20131200 Ver 5_2nd 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 3:50 PM
To: Burdette, Jennifer a
Subject: FW: Additional Information Requested Regarding TIEC Response to Corps Comments
Attachments: Letter fofrom Polk Co Soil Water for Harmon Dairy080317.pdf, TIEC mit plan
addendum letter 8-3-17 Wildlands.pdf
Forwarding my July 26th additional info request email and Clements August 3rd response (best viewed in html). Clement is
on vacation right now, but I will be following up with him on Monday.
Steve
From: Clement Riddle [mailto:[e-mail]]
Sent: Thursday, August 03, 2017 10:14 PM
To: Jones, M Scott (Scott) CIV USARMY CESAW (US) <[e-mail]>
Cc: Kichefski, Steven L CIV USARMY CESAW (US) <Steven. L.Kichefski @usace.army.miI>, Tugwell, Todd J CIV USARMY
CESAW (US) <[e-mail]>
Subject: [Non-DoD Source] RE: Additional Information Requested Regarding TIEC Response to Corps Comments
Steve,
Thank you for sending us your comments. Additional information as requested in your email July 26, 2017 and
as discussed with Mr. Scott Jones in a meeting on July 31, 2017 is being been submitted in this email below. A
copy of the revised mitigation plan is being brought to your office Friday August 4th. A copy of this plan is also
available for download on our dropbox at
Blocl<edhttr)s://www.dror)box.com/s/tu9ilrn8lxo3mma/747%20Final%20Phase%202%20Harmon%20Dairy%20
Mit%20DIan%20revised%208-3-17.Ddf?dl=0
I have received and reviewed the additional information that was sent the evening of July 18, 2017. The additional
information provided justifies why all alternatives cannot be the LEDPA except for Multipurpose Field Alternative
#2, #3 and #7 east. Please provide further detail based on the questions below:
1. Multipurpose Field Alternative #2 - Please provide additional information to support your reasoning for
this alternative not being feasible or practicable.
a. Your response states that "...construction at this location would not be allowed by the gas/utility
company." It appears many other areas of TIEC are built or proposed to build infrastructure of
some sort over the gas line. What is different about the polo field that makes building on top of
the gas line not an option? Will any portion of the gas line be utilized by the preferred field
location and, if so, what?
Please note that there is no major infrastructure located on top of the gas line within the
existing or proposed resort. The original overall site master plan (Figure 7A) submitted in
February 16, 2017 highlights the gas line route in orange. The current gas line through the
resort consists of a grass strip, road crossings, and a few parking spaces. In the event of
needed repair or access to the line right of way (ROW), the majority of bridal paths, road

crossings or parking areas will still be accessible even with this maintenance
disturbance. The Multipurpose Field 2 (MF2) alternative location would have the gas line
bisecting the polo field. Maintenance activities on the gas line within any portion a
significant equestrian facility, such as the MF2-polo field, would render the field unusable
for months, not just for maintenance but also for re -growing sufficient safe turf for safe
footing for horses. All of the applicant's current equestrian performance areas have
avoided construction on top of the gas line for these reasons. The applicant is trying to
limit down time resulting from any future maintenance or problems with the gas line.
There will be some parking and road crossing at the polo field location, however, the
preferred alternative multi-purpose/polo field will not be located over the gas line.
b. If the field were moved further east from the preferred option, your comments expressed concern
over the redundancy of infrastructure and amenities making this option impracticable. What
infrastructure/amenities would the preferred alternative shore that the further option would not
benefit from? With o 10 -acre field, would any concessions, restrooms, or parking need to be
constructed anyway for the preferred field location? How would the horses be handled differently
for the preferred option os far os shored infrastructure (off-loading and barns)?
As noted previously, the development goals and vision for this facility are focused around
creating a central amenity area that can be easily accessed by spectators and participants
similar to most development models in which there is a central area in which a majority of
the infrastructure is concentrated. There are many reasons for this, one of which being a
response to market demands/preferences that have been researched/proven over time and
also corresponds to financial success. A proven assumption is that the further away an
event is from the main facility the less likely it will be accessed by spectators and visitors
to the facility who are not expressly there to watch polo. Based on current trends in visitors
to the facility, many spectators/visitors come to the facility for the experience of the
amenities at the main facility and then explore the different type of equestrian events
occurring at that time. This is also true for the reverse for participants that come to event
and then can easily access nearby restaurants and shopping when their events are
completed. By locating this polo field away from the main facility, there will likely be less
spectators and visitors using this area so it is not financially practicable or feasible to create
redundant amenities (like restaurants/shopping) that won't be utilized. Due to the preferred
alternative's location closer to the main facility, spectators/visitors/participants to this area
can much more easily access the amenities in the main facility (and vice versa) and
therefore will likely do so.
The preferred alternative allows for shared uses of all the infrastructure (parking and
barns), amenities, (i.e. parking, restaurants, shopping, restrooms), utilities (water and
electric) and maintenance for the long-term use as a polo field. The short-term facilities
such as vendor tents additional restrooms will be utilized during the World Equestrian
Games. Long term this preferred alternative location would house minor concessions
during events which would be from vendors that are supplied by restaurants in the main
facility. There would be nearby restrooms as well similar to that located in various parts of
the main facility (i.e. there is no `central' bathroom area currently and there are multiple
locations throughout the facility).
There are no large-scale amenities such as restaurants or shopping venues shown at this
more eastern MF2 location because there would not be enough
N

spectators/visitors/participants for polo competitions by itself to support this redundancy
in this type of infrastructure located in the main facility. Conceptually this alternative
location is shown with minimal areas that would allow essential infrastructure such as
spectator parking, restroom facilities and watering stations for the horses. Horses would
have to be trailered/driven/unloaded in this area from the barns located at the main facility
and then return back to their stalls/barns at the main facility. Maintenance equipment such
as mowers, tractors, and waste management would have to be redundant for this area as
well since it is centralized at the main facility. Currently the conceptual plan for the M172
alternative shows a narrow (50-60 feet wide) area surrounding the field that would allow
for the minimal infrastructure noted above and access around the field.
c. Feasibility -Con the polo alternative (to the east of the endurance race start/finish line) location and parking
be adjusted to provide additional buffer between White Oak Creek so as to provide more conducive grading
issues and further avoid/minimize impacts to the UT's to White Oak Creek. For example, shifting the field
further west even if it means adjusting the endurance race infrastructure and start/finish line location.
The area shown as this alternative location was the closest location that would allow the
minimum size configuration needed for the field. There isn't enough room (north -south)
for the M172 polo field as shown on the 7/18/17 plan to move this field slightly to the west
even if the endurance race infrastructure could be adjusted. The property boundary narrows
in this area and is even further confined due to a meander bend in White Oak Creek which
makes this area too small for the standard field size. The property to the north is owned by
local residents and is not available for sale/purchase. In order to shift this alternative
location to the west, an undetermined amount of White Oak Creek would need to be
filled/armored/relocated in the southwest corner of the field. For these reasons, the location
for the alternative was shown to the furthest extent west as possible given these constraints.
For this alternative proposed location (MF2), over 75% of the surrounding parking and
area allotted for minimal infrastructure would be lost in order to avoid impacting the
tributary in the NE corner and creating a wider buffer on the southern end of the field to
White Oak Creek. By removing these areas, there would only be one main area for parking,
spectator viewing, horse traffic which would all concentrated on the western side of the
field and there would be no way to access the eastern portion of the field without exiting
the facility and going back out to Pea Ridge and then entering back in where the residential
area is proposed. With minimal infrastructure already conceptually shown for this area
(which is only 60 -feet wide), any reduction in this area makes the feasibility of this
alternative even more impracticable for use as a spectator friendly and safe/accessible
competitive polo field.
As stated previously, stream impacts under this proposed alternative are conservatively
estimated at approximately 1376-1576 linear feet (including 446 from previously approved
impacts). Also based on grading required, an undetermined amount of White Oak Creek
would need to be filled/armored/relocated in the southwest corner of the field. Currently
proposed impacts with the preferred alternative total 2,054 linear feet of stream channel
but is able to avoid any impacts to White Oak Creek and will be located on stream channels
that were previously approved to be impacted. Overall impacts would likely be similar to
the preferred alternative but would not meet the applicant's purpose/need.
3

d. Depending on the responses to the three items listed above, further information could be needed to
determine the practicability of any lost residential lots as a result of moving the polo field. Based on the
submitted plans, options appear available for moving the road network in a way to still support this
residential area without significant additional impacts.
The applicant believes that sufficient information has been provided above as to why MF
2 will not be suitable as shown or slightly further west. The applicant has not created a
new subdivision layout for the potential future subdivision roads affected by MF2. The
stream impact estimates are based on the numerous stream segments and steep topography.
2. Multipurpose Field Alternative #3 - Since this alternative depends on whether the Multipurpose Field LEDPA
involves a different location/configuration then the preferred alternative as presented, there may need to be
additional information provided as to why the temporary infrastructure needed for the endurance event/polo
exhibition cannot be moved/puzzled to further avoid/minimize impacts. This additional information will depend
upon your responses to the other two alternatives discussed in this email.
Even is some of the temporary WEG infrastructure (south of the multipurpose field) can be moved
"puzzled" for WEG, this area is still going to be used long term for the polo field. The site plan
submitted on July 18, 2017 shows that the MF2-polo field does not fit in the area east of the
preferred alternative location without significantly impacting White Oak Creek. There is even less
area for a polo field at the MF 3 alternative location (west of MF2). This appears to be the same
area as discussed above in questions I.e. above.
3. Multipurpose Field Alternative #7 East -The feasibility of this alternative depends in part to answers provided for
Alt#2 above regarding the shared versus new infrastructure/amenities needed. There is a bridge proposed (or
already built) on either side of this location, could these bridges either be utilized or moved to prevent the need for
an additional $750,000 bridge?
The bridge over White Oak Creek has already been built and was constructed at its current location
as it is approximately in the middle of the site and has gentle topography on both sides of the
stream for ease of construction. The bridge at this location also takes advantage of the paved road
locations that were existing at the time of purchase of the property.
The long-term use for this bridge access is planned for residential components of the
development. For the WEG games and other large-scale events, the bridge and road will be used
for shuttle buses from the remote spectator parking lots to the facility. The access road from the
south side of the resort to the main equestrian facility is critically important to moving residents
and spectators to the facility and back.
Using the existing bridge to access a remote multipurpose/polo field would require spectators to
drive approximately 1.51 mile away from the existing Equestrian center and amenities. A second
bridge is planned over White Oak Creek further to the west. This bridge is not under construction
and would also be approximately 1-1.3 miles from MF 7. This distance would be too far to
incorporate golf cart access and eliminate the use of any shared facilities for spectators. The
distance between the facilities would likely lessen the success of the polo operation by separating
this activity from the rest of the resort.
The preferred alternative allows for shared uses of all the infrastructure (parking and barns),
amenities, (i.e. parking, restaurants, shopping, restrooms), utilities (water and electric) and
maintenance for the long-term use as a polo field. The short-term facilities such as vendor tents
additional restrooms will be utilized during the World Equestrian Games. Long term this preferred

alternative location would house minor concessions during events which would be from vendors
that are supplied by restaurants in the main facility. There would be nearby restrooms as well
similar to that located in various parts of the main facility (i.e. there is no `central' bathroom area
currently and there are multiple locations throughout the facility).
There are no large scale amenities such as restaurants or shopping venues shown at this MF7
location because there would not be enough spectators/visitors/participants for polo competitions
by itself to support this redundancy in this type of infrastructure located in the main facility.
Conceptually this alternative location is shown with minimal areas that would allow essential
infrastructure such as spectator parking, restroom facilities and watering stations for the
horses. Horses would have to be trailered/driven/unloaded in this area from the barns located at
the main facility and then return back to their stalls/barns at the main facility. Maintenance
equipment such as mowers, tractors, and waste management would have to be redundant for this
area as well since it is centralized at the main facility. Currently the conceptual plan for the MF7
alternative shows a narrow (50-60 feet wide) area surrounding the field that would allow for the
minimal infrastructure noted above and access around the field.
4. Mitigation Plan:
All comments regarding the Harmon Dairy Phase 2 mitigation plan are addressed in the attached letters
from Wildlands Engineering, Polk County Soil and Water Board and the Harmon Dairy Phase 2 Mitigation
Plan Revised August 3, 2017.
Please do not hesitate to contact me with any questions or comments.
Clement
From: Jones, M Scott (Scott) CIV USARMY CESAW (US)[mailto:[e-mail]]
Sent: Wednesday, July 26, 2017 10:33 AM
To: Clement Riddle <[e-mail]>
Cc: Kichefski, Steven L CIV USARMY CESAW (US) <Steven. L. Kichefski @usace.army.miI>, Tugwell, Todd J CIV USARMY
CESAW (US) <[e-mail]>
Subject: Additional Information Requested Regarding TIEC Response to Corps Comments
Forwarding to you on behalf of Mr. Steve Kichefski.
Clement,
I have received and reviewed the additional information that was sent the evening of July 18, 2017. The additional
information provided justifies why all alternatives cannot be the LEDPA except for Multipurpose Field Alternative #2, #3
and #7 east. Please provide further detail based on the questions below:
1. Multipurpose Field Alternative #2 - Please provide additional information to support your reasoning for this
alternative not being feasible or practicable.
a. Your response states that "...construction at this location would not be allowed by the gas/utility
company." It appears many other areas of TIEC are built or proposed to build infrastructure of some sort
over the gas line. What is different about the polo field that makes building on top of the gas line not an
option? Will any portion of the gas line be utilized by the preferred field location and, if so, what?
5

b. If the field were moved further east from the preferred option, your comments expressed concern over
the redundancy of infrastructure and amenities making this option impracticable. What
infrastructure/amenities would the preferred alternative share that the further option would not benefit
from? With a 10 -acre field, would any concessions, restrooms, or parking need to be constructed anyway
for the preferred field location? How would the horses be handled differently for the preferred option as
far as shared infrastructure (off-loading and barns)?
c. c) Feasibility - Can the polo alternative (to the east of the endurance race start/finish line) location and
parking be adjusted to provide additional buffer between White Oak Creek so as to provide more
conducive grading issues and further avoid/minimize impacts to the UT's to White Oak Creek. For
example, shifting the field further west even if it means adjusting the endurance race infrastructure and
start/finish line location.
d. Depending on the responses to the three items listed above, further information could be needed to
determine the practicability of any lost residential lots as a result of moving the polo field. Based on the
submitted plans, options appear available for moving the road network in a way to still support this
residential area without significant additional impacts.
Multipurpose Field Alternative #3 - Since this alternative depends on whether the Multipurpose Field LEDPA
involves a different location/configuration then the preferred alternative as presented, there may need to be
additional information provided as to why the temporary infrastructure needed for the endurance event/polo
exhibition cannot be moved/puzzled to further avoid/minimize impacts. This additional information will depend
upon your responses to the other two alternatives discussed in this email.
Multipurpose Field Alternative #7 East - The feasibility of this alternative depends in part to answers provided for
Alt#2 above regarding the shared versus new infrastructure/amenities needed. There is a bridge proposed (or
already built) on either side of this location, could these bridges either be utilized or moved to prevent the need
for an additional $750,000 bridge? Depending on the responses to these items, further information could be
needed to determine the practicability of any lost residential lots as a result of moving the polo field.
4. Mitigation Plan:
a. For any areas where the channel is filled or lifted, will existing substrate material be collected for use in
the new channel bottom?
b. The wording in a design note is confusing, but there appear to be areas where credit is still being sought
within breaks in the easement (UT 2 Reach 3 and UT 3 Reach 2). Please verify whether there are any
areas where this is the case, since no credit should be given within any easement breaks, utility crossings,
or farm crossings within the easement.
c. Performance standards and monitoring should match the Oct. 2016 guidance, so review that document
and update the proposal to meet the minimum standards stated. That guidance applies to banks and
Permittee Responsible Mitigation alike.
d. Based on the plans submitted, it is difficult to tell where plan features occur on the landscape in order to
verify design approaches previously discussed in the field. A plan view overlain on an aerial with reaches
labeled is needed so we can see the land use/condition for each of the different reaches.
e. In cut areas of the project, will the topsoil be preserved and reused for better vegetative growth? If not,
why is that not needed?
f. On UT2 from —28+50 to —31+00 there appear to be some bends in the channel that are close to the CE
boundary. Please verify boundary widths in this area (any areas of the proposed mitigation where there
will be less than 50' of buffer from the top of bank). Can the easement be adjusted to provide 50' buffers
in these areas?

Please provide a letter from Polk County that explains their breakdown of annual costs for LTM (labor,
travel, supplies, etc. so that we can verify the amount committed is sufficient), their commitment to the
project, and how the non -wasting individual fund will be managed. For the non -wasting individual
account, who manages the account and what is the projected return on the endowment?
h. Please explain what is being done in the UT3 design from —104 +50 to 106+00 with the channel step
down in order to help clarify the design approach in this area.
Thank you and feel free to contact us for any clarification of items requested. I will be back in the office beginning
Wednesday, August 9th or you can contact Scott Jones in my absence.
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

POLK SOIL & WATER CONSERVATION DISTRICT
156 School Road
Mill Spring, NC 28756
[phone]
Kelly Gay — District Administrator
[e-mail]
Board Members: Richard Smith — Chairman David Stater — Secretary John Vining
Clear Water
32 Clayton Street
Asheville, NO 28801
August 3, 2017
Dear Mr. Riddle,
The Polk Soil & Water Conservation District has been presented with a proposal to
hold and monitor the easement associated with Phase 1 of the Harmon Dairy
Stream Mitigation Plan dated August 15, 2016 and updated December 29, 2016.
The District has also recently been asked to hold and monitor the easement for
Phase 2 of the Harmon Dairy Stream Mitigation Plan dated June 1, 2017, however
this has not been voted on at this time.
The property is located at 335 Harmon Dairy Lane, Columbus, NC. This property is
situated eleven miles from the Polk SWCD and will be monitored one time per year
once tie initial 7 year period of monitoring by the Army Corps of Engineers has
been completed and the mitigation responsibility has been completed by Tryon
Equestrian. The annual monitoring will take two people approximately 3 hours to
complete and the necessary supplies will be limited to a camera, notebook, and pen.
On Ncvember 7, 2016 the Board members voted unanimously to approve the first
Phase of this undertaking, thus the Polk SWCD is committed to this project in
perpetuity. This is consistent with the work and scope of the Soil & Water
Conservation District.
A non -wasting monitoring account has been set up specifically for this project at
HomeTrust Bank in Columbus, NC. The current interest rate is 0.01%. Felly Gay,
District Administrator, is responsible for managing the account. She serves as the
Budget and Finance Officer for the District and is accountable to the Board. Please
let the District know if you have any questions or need additional information.
Thank you very much.
Sincerely,
h_6�
Kelly Gay, District Administrator

., �IENGtNEERING-
August 3, 2017
Mr. Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
Subject: Addendum to Mitigation Plan
Harmon Dairy Stream Mitigation Project Phase 2
Polk County, North Carolina
Dear Mr. Kichefski:
This addendum responds to comments provided on the draft mitigation plan dated August 3,
2017, and it transmits revised figures. Responses to specific comments are presented below:
1. Mitigation Plan:
a. For any areas where the channel is filled or lifted, will existing substrate material
be collected for use in the new channel bottom?
Yes, provided it meets the gradation we're looking for. Some imported
stone or on-site quarried rock will likely be necessary to provide adequate
grade control.
b. The wording in a design note is confusing, but there appear to be areas where
credit is still being sought within breaks in the easement (UT 2 Reach 3 and UT 3
Reach 2). Please verify whether there are any areas where this is the case, since
no credit should be given within any easement breaks, utility crossings, or farm
crossings within the easement.
The restoration and enhancement lengths do account for the easement
breaks, i.e. the breaks are removed from the credit totals. Table 2, UT3,
Reach 2 appears to be the source of the confusion. The easement break
occurs in the middle of reach 2 and we did not separate out the stationing
of the break in the table for simplicity.
c. Performance standards and monitoring should match the Oct. 2016 guidance, so
review that document and update the proposal to meet the minimum standards

stated. That guidance applies to banks and Permittee Responsible Mitigation
alike.
The plan has been revised Section 7.0 and 8.0 to follow the 2016
monitoring guidelines.
d. Based on the plans submitted, it is difficult to tell where plan features occur on
the landscape in order to verify design approaches previously discussed in the
field. A plan view overlain on an aerial with reaches labeled is needed so we can
see the land use/condition for each of the different reaches.
Please see the revised plan Sheet 0.2, which shows an overview of the
project reaches overlain on an aerial photograph.
e. In cut areas of the project, will the topsoil be preserved and reused for better
vegetative growth? If not, why is that not needed?
Suitable topsoil that is not contaminated with invasive exotic species will
be stripped, stockpiled and re -used on graded areas.
f. On UT2 from -28+50 to -31+00 there appear to be some bends in the channel
that are close to the CE boundary. Please verify boundary widths in this area (any
areas of the proposed mitigation where there will be less than 50' of buffer from
the top of bank). Can the easement be adjusted to provide 50' buffers in these
areas?
The easement boundary has been adjusted to provide a minimum buffer
width of 50 feet on both banks. Please seethe revised plan Sheet 1.6.
g. Please provide a letter from Polk County that explains their breakdown of annual
costs for LTM (labor, travel, supplies, etc. so that we can verify the amount
committed is sufficient), their commitment to the project, and how the non -
wasting individual fund will be managed. For the non -wasting individual
account, who manages the account and what is the projected return on the
endowment?
A letter from Polk County regarding this account is attached.
h. Please explain what is being done in the UT3 design from -104 +50 to 106+00
with the channel step down in order to help clarify the design approach in this
area.
The channel bed will be raised to address channel incision and stepped
down with a series of step -pool structures. The design profile does not
Addendum to Mitigation Plan
Harmon Dairy Stream Mitigation Project Phase 2 Page 2 of 3

show the detail of small pools below each step, but this detail is provided
on Sheet 4.4.
We trust that these responses and the attached additional information adequately address the
comments on the draft plan. Please call me at 828.606.0306 if you require additional
information.
Sincerely,
Wildlands Engineering, Inc.
Andrew Bick, PE, CFM
Project Manager
Attachments
Addendum to Mitigation Plan
Harmon Dairy Stream Mitigation Project Phase 2 Page 3 of 3