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John Royal <br /> November 15,2012 <br /> Page Two <br /> 2. Section 46-339.Fertilizer free zone-Fertilizer shall not be applied within fifteen <br /> (15)feet of any surface waters,pond, stream, watercourse, lake, canal, or wetland <br /> The proposed fertilizer free zone is more restrictive than the model ordinance.We advocate the <br /> adoption of the recommended zone width specified in the model ordinance. <br /> 3. Section 46-341. Fertilizer content and application rates-No fertilizer containing <br /> phosphorous shall be applied to turf or landscape plants in Brevard County... <br /> This standard is more restrictive than the model ordinance. Rule 5E-1.003(2)allows up to 0.25 <br /> lbs P205/ 1000 sq. ft.per application up to 0.5 lbs.P205/ 1000 sq. $. annually without testing. <br /> In the absence of scientific evidence supporting the effectiveness of the proposed more <br /> I, <br /> stringent standards,the Department of Agriculture and Consumer Services endorses the adoption <br /> of the model ordinance as written. The model ordinance was derived from the legislatively j <br /> mandated Consumer Fertilizer Taskforce. A tremendous effort went into the development of this <br /> document,which encompassed a broad spectrum of stakeholders and consideration of the best <br /> available science pertaining to this issue. While this document is a compilation of the existing <br /> research at that time and due to the nature in which the document was developed; it does not <br /> inclusively conform to all the reviewed literature. It does however provide a mechanism for <br /> protecting surface and groundwater quality. <br /> We appreciate the opportunity to comment on Brevard County's proposed fertilizer <br /> ordinance, In the absence of definitive science supporting more stringent standards we strongly <br /> recommend that you adopt the model ordinance as written and defer consideration of more <br /> stringent standards until current research has been published. <br /> Sincerely, <br /> ADAM H.PUTNAM <br /> COMMISSIONER OF AGRICULTURE <br /> Weldon Collier,Program Planning Coordinator <br /> Division of Agricultural Environmental Services <br /> cc: Anderson H. Rackley,Director <br /> Steve Dwinell,Assistant Director <br /> 50f5� ��- <br />