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BOARD OF COUNTY COMMISSIONERS <br /> Bob Solari (fraVER ., Joseph E. Flescher <br /> Chairman District 2 <br /> District 5 <br /> 4 <br /> Tim Zorc <br /> District 3 <br /> Susan Adams * <br /> Vice Chairman t Peter O'Bryan <br /> District 1 District 4 <br /> July 26, 2019 <br /> Kristin Gousse <br /> Government Analyst, Division of Water Resource Management <br /> 2600 Blair Stone Road. MS 2500 <br /> Tallahassee. FL 32399-2400 <br /> Maurice Barker <br /> Biosolids Coordinator, Domestic Wastewater Section <br /> 2600 Blair Stone Road, MS 3540 <br /> Tallahassee. FL 32399-2400 <br /> Re: Biosolids Rulemaking, Chapter 62-640 <br /> Dear Ms. Gousse and Mr. Barker: <br /> Staff at Indian River County has already sent in a number of comments in response to the <br /> proposed new Chapter 62-640, which covers the land application of biosolids. I am writing on <br /> behalf of the Board of County Commissioners of Indian River County with additional comments <br /> of a less technical nature dealing more with some of the policy aspects of the proposed rule. <br /> The immediate first impression of the proposed rule is that it is more heavily weighted to <br /> preserve the waste producers' ability to dump biosolids on Florida lands than it is to protect our <br /> environment, particularly the waters of the state of Florida. This is of particular concern to the <br /> people of Indian River, who have seen one of its great environmental resources -- the Blue <br /> Cypress Lake located in the most rural area of our County -- suffer in recent years from too mich <br /> phosphorus as literally tons of biosolids have been dumped in the area of the lake. This includes <br /> a reported 293,358.9 pounds of total phosphorus in 2017 alone. <br /> Two things are clear from the start. First, based on scientific studies analyzing the land <br /> application of biosolids in areas with physical characteristics similar to the Blue Cypress Lake, <br /> surrounding waters will be polluted. Second, the dumping of tons of biosolids on fields, <br /> particularly with the known ratio of TN to TP. serves no valid agronomic purpose. More <br /> importantly. as a former citrus grower in Florida I know that I would never send, nor can I <br /> 1801 27th Street, Building A <br /> Vero Beach, FL 32960 <br /> (772) 226-1490 <br />