Fertilizer Task Force On Line Comments by mikesanye

VIEWS: 16 PAGES: 28

									                                                                                           1



Fertilizer Task Force On-Line Comments

12/14/07 - 1/4/08

1. Statewide Guidelines for Use (use rates, formulations, and applications)
   Developing Improved Standards

What herbicides and pesticides presently in use, in Florida, are banned in other states,
Why? Is there sufficient data available through independent research to ban them in
Florida, as well?
--Ed Tedtmann
  Sierra Club


I believe the recent standards set by the City Council of Sanibel should be used as a
guideline for these...I'm quite sure you have them on record.
--Charles Sobczak
  START (Solutions to Avoid Red Tide) Sanibel Chapter


I feel there should be a state rule that all counties & states must follow.
--Mario Perone
  ABC Pest Control


I feel there should be a state rule that all counties & states must follow.
--Robin Fogle


I feel there should be a state rule that all counties & states must follow.
--Tami Libretto


I feel there should be a state rule that all counties & states must follow.
--Nichole Libretto


I feel there should be a state rule that all counties & states must follow.
--Cory Page
  Homeowner
                                                                                              2

I feel there should be a state rule that all counties & states must follow.for beat water
quality in fl.
--Nick Libretto
  home ower


I feel there should be a state rule that all counties & states must follow.for beat water
quality in fl.
--Bob Hanna
  ower


I believe that there should be some rules that all States, counties, and townships should
have to follow in order that we can enjoy the highest water quality available.
--Jim Thorpe
  Resident


I am a firm believer that all States,counties, and cities should have rules and regulations
for fertilizing so that we can keep our water and waterways safe but on the otherhand i
believe that fertilizing should not be eliminated some months out of the year so we can
have nice healthy green grass and have nice healthy shrubs.
--Ryan Kirsch
  Resident


I am a firm believer that all States,counties, and cities should have rules and regulations
for fertilizing so that we can keep our water and waterways safe but on the otherhand i
believe that fertilizing should not be eliminated some months out of the year so we can
have nice healthy green grass and have nice healthy shrubs.
--Glenn Cannedy
  Pest Control Tech


The state should regulate a signifigant reduction in fertilizer use in coastal and watershed
communities, and at the same time, allow the individual local goverments to enact stricter
regulations as needed.
--David Barney


As a business owner I have much concern with recent activity's of various counties,
city's, municipality's developing their own fertilizer ordinances. I have twenty business
locations and everyday we serve customers/consumers in multiple county's, city's, and
municipality's. A lawn truck on a typical day may leave the office location and service
several different city's, municipality's in different county's. Trying to comply with a
different city, municipality, and/or county everyday will be confusing to say the least,
                                                                                            3

counter productive, and costly to the business and trickled down to the consumer. The
honest company's will comply while others may not. This puts the honest company at a
distinct disadvantage, and better yet, most of the ordinances I have read are not even
enforceable. why would anybody want to spend valuable time and effort towards
something that will do very little for water quality and end up costing the small business
and consumers of Florida more money? Most if not all of the ordinances I have read have
no budget for the implementation nor enforcement of such ordinances.
--Dempsey R. Sapp Jr.
  Florida Pest Control & Chemical Co.


A couple of thoughts: 1. Fertilizer that "runs off" anywhere, is wasted money.
Commercial agriculture and lawn mainteance operators pay huge sums of money to
fertilize their crops, and residential and commercial landscapes. Run off is waste pure and
simple. The selling point is "don't waste your money over fertilizing!" This will appeal
even to residential users. 2. I see lots of references to Phosphate ( I assume they mean
phosphorus) levels and Nitrogen levels in many people's comments. Don't people know
about 30% of the naturally occurring phosphate (Phosphorus) on the planet Earth is in
Florida. They donít mine phosphate here because itís some rare thing! The fact that we
have high levels of phosphate in the water supply should not come as a surprise to
anyone, but is phosphorus the actual problem? I don't know. Does anyone know what the
levels of Phosphate in our lakes and streams was 50 years ago? 2. On Nitrogen, again we
don't know what the levels were 50 years ago, but I'd suggest to you they were high then
too because Florida is the air to ground lightning strike capital of the Northern
Hemisphere. When lightning strikes nitrogen is precipitated out of the atmosphere. Again
I suggest, is Nitrogen the actual problem, or is it something else? I donít know. 3. We
need good science to get good answers and sound policy. A knee jerk reaction wonít help
us solve the big problem. Implement BMPís now and fund research to find what the
actual causes are and how we control them. Monitor Ag runoff, and work with farmers to
reduce the wasted fertilizer. Work with the commercial lawn maintenance companies to
eliminate nutrient runoff. I canít imagine they wonít want help saving operating costs. 4.
Homeowners use of fertilizer is a significant problem. Education is the key, but
unfortunately most Florida homeowners just got here last year and they donít have a clue
how things grow here. They got an estimate from a national lawn care company to
fertilize their lawn for $50, so they go down to Home Depot and buy $40 of fertilizer and
dump it on the yard. The lawn greens up, tons of fertilizer runs off into the aquifer and
the homeowner saved $10. The only thing to do is put fertilizers and pesticides in the
hands of licensed operators who are properly trained and have a financial incentive to get
the job dome as cost effectively (read using as little fertilizer and pesticides) as possible.
--Andy Reasoner
  Reasoners Royal Palm Nurseries, Inc.; Serving Florida Horticulture Since 1881
                                                                                                  4

In you efforts to develop state guidelines for fertilizer use, please consider the importance
of reducing pollution to our waterways. Rain runoff now accounts for 60% of phosphorus
pollution in our waters. The importance of decreasing nutrients cannot be overstated.
Let's put the environment first -- before special interests. Natalie Tierney
--Natalie Tierney
  Pelican Cove Bay and Water Committee


There are so many alternatives to fertilizing one's lawn.We all want nice looking
lawns,but at what expense?All harmful fertilizers should be banned for sale in the state of
Florida.In doing so,all the waterways in Florida would return to their natural state.We
need to do this before it is too late,if it isn't TOO LATE already.SAVE FLORIDA'S
WATERWAYS!!!
--John H.Logue
  Concerned Citizen,Fisherman,Common Sense Human Being


We need uniform guidelines to follow. Having multiple regulations to have to deal with
every day will be difficult. I can't think of any other trade, i.e., plumbers carpenters, etc.,
that would have to operate uncer multiple regulations.
--Bruce McCown
  Florida Pest Control and I'm a Homeowner


Statewide guidlines for non-agricultural fertilizer use if promoted properly will educate
the public where needed. There may be areas of the state that have different soils and
plant material needs so some consideration should be made to accomodate these needs.
--Rick Reinhardt
  Dr. Jack Reinhardt, Inc.


I urge the task force to put the good of the environment ahead of the business concerns.
Limit the use of fertilizers state wide. Have no fertilizers use during the rainy season.
Mandatory education for the fertilizer companies. Encourage changes in Homeowner
Restrictions to change grass area requirements to native plants and ground covers, that
require less water and discourage St Augustine grass. Allow local governments to have
their own restrictions as long as they are not LESS strict than the state ones. With the
increased population and therefore huge new subdivisions that use grass, it is imperative
that water and fertilizer use be restricted. respectfully, Wanda Kerr
--Wanda Kerr
  Concerned Citizen


Approved fertilizer labels should ditate use rates and applications similar to the way
pesticide labels do, not ordinances. If homeowners can be educated applicators can be
educated. Ordinances are not needed for responsible individuals and will not work for
                                                                                               5

individuals that are not responsible. Reward and recognition of companies that comply
would be better accepted and propuce more results than threatening punishment will.


Florida without clean water is no better than Iowa or Nebraska, not that there's anything
wrong with these states. It's just that Florida should not sell its future so fertilizer
companies can make a buck today. Tough standards that keep Florida water clean will
prove more advantageous over the long run. If you're interested in seeing your children
and grandchildren drink fresh water, swim in clean water and fish in live water, then the
toughest standards must be in place to control the fertilizer industry interests.
--Jeffrey Weisman
  Citizen, Sierra Club


I supports tough uniform regulation of fertilizer use across the state. Water sources don't
operate in a vacuum or respect jurisdictional boundaries.I support regulation based on
sound science, not emotional hype. Some scientific findings are actually counter-intuitive
- we must deal in facts.
--Patrick H Marriott
  Proway Services inc.


we need state guidelines not county by county
--Craig Devereaux
  Turfmaster Lawn(Sarasota)


 Florida Greens Industries BMP for protecting our florida water resources released in
June of 2002
--Kevin E. Fee
  Extermination Station


GENERAL COMMENTS: I ask that your Task Force adopt appropriate policy changes
that will help reduce the improper and excessive use of fertilizers. As an avid gardener, I
use no fertilizers or perticides in my yard, and my plants do just fine. There is absolutely
no need for phosphates in our urban, suburban or rural landscapes. Please support
changes that will insure clean and healthy waterways.
--Linda Schilke
  Lemon Bay Garden Club, Native Plant Society, various others


we are infavor of strict laws and regulation and what ever is required to stop red tide and
will vote accordingly.
                                                                                                6

I believe strict guidelines should be put in place for all users of fertilizers in the State.
--Elizabeth France
  Clearwater Garden Club, Pinellas Chapter of FNPS, Croton Society


Every county must test its water bodies periodically for contaminants, oxygen levels,
salinity and clarity.
--Alexa Ross
  Volusia Flagler Environmental Action Committee, Inc.


1. No Nitrogen & Phosphorus application should be allowed from June 1 to October 31.
October is clearly within the rainy season, as the constant October rains this year showed!
4 pounds of Nitrogen per 1000 square feet per year should be the maximum, or better
even just 2 pounds, which is easily doable. Training for all applicators a must!

2. Sarasota County's Fertilizer Ordinance should be used as minimum standard, but
strengthened by adding October.

3. It is in the public's, and absolutely in everybody's best interest to protect all our water
from run-off and contamination. There is no hardship in reducing fertilizer application for
a few months a year! The United Nations Environmental Program has in recent years
repeatedly asked coastal communities worldwide to reduce nitrogen and phosphorus use
and run-off. At its annual global meetings, scientists have put eutrophia, apoxia, and
dying waters and oceans (and their fast increasing dead zones!!)on the list of global
environmental problems for which fast actions is needed. They are calling for decisive
action from policy makers.

4. There has been sufficient scientific evidence, as shown by the research and warning
statements from large numbers of scientists all over the worls during the United Nations
Environmental Program's annual meetings, and in many other contexts, that overuse and
run-off from nitrogen and phosphorus is causing far-reaching, dangerous environmental
problems. We hope our policy makers will take meaningful, decisive steps before there is
more damage. Please Do Not Act As The Defenders Of Chemically Dependent,
Unnaturally Green Turf, But As The Protectors Of Our Gulf, Rivers, Estuaries, Ground
Waters, And So And. Healthy Water Is Critically Important For Our Survival, Health,
And The Fishing And Tourism Industry Here In Florida. Be Proactive And Err On The
Side Of Caution! We Cannot Gamble With Something As Vitally Important As Water,
But We Can Easily Live With Turf That Is (Maybe) Just A Little Less Green A Few
Days Or Weeks A Year. We, Personally, Find That Fertilization Is Not Even Necessary
During The Summer Months. Without Fertilizatiom, Most Lawns Are Green From Other
(For Instance Atmospheric) Nitrogen Sources. Last, We Should Not Endanger Our
Water Bodies For The Sake Of Ornamental Use Applications. This Is The Area Where
We Can Cut Back Most Easily!
--Claudia and Glenn Cuomo
                                                                                            7



Yes - Good idea - lets look for consistency in regulations to much to keep on when,
where, how much, etc.
--Jeffrey Melmer
  Quality First Lawn and Shrub Care, Inc.


Statewide guidelines make more sence than every county making it's own rules
--Danny Swain
  Bug Termiteand Pest Control Co Inc.


I think if everyone had to become BMP certifided, it would solved most of the concerns
over the water quality impact from fertilizers.
--Mickey Nolen
   Nozzle Nolen, Inc.


Nitrogen - It is unfair from a labor standpoint to only permit 1# N per 1000 sq ft per
application when products such as IBDU, Nitroform, and others will provide true slow
release and still minimize leaching. Please scratch the 1# N at any one time and leave the
annual amounts to serve your purpose.
--Ken Miller
  affiliations with FTGA, FPMA, ISA, FNGLA


Buffers of 3 feet and 10 feet from the waters edge are often used as guidance for fertilizer
application in areas adjacent to water. These setbacks are based on the lateral projection
of fertilizer applicators with and without deflector so that there is no direct projection of
the fertilizer into the water body. What this recomendation fails to recognize is that most
waterbodies fluctuate and therefore a 3 or 10 foot setback on the day of application may
result in complete inundation of the area after a stormevent. As a result although direct
contact did not occur at the time of applicaion, the change in water level still results in
direct contact betweeen fertilizer and water. These "buffers" have little scientific basis as
a means to reduce runoff of nutrients into the water body, especially for dissolved
nutrients and therefore if the intent of the applicaion buffer is to minimize nutrient inputs
it needs to be based on something other than fertilizer spreader application distances.
There should also be a clear distinction between natural and constructed water bodies.
natural systems should have a set back of at least 25' and likely more to reduce the
liklihood of nutrient runoff. Constructed waterbodies could be managed with narrower
buffers as long as excess nutrient issues are not having to be managed in the constructed
water body. In general the top of bank should be used as the limit to fertilizer application
or a buffer set back based on the maximum high water level.
                                                                                           8

2. Local Government Mechanisms to Promote and Encourage Proper Use

Enforce mandatory Best Management Practices through County Extension Offices
investigation,in cooperation with the County Sherrifs' Dept. for enforcement. Or we can
rehire the State Ag. department Citrus destruction "police" (LOL).
--Ed Tedtmann
  Sierra Club


REQUIRE landscapers to use low nitrogen and phosphor fertilizer especially in Cape
Coral with 400 miles of canals.
--S.L Baldwin


Mandatory training and inforcement via occupational lisences to all commercial and
residential landscaping firms.
--Charles Sobczak
  START (Solutions to Avoid Red Tide) Sanibel Chapter


I feel that all counties and cities should have all companies follow BMP's
--Mario Perone
  ABC Pest Control


I feel that all counties and cities should have all companies follow BMP's
--Robin Fogle


I feel that all counties and cities should have all companies follow BMP's
--Tami Libretto


I feel that all counties and cities should have all companies follow BMP's
--Nichole Libretto


I feel that all counties and cities should have all companies follow BMP's
--Cory Page
  Homeowner


I feel that all counties and cities should have all companies follow BMP's so we or work
to clean up are water
--Nick Libretto
  home ower
                                                                                           9




I feel that all counties and cities should have all companies follow BMP's so we or work
to clean up are water
--Bob Hanna
  ower


I think that all counties and cities should have all companies follow BMP's so we work to
clean up our water. That would ensure that only qualified people are doing this and
following it to the format laid ou in the BMP's.
--Jim Thorpe
   Resident


I believe that all states, counties, and cities should have all companies that provide
fertilizing to become BMP certified so we can get the water and waterways cleanup
because if your BMP certified you took a class for proper fertilizing methods and proper
amount of fertilizer when fertilizing.
--Ryan Kirsch
  Resident

I believe that all states, counties, and cities should have all companies that provide
fertilizing to become BMP certified so we can get the water and waterways cleanup
because if your BMP certified you took a class for proper fertilizing methods and proper
amount of fertilizer when fertilizing.
--Glenn Cannedy
  Pest Control Tech


Local goverment should not promote fertilizer use, but where it is needed, regulate the
proper use w/ enforcible codes.
--David Barney


I have and continue to support the science based model ordinance which incorporates 5E-
1.003, cultural and application practices which minimize the potential for fertilizer to
reach water. If local government wants to promote and encourage the proper use of
fertilizers, I suggest they move towards the homeowner applications. Certified Pest
Contol Operators have to atleast go through rigorous training to become certified. It is the
responsibility of every Certified Pest Control Operator (CPO) to provide adequate
training to all staff applying fertilizer and or pesticides. Every CPO is compelled to train
their people or they will damage the lawns and subsequently have liability. What training
do the homeowners have? Very little to none. Most of the retailers selling fertilizers to
                                                                                         10

the consumers don't have any training either. This is a huge area being over looked. I
don't know if some of the tonnage fees collected could be targeted towards consumer
education and awareness or not.
--Dempsey R. Sapp Jr.
  Florida Pest Control & Chemical Co.


Look at what Manatee County has done in the Lake Manatee Watershed. We studied ag
runoff, worked with the farmers, and now as far as I know, Manatee County has (and has
had for the last 40 years) a model water system. Statewide we should be doing the same
thing. study, co-operate, design good science based programs and implement them. I was
a part of the development of the program in Manatee County 17 years ago. People from
various groups suggested nutrient run-off levels they felt would work based on data from
other areas of the US. In fact what we found out was they were proposing nutrient run-off
levels that were higher than the naturally occurring levels in the rainfall in West Central
Florida. We threw out their suggestions, did the research to find out what was right for
here (which may or may not have anything to do with whatís right in other parts of
Florida) and now we have a pretty good program and we continue to have extremely high
quality water to spare in our area. Weíre actually talking about pumping our water from
Manatee County 2 counties south to Charlotte County to help them out. Itís too bad the
leaders of other areas of Florida 40 years ago didnít have to foresight that the leaders of
Manatee County had. Given the bureaucracy of the state and federal governments the
Manatee County model probably canít be implemented today. If you want the answer to
the long term situation, cut the bureaucracy and implement the Manatee model anywhere
it will work. Stop relying solely on groundwater for our drinking water supply!
--Andy Reasoner
   Reasoners Royal Palm Nurseries, Inc.; Serving Florida Horticulture Since 1881



Nothing in the state guidelines should prohibit local communities from passing and
enforcing their own fertilizer policies. Each area has its own uniques eco-systems. Natalie
Tierney
--Natalie Tierney
  Pelican Cove Bay and Water Committee


Ban for sale all harmful fertilizers in the state of Florida,and promote the use of natural
fertilizers that don't harm the ecosystem.Let's return the waterways of Florida back to the
way they were,before it is too late.
--John H.Logue
  Concerned Citizen,Fisherman,Common Sense Human Being
                                                                                      11

Local government's role should be to promote education of a statewide regulation rather
than passing a local ordinance. Education rather than punishment should be the direction
of local government.
--Bruce McCown
  Florida Pest Control and I'm a Homeowner


Local Government through the Florida Extension Services can promote and encourage
proper fertilizer use through its programs and materials
--Rick Reinhardt
  Dr. Jack Reinhardt, Inc.


There needs to be enforcement and fines for non compliance.
--Wanda Kerr
  Concerned Citizen


See #1
--Jeffrey Weisman
  Citizen, Sierra Club


I support state wide guide lines with local government promoting the proper use of
homeowners
--Patrick H Marriott
  Proway Services inc.


yes
--Craig Devereaux
  Turfmaster Lawn(Sarasota)


There are to many local governments, noone agrees on everything you must keep it
statewide
--Kevin E. Fee
  Extermination Station


Yes--incentives often work well.
--Elizabeth France
  Clearwater Garden Club, Pinellas Chapter of FNPS, Croton Society
                                                                                          12



Chemicals that can leach into groundwater or river systems must be regulated and those
who apply them educated and permitted in order to restore and preserve water quality.
--Alexa Ross
  Volusia Flagler Environmental Action Committee, Inc.


Too much knee jerk reactions - we need to be more educated.
--Jeffrey Melmer
  Quality First Lawn and Shrub Care, Inc.


NO statewide guidelines mak more sence
--Danny Swain
  Bug Termiteand Pest Control Co Inc.


Offer free BMP training and require it for all landscapers, etc.
--Mickey Nolen
  Nozzle Nolen, Inc.


Wisconsin recently passed new anti-phosphorus fertilization legislation that includes golf
course properties. As of March 10, 2008, anyone applying fertilizer to five acres or more
will required to have a written site specific nutrient management plan based on soil tests.
Phosphorus applications are prohibited unless deficiencies via soil testing. Thanks to
decades of studies, we have practical, environmentally safe Florida nutrient management
requirements for turfgrasses already calculated for Florida soils and regions north, central
and south. These are already contained in our Golf and Green Industry Best Management
Plans. Mandate that they be followed.
--Joel Jackson
  Florida Golf Course Superintendents Association


The focus needs to be on the homeowner, as the professional is already using as little
fertilizer as possible(profit) and is educated in BMP's
--Ken Miller
  affiliations with FTGA, FPMA, ISA, FNGLA


This will always be an enforcement issue, but there is a visual difference between a
healthy green lawn and an overfertilized lawn (that is why people over fertilizer). I think
it would be possible to develope a species specific and seasonal specific spectral
signature for a lawn that has been overfertilized. This spectral indicator could be verified
using a soil test if need be to verify sourse of nutrient is fertilizer based on isotope
signature and the amount in excess of normal application. This combined with
                                                                                         13

sufficiently strict penalties for over use may become a deterent. All fines should be used
for mitigation and TMDL implimentation as that will help ofset the cost we will all be
paying to make up for the implications of this over use. Local Governemtns should
review all homeowner association policies that require certain lawn care criteria so that
somebody that doesn't whant to mow or fertilizer doesn't have to. Make these HOA
requirements at least optional so that the peer pressure can begin to swing in the other
direction.



3. Local Government Regulations Based on Sound Science
   Model Ordinances

Tough, and REQUIRED
--S.L Baldwin


It should no longer be allowed to have homeowners associations to have the right to
mandate lawns or the level of lawn coverage in any subdivision or golf course
community. This is, in effect mandated pollution. A State constitutional amendment
banning this practice should be put in place.
--Charles Sobczak
   START (Solutions to Avoid Red Tide) Sanibel Chapter


The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Mario Perone
  ABC Pest Control


The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Robin Fogle


The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Tami Libretto


The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Nichole Libretto
                                                                                           14

The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Cory Page
  Homeowner


The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Nick Libretto
  home ower


The state should come up with regional reccomendations instead of local ordinances due
to city or county upriver water flow could effect what happens downflo.
--Bob Hanna



The state should come up with regional recomendations instead of local ordinances due
to city or county upriver water flow could effect what happens down stream. Also it
would make sure everyone is doing the same thing in the same area.
--Jim Thorpe
  Resident


I believe that every state should have rules and regulations so that companies dont have
20 different ordinances to follow because counties and citites have their ordinaces to
follow that overide the states rules and regulations I think if their was one ordinance to
follow for the whole stae and everone putting fertilizer was BMP certified it would make
life easier and encourage better water and waterways.
--Ryan Kirsch
   Resident


I believe that every state should have rules and regulations so that companies dont have
20 different ordinances to follow because counties and citites have their ordinaces to
follow that overide the states rules and regulations I think if their was one ordinance to
follow for the whole stae and everone putting fertilizer was BMP certified it would make
life easier and encourage better water and waterways.
--Glenn Cannedy
   Pest Control Tech

Local goverment (especially in coastal / watershed communities) should be allowed to
regulate using the latest science and water quality testing data available. There should
also be nothing to stop local goverment from enacting stricter regulations as needed.
--David Barney
                                                                                         15




This is a must! From what I have seen and read, most of the ordinances are based on
compulsive emotions and hype rather that any sound science. We are all very concerned
about the quality of water, not just in Florida. We all know or are told that there is too
much Nitrogen in the water samples. What we don't know is how much is naturally
occurring, or how much can be directly related to business putting it out verses the
consumers applications. Just because pest control companies, lawn care companies,
landscapers, or lawn maintenance company's are easier to regulate or easy targets doesn't
constitute a valid reason to target them. All pest control companies are already regulated
and have training requirements yet the very people that are not, are exempt, the
consumers.
--Dempsey R. Sapp Jr.
  Florida Pest Control & Chemical Co.


I would hope that sound science would provide the basis of a statewide regulation. Local
government's role would be to educate and interpret the regulation as it would apply to
local ecosystems.
--Bruce McCown
  Florida Pest Control and I'm a Homeowner


Local governments need to base their ordinances on state guidlines and sound science,
not on local public perceptions.
--Rick Reinhardt
  Dr. Jack Reinhardt, Inc.


See #1
--Jeffrey Weisman
  Citizen, Sierra Club


I support state regulation based on sound science, not emotional hype. Some scientific
findings are actually counter-intuitive - we must deal in facts. I support the statewide
adoption of the Florida Green Industries Best Management Practices (BMPs) as the guide
to fertilizer use - the best science-based tool we have to promote water quality, quality of
life, and still allow for individual choices. These were developed in conjunction with the
state Department of Environmental Protection and the University of Florida Institute for
Food and Agricultural Sciences.
--Patrick H Marriott
   Proway Services inc.
                                                                                             16



based on science,not a feel good law. sarasota was not based on science !!
--Craig Devereaux
  Turfmaster Lawn(Sarasota)


Let's keep the Junk science out of all our lives and rely on scientific facts, not fear facts.
--Kevin E. Fee
  Extermination Station


Yes and perhaps stronger rules than the State's, depending on the location of the
municipality or county.
--Elizabeth France
  Clearwater Garden Club, Pinellas Chapter of FNPS, Croton Society


Public notice in readable form of regulations that aim to preserve water quality.
--Alexa Ross
  Volusia Flagler Environmental Action Committee, Inc.


Yes - Follow & Adopts BMPs! Training!
--Jeffrey Melmer
  Quality First Lawn and Shrub Care, Inc.


no sutch thing
--Danny Swain
  Bug Termiteand Pest Control Co Inc.


I like the Naples Ordinance that if you are BMP certified, then you are exempt from local
regulation
--Mickey Nolen
   Nozzle Nolen, Inc.


The BMP's should not be easily overriden, as appears to be the case in the proposed
document, because by definition the BMP's are complete.
--Ken Miller
  affiliations with FTGA, FPMA, ISA, FNGLA


On Page 17 of the Dec. 17 summary, near the bottom: “Best Management Practices for
Protection of Water Resources in Florida, June 2002, Florida Green Industries as
                                                                                        17

referenced in 5E-1003(2)” is misidentified in the FDACS Rule. The correct title is:
“Florida Green Industries Best Management Practices for Protection of Water Resources
in Florida, June 2002,” published by the Florida Department of Environmental
Protection.


Developers should adopt Low Impact Development practices that minimize the amount
of turf left behind after the development is complete. This starts everything off in the
right direction. LID practices also minimize disturbance of native landscapes which can
also be a signficant contributor to downstream water qualtiy degredation.


4. Training and Education on Proper Use

County Extension mandatory Classes for all licensed growers.
--Ed Tedtmann
  Sierra Club


Set this up on a local basis, just as Sanibel is currently doing.
--Charles Sobczak
  START (Solutions to Avoid Red Tide) Sanibel Chapter


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Mario Perone
  ABC Pest Control


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Robin Fogle


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Tami Libretto


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Nichole Libretto
                                                                                          18

local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Cory Page
  Homeowner


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Nick Libretto
  home ower


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines.
--Bob Hanna
  ower


local counties and cities should set up educational programs,literiture,and cd`s on proper
ways to fert through extention office following state guidelines. Also the more educated a
person is about thier job or position the more likely they are to make sure that they are
following the rules and regulations.
--Jim Thorpe
  Resident


I think the state should have the counties and cities put on training seminars to train and
educate people the are putting down fertilizer using the state rules and regulations and
have cds, dvds, and a book providing proper techniques and the rules and regs.
--Ryan Kirsch
   Resident


I think the state should have the counties and cities put on training seminars to train and
educate people the are putting down fertilizer using the state rules and regulations and
have cds, dvds, and a book providing proper techniques and the rules and regs.
--Glenn Cannedy
   Pest Control Tech


Require a small tax on fertilizer products to help fund a statewide campaign on the proper
use of fertilizers and educate the public on the effects of fertilizers on the states water
resources.
--David Barney
                                                                                          19

I am all for better training and education on the proper use and application of fertilizers.
Our company has been providing and administering this for years. I think more imphasis
should be towards the consumers. If any city, county or municipality is going to come up
with an ordinance, it must be based on sound science and you can't have a different one
for each and every county, city or municipality. There are 67 counties in the state of
Florida. My company probably services forty or more of these county's.
--Dempsey R. Sapp Jr.
  Florida Pest Control & Chemical Co.


Companies already have an incentive to properly apply fertilizers as it affects their
bottom line. It doesn't make sense to apply fertilizers to non-target areas and training and
education along with verification can assure this.
--Rick Reinhardt
  Dr. Jack Reinhardt, Inc.


See #1 Make fertilizer companies adhere to the strict standards. They can train their
people. The less harsh fertilizer their employees use, the more healthy their employees
will become. After all, poison begets poison.
--Jeffrey Weisman
  Citizen, Sierra Club


I also support educating the public about a uniform, sound, science-based approach to
fertilizer use.
--Patrick H Marriott
  Proway Services inc.


all for it. leave apps. to licensed companys
--Craig Devereaux
  Turfmaster Lawn(Sarasota)

Get the products out of the publics hands and allow the licensed professionals to apply
the products properly.
--Kevin E. Fee
  Extermination Station


Essential!
--Elizabeth France
  Clearwater Garden Club, Pinellas Chapter of FNPS, Croton Society
                                                                                          20

IFAS conducts classes for professional landscapers.
--Alexa Ross
  Volusia Flagler Environmental Action Committee, Inc.


This is essential all the way down to technicians
--Jeffrey Melmer
  Quality First Lawn and Shrub Care, Inc.


Always the best idea is education
--Danny Swain
  Bug Termiteand Pest Control Co Inc.


Needs to be readily available to all
--Mickey Nolen
  Nozzle Nolen, Inc.




There needs to be a simple example, on the fertilizer label/bag and in literature, of how to
obtain sq. ft. for the homeowner. Most homeowners haven't a clue as to the amount of
turf area they have. I think this contributes and is the root to most over applications to
date!
--Ken Miller
  affiliations with FTGA, FPMA, ISA, FNGLA


Don't confuse turf BMP's that establish a minimum fertilizer application rate for healthy
lawns with BMP's that minimize nutrient runoff from a landscape. These are two
different objectives. A non turf yard may be the best managment approach to minimize
nutrient leaching or surface runoff. Make it clear to homeowners that a turf lawn will
require nutrients and water to be healthy and that as a result it will have increased water
demand, fertilizer application rate and other need for pest managment than certain
alternative landscapes.


5. Research and Studies Needs and Recommendations

Universities through state grants.
--Ed Tedtmann
                                                                                         21

 Sierra Club

We don't need any MORE money spend on research, we have PLENTY of proof that it is
effecting the waterways in a negative manner.
--S.L Baldwin




All you need down here on Sanibel to note the difference is that we haven't had an
Okeechobee release in two years and our water is clean, clear and the algae growth down.
--Charles Sobczak
  START (Solutions to Avoid Red Tide) Sanibel Chapter


any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Mario Perone
  ABC Pest Control


any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Robin Fogle


any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Tami Libretto


any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Nichole Libretto


any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Cory Page
  Homeowner


any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Nick Libretto
  home ower
                                                                                              22




any ordinance that is set up by state should go by science & research not by politictal or
public opinion
--Bob Hanna
  ower


any ordinance that is set up by state should go by science & research not by politictal or
public opinion. It sometimes feels that our politicians are swayed into making a decesion
without having all the facts, and then try to appease people that are only pushing issues
out of self serving interests.
--Jim Thorpe
  Resident


I think that the states rules and reg. should be based on science and research and not
political wise so that we can ensure we have the proper rules and regs so that we can have
good clean quality water and start getting fish back in.
--Ryan Kirsch
   Resident


I think that the states rules and reg. should be based on science and research and not
political wise so that we can ensure we have the proper rules and regs so that we can have
good clean quality water and start getting fish back in.
--Glenn Cannedy
   Pest Control Tech


Use some of the above mentioned tax funds to fund a statewide water testing program
using the best available testing methods (i.e. stable nitrogen isotope testing).
--David Barney


I think that the U of F IFAS should come up with the science to base our needs on. I think
the adoption of the Florida Green Industries Best Management Practices (BMP's) should
be used as a guide to fertilizer uses. I agree that one size doesn't necessarily fit all, neither
does a different ordinance for every city, county or municipality. That is over-kill. I really
think that the consumers are a big area that is starving for knowledge.
--Dempsey R. Sapp Jr.
   Florida Pest Control & Chemical Co.
                                                                                      23

Research showing the fate of lawn nitrates would benefit.
--Bruce McCown
  Florida Pest Control and I'm a Homeowner


Continued benefits of proper plant growth and properly applied fertilizer should be
weighed against the risks. The BMP already addresses these issues and is a good program
to support. Additional research or continued research to address reducing the affects of
fertilizers from contaminating our water should be conducted
--Rick Reinhardt
  Dr. Jack Reinhardt, Inc.


See #1 Measure human standards. How green the grass is not a measurement. The
number if live animals and fish is a measurement.
--Jeffrey Weisman
  Citizen, Sierra Club


We need to make sure the experts are making these regulations. Find out how much is
caused by other areas not under our industries control.
--Patrick H Marriott
  Proway Services inc.


yes, base it on science
--Craig Devereaux
  Turfmaster Lawn(Sarasota)


Most of your overuse comes from the public, take the products off of the over the counter
market and let the professionals handle the proper application of the products, or adopt
the Florida greens industries BMP's. We have research and studies, let's use them.
--Kevin E. Fee
  Extermination Station


I am not a scientist. The University of Florida should have valuable information.
--Elizabeth France
  Clearwater Garden Club, Pinellas Chapter of FNPS, Croton Society


Continual assessment of sea grasses, bottom dwellers, fish and marine mammals.
--Alexa Ross
  Volusia Flagler Environmental Action Committee, Inc.
                                                                                          24



I have little capability of keeping up on ever changing requirements
--Jeffrey Melmer
  Quality First Lawn and Shrub Care, Inc.


Try science it's reality
--Danny Swain
  Bug Termiteand Pest Control Co Inc.


I think IFAS is doing a great job but maybe we should get the USDA to do similar studies
for a second resource.
--Mickey Nolen
   Nozzle Nolen, Inc.


Research needs to be conducted based on total nutrient loading and a mass balance
approach. This needs to include both surface runoff and leaching. The need to fertilize a
lawn is because nutrient cycling is not 100% efficient and a net loss of things like
nitrogen often occur. Most research conducted on turf has been looking at the minimum
amount of fertilizer application to maintain a healthy turf, not the net loading to the
environment that occurs due to leaching and or runoff of nutrients added. A mass
balance approach would also do a much better job at assessing the cumulative loading
effect of fertilizers being applied at the watershed scale. Particulate transport and erosion
of sediments is often used as an arguement that turf needs to be fertilized to stabilize the
soils. This agrument has been supported in certin areas of the country where elevations
are high, but I have not seen these same studies conducted in florida where elevation is
for the most part very low. Turf studies should be conducted on more realistics conditions
of highly compacted soils. Most turf studies have had minimum runoff due to the fact that
the soils in the study are not compacted in a manner similar to that of a typical lawn or
comercial area that may be 80-90% compacted after construction.


6. Additional Overarching Considerations
   A. Using Best Available Data and Science
   B. Assessing Nutrient Enrichment And Surface Waters Due To Fertilizer
   C. Reducing Water Quality Impacts Associated With Fertilizer, Non-point
Source Pollution
   D. Complying with State and Federal Water Quality Standards
   E. Ensuring Uniformity, Accounting for Geographic Diversity and Variations

We must move away from landscaping toward Xeriscaping, and eventually to
Xeroscaping. One last item of note. In a state that is running out of water has anyone
considered use of the billions of gallons of untapped water that drain away from the
millions of AC units in the state? Can't we come up with a method or recapture and use
                                                                                          25

of that water?
--Charles Sobczak
  START (Solutions to Avoid Red Tide) Sanibel Chapter


A. using best educational resources
--Mario Perone
  ABC Pest Control


A. using best educational resources
--Robin Fogle


A. using best educational resources
--Tami Libretto


A. using best educational resources
--Nichole Libretto


A. using best educational resources
--Cory Page
  Homeowner


A. using best educational resources
--Nick Libretto
  home ower


A. using best educational resources
--Bob Hanna
  ower


I can not in good concious choice any one answer above the other, I feel and believe that
all should be followed to insure that we in Florida Can enjoy all that is available here for
many years to come and that we leave it in better shape for future, and many generations
to come.
--Jim Thorpe
  Resident
                                                                                           26

I believe all those should be used to ensure that we can keep our water clean and promote
fish to come in and ensure that we can have clean water for the years to come and future.
--Ryan Kirsch
  Resident


I believe all those should be used to ensure that we can keep our water clean and promote
fish to come in and ensure that we can have clean water for the years to come and future.
--Glenn Cannedy
  Pest Control Tech

Give the recent outbreak of red tide in brevard & indian river counties and reviewing the
water quality data collected by the surfrfider foundation and harbor branch oceanigraphic
institute, one could begin to formulate a connection between nutrient enriched waters and
outbreaks of harmful algal blooms. All sources of nutrient enrichment must be addressed.
The adverse impacts to the indian river lagoon and the nearshore coastal waters requires
an immediate response to help prevent further outbreaks and the possible loss of these
incredibly valuable resources.
--David Barney




Research should show how and to what percentage fertilizer applicatons get into our
water. Understanding the source and levels will allow us to better target our efforts to
maintain our water quality and not have kneejerk reactions based on media reports.
--Rick Reinhardt
  Dr. Jack Reinhardt, Inc.


See #1
--Jeffrey Weisman
  Citizen, Sierra Club


6.E. Turf Care Supply Corp. is a producer of granular fertilizer and pest control products
for the professional landscaping and golf industries. We exist, in part, because our
products are beneficial to society and the environment. But as with almost all chemical-
based products, they can be abused to the detriment of everyone. In light of this, we
encourage the performance of sound scientific studies that will identify the best ways of
using our products, and we support the education of the public in those ways. We
recognize that the best way to use our products can vary significantly from county to
county in any state. In fact, the best way to use our products may vary from neighborhood
to neighborhood, or even house to house. One side of a street may be dead flat, while the
other slopes steeply to a ditch ultimately leading to a lake or river. Due to this potential
                                                                                            27

for severely variable local conditions, we believe it is a mistake to require product labels
to carry the information specific to local or regional uses. This information is best made
available through readily accessible media, such as the internet, and enforcement should
be achieved locally at the point of sale and point of use. Automobile manufacturers do
not produce ownerís manuals that list all the streets of the nation along with their speed
limits. To do so would be an expensive and absurd effort. So it would be with fertilizer
and combo product labels. Even now, we are starting to produce and limit product
registration and distribution to certain states, solely because of labeling requirements. If
this trend continues, I am sure that we will strive to keep up with the legislative demands,
but it will be at a cost that will be borne by the consumer. The environment will be better
served by a web-based system that presents local restrictions and recommended
management practices. Let the product labels accurately and thoroughly describe product
characteristics, intended uses, and general restrictions, allowing local users to make
informed and compliant decisions. The resulting market demands will push producers
and distributors to get the appropriate products to the right places.
--Gary Platek
  Turf Care Supply Corp.


Some counties, cities have enacted regulations that go against the science. We need
strong state regulations similar to the pesticide laws.
--Patrick H Marriott
  Proway Services inc.


use and require "bmp's" as guidelines for any county. let us not just exclude golf courses
just becuse!!!!!
--Craig Devereaux
  Turfmaster Lawn(Sarasota)


As a longtime resident of Pinellas County, I strongly believe that the State of Florida
should adopt restrictions on the use of fertilizers. The public needs to be educated that
plants used in other areas and other countries cause problems here in Florida. Only a
small percentage of us residents know that by eliminating grass and using native and
Florida-friendly plants, the need for fertilizers and chemicals will become almost non-
existent. The local governments should offer education and incentives to homeowners.
--Elizabeth France
  Clearwater Garden Club, Pinellas Chapter of FNPS, Croton Society


The Dead Zone in the Gulf is the best known disaster from the cumulative tragedy of the
commons, the use of the watershed as a giant sewer of agricultural chemicals.
--Alexa Ross
  Volusia Flagler Environmental Action Committee, Inc.
                                                                                      28



On the other hand, six years of research conducted at the University of Wisconsin by Dr.
Wayne Kussow has shown that: 1. Banning phosphorus in fertilizer does not reduce
phosphorus runoff into water bodies. 2. Lawns treated with phosphorous fertilizer
produced less phosphorus runoff than those where no phosphorus was applied. 3. On the
average, runoff was 787% greater from unfertilized plots than from fertilized plots.
Source: Minnesota GCSA, Hole Notes Magazine Nov/Dec 2007 issue. The point:
Beware of the unintended consequences of applying non-scientifically based restrictions
on the proper management of a turfgrass eco-system.
--Joel Jackson
  Florida Golf Course Superintendents Association


Fertilizer Task Force
E-Mail Comments
1/2/08



I most sincerely request that the Florida Consumer Fertilizer Task Force and the 2008
Florida Legislature preserve in the proposed model ordinance the protective provision
allowing local governments to adopt different or more stringent measures than those
contained in the model if needed to attain TMDL goals or improve water quality. As you
know the Florida Stormwater Association estimates the cost of compliance for city and
county governments alone to attain targets to reduce loadings from various pollutants
pursuant to TMDLs is close to $52 Billion dollars and this does not include the cost of
operation or maintenance. The vast majority of the cost for retrofitting for urban Best
Management Practices will never be funded by the federal and/or state governments. For
example, the $20 Million allocation for TMDL grants established by the Florida
Legislature in 2005 was recently reduced by $2 Million. Please enter this request
verbatim into the written record at the final Florida Consumer Fertilizer Task Force
meeting to be held in Tallahassee on January 10th & 11th, 2008. Thank you, sir, and
Happy New Year.

Best Personal Regards,


Frederick C. Brummer
Orange County Commissioner

								
To top