STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

MARY ANN WHITE, )

)

Petitioner, )

)

vs. ) CASE NO. 90-3120

)

DEPARTMENT OF HEALTH AND )

REHABILITATIVE SERVICES, )

)

Respondent. )

)

RECOMMENDED ORDER

Pursuant to notice, this cause came on for hearing before P. Michael Ruff, duly-designated Hearing Officer of the Division of Administrative Hearings, on August 20, 1990, in Cross City, Dixie County, Florida.

APPEARANCES

FOR PETITIONER: Mary Ann White and Iman White, pro se

P.O. Box 756

Old Town, Florida 32680

FOR RESPONDENT: Frances Childers, Esquire

Assistant District Legal Counsel HRS District 3 Legal Office

1000 Northeast 16th Avenue Gainesville, Florida 32669

STATEMENT OF THE ISSUES

The issue for consideration in this proceeding concerns whether the Petitioner is entitled to an on-site sewage disposal system ("OSDS") permit authorizing installation of an OSDS on property which Petitioner owns near the Suwanee River in Dixie County, Florida, in accordance with Section 8l.272, Florida Statutes, and Chapter 10D-6, Florida Administrative Code.

PRELIMINARY STATEMENT

This cause arose upon the filing of an application for an OSDS permit by Petitioner, Mary Ann White, and Inman White. That application was filed with the Department, the Respondent herein, on March 20, 1990, and relates to the Petitioner's intention to place a mobile home residence on their property, consisting of approximately 18.5 acres, near the Suwanee River, in Dixie County, Florida. The Respondent denied that permit application. On April 23, 1990, the Respondent advised the Petitioner that they could pursue a formal administrative proceeding to contest the denial of that permit but advised them that the normal variance board procedure world be dispensed with because of the Respondent's view that the Governor's Executive Order NO. 90-14 had the effect of precluding

any OSDS for property located beneath the ten-year flood elevation of the Suwanee River. Hence, the Petitioner never actually filed an application for a variance from the statutes and rules governing permitting of OSDS's.

The cause came on for hearing as noticed. The Petitioner presented the testimony of Inman L. White at the hearing, and Petitioner's Exhibit Nos. 1 and

2 were admitted into evidence. The Respondent presented the testimony of James

1. Fross, and Respondent's Exhibit Nos. 1, 2 and 3 were admitted into evidence. At the conclusion of the hearing, the parties ordered a transcript of the proceeding and were given the right to file proposed findings of fact and conclusions of law in the form of Proposed Recommended Orders. Only the Respondent filed proposed findings of fact, which are addressed in this Recommended Order and in the Appendix attached hereto and incorporated by reference herein.

   
   

   FINDINGS OF FACT

   
   

   1. The Petitioner is an owner, by joint tenancy, of real property located in Dixie County, Florida, more particularly described as part of Government Lot 1, Section 4, Township 11 South, Range 13 East; closely proximate to the Suwanee River at a location generally known as "New Pine Landing". The surrounding property is characterized by homes and mobile home,;, which have OSDS's installed and operating. The subject property has no improvements constructed thereon, although the Petitioner intends the placement of a 12X60 foot mobile home, containing two bedrooms and one bathroom. There is no OSDS of any type installed on the property at the present time.

      
      

   2. The subject property is approximately 18.5 acres in size. It was purchased on January 17, 1990, but the property in question has never been platted. On March 20, 1990, the Petitioner made application for an OSDS permit for the aforesaid property, which was denied by the Respondent's letter of denial dated April 23, 1990. The Petitioner was not afforded the opportunity to pursue an informal variance application through the variance procedure set up by the statute and rules cited hereinbelow. Rather, the Respondent, in its denial letter, indicated that, because of the perceived effect of the Governor's Executive Order, discussed hereinbelow, no variances were being granted and the variance procedure would be "bypassed" in favor of affording the Petitioner a formal administrative hearing before the Division of Administrative Hearings concerning the permit denial.

      
      

   3. The Petitioner testified generally concerning the character of the property in question and the general nature of the terrain and vegetation. The property is characterized by a wetland or swampy area at one end of the property and, in the area of the proposed installation site, the ground elevation is higher, with a benchmark elevation of 8.8 feet above mean sea level ("MSL"), as established by Herbert H. Raker, certified land surveyor, and depicted by Petitioner's Exhibit 2 in evidence. The Petitioner offered no testimony concerning the ground water levels, other than to say that at one point in time, he dug a three-foot-deep hole on the subject property near the septic tank installation site and observed no water in the hole. His testimony did not indicate at what season of the year the observation was made nor whether conditions were wet or dry at the time. The only concrete evidence concerning ground water level at this installation site was that offered by the Respondent, which indicates that the ground water level at the time of the site evaluation was 42 inches below the surface of the property in question at the proposed installation site and, through observation of "mottling1, of the soil, indicating the presence of dampness, that the wet season water table is 12

      inches below the surface of the property. Likewise, the Petitioner professed to have no knowledge of the ten-year flood elevation for the property. The Respondent's evidence, derived from materials submitted by the Petitioner in furtherance of the application, consisting of a report from the Suwanee River Water Management District, establishes that the ten-year flood elevation is 14 feet above MSL for Suwanee River Mile 29, which corresponds to the location of the subject property.

      
      

   4. The property is also located within the regulatory floodway administered by the Suwanee River Water Management District. Rule 10D-6.047, Florida Administrative Code, mandates that before a mounded system for on-site sewage disposal can be installed, a certification by a registered engineer would be necessary to determine that installation of such a mounded system would not raise the level of the "base flood". No such engineering testimony or evidence has been offered in this proceeding, however.

      
      

   5. The Petitioner further testified in a general sense that it would be a hardship not to be able to) install the OSDS on the property, given the money paid to purchase the property and the intent by the Petitioner to use it for a residence. The Petitioner has no use for the property without being able to use it for a residence. The Petitioner, however, did not offer any testimony or evidence concerning alternatives to installing the proposed OSDS, nor did the Petitioner establish that installation of such a system or an alternative system would pose no adverse health effects on the Petitioner or members of the general public nor that it would pose no degradation to the surface or ground waters involved for purposes of the Petitioner establishing entitlement to a permit or a variance It should be remembered, however, that the Petitioners were not accorded the opportunity to avail themselves of the variance procedure because of the Respondent's interpretation of the Governor's Executive Order 90-14, which it opines precludes it from granting any variances, or permits for OSDS within the ten-year flood elevation. This leads to its advising the Petitioner that to apply for a variance in this instance would be futile. The Governor's Executive Order, which incorporated the "Suwanee River Task Force" recommendation to preclude such system; beneath the ten-year flood elevation was entered on January 17 1990. The Respondent has, in effect, interpreted that Executive Order as precluding it from exercising its discretion to entertain and grant or deny variance applications.

      
      

      CONCLUSIONS OF LAW

      
      

   6. The Division of Administrative Hearings has jurisdiction over the subject matter and the parties to this proceeding. Section 120.57(1), Florida Statutes (1989).

      
      

   7. The Petitioner seeks to obtain an OSDS permit for property located in Dixie County, Florida. The Petitioner seeks to change the status quo and, therefore, has the burden to establish the proof necessary to demonstrate entitlement to the OSDS permit. See, Florida Department of Transportation v.

      J.W.C. Company, Inc., 396 So.2d 778 (Fla. 1st DCA 1981). The Petitioner did not file an application for a variance because of representations made by the Respondent's personnel that such an application would be futile in light of the interpretation of the applicability of the Governor's Executive Order, referenced herein. The Petitioner's proof established no potential alternative sewage disposal systems and Methods for the property in question, which might safely and effectively treat the effluent without causing degradation of ground or surface waters or health hazards. Therefore, no substantial effort was made to comply with the permitting statutes and rues, themselves, through

      demonstration of effective alternative sewage disposal and treatment systems in the face of the fact that the property at issue lies below the ten-year flood elevation. Likewise, no proof was offered supportive of the grant of a variance (due to hardship) from the permitting statutes and rules in terms of the three variance criteria enunciated in Section 381.272(8), Florida Statutes, and the related rule That is, no proof was offered that no reasonable alternative to a conventional septic-tank-drain-field-type disposal system was offered by the Petitioner, nor was it established that the effluent from the system proposed to be installed would not adversely affect the health of the Petitioner or the general public nor that it would not adversely affect the quality of the surface or ground waters involved at the site. Ths, had a variance been applied for, it could not be granted- based upon the quality of proof offered by the Petitioner.

      
      

   8. The basic requirements for an OSDS permit are contained in Section 381.272, Florida Statutes, which provides as follows:

      
      

      "(1) where a publicly owned or investor owned sewage system is not available, the Department of Health and Rehabilitative Services may issue permits for construction or installation of on-site sewage disposal

      systems under conditions as described in this section.

      1. Subdivisions and lots in which each lot has a minimum of at least one-half acre and either a minimum dimension of 100 feet or a main of at least 100 feet of the side bordering the street and the distance formed by a line parallel to the side bordering the street drawn between the two most distant points of the remainder of the lot be developed with a private potable well and on- site sewage disposal system, provided the projected domestic sewage flow does not exceed an average of 1500 gallons per acre per day, and provided satisfactory drinking water can be obtained and all distance and set back, soil conditions, water table elevation, and other requirements of this section and rules promulgated hereunder can be met.

      2. Subdivisions and lots with public water system may utilize on-site sewage disposal systems, provided there are no more than four lots per acre, provided the projected daily domestic sewage flow does not exceed an average of 2500 gallons per acre per day, and provided all distance and set back, soil conditions, water table elevation and other related requirements which arc generally applicable to the use of on-site sewage disposal systems are met."

         
         

   9. The specific requirement for on-site sewage disposal systems for lots platted before 1972, set forth in Section 381.272, Florida Statutes, does not pertain to the property in question because the property has never been platted.

   10. Rule 10D-6.043(1), Florida Administrative Code, provides that no on- site sewage disposal system shall be installed without a permit obtained from the Department.

       
       

   11. Rule 10D-6.044(3), Florida Administrative Code, states that suitability of the property for use of an on-site sewage disposal system shall be determined by evaluation of lot size, anticipated hydraulic load to the system, soil and water table conditions, and soil drainage and site typography.

       
       

   12. Rule 10D-6.046, Florida Administrative Code describes the requirement for location and installation of an on-site sewage disposal system and Rule 10D- 6.046(7)(a), Florida Administrative Code, provides that each lot upon which an OSDS his installed shall have a minimum area of one-half acre. The property in question meets the minimum size-standard.

   13. Rule 6D-6.047(6), Florida Administrative Code states that: "(6) The final lot elevation the site of

       the proposed system installation and the

       additional unobstructed land referred to in Rule 10D-6.046(4) is not subject to frequent flooding. In addition, the bottom surface of the drain field trench or absorption bed shall not be subject to flooding based on ten year flood elevations. U.S. Department of Agriculture Soil Conservation Service soil maps, state of Florida Water Management District's data, and federal emergency management agency flood insurance maps are resources that can be used to identify the flood prone areas. Mound systems, sand placement of fill material or construction of above grade structures, will not be authorized within a regulatory floodway unless certified by an engineer registered within the state of Florida that the placement of such fill or structures will not increase the water surface elevation of the base flood. The certification of such systems shall be substantiated by data and method of calculation provided, by the engineer and shall be subject to review and approval by the County Public Health Unit."

       
       

   14. It should be noted that this particular property is within the regulatory floodway. Therefore, the engineering certification, calculation and data would be required preparatory to authorization and permitting of a mounded system, consisting of fill material or construction above the grade of the property at the installation site. No such engineering proof has been adduced in this proceeding, however.

       
       

   15. When pursuing a permit application, the applicant must demonstrate entitlement to the OSDS permit based upon demonstrated compliance with the criteria contained in the statute and rules cited herein. This application was denied specifically because the site of the proposed drain-field system is within the ten-year flood elevation parameter for the Suwanee River. The Petitioner failed to prove that the property is above the ten-year flood

       elevation so as to entitle Petitioner to an OSDS permit, in accordance with the rule cited last above. That was the sole basis for the Respondent's denial of j-he permit application, as shown by the denial letter and testimony of record.

       In fact, the evidence affirmatively establishes that the property and proposed installation site lies below the ten- year flood elevation. Parenthetically, it should be noted that it was established that the appropriate types of soil extend 42 inches or more below the bottom surface of the proposed drain-field trench or absorption bed, in accordance with Rule 10D-6.047(1), Florida Administrative Code, but the water table elevation at the wettest season of the year does not lie at least 24 inches below the bottom surface of the proposed drain-field trench or absorption bed. In fact, Respondent's Exhibit NO. 2 in evidence establishes that the bottom of the proposed drain-field trench would lie only approximately 12 inches above the wet season water table. The failure to show compliance with this additional standard for OSDS permitting would constitute an independent basis for denial of the permit. However, the installation site not being in compliance with the ten-year flood elevation standard in paragraph (6) of Rule 10D-6.047, Florida Administrative Code, was the sole basis for denial of the permit, expressed in the denial letter initiating this proceeding, and is a sufficient basis for denial.

       
       

   16. As alluded to above, the applicant's proof does not support entitlement to a variance from the above-cited permitting statute and rules. The applicant did not demonstrate that no reasonable alternative exists for the treatment of the sewage in question and did not demonstrate that the discharge from the individual sewage disposal system proposed would not adversely affect the health of the applicant, members of the public, or would not significantly

       degrade the ground or surface waters involved. It was not demonstrated that the lot in question was platted prior to 1972, as that relates to special considerations which can be given under Section 381.272(8), Florida Statutes, concerning variances. In fairness to the Petitioner it should be pointed out that the Petitioner did not come to hearing seeking to prove entitlement to a variance apparently because the Respondent had instructed the Petitioner as to the futility of applying for a variance and seeking to prosecute a variance proceeding through its informal variance board process. This was because of the Respondent's perception concerning the applicability of the Governor's Executive Order No.. 90-14, as precluding any consideration of variance requests. In that connection, on January 17, 1990, Governor Martinez issued Executive Order NO. 90-14 (d the Suwanee River basin. In section 1 of that Order, the Governor directed the Respondent to implement the Suwanee River recommendation, as described in the Task Force Report. That report recommended that OSDS's should be prohibited within the ten-year flood plan and should otherwise be in compliance with applicable rules and regulations concerning such systems and their installation. The Respondent has taken the position, therefore, that the Governor's Executive Order, in effect, indicates that OSDS's are sources of pollution in the Suwanee River, and that regulations prohibiting the installation of them within the ten-year flood elevation are, ipso facto, designed to protect public health and prevent significant degradation of ground or surface waters. In effect, the Respondent conclusively presumes that if such systems are installed within the ten-year flood elevation, the they cause degradation or adverse effect on public health and ground or surface waters.

       The Respondent, thus, has conclusively presumed that no such variance applications can be granted, nor can permits be granted based upon alternative systems and approaches to treatment and disposal of sewage effluent on site if the installation site in question is at or beneath the ten-year flood elevation.

   17. Section 381.272(8), Florida Statutes, authorizes, along with the related rules enacted pursuant to it, that the Respondent may grant variances from the statutory and rule- embodied permitting requirements for OSDS's. That statutory mandate under which the related rules were enacted, constitutes authority emanating from the Florida Legislature directing the Respondent to allow a procedure whereby variances from strict application of the permitting requirements can be granted, in proper cases, so as to authorize them in cases of unavoidable hardship, balanced with the small likelihood of environmental damage, as enunciated in the statutory provision arid rules cited above. Section 381.272(8), Florida Statutes, and the rules enacted under it clothe the Respondent with discretion in this area and mandate that such a variance procedure be inaugurated and followed for the benefit of the members of the public who seek OSDS permits, have them denied, and, therefore, need an opportunity to demonstrate a hardship entitlement to a variance from the

       permitting rules, if the above-cited three requirements for proof of entitlement to a variance can be met. This is not an unbridled discretion, and the consideration of variance applications must conform to the three requirements set forth in the statutory section cited last above and repeated in Rule 10D- 6.045(3), Florida Administrative Code. This statutory and regulatory scheme sets up a discreet variance procedure which affords the affected public the opportunity to show the Respondent a hardship basis for avoiding the stricture of a permit denial for noncompliance with the statutes and rules pertaining to permitting, itself. If the Respondent persisted in its present interpretation of the effect of the Governor's Executive Order, it would, in effect, create a conclusive presumption against the grant of any variances for any property and OSDS installation sites owned by an applicant which happened to lie beneath the ten-year flood elevation for the Suwanee River. The Governor's Executive Order, however, cannot legally obviate the mandate of the Legislature that the Respondent must exercise discretionary authority in this area, within the bounds of the variance criteria enacted by the Legislature in Section 381.272(8), Florida Statutes, and in the above-cited rule. If the Executive Order is so interpreted by Final Order in this and other similar proceedings, it would constitute a violation of the separation of powers doctrine embodied in the Florida Constitution and thus would be an impermissible usurpation of the authority of the legislative branch of government by the executive.

       
       

   18. Rather, at most, the Governor's Executive Order can only serve as guidance to the Respondent in considering variance applications under the legislatively-mandated variance criteria referenced above, as, for instance, a policy basis for determining the materiality of deviations from the technical permitting standards for such installations concerning the overall issue in variance proceedings regulating whether the discharge will adversely affect health or significantly degrade ground or surface waters. The Governor's Executive Order cannot, however, appropriately be used as raising a conc1usive presumption having universal application to all such proceedings, dictating that all variances be denied simply because the sites to which they relate lie below the ten-year flood elevation of the Suwanee River. All opportunity to show lack of adverse health effects, lack of degradation of ground or surface waters or that no reasonable alternatives exist for the treatment of the sewage effluent in question, as that relates to demonstration of sufficient hardship justifying the grant of a variance, cannot thus be automatically and arbitrarily foreclosed. Since the variance statute in question and the rules enacted pursuant to it constitute a legislative mandate that that variance procedure be inaugurated and followed by the Respondent in situations where permits are initially denied by the Respondent, that scheme must be employed and followed until repealed or amended-.

   19. Although the subject OSDS permit entitlement has not been proven by the Petitioner because of the ten-year flood plain consideration discussed herein, that does not mean that the Petitioner should not be accorded the opportunity to establish entitlement to a variance. Likewise, if the Petitioner, by later application, can demonstrate changed factual circumstances as, for instance, that alternative treatment and disposal systems or methods are available and feasible (which was not done in this case), then a later permit application, itself, encompassing demonstration of such changed circumstances, could be entertained.

RECOMMENDATION

Having considered the foregoing Findings of Fact, Conclusions of Law, the evidence of record, the candor and demeanor of the witnesses, and the pleadings and arguments of the parties, it is therefore,

RECOMMENDED that a Final Order be entered denying the Petitioner's application for an OSDS permit without prejudice to the Petitioner applying for and seeking a variance from the statutory and rule requirements related to permitting, for the reasons found and concluded above; and without prejudice to pursuing an OSDS permit application at a later time should the Petitioner become able to demonstrate that alternative methods of treatment and disposal of the sewage effluent in question can feasibly be performed within the bounds of the standards enunciated in the above-cited statutes and rules concerning on- site sewage disposal permitting.

DONE AND ENTERED this 19th day of December, 1990, in Tallahassee, Leon County, Florida.

P. MICHAEL RUFF Hearing Officer

Division of Administrative Hearings The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-1550

(904) 488-9675

Filed with the Clerk of the Division of Administrative Hearings this 20th day of December, 1990.

APPENDIX TO RECOMMENDED ORDER IN CASE NO. 90-3120

Respondent's Proposed Findings of Fact: 1-9. Accepted.

Petitioner's Proposed Findings of Fact: None filed.

COPIES FURNISHED:

Sam Power, Agency Clerk Department of HRS

1323 Winewood Boulevard

Tallahassee, Florida 32399-0700

Linda K. Harris, Esquire General Counsel Department of HRS

1323 Winewood Boulevard

Tallahassee, Florida 32399-0700

Mary Ann White and Inman White

P.O. Box 756

Old Town, Florida 32680

Frances Childers, Esquire Assistant District Legal Counsel HRS District 3 Legal Office

1000 Northeast 16th Avenue Gainesville, Florida 32609

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit written exceptions to this Recommended Order. All agencies allow each party at least 10 days in which to submit written exceptions. Some agencies allow a larger period within which to submit written exceptions. You should contact the agency that will issue the final order in this case concerning agency rules on the deadline for filing exceptions to this Recommended Order. Any exceptions to this Recommended Order should be filed with the agency that will issue the final order in this case.

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AGENCY FINAL ORDER

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STATE OF FLORIDA

DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES

MARY ANN WHITE,

Petitioner, CASE NO. 90-3120 vs.

DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES,

Respondent.

/

FINAL ORDER

This cause came on before me for the purpose of issuing a final agency order. The Hearing Officer assigned by the Division of Administrative Hearings (DOAH) in the above-styled case submitted a Recommended Order to the Department of Health and Rehabilitative Services (HRS). A copy of that Recommended Order is attached hereto.

FINDINGS OF FACT

The department hereby adopts and incorporates by reference the findings of fact set forth in the Recommended Order.

CONCLUSIONS OF LAW

The department hereby adopts and incorporates by reference the conclusions of law set forth in the Recommended Order except where inconsistent with the following:

In Executive Order 90-14 the Governor concluded that the greatest threat to the Suwannee River is potential development along the river and that only those land uses compatible with maintaining the natural resource values of the Suwannee River basin should be allowed.

The problems with use of septic tanks in the Suwannee floodplain were addressed in the report of the task force adopted in Executive Order 90-14. The extent of the problem can be seen from the following exerpts from page 14 and 19 of the report:

.... there are an estimated

20,000 - 25,000 small tract platted lots in the Suwannee basin, most of which are currently undeveloped....

Septic tanks along the Suwannee River have been implicated in

contributing to the high levels of fecal coliform bacteria that have resulted in the closing and restricting of shellfishing in a large portion of Suwannee Sound....

Executive Order 90-14 (adopting recommendation 36 of the Task Force Report) prohibits septic tanks (on-site sewage disposal systems) within the 10 year floodplain of the Suwannee River. The Hearing Officer expressed concern about the constitutionality of such a prohibition and suggested that Executive Order 90-14 be considered as advisory only. The Courts have held that administrative agencies lack the authority to adjudicate constitutional issues. Key Haven vs. Board of Trustees, 427 So2d 153 (Fla. 1982), State Department of Transportation vs. Hendry, 500 So2d 218, 222 (Fla. 1st DCA 1986), Carrollwood State Bank vs.

Lewis, 362 So2d 110, 113 - 114 (Fla. 1st DCA 1978). Thus, I conclude that the department should continue to enforce the ban on on-site sewage disposal systems within the 10 year floodplain of the Suwannee River.

Based upon the foregoing, it is

ADJUDGED, that petitioner's application seeking a permit for an on-site sewage disposal system be DENIED.

DONE and ORDERED this 15th day of February, 1991, in Tallahassee, Florida.

Robert B. Williams Acting Secretary Department of Health and Rehabilitative Services

by for Deputy Secretary for Health

A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW WHICH SHALL BE INSTITUTED BY FILING ONE COPY OF A NOTICE OF APPEAL WITH THE AGENCY CLERK OF HRS, AND A SECOND COPY, ALONG WITH FILING FEE AS PRESCRIBED BY LAW, WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE AGENCY MAINTAINS ITS HEADQUARTERS OR WHERE A PARTY RESIDES. REVIEW PROCEEDINGS SHALL BE CONDUCTED IN ACCORDANCE WITH THE FLORIDA APPELLATE RULES. THE NOTICE OF APPEAL MUST BE FILED WITHIN 30 DAYS OF RENDITION OF THE ORDER TO BE REVIEWED.

Copies furnished to:

Mary Ann White & Inman White, pro se Post Office Box 756

Old Town, FL 32680

Frances S. Childers, Esquire District 3 Legal Office

1000 N.E. 16th Avenue Gainesville, Florida 32609

P. Michael Ruff Hearing Officer

DOAH, The DeSoto Building 1230 Apalachee Parkway

Tallahassee, FL 32399-1550 Eanix Poole (HSEH)

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing was sent to

the above-named people by U.S. Mail this 22nd day of February, 1991.

R. S. Power, Agency Clerk Assistant General Counsel Department of Health and

Rehabilitative Services 1323 Winewood Boulevard Building One, Room 407

Tallahassee, Florida 32399-0700 904/488-2381

Docket for Case No: 90-003120

Orders for Case No: 90-003120