20131200 Ver 4_WRC Comments_20160707

L North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
August 7, 2015
Mr. Steve Kichefski
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Tryon International Equestrian Center
UTs to White Oak Creek, Polk County
Action ID#: SAW -2013-02262
Dear Mr. Kichefski:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
individual permit application to fill 0.02 acre of wetland and temporarily impact 150 ft and
permanently impact 908 ft of unnamed tributaries (UTs) to White Oak Creek in Polk County. I
attended on on-site meeting with representatives of Clearwater Environmental Consultants and
regulatory agencies on May 4, 2015. Our comments on this application are offered for your
consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish
and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
Tryon International Equestrian Center is on a 1,276 acre site on White Oak Creek. Seagreen
Darter [Etheostoma thalassinum, NC Significantly Rare (SR)] is found in White Oak Creek in
the vicinity of the project, and Carolina Foothills Crayfish (Cambarus johni, NC SR) is found
downstream in the Green River. The project should not impact trout and activities do not need to
be avoided during the trout spawning moratorium.
A master plan has been developed for the Center, and it includes six riding arenas, four riding
rings, a polo field, a covered riding facility, 1,000 permanent stables, bridle paths, an outdoor
sports complex, golf course, spa resort with hotel, log cabin village, RV park, rental homes,
residential lots, and farmettes. Some of this infrastructure has been built, involving previously
permitted impacts of 405 ft of stream.
Impacts
The application proposes to install utility crossings at five sites, temporarily impacting 150 ft of
stream, culvert 462 ft of stream for road crossings, and permanently 611446 ft of stream to
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Polk County
develop barns, parking, a bridle path, and farmettes. There is no description or detailed map
provided for the 446 ft of permanent stream impact, so it is difficult to understand the need for
this impact and its setting within the development. Many of the proposed road crossings involve
very long culverts (e.g., 91 ft for RC1 and 185 ft for RC2, which involves crossing two streams);
in comparison, already installed and permitted road crossings have much shorter culverts,
involving 35-40 ft of impact.
The application states that there will be minimal impacts to biological characteristics of the
ecosystem and special aquatic sites. It also minimizes the secondary and cumulative impacts that
will likely result from the project. The master plan involves the clearing of currently wooded
area and extensive construction of roads, buildings, and other impervious areas, all of which will
impact the hydrology of the site and streams. Unless stormwater is managed to mimic pre -
development hydrologic conditions, the increased impervious cover will result in increased
stormwater flows capable of destabilizing stream channels and impacting in -stream habitat and
biota. In addition, the loss of forested habitat will displace forest -dependent wildlife species,
such as song birds, reptiles, and amphibians.
Mitigation
Mitigation is proposed for a portion of previous impacts and proposed permanent stream
impacts, which total 1,023 ft of impact. A 2:1 mitigation ratio is proposed, with 1,023 ft of
restoration provided through NC Division of Mitigation Services and 7,979 ft of on-site stream
preservation provided at a 7.5:1 ratio, resulting in 1,023 mitigation units.
Mitigation is not proposed for 150 ft of temporary utility crossing impacts. As these impacts will
involve open cuts of these streams, we recommend that mitigation be required at a 1:1 ratio for
these temporary impacts.
Preservation involves the protection of 1St and 2nd order stream channels and 30 ft buffers. The
May 2015 site visit allowed examination of a portion of the streams proposed for preservation
that run close to a road. There are extensive exotic species within the riparian buffer, and the
application proposes the control of exotic and invasive species during years 1, 3, and 5. Based
on analysis of aerial photographs, some of the proposed preservation stream length along the
road has less than 30 ft of woody vegetation on the road side of the stream. In addition, there is a
culvert in the channel that is perched 2-3 ft, serving as a barrier to aquatic organisms.
According to the site plan, the proposed preservation reaches will drain what appear to be
residential lots. There is no information provided on how these lots will be developed and how
stormwater will be controlled. Sediment from lot development and post -construction stormwater
could negatively impact these preservation reaches.
We are concerned about the present and future quality of these streams and associated riparian
zones and recommend that off-site high quality preservation be used to mitigate for the present
impacts. Due to the size of the Tryon International Equestrian Center and development that will
likely occur in the area as a result of the Center, we recommend that any future mitigation
needed for Center expansion include preservation of off-site high quality streams and riparian
areas, as well. NCWRC welcomes the opportunity to work with regulatory agencies and the

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Polk County
permittee to develop a mitigation plan to achieve this. If the streams proposed for preservation
are used to mitigate for the current project's impacts, we recommend that a higher mitigation
ratio be used, such as 10:1.
We offer the following recommendations to minimize the potential for impacts to aquatic and
terrestrial resources:
1. Utility crossings should involve the placement of native stream substrate on the stream bed in
order to mimic pre -disturbance conditions. In addition, stream banks should be planted in
native woody vegetation.
2. Culvert length for road crossings should be minimized as much as possible.
3. A detailed map and description should be provided for the 446 ft of proposed impact
involved in the development of barns, parking, a bridle path, and farmettes. Impacts should
be minimized as much as possible.
4. Mitigation should be required at a 1:1 ratio for the temporary utility crossing impacts.
5. We recommend that proposed and future mitigation associated with Center expansion
involve off-site high quality preservation. If proposed preservation reaches are used as
mitigation, they should be provided at a higher ratio, such as 10:1.
6. Stormwater from site development has the potential to degrade streams both on-site and
downstream. We recommend that the Center use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%. We also encourage the
use of non-invasive native species and Low Impact Development (LID) technology in
landscaping. Using native species instead of ornamentals should reduce the need for water,
fertilizers and pesticides. Using LID technology in landscaping will not only help maintain
the predevelopment hydrologic regime, but also enhance the aesthetic and habitat value of
the site.
7. Conserve as much of the native woodland as possible in order to protect on-site wildlife
habitat.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Clement Riddle, C1earWater Environmental
Andrew Moore, NC Division of Water Resources
Bryan Tompkins, US Fish and Wildlife Service
TR Russ, Kendrick Weeks, Powell Wheeler, NCWRC