20131200 Ver 5_More Info Letter_20170406

April 6, 2017
DWR # 13-1200 v5
Polk County
Tryon Equestrian Partners, LLC
Attn: Mr. Jeff Brown
2659 Sandy Plains Road
Tryon, NC 28782
Subject: REQUEST FOR ADDITIONAL INFORMATION
Tryon International Equestrian Center
On February 20, 2017, the Division of Water Resources (Division) received your application
dated February 15, 2017, requesting modification of an Individual Water Quality Certification
from the Division for the subject project. The Division has determined that your application is
incomplete and cannot be processed. The application is on -hold until all of the following
information is received:
I. It is unclear where proposed impacts E3, E4, and E5 begin and end. Clearly depict the
starting and ending locations of these proposed impacts.
The applicant should provide a more comprehensive discussion of practical alternatives
for the multi-purpose field (proposed impact E3) that avoid or minimize stream impacts
and fill amounts. Specifically, the Division has the following questions:
a. 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.
b. The application provides three reasons why alternative #2 is not practical:
excess fill material, creation of a large pit/hole adjacent to the area, and
insufficient width for lining up horses for the endurance course. This alternative
is insufficiently developed and evaluated for this analysis because excess fill
could be balanced on-site with the large pit/hole adjacent to the area and
vender concession, temporary stalls and temporary bathrooms are blocking the
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 807 6300

Tryon Equestrian Partners, LLC
Request for Additional Information
Page 2 of 4
entrance to the grass track. Prepare a revised alternative that locates the vendor
concession, temporary stalls, and temporary restrooms on the opposite side of
the field adjacent to International Boulevard and realigns the access road to
connect into International Boulevard. This alternative could reduce the stream
impacts by 1,000 linear feet or more.
Please provide the width required for each entrant and data on the number of
endurance course entrants and line up configurations for the last three world
games.
d. For the proposed alternative, could the vendor concession, temporary stalls, and
temporary restrooms by moved adjacent to International Boulevard and realign
the access road to connect into International Boulevard to minimize the amount
of stream impact required for the multi-purpose field?
3. 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. Specifically, could
the barn at impact E5 be shifted south and Barn 8 and associated parking be shifted
west with a horse/pedestrian bridge for crossing the stream?
4. This Office believes that the majority of impact E4 and E5 could be avoided by
reconfiguring the hotel, hotel parking, RV hook-ups and Olympic Village. Specifically,
the Division has following questions/comments:
a. Provide the number of temporary trailers required, the number of parking spots
required per trailer, and the number of parking spaces provided within the
Olympic Village
b. Explain the purpose of the non -parking area in the center of the Olympic Village.
Could this area be reduced to allow the barns and associated parking to be
relocated to avoid stream impacts?
Could the RV hook-up slots around the hotel be switched with the parking area
for the hotel allowing reconfiguration of the RV hook-up slots to minimize the
stream impact to a crossing?
d. Could a larger hotel with a larger footprint be constructed within the mixed-use
residential/commercial area to avoid construction of the hotel within
Recreational Village Loop? Could commercial buildings be two-story with
restaurants above retail to allow more space for a larger hotel footprint? Could
the residential portion of this area be relocated to one of the three or four
upland areas that do not have development plans depicted?

Tryon Equestrian Partners, LLC
Request for Additional Information
Page 3 of 4
e. Have you 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. If impacts E3, E4, and E5 are demonstrated to be unavoidable, provide a sequence of
construction and construction details, 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.
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.
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. You have proposed permittee responsible mitigation, please provide a complete detailed
mitigation plan (including full sized plans and detail sheets) for this project.
9. Provide a conceptual stormwater management plan (SMP) for the proposed project. A
final SMP will be required before the 401 Water Quality Certification can be issued.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. If all of the requested information is
not received in writing within 30 calendar days of receipt of this letter, the Division will be unable
to approve the application and it will be returned. The return of this project will necessitate

Tryon Equestrian Partners, LLC
Request for Additional Information
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reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please respond in writing within 30 calendar days of receipt of this letter by sending three copies
of all of the above requested information to the 401 & Buffer Permitting Branch, 1617 Mail
Service Center, Raleigh, NC 27699-1617. Please also submit copies of full-sized plans using the
following link: https:Hedocs.deq.nc.gov/Forms/Supplemental-Information-Form.
Please be aware that you have no authorization under the Section 401 of the Clean Water Act
for this activity and any work done within waters of the state may be a violation of North
Carolina General Statutes and Administrative Code.
Please contact Jennifer Burdette at 919-807-6364 or [e-mail] if you have
any questions or concerns.
cc: Clement Riddle, ClearWater Environmental Consultants, Inc (via [e-mail])
Amanda Jones (via [e-mail])
USACE Asheville Regulatory Field Office
DWR ARO file
DWR 401 & Buffer Permitting Branch file
Filename: 131200v5TryonlntEquestrianCenter(Polk)_401_IC_Mod_Hold.docx