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imagine any other responsible farmer sending, any workers into any groves for a very long time after the dumping of tons of biosolids on the land. Based on the amounts of biosolids being dumped on fields in the area of Blue Cypress Lake, the time between the application of biosolids and the time when a responsible farmer would allow the reentry of workers would be so long that it would be impossible to grow and harvest a commercially viable crop. Three specific points on the proposed rule: 1. 62-640.100(1)(h) — The rule gives up to three years from its effective date to achieve compliance. Given that the effective date will very possibly be more than a year from now, this will mean that hundreds of thousands of additional biosolids will probably be dumped on fields that need essentially no phosphorus. This will lead to significant additional degradation of the waters of the state. The additional dumping of biosolids at rates similar to those at which they have been dumped over the past four years for an additional four years will most probably put Bh'e Cypress Lake in a crisis condition. The time to come into compliance with any new rules should be significantly shortened. 2. 62-6450.500 Nutrient Management Plan (NMP) — If protection of Florida waters is a goal of the rule-making process, the goal will not be met with this rule. The rule is bad law in the sense that it is so loose and vague in certain areas that no two people will have the same understanding of what it means. Worse for the environment is that the rule is heavily -favored to allow the inappropriate application of biosolids, rather than to protect Florida waters. Two examples of this are, first, (5)(1) directs respondents to "Include a discussion of the risk associated with phosphorus accumulation and a proposed phosphorus drawdown strategy if the soil phosphorus levels are increasing on any application zones on the site." (Emphasis added) If soil phosphorus levels are increasing on Florida lands that need very little if any phosphorus to begin with, the response should not be a "discussion"; if the health of the environment is of any concern, it should be to immediately stop applying more phosphorus. Second. (8) states: "When considering the availability of nitrogen in biosolids, once the amount of plant available nitrogen to be supplied has been determined (i.e., the crop nitrogen demand has been adjusted to take other sources of nitrogen into account), this amount may be multiplied by a.factor Q/1.5 (i. e. a 50 percent increase) to determine the amount of nitrogen that may be supplied by biosolids." (Emphasis added) If I understand this provision correctly, it will allow biosolids -- at a time when excess nitrogen and phosphorus are said to be one of the major cause of polluted waters in Florida -- to be applied at clearly excessive rates. This agronomically irresponsible allowance of 50 percent more nitrogen than the plant needs is particularly dangerous given the roughly 2.5TN:ITP in Class B biosolids, which before the 50 percent increase provides phosphorus five-to-ten times greater than crop needs. This section should be changed to something much simpler and designed to both allow the application of biosolids, albeit at reduced levels, and to protect the environment.