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10. A .4 . <br /> 9-ZO . 0 <br /> Statement to IRC Board of County Commissioners <br /> August 20, 2013 <br /> Regarding the Final Model Ordinance for the application of fertilizers <br /> The Indian River Neighborhood Association congratulates your Board in moving <br /> forward with this Ordinance for its potential to protect the Lagoon from the <br /> damaging effects of harmful fertilizers and practices. <br /> During the process of your reviewing and revising the initial model, you have <br /> added several provisions which will add to the Ordinance's overall effectiveness. <br /> Unfortunately there remain two changes which we respectfully suggest you <br /> reconsider. One appears to be a drafting oversight; the other is a disturbing policy <br /> which received your vote. <br /> The drafting oversight is in Section 316.2, the definition of"Prohibited Application <br /> Period." The definition prohibits fertilizer applications during watches for <br /> flooding, tropical storms and hurricanes or "if heavy rain is likely." Rain forecasts <br /> are difficult enough to forecast without introducing the ambiguity about the <br /> meaning of the word "heavy." <br /> In the Model Ordinance presented to you at your July 2, 2013 meeting, heavy rain <br /> was defined as rain exceeding 2" in a twenty-four hour period. In the Ordinance <br /> presented to you at your July 16 meeting this definition was dropped, <br /> inadvertently we understand. We believe the County Attorney agrees that the law <br /> would be clarified by reinserting this definitions. We urge you to do so. <br /> In addition the IRNA would prefer the blackout approach during the summer <br /> months. We do so because of the ease of administration during this period when <br /> rains are often heavy and because of the lack of any evidence that fertilizer <br /> application during the summer months is needed. <br /> 5q �j32 <br />