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12.G.1. FDEP Biosolids Rule ,I If one reads FDEP'slIproposed Biosolids Rule, one cannot come away knowing that the environment is protected. The language is to convoluted and open to multiple interpretations. Ask three people toi read the Rule and one will get three very different explanations of what it means. At a minimum, I would suggest: I 1) That the Boallyd authorize the Utilities to submit its comments to FDEP. 2) That the board authorize the Chair.................. to submit comments on behalf of the board Noting: a. That the proposed rule does not go far enough to clearly protect the environment. b. That the law is to convoluted, unclear and to open to multiple interpretations to be good law.! c. That a simple, clear and understandable solution that will protect the environment is available and found in Rule no. 62-640.400 (12) so essentially, Land application of biosolids will not be permitted anywhere in the State of Florida unless the applicant for a site permit affirmatively demonstrates that and phosphorus loads will not add to nitrogen and phosphorus loadings in the watershed. d. If FDEP wil!il not recommend the suggested language, then given the conditions around the Blue Cypress Lake, which mirror near exactly what science has:-already established are such that will lead to significant environmental damage with the dumping of biosolids, at least clearly carve out Indian River County and the headwaters of the St. Johns River with the affirmatively demonstrates language above and allow IRC to maintain its moratorium on the dumping of biosolids. /3) ,. I,f-the provision! of the rule that gives present permit holders three more years to dump Biosolids on lands that will pollute the environment remains in the rule for Indian River County, I suggeist that we ask the County Attorney to start investigating what causes of action we may have in law to file against anyone who does come into Indian River County and knowingly dumps biosolids, which present science makes clear, will pollute our environment. I Given all we are paying and will pay to remediate the damage that pollutants have done to the Lagoon, we cannot afford another $100,000,0000 remediation project to clean up the Blue Cypress Lake area. If FIDiEP is not going to do its job and protect the environment, we need to be prepared to step up and protect the natural resources of Indian River County. 164 - f