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Fortunately, there is a rule in Florida that seems to do both successfully. It is that the <br /> permit holders shall provide annual documentation that there has been no net loading of <br /> phosphorus by accounting for phosphorus applied to the site with the amount of <br /> phosphorus exported in production generated on the site. In short, no more phosphorus <br /> can be put down than the crop is actually using. This should be documented and <br /> supported with appropriate monitoring. <br /> 3. The rule should make clear that from this point forward the cost of remediation for any <br /> damage done to the waters of the State of Florida is paid for by the entities responsible <br /> for the pollution. This provision also will require appropriate monitoring so that those <br /> responsible for the damage can be properly identified. <br /> The science is clear: the risk of negative phosphorus impacts on surface waters increases with <br /> higher levels of soil phosphorus, proximity of surface waters, and well-defined pathways for <br /> transporting soil phosphorus to surface waters. These conditions are all met at Blue Cypress <br /> Lake. Additionally, in the past years tons of biosolids have been dumped in the near vicinity of <br /> Blue Cypress. There is now a documented problem with phosphorus in the Blue Cypress Lake, <br /> just as science has said there would be. What we in Indian River County need is a rule that will <br /> clearly stop the dumping of biosolids in areas that will further pollute our waters. <br /> To most of us in Indian River County, the present rule appears to be focused on insuring that <br /> management costs for municipalities is reduced and not that the waters of the State of Florida are <br /> protected. This is something that our citizens cannot accept. They may not understand the ins- <br /> and-outs of biosolids but they know that something stinks when they are being told to spend ten <br /> to fifteen thousand dollars apiece to move off their septic tanks (to County sewer) because of the <br /> crisis that their perhaps five pounds of phosphorus annually is causing in the Indian River <br /> Lagoon, when just to the west of them literally tons of phosphorus from South Florida have been <br /> dumped -- after being properly permitted by FDEP-- onto fields at the headwaters of the St. <br /> Johns River. All the while having been made aware that during this period of permitted dumping, <br /> the previously healthy waters of the Blue Cypress Lake have been significantly impaired. <br /> Please change your focus and change the rule. Change your focus from reducing the costs for <br /> South Florida waste producers to protecting the environment of Florida and change the rule so <br /> that it protects the Blue Cypress Lake and similar waters in our great state. <br /> If there is anything that I can do to help make a better rule, please let me know. <br /> Sincerely, <br /> Bob Solari <br /> Chairman, Indian River County Board of County Commissioners <br /> Commissioner, District 5 <br /> bsolari(a:irct;ov.corn <br /> 772-226-1438 <br />