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Susan Adams <br />Chairman <br />District I <br />Joseph E. Flescher <br />Vice Chairman_ <br />District 2 <br />B(7ARD OF COUNTY COMMISSIONERS <br />November 19, :2019 <br />Maurice Barker <br />Senior Program Analyst <br />Division of Water Resource Management <br />2600 Blair Stone Road, MS 3540 <br />Tallahassee, Florida 32399-2400 <br />Email: Maurice.Barker@dep.state.fl.us <br />Tim Zorc <br />District 3 <br />Peter D. O'Bryan <br />District 4 <br />Bob Solari. <br />District 5 <br />RE: Proposed Rule Making - Chapter 62-640, Florida Administrative Code <br />Mr. Barker, <br />As the chair of the Indian River County Board of County Commissioners, I am <br />submitting these comments to the Florida Department of Environmental Protection, concerning <br />the above -referenced matter, to supplement those prepared by Indian River County staff. f=irst, <br />and foremost, the proposed rule does not go far enough to clearly protect the environment in <br />Indian River County and the State. of Florida as a whole. The proposed rule is convoluted, <br />unclear and open to multiple interpretations. <br />The Board believes that a simple, clear and understandable solution that will protect the <br />environment is available and found in Rule 62.640.400 (12), Florida Administrative Code. This <br />rule does not permit the land application of biosolids in certain watersheds, unless an applicant <br />for a site permit affirmatively demonstrates that the nitrogen and phosphorus in the biosolids will <br />not add to nitrogen and phosphorus loadings in those watersheds. If the Department will not <br />recommend utilizing this suggested language statewide, then given the conditions around Blue <br />Cypress Lake, which mirror near exactly what science has already established are such that the <br />dumping of biosolids will lead to significant environmental damage, at least clearly carve out <br />Indian River County and the headwaters of the. St. Johns River with such language and allow <br />Indian River County to maintain its moratorium on the dumping of biosolids. <br />Thank you for your consideration of these comments, <br />erely, <br />isairman, <br />an Adams; <br />Indian River County <br />1801 271h Street., Building A <br />Vero Beach, FL -32960 <br />(772) 226-1490 <br />I tri —zi <br />