The Draft Interim Guidance for former agricultural sites in Miami-Dade County that has been proposed by the Miami Dade County Department of Environmental Resources Management (DERM) unfairly targets agricultural lands, assumes without evidence that they are polluted, and imposes heavy handed environmental testing protocols. These decisions were made without without the input of the environmental community and landowners that it affects. This will create an unnecessary burden on owners of current and former agricultural lands that is duplicative and expensive, with no benefit to the health and safety of the public and environment.