Comment submitted by Joel Jackson, Executive Director, Florida Golf Course Superintendents Association (FGCSA)

The assignment of a fixed numeric concentration for nitrogen, phosphorus and chlorophyll A in the waters of a state enriched by all three ignores the variabilty of Florida's surface waters. Trying to meet arbitrary numbers in a dynamic everchanging natural system will waste valuable time, effort and resources. This artificial number system will divert funds being spent on real time efforts to install best management practices which realistically improve the state's water quality. One example was the survey of 20 of Florida's most productive fishing lakes. Under the proposed EPA criteria 80% of them would be classified as impaired, and yet they are thriving biologically diverse and robust bodies of water. At a time when our state's economy is already reeling under the recession, this unfunded mandate to meet these flawed numeric levels that are mathematically modeled instead of being site specific will place undue burdens on local governments and businesses struggling to survive as it is. We need realistic, attainable goals based on site specific conditions that react to the real inputs from all sources natural and manmade and not a artificial number forced on one state out of 50 not yet in full mathematic compliance with the Clean Water Act.