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3.ia'�3 <br /> ATTACHMENT E (0, P,L1 . <br /> BT <br /> DIVISION op AGRICULTURAL � °� <br /> ENVIRONMENTAL SERVICES e6 i THE CONNER 1NG <br /> X850)6r]-7900 e�$ i1 3125 CONNGR BOULEVARD <br /> TALLAHASSEE,FLORIDA3z399-id5o <br /> • �DVG � <br /> FLORIDA DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES ' <br /> COMMISSIONER ADAM H. PUTNAM <br /> November 15,2012 <br /> Mr. John Royal <br /> Environmental Section Supervisor <br /> Brevard County Natural Resources Management Office <br /> 2725 Judge Fran Jamieson Way <br /> Viera,Florida 32940 <br /> Mr,Royal: <br /> I have been asked by Commissioner Putnam to reply to your e-mail request to review and <br /> comment on the Brevard County's draft fertilizer ordinance. We have reviewed the proposed <br /> fertilizer ordinance and determined there are several standards in the proposed ordinance more <br /> stringent than the Florida Department of Environmental Protection's Model Ordinance for <br /> Florida Friendly Fertilizer Use on Urban Landscapes(model ordinance). <br /> Comments on standards more stringent than the model ordinance are expressed below: <br /> 1. Section 46-338. Timing of fertilizer application—Recommend restricted <br /> application period <br /> The restricted fertilizer application period(summer blackout period), continues to be the most <br /> controversial standard proposed in local ordinances. To date we arc unaware of any research <br /> which supports the merits of a ban on summertime applications. Recently published research has <br /> documented that actively growing,healthy turf mitigates the leaching of nitrates derived fi om <br /> turf fertilization(Trenholm et al., 2012).Therefore in the summer months,healthy, actively <br /> growing turf has the capacity of absorbing applied nutrients with minimal risk to the <br /> environment. <br /> It also should be noted that this standard also has an unintended consequence of potentially <br /> encouraging the over application in the spring when turf's root structure has not fully developed, <br /> or late fall applications when turf's is entering dormancy, decreasing its ability to absorb <br /> nutrients and increasing the potential of nitrates leaching into groundwater. <br /> 1 800-HELPFLA F1L'i�tda. www.FreshFromFlorida.com <br /> IJ' � <br />