20131200 Ver 5_Response to USACE Add Info_20170811

Burdette, Jennifer a
From: Kichefski, Steven L CIV USARMY CESAW (US) <Steven. L.Kichefski @usace.army.miI>
Sent: Friday, August 11, 2017 3:22 PM
To: Burdette, Jennifer a
Subject: FW: Corps TIEC Meeting Summary: 07/06/17
Attachments: image001jpg; [Non-DoD Source] TIEC Response to Corps Comments and Draft EA
So I met with Amanda/Clement on July 6th to go thru info still needed after their June 12th comment response
(about the same issues you/Karen/I discussed) and they sent me a meeting summary as a way of documenting
the additional info needed. Here is the back and forth of that and I attached their July 18th response. I will
forward the next additional info comment and response in a separate email.
Steve
-----Original Message -----
From: Kichefski, Steven L CIV USARMY CESAW (US)
Sent: Wednesday, July 12, 2017 3:31 PM
To: 'Clement Riddle' <[e-mail]>
Cc: Jones, M Scott (Scott) CIV USARMY CESAW (US) <[e-mail]>
Subject: RE: Corps TIEC Meeting Summary: 07/06/17
Clement,
I think your summary sounds good with two clarifications/notes below:
1) Multipurpose Field Alternative #2: Yes, this discussion focused on feasible alternatives with the long-term
polo field separate from the temporary endurance race, but included the near east area (possibly straddling the
gas line if that is a safe/feasible/practicable alternative) and/or into the residential area further east if it is
practicable. This discussion could include the construction feasibility/practicability of these areas and how
losing a few residential lots would make it not practicable for such a large mixed development project? It seems
this alternative would meet Multi-purpose field criteria #4 (Ability to reconfigure field) and MFC#6 (Long term
use), but it better justification is needed to show why it wouldn't meet MFC#2 (accessibility). It is unclear how
the following statement from this alternative is substantiated, "However, more importantly this location would
separate the future polo field from the main facility." How would this distance make the field not a viable
alternative? Is the polo field as proposed not going to have its own supporting infrastructure
(restrooms/concessions/access/etc). Is it not still readily accessible by golf cart or shuttle for the games or does
it even need to be directly connected for future polo matches?
2) Lodging Alternative #5 (or Lodging Alternative #3 depending on how you choose to look at it): Remember
to include the discussion of whether any hotels could be built wider across the site even if it means sacrificing

or rearranging other proposed development (if not a viable alternative this may need business
model/practicability justification).
Just a reminder that I'll be in the office all next week, before I'm out of the office from July 24 -Aug 8. Feel free
to contact me with any questions.
Regards,
Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
(828)-271-7980 Ext. 4234
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure
we continue to do so, please complete the Customer Satisfaction Survey located at our website at
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0 to complete the survey online.
From: Clement Riddle [mailto:[e-mail]]
Sent: Monday, July 10, 2017 10:29 AM
To: Kichefski, Steven L CIV USARMY CESAW (US) <Steven. L.Kichefski @usace.army.mil>
Subject: [Non-DoD Source] Corps TIEC Meeting Summary: 07/06/17
N

Steve,
Below is a summary of our meeting on Thursday July 6th. Purpose of meeting was to discuss information
submitted on June 15, 2017 in response to Corps and DWR comments/questions regarding mainly
avoidance/minimization efforts and on-site alternatives and configurations of the proposed long-term polo field
and lodging impacts.
Long-term Polo Field - essentially there needs to be an alternative analysis that separates the long-term polo
field from the temporary endurance event needed for the Games.
1) Multipurpose Field Alternative #1 - Need to provide additional information as to why the existing large field
can not be used for a long term polo field once the Games are completed. Need to address in more detail the
existing infrastructure to the south of this existing field and if it can be incorporated into a permanent polo
field.
2) Multipurpose Field Alternative #2 - Need to discuss this alternative in more detail and show why this field
can/can not be moved immediately to the east (versus in the proposed residential areas as an additional
alternative and what infrastructure would be required (along with cost) to have this field in this location. Also
need to address the financial consequences of any lots lost as a result of moving the this polo field and how it
affects the overall development plan in more detail (which is also for alternative #6 and #7).
3) Multipurpose Field Alternative #3 - Based on the results of the analysis of comment #2 above, then there
may need to be additional information provided as to why the temporary infrastructure needed for the
endurance course can not be moved/puzzled to avoid/minimize impacts if the polo field can be moved to the
east.
4) Multipurpose Field Alternative #6 - Need to provide more detailed information that shows if the polo field
can fit in this area. If it is determined that it can fit, then more information would need to be provided as to why
the farmette areas can not be moved to other areas and/or why the loss of farmettes would not be considered
practicable to the overall development project purpose/need.

5) Multipurpose Field #7 and #8 - Need to address in further detail why losing lots could not be considered a
practicable alternative and what permanent infrastructure (along with cost) would be needed to move the long-
term polo field in these areas.
Lodging Selection Criteria and Alternatives Analysis:
6) Proximity Selection Criteria - Need to provide more information on the industry standard from past Games
and what other venues have done to meet the FEI lodging requirements.
7) Adheres to Local Zoning Selection Criteria - Potentially remove this selection criteria based on Corps
comments
8) Alternative Analysis Table - Need to add a column that depicts # of linear foot change versus overall
percentage. Needs to match table in Multipurpose Field Alternative Analysis.
10) Lodging Alternative #4 - Need to discuss in further detail the practicability and feasibility of moving the
White Horse Inn further to the west and what the cost and infrastructure implications would be for losing RV
lots and if those lots can be regained somewhere else (further to the west) or reconfigure the Olympic Village.
Need more information on the infrastructure requirements for the hotel and what additional infrastructure
would be needed if this hotel is moved further to the west. Also another new alternative that should be
discussed in keeping the location of the White Horse hotel and propose moving/losing the temporary cabins to
allow for needed parking and how this alternative would affect lodging needs and overall purpose/need.
11) Lodging Alternative #5 - Need to explore this alternative in more detail despite the zoning restrictions on
height. Need to provide information on if this alternative to make the White Horse and/or Stable Inn higher
would meet demand and where associated parking would be located.
Barns Avoidance/Minimization:
12) Need to discuss if the barns can be moved on the north side of the covered arena between the RV area and
show this area in more detail.

We will be submitting this information to you as quickly as possible.
Clement
32 Clayton Street
Asheville, NC 28801
Office: 828-698-9800
Mobile: [phone]
[e-mail] <mailto:[e-mail]>
BlockedWWW.CWENV.COM <Blockedhttp://www.cwenv.com/>

Burdette, Jennifer a
From: Amanda Jones <[e-mail]>
Sent: Tuesday, July 18, 2017 6:54 PM
To: Kichefski, Steven L CIV USARMY CESAW (US)
Cc: Jones, M Scott (Scott) CIV USARMY CESAW (US); Clement Riddle
Subject: [Non-DoD Source] TIEC Response to Corps Comments and Draft EA
Attachments: TIEC_071817_HQ SOFEA Template 3 Oct.docm; TIEC_ResponseCorpsComments_
071817.pdf
Steve,
Attached is the response to your comments from our July 6th meeting. I've also attached a draft version of the
new template EA. I took the relevant text from your previous EA and inserted in the applicable sections and
then updated with the information from the permit re -submittal and response to comments (both June and now
this responses). Highlighted areas shows changed/added text.
As an update, we responded to some minor questions from DWR about the storm water plan with a submittal
this morning so we anticipate the 401 soon.
Also, Sharon Decker may be giving you or Scott a call later this week to see if you have had a chance to review
this latest information and get a timeline on permit issuance. Clement is out of the office this week on vacation
and I will no longer be available after today so if you have any comments/question please direct to Clement.

July 18, 2017
Mr. Steve Kichefski
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-2638
RE: Tryon Equestrian Partners, LLC, Tryon International Equestrian Center
(+/- 1,405 AC) Individual Permit Request for Additional Information
Response, Polk County, North Carolina
Dear Mr. Kichefski,
Enclosed is information pertaining to your request for additional information from an in-person
meeting on July 6, 2017. As stated during the meeting, many of your comments/questions were
answered with our recent submittal however, there were a few outstanding items that you requested
clarification on as they pertain to on-site alternatives discussions. We believe the information
enclosed satisfies the Corps concerns and documents that the proposed impacts are associated with
the least damaging and practicable alternative. We appreciate any assistance to finalize your
decision and issue an authorization for the proposed work as soon as possible due to time sensitive
nature of this project.
Respectfully,
R. Clement Riddle, P.W.S
Principal

Based upon discussions during our July 6, 2017 meeting, many of comments related to
separating out the analysis of potential alternatives for the long-term polo field from the
Endurance Event associated with the World Equestrian Games and are separated and
summarized below. The enclosed figure shows the locations of the alternative long-term
polo fields discussed below (with the exception of Comment #1).
Comment #1: For the Multipurpose Field Alternative #1, additional information needs to he
provided as to why the existing large field cannot he used, for a long term polo field once the
Games are completed. The applicant needs to address in more detail the existing infrastructure
to the south of this existing field and if it can he incorporated into a permanent polo field.
As noted in the application, this field cannot be expanded to the south without removing
existing infrastructure already in place and also eliminating the current use of the field. Currently
there is one warm up ring (400' X 400') in size and associated stabling/barns that are used
currently for events and will be used for the Games. One barn area and associated parking is
located on the west side of the warm ring and another barn area is located on the south side of
this warm up ring. To re -configure this field to the needed 900'X 480' size, over half of the
warm up ring would be lost. More importantly, the opportunity to use this field for other events
as it is currently being used now would be lost and eliminate these events/services from TIEC.
This field currently holds `hunting/derby' events that occur routinely from May -November. This
would be the same time that proposed polo events would be happening as well so there would be
significant scheduling conflicts that would preclude them from being used for both events long-
term. Also by trying to use this existing field, there could not be the exhibition polo game on
this field during the Games since this field will have a sand center and grass/sod is required for
polo. Also if this field was used in the long term, it could not be ready until the following Spring
(2019) at least until after the Games have concluded since the temporary stadium seating would
have to be removed which takes approximately 2 months and sod would have to be placed on the
field after the Games and allowed to regrow until the following Spring (2019). Also the existing
infrastructure would have to be removed and the area re -graded which would likely lengthen this
timeline beyond when this field would be needed/used. Based on this information and the
information in the previous submittal, we believe that this comment has been addressed and this
alternative is not considered practicable.
Comment #2: For the Multipurpose Field Alternative #2, additional information needs to he
provided to show why this field can or cannot he moved immediately to the east before the
residential area/lots begin and also elaborate on how losing residential lots affects the overall
feasibility of this large mixed use development if it cannot he moved to the area where lots would
not he lost. This discussion should also address in more detail as to why these alternatives would
not he considered practicable if this long-term polo field is not immediately adjacent to the main
facility and describe any infrastructure that would he needed if this field was separated from the
main facility.
The enclosed figure shows the only location large enough to separate/relocate the long-
term polo field to the east of the currently proposed location. This field size is the industry
standard of 900' X 480' with a perimeter of parking approximately 60 -feet in width that would
be needed surrounding the field. For polo events at these fields located away from the facility,

additional/separate parking would be needed for spectators/participants since it is too far of a
distance from the main facility (0.5 mile approximately) to expect spectators/participants to
walk. Horses would be brought in by trailers and off-loaded for the events and then re -loaded
and taken to barns elsewhere on the facility. There would be no other infrastructure planned
other than electrical for water/sewer for bathrooms, water for spectators/horses, etc.
The enclosed plan depicts the field in a hatched shading with the parking shown around
the perimeter and does not include/show grading but impacts discussed below were estimated by
the engineer based on calculations from a rough grading plan for this field/area. Ultimately,
approximately 730 linear feet of stream channel would need to be filled in a tributary to the east
and a small tributary that drains into White Oak. Also based on grading required, a portion of
White Oak Creek would need to be filled/armored/relocated in the southwest corner of the field.
This location also cannot avoid the existing gas line and construction at this location would not
be allowed by the gas/utility company. This location is approximately 0.5 mile from the main
facility and it is unlikely that many of the spectators in the main facility area (especially those
with small children/families) would venture to this area since there are no facilities/amenities
like there are at the closer preferred alternative and it would be cost prohibitive and
unnecessarily redundant to create the same amenities that are at the main facility.
Notwithstanding these issues noted above, this location would substantially alter the
residential development plan in this area and eliminate road access to connect residential areas to
the north and south of the field. To connect these two areas there would need to be an additional
road crossing impacts to the east (where the two cul-de-sacs are shown) which would impact an
additional 200-400 linear feet of stream in an undesirable location at/near the confluence of
several perennial stream channels if bridges/bottomless culverts were not an option as
determined by a more detailed engineering study. This field location would also eliminate
approximately 8 lots and eliminate $2,400,000 in revenue from selling these lots at $300,000
each which is a modest/low estimate.
It should be noted that separation of this field from the main facility for the purposes of
this discussion pertaining to this alternative and the ones below (Comment 45) did not
include/address the addition of redundant infrastructure and amenities at this polo field location
since logistically and financially it is impracticable to expect that similar facilities would be built
around this field that is at the main facility. There is not the room for this to occur in this area (or
with the other locations across White Oak Creek) when taking into account how large the field is
just by itself (10 acres). Also from a business/development perspective, it is the applicant's
opinion that this long-term polo field cannot be viewed as a standalone/independent amenity
which is what the Corps is requesting that the applicant do with this analysis and the Corps
concerns over the `proximity' selection criteria. This proximity/accessibility of this field has
always been a consideration for the siting of this field because of the crucial role that it plays
with overall long-term success of the facility and has always been presented as a significant
consideration when master planning this facility. The applicant understands the responsibility of
the Corps to analyze and assess other potential alternatives that might have lesser impacts to
aquatic resources. However, the applicant also believes that this analysis should be limited to
reasonable alternatives and that the determination of those alternatives as being considered
feasible/practicable is achieved when using the selection criteria set forth by the applicant based

on their long-standing knowledge, experience and expertise in these matters. Based on this
information, the location of this field as shown to the east of the preferred alternative is not
considered feasible or practicable and the applicant believes they have adequately addressed your
concerns/comments.
3) Multipurpose Field Alternative #3 - Based on the results of the analysis of comment #2 above,
then there may need to he additional information provided as to why the temporary
infrastructure needed .for the endurance course cannot he moved/puzzled to avoid/minimize
impacts if the polo field can he moved to the east.
Based on the discussion above, we believe that is not practicable to consider moving the
field to the east as a viable alternative for any further discussion/analysis therefore this comment
is no longer relevant.
Comment #4: For Multipurpose Field Alternative #6, please provide more detailed information
that shows if the polo field can fit in this area. If it is determined that it can fit, then more
information would need to he provided as to why the farmette areas cannot he moved to other
areas and/or why the loss of farmettes would not he considered practicable to the overall
development project purpose/need.
See enclosed plan showing the location of this alternative. Based on this information, the
footprint alone from the field and parking would extend into White Oak Creek. If parking was
removed from the south side of the polo field, fill slopes would still extend into White Oak
Creek. This location would also eliminate the existing cross-country trail that is located in this
area by White Oak Creek and provides a trail connection for horses from the western end of the
facility to the eastern end. Based on this information, we do not believe that location is feasible
due to the impacts to White Oak Creek and loss of this existing cross country course independent
of the loss of the future farmettes that would occur.
Comment #5: With regards to Multipurpose Field #7 (west) and #7 (east), the applicant needs to
provide further detail as to why losing lots could not he considered a practicable alternative and
what permanent infrastructure (along with cost) would he needed to move the long-term polo
field in these areas.
These locations on the other side of White Oak Creek are shown in the attached plan. For
Field 47 (west), there is a limited area to place this field due to an parcel not owned by TIEC
which is an existing private residence (noted in red on the plan) that is not for sale or available to
purchase. This location would require a bridge to be constructed to connect it to the main facility
which would cost approximately $750,000. While there would be no direct impacts to stream
channels/wetlands for this location, the location would also be located approximately 0.5 mile
from the main facility and be separate from the amenities offered/used by spectators/participants.
There would also be approximately 15 lots lost directly from the construction from the field itself
and another 13 lots lost since the remaining area to the south would be too small and no longer
appropriate/marketable as residential lots which would result in a loss in revenue of
approximately $8,400,000 which significantly threatens the long-term viability of the project.
H

For Field 47 (east), this field has similar feasibility issues as with the field to the west. A
bridge would be needed as well to connect it to the facility ($750,000) and there is an existing lot
already sold in this area that would need to be purchased back. The location of this field would
result in minor wetland impacts (approximately 0.25 acre) but no stream channel impacts.
Approximately 25 lots would be lost in this area which would result in a loss in revenue of
approximately $7,500,000. This location would also be located approximately 0.5 mile from the
main facility and be separate from the amenities offered/used by spectators/participants.
The following comments pertain to questions regarding the Lodging Selection Criteria and
its associated Alternatives Analysis:
Comment #6: For the Proximity Selection Criteria, additional information should he provided on
the industry standard from past Games and what other venues have done to meet the FEI lodging
requirements.
Due to lessons learned from past events, the FEI has emphasized that the need for easily
accessible and nearby lodging is a strong consideration when determining future hosts for the
Games. Different approaches to lodging have been utilized in the past based on the capabilities
of the hosting facility. For example, during the 2014 Normandy, France Games there was no
concentrated lodging since there were was no concentrated facility for the Games and events
were scattered throughout the region which was a major complaint/disadvantage to these Games.
In 2010 at the Kentucky Horse Park, lodging needs for groomsmen and caretakers were met by
bringing in FEMA trailers to the facility which were costly and sub -standard accommodations.
Also, it should be noted that the Kentucky Horse Park is a state owned/operated facility so it is
not likely that this facility will ever be expanded to provide more than temporary lodging in the
event that the Games are held there again. In 2006, the Games were held in Aachen, Germany
which is located in a large metropolitan area with a multitude of accessible lodging nearby to the
facility in which the Games were held.
TIEC will be unique in that it can meet the lodging needs of the groomsmen/caretakers
for the Games on the site which makes this ability even more crucial when being considered to
host the Games again in the future. Based upon feedback provided by FEI to the applicant, this
ability will help ensure that the World Equestrian Games will be held again at TIEC likely in
2026 since there are no facilities in the U.S. (or abroad) that can compare with the capabilities of
TIEC. This proximity/access criteria is also important to the long-term lodging plans of TIEC as
well. The proposed location of the hotel will be the closest lodging for a majority of where the
barns/stalls are located on the western side of the facility and is within easy walking/golf cart
access to the other amenities in the facility. This hotel will be located at the main gate/entrance to
the facility and near the check-in for the horses/athletes. With its location on the western side of
the facility, it will meet TIEC's long term plans for expanding western style equestrian sporting
events where it is likely that spectators and participants will utilize this hotel and the surrounding
RV/cabins since it will be designed/planned to accommodate that demographic/market.
Also in regards to the option of providing temporary housing in the form of FEMA
trailers similar to that of the 2010 Games, this option was considered for the purposes of this
discussion/response. In order to meet the expected need for the Games, the cost for acquiring the

number of needed trailers would be approximately $3,000,000 and they would have to be located
off-site since there is nowhere to locate these trailers within the facility which creates a
undesirable situation with groomsmen having constant/easy access to the horses. This option
would also not meet the applicant's long-term need for lodging in this area of the facility as
discussed above.
Comment #7: For the Adheres to Local Zoning Selection Criteria, please remove this selection
criteria for consideration when evaluating if alternatives are considered practicable.
The attached draft Environmental Assessment provides a modified alternatives analysis
in which this criteria was removed from consideration. While they are still discussed as a factor
for consideration, they are removed from the selection criteria.
Comment #8: For the Alternative Analysis Table, there needs to he column that depicts the # of
linear foot change versus overall percentage.
The attached draft Environmental Assessment provides a modified alternatives analysis
in which this table has been modified as requested along with the corresponding
discussions/references.
Comment # 10: For Lodging Alternative #4, please discuss in further detail the feasibility and
practicability of moving the White Horse Inn further to the west and what the cost and
infrastructure implications would be for losing RV lots and if those lots can he regained
somewhere else (further to the west) or reconfigure the Olympic Village. Information should he
provided on the infrastructure requirements for the hotel and what additional infrastructure
would he needed if this hotel is moved further to the west.
Also another new alternative that should he discussed is keeping the location of the White Horse
hotel and propose moving/losing the existing cabins to allow for needed parking and how this
alternative would affect lodging needs and overall purpose/need.
As noted in the application, there are approximately 39 existing RV spaces to the west of
the currently proposed location for the hotel which are comprised of a concrete pad, electrical
and water/sewer hookups. The cost to relocate/rebuild these existing spaces somewhere else on
the property would be approximately $1,560,000 ($40,000/space) but there is nowhere else to
relocate these spots to. The stream channel immediately to the west of this area is the property
boundary and the topography adjacent to the creek would be too steep to construct an area large
enough to relocate these spaces plus the additional ones planned. The applicant has attempted to
purchase the property on the other side of the stream channel but the property is not for sale at
this time. There is also not the opportunity to re -configure the Olympic Village for the reasons
noted in the recent submittal.
Essentially, relocating the White Horse Inn and associated parking to this area would
eliminate this RV parking area altogether. The existing RV parking (and cabin rentals) in this
area are routinely sold out already on a weekly basis during the May -October season already
which is why the additional 63 spaces are planned/being constructed. By removing this lodging

type in lieu of the proposed hotel, there is a significant loss in capacity and revenue. The RV and
cabin rentals are reserved on a weekly (versus nightly) basis and cost approximately
$1,500/night. If the White Horse Inn is moved here, not only will the existing 39 RV spaces be
removed, the remaining planned RV spaces (63 approximately) would not be able to be
constructed since parking for the hotel would eliminate this area. This would result in a loss in
revenue of approximately $3,672,000. Also by eliminating this lodging, there would be a
shortage in rooms needed for the upcoming Games so the applicant would not be able to fulfill
its obligations to the FEI.
The other potential alternative noted was to remove the surrounding cabin lodging that is
in the currently proposed location of the White Horse Inn and used that for parking. This would
result in the loss of approximately 54 cabins that also could not be relocated elsewhere on the
property due to same reasons noted above for the RV spaces. This would also result in a loss in
revenue of approximately $1,944,000. This area would also likely not be large enough to
accommodate the required number of parking spaces for the hotel and would likely still encroach
into the stream channel/wetland but impacts would be less than the proposed plan. Also by
eliminating this lodging, there would be a shortage in rooms needed for the upcoming Games so
the applicant would not be able to fulfill its obligations to the FEI.
It is important to note how a diversity in lodging fits into the long-term development and
marketing plans for TIEC. Since this facility is equestrian sports based but with a focus on
creating a spectator experience for everyone that visits the facility, a diversity in lodging types is
important to the long-term success of the facility. Based on market analysis and experience,
many of the customers that will use the facility may prefer one lodging type over the other
depending on their needs such as what/which events they will be attending, if they will be
entering a horse in a competition, or if they are just purely a spectator that is drawn to the area
for an overall experience to include the other proposed amenities in the planned mixed-use Tryon
Village area. Since this area is where the `western' style sporting will be concentrated, RV and
cabin lodging is needed since it is more complementary to this type of customer base versus
those that are there to view/participate in polo matches and would likely be staying at other
hotels/lodging such as the Salamander Hotel or one of the hotels within the Tryon Village area.
Even if there was available space somewhere else on the property to relocate RV/cabins to, it
would be well away from this area where the customers using these facilities would have to be
lodged which does not provide easy accessibility/proximity between the lodging and
customers/participants which is one of the main goals of this development and important to its
long-term success. This hotel is also proposed to be located at the main entrance of the facility at
the current location of the existing check-in/registration office for all lodging on the site which is
also a crucial location for customers/spectators to easily access (by foot or golf cart) the main
area of the facility. Relocating this hotel further to the west, would further remove customers
from access to the facility and make it more difficult to easily access other parts of the facility
without driving which again contradicts TIEC's long term development goals for a successful
facility based on their marketing research and extensive development experience in this area.
Comment #11: For Lodging Alternative #5, please explore this alternative in more detail despite
the zoning restrictions on height. Additional information is needed to determine if this alternative
to make the White Horse and/or Stable Inn higher would meet demand and where associated
7

parking would be located. Also, the applicant should address if making this hotel wider (versus
higher) would provide a practicable alternative.
Notwithstanding the zoning/height restrictions enforced by the County, increasing the
capacity of the White Horse Inn by increasing the height would not reduce impacts since even
more parking spaces would be required for this hotel. In its currently proposed location if the
hotel size was increased by 25% by adding another floor, then there is nowhere else for this
additional/required number of spaces to go and still be accessible to the hotel. This is the same
case for the Stable House Inn where increasing height would increase the needed parking and
there is nowhere to place this parking. Making the hotel wider encounters the same issues since
capacity is being increased so again parking would need to be increased as well and again there
is nowhere to locate this additional parking.
The following comments pertain to questions regarding the impacts associated the
construction of two additional barns and parking.
Comment #12: The applicant should discuss if the barns can be moved on the north side of the
covered arena between the RV area and show this area in more detail.
As noted in the application, approximately 1,072 linear feet of stream channel will be due
to impacts for the construction of two barns and associated parking to serve the covered arena
and warm up ring in this area which is where western style equestrian sporting will occur for the
Games and in the long-term. Enclosed is an additional figure that depicts this area in more detail
as requested. The barns/associated parking have been located on the western side of the arena to
provide a needed separation between horse/participant traffic and other traffic associated with the
lodging and general entrance to the facility on the north side of the arena. Since this area is at the
main entrance to the facility, Barns 8 and 9 will already be the closest barns to heavily trafficked
areas compared to the other barns within the facility which are located on the back sides of the
arenas and away from heavily trafficked and non -participant areas. Moving one of these barns
would remove needed parking on the north side of the arena and place the horses/participants in
an unsafe and heavily trafficked area when trying to unload/prepare the horses. A barn on the
north side of the arena would also make it difficult and unsafe for the horses in this barn to get to
the warm-up ring before a competition since it is on the south side of the arena. As noted in the
plan, there is also an existing pump station in the southwest corner adjacent to the warm up ring
which also precludes the opportunity to re -configure the barn locations.
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PROJECT NUMBER SHEET
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P-0880

CE SAW — RG -A (File Number, SAW -2013-02262)
MEMORANDUM FOR RECORD
SUBJECT: Department of the Army Environmental Assessment and Statement of
Findings for the Above -Referenced Standard Individual Permit Application
This document constitutes the Environmental Assessment, 404(b)(1) Guidelines Evaluation,
as applicable, Public Interest Review, and Statement of Findings for the subject application.
1.0 Introduction and Overview: Information about the proposal subject to one or more of
the Corps' regulatory authorities is provided in Section 1, detailed evaluation of the
activity is found in Sections 2 through 11 and findings are documented in Section 12 of
this memorandum. Further, summary information about the activity including
administrative history of actions taken during project evaluation is attached (ORM2
Summary).
1.1 Applicant: Mr. Jeff Brown, Tryon Equestrian Partners, LLC, 2659 Sandy Plains Road,
Tryon, NC 28782
1.2 Activity location: The Tryon International Equestrian Center (TIEC) is located at the
intersection of Pea Ridge Road and US Highway 74 northeast of Tryon in Polk County,
North Carolina. To access the site from Asheville, take I-26 East to Exit 67 (US Highway
74). Continue on US Highway 74 East and take the Pea Ridge Road Exit (Exit 170).
Turn right on to Pea Ridge Road and the site is immediately to the south. In general,
the site is bordered to the north by Pea Ridge Road and to the south and east by Sandy
Plains Road. White Oak Creek bisects the site generally east to west. Site coordinates
are 35.274474 ° North and -82.055471 ° West.
1.3 Description of activity requiring permit: The Tryon Equestrian Center (TIEC) is a 1,405 -
acre equestrian -based development with multiple programming components some of
which have been constructed and some of which are currently under construction. In
general, the area properly known as the Tryon International Equestrian Center (i.e.
`main facility') is approximately 100 -acres and is comprised of a densely developed area
for equestrian sporting to include competition fields/arenas and barns/stables which are
serviced by restaurants, shops and parking. There are multiple types of
structures/facilities within this area to include:
• A 1.76 -acre main stadium arena that seats 6,000 spectators but plans include
expanding this seating capacity to 13,500.
• A 3.5 -acre secondary arena of all-weather footing.
• An 8.3 -acre engineered grass ring on a special blend of all-weather footing.
• Six practice rings with all-weather footing with covered viewing areas for both spectators
and horses at each ring.
Page 1 of 55

CE SAW — RG -A (File Number, SAW -2013-02262)
• A 2.5 -acre arena is currently being enclosed to support full indoor activities and will be
configured to seat up to 5,000 spectators around the ring.
• Seven permanent barns.
• 1,056 stalls (10'x12) equipped with mats, fans, tack management, and wash stalls.
• 115 lockable tack rooms.
Additional residential and commercial development is currently on-going throughout
different areas of the property. The area immediately to the north of the main facility is
approximately 45 -acres and is being actively graded for a mixed-use development to
include multiple hotels, restaurants, retail, cinema, fitness/sports complex, a chapel, town
homes, condominiums, and a welcome/visitor center. The re -location of the Pea Ridge
Road and Sheehan Road off from Hwy 74 is currently being constructed in this area and
will include a roundabout to facilitate traffic to/from Hwy 74 which is the main access point
to the site.
There are also various types of semi-permanent and permanent residential housing spread
near the main facility and throughout the project area as well. Currently, there are RV
parking/hook-ups that can be rented weekly along with a planned log cabin rental
community in which six cabins have already been constructed. Included in this plan is the
construction of another log cabin rental community. Also as previously mentioned in the
background/project history, TIEC also purchased the abandoned White Oak Plantation
residential development and golf course. The golf course has been abandoned and may
be re -developed at some point in the future. There is also a 100 -mile cross-country course
for recreational and competitive equestrian events that is located throughout this portion of
property.
Additional expansion and subsequent future impacts to stream channels and wetlands on
the site are associated with expanding the existing infrastructure described above and
preparing to host the 2018 World Equestrian Games (Games) along with other equestrian
competitive sporting events post -Games. These Games are held world-wide at a select
number of facilities every four years. Over 500,000 spectators and participants are
expected to attend the Games over this two-week period. The Games are comprised of 7
categories of events (e.g. disciplines) that will occur over a two-week period in September
2018 to include Show Jumping/Dressage, Eventing/Driving, Reining/Vaulting/Para, and
Endurance. In addition to the basic direct needs to support these events (i.e. fields, arenas,
and stables/barns), support infrastructure such as bathrooms, spectator seating, parking,
and a WEG `olympic village' are also needed. In order to accommodate these sporting
events/competitions and the venue support infrastructure, proposed plans include the
construction of an additional multi-purpose field with spectator viewing/parking, restrooms,
and concessions. Once the Games have been completed, this field/area will be converted
to a polo field for competitive events to fill a long-term need in that sport. Also, in order to
provide additional on-site hotel accommodations for the Games and for future use by
visitors to the facility/area, impacts are proposed to stream channels associated with the
construction of parking areas to serve this new on-site hotel.
Page 2 of 55

CE SAW — RG -A (File Number, SAW -2013-02262)
The previously approved and subsequently revoked permit authorized 446 linear feet of
permanent stream channel impacts for the expansion of the largest stadium/arena on the
site to allow for parking and access for this field and overall road access to the eastern side
of the facility. This impact is still needed, however additional impacts needed now total
3,483 linear feet of stream channel. Approximately 1,608 linear feet is associated with the
construction of the additional multi-purpose field in the area adjacent to where the
previously approved impacts were authorized. An additional 1,875 linear feet of stream
channel is also needed for the construction of parking areas to service one of the recently
proposed on-site hotels and two additional barns as summarized in the table below. This
table also summarizes previous impacts that have occurred that were associated with past
authorizations.
Currently Proposed
Impact Label Stream
(Permanent)
Stream
(Temporary
Wetland
(Permanent)
E1*- Multipurpose Field 393 I.f.
--------
--------
E2* - Multipurpose Field 53 I.f.
--------
-------
E3- Multipurpose Field 1,608 I.f.
--------
--------
E4 — Hotel Parking 803 I.f.
--------
0.09 acre
E5 — Barns/Parking 1,072 I.f.
--------
---------
B1 — Bridge J -hooks 200 I.f.
--------
-------
Currently Proposed Total 4,129 I.f.
120 I.f.
0.09 acre
Previously Permitted/Completed
UC (Utility Crossings 1, 3, 4,
120 I.f.
-------
P6— 290l.f.
---------
---------
W01 -3*** 115 I.f
---------
--------
Cumulative Total 4,534 I.f.
120 I.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.
1.3.1 Proposed avoidance and minimization measures: Describe here
1.3.2 Proposed compensatory mitigation: A total of 3,929 linear feet of permanent stream
impacts associated with the development of the TIEC will be mitigated for.
Approximately 290 linear feet of stream impact was mitigated for associated with the
Nationwide Permit 39 issued for the equestrian facilities (Action ID 2013-02262) and
therefore is not included in the table below. Also, the 115 linear feet of stream channel
impacts that were previously authorized but not mitigated for is being compensated for
Page 3 of 55

CE SAW — RG -A (File Number, SAW -2013-02262)
with this authorization therefore total stream channel impacts that require compensatory
mitigation are 4,044 linear feet. These impacts will be mitigated for at a 2:1 ratio based
on the good quality of the stream channels which becomes 8,088 linear feet of required
stream mitigation credit as summarized in the table below.
Mitigation Required
Permitted impacts will be mitigated through 1) permittee responsible mitigation at an
off-site location known as Harmon Dairy and 2) payment into the Box Creek
Wilderness mitigation bank as summarized in the table below. Stream mitigation
efforts at the combined Harmon Dairy (Phase 1 and Phase 2) will generate a total of
5,005 stream mitigation units. The remaining 3,083 stream mitigation credits will be
purchased from the Box Creek Mitigation Bank to meet the 8,088 linear feet of stream
channel mitigation needed. Due to the minor amount of wetland impacts proposed
(0.09 acre), there is no compensatory mitigation proposed for the wetland impacts.
Linear Feet
Compensatory
Basic Mitigation
Type of Impact
Impact (LF)
Mitigation Ratio
Requirement (LF)
(x:1)
Credit
(x:1)
Mitigation
Equestrian Center - E1
393
2
786
Equestrian Center — E2
53
2
106
Equestrian Center— E3
1,608
2
3,216
Equestrian Center— E4
803
2
1,606
Equestrian Center— E5
1,072
2
2,144
WO1-3
115
2
2,30
Total Impacts Requiring
4,044
Total Mitigation
8,088
'
Mitigation
2,660
Requirement
1.5:1
Permitted impacts will be mitigated through 1) permittee responsible mitigation at an
off-site location known as Harmon Dairy and 2) payment into the Box Creek
Wilderness mitigation bank as summarized in the table below. Stream mitigation
efforts at the combined Harmon Dairy (Phase 1 and Phase 2) will generate a total of
5,005 stream mitigation units. The remaining 3,083 stream mitigation credits will be
purchased from the Box Creek Mitigation Bank to meet the 8,088 linear feet of stream
channel mitigation needed. Due to the minor amount of wetland impacts proposed
(0.09 acre), there is no compensatory mitigation proposed for the wetland impacts.
Page 4 of 55
Linear Feet
Mitigation Activity Ratio
Total
Stream
of
Type
(x:1)
Credit
Mitigation
Phase 1
UTstoMary'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
Page 4 of 55

CE SAW — RG -A (File Number, SAW -2013-02262)
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
Total Linear Feet
6039
Total Mitigation Credits from Harmon
5005
of Mitigation
Dairy
Box Creek Mitigation Bank - credits
3,083
Total Mitigation Credit Provided
8,088
1.4 Existing conditions and any applicable project history: The TIEC project site consists of
1,405 -acres of the equestrian facilities (arenas, barns, track), commercial facilities,
residential lots and roads, undeveloped wood land, a partially finished (12 holes) golf
course, approximately 6 single-family homes, and approximately 3 miles of roads. In
general, elevations range from approximately 966 feet above mean sea level (MSL) on
the northern portion of the property to 760 feet above MSL on the southeastern portion
of the property (Figure 2). There are eleven natural communities present on site which
includes over 66,000 linear feet of stream channel, 21 acres of wetlands and 4 acres of
open water ponds. The community types have been described in detail in the previous
submittal and therefore have not been included in this modification.
Pine Plantation - There are several areas on the project site composed of planted
pine plantation. The pines are primarily Virginia pine (Pinus virginiana) and loblolly
pine (Pinus taeda). These trees range in age from approximately five to thirty years
old. These areas have been planted in dense rows or densely seeded patches and
almost completely shade out other forms of vegetation. Drought tolerant ferns such
as bracken fern (Pteridium aquilinum) and ebony spleenwort (Asplenium
platyneuron) were observed but uncommon. Common greenbriar (Smilax
rotundifolia) was also occasionally observed.
Pine -Oak -Heath - This habitat occurs on south facing slopes and on the tops of
ridges on site. Flat areas in the uplands on the southern side of the site contain
various successional stages of a pine -oak -heath habitat. The canopy layer is
dominated by Virginia pine, loblolly pine, red oak (Quercus rubra), and white oak
(Quercus alba). Saplings of the species listed above along with flowering dogwood
(Cornus florida), American holly (Ilex opaca), and red maple (Acer rubrum) dominate
the midstory of this area. Shrub species observed include blueberry (Vaccinium
pallidum), deerberry (Vaccinium stamineum), and sassafras (Sassafras albidum).
Vines observed included white leafed greenbriar (Smilax glauca), sawtooth
greenbriar (Smilax bona-nox), and common greenbriar. The herb layer is sparse and
Page 5 of 55

CE SAW — RG -A (File Number, SAW -2013-02262)
is comprised of composites such as goldenrod (Solidago spp.) and whorled
coreopsis (Coreopsis major). Xeric ferns such as bracken fern are occasional.
Montane Oak-Hickory/Dry Oak -Hickory - This habitat is found on sites with dry to
mesic slopes and partly sheltered ridgetops at moderate to fair elevations. The
overstory of this community is dominated by white oak, red oak, Southern red oak
(Quercus falcata), sweet pignut hickory (Cayra glabra var. odorata), mockernut
hickory (Carya tomentosa), and shagbark hickory (Carya ovata). Other trees
observed were sourwood (Oxydendron arboreum) and tulip poplar (Liriodendron
tulipifera). Conifers such as red cedar (Juniperus virginiana), white pine (Pinus
strobus), Virginia pine, and Canada hemlock (Tsuga canadensis) were observed but
rare in this habitat. Species observed in the midstory include flowering dogwood,
and American holly. Typical shrubs in this habitat include mountain laurel (Kalmia
latifolia), great rosebay rhododendron (Rhododendron maximum), huckleberry
(Gaylusaccia baccata), American hazelnut (Corylus americana), maple leaf
viburnum (Viburnum acerifolium), nanny berry (Viburnum prunifolium), coral berry
(Symphoricarpos orbiculatus), blueberry, and deerberry. Vines such as common
greenbriar and sawtooth greenbriar are common. The herb layer is sparse and
patchy. Common members include false Solomon's seal (Smilacina racemosa),
false yellow foxglove (Aureolaria flava), goldenrod, whorled coreopsis, spotted
wintergreen (Chimaphila maculatum), woodland sedge, (Carex rosea), panic
grasses (Panicum spp.), and Virginia snakeroot (Aristolochia serpentaria).
Rich Cove Forests (Montane Intermediate Subtype) - This habitat occurs in mesic
forests at low to mid elevations. Usually found on lower concave slopes and flats
above streams. Many trees in this habitat are shared with the dry oak -hickory list
such as red oak, blackjack oak (Quercus marilandica), scarlet oak (Quercus
coccinea), chestnut oak (Quercus prinus), white oak, mockernut hickory, sweet
pignut hickory, and shagbark hickory. Additional members observed in the Rich
Cove Forest are Canada hemlock, red elm (Ulmus rubra), basswood (Tilia
americana), and buckeye (Aesculus octandra). Herbaceous plants that occur on
steep slopes above the floodplain of White Oak Creek include bloodroot
(Sanguinaria canadensis), mayapple (Podophyllum peltatum), Indian cucumber root
(Medeola virginiana), trilliums (Trillium spp.), rattlesnake plantain (Goodyera
pubescens), and Christmas fern (Polystichum acrostichoides). Other herbs
observed that are typical of rich coves include black cohosh (Cimicifuga racemosa),
American ginseng (Panax quinquefolia), mountain mints (Pycnanthemum spp.), wild
comfrey (Cynoglossum virginianum), beech fern (Thelypteris hexaganoptera),
Southern lady fern (Athyrium filix-femina), maidenhair fern (Adiantum pedatum),
Solomon's seal (Polygonatum biflorum), wild geranium (Geranium maculatum), and
Jack-in-the-pulpit (Arisaema triphyllum).
Montane Mafic Cliffs - This community is defined as steep to vertical slopes on
metamorphic, basic igneous, or mafic rock. This habitat is in the northwest section of
the site just north of White Oak Creek and consists of large boulders and exposed
rock faces. A closed tree canopy was lacking in this area but saplings of Canada
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CE SAW — RG -A (File Number, SAW -2013-02262)
hemlock, hackberry (Celtic laevigata), and hop tree (Ptelea trifoliata) were present.
An understory dominated by vines such as common greenbriar, Virginia creeper
(Parthenocissus quinquefolia), and poison ivy (Toxicodendron radicans) was
observed. Herbs such as wild comfrey, spotted St. John's wort (Hypericum
punctatum), and resurrection fern (Polypodium spp.) were scattered.
Montane Alluvial Forest (Large River Subtype) - This habitat is found on the
floodplains surrounding White Oak Creek and its major tributaries. Dominant trees
observed in this habitat include green ash (Fraxinus pensylvanicum), sweetgum
(Liquidambar styraciflua), sycamore (Platanus occidentalis), four wing silverbell
(Halesia tetraptera), river birch (Betula nigra), basswood, ironwood, and red maple.
Dominant shrubs in this habitat include hop tree, button bush (Cephalanthus
occidentalis), spicebush (Lindera benzoin), bubby bush (Calycanthus floridus), tag
alder (Alnus serrulata), elderberry (Sambucus canadensis), black willow (Salix
nigra), yellowroot (Xanthorhhiza simplicissima), rivercane (Arundinaria gigantea),
Virginia willow (Itea virginica), and silky dogwood (Cornus amomum). Vines
observed include Virginia creeper, poison ivy, and Japanese honeysuckle (Lonicera
japonica). Examples of herbaceous species in the alluvial forest include orange
jewelweed (Impatiens capensis), pokeweed (Phytolacca americana) tear thumb
(Polygonum sagittatum), and Halberd leafed violet (Viola hastata).
Wetlands - The wetlands on this site are composed of non -alluvial bottomland hardwood
depressions and stream head seeps. Dominant trees such as green ash, red maple,
and black willow are common but patchy along the wetlands. Most shrubs were
observed on hummocks and include species such as Virginia willow, elderberry, silky
dogwood, spicebush, tag alder, and yellowroot. Other shrubs such as swamp haw
(Viburnum nudum) were uncommon. The understory is composed of dominant species
such as microstegium (Microstegium vimineum), downy lobelia (Lobelia pubera), orange
jewelweed, stinging nettle (Urtica dioca), ironweed (Vernonia novaeboracensis), and
green coneflower (Rudbeckia lacinata). Emergent herbs such as arrow leaf arum
(Peltandra virginica) and spatterdock (Nuphar luteum) are found in lower areas
associated with flooding. The sedge and grass species are dominant in the herb layer
and cover most of the understory. Common sedges observed include shallow sedge
(Carex lurida), fringed sedge (Carex crinita), hop sedge (Carex lupilina), and pointed
broom sedge (Carex scoparia). Rushes such as false nutsedge (Cyperus strigosus) and
woodland bulrush (Scirpus expansus) were also observed. Small patches of ferns
observed include cinnamon fern (Osmunda cinnamomea) and netted chain fern
(Woodwardia areolata).
Stream Bank and Riparian - These freshwater habitats include the streambeds and
banks of White Oak Creek, and its unnamed tributaries. White Oak Creek flows through
the site, while other unnamed tributaries have their origins in seeps and springs on site.
Permanently rooted aquatic plants are practically non-existent in swift streams such as
those on site. Most streams are incised and are bordered by hardwood forests
dominated by tulip poplar, red maple, sweetgum, buckeye, and river birch. In addition
to saplings of the above trees, species commonly observed in the shrub layers along
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CE SAW — RG -A (File Number, SAW -2013-02262)
streams include great rhododendron, mountain laurel, and spicebush. The streamside
herbaceous layer includes microstegium, southern lady fern, heart -leaf (Hexastylis
spp.), and Christmas fern. Sedge species such as shallow sedge, fringed sedge, and
foxtail sedge (Carex vulpinoidea) are scattered along the banks.
Clear Cut/Power Line and Gas Rights -of -Way - This habitat is seasonally cut and
maintained through mechanical means such as mowing and bushhogging. Most of this
man-made habitat is located in areas that were previously Montane Oak- Hickory or
Pine -Oak -Heath, and it resembles an old field successional site. Some early
successional tree saplings and shrubs exist but this site is dominated by herbs and
grasses. Trees such as red maple, blackjack oak, scarlet oak, southern red oak, white
oak, chestnut oak, red cedar, black locust (Robinina pseudacacia), and tree -of -heaven
(Ailanthus altissima) are on the right-of-way edge as the forest edge takes over. Shrubs
observed in this habitat include black raspberry (Rubus occidentalis), wineberry (Rubus
phoenicolasius), mountain laurel, great rhododendron, and American hazelnut. Herbs
and grasses dominate this habitat and species observed include goldenrods, whorled
coreopsis, hoary mountain mint (Pycnanthemum incanum), butterfly weed (Asclepias
tuberosa), ironweed, Queen Anne's lace (Daucus carota), alternate leaf wing stem
(Verbesina alternifolia), and crownbeard (Verbesina occidentale). Other less common
plants included butterfly pea (Clitoria mariana), fleabane (Erigeron philadelphicus),
evening primrose (Oenothera biennis), sunflowers (Helianthus spp.), Indian plantain
(Cacalia muhlenbergii), and round leaf eupatorium (Eupatorium rotundifolium).
Montane Alluvial Clear Cut and Existing/Future Golf Course - This habitat is on the
floodplain of White Oak Creek. It will be constantly cut and maintained as an official golf
course. Tree, shrub, and stump removal has resulted in a lack of overhead canopy. It is
being converted to uniform lawn and sand traps. Grass species such as Bermuda
(Cynodon dactylon), fescue (Festuca spp.), blue grass (Poa spp.), broom sedge
(Andropogon virginicus), and Foxtail millet (Setaria spp.) have been sown.
Landscaped Areas and Residential Lawns - Turf grass or maintained lawns were
identified on certain areas around the TIEC. This includes a number of completed
residential lawns, maintained grass medians, and landscaped areas. These areas
undergo regular mowing and maintenance. Vegetation in these areas was dominated
by a variety of introduced grasses including perennial ryegrass (Lolium perenne), redtop
(Agrostis gigantea), red fescue, bluegrass, and fescue. Other common herbaceous
species included dandelion (Taraxacum officinale), lyre -leaf sage (Salvia lyrata),
common plantain (Plantago major), lance leaf plantain (Plantago lanceolata), and white
clover (Trifolium repens).
The project site is located within the Piedmont physiographic region of North
Carolina and more specifically the Southern Inner Piedmont Ecoregions. Three soil
associations are present on site: the Pacolet-Madison-Rion association, the Pacolet-
Bethlehem-Rion association, and the Riverview-Chewacla-Buncombe association.
The Pacolet-Madison-Rion association and the Pacolet-Bethlehem- Rion
Page 8 of 55

CE SAW — RG -A (File Number, SAW -2013-02262)
association are classified as gently sloping to steep, well drained soils. These
associations are found on piedmont uplands. The Riverview-Chewacla- Buncombe
association is classified as nearly level and gently sloping, somewhat poorly drained
to excessively drain soils. This soil association is found on floodplains. Soil series
present on site include: Buncombe, Cecil, Chewacla, Grover, Madison, Pacolet-
Bethlehem complex, Rion -Ashlar -Rock outcrop, Rion- Cliffside complex, Skyuka,
and Wehadkee.
Wildlife species inhabiting the site include those typically found in the forest types of the
region previously described above. Although site-specific studies and inventories
documenting species utilization of the TIEC project area have not been conducted,
general observations of fish and wildlife use were recorded during the wetland and
stream delineation and the threatened and endangered species assessments.
The additional parking areas that have been added are 24 acres (North Parcel) and 73
acres (Parcel P106-23) respectively. The 24 -acre parcel is located on the north side of
Hwy 74 at the Pea Ridge Road interchange and has already been graded and includes
existing gravel parking areas. There is a stream channel located in the southern portion
of the site that has been left wooded/undisturbed. The 73 -acre parcel is located to the
south of the TIEC facility and across White Oak Creek. This area is predominately
wooded with Virginia pine (Pinus virginiana) and loblolly pine (Pinus taeda). These
trees range in age from approximately five to thirty years old. These areas have been
planted in dense rows or densely seeded patches and almost completely shade out
other forms of vegetation. Drought tolerant ferns such as bracken fern (Pteridium
aquilinum) and ebony spleenwort (Asplenium platyneuron) were observed but
uncommon. Common greenbriar (Smilax rotundifolia) was also occasionally observed.
There is also a stream channel that begins in the southwestern portion of the property.
With regards to project history, Tryon Equestrian Partners purchased approximately
417 acres adjacent to John Shehan Road in 2013 which has become the main site
for the equestrian facilities. The Corps issued a Nationwide Permit 39 (Action ID
SAW -2013-02262) for 290 linear feet of permanent stream impact and 5 linear feet of
temporary stream impacts associated with development of Phase I of the equestrian
facilities on December 23, 2013.
The TIEC also includes approximately 935 acres of property previously known as
White Oak Plantation. White Oak Plantation was planned as an 18 -hole golf course
community with equestrian oriented amenities. In 2012 the local bankruptcy court
ordered the auction of White Oak Plantation. At that time, approximately 29 lots out
of 700 were sold and approximately 6 houses were constructed. In December of
2005 and while still known as White Oak Plantation, the Corps issued Nationwide
Permits 12 and 13 for bank stabilization and a water intake on White Oak Creek
under Action IDs SAW -2006-30110 and SAW -2006-30195. In June of 2006, the
Corps issued Nationwide Permit 39 (Action ID SAW -2006- 32154) for two
permanent road crossings impacting 139 linear feet of stream, 12 temporary road
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CE SAW — RG -A (File Number, SAW -2013-02262)
crossings to aid in utility installation, and 12 utility line crossings. This Nationwide
Permit was re -authorized and modified in November of 2008. The modification
authorized a cumulative total of 150 linear feet of permanent stream impacts;
however, only 115 linear feet of permanent impacts were completed. In February of
2009, the Nationwide Permit 12 was re -authorized for 165 linear feet of temporary
stream impacts and 0.008 acre of temporary wetland impacts.
More recently, a permit request was previously submitted to expand the facility in June
2015 based on current plans at that time. An individual permit was subsequently issued
on January 11, 2017 for 446 linear feet of permanent stream channel impacts
specifically associated with parking and access to the largest stadium/arena on the
property. This permit also authorized 120 linear feet of temporary stream impacts
associated with utility line installation in the residential areas in the former White Oak
subdivision. In the final stages of the permit issuance, TIEC was awarded to be the host
site for the World Equestrian Games (WEG) scheduled to take place in September
2018. The need for additional infrastructure to host this event plus the continued
planned expansion of this resort facility required impacts to streams/wetlands beyond
those previously permitted.
Subsequently, the previous permit authorization was suspended on February 3, 2017
pending the modification and submittal of this revised permit request for additional
stream/wetland impacts. Through follow-up coordination, a portion of the previous
permit was reinstated to allow the 120 linear feet of temporary stream channel impacts
associated with utility construction to proceed based on a February 15, 2017
letter/authorization .
1.5 Permit Authority: Section 404 of the Clean Water Act (33 USC 1344).
2.0 Scope of review for National Environmental Policy Act (i.e. scope of analysis),
Section 7 of the Endangered Species Act (i.e. action area), and Section 106 of
the National Historic Preservation Act (i.e. permit area)
2.1 Determination of scope of analysis for National Environmental Policy Act (NEPA):
The scope of analysis includes the specific activity requiring a Department of the Army
permit. Other portions of the entire project Select appropriate choice included because
the Corps Select appropriate choice have sufficient control and responsibility to
warrant federal review.
Final description of scope of analysis: Describe here
2.2 Determination of the "action area" for Section 7 of the Endangered Species Act (ESA):
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Description of ESA scrape with rationale here.
2.3 Determination of permit area for Section 106 of the National Historic Preservation Act
(N H PA):
The permit area includes elect first option if the permit area includes uplands if?
addition to waters, and the second option if the permit area includes only watersthose
areas comprising waters of the United States that will be directly affected by the
proposed work or structures elect first option if the permit area includes uplands, and
the second option if the permit area includes only waters
Final description of the permit area: Final description of permit area with rationale
here.
3.0 Purpose and Need
3.1 Purpose and need for the project as provided by the applicant and reviewed by the
Corps: The project purpose is the continued development of the Tryon International
Equestrian Center as a mixed-use residential and commercial resort development that
is capable of hosting the World Equestrian Games.
3.2 Basic project purpose, as determined by the Corps: The basic project purposes is to
develop an equestrian center resort with housing and recreational opportunities.
3.3 Water dependency determination: The activity does not require access or proximity to
or siting within a special aquatic site to fulfill its basic purpose. Therefore, the activity
is not water dependent.
3.4 Overall project purpose, as determined by the Corps: Describe here.
4.0 Coordination
4.1 The results of coordinating the proposal on Public Notice (PN) are identified below,
including a summary of issues raised, any applicant response and the Corps'
evaluation of concerns.
Were comments received in response to the PN? Yes
Since this authorization is associated with a permit modification, a previous public
notice was issued for this project which received comments. These comments have
been documented in the previously approved Environmental Assessment for the initial
individual permit application that was revoked. The comments listed below were
received in response to the public notice for the modified plans.
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Were comments forwarded to the applicant for response? Yes
Was a public meeting and/or hearing requested and, if so, was one conducted? No,
no public hearing or meeting was requested.
Comments received in response to public notice:
Comment 1: North Carolina Wildlife Resource Commission (NCWRC) by letter dated
March 22, 2017. The NCWRC noted that the project is not expected to impact trout
since they do not occur in this area and therefore on-site construction activities can
occur during trout spawning season. NCWRC requested more detailed information
on staging, culvert type, installation/stabilization methods for the proposed impacts
and recommended storm water management to reduce any potential to degrade
downstream waters. NCWRC also recommended the implementation of low -impact
development techniques in landscaping. NCWRC also noted that they supported
the use of the Harmon Dairy site to provide compensatory mitigation credit and that
the remaining credit needed should be provided through preservation in the Broad
River Basin.
Applicant's Response: N/A
Corps Evaluation: Summarize Corps evaluation here.
Comment 2: Eastern Band of Cherokee Indians (EBCI), Tribal Historic Preservation
Office (THPO) by letter dated March 14, 2017. The EBCI-THPO responded that no
historic properties will be adversely impacted by this project and that in the event
that project plans change or cultural resources or human remains are inadvertently
discovered during construction, that all work cease and the EBCI-THPO be notified
so nation -to -nation consultation can continue.
Applicant's Response: N/A
Corps Evaluation: Summarize Corps evaluation here.
Comment 3: United Bank of Cherokee Indians in Oklahoma (UKB), Tribal Historic
Preservation Office (THPO) by letter April 7, 2017. The UKB-THPO noted that the
project site lies within their traditional territory and that information on Native
American use in the project vicinity shows that prehistoric, ethnographic, historic,
and traditional sites of values to the UKB surround the project area. Based on this,
the UKB recommended that a cultural resource inventory be completed.
Applicant's Response: N/A
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Corps Evaluation: Summarize Corps evaluation here.
Comment 4: The North Carolina State Historic Preservation Office (SHPO) by letter
dated March 31, 2017. The SHPO commented that they are not aware of any
historic resources that would be affected by the project and that they had no
comment.
Comment 5: The North Carolina Division of Water Resources (NCDWR) by letter
dated April 6, 2017. NCDWR provided several comments/concerns related to
clarification of impacts, avoidance and minimization efforts, and potential on-site
alternatives.
Applicant's Response:
Corps Evaluation: Summarize Corps evaluation here.
Additional discussion of submitted comments, applicant response and/or Corps'
evaluation: Select N/A or provide discussion as appropriate.
4.2 Were additional issues raised by the Corps including any as a result of coordination
with other Corps offices? Select Yes or No
If yes, provide discussion including coordination of concerns with the applicant,
applicant's response and Corps' evaluation of the response: Select N/A or provide
discussion as appropriate.
4.3 Were comments raised that do not require further discussion because they address
activities and/or effects outside of the Corps' purview? Select Yes or No
If yes, provide discussion: Select N/A or provide discussion as appropriate.
5.0 Alternatives Analysis (33 CFR Part 325 Appendix B(7), 40 CFR 230.5(c) and 40
CFR 1502.14). An evaluation of alternatives is required under NEPA and under the
Section 404(b)(1) Guidelines for projects that include the discharge of dredged or fill
material. NEPA requires discussion of a reasonable range of alternatives, including
the no action alternative, and the effects of those alternatives., under the Guidelines,
practicability of alternatives is taken into consideration and no alternative may be
permitted if there is a less environmentally damaging practicable alternative.
5.1 Site selection/screening criteria: In order to be practicable, an alternative must be
available, achieve the project purpose (as defined by the Corps), and be feasible
when considering cost, logistics and existing technology.
Corps -determined criteria for evaluating alternatives: See below.
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5.2 Description of alternatives
5.2.1 No action alternative: 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 along with meeting
long-term needs of the facility to host competitive polo and other sporting events. For
the impacts associated with lodging, 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 jeopardize TIEC's ability to host the 2018 World Equestrian Games
and the ability of the development to meet lodging demands in the long-term.
5.2.2 Off-site alternatives
Five tracts of land greater than 1,000 acres in Polk County were identified. One
thousand acres was chosen and is consistent with the initial parcel purchase (923
acres) and current property size of TIEC (1,276 acres). Each of the five tracts was
combined with smaller but adjacent parcels owned by the same entity. Tracts
identified include properties owned by Hidden Spring Holdings, LLC, Grassy Knob
Land, LLC, Ricks Mountain, LLC, and Green River Farms, LLC. Each property is
discussed below with regards to the following off-site selection criteria and
summarized in the table below.
A) Licensing: The United States Equestrian Federation (USEF) requires
competition licensing in the United States. Location, dates, rating, level, and
prize money are reviewed and approved by the USEF Competitions
Department for each competition. Subchapter 3-B of the "2015 United States
Equestrian Federation, Inc. Rule Book" outlines licensing requirements. The
USEF seeks to provide for financially and otherwise viable competitions to meet
the needs of the sport within a geographic area. Additionally, the USEF
recognizes and acknowledges that mileage is an important factor for shows to
keep their standards high, thus enabling them to better meet the rules and
requirements for a given rating or level. General Rule 308 outlines mileage
restrictions between competitions depending on the level of competition.
Separation generally ranges from 50-250 miles with higher level shows
requiring greater separation. The TIEC conducts approximately 30 shows each
year. To prevent competition conflicts, equestrian centers where USEF
competitions are occurring must maintain the required mileage separation and
each show must be licensed. Instead of obtaining new licenses, it is beneficial
to purchase or lease existing licenses from other facilities.
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B) Access to Transportation Routes: Horses are transported to equestrian
centers via semi -truck and trailer. A trailer can reach 50 feet in length and
require a large turning radius. Because of the size of the trailers required to
transport horses and large turning radii required for 90 degree or tighter turns,
equestrian centers are generally not sited in urban areas or rural areas
requiring traveling on narrow, winding roads. Horses, riders, officials, and
spectators are also transported via plane; therefore, the chosen site should
be located with relatively easy access to airports.
C) Residential Component: Tryon Equestrian Partners, LLC wants an equestrian
center to be the central amenity of the development; however, they do not
want these areas to overshadow the rest of the development or encompass
the majority of the land mass at the chosen site. The ability to provide
residential housing allows for recuperation of the initial investment made for
the development of the equestrian center.
D) Community Infrastructure: The property should be adequately served by
community infrastructure. The ability to tap into existing sources of utility
(water and sewer) is important in determining the feasibility and practicability
of a project.
E) Weather: The property should be in located in a temperate region with
relatively stable weather patterns. A mild climate allows for maximization of
the show season which is generally May — September but can be extended
depending on the location of the facility.
F) Established Equine Community: The property should be in a location with an
established equine community and an existing `horse' culture.
G) Estimated Stream Resources (Corps Determined/Added) - Placement of fill in
streams. Reported in linear feet of impact/must avoid, minimize, and/or
mitigate for loss.
Off-site alternative 1: Hidden Springs Holdings, LLC
A) Licensing: It is assumed that this site could meet licensing criteria by purchasing or
moving licenses.
B) Access to Transportation Routes — The most direct routes to this site are via Lake
Adger Road or Coopers Gap Road. Either route would require approximately 4 to 5
miles of travel on primary roads. Due to the size of horse trailers, access to this site
is not desirable. This site does not meet access criteria.
C) Residential Component — This site is a part of the Brights Creek development but
the land is undeveloped. The Brights Creek development includes an Equestrian
Center with upscale facilities, riding rings, riding trails, and boarding. A residential
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development is adjacent to the Brights Creek Golf Course. This site could meet the
residential component criteria.
D) Community Infrastructure — The proposed project would require a 12 -inch water
line to meet all projected demands (600,000 gallons per day). In 2013, when Tryon
Equestrian Partners, LLC was looking to purchase property, the nearest 12 -inch
water line to property owned by Hidden Holdings, LLC was approximately 20 miles
away. Additionally, due to the elevation of the site, a booster station and/or a water
tank would need to be constructed. Both would require approval from Polk County
because Polk County would have to own and operate the system. Public sewer
service would have to be extended to the site or a major expansion would be
needed to enlarge the existing sanitary sewer treatment plant. No receiving
streams in the vicinity of the sanitary sewer treatment plant are large enough to
allow for the expected discharge volume (600,000 gallons per day); therefore,
public sewer would need to be extended to the site. The nearest wastewater
treatment plant (WWTP) is located in Lake Lure; however, the Lake Lure WWTP
does not have sufficient capacity for the expected discharge volume. Another
alternative would be to pump wastewater to Columbus. Due to the excessive
distance from the site to the Town of Columbus, the detention time in the force
main for this volume of flow would not be treatable by the Columbus WWTP. This
site does not meet the community infrastructure criteria.
E) Weather— Because this site is located in the "thermal belt', it meets the weather
criteria.
F) Established Equine Community — Due to its proximity to Tryon, NC, this site meets
the equine community criteria.
G) Estimated stream resources — Although delineations could not be performed on all
off-site properties, GIS was utilized to estimate the linear footage of streams, using
available USGS stream data, for each site identified and for TIEC. Based on this
method (which should not be misconstrued as a stream delineation), this site
contained 24,157 linear feet of stream channels. Since the TIEC essential
infrastructural needs occupy a large footprint with specific location requirements it
was assumed that impacts would be comparable for each site. Since this site was
estimated to have a higher amount of stream than the preferred alternative it
seemed reasonable that the proposed impacts would be higher as well, therefore
not meeting stream impact criteria.
Off-site alternative 2: Grassy Knob Lands, LLC
A) Licensing - It is assumed that this site could meet licensing criteria by
purchasing or moving licenses.
B) Access to Transportation Routes - The most direct routes to this site are
via Coopers Trace or Grassy Knob Road. Either route would require
approximately 1.5 to 2 miles of travel on primary roads. Due to the size of
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horse trailers, access to this site is not desirable but could be sufficient if all
other criteria were met.
C) Residential Component — The property owned by Grassy Knob Lands,
LLC is a gated residential equestrian and conservation community with 25
parcels and 1,500 acres of protected land. The property is not available for
additional development. This site does not meet the residential component
criteria.
D) Community Infrastructure - The proposed project would require a 12 -inch
water line to meet all projected demands (600,000 gallons per day). In
2013, when Tryon Equestrian Partners, LLC was looking to purchase
property, the nearest 12 -inch water line to property owned by Hidden
Holdings, LLC was approximately 18 miles away. Additionally, due to the
elevation of the site, a booster station and/or a water tank would need to
be constructed. Both would require approval from Polk County because
Polk County would have to own and operate the system. Public sewer
service would have to be extended to the site or a major expansion would
be needed to enlarge the existing sanitary sewer treatment plant. No
receiving streams in the vicinity of the sanitary sewer treatment plant are
large enough to allow for the expected discharge volume (600,000 gallons
per day); therefore, public sewer would need to be extended to the site.
The nearest WWTP is located in Lake Lure; however, the Lake Lure
WWTP does not have sufficient capacity for the expected discharge
volume. This site does not meet the community infrastructure criteria.
E) Weather - Because this site is located in the "thermal belt', it meets the
weather criteria.
F) Established Equine Community - Due to its proximity to Tryon, NC, this
site meets the equine community criteria.
G) Estimated Stream Resources - Although delineations could not be
performed on all off-site properties, GIS was utilized to estimate the linear
footage of streams, using available USGS stream data, for each site
identified and for TIEC. Based on this method (which should not be
misconstrued as a stream delineation), this site contained 12,815 linear
feet of stream channels. Since the TIEC essential infrastructural needs
occupy a large footprint with specific location requirements it was assumed
that impacts would be comparable for each site. Since this site was
estimated to have a lower amount of stream than the preferred alternative
it seemed reasonable that the proposed impacts would be lower as well,
therefore meeting stream impact criteria.
Off-site Alternative 3: Ricks Mountain, LLC
A) Licensing — It is assumed that this site could meet licensing criteria by
purchasing or moving licenses.
B) Access to Transportation Routes — Although this site is adjacent to
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Interstate 26, the most direct routes to this site are via Skyuka Mountain
Road or Holbert Cove Road. Either route would require approximately 4 to
5 miles of travel on primary roads. Accessing the site from Skyuka Road
would require traveling through downtown Columbus which is not
desirable. Additionally, Skyuka Mountain Road is very steep with many
curves and would not be suitable for large horse trailers. Holbert Cove
Road could provide additional access to the site but due to the size of
horse trailers and distance to travel on primary roads this access is not
desirable. This site does not meet access criteria.
C) Residential Component — Due to the NC Permit Extension Act that became
law in 2009, Preliminary Plats that had been approved prior to the
recession maintained their approval through the end of 2010. The original
White Oak Plantation development was approved for over 700 lots
averaging half an acre. After 2010, Polk County and the developers of
White Oak Plantation completed a Development Agreement that extended
the preliminary plat approval indefinitely. The Ricks Mountain, LLC site is
currently undeveloped with no vested development rights. Current
subdivision ordinances limit lot sizes to 2 acres and would not allow for the
residential housing density adequate enough to offset the initial capital
investment required to develop an equestrian center. This site does not
meet the residential component criteria.
D) Community Infrastructure - The proposed project would require a 12 -inch
water line to meet all projected demands (600,000 gallons per day). Polk
County does not provide water service for this area; therefore, a water main
extension from the Town of Columbus would be necessary. Columbus does
not have sufficient capacity to serve this site. While Tryon's Water
Treatment Plant could meet the capacity requirements of the project, the
raw water supply is tenuous. Tryon currently obtains raw water from Lake
Lanier; however, the water rights only exist if water is overflowing the dam.
There have been many instances since 2000 where there has been no flow
over the dam. In those cases, Tryon had to institute mandatory restrictions
on water use based upon the current demand of around 500,000 gallons
per day. Tryon could not meet its current demand (500,000 gallons per day)
and additional demand for the Equestrian Center (600,000 gallons per day)
without identifying and constructing access to an alternate water source.
Public sewer service would have to be extended to the site or a new
wastewater treatment plan would need to be constructed. No receiving
streams in the vicinity are large enough to allow for the expected discharge
volume (600,000 gallons per day); therefore, public sewer would need to be
extended to the site. A new lift station and force main could be constructed
to serve the site. Due to the expected rock that would be encountered
during the installation of a force main, the expected cost would
approximately $4,000,000. This site does not meet the community
infrastructure criteria.
E) Weather - Because this site is located in the "thermal belt", it meets the
weather criteria.
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F) Established Equine Community — Due to its proximity to Tryon, NC, this
site meets the equine community criteria.
G) Estimated stream resources — Although delineations could not be
performed on all off-site properties, GIS was utilized to estimate the linear
footage of streams, using available USGS stream data, for each site
identified and for TIEC. Based on this method (which should not be
misconstrued as a stream delineation), this site contained 10,292 linear
feet of stream channels. Since the TIEC essential infrastructural needs
occupy a large footprint with specific location requirements it was assumed
that impacts would be comparable for each site. Since this site was
estimated to have a lower amount of stream than the preferred alternative
it seemed reasonable that the proposed impacts would be lower as well,
therefore meeting stream impact criteria.
Off-site Alternative 4: Green River Farms, LLC Site A and Site B
For discussion purposes, Green River Farms has been divided into Site A and Site
B. Each site contains tracts greater than 1,000 acres; however, the tracts are
contiguous when considering adjacent parcels owned by the same entity. TIEC had
conversations with the owner of Green River Farms and the site is not available for
purchase.
A) Licensing — It is assumed that both sites could meet licensing criteria
by purchasing or moving licenses.
B) Access to Transportation Routes — Both sites have almost immediate
access from Highway 74 via Cox Road. This site meets access
requirements.
C) Residential Component — Due to the NC Permit Extension Act that
became law in 2009, Preliminary Plats that had been approved prior to
the recession maintained their approval through the end of 2010. The
original White Oak Plantation development was approved for over
700 lots averaging half an acre. After 2010, Polk County and the
developers of White Oak Plantation completed a Development
Agreement that extended the preliminary plat approval indefinitely.
The Green River Farms, LLC sites are currently undeveloped with no
vested development rights. Current subdivision ordinances limit lot
sizes to 2 acres and would not allow for the residential housing
density adequate enough to offset the initial capital investment
required to develop an equestrian center. These sites do not meet the
residential component criteria.
D) Community Infrastructure - The proposed project would require a 12 -
inch water line to meet all projected demands (600,000 gallons per
day). A water main extension would be necessary and would require
Polk County's approval. Public sewer service would have to be
extended to the site or a new wastewater treatment plan would need
to be constructed. Utilizing a cost estimate of $10 per gallon, a new
WWTP would cost approximately $6,000,000 assuming the NPDES
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permit could be obtained. The nearest WWTP is located in
Rutherfordton. A recent Capital Improvement Plan completed by the
Town of Rutherfordton indicates that the current plant, while permitted
for 3.0 million gallons a day (MGD), is only capable of treating 1.0
MGD without substantial improvements. With the current flow volume
plus those approved flows not yet contributory to the Town's WWTP,
the Town of Rutherfordton would be treating slightly over 1.0 MGD. An
additional 600,000 gallons per day from the equestrian center would
require substantial investment on behalf of the Town of Rutherfordton.
Additionally, a lift station and force main would need to be constructed
with costs of approximately $3,000,000. Since the site is located in a
different County from the WWTP, additional approvals would be
necessary from Polk County to allow cross -county to occur. This site
does not meet the community infrastructure criteria.
E) Weather— Because these sites are located in the "thermal belt", they
meet the weather criteria.
F) Established Equine Community — Due to their proximity to Tryon, NC,
these sites meet the equine community criteria.
G) Estimated stream resources — Although delineations could not be
performed on all off-site properties, GIS was utilized to estimate the
linear footage of streams, using available USGS stream data, for each
site identified and for TIEC. Based on this method (which should not be
misconstrued as a stream delineation), Green River Site A contained
15,852 linear feet of stream channels and Green River Site B contained
21,949 linear feet of stream channels. Since the TIEC essential
infrastructural needs occupy a large footprint with specific location
requirements it was assumed that impacts would be comparable for
each site. Since Green River Site A was estimated to have a lower
amount of stream than the preferred alternative it seemed reasonable
that the proposed impacts would be lower as well, therefore meeting
stream impact criteria. Since Green River Site B was estimated to have
a higher amount of stream than the preferred alternative it seemed
reasonable that the proposed impacts would be higher as well,
therefore not meeting stream impact criteria.
Criteria
G
Site
Criteria
A
Criteria
B
Criteria
C
Criteria
D
Criteria
E
Criteria
F
Streams
(LF)"
Hidden Springs
Holdings
o
X
o
X
o
0
24,167
Grassy Knob Land
o
o
X
X
o
0
12,815
Ricks Mountain
o
X
X
X
o
0
10,292
Green River Farms (A)
o
o
X
X
o
0
15,852
Green River Farms (B)
o
o
X
X
o
0
21,949
As -Proposed
o
0
0
0
0
0
18,874
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o - meets criteria
X - does not meet criteria
" Based on GIS for discussion purposes only. Actual jurisdictional waters present on site may be
different.
5.2.3 On-site alternatives
For discussion purposes, the on-site alternatives analysis is broken down into the
analysis of alternative locations for the multipurpose field and the lodging since
requirements/site selection criteria for those proposed impacts are specific to those
purposes. Also, since the site is comprised of 1,405 acres, `on-site alternatives' for the
purposes of this discussion includes alternative locations within the entire 1,405 -acre
project boundary in which other locations could potentially be used to place the
multipurpose field or lodging.
For the multipurpose field, there were a total of six site selection criteria used to
evaluate eight potential on-site alternative locations and/or configurations of this
proposed field which are summarized in the tables below. Below is a description of the
multipurpose field selection criteria as referenced in the following on-site alternatives.
Multipurpose Field Criteria #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 as
outlined in the table below.
Course
➢
15 km training track
Specifications
➢
160 km natural terrain track with no more than 10% on
hard 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 Parking
Other
➢
Press Tent/Office
Requirements
➢
Information Tent
➢
Emergency Services Tent
➢
Rider Hospitality Tent
➢
Rider/VIP Restrooms
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➢ VIP Tent /Golf Cart Parking
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 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.
Multipurpose Field Criteria #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.
Multipurpose Field Criteria #3: Constructability
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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.
Multipurpose Field Criteria #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 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 Multipurpose Field Criteria # 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.
Multipurpose Field Criteria #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.
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
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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.
On-site alternative 1 (applicant's preferred alternative): Herein referred to at On-site
Multipurpose Field (MF) Alternative #1. This proposed field will impact approximately
2,054 linear feet (including 446 If 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.
On-site Multipurpose Field (MF) Alternative #2: Use Existing Large Field
This alternative evaluated 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
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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.
On-site Multipurpose Field (MF) Alternative 3: 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.
On -Site Multipurpose Field (MF) Alternative 4: 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.
On -Site Multipurpose Field (MF) Alternative 5: 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
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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.
On -Site Multipurpose Field (MF) Alternative 6: Move Field to the 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.
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.
On-site Multipurpose Field (MF) Alternative #7: Move Field to the 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
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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.
On-site Multipurpose Field (MF) Alternative #8: 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.
On-site Multipurpose Field (MF) Alternative #9: 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.
Page 27 of 55
Hosting Accessibility Constructability
Ability
Ability to Re-
configure
Field
Transportation
Flow/Safety
Long
Term
Use
Aquatic
Resource
Impacts
MF Alt. #1
0 0 0
0
0
0
2,054 If stream
MF Alt. #2
X o o
X
o
X
446 If stream
MF Alt. #3
o X o
X
o
X
446 If stream
MF Alt. #4
0 o X
X
X
X
1,027 If stream
MF Alt. #5
0 o X
o
0
0
446 If stream
MF Alt. #6
X X X
X
X
X
300 If stream
MF Alt. #7
X X o
0
0
0
778 If stream
MF Alt. #8
o X o
0
o
X
446 If stream
MF Alt. #9
X X o
0
0
0
2,054 If stream
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o — meets criteria
X - does not meet criteria
For the proposed lodging impacts, there were a total of three site selection criteria
used to evaluate eight potential on-site alternative locations and/or configurations of
the proposed lodging/parking which are summarized in the tables below. Below is a
description of the lodging selection criteria as referenced in the following on-site
alternatives.
Lodging Criteria #I: 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
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.
Lodging Criteria #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.
Lodging Criteria #3: 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
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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, 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.
Lodging On-site Alternative #1 (Preferred):
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.
Lodging On-site Alternative #2 — Utilize Parking Inside Olympic Village
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 On-site Alternative #3 - Construct Retaining Walls
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 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.
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Lodging On-site Alternative #4 — 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 On-site Alternative #5: 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 On-site Alternative #6 — 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 On-site Alternative #7 — 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 On-site Alternative #8 — 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 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.
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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.).
Also, parking decks are problematic from a long term development/marketing standpoint since
they are generally associated with municipal/urban settings and create an undesirable stigma
when applied to more rural settings and the customer base that would be using this facility. It is
a concern that if customers have to use a parking garage then they likely would be deterred
from choosing to lodge at the White Horse Inn (or any hotel at the site with a garage)
especially since many of the customer base will be driving large trucks/vehicles that are typical
for this area/region and are difficult to maneuver and park in a confined garage. As evidenced
when evaluating the type of vehicles using the facility now, many parking spaces are occupied
now by large/oversized trucks that are capable of pulling horse trailers.
o — meets criteria
X - does not meet criteria
5.3 Evaluate alternatives that are not practicable or reasonable: Provide appropriate
discussion here.
5.4 Least environmentally damaging alternative under the 404(b)(1) Guidelines (if
applicable) and environmentally preferred alternative under NEPA:
Page 31 of 55
Capacity
Proximity
Long -Term
Development Plan
Stream Channel/Wetlands
Impacts
Lodging Alt. #1
0
0
0
803 lf/ 0.09 acres
Lodging Alt. #2
0
o
X
0
Lodging Alt. #3
0
0
0
430
Lodging Alt. #4
x
o
X
0
Lodging Alt. #5
X
o
X
0
Lodging Alt. #6
0
0
0
0
Lodging Alt. #7
o
x
x
0
Lodging Alt. #8
0
o
X
0
o — meets criteria
X - does not meet criteria
5.3 Evaluate alternatives that are not practicable or reasonable: Provide appropriate
discussion here.
5.4 Least environmentally damaging alternative under the 404(b)(1) Guidelines (if
applicable) and environmentally preferred alternative under NEPA:
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Identify the least darrfagrnglenvirc�nmer?tally preferred alternative. If more than one
alternative is practicable based car? the analysis above, include discussion of
environmental effects of each and rationale for selecting the least damaging one.
6.0 Evaluation for Compliance with the Section 404(b)(1) Guidelines. Select
appropriate choice.
6.1 Practicable alternatives to the proposed discharge consistent with 40 CFR 230.5(c)
are evaluated in Section 5. The statements below summarize the analysis of
alternatives.
In summary, based on the analysis in Section 5.0 above, the no -action alternative,
which would not involve discharge into waters, is not practicable.
For those projects that would discharge into a special aquatic site and are not water
dependent, the applicant has demonstrated there are no practicable alternatives that
do not involve special aquatic sites.
It has been determined that there are no alternatives to the proposed discharge that
would be less environmentally damaging. (Subpart B, 40 CFR 230.10(a)). The
proposed discharge in this evaluation is the practicable alternative with the least
adverse impact on the aquatic ecosystem, and it does not have other significant
environmental consequences.
6.2 Candidate disposal site delineation (Subpart B, 40 CFR 230.11(f)). Each disposal site
shall be specified through the application of these Guidelines:
Discussion: The disposal sites are medium to high quality warm water streams in a
rural setting.
6.3 Potential impacts on physical and chemical characteristics of the non -living
environment (Subpart C). See Table 1:
Table 1 — Potential Impacts on Physical and Chemical Characteristics
Minor
Minor
Physical and Chemical
No
Negligible
Effect
Effect
Major
N/A
Characteristics
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Substrate
X
Suspended particulates/
X
turbidity
Water
X
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Table 1 — Potential Impacts on Physical and Chemical Characteristics
Minor
Minor
Physical and Chemical
No
Negligible
Effect
Effect
Major
N/A
Characteristics
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Current patterns and water
X
circulation
Normal water fluctuations
X
Salinity gradients
X
Discussion: Any discharge associated with these impacts would consist of suitable,
clean fill material and would not include any trash, debris, car bodies, asphalt, etc. The
fill material would also be free of toxic pollutants in toxic amounts. Although proper
sediment and erosion control devices would be installed prior to and during
construction, turbidity rates would likely increase during construction, but would
subside upon completion of the work. The discharge of fill material associated with this
project would not be expected to have substantial effects on the downstream
hydrologic regimes, current water patterns and/or circulation, or water chemistry.
Although substrate and hydrologic functions would be lost in the area of the authorized
fill, the drainage in this area is proposed to be collected by french drains and released
down its normal path downslope of the areas of fill. During construction activities in the
project area, there could be increases in suspended particulates that could lead to
increased turbidity in on-site streams. The applicant, however, would minimize the
effects of suspended particulates through the placement of appropriate and required
sediment and erosion control techniques in the areas of disturbance. In order to
reduce suspended particulate/turbidity, any permit that may be issued for this project
would require that the applicant (permittee) do the following: comply with the 401
Water Quality Certification that was issued for this project; comply with all aspects of
the Sedimentation Pollution Control Act of 1973; ensure that waters of the U.S. are
dewatered during excavation and/or construction; not place heavy equipment in
surface waters or stream channels during the clearing phase of the project; use
temporary stream crossing to access the opposite sides of stream channels; prevent
grubbing of riparian vegetation until immediately before construction begins on a given
segment of stream channel; implement all reasonable and practicable measures to
ensure that equipment, structures, fill pads, work, and operations associated with this
project do not adversely affect upstream and/or downstream stream reaches, and;
revegetate affected upland areas (associated with temporary fills placed in waters of
the U.S.) within 60 days of project construction. Any construction -related impacts
would occur primarily during and immediately after construction, and would be
expected to dissipate upon project completion.
6.4 Potential impacts on the living communities or human uses (Subparts D, E and F):
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6.4.1 Potential impacts on the biological characteristics of the aquatic ecosystem (Subpart
D). See Table 2:
Table 2 — Potential Impacts on Biological Characteristics
Minor
Minor
Biological
No
Negligible
Effect
Effect
Major
N/A
characteristics
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Threatened and
X
endangered species
Fish, crustaceans,
mollusk, and other
X
aquatic organisms
Other wildlife
X
Discussion: Implementation of the proposed project would permanently impact 4,129 If
of stream channel, temporarily impact 120 If of stream channel and permanently
impact 0.09 acres of wetlands within the 1,405 acre project area. Permanent impacts
would result from the placement of fill for new project slopes and temporary placement
of fill for temporary dewatering. These permanent impacts would adversely affect
aquatic functions within the impact areas, as these areas would no longer provide
nutrient filtration, sediment removal, hyporheic zone functions, and natural habitat for
aquatic species. All bottomless arch culverts would be installed to allow the passage
of low stream flows and the continued movement of fish and other aquatic life as well
as to prevent head -cutting of the streambed. No obstructions would be permanently
placed in streams that flow (and would flow) under the road. In order to allow for the
continued movement of bed load and aquatic organisms, existing channel widths and
depths would be maintained at the inlet and outlet ends of culverts. During
construction activities, there could be increases in suspended particulates that could
lead to increased turbidity in on-site streams. The applicant, however, would minimize
the effects of suspended particulates through the placement of appropriate and
required sediment and erosion control techniques in the area of disturbance. Any
permit that may be issued for this project would include a special condition that
requires the permittee to temporarily dewater all excavation and/or construction areas
in waters of the United States. Any construction -related impacts would occur primarily
during and immediately after construction, and would be expected to dissipate upon
project completion.
The only federally listed species that would be affected by this project is the Northern
long-eared bat (NLEB) (Myotis septentrionalis). Based on the August 4, 2015, USFWS
response, the determination of effects to the NLEB from this project is "may affect, not
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likely to adversely affect," based on removal of habitat (trees) in the range of the
NLEB. No federally designated critical habitat for any listed species would be affected
by this project.
6.4.2 Potential impacts on special aquatic sites (Subpart E). See Table 3:
Table 3 — Potential Impacts on Special Aquatic
Sites
Minor
Minor
Human Use
No
Negligible Effect
Effect
Major
Special Aquatic Sites
N/A
N/A
Effect
Effect (Short
(Long
Effect
(Short
(Long
Effect
Term)
Term)
Sanctuaries and
Term)
Term)
Municipal and private
X
refuges
X
Wetlands
X
Mud flats
X
Vegetated shallows
X
X
Coral reefs
X
commercial fisheries
Riffle pool complexes
X
Discuss: No sanctuaries, refuges, mud flats, vegetated shallows, or coral reefs are
located in the project area or in close proximity of the project area. All wetlands within
the project area have been avoided by the project. Implementation of this project
would be expected to have a minor, long-term effect to streams, as riffle pool complex
functions in the footprint(s) of the 446 If of permanent impacts would be lost or
diminished; compensatory mitigation would offset these effects to some degree.
6.4.3 Potential impacts on human use characteristics (Subpart F). See Table 4:
Table 4 — Potential Impacts on Human Use Characteristics
Minor
Minor
Human Use
No
Negligible
Effect
Effect
Major
N/A
Characteristics
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Municipal and private
X
water supplies
Recreational and
X
commercial fisheries
Water -related recreation
X
Aesthetics
X
Parks, national and
X
historical monuments,
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Table 4 — Potential Impacts on Human Use Characteristics
Physical characteristics
Hydrography in relation to known or anticipated sources of contaminants
Minor
Minor
of the project
Human Use
Known, significant sources of persistent pesticides from land runoff or
No
Negligible
Effect
Effect
Major
hazardous substances
N/A
Other public records or significant introduction of contaminants from
industries, municipalities, or other sources
Known existence of substantial material deposits of substances which
Characteristics
could be released in harmful quantities to the aquatic environment by man -
Effect
Effect
(Short
(Long
Effect
Term)
Term)
national seashores,
wilderness areas,
research sites, and
similar preserves
Discussion: The TIEC will be able to connect to the local municipal water supply of
Polk County and sewer system of the Town of Rutherfordton that was installed on the
site in 2007 & 2008 by the existing residential golf course community. There are no
known commercial fisheries, but there may be some public use of the on- site waters
for fishing or other forms of recreation. It is expected that the project area will shift to a
higher density of development than prior to the project and the addition of equine
facilities. Aesthetics is highly subjective, some county residents have expressed
support for the project, while others have expressed concern for the diminishing rural
area. Therefore, effect to aesthetics would be considered negligible.
6.5 Pre -testing evaluation (Subpart G, 40 CFR 230.60):
The following has been considered in evaluating the biological availability of possible
contaminants in dredged or fill material. See Table 5:
Table 5 — Possible Contaminants in Dredged/Fill Material
Physical characteristics
Hydrography in relation to known or anticipated sources of contaminants
Results from previous testing of the material or similar material in the vicinity
of the project
Known, significant sources of persistent pesticides from land runoff or
percolation
Spill records for petroleum products or designated (Section 331 of CWA)
hazardous substances
Other public records or significant introduction of contaminants from
industries, municipalities, or other sources
Known existence of substantial material deposits of substances which
could be released in harmful quantities to the aquatic environment by man -
induced discharge activities
Discussion: N/A
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It has been determined that testing is not required because Select
6.6 Evaluation and testing (Subpart G, 40 CFR 230-61):
Discussion: N/A
6.7 Actions to minimize adverse impacts (Subpart H). The following actions, as
appropriate, have been taken through application of 40 CFR 230.70-230.77 to ensure
minimal adverse effects of the proposed discharge. See Table 6:
Table 6 — Actions to Ensure Adverse Effects are Minimized
Actions concerning the location of the discharge
Actions concerning the material to be discharged
Actions controlling the material after discharge
Minor
Actions affecting the method of dispersion
Site
Actions affecting plant and animal populations
No
Actions affecting human use
Effect
Discussion: N/A
6.8 Factual Determinations (Subpart B, 40 CFR 230-11). The following determinations are
made based on the applicable information above, including actions to minimize effects
and consideration for contaminants. See Table 7:
Table 7 — Factual Determinations of Potential Impacts
Minor
Minor
Site
N/A
No
Negligible
Effect
Effect
Major
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Physical substrate
X
Water circulation, fluctuation
X
and salinity
Suspended
particulates/turbidity
X
Contaminants
X
Aquatic ecosystem and
X
organisms
Proposed disposal site
X
Cumulative effects on the
X
aquatic ecosystem
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Table 7 — Factual Determinations of Potential Impacts
Subject
Yes
No
1. Is there a practicable alternative to the proposed discharge that
Minor
Minor
would be less damaging to the environment (any alternative with
No
Negligible
Effect
Effect
Major
Site
N/A
2. Will the discharge cause or contribute to violations of any
X
applicable water quality standards?
Effect
Effect
(Short
(Long
Effect
4. Will the discharge jeopardize the continued existence of
Term)
Term)
Secondary effects on the
5. Will the discharge violate standards set by the Department of
X
X
aquatic ecosystem
Discussion: As discussed in Section 6.3, implementation of the proposed
alternative/project would impact 4,129 If of stream channel, temporarily impact 120 If
of stream channel and permanently impact 0.09 acres of wetlands within the 1,405
acre project area in which the Corps has determined that this alterative is the LEDPA.
Permanent impacts would result from the placement of fill for new project slopes and
temporary placement of fill for temporary dewatering during the installation of
bottomless arch culverts. The effects on physical substrate, water circulation,
fluctuation, salinity, suspended particulates/turbidity, and contaminates are detailed in
Section 6.3. The effects on the aquatic ecosystem and organisms are detailed in
Sections 6.3, 6.4.1, and 6.8. Any construction -related impacts would occur primarily
during and immediately after construction, and would be expected to dissipate upon
project completion.
6.9 Findings of compliance or non-compliance with the restrictions on discharges (40 CFR
230.10(a -d) and 230.12). Based on the information above, including the factual
determinations, the proposed discharge has been evaluated to determine whether any
of the restrictions on discharge would occur. See Table 8:
Table 8 — Compliance with Restrictions on Discharge
Subject
Yes
No
1. Is there a practicable alternative to the proposed discharge that
X
would be less damaging to the environment (any alternative with
less aquatic resource effects, or an alternative with more aquatic
resource effects that avoids other significant adverse environmental
consequences?)
2. Will the discharge cause or contribute to violations of any
X
applicable water quality standards?
3. Will the discharge violate any toxic effluent standards (under
X
Section 307 of the Act)?
4. Will the discharge jeopardize the continued existence of
X
endangered or threatened species or their critical habitat?
5. Will the discharge violate standards set by the Department of
X
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Table 8 — Compliance with Restrictions on Discharge
Subject
Yes
No
Commerce to protect marine sanctuaries?
6. Will the discharge cause or contribute to significant degradation of
X
waters of the U.S.?
N
7. Have all appropriate and practicable steps (Subpart H, 40 CFR
O U
230.70) been taken to minimize the potential adverse impacts of the
Z
X
discharge on the aquatic ecosystem?
c
Discussion: N/A
7.0 General Public Interest Review (33 CFR 320.4 and RGL 84-09)
The decision whether to issue a permit will be based on an evaluation of the probable
impacts, including cumulative impacts, of the proposed activity and its intended use on
the public interest as stated at 33 CFR 320.4(a). To the extent appropriate, the public
interest review below also includes consideration of additional policies as described in
33 CFR 320.4(b) through (r). The benefits which reasonably may be expected to
accrue from the proposal are balanced against its reasonably foreseeable detriments.
7.1 All public interest factors have been reviewed and those that are relevant to the
proposal are considered and discussed in additional detail. See Table 9 and any
discussion that follows.
Table 9: Public Interest Factors
Effects
N
.�
O U
Z
c
N .LM
c
Z Q
D
Z E
Z
m
Q
1. Conservation:
X
2. Economics:
X
3. Aesthetics:
X
4. General Environmental Concerns: There are no
additional general environmental concerns that are not
X
discussed/addressed in this review.
5. Wetlands: Approximately 0.09 acres of wetlands will be
filled as a result of this project and all functions/values
X
associated with this wetland will be lost.
6. Historic Properties: Refer to Section 10.3
X
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Table 9: Public Interest Factors
Effects
ON
c
5
O
U
Z
c
�
N
0)
C
O
Z Q
0
Z E
Z
CO
Q
7. Fish and Wildlife Values: See Section 10.1.2 for a
detailed discussion concerning Section 7(a)(2) of the ESA.
While construction of the project would be expected to impact
fish and wildlife resources, such as loss/reduction of food
sources, loss of habitat, clogging and/or abrading of gills,
etc., the permittee would employ measures such as
dewatering construction sites, adhering to all requirements of
X
the 401 Water Quality Certification that was issued for this
project, complying with all aspects of the Sedimentation
Pollution Control Act of 1973. As such, impacts to fish and
wildlife would be expected to be adverse, yet minor, and
those that are construction related would subside upon
completion of construction.
8. Flood Hazards: Four boulderj-hooks vanes will be
constructed on White Oak Creek to help stabilize a proposed
bridge crossing. The applicant has stated in their application
X
that they will work with Polk County to obtain any appropriate
floodplain approvals for development in a floodplain.
9. Floodplain Values: The streams and floodplains in the
project area provide many natural values, including water
quality maintenance, flood storage, energy dissipation, and
aquatic habitat for wildlife and plants. Culverts and pipes in
the impact areas are designed to adequately pass
X
anticipated flood flows. While some of these values would be
lost in the footprints of the fill, these areas do not constitute a
substantial amount. In the context of Polk County, the overall
effect on floodplain values would be minor.
10. Land Use: The residential component of this project is
already zoned and partially built as residential prior to
X
purchase.
11. Navigation:
X
12. Shoreline Erosion and Accretion:
X
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Table 9: Public Interest Factors
Effects
ON
c
5
O
U
Z
c
�
N
0)
C
O
Z Q
0
Z E
Z
CO
Q
13. Recreation: There is no known park located in the
project area. Additionally, implementation of this project
would not be expected to affect any downstream recreational
activities (assumed activities — none identified). Since a
portion of the permitted activities support the completion of
X
an equestrian center including various competitions year
round and sports such as polo, the recreational component of
this property has been increased. Also, a previously
developed but not used golf course will likely be improved
and provide additional recreational opportunity.
14. Water Supply and Conservation: Although an existing
residential community already existed on portions of the
project area, additional development will be completed. This
will provide for additional water consumption and increase
impervious surface in the area, thereby decreasing
localized water infiltration and recharge. Prior approval was
given for connectivity to the Polk County water supply
therefore no unknown strains should be placed on its
X
infrastructure. Since the development stayed under state
impervious surface density thresholds for requirement of
stormwater plans, the overall reduced infiltration should be
negligible over the entire project area. Construction activities
would be expected to require a minimal amount of water;
however, the structures would not require water input post -
construction.
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Table 9: Public Interest Factors
Effects
ON
c
5
O
U
Z
c
�
N
0)
C
O
Z Q
0
Z E
Z
CO
Q
15. Water Quality: The proposed impacts to waters of the
U.S. for this project would affect numerous stream
functions, as previously discussed in this document, to
include water quality. The avoidance and minimization
measures that the applicant would employ, and the
compensatory mitigation provided by the applicant, would
adequately compensate for these impacts. The NCDWR
issued a Certification with Additional Conditions Modification
Correction (Certification No. WQC4047) on November 14,
2016. Special conditions were issued and a copy of these
conditions is attached to this document. With this
conditioned certification, the state has verified that this
X
project would meet all applicable state water quality
standards and also complies with Section 401 of the CWA.
The Water Quality Certification, including all conditions
stated therein, would be made a part of any permit which
may be issued for this project. No substantial impacts to
water quality would be expected; however, minor and
temporary adverse impacts may result, including increases
in turbidity, during construction. These would subside upon
completion of construction. Overall the effect on area water
quality would be negligible.
16. Energy Needs: Construction of the project would require
the use of petroleum products for operation of construction
equipment. Additional development within the project area is
X
expected to increase the consumption of electricity. Overall,
implementation of the proposed project would be expected to
have a negligible effect on energy supply/needs.
17. Safety: A permanently increased local resident
population and sporadically increased event based
population is expected to caused increased safety concerns
due to issues such as increased traffic. Since the area
X
already contains a development, is adjacent to Hwy 74 which
is a major transportation corridor and there is increased
traffic safety considerations as part of the project, overall
effects should be negligible.
18. Food and Fiber Production:
X
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Table 9: Public Interest Factors
Effects
ON
c
5
O
U
�
O
0
z E
Z
CO
Q
19. Mineral Needs:
X
20. Consideration of Property Ownership:
X
21. Needs and Welfare of the People: Although some local
residents will see an increase in development density and
event based population increases for area the increase in
X
economic opportunity and both recreational/residential
opportunities for an traditionally horse loving community are
overall positive for the area.
Additional discussion of effects on factors above: N/A
7.2 The relative extent of the public and private need for the proposed structure or work:
Through their market research, the developers have determined the need for this type
of equestrian facility combined with a residential development. This appears to be
supported by the influx of attendees at the competitions and residents moving into the
area.
7.3 If there are unresolved conflicts as to resource use, explain how the practicability of
using reasonable alternative locations and methods to accomplish the objective of the
proposed structure or work was considered.
Discussion: There were no unresolved conflicts identified as to resource use.
7.4 The extent and permanence of the beneficial and/or detrimental effects that the
proposed work is likely to have on the public and private use to which the area is
suited:
Detrimental effects are expected to be minimal and permanent.
Beneficial effects are expected to be minimal and permanent.
Provide rationale here as needed to support the determinations above.
8.0 Consideration of Cumulative Impacts
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(40 CFR 230.11(g) and 40 CFR 1508.7, RGL 84-9) Cumulative impacts result from
the incremental environmental impact of an action when added to all other past,
present, and reasonably foreseeable future actions. They can result from individually
minor direct and indirect but collectively significant actions taking place over a period
of time. A cumulative effects assessment should consider both direct and indirect, or
secondary, impacts. Indirect impacts result from actions that occur later in time or are
farther removed in distance from the original action, but still reasonably foreseeable.
8.1 Identify/describe the direct and indirect effects of the proposed activity: See Sections 6
and 7 for detailed discussions of direct and indirect effects. There may be an increase
in the potential for the proposed project to result in a change or increase in the relative
attractiveness of the area and its subsequent growth. However, this area is already
known for its equestrian community and much of the area purchased was already
developed or planned for residential development, so this project when considered
with impacts as discussed in the geographic scope below is not expected indirectly
affect land use in a significantly adverse way.
8.2 The geographic scope for the cumulative effects assessment is: The geographic area
for this assessment is the Upper Broad watershed, subbasin 03050105. According to
the 2008 NC DWQ (now NC DWR) Broad River Basin Plan, the Broad River basin
encompasses 5,419 square miles within North and South Carolina. The North
Carolina portion covers 1,513 square miles - nearly 28 percent of the entire
watershed. This basin plan estimates 1,508 linear miles of stream within the NC
portion of this basin. The headwaters and major tributaries in the Broad River basin
begin in the Blue Ridge Mountains of western North Carolina. The river continues to
flow south-southeast through the foothills and southern piedmont into Cherokee
County, South Carolina where it eventually joins the Congaree and Santee Rivers and
then the Atlantic Ocean. Population distribution and land cover patterns are highly
variable in the Broad River basin. Land use varies from generally undisturbed areas in
the headwater tributaries to relatively urban areas where much of the population can
be found around the Towns of Spindale, Forest City, Rutherfordton, and the City of
Shelby. According to 2001 NRI Land Cover data, nearly 66 percent of the land in the
basin is forested, and approximately 23 percent is agricultural. Nine percent is
developed.
Based on the watershed plan with regards to impairments for this basin, in most
cases, habitat is degraded by the cumulative effect of several stressors acting in
concert. These stressors often originate in the upstream portions of the watershed
and may include runoff from impervious surface, sedimentation, and erosion from
construction, general agricultural practices, or other land disturbing activities.
Naturally erodible soils in the Broad River basin make streams highly vulnerable to
these stressors. Habitat degradation (as indicated by impaired biological integrity and
high turbidity) was identified as a stressor for nearly 270 miles of streams in the
Broad River basin. The distribution of turbidity violations and sample locations make
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it difficult to isolate a single source of erosion in the Broad River basin. However, it
appears that violations are highest in urban transition and agricultural areas.
Violations are lowest in the upper part of the basin where land use is predominantly
forested.
The first historical impacts that most likely occurred in this area probably resulted
from the conversion of forested land to agricultural land, and included the drainage
of wetland areas and channelization of creeks to increase the amount of productive
land.
The effect that these activities have had to the aquatic ecosystem can still be seen.
The incised condition of many of the stream channels, for instance, is in part due to
changes in runoff associated with the conversion of forested areas to agricultural
areas or urban areas. Unfortunately, it is nearly impossible to quantify many of these
historical impacts because of the lack of documentation. Eventually portions of these
agricultural and silvicultural watershed areas upstream of the project site have been
converted to residential, commercial and transportation uses.
Impacts that are known to have occurred within this watershed in the recent past,
based on review of the USGS topographic maps, are primarily due to fill material
placed for the construction of transportation crossings, urbanization of the watershed,
construction of small impoundments, and agricultural and forestry activities. The
cumulative effect of these has resulted in an incremental degradation of riverine and
wetland functions.
With respect to water quality and habitat, the conversion of wetlands and stream
channels to agricultural ditches, roadways, parking lots, and fill for building sites
results in a complete loss of function, including the capacity to filter pollutants,
sediment, and nutrients from water. The agricultural ditches, road surfaces and
associated storm drains also serve as a conduit for additional pollutants to enter the
system. These changes also have a detrimental effect on aquatic and riparian habitat
downstream as channels are subject to erosive flows and sediment deposition. The
long-term cumulative effects would also include the incremental loss of stormwater
retention, baseflow maintenance, groundwater recharge, sediment transport, etc.
8.3 The temporal scope of this assessment covers: The temporal scope of this document
ranges from general cumulative impacts taking place over hundreds of years, to
directly recorded impacts from the Corps database since January 1, 2000 and even
reasonably foreseeable future impacts as a result of this project.
8.4 Describe the affected environment: See Section1.4 and 8.2
Authorized impacts to water of the U.S. between January 1, 2000 and December 22,
2016 by previously issued Department of the Army permits for permanent impacts to
stream channels in the Upper Broad subbasin total approximately 202,636 linear feet
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according to a database report. This report also showed 365,880 linear feet of
mitigation required for this subbasin over the same timeframe. This timeframe was
selected due to data entry problems in our previously used database (RAMs) prior to
2000 and then conversion issues from RAMS to our new database tracking system
(ORM2). It has been determined that data from January 1, 2000 till the present offers
a reasonable representation of impacts during this time frame. This data will not show
all the impacts that occurred at the beginning of the implementation of Section 404 of
the Clean Water Progam, but it does show a general trend of impacts in the
watershed.
8.5 Determine the environmental consequences: Impacts similar to the proposal are
typical of other activities in this region and the urban portions of the subbasin.
Secondary effects on the aquatic environment associated with the proposed project
generally would result from the conversion of a small amount of upland to impervious
surfaces, and the loss of in -stream and riparian habitat. A minor amount of
sedimentation may occur from construction of the project itself and therefore some
minor changes in water chemistry and turbidity are possible.
Overall, the cumulative effect of past activities within the watershed is relatively
minimal, considering the remaining length of relatively undisturbed channel in the
watershed. The cumulative effects of the proposed activity are minimal due to the
minor amount of impact to stream channels and wetlands on the site. The applicant
has attempted to minimize these effects further with the use of proper construction
techniques. Cumulative effects can also be minimized by the proper enforcement of
permit conditions, including the regular maintenance of sediment control devices.
The proposed project, in association with similar activities, does have the potential to
result in adverse cumulative impacts on the aquatic ecosystem; however it is expected
that other projects in the area would be implemented as follows: projects would use
erosion control measures, silt fencing, and other BMPs; sufficient storm water
management structures would be constructed as part of new construction; erosion and
sedimentation control plans would be filed in accordance with the Sedimentation
Pollution Control Act of 1973 (North Carolina General Statutes Chapter 113A Article
4); and all projects would be conducted in accordance/in compliance with federal,
state, and local laws and requirements. This includes obtaining and adhering to
appropriate CWA permits, including compliance with compensatory mitigation
requirements outlined in permit(s).
We have determined that the proposed project, with proposed special permit
conditions, would not have significant impacts on the aquatic ecosystem when
considered alone or in concert with the other past, present and reasonably
foreseeable future projects in the project vicinity.
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8.6 Discuss any mitigation to avoid, minimize or compensate for cumulative effects: other
than the avoidance and minimization efforts discussed in Section 1.3.1, and the
compensatory mitigation for losses of waters of the U.S. associated with this project
(see Section 1.3.2 and 9), no other mitigation was proposed for this project.
8.7 Conclusions regarding cumulative impacts:
When considering the overall impacts that will result from this project, in relation to the
overall impacts from past, present, and reasonably foreseeable future projects, the
cumulative impacts are not considered to be significantly adverse. Compensatory
mitigation will be required to help offset the impacts.
9.0 Mitigation(33 CFR 320.4(r), 33 CFR Part 332, 40 CFR 230.70-77, 40 CFR 1508.20
and 40 CFR 1502.14)
9.1 Avoidance and Minimization: When evaluating a proposal including regulated
activities in waters of the United States, consideration must be given to avoiding and
minimizing effects to those waters. Avoidance and minimization measures are
described above in Sections 1.
Were any other mitigative actions including project modifications discussed with the
applicant that were implemented to minimize adverse project impacts? (see 33 CFR
320.4(r)(1)(i)) Select Yes or No
Describe here.
9.2 Is compensatory mitigation required to offset environmental losses resulting from
proposed unavoidable impacts to waters of the United States? Yes
If no, rationale: Describe here
9.3 Type and location of compensatory mitigation
9.3.1 Is the impact in the service area of an approved mitigation bank? Yes
If yes, does the mitigation bank have appropriate number and resource type of credits
available? Yes
9.3.2 Is the impact in the service area of an approved in -lieu fee program? Yes
If yes, does the in -lieu fee program have the appropriate number and resource type of
credits available? Yes
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9.3.3 Selected compensatory mitigation type/location(s). See Table 10:
Table 10 — Mitigation Type and Location
Mitigation bank credits
X
In -lieu fee program credits
Permittee -responsible mitigation under a watershed approach
Permittee -responsible mitigation, on-site and in-kind
Permittee -responsible mitigation, off-site and/or out of kind
9.3.4 Does the selected compensatory mitigation option deviate from the order of the
options presented in §332.3(b)(2)-(6)? Yes
If yes, provide rationale for the deviation, including the likelihood for ecological
success and sustainability, location of the compensation site relative to the impact site
and their significance within the watershed, and/or the costs of the compensatory
mitigation project (see 33 CFR §332.3(a)(1)):
At the time of the application submittal there were no approved banks within the
watershed of the proposed project. There were approved In -lieu fee credits available
for purchase within the proposed project watershed. The applicant initially submitted to
purchase a portion of the needed compensatory mitigation from the NCDMS (state
approved In -lieu fee program) and later submitted mitigation plans for off-site in-kind
permittee responsible mitigation. The site chosen for restoration (Harmon Dairy
Stream Mitigation Project Site) was verified by both the Corps and the NCDWR as
having impaired function that was a good candidate for uplift. The restoration site is in
the same watershed and approximately 5 miles from the impact locations, which is
likely to be closer than the In -lieu fee site location. The restoration project was
designed by an experienced local engineer with a low risk project approach.
Appropriate performance standards, monitoring, financial assurances, long term
management and preservation mechanisms were all incorporated into the final
mitigation plan.
9.4 Amount of compensatory mitigation: 8,088 linear feet of stream
Rationale for required compensatory mitigation amount: Refer to Section 1.3.2.
9.5 For permittee responsible mitigation identified in 9.3.3 above, the final mitigation plan
must include the items described in 33 CFR 332.4(c)(2) through (c)(14) at a level of
detail commensurate with the scale and scope of the impacts. As an alternative, the
district engineer may determine that it would be more appropriate to address any of
the items described in (c)(2) through (c)(14) as permit conditions, instead of
components of a compensatory mitigation plan. Presence of sufficient information
related to each of these requirements in the applicant's mitigation plan is indicated by
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"Yes" in Table 11. "No" indicates absence or insufficient information in the plan, in
which case, additional rationale must be provided below on how these requirements
will be addressed through special conditions or why a special condition is not required:
Table 11 — Permittee -Responsible Mitigation Plan Requirements
Requirement
Yes No
Objectives
X
Site selection
X
Site protection instrument
X
Baseline information
X
Determination of credits
X
Mitigation work plan
X
Maintenance plan
X
Performance standards
X
Monitoring requirements
X
Long-term management plan
X
Adaptive management plan
X
Financial assurances
X
Other
For any "No", provide rationale on how the subject component(s) of the compentatory
mitigation plan will be addressed as special conditions or why no special conditions
are required:
10.0 Compliance with Other Laws, Policies, and Requirements
10.1 Section 7(a)(2) of the Endangered Species Act (ESA): Refer to Section 2.2 for
description of action area for Section 7.
10.1.1 Has another federal agency taken steps to document compliance with Section 7 of the
ESA and completed consultation(s) as required? No
If yes, identify that agency, the actions taken to document compliance with Section 7
and whether those actions are sufficient to ensure the activity(s) requiring DA
authorization is in compliance with Section 7 of the ESA:
10.1.2 Known species/critical habitat present: Yes
Effect determination (s), including no effect, for all known species/habitat, and basis for
determination(s):
A "no effect' determination was made for three listed species: dwarf flowered
heartleaf (Hexastylis naniflora), white irisette (Sisyrinchium dichotomum) and small
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whorled pagonia (Isotria medeoloides). A "may affect, not likely to adversely affect
determination was made for northern long-eared bat (NLEB) (Myotis septentrionalis).
The individual permit application indicates that surveys for federally listed species
were conducted in 2007 and in 2014. According to the information that was gathered
during the surveys, the project site contains suitable habitat for several federally listed
species including the federally endangered white irisette, as well as dwarf flowered
heartleaf, small whorled pogonia and northern long-eared bat which are all currently
federally listed as threatened species. Dwarf -flowered heartleaf was the only federally
listed species found to occur on the site; however, it occurs in an area that will not be
impacted by development. Though suitable habitat is present, surveys were not
conducted for northern long-eared bat within the project area. The USFWS
commented, by letter dated August 4, 2015, "We concur with your 'not likely to
adversely affect' determination and we believe the requirements under section 7(c) of
the Endangered Species Act are fulfilled for this species." Since the initial USFWS
comment, The USACE conducted a GIS review of the project and surrounding areas
and also reviewed the most current maps of confirmed/known hibernation and
maternity (tree) sites for the NLEB at
http://www.fws.gov/asheville/htmis/prosect review/NLEB in WNC.html. This project is
located outside of the highlighted areas/red 12 -digit HUCs and does not require
prohibited incidental take; as such, this project meets the criteria for the 4(d) rule and
any associated take is exempted/excepted.
10.1.3 Consultation with either the National Marine Fisheries Service and/or the U.S. Fish
and Wildlife Service was initiated and completed as required, for any determinations
other than "no effect" (see the attached "Summary" sheet for begin date, end date and
closure method of the consultation). Based on a review of the above information, the
Corps has determined that it has fulfilled its responsibilities under Section 7(a)(2) of
the ESA.
10.2 Magnuson -Stevens Fishery Conservation and Management Act (Magnuson -
Stevens Act), Essential Fish Habitat (EFH). N/A, there is no essential fish habitat in
this district's area of responsibility.
10.2.1 Has another federal agency taken steps to comply with the EFH provisions of the
Magnuson -Stevens Act? No
If yes, identify the agency, the actions taken to document compliance with the
Magnuson Stevens Act and whether those actions are sufficient to ensure the
activity(s) requiring DA authorization is in compliance the EFH provisions.
10.2.2 Did the proposed project require review under the Magnuson -Stevens Act? No
10.2.3 If yes, EFH species or complexes considered: Enter EFH species or complexes
considered here
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Effect determination and basis for that determination: Provide determination(s) and
rationale here.
10.2.4 Consultation with the National Marine Fisheries Service was initiated and completed
as required (see the attached "Summary" sheet for consultation type, begin date, end
date and closure method of the consultation). Enteradditional discussion here as
needed. Based on a review of the above information, the Corps has determined that it
has fulfilled its responsibilities under EFH provisions of the Magnuson -Stevens Act.
10.3 Section 106 of the National Historic Preservation Act (Section 106): Refer to
Section 2.3 for permit area determination.
10.3.1 Has another federal agency taken steps to comply with Section 106 and completed
consultation(s) as required?
No
If yes, identify that agency, the actions taken to document compliance with Section
106 and whether those actions are sufficient to ensure the activity(s) requiring DA
authorization is in compliance with Section 106 of the NHPA.
10.3.2 Known cultural resource sites present and/or survey or other additional information
needed? Yes
Basis for effect determination (s) for all known site(s) and/or site(s) identified by a
survey:
A `no effect' determination was made in regards to cultural/archaeological resources on
the site. During the previous permit submittal/approval, Section 106 of the National
Historic Preservation Act (NHPA) was completed. Ultimately, archaeological surveys
were conducted in which several ineligible resources were identified and/or resources
were not located within proposed impact areas and therefore eligibility determinations
were not made. One archeological site (31 PL90) was not evaluated for an eligibility
determination since they were not in/near the proposed site, however this site was
subsequently assessed as part of this permit modification and determined to be
ineligible. Archaeological surveys for the recently added 73 -acre parking parcel (Parcel
P106-23) was recently conducted as well in which no resources were found. An
archeological survey of the 24 -acres North Parcel was not conducted due to its current
condition as a parking area since 2015. The North Carolina State Historic Preservation
Office (SHPO) concurred with these eligibility determinations and concurred that there
were no impacts proposed to cultural/archaeological resources by a letter dated XXX.
The Mill Cemetery (part of 31 PL83) and the other on-site 19th century cemetery will still
be protected from disturbance in accordance with INC G.S.14.
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10.3.3 Consultation was initiated and completed as required with the appropriate agencies,
tribes and/or other parties for any determinations other than "no potential to cause
effects" (see the attached "Summary" sheet for consultation type, begin date, end date
and closure method of the consultation). Based on a review of the information above,
the Corps has determined that it has fulfilled its responsibilities under Section 106 of
the NHPA.
10.4 Tribal Trust Responsibilities
10.4.1 Was government -to -government consultation conducted with Federally -
recognized Tribe(s)? Select Yes or No
Provide a description of any consultation(s) conducted including results and how
concerns about significant effects to protected tribal resources, tribal rights and/or
Indian lands were addressed. Provide additional discussion here as needed ordelete
if not needed The Corps has determined that it has fulfilled its tribal trust
responsibilities.
10.5 Section 401 of the Clean Water Act — Water Quality Certification (WQC)
10.5.1 Is a Section 401 WQC required, and if so, has the certification been issued or waived?
Select appropriate option
10.6 Coastal Zone Management Act (CZMA)
10.6.1 Is a CZMA consistency concurrence required, and if so, has the concurrence been
issued, waived or presumed? N/A, a CZMA consistency concurrence is not required.
10.7 Wild and Scenic Rivers Act
10.7.1 Is the project located in a component of the National Wild and Scenic River System, or
in a river officially designated by Congress as a "study river" for possible inclusion in
the system? No
If yes, summarize coordination and the determination on whether activity will
adversely affect the Wild and Scenic River designation or study status. The Corps has
determined that it has fulfilled its responsibilities under the Wild and Scenic Rivers Act.
10.8 Effects on Federal Projects (33 USC 408)
10.8.1 Does the applicant also require permission under Section 14 of the Rivers and
Harbors Act (33 USC 408) because the activity, in whole or in part, would alter,
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occupy or use a Corps Civil Works project? No, there are no federal projects in or
near the vicinity of the proposal.
If yes, provide date that permission is provided:
10.9 Corps Wetland Policy (33 CFR 320.4(b))
10.9.1 Does the project propose to impact wetlands? Yes
10.9.2 Based on the public interest review herein, the beneficial effects of the project
outweigh the detrimental impacts of the project.
10.10 Other (as needed): Provide discussion here as needed.
11.0 Special Conditions
11.1 Are special conditions required to protect the public interest, ensure effects are not
significant and/or ensure compliance of the activity with any of the laws above? Select
Yea or AJo
If no, provide rationale: Describe rationale
11.2 Required special condition(s)
Special condition(s): Enterspecific condition(s)
Rationale: Enterrationale here
12.0 Findings and Determinations
12.1 Section 176(c) of the Clean Air Act General Conformity Rule Review: The proposed
permit action has been analyzed for conformity applicability pursuant to regulations
implementing Section 176(c) of the Clean Air Act. It has been determined that the
activities proposed under this permit will not exceed deminimis levels of direct or
indirect emissions of a criteria pollutant or its precursors and are exempted by 40 CFR
Part 93.153. Any later indirect emissions are generally not within the Corps'
continuing program responsibility and generally cannot be practicably controlled by the
Corps. For these reasons a conformity determination is not required for this permit
action.
12.2 Presidential Executive Orders (EO):
12.2.1 EO 13175, Consultation with Indian Tribes, Alaska Natives, and Native Hawaiians:
This action has no substantial effect on one or more Indian tribes, Alaska or Hawaiian
natives.
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12.2.2 EO 11988, Floodplain Management: There is minor work in the floodplain along White
Oak Creek which consists of four boulder J -hook vanes to stabilize an eroding section
of bank and to help reduce the risk of a bridge being washed away during high flows.
It is not anticipated that this work will adversely affect the floodplain and any local
approvals needed will be received before conducting the work.
12.2.3 EO 12898, Environmental Justice: The Corps has determined that the proposed
project would not use methods or practices that discriminate on the basis of race,
color or national origin nor would it have a disproportionate effect on minority or low-
income communities.
12.2.4 EO 13112, Invasive Species: There are no invasive species issues involved in this
proposed project.
12.2.5 EO 13212 and EO 13302, Energy Supply and Availability: The proposal is not one
that will increase the production, transmission, or conservation of energy, or
strengthen pipeline safety.
12.3 Findings of No Significant Impact: Having reviewed the information provided by the
applicant and all interested parties and an assessment of the environmental impacts, I
find that this permit action will not have a significant impact on the quality of the
human environment. Therefore, an environmental impact statement will not be
required.
12.4 Compliance with the Section 404(b)(1) Guidelines: Having completed the evaluation
above, I have determined that the proposed discharge complies with the Guidelines.
12.5 Public interest determination: Having reviewed and considered the information above,
I find that the proposed project is not contrary to the public interest.
PREPARED BY:
Date:
Project Manager
REVIEWED BY:
Enter name of appropriate /eve/ reviewer
APPROVED BY:
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nternarr7e of appropriate /eve/ approver
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