07-001413 In Re: Petition To Establish The Southeasten Community Development District vs. * Status: Closed Recommended Order on Monday, July 2, 2007.

Summary: Report issued concerning the petition to contract the size of an existing community development district in Tallahassee.

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

IN RE: PETITION FOR RULE )

CREATION – SOUTHEASTERN ) Case No. 07 - 1413

COMMUNITY DEVELOPMENT DISTRICT )

_ _______________________________ )

ADMINISTRATIVE LAW JUDGE'S REPORT TO THE FLO RIDA LAND

AND WATER ADJUDICATORY COMMISSION

Pursuant to notice, a local public hearing was held in this

matter in Tallahassee, Florida, on June 5, 2007, before

D onald R. Alexander, a n Administrative Law Judge of the Division

of Administr ative Hearings .

APPEARANCES

For Petitioner: Michael C. Eckert, Esq uire

Joseph A. Brown, Esq uire

Hopping Green & Sams, P.A.

Post Office Box 6526

Tallahassee, Florida 32314 - 6526

STATEMENT OF THE ISSUE

The issue is whether the Petition to E stablish the

Southeastern Community Development District (Petition) meets the

applicable criteria set forth in Chapter 190, Florida Statutes

(2006 ), 1 and Florida Administrative Code Rule Chapter 42 - 1. The

pu rpose of the hearing was to gather information in anticipation

of quasi - legislative rulemaking by the Florida Land and Water

Adjudicatory Commission (Commission).

PRELIMINARY STATEMENT

On February 2, 2007, The St. Joe Company (Petitioner) filed

its Petit ion with the Secretary of the Commission. Prior to

that time, a copy of the Petition and exhibits , along with the

requisite filing fee, were filed with the City of Tallahassee

(City) and Leon County (County) , where the proposed community

development distr ict ( District ) will be located . 2

On February 15, 2007, the Commission issued a Notice of

Insufficiency and Reque st for Additional Information (Notice of

Insufficiency) . On March 15, 2007, Petitioner submitted its

Response to the Notice of Insufficiency.

On March 21, 2007, the Secretary of the Commission

certified that the Petition contained all required elements and

forwarded it to the Division of Administrative Hearings for the

purpose of holding the local public hearing required under

Section 190.005( 1)(d), Florida Statutes.

The local public hearing was held on June 5 , 2007 , in

Tallahassee, Florida. Notice of the public hearing was

published in accordance with Section 190.005(1)(d), Florida

Statutes. On June 1, 2007, Petitioner pre - filed the testi mony

of its five witnesses.

At the local public hearing, Petitioner presented the

testimony of Bill Wier , its Vice President and Project Manager ;

Fred A. Greene , P. E., of CH2M Hill and accepted as an expert ;

James A. Perry, Managing Director of Governmen tal Management

Services, LLC, and accepted as an expert; G. Russell Weyer ,

Senior Associate at Fishkind & Associates, Inc . , and accepted as

an expert ; and Jorge Gonzalez , its Vice President of

Entitlements and accepted as an expert. No members of the

publ ic appeared at the hearing. Petitioner also offered

Petitioner's Exhibits 1 through 7, which were received into

evidence. Composite Exhibit 1 is the Petition and attached

E xhibits 1 - 9; Exhibit 2 contains the affidavits of publication;

Exhibit 3 is the re solution of the City supporting the

establishment of the District; Exhibit 4 is a similar resolution

by the County; Exhibit 5 is the pre - filed testimony of the five

witnesses; Exhibit 6 contains consents to establish the District

by two entities that purch ased parcels within the proposed

District after the Petition was filed; and Exhibit 7 is the

resume of Jorge Gonzalez.

The T ranscript of the local public hearing was filed on

June 19, 2007. On the same date, Petitioner filed a Proposed

Report of Findin gs and Conclusions , which has been considered in

the preparation of this Report .

SUMMARY OF THE RECORD

A. Petition and Related Matters

1. Petitioner is seeking the adoption of a rule by the

Commission to establish the District , which will consist of

approximately 1,035 acres located within the City and

unincorporated part of the Co unty. The proposed District lies

just south of Apalachee Parkway , east of Capital Circle

Southeast ( as it swings in a southerly direction from Apalachee

Parkway before turn ing to the west), and north of Tram Road.

The southern boundary of the District lies a short distance from

the State office complex in Southwood. The name for the

proposed District is the Southeastern Community Development

District. Petition Exhibit 2 d escribes the metes and bounds of

the external boundaries of the District , while Petition Exhibit

4 is a map depicting the boundaries of the District and the land

uses on the Future Land Use Map of the local comprehensive plan .

2. There are two parcels wit hin the external boundaries of

the proposed District which are to be excluded from the

District. The two out - parcels are owned by Kilpatrick Cemetery,

c/o Eddie L. Kilpatrick, 3727 Old St. Augustine Road,

Tallahassee, Florida , and Jennie V. Fowler, 517 Ho ward Avenue,

Tallahassee, Florida. Both parcels are on the eastern edge of

the District 's property and are accessed by way of the old

Southwood Plantation Road. When the Petition was filed, The St.

Joe Company was named as the owner of the property. Pe tition

Exhibit 3 is the Consent and Joinder of Landowner to

Establishment of a Community Development District executed by

the owner.

3. The Petition indicates that the five persons designated

to serve as initial members of the Board of Supervisors are Cla y

Smallwood, Chris Gent, Shaw Flippen, Sean Fennelly, and Pat

Groeniger, and that each member is a resident of the State of

Florida and a citizen of the United States.

4 . The estimated cost of the infrastructure facilities and

services which are presently expected to be provided to the

lands within the District was included in the Petition as filed

and as amended in the Response to the Commission’s Notice of

Insufficiency issued on February 15, 2007 .

5 . Petition Exhibit 6 describes the type of faciliti es

Petitioner expects the District to finance, construct, acquire,

and install, as well as the anticipated owner and entity

responsible for the operation and maintenance. Petition

Exhibit 7 identifies the estimated costs of constructing those

facilities as $45,750,000.00.

6 . Petition Exhibit 8 is the Statement of Estimated

Regulatory Costs (SERC), which indicates that it was prepared in

accordance with Section 120.541, Florida Statutes.

7 . Finally, Petition Exhibit 9 identifies Jonathan T.

Johnson, Es quire, and Brian A. Crumbaker, Esquire, as authorized

agents for Petitioner.

8 . The sole purpose of this proceeding was to consider the

establishment of the District as proposed by Petitioner.

Information relating to the managing and financing of the

ser vice - delivery function of the proposed District was also

considered. Because Section 190.005, Florida Statutes, contains

the statutory criteria to be considered, a summary of the

evidence relating to each enumerated section of the statute is

set forth in the following section of this Report.

SUMMARY OF EVIDENCE AND TESTIMONY

A. Whether all statements contained within the Petition

have been found to be true and correct.

9 . Petitioner's Hearing Composite Exh ibit 1 consists of

the Petition and its exhibits as filed with th e Commission.

Mr. Wier , who is a Vice - President with The St. Joe Company,

testified that he had reviewed the contents of the Petition . He

noted several changes or corrections to the Petition in his

testimony. Specifically, Mr. Wier sta ted that p aragraph 8 of

the Petition should be amended, as provided in Exhibit A to his

written testimony, to provide additional information regarding

the operation and maintenance responsibility between the

District and the City for relevant stormwater fa cilities within

the propo sed District. Mr. Wier also testified that Petition

Exhibit 3 would be supplemented with additional consents of

parties that have become landowners within the proposed boundary

of the District since the Petition was filed. Supple m ental

consents of Beazer Homes Corporation and Weekley Homes , LP, were

admitted into evidence as Hearing Exhibit 6. (The additional

consents are required because during the pendency of this

proceeding , parcels within the proposed District are being s old

to third parties. Therefore, as each parcel is sold, the

consent of the new owner is required.) The original consent of

Weekley Homes , LP, was not available at the time of the public

hearing and is therefore being transmitted with this Report.

Additiona lly, Mr. Wier stated that in response to the Notice of

Insufficiency, Petition Exhibit 4 was supplemented to provide

further description of the general distribution, location , and

extent of the public and private uses of land . In addition ,

Petition Exhibi t 7 was supplemented with a more detailed good

faith estimate of the order and seque nce of District

construction . Mr. Wier also generally described certain of the

exhibits to the Petition. Finally, Mr. Wier testified that the

Petition and its exhibits we re true and correct , as amended, to

the best of his knowledge.

10 . Mr. Greene , who is a professional engineer, testified

that he had assisted in the preparation of portions of the

Petition and its exhibits . Mr. Greene generally described the

services an d facilities that the proposed District is expected

to provide. He also generally described those Petition exhibits

that he had reviewed and described in his testimony the need for

certain amendments and revisions to the Petition and exhibits ,

all of whic h have been previously described above in Mr. Wier ' s

testimony. Finally, Mr. Greene testified that, with the

exception of the amendments to the Petition and its exhibits as

described , Petition Exhibits 1, 2, 4, 5, 6, and 7 were true and

correct to the bes t of his knowledge.

11 . Mr. Weyer , who is a financial advisor to the District,

testified that he had prepared the SERC, which has been received

in evidence as Petition Exhibit 8 . He added that the SERC was

true and correct to the best of his knowledge.

12 . The testimony is that the Petition and its exhibits as

amended and suppl e mented are true and correct.

B. Whether the establishment of the District is

inconsistent with any applicable element or portion of the State

Comprehensive Plan or of the effec tive local government

comprehensive plan.

13 . Mr. Gonzalez , a Vic e - Pr esident for The St. Joe

Company, reviewed the proposed District in light of the

requirements of the State Comprehensive Plan codified in

Section 187.201, Florida Statutes. He also re viewed the

proposed District in light of the requirements of the

Tallahassee - Leon County Comprehensive Plan.

1 4 . The State Comprehensive Plan " provides long - range

policy guidance for the orderly social, economic and physical

growth of the State " by way of twenty - five subjects and numerous

goals and policies. § 187.101, Fla. Stat. From a planning

perspective, the witness indicated that three subjects of the

State Comprehensive Plan apply directly to the establishment of

the proposed District as do the p olicies supporting those

subjects.

1 5 . First, Mr. Gonzalez cited Subject 15, Land Use, which

recognizes the importance of locating development in areas with

the fiscal ability and service capacity to accommodate growth.

§ 187.201(15), Fla. Stat. He tes tified that t he proposed

District will have the fiscal ability to provide services and

facilities and help provide infrastructure in a fiscally

responsible manner in an area which can accommodate development

within the City and County .

1 6 . Mr. Gonzalez a lso referred to P olicy 1 under Subject

15 , which promotes efficient development activities in areas

which will have the capacity to service new populations and

com merce. The witness testified that t he proposed District will

be a vehicle to provide high qu ality services in an efficient

and focused manner over the long term.

1 7 . Second, Mr. Gonzales cited Subject 17 of the State

Comprehensive Plan, Public Facilities, which promotes efficient

and orderly financing of new facilities . § 187.201(17), Fla.

St at. Especially relevant are Policy 3 of that Subject which

provides that the cost of new public facilities should be

allocated to existing and future residents on the basis of

benefits received and Policy 6 , which provides that fiscally

sound and cost - eff ective techniques for financing public

facilities should be encouraged. Mr. Gonzalez also testified

that the District will further these goals and related policies.

1 8 . Mr. Gonzalez testified that Subject 25 of the State

Comprehensive Plan , Plan Implem entation, should also be

considered. That Subject provides that systematic planning

shall be integrated into all levels of government, with emphasis

on intergovernmental coordination , should be considered .

§ 187.201(25), Fla. Stat. He indicated th at t he proposed

District is consistent with this element of the State

Comprehensive Plan because the proposed District will

systematically plan for the construction, operation , and

maintenance of the public improvements and the community

facilities authori zed under Chapter 190, Florida Statutes,

subject to and not inconsistent with the local government

comprehensive plan and land development regulations.

Additionally, the witness stated that the District meetings are

publicly advertised and are open to the public so that all

District property owners and residents can be involved in

planning for improvements.

1 9 . Mr. Gonzalez further opined that there are three

relevant policies under Subject 25 : Policies 2, 3 , and 6.

Policy 2 seeks to ensure operational authority in each level of

government for the implementation of the policy directives in

the State Comprehensive Plan . In conjunction with that Policy,

the witness pointed out that Chapter 190, Florida Statutes,

provides the proposed District with operat ional authority to

deliver basic community services and capital infrastructure.

According to Mr. Gonzalez, Policy 3 seeks to provide effective

monitoring, incentive, and enforcement capabilities to ensure

that regulatory programs are met, and under Sectio n 189.415(2),

Florida Statutes, the District will have to submit public

facilities reports to the local general - purpose government. He

further stated that Policy 6 encourages citizen participation in

all levels of policy development, planning , and operati ons, and

under Chapter 190, Florida Statutes, the District is required to

eventually transition to a resident elected Board of

Supervisors . The witness added that r egardless of the method of

election, the Board of Supervisors must convene meetings in

acco rdance with Florida ' s government - in - the - sunshine laws.

20 . Mr. Gonzalez also reviewed the proposed District in

light of the requirements of the Tallahassee - Leon County

Comprehensive Plan. Mr. Gonzalez testified that under

Chapter 190, Florida Statut es, the District is prohibited from

acting inconsistently with the loca l government comprehensive

plan. As to this requirement, the witness testified that the

establishment of the proposed District would not be inconsistent

with any applicable element or portion of the Tallahassee - Leon

County Comprehensive Plan.

2 1. Mr. Weir indicated that t he Department of Community

Affairs (DCA) reviewed the Petition for compliance with its

various programs and responsibilities. A ccording to Mr. Weir,

a fter conducting a review of the Petition, the DCA identified no

potential inconsistency between the Petition and Chapters 163

and 380, Florida Statutes, and found that the land uses and

infrastructure improvements proposed with in the District are

consistent with the Sout hWood DRI Development Order (DRI) .

22 . The testimony and exhibits indicate that the proposed

District will not be inconsistent with any applicable element or

portion of the State Comprehensive Plan or the Tallahassee - Leon

County Comprehensive Plan .

C. W hether the ar ea of land within the proposed D istrict

is of sufficient size, is sufficiently compact, and is

sufficiently contiguous to be developable as one functional

interrelated community.

23 . According to Mr. Weir, t he proposed District will

include approximately 1,035 acres located within the City and

unincorporated part of the County. As indicated in the

testimony of Mr. Weir, Mr. Greene, and Mr. Weyer, f rom economic,

engineering , and management perspectives, the area of land to be

included in the proposed District is of sufficient size, is

sufficiently compact, and is sufficiently contiguous to be

developed as a single functionally interrelated community.

2 4 . The testimony was that Petitioner has demonstrated

that the proposed District will be o f sufficient size, is

sufficiently compact, and is sufficiently contiguous to be

developed as a single functionally interrelated community.

D. Whether the proposed District is the best alternative

available for delivering community development services an d

facilities to the area that will be served by the proposed

District.

2 5 . Petitioner's Exhibit 6 indicates that The St. Joe

Company's present intention is for the District to construct or

provide certain infrastructure i mprovements as outlined in the

P e tition.

2 6 . In this respect, Mr. Wier testified that the

i nstallation and maintenance of infrastructure systems and

services by the proposed District is expected to be paid through

the imposition of special assessments. He added that the u se of

such asse ssments will ensure that the real property benefiting

from District services is the same property which pays for them.

2 7 . According to witnesses Perry and Wayer, t hree

alternatives to the use of the District exist. First, a local

general - purpose govern ment might provide facilities and services

from its general fund. Second, a developer might provide the

proposed improvements using private financing. Third,

facilities and services might be provided by some private means,

with maintenance delegated to a property owners' association or

a homeowners' association .

2 8 . Both witnesses testified that the District is

preferable to these alternatives at focusing attention on

providing the best long - term service to specific benefited

properties.

2 9 . The y add ed that the District will construct certain

infrastructure and community facilities which will be needed by

the property owners and residents of the project. Expenses for

the operations and maintenance of the facilities the District

retains are expected t o be paid through maintenance assessments

to ensure that the property receiving the benefit of the

district services is the same property paying for those

services.

30 . Mr. Perry and Mr. Weyer also testified that o nly a

community development district all ows for the independent

financing, administration, operations , and maintenance of the

land within such a district ; that only a community development

district allows district residents to ultimately completely

control the district ; and that the other altern atives do not

have these characteristics.

31 . Mr. Perry and Mr. Weyer further testified that the

proposed District is the best alternative to provide the

proposed community development services and facilities to the

land included in the proposed District because it is a long -

term, stable, perpetual entity capable of maintaining the

facilities over their expected life.

3 2. Additionally, Mr. Gonzalez testified that the boundary

of the proposed District is intended to track Phase II of the

DRI , so that th at the District will encompass those lands

subject to the new Phase II DRI infrastructure obligations

recently approved by the City .

33 . The testimony is that Petitioner has demonstrated that

the proposed District is the best alternative available for

d elivering community development services and facilities to the

area that will be served by the proposed District.

E. Whether the community develo pment services and

facilities of the proposed District will be incompatible with

the capacity and uses of exis ting local and regional community

development services and facilities.

3 4 . According to witnesses Gonzalez, Weyer, Greene, and

Perry, t he services and facilities proposed to be provided by

the District are not incompatible with uses and existing local

an d regional facilities and services ; the District's facilities

and services will not duplicate any existing regional services

or facilities ; and the proposed services or facilities to be

provided by the District are either not yet in existence or have

been provided in accordance with the development plan for the

area . Further, as noted above, the proposed District is

intended to track Phase II of the DRI and associated distinct

infrastructure obligations.

3 5 . The testimony is that the community developme nt

services and facilities of the proposed District will not be

incompatible with the capacity and uses of existing local and

regional community development services and facilities.

F. Whether the area that will be served by the District is

amenable to se parate special - district government.

3 6 . Witnesses Gonzalez, Perry, and Greene each indicated

that from economic, planning , engineering, and special district

management perspectives, the area of land to be included in the

proposed District is of sufficien t size, is sufficiently

compact, and is sufficiently contiguous to be developed and

become a functionally interrelated community. The y added that

the community to be included in the District has need for

certain basic infrastructure systems and the propos ed District

provides for an efficient mechanism to oversee the installation

of these improvements. Finally, as noted above , the District ' s

proposed establishment is intended in coordination with Phase II

of the DRI infrastructure obligations.

3 7 . The t estimony is that f rom management, engineering,

and planning perspectives, the area that will be served by the

District is amenable to separate special - district government.

G. Other Requirements Imposed by Statute or Rule

3 8 . Chapter 190, Florida Statut es, and Florida

Administrative Code Rule Chapter 42 - 1 impose specific

requirements regarding the petition and other information to be

submitted to the Commission.

a. Elements of the Petition

3 9 . The Commission has certified that the Petition meets

all of the requirements of Section 190.005(1)(a), Florida

Statutes.

b. State ment of the Estimated Regulatory Costs

40 . According to Mr. Weyer, the SERC contains an estimate

of the costs and benefits to all persons directly affected by

the proposed rule to est ablish the District -- the State of

Florida and its citizens, the City and County and their

citizens, Petitioner, and consumers.

41 . Petitioner's Exhibit 8 indicates that b eyond

administrative costs related to rule adoption, the State and its

citizens wi ll only incur minimal costs from establishing the

District ; that these costs are related to the incremental costs

to various agencies of reviewing one additional local government

report ; that the proposed District will require no subsidies

from the State ; and the b enefits will include improved planning

and coordination of development, which is difficult to quantify

but nonetheless substantia l.

42 . The same exhibit states that a dministrative costs

incurred by the City and County related to rule adoption wi ll be

modest and that these modest costs are offset by the $15,000 .00

filing fee required to accompany the Petition to both the City

and the County .

43 . Exhibit 8 further provides that c onsumers will pay

non - ad valorem or special assessments for certain facilities and

that l ocating within the District is voluntary. It goes on to

say that g enerally, District financing will be less expensive

than maintenance through a property owners' association or

capital improvements financed through developer loans. I t

further states that b enefits to consumers in the area within the

community development district will include a higher level of

public services and amenities than might otherwise be available,

completion of District - sponsored improvements to the area on a

timely basis, and a larger share of direct control over

community development services and facilities within the area.

4 4. Section 190.005(1)(a), Florida Statutes, requires the

petition to include a SERC which meets the requirements of

Section 120.541, Florida Statutes. As noted above, t he P etition

contains a SERC and appears to meet all requirements of that

statute.

c. Other Requirements

4 5 . According to Mr. Weir, Pe titioner has complied with

the provisions of Section 190.005(1)(b)1., Florida Sta tutes, in

that the City and County were provided copies of the Petition

and were paid the requisite filing fee.

4 6 . Section 190.005(1)(d), Florida Statutes, requires a

p etitioner to publish notice of the local public hearing in a

newspaper of general cir culation in the County for four

consecutive weeks prior to the hearing. The notice was

published in the Tallahassee Democrat , a newspaper of general

paid circulation in the County on May 9, 11 , 16, 23, and 30 ,

2007 . The May 11 publication was a re - public ation of the May 9

publication, which mistakenly appeared in the classifieds

section of the newspaper.

4 7 . No public comment was received during the hearing .

APPLICABLE LAW

4 8 . This proceeding is governed by Chapters 120 and 190 ,

Florida Statutes, and Florida Administrative Code Rule Chapter

42 - 1.

4 9 . Section 190.005(1), Florida Statutes, provides that

the exclusive method for establishing a community development

district with a size of 1,000 or more acres shall be by rule

adopted by the Commission.

50 . The evidence was that the proceeding was properly

noticed pursuant to Section 190.005 (1)(d) , Florida Statutes, by

publication of an advertisement in a newspaper of general paid

circulation in the County and of general interest and readership

once ea ch week for the four consecutive weeks immediately prior

to the hearing.

51 . The evidence was that Petitioner has met the

requirements of Section 190.005 (1)(b) , Florida Statutes,

regarding the submission of the Petition and satisfaction of

filing fee requ irements.

52 . Petitioner bears the burden of establishing that the

P etition meets the relevant statutory criteria set forth in

Section 190.005(1)(e), Florida Statutes.

53 . The evidence was that a ll portions of the Petition and

other submittals have been completed and filed as required by

law.

5 4. The evidence was that a ll statements contained within

the Petition as corrected and supplemented at the hearing are

true and correct. § 190.005(1)(e)1., Fla. Stat.

5 5. The evidence was that t he establishment o f the

District is not inconsistent with any applicable element or

portion of the State Comprehensive Plan or the effective

Tallahassee - Leon County Comprehensive Plan. § 190.005(1)(e)2.,

Fla. Stat.

5 6 . The evidence was that the area of land within the

pro posed District is of sufficient size, is sufficiently

compact, and is sufficiently contiguous to be developable as one

functional interrelated community. § 190.005(1)(e)3., Fla.

Stat.

5 7 . The evidence was that the proposed District is the

best alternativ e available for delivering community development

services and facilities to the area that will be served by the

District. § 190.005(1)(e)4., Fla. Stat.

5 8 . The evidence was that the community de velopment

services and facilities of the proposed District w ill not be

incompatible with the capacity and uses of existing local and

regional community development services and facilities.

§ 190.005(1)(e)5., Fla. Stat.

5 9 . The evidence was that the area to be served by the

proposed District is amenable to separate special district

government. § 190.005(1)(e)6., Fla. Stat.

CONCLUSION

Section 190.005(1)(e), Florida Statutes, states that the

Commission "shall consider the entire record of the local

hearing, resolutions adopted by the local general - purpose

go vernments," and the factors listed in subparagraphs 1. through

6. of that statute. Based on the record evidence, the Petition

appears to meet all statutory requirements, and there appears to

be no reason not to grant the Petition to Establish the

Southeas tern Community Development District as requested by

Petitioner. For purposes of drafting a rule, a copy of the

metes and bounds description of the District is found in

Petition Exhibit 2 .

DONE AND ENTERED this 2nd day of July, 2007, in

Tallahassee, Leon C ounty, Florida.

S

DONALD R. ALEXANDER

Administrative Law Judge

Division of Administrative Hearings

The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399 - 3060

(850) 488 - 9675 SUNCOM 278 - 9675

Fax Filing (8 50) 921 - 6847

www.doah.state.fl.us

Filed with the Clerk of the

Division of Administrative Hearings

this 2nd day of July, 2007 .

ENDNOTE S

1/ All references are to the 2006 version of the Florida

Statutes.

2/ The County held its optional public hearing on April 10,

2007, and the City held its public hearing on May 23, 2007.

Both the City and the County supported the establishment of the

District and have adopted resolutions to that effect.

COPIES FURNISHED:

Jerry McDaniel, Secretary

Florida Land a nd Water

Adjudicatory Commission

The Capitol, Room 180 2

Tallahassee, Florida 32399 - 0001

Barbara Leighty, Clerk

Florida Land and Water

Adjudicatory Commission

Office of Policy and Budget

The Capitol, Room 1801

Tallahassee, Florida 32399 - 0001

Paul C. Huck, Jr., General Counsel

Office of the Governor

The Capitol, Room 209

Tallahassee, Florida 32399 - 0001

Michael C. Eckert, Esquire

Hopping Green & Sams

Post Office Box 6526

Tallahassee, Florida 32314 - 6526

Shaw P. Stiller, General Counsel

Department of Community Affairs

2555 Shumard Oak Boulevard

Tallahassee, Florida 32399 - 2100