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BCC Minutes 11/06/1991 S Naples, Florida, November 6, 1991 LET IT BE REMEMBERED, that the Board of County Commissioners in and for the County of Collier, and also acting as the Board of Zoning Appeals and as the governing board(s) of such special districts as have been created according to law and having conducted business herein, met on this date at 5:05 P.M. in SPECIAL SESSION in Building "F" of the Government Comple~K, East Naples, Florida, with the following members present: CHAIRMAN: VICE-CHAIRMAN: (Arriv,.~d at 5:11 P.M.) PatriCia Anne Goodnight Michael J. Volpe R~lchard S. Shanahan Max A. Hasse. Jr. Butt L. Saunders ALSO PRESENT: Debby Famris and Wanda Arri~]hi, Deputy Clerks; Jennifer Pike and Tom Olliff, Assistants to the County Manager; David ${eigel, Assistant County Attorney; Bob Blanchard, Growth Planning Director; Will~am D. Lorenz, Jr., Environmental Services Administrator; George Yilmaz, Pollution Control Director; Sue Filson, Administrative Assistant to t~he Board; and Byron Tomlinson, Sheriff's Office. Page November 6, 1991 Tq~e #1 0RDIF. UI~ 91-103 RE THE COLLIER COUNTY GRO~ATER PROTECTION Legal notice having been published in the Naples Daily News on October 31, 1991, as evtdenc,~d by Affidavit of Publication filed with the Clerk, public hearing wa~ continued from October 23, 1991, to con- s~der adoption of Collier County's Groundwater Protection Ordinance. Environmental Seevices Administrator Lorenz explained that tonight is the second public hearing to be held as a requirement of the Land 0evelopment Regulation through the Growth Management Act. Referring to page 1 of a memorandum dated November 1, 1991, with a tltle page labelled "Issue Papers Relating to Questions Raised at Board of County ,:ommtsstoners' Public Workshop" (Copy not provided for the record), he stated same contains dtscuss~.on with regard to a need for the regula- tion. Regarding hazardous products and hazardous waste, he reported that DER (Department of Environmental Regulation) performed inspec- tions on at least 52 facilities, 22~ of which have documented a release of hazardous products or hazardous waste. He confirmed that. the Groundwater Protection Ordinance does address wastewater treatment plants, and directed attention to page 2 which reveals a t')ta] of 466 microbiological violations documented by the Environmental Services Department from July of 1986 through December of 1990. He commented that staff is attempting to develop appropriate and reasonable cri- teria to minimize sanitary hazards. He revealed there have been 48 Instances of either petroleum discharge, hazardous product discharge, or problems with discharge from wastewater treatment facilities in the past six months, inspected by staff, and which are documented on pages 2 through the top of page 5. He reflected that page 5 also contains a llst of the top ten problem sites of petroleum storage tank discharges. He identified #3 as a fuel spill at a gas station in Immokalee caused by delivery ~f fuel to an already full fuel tank. He reported Collier County has two contracts with the State, one for inspection of factllties and the other for a $1,000,000 cleanup Page 2 November 6, 1991 program aimed at priority sites. Referring to an aerial map of the Immokalee area, Mr. Lorenz iden- tified the wellfield protection zones as well as the facilities which have leaks. He confirmed th~re are a number of sites with petroleum contamination, either in the soil or the groundwater. Referring to page ? of the Issue Papers, Mr. Lorenz explained that the Marco Island Utilities' pit water supply at the intersection of U.S. 41 and S.R. 951 was not incorporated into the Groundwater Protection Ordinance as same deals with sensitive areas in regard to wellfields. He added, however, that staff recommends a system be developed to protect that particular water supply source with regard to risk management zones set up similar to the Groundwater Protection Ordinance. He estimated it ~ill take between 10-12 months for the existing staff to perform that modeling effort, validate same and return to the Board of County Commissioners with the necessary map and documents. Mr. Lorenz confirmed that the County is providing the Groundwater Protection Ordinance and applying it to public water supplies other than those owned by Collier County. Following discussion regarding the pros and cons of including the hereinabove mentioned Marco Island open pit water supply in the Groundwater Protection Ordinance, Commissioner Shanahan concluded there is no value in doing so at this point. In response to Commissioner Volpe, Assistant County Attorney ~eigel explained that the Grcundwater Protection Ordinance is an attempt to provide an Ordinance required by the State to protect well fields, and the open pit water supply does not fall under the defini- tion of wellfields, but added it might be prudent to follow up with a modeling that would lend itself to regulation through an Ordinance that would be compatible with the same goals of the Wellfield Protec- tion Ordinance. Referring to issue paper 3 on page 8, Mr. Lorenz stated this addresses the issue of whether existing facilities should be required Page 3 November 6, ~9gl to meet criteria for future facilities in terms of retrofitting. He remarked that an issue for =he Board of County Commissioners is to determine, as a matter of policy, the cost to retrofit certain facili- ties already in existence and whether concentration should be given to complete retrofitting to future standards or some point in between. He reported that currently ~:here are no wastewater treatment facili- ties existing in Zo~;e 1 and, therefore, no additional cost associated with retrofitting in terms ¢,f that facility. He requested deletion of the reference to residual sludge disposal sites. Under well construc- tion, he stated it is recommended that future wells be 4" wells. Regarding existing use in handling storage transport processing of hazardous products and hazardous waste, he explained the future stan- dards for these facilities include secondary containment. He ela- borated that for exAst~ng fa=il~ties staff is not recommending secondary containment but rather an alternative requirement. He reflected that the state has preempted local governments from adopting regulations addressing petroleum storage tanks and, therefore, staff's recommendation of an overlay zoning district prohibiting such facilf- ties within Zone 2 should be completely stricken from this Ordinance, as such"inclusion will subject the County to challenge and approval by the State of the total Groundwater Protection Ordinance. He added that the State does allow adc.ption of an Ordinance adopting the State's regulations by going through the administrative process and procedures for adoption of same. Assistant County Attorney Weigel AnterJected that there had been a difference of opinion as to what this proposed Ordinance purports to do in providing regulation as opposed to implementing standards affecting petroleum tanks themasia,es. He remarked it appears there ~s a potential that the Ordinance might be construed as entering into that area of preemption by DER which could subject the County to challenge. He added that the County, under State Statute and DER Regulations, is afforded the opportunity to provide for what is called "additional and more stringent requirements" than DER has, but which Page 4 November 6, 1991 staff and the County Attorney's Office believe are not protective and stringent enough for the purpose,3 of Collier County's wellfield pro- tection. He elaborated that the Ordinance is, in effect, not finally approved and, therefore, enforceable. In answer to Commissioner Volpe, Mr. Lorenz stated that, under the County's contract with DER, the County provides the inspections and documents the viola~'ions whinh in turn are provided to DER, which ren- ders a decision as to what extent they want to pursue the enforcement case. ~e related it is the ~:ounty's desire to have the ability to enforce the regulations under County authority in instances where it ~s felt the State is not moving fast enough. In reply to Commissioner Shanahan, Mr. Lorenz reported that there are no wastewater treatment facilities in Zone 1; that sludge disposal is an academic point; that well construction is out in zones ~ through 4; regarding existing storage transportation processing of hazardous products, that there is some retrofitting possibilities in this area; and that the petrcleum storage is out of the Ordinance and will be addressed as a separate entity. In reply to Commissioner Volpe, Mr. Lorenz stated that staff requests the fire plan approved by the local district be provided to the Gounty as part of the Certificate to Operate, adding that the containment standards are designed for protecting groundwater from sp~11s. Referring to page l0 of the Issue Paper, Mr. Lorenz stated that, although it is recommended the Port of the Islands wellfield not be included as part of the protected wellfield, it Is recommended that The Glades and Pelican Bay wellfields be included for protection under the Ordinance. In reply to Commissioner Volpe, Mr. Lorenz confirmed that there is s provision in the Ordinance addressln~ abandonment of a wellfield. In answer to Commissioner Shanahan, Mr. Lorenz stated that as new wells come on line, the Board of County Commissioners will need to adopt maps listing the new protected wellfield. OO0 . O6 Page 5 November 6, 1991 In response to Commissioner Hasse, Mr. Lorenz confirmed that when a water supply As designated as a future potable supply wellfield, then staff specifies the zones around said wellfield. Referring to Issue Paper #5 on page 12, Mr. Lorenz recommended that staff review these zone~ at least annually. He acknowledged that Issue #6 on page 14 deals with sewage treatment plants and septic tank systems. He stated the current Ordinance recommends that future sewage treatment plants should not be sited in :~one 1. In response to Mr. Loren:~, Assistant County Attorney Weigel explained the Ordinance may provide that a Conditional Use Permit is an option in circumstance:~ where there is a need for some kind of treatment to occur in the zone, with additional criteria beinG pro- vided for the unique and par~icular situations presented to the Board of County Commissioners. In response to Commissioner Volpe, Mr. Lorenz stated that the wastewater facility itself i~ the problem, i.e. when the raw sewage comes into the plant there could be spills, etc. He reiterated staff's recommendation that ~ihe wastewater treatment facility itself should not be sited in zone ~. Referring to pag'e 15, Mr. Lorenz stated there are different a~,pltcation rates of effluent to the land surface. In response to Commissioner Hasse's inquiry regarding single family homes with a septic tank and well, Mr. Lorenz stated that if the residence is meetin~ Health Department standards, staff considers that sufficient. In response to Commissioner Volpe, Mr. Lorenz stated septic systems are permitted for single family residences in zone 1. In reply to Commissioner :~hanahan, Mr. Lorenz stated that industrial waste facilJties not havinG toxic limits placed upon them with regard to their effluent limits are allowed to discharge, even in Zone l, as lonG as they meet ~he level of distnf~ctton standard. He added, however, that facillti,~s for which EPA ha~ ]dentif~ed toxic substances and promulgated effluent Guidelines for addressinG same are Pa!~e 6 November 6, ]991 prohibited from discharginG throughout Zones 1, 2 and 3. He pointed out there are no existing industrial facilities. Regarding septic tanks in the Goodlette-Frank Road area, Mr. Lorenz stated there seems only a few areas wher.e Zone 1 encroaches on that development. Mr. Lorenz acknowledged .a mailing list is maintained by both the County Manager's Office and ,~ounty Attorney's Office and includes those individuals expressing an interest in following tkis process. An unidentified individual distributed a handout at this time (copy not provided for the record). Assistant to the County lianaget Olltff stated that the special notices sent out based on the list maintained in the County Manager's Office Includes almost all of the major businesses, industries, and development interests in existence. He reported that Carl Loveday had a program on WNOG on the passage of the Ordinance and provided the date and time of the hearing. Referring to Issue Paper #8, Mr. Lorenz stated that, in striking out petroleum storage, the issue of fuel storage at the Immokalee air- port is not addressed. He stated that within Wellfield Zones 1, 2, and 3, future facilities storing greater than 250 gallons of hazardous p~oducts or hazardous waste m'ast still meet these requirements. Regarding the wastewater treatment plant, he stated that for facili- ties not located tn Zone 1, there will be no retrofit required and future expansion of effluent disposal is for sites outside this par- tlcular Zone. He explained there Is a problem w:[th future well sites. Referring to Item #3 on page 17, he re]ported that wells #203 and #204 are being requested for an am(~ndment of their Consumptive Use Permit and are being proposed to be Felocated closer to the wellfielJ existing at the airport. Ref~rring to Option 1 on page ]8, he explained this exists within the Ordinance itsell!. He stated that Option 2 grandfathers facilitles undergoing some type of permit pro- cess, and Option 3 provides guidelines to be considered Jn si~ing future protected water supply wells. He relayed staff's recommen- Pa.qe ? November 6, lggl datlon that Option #3 be applied. Assistant County Attorney Wetgel pointed out that a g~lideline cer- latnly is not a regulation rut merely a recommendation within the Ordinance. He explained that Option #1 and Option #2, in essence, protects the Interest of those property owners within the area. He stated that, with the situation of petroleum storage fact]itiei~, the County should be aware of the fact that creation or developmen~ of a future wellfield in an area already designated as an industrial or commercial area will certainly bring certain pressures to bear against the property owners of the area already in the process of deve].opinG their properties. Regarding the ~election of Option #1 or Option #2 as opposed to Option #3, he acknowledged there are benefits afforded property owners in the area by not having a wellfield come to them. He reported there is no liability problem in the Board's selection of one option over the other. Mr. Lorenz advised that the next Issue paper relates to the question of funding for the program. Grover Whidden, Area Manager for Florida Power & Light, proposed that the location of otl field tri~nsformers be exempt from re~ulation as doing so will have no impact to the protection of potable wells. In response to Commissioner Volpe, Mr. Lorenz confirmed sl:aff's recommendation that this be built in as an exemption. In reply to Commissioner Hasse, Mr. Whidden stated there haue been no failures of a transformer of any great magnitude in this county. In answer to Commissioner Vo]pe, Mr. Whidden confirmed there are certain state standards which EPA recommends in terms of dealing ~ainly with containment and cleanup, which his organization must comply with. Assistant County Attorney Wetgel reflected that the suggested change which Mr. Whtdden, on behalf of Florida Power & Light, has proposed appears on page 13 of the draft Ordinance, in Section 3.1.8, &nd is identified by dark highlighting. He stated the language, as it appears, mirrors exactly the language supplied to the County Page. 8 November 6, 11991 Attorney's Office in his let~.er of November 4, 1991. Mike Slayton of Big Cypr,.~ss Basin/South Florida Water Management District, regarding the Marc,) Island water supply source arid the oncoming source that is bein(j proposed for development, recommended that staff be given directloll to proceed with the modeling of the existing source and the future source. Secondly, regarding the requirement for ret~'ofitting existing nonconforming uses, he stated that past experience lndicat~.s it is cheaper to move the well in a conflicting situation than tc retrofit a gas station or other type of facility. He urged the Board of County Commissloners to consider, for metrofitting existing nonconforming uses or relocation of ~.'ells, some cost sharing mechanism. In answer to Commiss~oner Volp.-=, Mr. Lorenz reflected that staff %{ill be developing a map of high recharge areas within the County and ~lppl¥ing standards to those a~eas ~ithin the next ~2-18 months. Commissioner Shanahan asked th,.· Board of County Commissioners to consider directing staff to m,)del both the open pit on S.R. 951 and U.S. 41 and the one three and one-half miles eas-.. Mr. Slayton lnter3ected ti~at, unless the County has a finalized arrangement, it should protec-. that water source as is. Regarding the m~deling program, Commissioner Saunders suggested ~hat, as the program will provide -.;ome benefit to Southern States Utilities (SSU), staff should explore cost sharing with them. Commissioner Shanahan requested the Board of County Commissioners give consideration to his ear2.~er recommendation to include that staff: (a) proceed with the modeling, and, (b) approach SSU regardinG participation in the modeling, if not total/y, then at least 50%. Following further discussion, ]t was the consensus of the Board of County Commissioners that staff should approach SSU regarding cost sharing of the modeling fees. In response to Commissioner Sha.nahan, Mr. Slayton explained that III lo Page 9 November 6, 1991 his suggestion regarding nonconforming uses which do not meet the standard that the new use has, ll~ that Board of County Commissioners either require retrofitting ~f that facility through a cost sharing agreement or work with the utility to ]'elocate the well, aga'[n thrcugh a cost sharing agreement. **= At this time Deputy Cleric &rrtght l'eplaced Deputy Clerk Ferris Brian MacKenzie, represe;ating Collier Resoum. ce Company, ~'eferred to pages 27 and 28 of the proposed ordinance, and asked for clarifica- tion of whether the intent of the exploration facility is exploration well drilling? Mr. Lorenz explained that the intent is for both well drilling exploration and production. In response to Mr. MacKenzie, Mr. Lorenz advised if a wellfield is modified, whether by putting in a new well or by changing the con- ftguration of the Zones, new facilities that were previously outside the Wellfield Management Zones at,: now within, and will haue to meet the standards of the ordinance. Mr. MacKenzie indicated ¢oncel.~n with a possible future scenaz'io such as the County making a new wellfield and only leasing the piece of land upon which the facilities are built. He asked what would', be the implication to all those peop].e who may have somethinG planned for land that may be in or near a W-l, W-2 or W-3 wellfield zone? He said in his opinion, if the County determines to make another wellfield, thought should be given to leasin? the entire area. Com~tsetomsr Volpe moved, secc,nded by Cornels:stoner ShaI~ahaun to mlo~e the public hearing. Assistant County Attorney Wetgel informed that a letrex' was ~ecl:tved on November §th by t[%e Growth Managemen': Department from Attorney Pamela Garyin, on behalf of Peninsula Improvement ,~ort)oration, requesting that ':he letter be read at the public hearing. lie t~uggested in lieu of reading the letter, that it be ~ntered into 'the record. Upon c&11 for the question, th,m motion carried unantmou~ly. Page 10 November 6, 1991 Commissioner Saunders a:~ked if there is an environmental reason for the wellfield protection zones to be evaluated on a y¢:arly basis, rather than every five Mr. Lorenz stated the foundation of the ordinance is placed on risk management. He said too great not to have some standa=ds placed upon it. He ]nd].cated with an evaluation ~very five yea~s, a higher degree ~isk would have to be accepted. Commissioner Saunders asked if the real issue with wastewater t~ansmiss~on facilities is infiltration of water into those facilities as opposed to the facilities themselves ]eaklng? He said argument has been made that those facilities should not be covered to the extent they are ~n the ordinance. ~e asked for the opinion of Mr. Lorenz on that issue. MF. Lorenz reported when the ground water table is higher than the sewer line, there will be infiltration. However, he said, with a force main condition or where the ground water table elevation is ]ess than the system, leakage out of the system will occur. He agreed that many of the systems in Collier County will be below the water table during a portion of the yea~, however, there is a sufficient number of systems that cause concern with exflltration. He indicated Staff is recommending a ~easonable approach to provide for semi-annual inspec- tions for facilities within Zone 1. In answer to Commissioner Shanahah, Mr. Lorenz indicated Staff has not yet p~epared a fee schedule resolution. He referred to the Fiscal Impact section of the Executive Summary, advising that Staff is recom- mending Plan B, which would result in a fee schedule that 92% of the program would be fee based. He e~:platned the total cost of that ~mplementation plan ~s $145,661, of which $~2,253 will be subsidized out of Pollution Control Department funds. He said Staff will return to the Board with a fee schedule resolution at a later date. Responding to Commissioner Shanahan~ Mr. Lorenz stated 2 .44 addi- Tional positions will be required with the ~mplementation of this Page November 6, 1991 ordinance. He pointed out the ordinance provides the intent that its implementation should be mainly based on fees. In response to Commissioner Volpe, Mr. Lorenz advised that total implementation of the program will require more than 2.44 positions, however, existing personnel will be allocated from current services. George Yilmaz, Pollution Control Director, advised the Board that he has reprioritized extstin~ programs to reallocate approximately 1,OO0 Staff hours to assist in the implementation of parts of the new program. Commissioner Volpe pointed out that changes have been made to the ordinance since the human resources recruiting strategy was developed, i.e., the underground storage facilities aspect has been removed, which apparently was a significant problem. As a result of ~hat change in the ordinance, the fact that there are no recharge areas and some other changes, he asked if existing personnel can be utilized until additional responsibilities are taken on? Mr. Yilmaz pointed out that ~here were no man year allocations for the storage tanks, because that was proposed as a land use decision, and there were no inspectton:~ associated with those facilities. Commissioner Volpe asked if the additional personnel will be doing some of the modeling with re:~pect to the Marco Island facility7 Mr. Yilmaz noted ~n terms of modeling, Coll~[er County has received a 3oint award from EPA and DiOR of $60,000, with $10,000 ~[n matching funds. He said the intent of the award is to a~[low Collier County to work on its high recharge areas. He stated when the award is fina- llzed in the form of a contract, he will request from the Board addi- tional resources which will be paid by those additional funds. Assistant ~ounty Attorne%~ Weigel recalled p~.ev~ous discussion regarding a possible change i[n the ordinance, with the exact language to be provided by Mr. Lorenz or the legal consultant hired by the Gounty to assist in drafting the ordinance. Barbara Levitt, with the law firm of de la Parte and Gilbert, recommended that Sections 4.~.4.3 and 4.3.4.~.2 be combined to allow Novemb,mr 6, 1991 the location of future lndu~trlal wastewater treatment plants subject to pre-treatment standards or effluent limits for Toxic Pollutants subject to a CTO. She said they would be allowed in all Zones, County-wide. She clarified that currently there is a prohibition on the location of these parti(:ular types of facilities in Zone~ 1 and 2. She also recommended for clarification purposes; that Section 11.2.1 be amended to read, "Fixture prc~tected wells and well fields should not be located in any area designated b%, the Future Land Use Map of the Collier County Comprehensive Plan for industrial use." She explained that will restrict siting wells Jn areas known to have hazardous waste or hazardous products. Co~teoloaer Saunders a¢~ed, seconded by Co~tsstoner Shamahan, to approve OptIoa No. 3 and a]ae~d the language of the ordinance as Indicated &bo~e. Co~tmtsstoner Volpe asked what direction is Staff being given with regard to Implementation of the ordinance? Commissioner Saunders commented he intentionally cmit~ed that Issue because in his opinion, there will be lengthy discussion at a future meeting concerning the fee schedule and additional personnel Staff feels t~ necessary. ~p~n call for the question, the ~otlon carried umamisouely, that the Ordinamce as n~red ~d titled bel~ be adopted ~d entered Into Ordi~c,~ ~ok No. ~0: Oi~DINANCE 91-103 ORDINANCE OF THE BOARD OF COUNTY COMMISSIONERS OF COLLIE~ COUNTY, FLORIDA, PROVIDING FOR PROTECTION OF EXISTING AND FUTURE WELLFIELDS AND PROTECTIO~g OF EXISTING AND FUTURE GROUND WATER RESOURCES THROUGH CREATION OF WELLFIELD RISK MANAGEMENT SPECIAL TREATMENT OVERLAY ZONES WITHIN WHICH SPECIFIC DEVELOPMENT WILL BE PROHIBITED OR REGULATED; PROVIDING FOR CREAUION OF GROUND WATER PROTECTION ZONE; PROVIDING FOR INCLUSION IN LAND DEVELOPMENT CODE AND ZONING ATLAS; PROVIDi[NG TITLE AND CITAT]'ON, LEGISLATIVE AUTHORITY AND FINDS OF F~CT; PROVIDING FOR APPLICABILITY; PROVIDING TECHNICAL FIND]'NGS OF FACT; PROVIDING IDENTIFICATION OF PROTECTED PUBLIC WATER SUPPLY WELLFIELDS; P~OVIDING FOR CREATING, MAPPING, DESCRIPTION AND BASIS OF WELLFIELD RISK MANAGEMENT SPECIAL TREATMENT OVERLAY ZONES; PROVIDING FOR REGULATE[) DEVELOPMENT INCLUDING STANDARDS FOR EXISTING AND FUTURE OPERATION, FACILITIES AND LAND USES; PROVIDING FOR WELLFIELD EXEMPTIONS FROM COMPLIANCE WITH IDENTIFIED PROHIBITION OR REGULATION; PROVIDING FOR WELLFIELD CONDITIONAL USES; PROVIDING FOR APPROVAL OF REGULATED DEVELOPMENT AND CERTIFICATES TO OPERATE AND PROHIBITED APPROVALS OF REGULATED DEVELOPMENT ~ND CERTIFICATES TO OPERATE; November 6, 1991 PROVIDING MINIMUM STANDARDS FOR GROUND WATER QUALITY; PROVIDING FOR MODIFICATION OF REGULATED DEVELOPMENT, REVISION OR REVOCATION OF CERTIFICATE TO OPERAT]{, WELLFIELD CONDITIONAL USE PfRMIT, OR WELLFIELD EXEMPTION; PROVIDING FOR RESTRICTIONS ON ISSUANCE OF APPROVED SITE PLANS AND CERTIFICATES OF OCCUPANCY; PROVIDING FOR PUBLIC HEARINGS AND APPEALS; PROVIDING FOR FUTURE ;JELLS AND WELLFIELDS; PROVIDING FOR ADMINISTRATIVE FEES AND SURCHARGE; PROVIDING FOR ADMINISTRATIVE PROCEDURES/PROMULGATION; PROVIDING FOR VIOLATIONS, PENALTIE:i AND REMEDIES/ENFOHCEMENT; PROVIDING FOR NOTICES; PROVIDING DEFINZTIONS AND RULES OF CONSTRUCTION; PROVrDING FOR LIBERAL COIlSTRUCTION; PROVIDIMG FOR CONFLICT AND SEVERABILITY; AND PROVIDING AN EFFECTIVE DATE. There being no further business for the Good[ of the County, the meeting was adjourned by Order of the Chair - Time: 7:20 P.M. BOARD OF COUNTY COMMISSIONERS BOARD OF ZONING APPEALS/EX OFFICIO GOVERNING BOARD(S) OF SPECIAL DISTRICTS UNDER ITS CONTROL as presented X or as corrected D/'~'~--' ,/~ /~'?~.,..-J 3/3/92 PATRICIA ANNE GOODNIGHT,(~HAIRMAN March 3, 1~2 El 000,,..., 15 PaGe 14