20131200 Ver 5_Staff Comments_20170315

Burdette, Jennifer a
From: Moore, Andrew W
Sent: Wednesday, March 15, 2017 4:36 PM
To: Burdette, Jennifer a
Subject: ARO Comments -Tryon Equestrian Center Individual Permit Modification (20131200
V5)
Jennifer,
The following are the Asheville Regional Office's comments regarding the Individual Permit Modification submittal from
the Tryon Equestrian Center dated February 16, 2017:
1. It is unclear where proposed impacts E3, E4, and E5 begin and end. The applicant should provide larger scale
maps (1"= 50' is recommended) that clearly depict the starting and ending locations of the proposed impacts.
2. The applicant should provide a sequence of construction and construction details for impacts E3, E4, and E5,
including how work will be performed in the dry, more detail regarding the exact nature of the impacts (e.g.
multiple or single culverts, French drains, underdrains, rip rap pads, etc...), and how hydrology will be maintained
downstream of proposed impact E5. In addition, the applicant should ensure that the location of any temporary
impacts associated with dewatering are shown on the construction drawings.
3. The applicant should provide a more robust discussion of practical alternatives for the multi-purpose field
(proposed impact E3) that avoid or minimize stream impacts and fill amounts. The Division understands that
historically, most of the disciplines of the World Equestrian Games have been conducted at various event
locations within a region, rather than at one central location. It is not clear why the multi-purpose field could not
be constructed at another location within the region that avoids or minimizes stream impacts, while still hosting
events associated with the World Equestrian Games.
4. Has the applicant evaluated the feasibility of a parking deck to avoid and/or minimize proposed impact E4?
Numerous hotels in the region have been constructed within a small footprint by implementing multi -story
parking garages.
5. There is no avoidance and minimization section or discussion of practical alternatives for impact E5. The applicant
needs to demonstrate that there are no practical alternatives to the placement of the barns and that they have
avoided and minimized impacts associated with the two barns to the maximum extent practicable.
6. Per Polk County GIS, there appears to be a portion of Polk County Parcel P106-23 that is depicted as part of the
project boundary in Figure 6 of the IP application, but that has not been delineated. The shape and size of Polk
County Parcel P106-23 as depicted in Polk County GIS does not match that as depicted in the Stream and Wetland
Delineation Map Figure 5, Sheet 1 in Appendix B. The applicant should explain this discrepancy. All jurisdictional
features within the project boundary as depicted in Figure 6 should be shown on the map.
7. The Division of Water Resources understands from the Division of Energy, Mineral and Land Resources (DEMLR)
that additional infrastructure and site development associated with the Tryon Equestrian Center are planned
within the site boundary depicted on Figure 6 in the application. However, that proposed infrastructure is not
depicted on the figures provided with the application. For instance, the following S&EC plans have been
submitted to DEMLR for review: Tryon Horse Crossing (received by DEMLR 1/31/2017), the Tryon Eastern Track

(received by DEMLR 2/16/2017), and Luxury Hotel (received by DEMLR 2/9/2017). All of these plans were
submitted on the same date, or prior to, submittal of the IP application. The Impact Overview Map and associated
figures should show all planned built -out structures and impervious cover within the project boundary.
8. The applicant should provide more detail on the mitigation plan.
Feel free to contact me if you would like to discuss any of the comments further.
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
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