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Should IRC be concerned? <br />Of the 8 Million cubic yards of offshore <br />sand identified in the County Beach <br />Preservation Plan approximately 40% or <br />3 Million cubic yards lies within Federal <br />waters (3 nautical miles or greater). <br />Use of the identified offshore sanc <br />resources, in full or in part, will bE <br />required for the County's beach prograrr <br />the next 30-50 years. <br />Staff Comments on Proposed Rule <br />• Regulation of Borrow Area Sediments <br />- Unclear on its affect to Local and State projects not <br />partnered Federally. <br />• Sediment Quantity and Quality <br />- Lacks discussion on borrow sediment use, quantity, and <br />quality. <br />• Previously Issued BOEM Lease Agreements <br />- Where are these leases located? <br />- Are these documents available? <br />- Were there any legal challenges? <br />Note. Staff discussed the comments with the IRC Beach Committee where they <br />received unanimous approval <br />5/41/2016 <br />1292 <br />