The Urban Turf Rule in its current form is certainly in need of improvement; it sabotages the use of the most effective longer-term controlled-release Nitrogen products and allows for excessive application of Nitrogen and Phosphorous. However, the current Urban Turf Rule is not all bad - it does not deter local governments from adopting strict urban fertilizer ordinances.
Rulemaking in Florida is determined by statute; it must involve a stakeholder negotiation process and must make it easier rather than harder for stakeholders to participate. In as much, the environmental/conservation community would be remiss if we allowed the fertilizer, pest control and turf industries to take part in the rulemaking process without challenge.
We have two main concerns:
1. We need to challenge and defeat any modifications to the rule that would negatively impact the ability of local governments to continue to adopt strong, protective fertilizer ordinances that include rainy season application bans, requirements for high percentage controlled-release Nitrogen, and annual application rate limits.
2. We need to improve the Urban Turf Rule to make it more protective of water quality.
The Sierra Club has submitted information requests and comments related to the initially proposed modifications to the Rule and new proposed changes as well.
For the current Rule and links to the proposed changes (go to "Workshop") click here.
Right now the major issues are:
Re: Relevant research: Modifications should be based on relevant research.
Re: "Actively Growing": The newly proposed table ((2) (b) 4. a. Fertilization Guidelines for Established Turfgrass Lawns in Three Regions of Florida Nitrogen Recommendations) currently includes the unacceptable, very subjective, definition of "actively growing" that could be interpreted by some to mean that the only time to fertilize turf is during the height of the rainy season. What the revised Rule needs (by definition) is an appropriate, objective manner of stating clearly that dormant turf should not be fertilized. The current Rule guideline table is preferable to the newly proposed table for other reasons as well.
Re: Phosphorous application rates: It is high time for Florida to go "No Phosphorous" (without a soil test proven deficiency).
Re: Application rate for quick-release Nitrogen: It is also time to limit the per application rate of quick-release Nitrogen to .5 lb.; there is no research-based argument for remaining with the current Rule limit of .7 lb.
Re: Application rates for controlled-release Nitrogen: Care must be taken to allow for the use of higher percentage (longer extended) controlled-release Nitrogen (more pounds per application) in a way that does not allow too much of the quick-release Nitrogen (found in the controlled-release products) to be released in the first seven days.
Re: The adverse impact and/or regulatory costs incurred by the Rule changes: The statute related to the impact regulatory costs have on the rulemaking process can be found here. In a nutshell, if the costs meet a certain limit then the rule change must be ratified by the legislature. I am absolutely sure that all of the stakeholders have this fact on their minds and I believe this issue will be a significant part of the discussion as the workshops proceed.
Re: Subsequent workshop dates and locations: A number of local governments and organizations, including the Sierra Club, have requested regionally-located workshops to make stakeholder involvement more accessible. The more requests FDACS receives, the more likely regional workshops will be. Please send your own request to:
Program Planning Coordinator, Division of Agricultural Environmental Services
Florida Department of Agriculture and Consumer Services
3125 Conner Boulevard, Tallahassee, FL 32399-1650
Requests to be on the distribution list should also go to Mr. Collier.
The first rulemaking workshop, held in Tallahassee on May 28, was well-run and a full discussion of the issues was allowed. I encourage all who share the Sierra Club's concerns to attend subsequent workshops.
Please contact firstname.lastname@example.org for more information.