07-001414 In Re: Petition To Contract The Capital Region 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 TO CONTRACT )

THE CAPITAL REGION COMMUNITY ) Case No. 07 - 1414

DEVELOPMENT DISTRICT )

________________________________ )

ADMINISTRATIVE LAW JUDGE'S REPORT TO THE

FLOR IDA LAND AND WATER ADJUDICATORY COMMISSION

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

matter in Tallahassee, Florida, on June 5, 2007, by Donald R.

Alexander, a n Administrative Law Judge of the Division of

Administrative Hearings.

APPEA RANCES

For Petitioner: Jonathan T. Johnson, Esq uire

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 ISS UE

The issue is whether the Petition to Contract the Boundary

of the Capital Region Community Development District (Petition)

meets the applicable criteria set forth in Chapter 190, Florida

Statu tes (2006) 1 , and Florida Administrative Code Rule Chapter

42 - 1 . The purpose of the hearing was to gather information in

anticipation of quasi - legislative rulemaking by the Florida Land

and Water Adjudicatory Commission (Commission).

PRELIMINARY STATEMEN T

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

its Petition with the Commission. Prior to th at time, a copy of

the Petition and its attachments, along with the requisite

filing fee, were provided to the City of Tallahassee (City) and

Leon C ounty (County) , where the existing District lies . The

County held its optional public hearing on April 10, 2007, and

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

the County and the City supported the proposed contraction of

the existin g District and have adopted resolutions to that

effect.

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 public hearing required under

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

The land to be included within the proposed District is

located entirely within the incorporated limits of the City and

unincorporated Leon County.

Petitioner published noti ce of the local public hearing in

accordance with Section 190.005(1)(d), Florida Statutes. The

proofs of publication were received into evidence as Exhibit 2.

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

Tallahassee, Florida. At the local publ ic hearing, Petitioner

presented the testimony of Jorge Gonzalez, its Vice - President

and Chairman of the District ' s Board of Supervisors and accepted

as an expert in land use planning ; James A. Perry, Managing

Director of Governmental Management Services, LLC, and accepted

as an expert ; G. Russell Weyer, Senior Associate at Fishkind and

Associates and accepted as an expert ; and Fred A. Greene, a

professional engineer with CH2M Hill and accepted as an expert.

No members of the public appeared at the hearing . Also,

Petitioner offered Exhibits 1 through 7, which were received

into evidence . Composite Exhibit 1 is the Petition and attached

exhibits; Exhibit 2 is the notice of affidavit of publication;

Exhibit 3 is City of Tallahassee Resolution No. 07 - R - 27

su pporting the contraction of the District; Exhibit 4 is Leon

County Resolution No. R07 - 08 supporting the contraction of the

District; Exhibit 5 is the pre - filed testimony of the four

witnesses; Exhibit 6 is the supplemental consents for property

sold after the filing of the Petition; and Exhibit 7 is the

resume of Jorge Gonzalez.

The T ranscript of the loca l public hearing was filed on

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

Report of Findings and Conclusions , which has been considered in

the preparation of this Report.

SUMMARY OF THE RECORD

1. Petitioner is seeking the adoption of an amendment to

Florida Administrative Code Rule 42CC - 1 .002 to remove

approximately 1,081.55 acres from the District, as described in

the Petition. (The rule establishing the existing District

became effective February 28, 2000.) If the Petition is

granted, the District's size will be reduced from 3,286.94 acres

to 2,205.39 acres. (The area to be removed will be used to

establish the Southeastern Communi ty Development District, a

separate matter now pending in DOAH Case No. 07 - 1413.)

Generally, t he District , as amended, l ies south of Apalachee

Parkway, north of Tram Road, and east of Capital Circle

Southeast. However, parts of the District will still ex tend

south of Tram Road and across Capital Circle Southeast to the

west. The contracted District's northern boundary will adjoin

the southern boundary of the new Southeastern Community

Development District . Petition Exhibit 1 is a map reflecting

the proj ect location and the area to be removed from the

existing District. Petition Exhibit 2 reflects the current

metes and bounds description of the District, Petition Exhibit 3

reflects the metes and bounds of the land to be subtracted from

the District , and Petition Exhibit 4 reflects the metes and

bounds of the proposed District after contraction .

2. There are two parcels of land within the external

boundaries of the proposed District that are to be excluded from

the District, both of which are owned by the Board of Trustees

of the Internal Improvement Trust Fund. When the Petition was

filed, The St. Joe Company was identified as owner of the

property. Petition Exhibit 5 is the owner's Declaration of

Consent to Jurisdiction of Community Development Distric t and to

Imposition of Special Assessments.

3. The estimated cost of the infrastructure facilities and

services which are presently expected to be provided to the

lands within the District is included in the Petition.

According to Petition Exhibit 9, thi s amount totals

$69,350,000.00.

4. The Petition indicates that the five persons currently

serving the District as members of the Board of Directors are

Sean Fennelly, Jorge Gonzalez, Pat Groeniger, Alan Hanstein, and

Mary Lee Kiracofe, who are all residen ts of the State and

citizens of the United States.

5. Petition Exhibit 6 reflects the existing general

distribution, location, and extent of public and private uses

for the proposed area to be excluded from the District by the

Future Land Use plan element of the Tallahassee - Leon County

Comprehensive Plan.

6. Petition Exhibit 7 depicts the existing drainage

patterns, major trunk water mains, sewer interceptors, and

outfalls within the District's current boundaries and within the

lands to be removed.

7. Petition Exhibit 8 identifies the facilities

anticipated to be financed, constructed, acquired, or installed

by the District within the boundaries of the proposed contracted

District, while Petition Exhibit 9 provides the estimated cost

of these facilities .

8. Petition Exhibit 10 is the Statement of Estimated

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

accordance with the requirements of Section 120.541, Florida

Statutes.

9. Finally, the Petition states that the authorized agents

are Brian A. Crumbaker, Esquire, and Joseph A. Brown, Esquire.

10. The sole purpose of this proceeding was to consider

the contraction of the District boundary as proposed by the

Petitioner. Information relating to the managing and financing

of the service - d elivery function of the proposed contracted

District was also considered. Because Section s 190.046 and

190.005, Florida Statutes, provide 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 R eport .

S UMMARY OF EVIDENCE AND TESTIMONY

A. Whether all statements contained within the Petition

have been found to be true and correct.

11. Hearing E xhibit 1 consists of the Petition and its

attachments as filed with the Commission. Mr. Gonzalez , who is

a Vice - President with The St. Joe Company, testified that he had

reviewed the contents of the Petition and approved its findings.

Mr. Gonzalez generally described the exhibits to the Petition.

12. Mr. Gonzalez also testified that the Petition as

originally submitted should be amended as follows: Paragraph 2

of the Petition should be amended to reflect the fact that no

impact is anticipated on the excluded parcels identified in the

Petition, as is provi ded in Exhibit B attached to Mr. Gonzalez '

pre - filed written testimony; Paragraph 4 of the Petition should

be amended to reflect that Corbett Drew is currently serving the

unexpired term of resigned Supervisor Pat Groeniger; and that

Paragraph 7 of the Pet ition should be amended with regard to

operation and maintenance responsibility between the District

and City for stormwater facilities as provided in Exhibit A

attached to his pre - filed written testimony.

13. Mr. Gonzalez further testified that the fo llowing

Petition E xhibits as originally submitted should be amended :

Petition Exhibit 5 should be supplemented with additional

consents of property owners within the contraction parcel

provided at the time of the hearing; Petition Exhibit 6 should

be supp lemented to provide a further description of the general

distribution, location , and extent of the public and private

uses of land ; and Petition Exhibit 9 should be supplemented to

reflect a more detailed good faith estimate of the order and

sequence of Di strict construction, both as provided in Exhibit B

attached to his written prefiled testimony. Supplemental

consents were received into evidence at the hearing as Hearing

Exhibit 6. The original consent of Weekly Homes , LP, was not

available at the time of the public hearing and is therefore

being transmitted with this Report.

14. Finally, Mr. Gonzalez further testified that the

Petition and all its exhibits, amended as stated, were true and

correct to the best of his knowledge.

15. Mr. Greene , who i s a professional engineer, testified

that he helped prepare the Petition a nd had reviewed its

exhibits. He generally described those Petition exhibits that

he had reviewed and described in his testimony the need for

certain amendments and revisions to the Petition, all of which

have been previously described above in Mr. Gonzalez ' testimony.

Finally, Mr. Greene testified that the Petition and its exhibits

were true and correct amended as stated.

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

testified that he had prepared the SERC in Petition Exhibit 8 .

Mr. Weyer also testified that S ERC as submitted in the Petition

was true and correct to the best of his knowledge.

17. The testimony is that t he Petition and its exhibits as

amended and s upplemented are true and correct.

B. Whether the contraction of the District boundary is

inconsistent with any applicable element or portion of the State

Comprehensive Plan or of the effective local government

comprehensive plan.

18. Mr. Gonzalez revi ewed the proposed District boundary

contraction in light of the requirements of the State

Comprehensive Plan codified in Chapter 187, Florida Statutes.

1 9 . The State Comprehensive Plan is designed to provide

" long - range policy guidance for the orderly s ocial, economic and

physical growth of the State . " § 187.101, Fla. Stat. It

contains twenty - five subjects, and numerous goals and policies,

of which Mr. Gonzalez identified Subject Nos. 15, 17, and 25 as

being particularly relevant.

20. Subject 15 of the State Comprehensive Plan, Land Use,

recognizes the importance of locating development in areas with

the fiscal ability and service capacity to accommodate growth.

§ 187.201(15), Fla. Stat. Mr. Gonzalez testified that the

contracted District will cont inue to have the fiscal ability to

provide services and facilities to a population in a designated

growth area.

21. Subject 17 of the State Comprehensive Plan, Public

Facilities, promotes the protection of existing public

facilities and the efficient and orderly financing of new

facilities. § 187.201(17), Fla. Stat. Mr. Gonzalez testified

that the amendment of the District boundary will not affect the

District ' s ability to continue providing for the orderly

planning and financing of infrastructure withi n the District.

22. Subject 25 of the State Comprehensive Plan, Plan

Implementation, provides that systematic planning shall be

integrated into all levels of government, with emphasis on

intergovernmental coordination and citizen involvement.

§ 187.201(25), Fla. Stat. Mr. Gonzalez testified that the

contracted District will continue to systematically plan for the

construction, operation , and maintenance of the public

improvements and community facilities authorized under

Chapter 190, Florida Statutes, subject to, and not inconsistent

with, the local government comprehensive plan and land

development regulations. He added that th e District meetings

will continue to be publicly advertised and are open to the

public so that all District property owners and residents can be

involved in planning for improvements.

23. Mr. Gonzalez also reviewed the proposed amended

District in light of the requirements of the Tallahassee - Leon

County Comprehensive Plan. He testified that the District as

amended wo uld not be inconsistent with any applicable element o r

portion of the Tallahassee - Leon County Comprehensive Plan. He

further testified that under Chapter 190, Florida Statutes, the

District is prohibited from acting inconsistently with the local

governmen t comprehensive plan and identified the F uture L and

U se, I ntergovernmental C oordination, and C apital I mprovement

E lements of the Tallahasse e - Leon County Comprehensive Plan as

being consistent with the proposed amended District.

24. According to Mr. Gonz alez, t he Department of Community

Affairs (DCA) reviewed the Petition for compliance with its

various programs and responsibilities. After conducting a

review of the Petition, the DCA identified no potential

inconsistency between the Petition and Florida ' s growth

management laws under Chapters 163 and 380, Florida Statutes,

and found that the land uses and infrastructure improvements

proposed within the proposed amended District are consistent

with the SouthWood DRI Development Order (DRI) . See Exhibit E

attached to the Gonzalez pre - filed testimony.

25. Based on the pre - filed testimony and exhibits in the

record, it appears that the proposed contracted District will

not be inconsistent with any applicable element or portion of

the State Comprehensive Plan .

26. B ased on the pre - filed testimony and evidence in the

record, it appears that the proposed contracted District will

not be inconsistent with any applicable element or portion of

the Tallahassee - Leon County Comprehensive Plan.

C. Whether the area of land within the proposed contracted

District is of sufficient size, is sufficiently compact, and is

sufficiently contiguous to be developable as one functional

interrelated community.

27. The Petition indicates that the contracted District

will include approximately 2,205.39 acres located within the

City and unincorporated part of the County. According to

witnesses Gonzalez, Perry, Weyer, and Greene, f rom engineering,

financial management , and land use planning perspectives the

proposed contracted Distr ict is of sufficient size, is

sufficiently compact, and is sufficiently contiguous to be

developed as a single functionally interrelated community.

28. B ased on the pre - filed testimony and evidence in the

record, it appears that Petitioner has demonstra ted that the

proposed District will be of sufficient size, is sufficiently

compact, and is sufficiently contiguous to be developed as a

single functionally interrelated community.

D. Whether the proposed District, contracted as proposed,

remains the best alternative available for delivering community

development services and facilities to the area that will be

served by the proposed District.

29. Hearing Exhibit 1 and Petition Exhibits 8 and 9

indicate that the District is currently providing certain

inf rastructure improvements and intends to construct or provide

additional infrastructure improvements all as outlined in the

Petition.

30. Mr. Perry and Mr. Weyer testified that following

contraction of its boundary, the proposed amended District

remains the best and most practical viable alternative to

provide the proposed improvements to accommodate the planned

development benefiting the lands to remain within the District.

31. Mr. Perry testified that the proposed amended District

would remain superi or to either a property owner ' s association

or the general purpose local government as a mechanism for

delivering community services and facilities to the area within

the proposed amended District. He also testified that the

District exceeds alternatives in the delivery of infrastructure

by focusing attention on when and where and how the next system

will be required. Also, a property owner ' s association could

not as effectively finance the infrastructure improvements

needed by the community, and provisio n of the infrastructure

improvements by the local general - purpose governments would

increase the demands upon, and require diversion of, local

general - purpose government resources. Mr. Perry testified that

only a community development district allows inde pendent

financing, administration, operations, and maintenance and

allows landowners to control the timing and extent of

infrastructure development.

32. Mr. Gonzalez went on to say that the proposed boundary

contraction was planned in conjunction with th e establishment of

a separate proposed Southeastern Community Development District

over substantially all of the contraction parcels. As explained

by the witness, the existing District is located within the DRI

and is subject to its terms and conditions. In approving Phase

2 of the DRI, the City and County "imposed additional

infrastructure obligations for Phase 2," and the Southeastern

Community Development District will be established and fulfill

those infrastructure obligations. Mr. Gonzalez also test ified

that the proposed contraction of the District ' s boundary will

not result in increased debt being imposed upon existing

homeowners residing within the contracted District boundary. He

added that a contraction parcel owned by the State of Florida in

t he southwestern portion of the District is being developed by

the State through a separate development entitlement process and

is not to be included within the proposed Southeastern Community

Development District.

33. The testimony is that Petitioner ha s demonstrated that

the proposed District remains the best alternative available for

delivering community development services and facilities to the

area that will be served by the proposed amended District.

E. Whether the community development services and

facilities of the proposed contracted District will be

incompatible with the capacity and uses of existing local and

regional community development services and facilities.

34 . Mr. Perry, Mr. Gonzalez , and Mr. Weyer testified that

the proposed bound ary contraction will have no e ffect on the

District 's ability to deliver community development services and

facilities and will not affect the current compatibility of

those services and facilities with existing local or regional

services or facilities. A lso, as noted in paragraph 32, the

proposed boundary contraction is planned in conjunction with the

establishment of a separate Southeastern Community Development

District . In this respect, Mr. Gonzalez testified that the

combined contraction/establishmen t tracks the separate Phase 1

and Phase 2 DRI requirements, thereby allowing Phase 2 DRI

obligations, particularly off - site transportation improvements,

to be coordinated by the proposed Southeastern Community

Development District established over the land s subject to the

Phase 2 DRI requirements.

35. The testimony is that the community development

services and facilities of the proposed contracted District will

not be incompatible with the capacity and uses of existing local

and regional community devel opment services and facilities.

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

amenable to separate special - district government.

36. As reported in paragraph 27, from engineering,

financial management , and land use planning perspectives, t he

area of land to remain in the District following contraction

will remain of sufficient size, compactness, and is sufficiently

contiguous to be a functionally interrelated community. Witness

Perry testified that once contracted the District will continu e

to successfully function as a separate special district

government. Also, Mr. Gonzalez testified that the boundary

amendment will have no e ffect on the District ' s operations and

functions and will not affect the prior determination of the

Commission tha t the District is amenable to separate special

district governance. Further, as noted above, Mr. Gonzalez

testified that a separate Southeastern Community Development

District is proposed to be established over substantially all of

the contraction parcels to effectively address the Phase 2 DRI

requirements tied to development within the contraction parcel.

37. The testimony is that Petitioner has demonstrated that

the area that will be served by the District is amenable to

separate special - district gov ernment.

G. Other requirements imposed by statute or rule

38. Chapter 190, Florida Statutes, 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

39. The Commission has certified that the Petition meets

all of the requirements of Section s 190.046(1)(g) and

190.005(1)(a), Florida Statutes.

b. Statement of Estimated Regulatory Costs

40. Both the Petition and the testimo ny of the witnesses

indicate that the SERC contains an estimate of the costs and

benefits to all persons directly affected by the proposed rule

to establish the District -- the State of Florida and its

citizens, the City of Tallahassee and Leon County and their

citizens, the Petitioner, and consumers.

41. Petition Exhibit 8 indicates that b eyond

administrative costs related to rule amendment, the State and

its citizens will only incur minimal costs from contracting the

District ' s boundary as proposed. T hese costs are related to the

incremental costs to various agencies of reviewing one

additional local government report, which are marginal. Also,

the District must pay an annual fee to the DCA to offset such

costs.

42. The same exhibit indicates that a dministrative costs

incurred by the City and County related to rule amendment will

be modest. Further, these modest costs are offset by the

$15,000 .00 filing fee that was required to accompany the

Petition to both the City and the County for this boundar y

amendment. Also, costs to the City and County will not change

from the pre - contraction costs incurred .

43. Petition Exhibit 8 further indicates that c onsumers

will pay non - ad valorem or special assessments for certain

facilities. Locating within the D istrict is voluntary.

Generally, District financing has been and will be less

expensive than maintenance through a property owners'

association or capital improvements financed through developer

loans. Benefits to consumers in the area within the Distric t

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 faci lities within the area.

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

petition to include a SERC which meets the requirements of

Section 120.541, Florida Statutes. The Petition contains a

SERC. According to Mr. Weyer, i t meet s all requirem ents of

Section 120.541, Florida Statutes.

c. Other Requirements

45. Mr. Gonzalez testified that P etitioner has complied

with the provisions of Section 190.005(1)(b)1., Florida

Statutes, in that the City and County were provided copies of

the Petition and were paid the requisite filing fee.

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

Petitioner to publish notice of the local public hearing in a

newspaper of general circulation in the County for four

consecutive weeks prior to the hearing. Hearing Exhibit 2

reflects that t he 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 - publication of the May 9 publication, which mis takenly

appeared in the classifieds section of the newspaper.

d. Public Comment During the Hearing

47. No public comment was received during the hearing.

APPLICABLE LAW

48. T his proceeding is governed by Chapters 1 20 and 190,

Florida Statutes, and Flo rida Administrative Code Rule Chapter

42 - 1.

49. Section 190.046(1), Florida Statutes, provides that an

existing district "may petition to contract or expand the

boundaries of a community development district in the . . .

manner" prescribed therein. Par agraph (g) of the same statute

provides that "[p]etitions to amend the boundaries of the

district which exceed the amount of land specified in paragraph

(f) [250 acres] shall be considered petitions to establish a new

district and shall follow all of the p rocedures specified in

s. 190.005." Because the amendment here exceeds the 250 - acre

statutory threshold, Petitioner must satisfy all procedures in

Section 190.005, Florida Statutes.

50. Petitioner bears the burden of establishing that the

P etition meet s the relevant statutory criteria set forth in

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

51. 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 each week for the four consecutive weeks immediately prior

to the hearing.

52. 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 requirements.

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

other submittals have been completed and filed as required by

law.

54. The evidence was that a ll st atements contained within

the Petition as corrected and supplemented at the hearing are

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

55. The evidence was that the establishment of 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.

56. The evidence was that the area of land within the

proposed contracted District remains of sufficient size, is

sufficiently co mpact, and is sufficiently contiguous to be

developable as one functional interrelated community.

§ 190.005(1)(e)3., Fla. Stat.

57. The evidence was that the proposed contracted District

remains the best alternative available for delivering comm unity

development services and facilities to the area that will be

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

58. The evidence was that the compatibility of facilities

of the proposed amended District with the capacity and uses of

existing loc al and regional community development services and

facilities will not be affected by the boundary contraction.

§ 190.005(1)(e)5., Fla. Stat.

59. The evidence was that the area to be served by the

proposed contracted District remains amenable to separa te

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

governm ents," and the factors listed in subparagraphs 1. through

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

Petition appears to meet all statutory requirements, and there

appears to be no reason not to grant the Petition to Contract

the Capita l Region Community Development District. For purposes

of amending Florida Administrative Code Rule 42CC - 1.002, a metes

and bounds description of the contracted District is found in

Petition Exhibit 4.

DONE AND ENTERED this 2nd day of Ju ly , 2007 , in

Talla hassee, Leon County, 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 - 967 5

Fax Filing (850) 921 - 6847

www.doah.state.fl.us

Filed with the Clerk of the

Division of Administrative Hearings

this 2nd day of Ju ly . 2007 .

ENDNOTE

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

Statutes.

COPIES FURNISHED :

Jerry McDaniel , Secretary

Florida Land and Water

Adjudicatory Commission

The Capitol, Room 1802

Tallahassee, Florida 32399 - 0001

Jonathan T. Johnson, Esquire

Hopping, Green & Sams, P.A.

Post Office Box 6526

Tallahassee, Florida 32314 - 6526

Barbara Leighty, Clerk

Flo rida Land and Water

Adjudicatory Commission

The Capitol, Room 180 1

Tallahassee, Florida 32399 - 0001

Paul C. Huck, Jr., General Counsel

Office of the Governor

The Capitol , Room 209

Tall ahassee, Florida 32399 - 0001

Shaw P. Stiller, General Counsel

Depart ment of Community Affairs

2555 Shumard Oak Boulevard

Tallahassee, Florida 32399 - 2100