the proposed Preservation and Enhancement Plan; therefore, the applicant has
strong incentive for the project to be successful or risk violating permit conditions.

Tryon International Equestrian Center - Preservation and Enhancement
- �__ ' 't � ,• - ' � l i r' �1,I l� I �Ir � . ' I l r _if � �- I I f r' , _ �r' I l rI (l �_ I + `' I 'r , � ,!I 1rr+_ ' � Ir I'' l r ` \! r rI l� ? ,I r1� _ �� ` j `,I � l r r' I� ' i 1 II� , r fI J t IP ' :l r� l r -� ;I 1 fi:r;1 i! J :'i' 'r _ !'r1r/ 1J - I, , ri'r'� y ( .'I ' ' (_ r'� I )I% -r , 1 - r : + 1 ' y , r /r +r7 �(I � JI I i+r'' 1rI -t+ = I ,r -!1r r'(I/ } /.�•_ = 'l1'+ ' / ' 7r�' ',j . = _ , r f•1' rf ' " y . rr �r,!- :',i' : l 1' �i f,r+, ✓ r1!;i �� � ; Jrr .rriy! r r/ % _ , '` / � r 1lF '` '-.11 �� f� � ir / ,, 1 I� ' :;1ri�, " ,! ` rl, ;r _ ° � ; '�r r- I i i 1rt , , � - " r % '+_ +, ; I�r� r , r / !i+ ' _ I I �%' � - y !I ix' • , ! rJ f _ + I J �/ I r r I i ,I ,, - � 1 � ,�i - r - _ -,� i� -j � - I' .- -- r'% � � r 1' , , •, + ; � — '' rr - ' —i J I1 I 7' � � � �— - _ I+' I - Ii I � i 1 ' � i r4r ' — fff fr - I I . - 1 I � J I j f ,r` � � rf- _ -_ — i lr ( fJ y _ '� _ `-f� - r _ J,1I i r! I r rr / -�f 4� ) 7 ;' `l , � _ ! r ', fI tr /— � !ti / r I,r - ! iI}- ; ti_ - "�r " ' , � �1 �i+ - - + ' �r t / rrI l ' y ;-r - - I 11S I! 1/ ; - I r r _; 1 I � t r;;,y1 1I J - _ � ! fJI iI J 'i ti_ rj1_ ;r�-�Iti�`I' 1I'�1�� j r, ! _' �.�r'I , I r_; 1', I f i' I ,'' 'i1r ' J I'� ,- � ti ' � � I , ' I '1 rI i ! ' ;I + r �-�� ' -i :I r ,�l. � I � � 'I �f R 4 � .I - � ' r1;' f , + I � - � rl I'j '1 ' 1 I� } .! r 1 �I y�r � � I r- - _'r � .,+' , 4� :" '' • i' �' . ,r' ' % :; ? — �I , :J •_l _ i � i - 51., i: _ !r '1— r.i �i/ —� '�J I y '�' '; �ll' r %' I I 1 � J 1-J- - ! +_1+� ~ _ ;fI -I- ''? ;I�' i,I1I IJS ' ,� _ I I _f' ' ,� _ - +; _ .l�/rI� '- I I Il � � �, , ,I% r ` '� � . -;I ., ' _ ! _ - r /.l I I . i r,/! !`_ % r I % _, II _ � ; , 1 _ J r , _ %i f � � � ' _ � ' >Ji� r� r +; iI � , �l�J � 1 -r � f . —' I ��j- � - ,✓ f r 1' `r - 'I '�, 1I r - 1/ I ' . - 'I J + , � `_ yr^ - / I ' i l� I r/ �� 'r ' � I � I'/ - I f I 1�l'I I � - I f I ri j I I. I \ , � I /7 i ; l � -, I ` I " �! �'r ' I I _ � \� JI ; I 1 1 I +I I !- f � ' / r- '\ 1 r II � •l � + I I + _ .I - i• ' l� -, hy r ! � ly l r I / ( 1 4 y � I \ , - ? � �� ' � i ", I 1�= , l 1 � - J ? ; l ' ' '! `+ ` f 1 I � _' i
Legend
Ohl
Property Boundary Streams Enhancement Areas - � _,• , I 1_ — y ' _ _ - ' 1 I `` I 1 - � l I 'I �' ' '� 1 , y �I +1 I 1' I '1 '\ I\ ' , II! ` .�, I \ ` _ ' '5 _ y ' -\t ' , '' 1 i - 1 , r '' I I i } I � - ' , � ' = ,j 1� � , — ,I = `\ '-- ` , i,r _ - ' \ i ' , y5 ! ' - I ��� ,I _ �,1 r —\ , , ,'_ ' , •�, , ` � ' ` \ " as� ,I 'r ti ,I !} i1 r , ;
Linear Wetland as
Proposed Site Plan Preservation Are
Culvert Wetland
XX
E 1
4
P
X.
Debris
Rem al
A
0".
JQ
N
\%
J
I A"iI,\1
N
0 00
Feet
250 500 1,0
�e
Duirii [N '11}22A
EC Pr 7W-
Polk County, Preservation and
North Carolina Enhancement Map
32 Clayton Street Figure I
Asheville, North Carolina 28801

=1ii= iii =i i _
'ICULVERT
6 " -12 "-
FLOW
HEADER ROCK OR HARDWOOD
LOG 12" DIAMETER
FOOTER ROCK OR '
HARDWOOD LOG 12" DIAMETER
NOTE:
MINIMUM BOULDER SIZE 4'X3'X2'
Clearwater
Environmental Consultants, Inc.
718 OAKLAND $T
HENDERSONVILLE NC 28791
PNONE (828) 698 -9800
FAX. [phone]
1
`TYPE 2 NONWOVEN
FILTER FABRIC
OVERLAP ROCK
(FABRIC SHOULD
OVERLAP RX TO
ELIMINATE BYPASSING)
FIGURE 2
The Ramble Biltmore Forest Step Pool Detail
Town of Biltmore Forest
Buncombe County
North Carolina Not to Scale

Attachment A
Restrictive Covenant Guidance

RESTRICTIVE COVENANT GUIDANCE
August, 2003
Often, developers of residential or commercial subdivisions subject the property on
which the subdivision is built to restrictive covenants, that include provisions such as
setbacks, types of homes/buildings that can be built, etc. If the District has determined
that restrictive covenants are acceptable as a means of preserving mitigation property, the
following language can be added to those restrictive covenants:
"The areas shown on the recorded plat (identify the plat by title, date, and
recording data) as conservation areas shall be maintained in perpetuity in their
natural or mitigated condition. No person or entity shall perform any of the
following activities on such conservation area:
a. fill, grade, excavate or perform any other land disturbing activities
b. cut, mow, burn, remove, or harm any vegetation
c. construct or place any roads, trails, walkways, buildings, mobile
homes, signs, utility poles or towers, or any other permanent or temporary
structures
d. drain or otherwise disrupt or alter the hydrology or drainage ways of
the conservation area
e. dump or store soil, trash, or other waste
f. graze or water animals, or use for any agricultural or horticultural
purpose
This covenant is intended to ensure continued compliance with the mitigation
condition of a Clean Water Act authorization issued by the United States of
America, U.S. Army Corps of Engineers, Wilmington District, Action ID
, and therefore may be enforced by the United States of America. This covenant
is to run with the land, and shall be binding on the Owner, and all parties claiming
under it."
Usually, restrictive covenants have a provision that the property owners (either all of
them or some percentage of them) can amend or modify the restrictive covenants. If that
is the case, that provision needs to provide that our required paragraph (usually identified
by paragraph number) cannot be amended without the express written consent of the U.
S. Army Corps of Engineers, Wilmington District.
The permit condition should state that the permittee will record restrictive covenants,
acceptable to the Corps of Engineers, for the purpose of maintaining the mitigation areas
in their natural state in perpetuity, prior to the sale or conveyance of any lots or other
property within the subdivision. It is important that the restrictions be recorded prior to
the sale of any property within the subdivision (or phase, if it is being developed by
phase). If they are not, then any property sold prior to the recording of the restrictive
covenant are not subject to those covenants. Suggest the following:

" Permittee shall execute and cause to be recorded in the County
Register of Deeds restrictive covenants acceptable to the Corps of Engineers for
the purpose of maintaining the conservation areas, as shown on the recorded
plat* (identify by title, date, and recording data), in their natural state in
perpetuity, prior to the sale or conveyance of any lots or other property within the
subdivision. The permittee shall enforce the terms of the restrictive covenants
and, prior to conveyance of the property, shall take no action on the property
described in the covenants inconsistent with the terms thereof. The permittee
shall provide a copy of the recorded restrictive covenants to the Corps of
Engineers within 15 days of recording."
* It is possible and acceptable that the plat may not be recorded at the time of the
issuance of the permit. If that is the case, delete the word "recorded" and be sure you
have a copy of a plat showing the conservation areas in the file, and identify it in the
permit condition by title and date. The plat, however, must be recorded at the time the
restrictive covenants are recorded, and prior to the sale of any lots in the subdivision.
2

Attachment B
Stream Quality Assessment Worksheets

USAGE AID# DWQ ti Site # (indicate on attached map)
M �A
STREAM QUALITY ASSESSMENT WORKSHEET ,,*
Provide the following information for the stream reach under assessment:
I. Applicant's name: TIC—C- 2. Evaluator's name: 1? A3'to" . K- M liL he' I I
3. Date of evaluation: 10 -21-15
5. Name of stream: P1
7. Approximate drainage area: 55 A(,
9. Length of reach evaluated: loo f-*
11. Site coordinates (if known): prefer in decimal degrees.
4. Time of evaluation: A+4
6. River basin: &L06L
8. Stream order: 151'
10. County: �a11:
12. Subdivision name (if any): TI CL
11-alitu&(ex 34,872312): t&5 2 Longitude (ex. — 77.556611): —52-1022>1'26
Method location determined (circle): GPS opo Sheet Ortho (Aerial) Photo /GIS Other GIS Other
13. Location of reach under evaluation (note near y roads and landmarks and attach map identifying stream(s) location):
P\ on
14. Proposed channel work (if any): +n0ne-
15. Recent weather conditions: GUO� d v-.t
16. Site conditions at time of visit: C001 k d L/
17. Identify any special waterway classifications known: _Section 10 _Tidal Waters _Essential Fisheries Habitat
_Trout Waters _Outstanding Resource Waters _ Nutrient Sensitive Waters _Water Supply Watershed _(]-IV)
18. Is there a pond or lake located upstream of the evaluation point? YES 0 if yes, estimate the water surface area:
19. Does channel appear on USGS quad map? YES NO 20. Does channel appear on USDA Soil Survey? YES NO
21. Estimated watershed land use: _% Residential % Commercial _% Industrial _5_0/o Agricultural
06 % Forested _% Cleared / Logged _% Other ( )
22. Bankfull width: 3 P(- 23. Bank height (from bed to top of bank): 1 �fi
24. Channel slope down center of stream: Y Flat (0 to 2 %) _Gentle (2 to 4 %) _Moderate (4 to 10 %) _Steep (>I 0%)
25. Channel sinuosity: Straight Occasional bends _Frequent meander _Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most appropriate ecoregion based on
location, terrain, vegetation, stream classification, etc. Every characteristic must be scored using the same ecoregion. Assign points
to each characteristic within the range shown for the ecoregion. Page 3 provides a brief description of how to review the
characteristics identified in the worksheet. Scores should reflect an overall assessment of the stream reach under evaluation. If a
characteristic cannot be evaluated due to site or weather conditions, enter 0 in the scoring box and provide an explanation in the
comment section. Where there are obvious changes in the character of a stream under review (e.g., the stream flows from a pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a separate form used to evaluate each
reach. The total score assigned to a stream reach must range between 0 and 100, with a score of 100 representing a stream of the
highest quality.
Total Score (from reverse):
Comments:.
Evaluator's Signature Gs.x Jtxl�.. Date --J n - ZI - B
This channel evaluation form is intended to be used only as a guide to assist landowners and environmental professionals in
gathering the data required by the United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not imply a
particular mitigation ratio or requirement. Form subject to change - version 06/03. To Comment, please call 919 -876 -8441 x 26.

STREAM QUALITY ASSESSMENT WORKSHEET
These characteristics are not assessed in coastal streams. 5`1

USACE AID;t DWQ # Site # (indicate on attached map)
FE-3 STREAM QUALITY ASSESSMENT WORKSHEET
Provide the following information for the stream reach under assessment:
I. Applicant's name: TIEC- 2. Evaluator's name: 12, 060k2► , k MttGVY II
3. Date of evaluation: 10'11- IS
5. Name of stream:
7. Approximate drainage area: Z5 A�-
9. Length of reach evaluated: I0r) -fir
IL Site coordinates (if known): preler in decimal degrees.
4. Time of evaluation: ARC
6. River basin: ZrOnd—
-8. Stream order: I St
10. County: ?011(-
12. Subdivision name (if any):
Latitude (ex 34 x72312): 35. Z(05411 Longitude (ex - 77.556611): - 82 , 055nfn
Method location determined (circle): GPS Topo Sheet Ortho (Aerial) Photo /GIS Other GIS Other
13. Location of reach under evaluation (note near y roads and landmarks and attach map identifying stream(s) location):
n un F
14. Proposed channel work (if any): 0We-
15. Recent weather conditions: Cool -r d ✓y
16. Site conditions at time of visit: 0061 It ULy
17. Identify any special waterway classifications known: _Section 10 _Tidal Waters _Essential Fisheries Habitat
_Trout Waters _Outstanding Resource Waters _ Nutrient Sensitive Waters _Water Supply Watershed (1 -IV)
18. Is there a pond or lake located upstream of the evaluation point? YES <� If yes, estimate the water surface area:
19. Does channel appear on USGS quad map? YES CO
21. Estimated watershed land use. _% Residential
100 % Forested
22. Bankfull width: 4,P+
20. Does channel appear on USDA Soil Survey? YES NO
_% Commercial _% Industrial _% Agricultural
_% Cleared / Logged _% Other
23. Bank height (from bed to top of bank): 2-41'c
24. Channel slope down center of stream: _)L - Flat (0 to 2 0/.,) _Gentle (2 to 4 %) _Moderate (4 to 10 %) _Steep (>I 0%)
25. Channel sinuosity: Straight Occasional bends _Frequent meander _Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most appropriate ecoregion based on
location, terrain, vegetation, stream classification, etc. Every characteristic must be scored using the same ecoregion. Assign points
to each characteristic within die range shown for the ecoregion. Page 3 provides a brief description of how to review the
characteristics identified in the worksheet. Scores should reflect an overall assessment of the stream reach under evaluation. If a
characteristic cannot be evaluated due to site or weather conditions, enter 0 in the scoring box and provide an explanation in the
comment section. Where there are obvious changes in the character of a stream under review (e.g., the stream flows from a pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a separate form used to evaluate each
reach. The total score assigned to a stream reach must range between 0 and 100, with a score of 100 representing a stream of the
highest quality.
Total Score (from reverse): 5-1 Comments:
Evaluator's Signature _1Cer2.( ALL� Date ID-21- kS
This channel evaluation form is intended to be used only as a guide to assist landowners and environmental professionals in
gathering the data required by the United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not imply a
particular mitigation ratio or requirement. Form subject to change - version 06/03. To Comment, please call 919 - 876 -8441 x 26.

STREAM QUALITY ASSESSMENT WORKSHEET
�;�, 4 � ^1 �: � next n
4-
n.gire
" I - i7a.
L01 -
5-
T7
[7
V
—tr-, -
ge
Iz
I These characteristics are not assessed in coastal streams.
T
-W
3
2-
2
A
2-
D

USACE AID# DWQ ti Site tl (indicate on attached map)
FEM STREAM QUALITY ASSESSMENT WORKSHEET <
Provide the following information for the stream reach under assessment:
1. Applicant's name:. T\E- - 2. Evaluator's name: r-, M HChIrtl
3. Date of evaluation: 4. Time of evaluation: Ay,A
5. Name of stream: ?3
7. Approximate drainage area: Cr'J AL
9. Length of reach evaluated: l oo (2 4-
11. Site coordinates (if known): prefer in decimal degrees.
6. River basin: R)(OnoL
8: Stream order: 2+14
10. County: Prn r-
12. Subdivision name (if any): 1 I —
Latiludc(cx.34.8723)2): 35.2Jo90 Longitudc(ex — 77.556611): - 0Z'o55o31
Method location determined (circle): GPS �Sheetc Ortho (Aerial) Photo /GIS Other GIS Other
13. Location of reach under evaluation (notads and lan dmarks and attach map identifying stream(s) location):
P�1, nn E2@ 1
14. Proposed channel work (if any): Y�Qne-
15. Recent weather conditions: (*Om Ir- d ✓I
16. Site conditions at time of visit: f o or *- 4V4
17. Identify any special waterway classifications known: _Section 10 _Tidal Waters _Essential Fisheries Habitat
_Trout Waters _Outstanding Resource Waters _ Nutrient Sensitive Waters _Water Supply Watershed (7 -IV)
18. Is there a pond or lake located upstream of the evaluation point? YES 0 If yes, estimate the water surface area:
19. Doss channel appear on USGS quad map? YES NO 20. Does channel appear on USDA Soil Survey? YES NO
21. Estimated watershed land use: _% Residential _% Commercial _% Industrial _% Agricultural
JUQ% Forested _% Cleared / Logged _% Other ( )
22. Bankfull width: 10 23. Bank height (from bed to top of bank): 1.5 -P+
24. Channel slope down center of stream: �4 Flat (0 to 2 %) _Gentle (2 to 4 %) _Moderate (4 to 10 %) _Steep (>I 0%)
25. Channel sinuosity: Straight _Occasional bends X - Frequent meander _Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most appropriate ecoregion based on
location, terrain, vegetation, stream classification, etc. Every characteristic must be scored using the same ecoregion. Assign points
to each characteristic within the range shown for the ecoregion. Page 3 provides a brief description of how to review the
characteristics identified in the worksheet. Scores should reflect an overall assessment of the stream reach under evaluation. If a
characteristic cannot be evaluated due to site or weather conditions, enter 0 in the scoring box and provide an explanation in the
comment section. Where there are obvious changes in the character of a stream under review (e.g., the stream flows from a pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a separate form used to evaluate each
reach. The total score assigned to a stream reach must range between 0 and 100, with a score of 100 representing a stream of the
highest quality.
Total Score (from reverse): Comments: FQ,fM CO3kgd n Icn cxeel" t'O �4 .
Evaluator's Signature `QQ NJ D -i44Al o Date 10 - 2l -15
This channel evaluation form is intended to be used only as a guide to assist landowners and environmental professionals in
gathering the data required by the United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not imply a
particular mitigation ratio or requirement. Form subject to change - version 06/03. To Comment, please call 919 - 876 -8441 x 26.

STREAM QUALITY ASSESSMENT WORKSHEET
+^ �Li
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These characteristics are not assessed in coastal streams.

USAGE AIDP DWQ k Site # (indicate on attached map)
FE13 STREAM QUALITY ASSESSMENT WORKSHEET
Provide the following information for the stream reach under assessment:
I. Applicant's name: T1EC 2. Evaluator's name: P t,-Sr— t�C• 4�lttr.InP.11
3. Date of evaluation: I fa - 21- Irt 4. Time of evaluation: Ah
5. Name of stream:_ ?5
7. Approximate drainage area: �5 A(-
9. Length of reach evaluated: IOD%r
11. Site coordinates (if known): prefer in decimal degrees.
6. River basin: 13ecctiL-
8. Stream order: 15t
10. County: Qd \5-
12. Subdivision name (if any): T kEC
Latitude (ex 34.972312): �J • ifo-1 41� Longitude (ex - 77.556611): — $2 • US \`140
Method location determined (circle): GPS Topo Sheet Ortho (Aerial) Photo /GIS Other G1S Other
13. Location of reach under evaluation (note nearby roads and landmarks and attach map identifying stream(s) location):
P o- F,
14. Proposed channel work (if any): yhUnC
15. Recent weather conditions: Col) � -
16. Site conditions at time of visit: COD/ tr CAy--( -
17. Identify any special waterway classifications known: _Section 10 _Tidal Waters _Essential Fisheries Habitat
_Trout Waters _Outstanding Resource Waters _Nutrient Sensitive Waters _Water Supply Watershed (I -IV)
18. Is there a pond or lake located upstream of the evaluation point? YES NO If yes, estimate the water surface area:
19. Does channel appear on USGS quad map? YES NO
21. Estimated watershed land use: _%o Residential
100 % Forested
22. Bankfull width: W-�-
20. Does channel appear on USDA Soil Survey? YES NO
_% Commercial _% Industrial _/o Agricultural
_% Cleared / Logged % Other ( )
23, Bank height (from bed to top of bank): 1.5 9-1-
24. Channel slope down center of stream: _Flat (0 to 2 %) Gentle (2 to 4 %) _Moderate (4 to 10%) _Steep ( >I0 %)
25. Channel sinuosity: Straight _A Occasional bends _Frequent meander _Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most appropriate ecoregion based on
location, terrain, vegetation, stream classification, etc. Every characteristic must be scored using the same ecoregion. Assign points
to each characteristic within the range shown for the ecoregion. Page 3 provides a brief description of how to review the
characteristics identified in the worksheet. Scores should reflect an overall assessment of the stream reach under evaluation. If a
characteristic cannot be evaluated due to site or weather conditions, enter 0 in the scoring box and provide an explanation in the
comment section. Where there are obvious changes in the character of a stream under review (e.g., the stream flows from a pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a separate form used to evaluate each
reach. The total score assigned to a stream reach must range between 0 and 100, with a score of 100 representing a stream of the
highest quality.
Total Score (from reverse): Y& V— 1 Comments:
Evaluator's Signature 1 a- Cpl -ems- Date 10-21-15
This channel evaluation form is intended to be used only as a guide to assist landowners and environmental professionals in
gathering the data required by the United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not imply a
particular mitigation ratio or requirement. Form subject to change - version 06103. To Comment, please call 919- 876 -8441 x 26.

STREAM QUALITY ASSESSMENT WORKSHEET
' These characteristics are not assessed in coastal streams. �D -1
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' These characteristics are not assessed in coastal streams. �D -1

USACE AID# DWQ # Site 4 (indicate on attached map)
STREAM QUALITY ASSESSMENT WORKSHEET
Provide the following information for the stream reach under assessment:
1. Applicant's name: T-1�C 2. Evaluator's name: R, IJCt.> ft Tl K• "1 me' . 0
3. Date of evaluation: \D-7—\-\5 4. Time of evaluation: AM
S. Name of stream: F2
7. Approximate drainage area:
9. Length of reach evaluated: 100
11. Site coordinates (if known): prefer in decimal degrees.
6. River basin: teoocL
8. Stream order: ,no
10. County: Po \y-
12. Subdivision name (if any): fIEX --
Lathude (ex 34 872312). 35 •2(0a-1 °Fb Longitude (cx. - 77.556611): - Oz-, 050 215
Method location determined (circle): GP5 opo Sheet Ortho (Aerial) Photo /GIS Other GIS Other
13. Location of reach under evaluation (note nearby roads and landmarks and attach map identifying stream(s) location):
E-L wtain 5-z� inn F� 1
14. Proposed channel work (if any): YNCAee
15. Recent weather conditions: too a r,I"
16. Site conditions at time of visit: 00A it r tti -
17. Identify any special waterway classifications known: _Section 10 _Tidal Waters _Essential Fisheries Habitat
_Trout Waters _Outstanding Resource Waters _Nutrient Sensitive Waters _Water Supply Watershed (1 -IV)
18. Is there a pond or lake located upstream of the evaluation point? YES ©O If yes, estimate the water surface area:
19. Does channel appear on USGS quad map? YES (0 20. Does channel appear on USDA Soil Survey? YES NO
21. Estimated watershed land use: _% Residential _% Commercial _% Industrial _ _% Agricultural
IQQ% Forested _% Cleared ! Logged _% Other ( )
22. Bankfull width: tD�+ 23. Bank height (from bed to top of bank): b�k
24. Channel slope down center of stream: Y Flat (0 to 2 %) _Gentle (2 to 4 %) _Moderate (4 to 10 %) _Steep (> 10 %)
25. Channel sinuosity: Straight �( Occasional bends _Frequent meander _Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most appropriate ecoregion based on
location, terrain, vegetation, stream classification, etc. Every characteristic must be scored using the same ecoregion. Assign points
to each characteristic within the range shown for the ecoregion. Page 3 provides a brief description of how to review the
characteristics identified in the worksheet. Scores should reflect an overall assessment of the stream reach under evaluation. If a
characteristic cannot be evaluated due to site or weather conditions, enter 0 in the scoring box and provide an explanation in the
comment section. Where there are obvious changes in the character of a stream under review (e.g., the stream flows from a pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a separate form used to evaluate each
reach. The total score assigned to a stream reach must range between 0 and 100, with a score of 100 representing a stream of the
highest quality.
Total Score (from reverse): 52 Comments:
Evaluator's Signature IM LIwoe U� Date 10-21-15
This channel evaluation form Is intended to be used only as a guide to assist landowners and environmental professionals in
gathering the data required by the United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not imply a
particular mitigation ratio or requirement. Form subject to change — version 06103. To Comment, please call 919- 876 -8441 x 26.

STREAM QUALITY ASSESSMENT WORKSHEET
of:
jp 119w
-4" -
1.: r?N A
v�n
2.
aff"
2
�TiO;gaoa ;-e apuousz4 'A t`. L=��.
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d
Ge
6
d"HAd
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PO
7,4
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FF
0
wy Oslo
'OL 5 7� A
ipI
.0
g� -MW
R T.,.-
X en 0
oil, llFFlFe.ITIY
-pu
IN -1 MIME-
31-ange -1 ION
izu.a 3
0 21
-T
P1401"M
1050ft, 'Rem
ld a
VA -t I i
"IM . 1 W74 AN w—, 3 627 W-51
Of 7-
2
n
rhese characteristics are not assessed in coastal streams.
57,

Attachment C
Representative Photographs

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10/21/2015
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Preservation Area 4 (P4)
Preservation Area 5 (P5)

Debris and household trash in Preservation Area 5 (P5)
Enhancement Area 1 (E 1)

Enhancement Area 2 (E2)