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Mr.john Royal <br /> Page 2 <br /> November 9,2012 <br /> the water while applying fertilizer. Such stormwater treatment systems are beyond the scope of this <br /> Model Ordinance except that stormwater treatment system or land use restrictions must be respected. <br /> The recommendation of the LPA to expand the voluntary low maintenance zonae is a similar situation. <br /> The ten(10)foot suggested width has been consistent in the Florida Yards Neighborhoods Program(a <br /> part of the Florida Friendly LandscapingTM Program)for 20 years or more. As a voluntary action, <br /> expanding the suggested width does not add to the stringency of the ordinance itself. <br /> Florida Statute 403.9337 recognizes that in some areas of the state the best management practices <br /> provided in the Model Ordinance must be amended to account for unique,site specific conditions that <br /> make adjacent surface water resources more vulnerable to nutrient enrichment. The statute provides <br /> local governments the authority to amend the ordinance with more stringent requirements.This authority <br /> is granted contingent upon documentation of those site specific conditions associated with increased <br /> vulnerability and documentation that complementary measures to the ordinance(a comprehensive non- <br /> point source control program)have been implemented. The County must be able to provide such <br /> documentation upon request. <br /> The actions of Brevard County to prevent nutrient loadings into adjacent surface waters are recognized <br /> and appreciated. Adoption of a local ordinance for urban fertilizer use will enhance the county's <br /> stormwater control program. I hope you find the comments offered above to be of assistance in <br /> demonstrating consistency with the expectations established section 403.9337,F.S. If you have any <br /> questions,please feel free to contact Mike Thomas,Professional Engineer III,with the Department's <br /> Division of Environmental Assessment&Restoration, at(850)245-7513. <br /> Sincerely, <br /> LbiTThomas M.Frick <br /> e; Watershed Restoration <br /> cc; Mike Thomas,Professional Engineer III,DEP <br /> Lee Marchman,Administrator,DEP <br /> 5q -1 ° <br />