20131200 Ver 5_WRC Comments_20170323

From: Leslie, Andrea ]
Sent: Thursday, March 23' 20170:07AK4
To: Clement Riddle; Moore, Andrew W;8urdette,Jennifer a;Byron Hamstead
(byron_hamstead@fwsgov); Russ, VV.Thomas; Weeks, Kendrick [;Wheeler, A. Powell
Subject: FW: WRC Comments: Tryon International Equestrian [enter, Polk County (Action ID#
SAVV'2013'02262)
Attachments: TryonInternationa|Equestrian[enterFebZUl7IP_UTsVVhiteOak[r_Po|k[o_VVR[[ommen
ts_FINAL_032217.pdf
Andrea Leslie
Mountain Habitat Conservation Coordinator
NCWildlife Resources Commission
2O83OGreat Smoky Mountain Expressway
Waynesville, NC28786
828-558-6011; 828-400-4223 (cell)
Get NC Wildlife Updat delivered to your inbuxfmm the N.C.Wildlife Resources Commission.
From: Deaton, Shannon L
Sent: Wednesday, March 22, 2017 5:18 PM
To: Steven. L0chef [e-mail]|
Cc: Cox, David R. <davidzox@ncwi|d|ife.or8>, Leslie, Andrea ] <andnea]es|ie@ncwi|d|ife.or8>
Subject: WRC Comments: Tryon International Equestrian Center, Polk County (Action ID# SAW -2013-02262)
Please find our agency comments attached. Let me know if you have an questions.
Shannon Deaton // Chiief
Habitat Conservation Division
NC WiiUdUiife Resources, Commmmissiion
1721 Mail Service Center
Raleigh, North Carolina 27699-1721
office: 919-707-0222 V mobile: [phone]
fax: [phone]
Dcwildlife.org

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t North Carolina Wildlife Resources Commission t
Gordon Myers, Executive Director
March 22, 2017
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 0.09 acre of wetland and permanently impact 3,929 ft of
unnamed tributaries (UTs) to White Oak Creek in Polk County. I attended an on-site meeting
regarding the project with representatives of Tryon Equestrian Center, Clearwater Environmental
Consultants, and regulatory agencies on January 26, 2017. 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-
6674).
Tryon International Equestrian Center (TIEC) is on a 1,405 -acre site on White Oak Creek.
Seagreen Darter [Etheostoma thalassinum, NC Significantly Rare (SR)] is found in White Oak
Creek near 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.
On January 11, 2017, the US Army Corps of Engineers (USACE) issued an individual permit to
the TIEC to permanently impact 446 ft and temporarily impact 120 ft of UTs to White Oak
Creek. This permit was suspended, and the 446 ft of permanent impacts are accounted for in the
present permit application. The authorization for the temporary stream impacts has been
reinstated.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh NC 27699-1721
Phone: [phone] • Fax: [phone]

Tryon International Equestrian Center Page 2 March 22, 2017
Polk County
Impacts associated with the present permit application are part of a proposed expanded
development of the TIEC, a recreational equestrian facility. The project purpose is to continue
development of the TIEC as a mixed-use residential and commercial resort that can host the
2018 World Equestrian Games.
Impacts
The application proposes impacts associated with the construction of a multi-purpose field and
parking areas for a proposed on-site hotel and two barns, as follow:
• 2,054 ft of stream for a multi-purpose field. This will involve filling a relatively steep
stream valley. The field would be adjacent to stadiums, parking, and farmettes.
• 803 ft of stream and 0.09 acre of wetland for parking adjacent to a proposed 250 -guest
hotel that is sited adjacent to the main facility. County ordinance requires that parking be
not more than 400 ft from the hotel.
• 1,072 ft of stream for trailer parking associated with barns.
• Loss of forested habitat for the construction of the multi-purpose field, hotel and barns,
and parking lots.
Details, such as staging, culvert type, installation method, and stabilization methods for the site
are not provided for these impacts. In addition, no information is provided on stormwater
management for the site.
The master plan involves the clearing of currently wooded areas and extensive construction of
roads, buildings, and other impervious areas, all of which will impact the hydrology of the site
and streams. Research indicates that large scale culverting of streams can directly impact passage
and quality of aquatic species and habitat. Evaluating the length and type of culverts can aid in
minimizing these impacts.
Stormwater from site development has the potential to degrade on-site and downstream waters.
Available literature indicates that the use of stormwater control measures that mimic the
hydrograph consistent with an impervious cover of less than 10% will minimize impacts on
stream hydrology, water quality, in -stream habitat, and aquatic wildlife. We 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. Also
incorporating LID approaches help to identify ways to conserve on-site wildlife habitat as part of
the site design which benefits forest -dependent wildlife species, such as song birds, reptiles, and
amphibians.
Mitigation
Mitigation at a 2:1 ratio is proposed for stream impacts, resulting in 8,088 ft of stream
mitigation. Of this total, 7,080 ft of mitigation is proposed with a stream restoration site at the
Harmon Dairy, which would address extreme channel instability, improve aquatic habitat, and
address water quality impacts associated with long-term livestock access. We support the use of

Tryon International Equestrian Center Page 3 March 22, 2017
Polk County
the Harmon Dairy for 7,080 mitigation credits. Preservation should be considered for the
remaining 1,008 credits within the Broad River basin. Further, we welcome any opportunity to
work with regulatory agencies and the permittee to identify and develop additional mitigation to
fulfill the remaining requirements.
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,
Shannon L. Deaton, Chief
Division of Habitat Conservation
ec: Clement Riddle, C1earWater Environmental
Andrew Moore and Jennifer Burdette, NC Division of Water Resources
Bryan Tompkins, US Fish and Wildlife Service
Andrea Leslie, TR Russ, Kendrick Weeks, Powell Wheeler, David Cox, NCWRC