20131200 Ver 3_ARO Comments Polk County_20150812

Strickland, Bev
From: Moore, Andrew W
Sent: Wednesday, August 12, 2015 10:51 AM
To: Burdette, Jennifer a
Subject: Tryon International Equestrian Center IP ARO Comments, Polk County
Jennifer,
The following are the Asheville Regional Office's comments regarding the Individual Permit application from the Tryon
International Equestrian Center (TIEC) dated June 2015:
1. Proposed impacts RC1 and RC2 include 3 stream crossings that all result in access to the same area. Why is RC2
necessary when that area can be accessed using RC1?
2. Figures 4A, 413, 4C, and 4D depict the road crossings associated with impacts RC1, RC2 (110 -foot section), RC3,
and RC4, respectively, crossing the stream non - perpendicular (i.e. at an angle other than 90 degrees) to the
stream. In fact, RC1, RC2, and RC4 appear to be at angles greater than 115 degrees. Orienting the crossings
perpendicular to the stream would minimize impacts. Is it possible to orient these crossings perpendicular to the
stream channels? If not, why?
3. Previously permitted road crossing impacts under Action ID 2006 -32154 for White Oak Creek development
resulted in two crossings at 35 and 40 feet of impact according to Impact Map Figure 4. Proposed road crossing
impacts for the current IP range from 60 -110 feet per crossing. Why is so much additional impact needed for
each crossing?
Under some circumstances, we understand that wider roads may be needed for horse trailers (i.e. to access
farmettes), but for those road crossings that are designed to access residential areas, it would seem that 35 -40
feet of impact would be adequate to construct a standard road.
It appears that a significant amount of fill is proposed over proposed impacts RC1 and RC -2 (110 -foot section)
resulting in additional, avoidable impacts. Is this much fill necessary and why? Could other construction methods
be employed at these two crossings that would minimize impacts?
4. It's not clear from the application what the applicant is proposing with respect to impacts E1 and E2. No details
or description of bridle path impacts E2 or impact E1 are provided. What are the impacts? Particular detail is
needed with respect to the development of bridle paths and impact E1. There are a significant number of bridle
paths throughout Polk County that do not require impacts to jurisdictional waters. To my knowledge, a bridle
path is simply a trail for horses to walk on. Additional description of proposed impacts E1 and E2 is needed along
with a more detailed discussion of avoidance and minimization for these impacts.
5. At full build out, including residences, will the built upon area exceed 24% impervious for the entire site, or for
any individual drainage area?
6. The southernmost tributary proposed for preservation as part of the mitigation plan has a short section with no
buffer near the head of the tributary. Is this section of stream not included in the mitigation plan? If not, why
not?

7. We recommend that one of the conditions of the Water Quality Certification be that pictures should be sent to
the Division of each of the installed culverts, both upstream and downstream, to confirm that they have been
installed in accordance with the "Placement of Culverts" condition. Note that one of the culverts associated with
RC2, and RCS, are proposed to be installed at a slope greater that 5 %.
Based on the sediment impacts to the unnamed tributary we observed during our site visit yesterday, I believe another
site visit is warranted to observe all streams on the property, and to properly document the impacts we observed
yesterday. I have tentatively planned another site visit with Tim Fox for Monday August 17, 2015.
Note that a NOV was issued to the TIEC last spring for impacts to unnamed tributaries of White Oak Creek and to White
Oak Creek. The response to that NOV from Clearwater included removing sediment from 532 feet of the tributary that
we observed with recent impacts. Therefore, it appears that they have already removed sediment from that tributary
once last year.
It is my understanding that Clearwater is conducting regular construction stormwater inspections of the TIEC. We are
considering requesting that they accompany us on our site visit on Monday. Let's touch base again before the end of the
week to discuss how to address the recent impacts (i.e. NOV or include in Add Info for IP).
Andrew W. Moore, P.G. — And rew.W.Moore @ncdenr.Rov
North Carolina Dept. of Environment and Natural Resources
Division of Water Resources — Water Quality Regional Operations Section
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: 828 - 296 -4684
Fax: 828 - 299 -7043
Notice: • po d • and from this address may be IM ' to the North •
Public Records Law and therefore may be disclosed • third parties.