20131200 Ver 5_1_FinalResponseNarrative_TIEC_061217_20170613

June 12, 2017
Mr. Steve Kichefski
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-2638
Ms. Karen Higgins
NCDEQ
Division of Water Resources
Wetlands & Storm Water Branch
512 North Salisbury Street
Raleigh, NC 27604
RE: Tryon Equestrian Partners, LLC, Tryon International Equestrian Center
(+/-1,405 AC) Individual Permit Request for Additional Information
Response, Polk County, North Carolina
Dear Ms. Higgins and Mr. Kichefski,
We have received your respective requests for additional information for the pending individual
permit request for the expansion of the Tryon International Equestrian Center (TIEC) dated April
6, 2017 from NCDEQ and April 26, 2017 from the U.S. Army Corps of Engineers. We appreciate
these comments/questions and have provided a consolidated response below since many of the
questions/comments were similar between these two regulatory agencies. Many of your
questions/comments were related to avoidance/minimization efforts, alternative designs/layouts,
and off-site options for needed facilities for the Games. Both agencies also requested specifics on
the criteria that the applicant used to determine why the plan as proposed is the only viable
alternative that meets the project's purpose/need and that there are no other lesser damaging and
practicable alternatives. We believe the information provided below satisfies this request and along
with the additional information provided, your respective agencies should be able to be use this
information to complete your review of the permit request.
Respectfully,
R. Clement Riddle, P.W.S
Principal
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Section 1.0: Hosting Criteria for the World Equestrian Games:
The Tryon Equestrian Facility was chosen to host the 2018 World Equestrian Games by the
Federation Equestre Internationale (FEI) due to its ability to meet specific selection criteria
outlined below in Table 1. For the purposes of this response/application, we will discuss in detail
Criteria #1 and #7 since those are directly related to the questions regarding proposed impacts
and potential for avoidance/minimization, alternative site designs, and off-site locations.
Table 1: FEI Host Selection Criteria for 2018 World Equestrian Games
Criteria #1
Hosting Capabilities for all 7 disciplines
Criteria #2
Financial Commitment/Support Information
Criteria #3
Commercial Restrictions/Obligations
Criteria #4
Confirmation of Time Tracking/Data Services
Provider
Criteria #5
Sponsorship Capabilities
Criteria #6
Qualifications of the Organizing Committee
Criteria #7
Accessibility to the Facility
Section 1.1: Criteria #1 for FEI Host Selection - Hosting Capabilities for all 8 Disciplines
For Criteria #1, there are 8 events (i.e. disciplines) that comprise the World Equestrian Games:
Jumping, Dressage, Para Dressage, Eventing, Driving, Endurance, Vaulting and Reigning. In
order to be awarded the bid to host the 2018 WEG, the chosen facility needs to provide venues
for all of these disciplines in one location which was the first criteria for selection that the TIEC
had to meet. At the time of this bid/award, there was not a specific criteria that required that the
chosen facility be able to host all of the disciplines on one site/facility since that would severely
limit potential bidders. Since this is an international/global sporting event, it is important that it
be held at different venues throughout the world in which some facilities may not have those
opportunities to meet Criteria #1 at one facility. However as noted in the enclosed letter
provided by FEI in Appendix A, a main consideration for awarding the 2018 WEG to TIEC was
its ability to be able to host the games at one facility due to the logistical and financial burdens
that occurred at the 2014 games that were held in Normandy, France. Many of the complaints
filed were directly related to the traveling logistics/hardships for both spectators and participants
trying to get to multiple venues within the region depending on the discipline/event. Widespread
complaints also included substandard accommodations for groomsman, caretakers, and the
horses/participants and vendors/spectator services (dining, bathrooms, etc.) being in separate
locations from the events. Due to these burdens/concerns, the overall financial viability of the
games was challenged so the WEG Strategic Review Committee prioritized finding a facility for
the 2018 Games that could host all the disciplines/events in one place.
Initially a venue in Bromont, Canada was chosen to host the 2018 World Equestrian Games and
was chosen because of its ability to host all 8 disciplines in one location. However due to
financial hardships, Bromont recused themselves and the FEI had to find an alternative location
very quickly. The TIEC subsequently submitted their bid in July 2016 and was chosen to host the
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2018 World Games in November 2016 because of their unique ability to host these games at one
facility in addition to meeting the selection criteria listed above. It should also be noted that the
most successful venue from past Games in regards to financial viability and the
spectator/participant experience was that of Aachen, Germany which hosted the 2006 World
Equestrian Games and in which all of the disciplines occurred at this one location. The following
2010 World Equestrian Games was held for the first time in the United States at the Kentucky
Horse Park in which all of the events were held at one location as well. When considering the
past locations of the World Equestrian Games and the future venues (including potential host
Samorin, Slovakia for 2022), three out of the four venues that hosted the Games were/will be
able to provide facilities for all disciplines in one location.
As previously noted in the project purpose/need, the proposed impacts to aquatic resources on
the site are associated with the ability to host the Games but is also for the continued long-term
use of the facility. There are several events that are currently are being scheduled to occur post
Games that will use the facilities and infrastructure constructed for the Games. TIEC is currently
proposing to host the Nation's Cup and World Cup which are Jumping competitions and expect
to draw approximately 200,000 spectators each. Other planned events also include the Driving
National and the Reigning National competitions. TIEC will also be hosting the Pan American
Games and the American Eventing Championship this fall which will also range between 60,000
and 200,000 spectators/participants. As previously noted, the proposed impacts/expansion has
been a part of TIEC's long term plans but were accelerated when they were chosen to host the
Games.
With regards to TIEC's ability to provide facilities for the 8 disciplines, a majority of the
infrastructure is already in place with the exception of the multipurpose field where the
Endurance and Eventing disciplines will be incorporated and discussed in more detail below.
Appendix A provides an excerpt (Part 05 Sport Requirements) from the FEI World Equestrian
Games 2018 Games Manual. For each discipline there is specific field/arena requirements and
required capacity for spectators. Based on these requirements, TIEC has developed a plan for
which arenas/stadiums/rings will be used for each discipline. The existing/large multipurpose
field will be converted to the required main stadium so that stadium seating can be added for
22,000 spectators as required for the Jumping discipline. There is a large warm up ring that is
immediately to the south of this area that will be required and used by all contestants to warm up
horses before entering main stadium. The current stadium which holds 5,000 to 6,000 spectators
will be used for Dressage and Para -Dressage. The arena on the west portion of the property will
be covered and hold the Vaulting and Reigning disciplines. Also areas previously designated as
"Farmettes" to the south of the multi-purpose field will be temporarily converted to
infrastructure that will provide facilities for the "Driving" discipline as noted on Figure 3
(Overall Site Plan). Ultimately, the multipurpose field is the only facility left/needed to be
constructed in order to be able host the "Endurance" and "Eventing" disciplines and to provide
venues for all 8 disciplines at one location.
Section 1.2: Multipurpose Field Criteria (MFC)
In order to understand the need for the multipurpose field configuration/layout, a set of selection
criteria has been defined and details provided below. Ultimately, the need for the multi-purpose
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is two -fold over a short term and long term planning horizon. The immediate need is to have a
hosting facility/area for the Endurance discipline but then to also have the capability to convert
this area to a competitive polo field venue for immediate/future use.
➢ Hosting Ability for Endurance/Eventing
➢ Accessibility
➢ Constructability
➢ Ability to Re -configure Field
➢ Transportation Flow/Safety
➢ Long -Term Use
MFC #1: Ability to Safely Host Endurance Discipline
The Endurance discipline is a long-distance race over multiple types of natural terrain. One of
the key criteria in determining the location of this multipurpose field is its ability to safely host
this event by meeting the FEI's criteria/requirements for this event. Appendix A provides the
hosting requirements for each discipline and Endurance is summarized below.
Course
➢
15 km training track
Specifications
➢
160 km natural terrain track with no more than 10% on hard
(from Appendix A)
ground
➢
The finish area must be in its own arena with sufficient room
for 3 horses to be racing towards the finish
➢
Veterinary check-in/stations
Support
➢
Approximately 150-190 stalls ( 1 stall per horse)
Infrastructure for
➢
National Team Tents (14) with food service and cultural
Horses/Participants
accommodations
Spectator
➢
Vendors/food in this area
Requirements
➢
Restroom Facilities
(for 800 spectators)
➢
Golf Cart Parkin
Other
➢
Press Tent/Office
Requirements
➢
Information Tent
➢
Emergency Services Tent
➢
Rider Hospitality Tent
➢
Rider/VIP Restrooms
➢
VIP Tent /Golf Cart Parkin
Approximately 150 horses/participants are currently expected to participate in the Endurance
event and will be starting at the same time and the same location (noted as the "Start/Finish
Area" on the plans). A 200 -foot width is required for the start to ensure that there is adequate
space for this many horses to line up at a starting point and a wide enough trail after the start
location to eventually work their way to the endurance course as the lineup narrows after the race
starts. As part of the Endurance event, regulations require that there be veterinary
stations/check-ins at the starting/finish line so that the health of the horses can be evaluated. Each
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time a horse finishes a 20 -mile loop, it will be required to stay at a designated veterinary station
and there needs to be space for multiple stations as multiple horses will be entering this area at
the same time. The horses are held in this area for 30-50 minutes during which a crew of
groomsmen/caretakers will be tending to the horses/athletes. There are also requirements
pertaining to support infrastructure for the horses/participants and spectators as noted above in
the table. The 2006 games had 157 endurance course participants, the 2010 games had 100
participants, and the 2014 games had 175 participants. The 2018 games are expected to have
between 150 and 175 participants but this number has not yet been finalized and could exceed
this estimation.
Much of the endurance course has been designed to take place off-site at the Green River Farms,
LLC Property to the east. Right of ways have been acquired through other adjacent properties to
access the Green River Farms, LLC property where the course will wind through existing trails
on this property. Figure 1 shows the location of the right of ways and the Green River Farms,
LLC property in relation to the TIEC. The horses/participants will run the same 20 -mile loop five
times before finishing in the same location in which they started.
MFC #2: Accessibility
Another important aspect of the location of this field is its accessibility to the rest of the TIEC
and keeping events for the Games and future competitions in close proximity to the main facility
so that the events are spectator and horse/athlete friendly. The ability for spectators,
horses/athletes and staff to be able to walk and/or use golf carts to access a majority of the
facility is crucial to the short-term and long-term goals of the project. Also, since there will be
multiple events occurring at the same time throughout the facility on all the field, arenas, and
stadiums, easy/quick access to all of these areas by spectators, horses/athletes, press, emergency
services, and other support services is crucial to executing the Games successfully and other
future competitions as well. As previously stated, one of the strategic organizational goals of this
facility is to create a facility that is spectator friendly and accessible so that enthusiasm for
equestrian sports will grow beyond the traditionally targeted audiences.
MFC #3: Constructability
There needs to be reasonable terrain and property access/ownership to be able to construct a field
of this size with the spectator and support infrastructure noted above in the Endurance discipline
requirements. For this event/field there needs to be access to sewer and water for the
horses/participants and spectators associated with dining events, vendors, restroom facilities, and
cultural accommodations.
MFC #4: Ability to Re -Configure Field
As noted previously, the purpose of this field is two -fold. During this Games, this area will serve
as the venue for the Endurance discipline. However, once this event is finished there is a Polo
exhibition game planned for this area. Immediately following the Endurance event, all the tents
and temporary structures within the field will be removed to host this Polo match. This will be an
exhibition game so that the industry standard field size of 900 -feet by 480 -feet will not need to
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be met and this game will be played on this smaller field size to demonstrate TIEC's future
capability to host competitive polo matches (please refer to MFC# 7 — Long Term Use).
Industry standards for polo fields are approximately 900'X480' (10 acres) in size, with a north -
south orientation, and is a permanently maintained grass field. A north -south orientation is
preferred in order to eliminate glare that negatively affects the horses/athletes and spectators
during competitions (including to but limited to the Endurance event for the Games). This
orientation also affects broadcasting times associated with televising the Games and other future
competitions. A north -south orientation allows a greater window for events/competitions to
occur which allows international television broadcasting to occur at a more optimal viewing
time. Other examples of competitive polo fields in the region are Aiken, SC (Aiken Polo Club),
Rogersville, AL (Bluewater Creek Polo Club), and Palm Beach, Florida (International Polo Club
Palm Beach) that have these standard size fields and orientations.
MFC #5: Transportation Flow/Safety
Another important component for this field/area is developing a plan that will facilitate vehicular
traffic flow for this eastern portion of the facility and allow a secondary/alternative route for
emergency vehicles, staff vehicular traffic, and other traffic/use generated by support services.
Currently there is only one entrance/exit to the facility which is located on the western side of the
facility. A second entrance/exit is needed on the eastern side to facilitate traffic flow, emergency
vehicle access, etc. for this event and future events and to connect the southern portion of the
property without having to navigate through heavily congested areas to exit the facility.
MFC #6: Long Term Use
As noted previously, the purpose of this field will be to host the Endurance event in the short
term for the 2018 World Equestrian Games but other design elements are needed for future/long-
term use of this area as well. Specifically, road access to the southeastern portions of the facility
that does not go through the main part of the fields/facility is needed to facilitate long-term
access to the planned farmettes post -Games.
Also, the ability for this multi-purpose field to be re -configured post -Games so that it can be
converted to a competitive polo field that meets industry standards is another important factor
that influences its layout/design and its ability to transition to serve other/future events. Once the
Games have been completed, the support structure to the south of the field (bathrooms, vending,
stalls, etc.) will be removed and the field will be expanded in this area to meet the standard field
length of 900 -feet. For future/long term use, this area is planned to be used to host national and
international Polo competition events and will be hosting National Polo League play which
requires a standard field size of approximately 900'X480' with a north -south orientation.
Section 1.3: Multipurpose Field Alternative Analysis
In order to determine the proposed multipurpose field location and layout that met the needed
criteria described above, the planning/engineering team evaluated several on and off-site
alternatives. The table summarizes the alternatives evaluated and their relationship to the
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selection criteria. An "x" was placed under the criteria if that alternative was determined to meet
that criteria. Each alternative is described below in more detail and Figure 2 shows the general
locations of these alternatives in relation to the overall TIEC plan.
MF Alternative #1: Using Existing Large Field
One alternative suggested by the agencies proposed utilizing the large, recently constructed field
immediately adjacent to and to the west of the proposed multipurpose field. This existing field is
approximately 600' X 650' in size and is configured in a north -south orientation. For the Games,
the Jumping discipline will occur in this stadium and it will be reduced in size to approximately
300 -feet by 300 -feet in order to place stadium seating to hold 20,000-22,000 spectators as
required by the hosting requirements for this discipline. The Jumping discipline is one of the
most popular/viewed events and has multiple competitions over the two week period. As part of
the requirements to host this discipline, the FEI requires that the Jumping discipline be located in
the `main arena' with the capacity to seat approximately 22,000 spectators. There is no other
available arena/stadium to move this event to so that Endurance can occur in this area that will
provide enough spectator capacity. The current stadium to the west only holds approximately
6,000 spectators and cannot be enlarged due to existing/surrounding infrastructure.
Also, this alternative would not allow the reconfiguration of this field for future use as an
expanded polo field. The 22,000 stadium seating is proposed as temporary and will be removed
post -Games but will likely be added back/re-built during needed future events for this field.
Also this field could not be expanded to meet the industry standards for a competitive polo field.
There is existing infrastructure to the south of this arena so that it could not be expanded to the
required 900 -feet north -south orientation. The field could be expanded 900 -feet to the east,
however the field orientation would not meet the criteria needed for a north -south orientation for
competitive polo events. In this alternative, the previously approved impacts (446 linear feet of
stream channel) would still be applicable associated with the construction of parking and
International Boulevard to the east of this existing field to facilitate traffic in this area and create
a secondary/eastern access.
0
Hosting
Ability
Accessibility
Constructability
Ability to Re-
configure Field
Transportation
Flow/Safety
Long
Term Use
Aquatic Resource
Impacts
MF Alt. #1
X
X
X
4461f stream
MF Alt. # 2
X
X
X
4461f stream
MF Alt. #3
X
X
1,0271f stream
MF Alt. #4
X
X
X
X
X
4461f stream
MF Alt. #5
3001f stream
MF Alt. #6
X
X
X
X
7781f stream
MF Alt. #7
X
X
X
X
4461f stream
MF Alt. #8
X
X
X
X
2,0541f stream
MF Alt. #9
4461f stream
Preferred
X
X
X
X
X
X
2,0541f stream
MF Alternative #1: Using Existing Large Field
One alternative suggested by the agencies proposed utilizing the large, recently constructed field
immediately adjacent to and to the west of the proposed multipurpose field. This existing field is
approximately 600' X 650' in size and is configured in a north -south orientation. For the Games,
the Jumping discipline will occur in this stadium and it will be reduced in size to approximately
300 -feet by 300 -feet in order to place stadium seating to hold 20,000-22,000 spectators as
required by the hosting requirements for this discipline. The Jumping discipline is one of the
most popular/viewed events and has multiple competitions over the two week period. As part of
the requirements to host this discipline, the FEI requires that the Jumping discipline be located in
the `main arena' with the capacity to seat approximately 22,000 spectators. There is no other
available arena/stadium to move this event to so that Endurance can occur in this area that will
provide enough spectator capacity. The current stadium to the west only holds approximately
6,000 spectators and cannot be enlarged due to existing/surrounding infrastructure.
Also, this alternative would not allow the reconfiguration of this field for future use as an
expanded polo field. The 22,000 stadium seating is proposed as temporary and will be removed
post -Games but will likely be added back/re-built during needed future events for this field.
Also this field could not be expanded to meet the industry standards for a competitive polo field.
There is existing infrastructure to the south of this arena so that it could not be expanded to the
required 900 -feet north -south orientation. The field could be expanded 900 -feet to the east,
however the field orientation would not meet the criteria needed for a north -south orientation for
competitive polo events. In this alternative, the previously approved impacts (446 linear feet of
stream channel) would still be applicable associated with the construction of parking and
International Boulevard to the east of this existing field to facilitate traffic in this area and create
a secondary/eastern access.
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MF Alternative #2: Move Field to the East
Another alternative suggested by the agencies was moving the field to the east. This option
would encroach into residential lots that have always been planned for this area. However, more
importantly this location would separate the future polo field from the main facility. In this
alternative, the previously approved impacts (446 linear feet of stream channel) would still be
applicable associated with the construction of parking and International Boulevard to the east of
this existing field to facilitate traffic in this area and create a secondary/eastern access.
MF Alternative #3: "Puzzling" of Support Infrastructure
This alternative is similar to the location/layout of the preferred alternative except that it
evaluated moving the support infrastructure (horse stalls, vendors, horse stalls, golf cart parking,
and restrooms) to other areas surrounding the field and grass trail. The surrounding topography is
even steeper with less distance to White Oak Creek south east of the proposed field area. The
area to the north of the `grass trail' is steep as well (Refer to Figure 3 for overview of existing
topography). Constructing these temporary facilities would be very difficult and costly and also
only temporarily delay the need for the impacts currently proposed since these temporary areas
will be converted to the needed polo field size. As noted above in selection criteria #4 and #6, the
area where these facilities are proposed is where the future competitive polo field will be
expanded to meet the 900 -foot industry standard for competitive polo field play. This alternative
would also not allow the construction of the long-term access to the farmette areas in the
southern portion of the property or allow an alternative southern access that bypasses heavily
trafficked areas.
MF Alternative #4: Move Field to the North
Initially, TIEC sought to locate this field to the north of its current proposed location in order to
avoid a majority of the proposed stream channel impacts. This would require purchasing a parcel
of land between TIEC's property and Pea Ridge Road. TIEC made repeated attempts to purchase
this property but the current owners have been unwilling to sell at this point. In this alternative,
the previously approved impacts (446 linear feet of stream channel) would still be applicable
associated with the construction of parking and International Boulevard to the east of this
existing field to facilitate traffic in this area and create a secondary/eastern access.
MF Alternative #5: Move Field to North Side of Hwy 74
Another potential alternative that the regulatory agencies have requested be evaluated is the use
of the parcel currently owned by TIEC on the north side of US Hwy 74. This tract is
approximately 24 acres and has approximately 332 linear feet of stream channel located in the
southern portion of the parcel adjacent to US Hwy 74. The area is currently being used as
overflow parking for competitions/events and will be used during the Games for buses/tractor
trailer/large multi -person vehicles. Ultimately, there will be a tunnel constructed under Hwy 74
that will allow a connection to the main facility.
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The configuration and topography of the parcel would allow an adequate field size to be
constructed with impacts to the 332 linear feet of stream channel on the site. However, there is
no connection between this parcel and the cross-country course. Multiple/additional right of
ways would have to be purchased which includes getting the horses/participants safely across
major roads and highways to connect to the Green River Farms, LLC course. In this alternative,
the previously approved impacts (446 linear feet of stream channel) would still be applicable
associated with the construction of parking and International Boulevard to the east of this
existing field to facilitate traffic in this area and create a secondary/eastern access.
MF Alternative #6: Move Field to Farmette Area
Another alternative that was also requested by the regulatory agencies involved utilizing the
future Farmette areas for the Endurance event. Currently as noted on the enclosed plans, this area
will be utilized to provide the training areas for the Driving discipline during the Games. An
alternative field/location would have to be found to move the Driving discipline but this is not an
option since this areas needs to be adjacent/near the main stadium. Also, this Farmette area is
approximately 17 acres in size and may not be large enough to support the field size needed due
to the steep topography adjacent to White Oak Creek. A detailed engineering study was not
conducted for this alternative but it is likely that tall retaining walls would be needed
immediately adjacent to the White Oak Creek to meet the field size requirements. Also,
additional stream channel impacts to create the `grass trail' to connect this field to the endurance
course would be needed to meet the requirements for the start/finish of the Endurance event. This
connection would need to be approximately 500 -feet wide and would need to cross the same
stream channel in which impacts are proposed for the road crossing/access to the south of the
preferred field configuration. Due to the topography and level grading requirements for the
starting/finishing corridor leading to the field, approximately 1,000 linear feet of stream channel
would need to be filled for this connection. Also, the previously permitted stream channel
impacts of 446 linear feet would still need to occur to construct the International Boulevard
which allows for the construction of road access to/around the eastern portion of the facility and
connection to the secondary entrance off of Pea Ridge Road. This alternative would minimize
impacts but leave a large/steep hole between the two impact areas which creates safety concerns
and also would ultimately degrade the stream channel in this area. Also if this field were able to
be constructed, it would not allow this area to become farmettes which is part of the long-term
residential plans for this area.
MF Alternative #7: Moving Field to South side of White Oak Creek
An additional alternative suggested moving the field to the south side of White Oak Creek. This
area as shown on enclosed plans/figures is planned for residential lots. This option would
encroach into these residential areas that have always been planned for this area. However, more
importantly this location would separate the future polo field from the main facility. In this
alternative, the previously approved impacts (446 linear feet of stream channel) would still be
applicable associated with the construction of parking and International Boulevard to the east of
this existing field to facilitate traffic in this area and create a secondary/eastern access.
91

MF Alternative #8: Holding Endurance Event at Biltmore Estate
TIEC evaluated the Biltmore Estate regarding the potential to hold the endurance event on the
Biltmore Estate grounds and proposed this concept to the WEG Strategic Review Committee.
However, during WEG's review of TIEC's bid request, it was noted that holding the endurance
games that far from TIEC would likely disqualify TIEC from holding the 2018 World Equestrian
Games. Also, even if the endurance event was held at Biltmore Estate, a polo field would still be
needed/requested by TIEC to meet their long term goals for this area.
MF Alternative #9: No Build/No Action
This alternative would eliminate the proposed multipurpose field and corresponding start/finish
for the endurance event. This would eliminate impacts to 1,608 linear feet of stream channel
since the previously approved impacts (446 linear feet of stream channel) would still be
applicable. However, this alternative would threaten TIEC's ability to host the 2018 World
Equestrian Games and not meet the project's overall purpose/need.
Preferred Alternative:
This proposed field will impact approximately 2,054 linear feet (including 4461f previously
permitted) of stream channel and the preferred field configuration is the only viable alternative to
meet TIEC's short term and long term plans for this area/facility. This plan/impact has not
changed since the previous submittal and detailed impact drawings have been included the show
the proposed French drain and construction sequencing. Based on the information and discussion
above other alternatives, this alternative was determined to be least damaging and practicable
alternative that meets the applicant's purpose/need.
Section 2.0: Criteria #7 for FEI Host Selection — Accessibility to the Facility
Another important criteria that was used to select the host venue for the 2018 World Equestrian
Games was the overall `accessibility' of the facility to spectators, participants and support staff.
This includes the location of the facility in relation to major highways/roads and airports,
lodging, restaurants, etc. Due to the size of this event along with its duration and the number of
expected spectators/participants/support staff, it is crucial that the hosting venue be located in an
area with adequate access to this type of infrastructure. The location of the facility within the
region of Mill Springs/Tryon is within desirable proximity to other larger cities which will
provide airport services and lodging opportunities for a majority of the spectators that travel to
the region. However, there is a lodging need specifically associated with the athletes and the
team's support staff as it relates to their accessibility to the Games.
As part of FEI's approval process for choosing a host facility, TIEC is responsible for
providing/securing lodging for the athletes and their support team along with one Chefs de
Mission for each participating National Federation. Each discipline has a support team that
includes one Chef d'Equipe, one veterinarian, and one groom per athlete for the Reining,
Dressage, Para -Dressage, Eventing, and Jumping. For Endurance and Driving there are two
grooms per athlete and Vaulting has the largest support team with one Chef d'Equipe, three
0

attendants, one national trainer, one team veterinarian, one groom per commenced 3 horses, and
all lungers. Based on this information, the table below provides the total number of people that
TIEC is required to lodge for each discipline*.
Discipline
Lodging Need (persons)
Reining
280
Dressage
340
Para Dressage
400
Endurance
600
Eventing
360
Jumping
720
Vaulting
1,500
Driving
150
Chef de Mission
35
Total
4,385
*The ranges that TIEC has used in calculations for lodging, field/spectator needs, barns/stabling, and associated
parking are consistent with the expected range based on past and projected data for horses and athletes. Appendix A
provides information on past Games that TIEC has used to generate approximate expected number of horses/athletes
per discipline. Also, the Sporting Requirements enclosed in Appendix A also provides a table of approximate
number of horses per discipline.
Of this total number of lodging requirements, approximately 1,010 are grooms and there is a
maximum of only two grooms per room allowed. The grooms are required to be lodged in as
close proximity to their horse as possible for caretaking, safety and security reasons.
Another requirement by FEI for the host facility is that accommodations be made for host
countries, judges, and Department of Homeland Security in the form of a designated
office/trailer for each of these entities. TIEC is currently proposing to meet this need by
providing an "Olympic Village" in which approximately 76 trailers and associated parking will
be temporarily set up in this area. There are approximately 70 host countries expected to
participate in the Games and each is required to have their own office/trailer. A substantial
amount of temporary parking in this area is needed/proposed as well which is associated with
17,000 employees, 130 judges, 76 stewards, 100 veterinarians, 1,200 journalists, and 300
photographers that will need to have parking on a daily basis during the Games. This area will
also serve as a temporary construction/staging area prior to the Games and will be converted to
farmettes post -Games. Based on these requirements for lodging and the Olympic Village, a set of
selection criteria has been clarified below to determine the most appropriate plan for lodging that
meets TIEC short term and long term goals.
Section 2.1: Lodging Selection Criteria (LSC)
LSC #l: Capacity
As noted above, TIEC has obligations to acquire/provide lodging for the athletes and their
support team and has a need to find/create lodging for approximately 4,385 people. For the
10

purposes of this selection criteria and subsequent alternative analysis discussion, the 1,010
person need for the grooms will be the focus since the proposed impacts to aquatic resources are
associated with creating lodging for these grooms in the short term.
There are several hotels planned on the site that range from moderate to more luxurious hotels
and range in distances from the main facility and where the horses will be located. The Overall
Site Plan (Figure 3) shows the locations of planned hotels on the site and their proposed height of
4 -stories which is the maximum allowed by Polk County. The lodging options available to meet
this 1,010 person need would be the Stable Horse Inn (250 occupancy), the proposed White Inn
(200 occupancy), Village Hotel #2 (200 occupancy), and the RV and modular trailer
accommodations (356 occupancy) since those are the most economical/moderate
accommodations. There are other hotels and lodging planned/shown such as the Salamander
Hotel, Village Hotel #1 and rental cottages/houses but these would not be appropriate lodging for
the grooms and these areas will be used to meet lodging requirements for the remaining 3,375
person need such as the athletes, veterinarians, National Federations, judges, etc.
LSC #2: Proximity
Grooms need to be in close and potentially immediate contact with their horse, proximity of their
lodging is a critical selection criteria as well. Off-site lodging where the groomsmen would have
to travel to have access to their horse is not an option and the TIEC would not be able to fulfill
their obligations to the FEI to host the Games. Also there are security, safety and quarantine
considerations as well that dictate that the lodging for the grooms be in as close proximity to
their horses.
LSC #3: Adheres to local zoning/ordinances
There are several local zoning and county ordinances that must be adhered to when
siting/designing the proposed hotels such as height requirements and also requirements for
parking in regards to number of required spaces and proximity of spaces to the hotel. Currently,
no hotels on the site can exceed 4 -stories and would not be able to get approvals/variances from
Polk County to do so.
LSC #4: Long Term Development Plan
Based upon historical precedents for attendance/participation in the Games and the need for
lodging generated from these past events, TIEC has pursued a business/development model for
the facility that will incorporate the required on-site lodging to the extent practicable for both the
Games and future operation of the facility. TIEC's goal is to not construct/build anything that
cannot be used in the long term. TIEC has attempted to create a development model for this
facility that will meet its' requirements for the Games but also just as importantly serve the long-
term strategic and organizational goals of the facility. As noted in Section 1. 1, there are many
large and frequently planned/scheduled events that will utilize any lodging constructed for the
Games. Also, as part of TIEC long term use for this area in particular of the facility, they are
expanding their reach/marketing to `western horse sport' which includes barrel racing, reigning,
11

cutting, and rodeo. TIEC is expecting to host the International Reigning Championships which
will actually generate more horses/athletes using this area than the Games.
Section 2.2: Lodging Alternative Analysis
In order to determine if the least damaging practicable alternative has been chosen, the following
options for meeting the lodging need associated with hosting the Games was evaluated in
relation to the selection criteria outlined above. The table summarizes the alternatives evaluated
and their relationship to the selection criteria. An "x" was placed under the criteria if that
alternative was determined to meet that criteria.
*Calculated as a percent increase or decrease of stream channel impacts compared to the overall proposed impact of
4,334 linear feet of stream channels.
Lodging Alternative #1 (From Application) — Utilize Parking Inside Olympic Village (Sheet
1 of Appendix C)
As included in the previous application, this alternative proposed that the parking needed for the
White Horse Inn hotel be located within the Olympic Village area which would reduce impacts
to stream channels in this area by 803 linear feet and result in an 18.5% decrease in the overall
stream impact. This area is not considered a feasible option for hotel parking for several reasons.
The area within the Olympic Village will be utilized for parking needed for the 76 trailers that
will be located within the village along with the temporary parking needed for 17,000 employees
and 1,500 journalists/photographers, etc. This Olympic Village area cannot be reconfigured
because there is nowhere to move/relocate these required offices to that would be within
proximity of the Games/facility. There is also nowhere to move the necessary
staging/construction areas that will utilize this area to prepare for the Games. Also, if the hotel
parking was moved here, it still would not meet the county's ordinance of providing parking
within 400 -feet of the hotel and this area could not be converted to farmettes post -Games which
is part of the long-term plans for this area.
Lodging Alternative #2 (From Application) - Construct Retaining Walls (Sheet 2 of
Appendix C)
This alternative was also included in the previous application and reduced impacts by 373 linear
feet of stream channel by constructing a retaining wall which is an 8.5% reduction in impact
12
Capacity
Proximity
Local
Zoning/Ordinances
Long -Term
Development Plan
Stream Channel
Impacts*
Lodging
Alt. #1
X
X
-18.5%
Lodging
Alt. #2
X
X
X
-8.5%
Lodging
Alt. #3
X
X
-8.5%
Lodging
Alt. #4
X
X
-18.5%
Lodging
Alt. #5
X
X
X
-18.5%
Lodging
Alt. #6
X
X
-18.5%
Lodging
Alt. #7
X
X
-18.5%
Lodging
Alt. #8
X
-18.5%
Preferred
X
X
X
X
No change
*Calculated as a percent increase or decrease of stream channel impacts compared to the overall proposed impact of
4,334 linear feet of stream channels.
Lodging Alternative #1 (From Application) — Utilize Parking Inside Olympic Village (Sheet
1 of Appendix C)
As included in the previous application, this alternative proposed that the parking needed for the
White Horse Inn hotel be located within the Olympic Village area which would reduce impacts
to stream channels in this area by 803 linear feet and result in an 18.5% decrease in the overall
stream impact. This area is not considered a feasible option for hotel parking for several reasons.
The area within the Olympic Village will be utilized for parking needed for the 76 trailers that
will be located within the village along with the temporary parking needed for 17,000 employees
and 1,500 journalists/photographers, etc. This Olympic Village area cannot be reconfigured
because there is nowhere to move/relocate these required offices to that would be within
proximity of the Games/facility. There is also nowhere to move the necessary
staging/construction areas that will utilize this area to prepare for the Games. Also, if the hotel
parking was moved here, it still would not meet the county's ordinance of providing parking
within 400 -feet of the hotel and this area could not be converted to farmettes post -Games which
is part of the long-term plans for this area.
Lodging Alternative #2 (From Application) - Construct Retaining Walls (Sheet 2 of
Appendix C)
This alternative was also included in the previous application and reduced impacts by 373 linear
feet of stream channel by constructing a retaining wall which is an 8.5% reduction in impact
12

from the proposed 4,334 linear feet of total stream impacts. With this alternative, a portion of the
required number of spaces would have to be located greater than 400 -feet from the hotel and an
additional cost of approximately $400,000 would be required to construct this retaining wall.
This alternative also creates a safety hazard for a heavy traffic area that is a concern as well and
does not substantially avoid/minimize impacts when compared to the overall/total impacts
requested in the application.
Lodging Alternative #3 — Reduce White Horse Inn to 3 -Story
This alternative would construct a 3 -story versus 4 -story hotel and eliminate the required parking
areas needed that extend beyond the required 400 -foot distance since the number of rooms (and
subsequent need for parking for those rooms) would be reduced. However, this would threaten
TIEC's ability (and their obligation) to provide the adequate number of rooms/lodging needed
and additional lodging off-site or outside the proximity needed for the grooms would have to be
found/provided for the Games and likely future events planned for this area.
Lodging Alternative #4: Move White Horse Inn to the West
This alternative would move the White Horse Inn to the west where there is current RV pads
already constructed with electrical and water hookups and where additional RV pads are
planned. This alternative would eliminate 39 existing RV pads and remove the planned
installation of another 63 RV pads. A small portion of these lost RV pads could be added back to
the area to the east where the hotel is being proposed, however this still would not be adequate
capacity to meet the lodging need for the Games and likely future events.
Lodging Alternative #5 — Make Other Hotels Higher
This alternative would allow a shorter White Horse Inn or eliminate its need altogether by
making other hotels higher/more stories. TIEC initially attempted to pursue this option with Polk
County and submitted a conceptual proposal for review. However, due to the strong opposition
and unlikely chance that it would not get approved, TIEC abandoned this concept and has
received zoning approval for all the proposed 4 -story hotels to date.
Lodging Alternative #6 — Relocate Hotel on North Side of Hwy 74
This approximately 24 -acre parcel is located on the north side of Hwy 74 and will have a
vehicular tunnel access under Hwy 74 to be constructed by NCDOT. This parcel is not located
within the main facility and would not allow the grooms to stay within close proximity to the
horses which creates safety and security concerns. Also, this area is proposed to be utilized for
bus, large multi -carrier transportation during the Games and there is nowhere to relocate this
parking to.
Lodging Alternative #7 — Construct Parking Decks
Parking decks have been considered to meet the needed parking for the White Horse Inn. Initial
cost estimates prepared by Odom Engineering indicate that construction of a parking deck for
13

280 spaces associated with the hotel would cost approximately $20,000 per parking space or $5.6
million dollars. Construction of the parking lot as proposed will be approximately $ 680,000
dollars. This includes costs for grading, French drain, paving and stream mitigation. Also, a
similar amount of stream channel would need to be filled to construct the deck as in Alternative
#1 which would only result in an 18.5% reduction in overall stream channel impacts.
It is also very unlikely that zoning approval would be given to construct a multi-level parking
deck since that type of structure does not fit into the County's approved strategic vision plan for
preserving the rural nature of this area. One of the main goals of the development plan for this
facility is to create an atmosphere that is complimentary to a rural setting, specifically an
aesthetic that does not disrupt the viewshed of this area and blends in as much as possible from
vantage points along Hwy 74, from adjacent properties, and from within the facility itself. This
effort is reflected in the design and the look/feel of the permanent proposed structures within the
facility. These goals have been promoted by the applicant as part of their development model but
also to meet local/county standards as well such as height and zoning requirements which are
based on similar goals. As quoted from the Polk County 20/20 Vision Plan (March 2010), the
"vision for Polk County's rural atmosphere and serene natural beauty will be vigorously
protected" and Polk County has been diligent in enforcing height restrictions and sensitive to any
development plans that stray from their adopted vision plan (e.g. tall hotels, parking decks, etc.).
Lodging Alternative #8 — No Build/No Action
This alternative would eliminate the construction of the White Horse Inn and the subsequent
parking/impact needed for this area. While this alternative would result in an overall decrease to
stream channel impacts by 18.5% it would not meet the overall purpose/need for the project as
proposed and jeopardize the hosting of the 2018 World Equestrian Games by TIEC.
Preferred Alternative
The preferred alternative proposes filling 803 linear feet of stream channel and 0.09 acres of
wetlands in order to construct a parking lot for the White Horse Inn. This plan/impact has not
changed since the previous submittal and detailed impact drawings have been included the show
the proposed French drain and construction sequencing. Based on the information and discussion
above, this alternative was determined to be least damaging and practicable alternative that meets
the applicant's purpose/need.
Section 3.0: Barns/Parking
Approximately 1,072 linear feet of stream channel is proposed in order to construct two barns
(Barns #7 and #8) and associated parking immediately adjacent to the Covered Arena and Warm
Up Ring on the western side of the facility. The Reigning and Vaulting disciplines will be
occurring in these arenas with an expected number of 140 horses/athletes competing in these
events combined. Both disciplines require an indoor/covered venue of at least 5000 seats with at
least three rings of at least 10m each. There is also a requirement for at least two riding/warm-up
areas of at least 20mx40m directly connected to the indoor covered arena. Stabling is required at
the indoor arena for all horses that will compete in each of these disciplines.
14

FEI requires that barns/stables be located within immediate proximity of the competition areas
and that these areas be completely enclosed within a suitably restrictive perimeter. The
barns/stables area must be sufficiently large enough to allow horses to be evacuated from the
stables in an emergency but still remain within the confines of the perimeter. Also, movement of
the horses between the barns/stables and the practice, grazing, and competition areas must be
strictly controlled for safety and security reasons as well. There are also FEI requirements on
specifications on the size of the stalls and support infrastructure (water, restrooms for
grooms/staff, manure areas, feed areas, etc.).
There are a total of 1,200 stalls proposed for the entire facility with 280 of those stalls being
located within Barns #7 and #8 to provide the needed stabling for the Reigning and Vaulting
disciplines. Also, these barns will be used at future events (such as the International Reigning
Championships) which is expected to have more horses using these areas than the Games. The
number of barns/stalls proposed for the entire facility is consistent with the expected number of
horses that will be participating in the Games and in future events for the respective disciplines
and the corresponding need for stables/barns.
Due the proximity requirements for stabling, there are no other practicable alternatives for
avoiding/minimizing impacts to this area. The stabling cannot be moved to the Olympic Village
area, Rental Cottage area or across White Oak Creek since it is too great of a distance, would
allow an unsecured perimeter for where the horses would be kept for these events and/or would
displace other needed/planned infrastructure in these areas. There are no other competition areas
available that meet the Reigning and Vaulting disciplines sporting criteria that these events could
occur within in other areas of the facility (and subsequently use other stabling areas). Reigning
and Vaulting are 2 of the 8 required disciplines that TIEC is responsible for hosting during the
Games and not providing venues/infrastructure for these disciplines would not meet the
applicant's purpose/need.
Section 4.0: Cumulative Impact/Secondary Impacts
Since the date of our previous submittal, there has been a minor impact added associated with the
stabilization of White Oak Creek near a proposed bridge crossing as noted on the attached plans.
This work will involve the construction of four boulder J -Hook Vanes along the north bank of
White Oak Creek in order to stabilize an eroding section of this bank and to help reduce the risk
of the bridge being washed out/damaged during high flow events. Impact numbers/calculations
have been adjusted to include this additional 200 -linear feet of impact. No mitigation is being
proposed for this work since it is associated with bank stabilization and will improve the in -
stream habitat of White Oak Creek. There have been no additional impacts beyond this change
associated with the project to include the residential component of the project.
Also included with this response is a delineation of the 42 -acre parcel (Appendix D) on the south
side of White Oak Creek per Division of Water Quality's request (Question #6 of Request for
Additional Information). This area was previously identified with a road corridor as shown on
the attached plans that will cross White Oak Creek to access a temporary parking area. This area
is part of the TIEC property as shown on the overall plan/impact map. Two stream channels were
15

identified in this area (but outside of the road corridor) for a total of 550 linear feet. No impacts
are proposed in this area with the road corridor shown.
With regards to the potential for other cumulative/secondary impacts, the area where the TIEC is
located is rural in nature and is expected to stay that way in the long-term due to the County's
approved master/strategic planning initiatives. Commercial and development corridors have been
identified in the typical expected areas (along major highways, city centers, etc.). There is on-
going interchange improvements occurring at the Pea Ridge Road and Hwy 74 interchange,
however there are no impacts to stream channels/wetlands associated with these improvements.
Also as noted on the attached plans, there is a vehicular tunnel access proposed under Hwy 74 to
connect a 24 -acre parcel on the north side of Hwy 74 to the main facility. There is approximately
334 linear feet of stream channel on this tract but there will be no impacts to this area associated
with the construction of this tunnel or associated with the parking needed for this area during the
Games. This tunnel will be constructed by DOT and there are currently no detailed plans
available. There is also not any cumulative/secondary impacts associated with
improvements/expansion to the off-site wastewater treatment facility that will be used by TIEC
which has plenty of capacity to handle increased discharges.
There is an interchange improvement planned at the I-26 and Tryon exit but this was already a
planned improvement on the Transportation Improvement Project (TIP) list but may be moved
up in priority due to increased traffic generated from the Games. It is unknown if there are any
impacts to stream channels and/or wetlands associated with this DOT project. Another project
that may incur additional cumulative impacts near the facility is a separate project associated
with an agriculturally exempt irrigation pond which has currently been submitted to the Corps
for review. Approximately 0.28 acres of wetlands and 2,287 linear feet of stream channel will be
impacted in order to construct an irrigation pond for a private horse farm. This farm is not
associated with TIEC and is a privately owned farm that breeds and trains horses for personal
use. Tryon Equestrian Partners, LLC does own/operate an additional hotel in Lake Lure called
"The Lodge". There were initial plans to expand this hotel, restaurant, and marina facility but not
necessarily for the Games. However, this plan has been changed from its original concept and
the currently proposed improvements will include the addition of 34 rooms and parking area
which will all occur in uplands. These improvements may or may not occur in advance of the
Games due a pending lawsuit associated with the expansion.
The development plan/model for the TIEC was specifically designed to concentrate development
within this 1,400 acres and to not have additional impacts/facilities for the Games or other
equestrian sporting events spread throughout the region. The location for this facility to be sited
in Polk County is in large part due to the rural nature of the area but also the long-standing
equestrian culture in this area. We would anticipate that there would continue to be minor
impacts to aquatic resources in the county/region associated with private horse farms at the same
rate as before this facility was proposed due to historical nature of this area being associated with
equestrian farms/facilities.
16

Section 5.0: Stormwater Plan:
The overall site is no longer subject to storm water management rules per Session Law 2017-10
Senate bill 131 signed into law May of 2017. However, TIEC is still committed to adequately
managing storm water from the site so that downstream waters are not degraded.
As part of submitting for a 401 Water Quality Certification from the North Carolina Department
of Environmental Quality (Water Resources Division), the Tryon International Equestrian Center
has been asked to submit a Conceptual Stormwater Plan for the project. This conceptual
stormwater plan is to ensure that the Division can certify downstream water quality will not be
degraded by issuing the permit.
The conceptual stormwater plan being submitted focuses on the planned development and in
particular addresses stormwater from higher density areas (those areas where the impervious area
exceeds 24% of the total land area. It is important to note that TIEC previously constructed 6
storm water treatment facilities (as can be seen on Figure 3- Overall Site Plan).
There are currently four proposed areas that have high density exceeding 24% built upon area.
These areas are the new Stablehouse Inn, the Salamander Hotel, the Tryon Village and the barn
and parking area associated with the White Horse Inn and covered arena expansion and barns.
Sheet 1 of the conceptual stormwater plan shows the Stablehouse Inn site. Curb and gutter will be
installed and stormwater will be collected in curb inlets and area basins. All roof drains will be
connected directly into the stormwater system. The stormwater will be directed to the rear of the
property to prevent increasing the runoff to the front yard of the house across John Sheehan Road
through an existing NCDOT pipe. The last section of piping for this collection system will
discharge at a flatter grade (0.5% or less) into a riprap outlet devise. The ultimate discharge
velocity will be the smaller of the pre -development discharge velocity or 10 feet per second.
Sheet 2 shows the Salamander Hotel conceptual stormwater plan. Curb and gutter will be installed
along the parking lots and drives, and stormwater will be collected in curb inlets and area basins.
All roof drains will be connected directly into the stormwater system. The stormwater will be
directed to the northwest and southwest corners of the site, which is the same direction the drainage
from the pre -developed site flows. For both stormwater outlets, the last section of piping will be
at a grade of 0.5% or less and will discharge into a riprap outlet device. The ultimate discharge
velocity will be the smaller of the pre -development discharge velocity or 10 feet per second.
Sheet 3 shows the area of the site known as The Village. The stormwater plans for this site are
still being developed, and detailed information is not yet available. The stormwater outlet from
this area will connect to an existing NCDOT drainage pipe. Underground detention will be used
to reduce the post -development flow rates to the pre -development discharge.
Sheet 4 shows the Barns and Parking, which is still being developed as well. The stormwater for
this area will be collected and discharged into the creek located just south of this area. As with
the other locations, the discharge velocity will be the smaller of the pre -development discharge
velocity or 10 feet per second.
17

Section 6.0: Mitigation Plan
The table below lists the updated/final linear feet and credit totals based on the type of mitigation
being performed for both the Phase 1 and Phase 2 of Harmon Dairy. The table presented in the
initial application is no longer valid and should be replaced with the table below. The initial table
assumed that Phase 3 of Harmon Dairy would be utilized which is no longer the case. Phase 1 of
the Harmon Dairy Mitigation project was approved as part of the previously authorized 404/401
permit on January 11, 2017 and provides 1,126 stream credits (plan not re -submitted with this
response). The Harmon Dairy Stream Mitigation Phase 2 plan (Appendix F) is included with this
submittal and provides an additional 3,879 stream credits.
Stream mitigation efforts at the combined Harmon Dairy (Phase 1 and Phase 2) will generate a
total of 5,005 stream mitigation units. The total mitigation need as referenced in the original
application is 8,088 SMU's (based on 4,044 linear feet of stream channel impacts that require
compensatory mitigation at a 2:1 ratio). The remaining 3,083 stream mitigation credits will be
purchased form the Box Creek Mitigation Bank and a credit reserve letter is also included in
Appendix F indicating that they have adequate credits available for purchase. Also included in
Appendix F is the delineation information and jurisdictional request information for Phase 2 of
Harmon Dairy.
18
Linear Feet
Mitigation Activity Ratio
Total
Stream
of
Type
(X: 1)
Credit
Miti ation
Phase 1
UTs to Mary's
1,126
Restoration
1:1
1,126
Branch
Phase 2
1,758
Restoration
1:1
1,758
Marys Branch
Phase 2
2,660
Enhancement 1
1.5:1
1,756
UTs to Mary's
Branch
Phase 2
665
Enhancement 2
2.5:1
266
UTs to Mary's
Branch
Phase 2
981
Preservation
10:1
99
UTs to Mary's
Branch
6039
Total Mitigation from Harmon Dairy
5005
Box Creek Mitigation Bank - credits
3,083
Total Linear Feet of
Total Mitigation Credit Provided
8,088
Mitigation
18

Section 7.0: Conclusion
In summary, the impacts associated with the hotel/parking areas, barns/parking, and
multipurpose field have not changed since the original submittal as summarized in the table
below. The purpose of this response was to clarify many of the questions/comments relating to
the purpose/need of the proposed impacts and why other lesser -damaging alternatives are not
considered practicable given the project's overall purpose need. Another purpose of this response
was to outline and innumerate the varied and complex requirements/criteria that drove many of
the applicant's decisions related to determining what facilities and infrastructure is needed and
where to host the Games but also future competitions which is crucial to the continued operation
of this facility and the subsequent benefits to the region's economy. Ultimately, it is the
applicant's responsibility to know their own marketibusiness and what their needs are based on
organizational and strategic goals. Many of the questions/comments relating to the criteria
regarding location/specifications /number of lodging, barns, parking, stalls, vendors, restrooms,
etc. has been determined by the applicant in order to respond to either 1) criteria, requirements,
and expectations from the FEI as part of the approval process to host the 2018 World Equestrian
Games and/or 2) complement TIEC's long term planning horizon and strategic goal of
expanding the interest for equestrian sporting to a broader market. The selection of TIEC to host
the Games substantially expedited their long-term goals/plans to a much shorter time frame but
has not changed them nonetheless.
While we understand the role of the review agencies to adequately evaluate potential alternatives
on the site, it should be noted that hosting an event of this scale (e.g. an `Olympic' size event)
has logistical and organizational considerations and also economic ramifications that most type
of applications/requests are not subject to. The amount and level of coordination required
between TIEC, FEI, surrounding businesses/communities, and local/state/federal
authorities/agencies among many others is monumental. The review agencies cannot reasonably
expect to become `experts' in the field of planning/organizing this type of events or similar
competitions. Essentially some discretion/acknowledgement should be given that the
applicant/developers are the experts in this field and expressly know what criteria/need that they
have to meet/provide for.
With regards to economic impacts, Appendix G provides additional information from experts in
this field and their opinions related to the economic impacts generated from this proposed
developmentibusiness. As noted in the diagram, the development of the Tryon International
Equestrian Center and associated businesses leverages benefits from a variety of different
`clusters' in the services, suppliers, and institution categories versus economic impacts being
located in one sector/category. As noted in this diagram, the continued success and expansion of
the TIEC will help leverage economic gains throughout multiple sectors in the region to include
hospitality/tourism, agribusiness, professional, community development, high education,
manufacturing, construction, and infrastructure. Ultimately, the continued operation and
expansion of the TIEC is expected to create approximately 6,600 jobs and a total of economic
impact of nearly $1 billion dollars.
19

Currently Proposed
Impact Label
Stream (Permanent)
Stream
(Temporary)
Wetland
(Permanent)
E1*- Multipurpose Field
393 l.f.
--------
--------
E2* - Multipurpose Field
53 If
--------
-------
E3- Multipurpose Field
1,608 If
--------
--------
E4 — Hotel Parking
803 If
--------
0.09 acre
E5 — Barns/Parking
1,072 If
--------
---------
B 1 —Bridge J -hooks
2001.f.
--------
-------
Currently Proposed Total
4,1291.f.
1201.f.
0.09 acre
Previously Permitted/Completed
UC (Utility Crossings 1, 3, 4,
1201.f
-------
P6**
2901.f.
---------
---------
WO 1-3 * * *
115 1. f
---------
--------
Cumulative Total
4,5341.f.
1201.f.
0.09 acre
*E1 and E2 were previously authorized by permit dated January 11, 2017 but was suspend due to pending
modification for impacts included in this request (E3, E4, and E5).
** Previously approved impact under AID: 2013-02262 for the equestrian center which was mitigated for.
***Road crossings impacts associated with White Oak Plantation authorized under AID: 2006-32154-375 but were
not mitigated for but is being mitigated for with this application.
20