Tuesday, March 30, 2010

2ND NOTICE - SIGN ON TO PROTECT FISHING AND SWIMMING WATERS IN FLORIDA

Dear Friends of Florida’s Waters –

Last week you should have received an urgent email from me with an attached comment letter regarding DEP’s plans to create a new “Designated Use” for Florida’s water quality standards which will be called Class III – Limited. What that means in reality is that these waters will be too polluted to swim in and will be barely able to support aquatic life. Right now, under Florida law, waters that are this polluted, go on the Impaired Waters List (required by the Clean Water Act) and are prioritized for pollution reductions. With the new Designated Use, Class III – Limited, these waters would be allowed to remain impaired indefinitely, and could continue to receive new and/or expanded discharges of pollution.
As we all know, all waters flow downstream and every stream, lake and canal in Florida will eventually end up in an estuary and then into either the Gulf or the Atlantic Ocean. The idea that some of our lakes, canals and even streams and rivers are not worthy of Clean Water Act protections is hard (if not impossible to swallow) for those of us who spend most of our time trying to protect these waters for everyone’s use and enjoyment. . . especially future generations.

So far 33 groups, businesses and organizations signed onto the attached letter to FDEP Secretary Mike Sole. The comment letter that we sent in December had more than 50 signatures. I would love to put at least 100 signatures on this letter. The more groups and businesses that sign on in support of our comments, the more impact we will have. We have made great progress so far in convincing FDEP to slow down their push to weaken our water quality standards. Now we want to stop this serious policy change entirely, but Clean Water Network of FL cannot do this without your help.

If your group or business is not one of the 33 that I heard from already, would you please take a few minutes to read over the attached letter and then if you agree with it, send me a quick email to let me know that I can add your organization or business to the list of supporters? Make sure to provide a contact person for the group.

If you have already signed on, I just want to thank you for everything you do for Florida’s waters and for better policies.

Everyone can also help by sending this to all of your contacts and ask them to keep it going. We need a wide variety of organizations, businesses, civic groups, etc. to add support to our efforts to keep our waters swimmable and fishable.

Thank you in advance for any help you can offer.

For all our waters,

Linda Young

Director

A project of the TIDES center


Post Office Box 254, Tallahassee, Florida 32302

Phone: 850-322-7978

llyoung2@earthlink.net

www.cleanwaternetwork-fl.org





March 24, 2010



Secretary Michael Sole

Florida Department of Environmental Protection

3900 Commonwealth Blvd.

Tallahassee, FL 32399-3000

Dear Secretary Sole:

Thank you for your reply to our December 11, 2009 letter regarding proposed revisions to the surface water quality classifications rule. While we are glad to see that you decided to keep the current classification structure and not create several new classifications of waters, your current plan will still not protect Florida’s waters for their highest and best uses. You characterized the new proposal for a Class III –Limited classification as an improvement over the former proposal, and we would like to respectfully disagree. Just on the surface, it is difficult to understand how waters that are not suitable for swimming would be appealing as a place from which to consume fish. We urge you to reconsider this approach, which will result in the downgrading of numerous Florida waters.

Mr. Secretary, over the past few months you have given several presentations across the state regarding the proposed numeric nutrient criteria that will soon be promulgated by the US EPA for the State of Florida. You have repeatedly used very strong words to criticize EPA’s proposed nutrient criteria, even though they are almost identical to those proposed by your own department. It is curious to hear your vehement objections to something so close to your own proposal. Your messages add to the confusion that many taxpayers in Florida currently feel as they try to make sense of the many changes that are being proposed for Florida’s water quality standards, for example:

• Proposed federal numeric nutrient criteria

• Proposed state numeric nutrient criteria

• Proposed new classifications/uses for Florida waters by the state

• Proposed new Site Specific Alternative Criteria (SSAC) conditions by the state

• Technical Support Document, which is almost 50 pages of fine print about how Use Attainability Analyses, Use downgrades and SSACs would be applied

• Impaired water lists and TMDLs

• BMAPs

The list goes on and on and it can be broken down within each of the above items. It may not seem like water-quality-change-overload to you and your colleagues, who change water quality protections for a living, but for the hardworking taxpayers who pay your salary and try to keep up with the changes that affect the waters in their communities, it is a lot of changes in a very short time. We would like to ask you again to stop your efforts to create a new unswimmable and barely fishable use for Florida waters. Not only is it bad policy, it is not timely, as the people of this state are struggling to understand the EPA’s nutrient criteria and what it will mean for their communities and their personal use of Florida’s waters, and how it will affect our waters for future generations. In fact, without knowing exactly what the final numeric nutrient criteria will be, it seems premature to be pushing the new unswimmable/barely fishable designated use through the legal process in Florida.

EPA’s proposed nutrient criteria describes the process of Use Designation and Use Attainability Analyses (UAA) in EPA’s existing regulations, but is far from explicit in its recommendations and possible rule language in three areas related to the use of UAAs to downgrade current use designations. In our comments on EPA’s proposed criteria, we will be asking EPA to place greater emphasis on the existing requirement to re-evaluate downgraded uses every three years. Is Florida ready to commit in writing to doing that for any and all waters that would potentially get downgraded to Class III-Limited? FDEP removed Section 3.6 from the prior draft entitled, Future Re-evaluation of Use Assignments, which emphasized that DEP is required to re-evaluate waterbody use designations resulting from UAAs during each future triennial review of its WQS if those revised uses do not meet the Section 101(a)(2) goals of the CWA (waterbodies with a use below the default uses of Class III). This section should be reincluded because of its importance in reminding applicants (and FDEP) that downgrades are not permanent and must be re-evaluated. In fact, this is required for any water body segment with water quality standards that do not include the uses specified in section 101(a)(2) of the Clean Water Act to determine if new information has become available making those uses attainable [40 C.F.R. Section 131.20(a)]. We will be urging EPA to bring attention to this requirement and to explain in detail how it should be carried out. It would make sense for Florida to wait until EPA does this before a state change to water classifications is finalized. Once the new Class III-Limited designated use is available to the hoards of big polluters who are supporting your plans to weaken our water quality standards, we can assume with confidence that your agency will be begin to receive high volumes of applications for SSACs, UAAs and reclassifications. That does not even account for the reclassifications and SSACs that DEP is likely to initiate. The work-load will be daunting, even for your dedicated staff who are always eager to find new ways to “manage” water quality challenges. For your taxpayers, who may want to have a voice in proposed downgrades to the waters they use, it will make effective participation even more arduous.

In addition, where removing or downgrading a use would have negative impacts on overall water quality goals, we will urge EPA to require Florida to gather the information needed to assess future attainability in order to trigger a thoughtful analysis under Section 131.20(a). Is this anticipated in your Technical Support Document? We urge the state to assure the citizens of Florida that this would be done for any water that is proposed for a downgrade. We also need to know in advance what the process to upgrade our waters will be. Does your department have this information for us yet?

Another concern we have with your proposed change to Florida’s water quality standards and the Technical Support Document is that there is nothing in either that would provide assurance to Floridians that existing uses will be protected. In fact, during a public hearing regarding the proposed revisions we asked Jerry Brooks, Director of DEP’s Division of Environmental Assessment and Restoration, whether a downgraded water body would remain on the Impaired Waters List and be ineligible for new and expanded discharges after the downgrade, and he said absolutely not. He told us the water body would come off of the 303(d) list and new and expanded discharges would be allowed a long as they did not cause or contribute to violations of the new SSAC. We strongly object to this policy. It will guarantee that the downgraded water will never regain its previous use (before being downgraded) and that it will continue to deteriorate.

You state in your letter to us that your amended proposed rule will protect existing water quality conditions. You assert that it prohibits the lowering of existing water quality within a Class III-Limited waterbody, through the limitations associated with Site Specific Alternative Criteria. It is not clear how an existing use would be protected when a water body is downgraded and the criteria are made less protective.

Not only does your proposal lack minimum criteria for Class III-Limited waters until a SSAC is approved for each individual waterbody, which violates the Clean Water Act at 33 U.S.C., Section 1313(c)(2)(A) , but nowhere in your proposal (rule or TSD) do you require detailed identifications of the uses that will be protected in downgraded waters. You are in essence asking the taxpayers to “trust” you or your successors to make good decisions about our waters as you downgrade their uses. You will essentially be allowed to set criteria at levels that will keep the waters off of the 303(d) list and which will allow discharges to continue unabated and new and expanded discharges to be permitted. That is too much to ask from us and we must insist that you abandon this plan. We believe that Florida DEP would be tempted to ignore the requirements in the Clean Water Act to protect existing uses in both the UAA and the antidegradation Tier I protections, thereby undermining the law and resulting in the continued decline of water quality in Florida.

One issue that is most troubling to us is an apparent contradiction in your responses regarding downstream waters protection. In a reply letter dated January 22, 2010 you state:

“Your letter was also insistent on downstream water protection, which we agree is critical. I want to emphasize that we have consistently maintained that downstream waters must be protected as part of any proposed reclassification. Both the previous rule draft and the proposed rule revisions reflect this downstream waters protection concern. The rules and draft support document, which will be incorporated into the rule by reference, clearly indicate that a waterbody cannot be reclassified to a lower use if this would lead to any loss of a downstream use.”

This morning, I received a copy of an email you sent to Dr. Ray McAllister in response to his concerns over the proposed unswimmable/barely fishable designated use. You wrote (in part):

“Our disagreement with EPA has been primarily associated with the “downstream protective values” proposed in their rule. While I support the intent of trying to establish numeric equivalents to protect downstream estuaries, the modeled approach that EPA has used is truly fundamentally flawed and inaccurate. Fortunately, EPA has agreed to not pursue this approach right now and work on this aspect of the Rule in future efforts.”

If the Department is committed to protecting downstream uses, why are you so opposed to EPA’s effort to do just that? You say that you don’t like their modeling approach, which is always an easy way to discredit someone else’s efforts. We would appreciate a more detailed explanation of exactly how you plan to protect downstream waters after upstream waters are allowed to become downgraded and more polluted. Jerry Brooks has stated in public workshops that you would be using mixing zones and other relief mechanisms in the downstream waters in order to comply with water quality standards. While these “tricks” may meet the letter of the law, they do not fulfill the spirit of the Clean Water Act and will not result in waters your taxpayers will feel safe swimming and fishing in.

Most important to our organization and our members is that all taxpayers have access to the process that could be used to adversely affect waters that all Floridians have a right to use and enjoy. You say in your January 22 letter that any applicant who petitions for a lower use classification will bear the burden of proof that the existing uses will not be removed and that the proposed use is the highest attainable use. We wish that we could rely on that and have assurance that this will be the case. Unfortunately, your Department has a long history of catering to polluters (i.e. Impaired Waters Rule, SSAC rule - type 2, and a long list of NPDES permits that are lax, don’t meet CWA requirements such as dioxin limits and are rarely if ever enforced) and it would be fool-hardy for anyone seeking greater protection for the health of the water and ordinary citizens to expect assistance from DEP. You offer comfort through the fact that a citizen can have input to the Florida Environmental Regulation Commission (ERC) and the US EPA. As for the ERC members, they are all representatives of big polluters and special interests in Florida and not one of them provides a voice for the ordinary taxpayer in the state. The US EPA has shown no interest in protecting Florida’s waters or standing up to you and your Department in at least 10 years. We do have the option of filing suit in federal court when and if EPA approves the downgrading of Florida waters, however, few citizens have the money to take their grievances into federal court. Some environmental groups such as ours may be able to file suit over some downgrades, but the sheer volume of we can expect will make it impossible to effectively prevent wide-spread abuses.

It is easy to understand why the special interests represented on the Technical Advisory Committee that you appointed for this issue are so eager to have new avenues for avoiding the Clean Water Act. However, I am not aware of anyone or any organization in support of this proposal that does not have something to gain financially by its passing.

Finally, we incorporate by reference the comment letter submitted by the Conservancy of SW Florida, except where there may be inconsistencies. There are many issues that we have not delved into here, but which we have raised previously in writing and at your public workshops.

As stated previously, we are not only opposed to the creation of a Class III-Limited designated use, but are greatly concerned that this issue is not receiving the public attention that it deserves. If you insist on moving forward with this effort, we urge you to hold as many more public workshops as would be needed for everyone in the state to attend one without having to drive more than 50 miles to get to it. You are embarking on a major policy change that will affect people’s property values, health, businesses, communities, culture and most importantly, the future of Florida’s waters. You must not do this at a time when there is so much turmoil and confusion over state and federal proposals and before you even know what EPA’s final numeric nutrient criteria will include as it relates to your designated uses rule change.

We appreciate that you have moved your final rulemaking before the ERC from earlier this year to a few months from now, but that short delay is still woefully inadequate.

We will be sending a subsequent copy of this letter shortly, with other organizations signed on in support of these comments.

For all of Florida’s waters,

Linda L. Young

Director



Midweek Red Tide Update, 03/30/2010

No water samples have been received this week from northwest Florida.




On the east coast of Florida, Karenia brevis, the Florida red tide organism, was not detected in water samples collected this week alongshore of Broward County.



In southwest Florida, Karenia brevis was not detected in water samples collected this week alongshore of Sarasota and Collier counties. Samples collected offshore of the gulf side of the Florida Keys (Monroe County) contained concentrations of K. brevis ranging from not present to very low.



Sampling will continue this week, and complete results will be available in the next scheduled status report on Friday, April 2.

Friday, March 26, 2010

Red Tide Status Reports, 03/26/2010

EAST COAST


Karenia brevis, the Florida red tide organism, was not detected in water samples collected this week alongshore of Brevard County or offshore of Broward County.



NORTHWEST COAST

Karenia brevis, the Florida red tide organism, was not detected in water samples collected this week alongshore of Escambia and Okaloosa counties. Samples collected late last week offshore of Okaloosa, Walton and Taylor counties also contained no K. brevis.



SOUTHWEST COAST

Karenia brevis, the Florida red tide organism, was not detected in water samples collected this week alongshore between Pinellas and Collier counties. Samples collected late last week offshore of Sarasota County also contained no K. brevis. One sample collected late last week offshore of the Dry Tortugas (Florida Keys, Monroe County) contained background concentrations of K. brevis.



Southwest Coast Bloom Boundary: A localized bloom of K. brevis was detected last week offshore of Monroe County, on the northern side of the lower Florida Keys. No samples were taken in the area this week.



Tables and maps of sample results are attached. This information is also available on our Web site: (http://research.myfwc.com/features/view_article.asp?id=9670). The Web site also provides links to additional information related to the topic of Florida red tide including satellite imagery, experimental red tide forecasts, shellfish harvesting areas, the FWC Fish Kill Hotline, the Aquatic Toxins Hotline (for information or to report human health effects), and other wildlife related hotlines: (http://research.myfwc.com/features/view_article.asp?id=9670#Links).

Oilfield math

Oilfield Math


A 15 mpg clunker that travels 12,000 miles a year uses 800 gallons of gas a> year.

A 25 mpg vehicle that travels 12,000 miles a year uses 480 gallons a year.

Therefore, the average Cash for Clunkers transaction will reduce US gasoline consumption by 320 gallons per year.  The government claims that 700,000 clunkers were turned-in, so that's 224> million gallons saved per year. That equates to a bit over 5 million barrels of oil.   5 million barrels is about 5 hours worth of US consumption.  More importantly, 5 million barrels of oil at $70 per barrel costs about $350 million dollars.  So, the government paid $3 billion of our tax  dollars to save $350 million.  In other words, we spent $8.57 for every dollar we saved.

 I'm pretty sure they will do a great job with our health  care,

Carl Hiaasen on Amendment 4 - Florida Hometown Democracy ballot initiative

Author and Columnist Carl Hiaasen Supports Amendment 4



Gainesville---The Florida Hometown Democracy campaign bagged a winner .....At the March 2nd lecture sponsored by U.F.'s Graham Center, long-time observer of Florida's political scene and environmental issues, Carl Hiaasen, spoke decisively in favor of Florida Hometown Democracy's Amendment 4. It will appear on the November 2nd ballot statewide. A Miami Herald columnist for twenty-five years, Hiaasen said, "There's a huge constituency for saving what's left of Florida" He railed against the out-of-control development, saying he supported the amendment for offering a voice to Florida's citizens.

Calling Florida "a place that's hard not to love," he said he thought people were tired of seeing the loss of the state's natural beauty. The Amendment 4 issue came up in response to a question from a person in the audience of some 300 people. "Do you support Florida Hometown Democracy Amendment 4?" Hiaasen quickly responded, "I do. I think the Hometown Democracy Amendment is wonderful."

"They’re [politicians and developers] squirming like, you know, worms on a frying pan right now about this whole thing: the idea that people would actually have a say in what kind of developments go to their [neighborhood] .

"I mean obviously it could be abused, but the point of this Amendment is that if you live in a place, and they’re going to come in and put in a huge subdivision or a huge mall or something, that you could actually have a vote on whether or not that’s a good idea or not.

"It isn’t just a group of people that you go in and you listen to them and you make a decision. You stand up and they ignore you – which happens -- I don’t know what happens in your town -- but in South Florida that was the M.O. They would put that last on the agenda that night -- the big Zoning Board change, the zoning change – you know, to go from pastures and agriculture to 16-unit-per- acre density apartment complex. OK, true.

"They always would put it on at like 3 or 4 in the morning, when everybody was gone or tired or left, and then they would slide [it] on through.

"Now, the idea that they might actually have to deal with public sentiment on these issues has got them all running for cover. The Florida Chamber of Commerce is upset, everybody’s upset, because “It’s gonna give away the jobs. People! Don’t you understand?”

"So they’re squirming and hopping around. I love to watch that.

"I don’t know that it’s going to pass, but I love to see how frantic they are about it because the idea of public involvement, trust me, is the last thing they want. That is the last thing they want. They do not want to hear your opinion.

"When these projects – the way they get started and the way they funnel through the political system – with the lobbyists -- and this is going down to the city commission level, city council level. It doesn’t matter.

"It’s all the same game. And that is, you get to people, and you get their support. Even if it means contributing $10,000 to their campaign; one way or another they’ll do that. People can be bought all different ways, but nobody sitting on [the council/commission] changes their vote for no reason. That’s the first lesson you learn. It’s that when you’ve got a 5-4 vote and there’s an adjournment, and now you’ve got a 5-4 vote the other way, something happened in those 5 minutes, OK. That wasn’t just a change of conscience.

"So this will put it directly in the public’s lap. At least in certain neighborhoods, they can make these decisions. I think it would be a great thing as an experiment to see how it does.

"I don’t know that it’s going to pass, but I like the idea."

To another question from the audience---" Why was there no opposition in Florida to weak land policies in both depressions, 1933 and 2008?"

Hiaasen replied:

"Greed. Greed. There’s no mystery to that. It’s not just Florida, by the way It’s not just endemic to Florida.

"The point from the beginning has been to get as many people here as we possibly could, and cram them into as much space as we could. Especially waterfront, oceanfront property. That’s been the whole game from the beginning. It’s not going to change, ever, you know. It’s just about money. It’s not about the place. It’s not about, you know, the quality of life, really. It’s about making money.

"And that’s what rules the day, generally speaking, in most states, politically. Anything that’s seen as an impediment to making money, the cry goes out, “You’re costing us jobs! Oh you’re costing us jobs!”

"We could put in this rock-mining pit in West Dade, and, “You’re going to cost us 17 jobs!” You know, 40 acres of digging up limestone on the edge of the Everglades. “But it will cost us 17 jobs!” or whatever. It’s ridiculous. That’s the battle cry. They’ve all got the same script. It doesn’t matter where you are. You go in any state and hear it."

Carl Hiaasen has authored twenty-one satirical novels with Florida settings. His next novel, "Star Island", is due out this Fall. He has also written children's books and collaborated with Jimmy Buffett to produce a movie of his book, "Hoot". The full lecture, "On Florida", can be viewed at www.graham.centers. ufl.edu/

Pam Sizemore-House Fund Raising Cancer Event

fund raiser cancer event


1:00pm Saturday, April 3rd Cross City

Pam Sizemore-House, Gayle Barringer Lovelace, and 10 other guests

Thursday, March 11, 2010

STATEMENT FROM DEP SECRETARY MICHAEL W. SOLE REGARDING ISSUANCE OF FINAL ORDER FOR INTERNATIONAL PAPER COMPANY (IP)

STATEMENT FROM DEP SECRETARY MICHAEL W. SOLE REGARDING ISSUANCE OF FINAL ORDER FOR INTERNATIONAL PAPER COMPANY (IP)

TALLAHASSEE – “After careful consideration and based on the conclusions of Judge Bram D.E. Canter’s recommendation, I have signed a Final Order to approve International Paper’s permit application and the company-planned reconfiguration of its Pensacola Mill at Cantonment in Escambia County.

“The final order will, after years of legal challenges, issue a permit for the mill. The permit strictly outlines all of the necessary improvements International Paper needs to make in order to protect the area’s natural resources as well as enhance the biological diversity and productivity of the nearby wetlands.

“Specifically, the permit requires International Paper to upgrade their wastewater treatment and relocate the existing discharge from Eleven Mile Creek to an effluent distribution system in a 1,381 acre wetland tract, with an additional 1,188 acres that will be managed as a conservation area.  These changes in land management activities and the relocation and modification of the effluent distribution system will result in the restoration of the historic ecosystems.  The permit also requires IP to achieve compliance with all water quality standards and permit limits by the end of the consent order.

“We look forward to working with both International Paper and community members to ensure that the mill’s enhancements protect the region’s natural resources and economy.”

BACKGROUND INFORMATION

What is being announced?
Florida Department of Environmental Protection (DEP) Secretary Michael W. Sole today signed a Final Order adopting  the Administrative Law Judge’s Recommended Order and  approving a proposed permit and Consent Order for International Paper Company (IP).  The permit authorizes a company-planned reconfiguration of its Pensacola Mill’s wastewater treatment and disposal system. The mill is located near the town of Cantonment in Escambia County. DEP’s Final Order specifically approves the proposed National Pollutant Discharge Elimination System (NPDES) Permit and the proposed Consent Order.

What are the environmental benefits of the new permit?
IP’s permit and accompanying consent order will result in an upgrade of its industrial wastewater treatment plant and relocation of its discharge from upper Eleven Mile Creek to a 1,400-acre wetland tract located 10 miles south of the mill. There, the mill’s effluent would be distributed and would flow into lower Eleven Mile Creek and Perdido Bay.  IP’s use of the wetland tract will set the Eleven Mile Creek on a course of recovery, improve the environmental health of Perdido Bay, and set aside substantial areas of important habitat for permanent protection.

What type of permit has the facility been operating under?
IP’s pulp and paper mill has been operating under an administratively continued 1989 wastewater permit and Consent Order. The Consent Order, which accompanied the permit, required the mill to conduct water quality studies and engineering evaluations, and develop plans to achieve compliance with water quality criteria for Eleven Mile Creek and Perdido Bay. By 1995, IP – then known as Champion International – had invested millions of dollars in mill modifications toward meeting this requirement.

When did the facility apply for a proposed permit?
On April 5, 2005, DEP noticed its intent to approve the requested NPDES Permit to authorize the industrial wastewater treatment improvements, including relocation of the discharge from Elevenmile Creek to the wetland, and three other agency actions (proposed Consent Order, an order allowing the experimental use of the wetland, and waiver to allow public access to Tee and Wicker Lakes which are a part of the proposed treatment wetlands).

These actions were petitioned by the Friends of Perdido Bay and additional residents near the mill in May 2005, and an Administrative Law Judge (ALJ) within the Department of Administrative Hearings was assigned to the case. An administrative hearing on the proposed permit began on May 31, 2006, and concluded on July 28, 2006. The ALJ entered his Recommended Order on May 11, 2007, recommending DEP deny the proposed agency actions.

On August 8, 2007, DEP entered a Final Order adopting the ALJ’s recommendations.

On August 10, 2007, IP filed an appeal of DEP’s Final Order with the First District Court of Appeal. The company requested the Department grant a stay of the Final Order to allow IP’s Pensacola Mill to continue to operate while the appeal process moves forward.

On August 22, 2007, the Department entered an Order granting IP’s request for a stay of DEP’s Final Order, and placed additional requirements on IP’s discharge.

When did the facility apply for the current proposed permit?
After the 2007 Final Order, IP conducted additional studies, modified the project and re-applied for the four authorizations.  In July 2008, the Department issued its Notice of Intent to issue an NPDES permit, a Consent Order, an exception for the experimental use of wetlands and a variance for the modified project.  Petitioners, Jacqueline Lane, Friends of Perdido Bay, Inc., and James Lane, challenged DEP’s four proposed agency actions.  Prior to final hearing, IP withdrew its request for the exception for the experimental use of wetlands and variance.  After final hearing in the matter, and being bound by certain findings in the DEP’s 2007 Final Order, ALJ Canter entered an order recommending the DEP enter a Final Order granting NPDES Permit No. FL0002526 and approving Consent Order No. 08-0358 for the IP Pensacola Mill.

What are the next steps?
Any party with standing may appeal the Final Order to the First District Court of Appeal within 30 days of entry of the Final Order.