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18 <br />consequences of using these products The APB would welcome the opportunity to work with <br />the Commission for the Environment to consider embarking on such an informational campaign. <br />Considering these factors, the APB questions how much more the local agricultural sector can <br />reduce nutrient levels? Soils in some areas of Orange County have high levels of Phosphorus, <br />occurring naturally. It will be very difficult to demonstrate any reduction in these communities <br />since farmers have reduced the use of Phosphorus as part of their fertilizer mix now. In <br />addition, the proposed rules do not speak to organic farming practices, which are increasing in <br />popularity in Orange County. The accounting tool should including references to organic <br />practices where appropriate. <br />Part of the APB's mission is to advise the BOCC on matters pertaining to local farming. It is our <br />understanding that the BOCC may have an opportunity to submit comments on this program in <br />the coming weeks. We hope you will consider incorporating our concerns into your broader <br />remarks on potential impact of these regulations on all local residents. <br />Thank you for the opportunity to submit comments on behalf of the agricultural community. If <br />we may offer any additional information please let us know. <br />2 <br />