Holtville Unified School District (PERB 0180E)

STATE 	OF 	CALIFORNIA
DECISION 	OF 	THE
PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
HOLTVILLE 	UNIFIED SCHOOL 	DISTRICT,
Employer,
v.
HOLTVILLE 	TEACHERS 	ASSOCIATION/
CTA/NEA,
Employee 	Organization.
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Case 	No. 	LA-R-604
LA-UM-108
PERB 	Decision 	No. 	180
November 	18, 	1981
Appearances: 	Kathryn B. 	Jansen 	for 	Holtville 	Unified 	School
District; 	Charles 	R. 	Gustafson, 	Attorney 	for 	the 	Holtville
Teachers 	Association/CTA/NEA.
Before 	Jaeger, 	Moore 	and 	Tovar, 	Members.
DECISION
This 	case 	is 	before 	the 	Public 	Employment 	Relations 	Board
(hereafter 	PERB 	or 	Board) 	on 	exceptions 	to 	the 	attached 	hearing
officer's 	proposed 	decision 	filed 	by 	the 	Holtville 	Unified
School 	District 	(hereafter 	District). 	The 	District, 	pursuant
to 	PERB 	rule 	33261 (b) ( 1), 1 seeks 	to 	modify 	the 	certificated
unit, 	represented 	by 	the 	Holtville 	Teachers 	Association, 	by
lpERB 	rules 	are 	codified 	at 	title 	8, 	section 	31000
et 	seq. 	of 	the 	California Administrative 	Code. 	Section 	33261
provides:
(b) 	A recognized 	or 	certified 	employee
organization, 	an 	employer, 	or 	both 	jointly
may 	file 	with 	the 	regional 	office 	a 	petition

designating 	the
	language, 	speech,
	and
	hearing
	specialist
	as
	a
management
	employee
	as
	defined
	by
	Government
	Code
	subsection
3540.l(g)2	
and
	thus 	exclude 	her
	from
	the
	unit
	as
	required
	by
Government
	Code
	subsection
	3545(b)
(1)
.3	
The
	hearing
	officer
determined
	the 	language, 	speech,
	and
	hearing
	specialist
	was
	not
a 	management
	employee
	since
	she
	did 	not
	possess
	significant
for
	change
	in
	unit
	determination 	pursuant
	to
Government
	Code
	section
	3541.3{e):
(1) 	To
	delete
	classifications
	no
longer 	in 	existence
	or
	which
	by
	virtue
of
	changes
	in 	circumstances 	are
	no
longer
	appropriate 	to
	the
	established
unit;
2The
	Educational
	Employment
	Relations
	Act
	is
	codified
	at
section
	3540
	et
	seq. 	of 	the
	Government 	Code.
	Subsection
3540.l(g) 	provides:
"Management
	employee"
	means 	any 	employee
	in
a
	position
	having
	significant
responsibilities
	for 	formulating
	district
policies
	or 	administering
	district
programs.
	Management
	positions 	shall
	be
designated	
by 	the
	public
	school
	employer
subject 	to
	review
	by
	the 	Educational
Employment
	Relations
	Board.
3subsection
	3545 (b) (1)	
provides:
(b)	
In
	all
	cases:
(1) 	A
negotiating 	unit 	that 	includesclassroom 	teachers
	shall	
not
	be
appropriate 	unless	
it
	at 	least
	includes
all	
of
	the 	classroom 	teachers
	employed
by
	the 	public 	school 	employer, 	except
management
	employees, 	supervisory
employees,
	and	
confidential	
employees.
2

responsibilities
	for
	either
	formulating
	District
	policies
	or
for 	administering
	District
	programs.
The
	Board
	has
	considered 	the
	record
	as
	a
	whole 	and
	the
proposed
	decision
	in
	light
	the
	exceptions
	filed
	and
	hereby
adopts 	the 	hearing
	officer's
	findings
	of
	fact
	and
	conclusions
of
	law.
ORDER
Upon
	the
	foregoing
	dee
	ion
	and
	the
	entire
	record
	in
	this
case,
	the
	Pub 	c 	Employment
	Relations
	Board
	ORDERS
	that:
The
	position
	of
	language, 	speech,
	and
hearing
	spec
ia
	st
	is
	not
	a 	management
position
	within
	the
	meaning
	of
	Government
Code
	subsection 	3540.l(g)
	and
	is,
	therefore,
included
	in
	the
	certificated
	unit.
PER
	CURIAM
3

PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
OF 	THE 	STATE 	OF 	CALIFORNIA
HOLTVILLE 	UNIFIED 	SCHOOL 	DISTRICT,
Employer,
and
HOLTVILLE 	TEACHERS 	ASSOCIATION/CTA/
NEA,
Employee 	Organization.
)
) 	Representation
Case 	No. 	LA-R-604
LA-UM-108
PROPOSED 	DECISION
(1/26/81)
)
)
)
)
)
)
)
)
)
~pearances: 	Kathryn 	B. 	Jansen 	for 	Holtville 	Unified 	School
District; 	Charles 	R. 	Gustafson, 	Attorney 	for 	the 	Holtville
Teachers 	Association/CTA/NEA.
Before 	Dee 	Crippen, 	Hearing 	Officer.
INTRODUCTION
The 	Holtville 	Unified 	School 	District 	(hereafter 	District)
has 	a 	student 	enrollment 	of 	approximately 	1,839 	at 	two
elementary 	schools, 	one 	junior 	high 	school, 	one 	high 	school 	and
a 	continuation 	school 	in 	the 	County 	of 	Imperial.l
On 	December 	20, 	1979 	the 	District, 	pursuant 	to
PERB 	Rule 	33260,2 	filed 	a 	unit 	modification 	petition 	with 	the
lcalifornia 	Public 	School 	Directory 	(1980) 	State
Department 	of 	Education, 	at 	p. 	131.
2Rule 	33260 	provides 	as 	follows:
Policy. 	It 	is 	the 	policy 	of 	the 	Board 	to
provide 	a 	single 	mechanism 	which 	shall 	be
utilized 	for 	the 	modification 	of 	all

Public 	Employment 	Relations 	Board 	(hereafter 	PERB) 	to 	exclude
the 	positions 	of 	Language, 	Speech 	and 	Hearing 	Specialist 	and
School 	Nurse 	from 	the 	established 	certificated 	unit. 	On
January 	21, 	1980 	the 	Holtville 	Teachers 	Association/CTA/NEA
(hereafter 	Association) 	filed 	its 	response 	in 	opposition 	to 	the
District's 	petition.
The 	District 	contended 	that 	the 	Language, 	Speech 	and
Hearing 	Specialist 	and 	the 	School 	Nurse 	were 	management
employees 	and 	consequently 	the 	positions 	should 	be 	excluded
from 	the 	certificated 	unit 	as 	required 	by 	Government 	Code
section 	3545(b) (1)3 	of 	the 	Educational 	Employment 	Relations
Act 	(hereafter 	EERA).
established 	units. 	This 	system 	is 	designed
to 	ensure 	that 	all 	parties 	to 	a 	modification
are 	afforded 	notice 	and 	opportunity 	to
express 	their 	views 	with 	regard 	to 	any
proposed 	modification, 	and 	to 	provide
assistance 	in 	the 	resolution 	of 	questions
raised 	by 	the 	parties 	to 	a 	dispute 	regarding
the 	modification 	of 	unit.
The 	Board 	will 	not 	allow 	a 	unit 	modification 	which 	is 	based
principally 	on 	employee 	dissatisfaction 	with 	the 	results 	of
negotiations 	or 	the 	exclusive 	representative; 	nor 	will 	the
Board 	permit 	a 	unit 	modification which 	impinges 	on 	the
integrity 	of 	another 	established 	unit 	in 	which 	there 	is 	a
different 	recognized 	or 	certified 	organization 	or 	which
compromises 	the 	exclusivity 	of 	such 	certification.
No 	unit 	modification may 	be 	made 	by 	any 	procedure 	other
than 	that 	contained 	in 	this 	Article. 	(Amended 	as 	of 	6/14/79.)
3Government 	Code 	section 	3545(b) (1) 	reads 	as 	follows:
(b) 	In 	all 	cases:
(1) 	A negotiating 	unit 	that 	includes
classroom 	teachers 	shall 	not 	be 	appropriate
2

The 	Association 	contended 	that 	the 	positions 	were 	not
management 	as 	the 	incumbents 	did 	not 	possess 	significant
responsibilities 	for 	formulating 	district 	policies 	and
administering 	district 	programs 	and 	should 	remain 	part 	of 	the
overall 	certificated 	unit.
After 	an 	informal 	conference, 	resolution 	was 	reached 	on 	the
position 	of 	School 	Nurse. 	It 	was 	determined 	that 	this 	position
was 	not 	one 	of 	management 	and 	the 	position 	was 	therefore
properly 	included 	in 	the 	overall 	certificated 	unit.
As 	no 	resolution 	was 	reached 	on 	the 	position 	of 	Language,
Speech 	and 	Hearing 	Specialist, 	a 	formal 	hearing 	was 	held 	on
September 	17, 	1980. 	Thereafter, 	simultaneous 	briefs 	were 	filed
by 	the 	parties 	on November 	28, 	1980.
FINDINGS 	OF 	FACT
On November 	11, 	1976 	a 	request 	for 	recognition 	filed 	by 	the
Association 	pursuant 	to 	3544.1 	was 	granted 	by 	the 	Board 	of 	the
Holtville 	Unified 	School 	District 	for 	a 	unit 	including:
All 	certificated 	employees,
except 	management, 	confidential 	and
supervisory 	employees.
unless 	it 	at 	least 	includes 	all 	of 	the
classroom 	teachers 	employed 	by 	the 	public
school 	employer, 	except 	management
employees, 	supervisory 	employees, 	and
confidential 	employees.
The 	EERA 	is 	codified 	at 	Government 	Code 	section 	3540 	et
seq. 	All 	statutory 	references 	are 	to 	the 	Government 	Code
unless 	otherwise 	noted.
3

Since
	recognition
	was
	granted 	to 	the
	Association,
	two
negotiated
	agreements
	have 	been
	entered
	into
	by
	the
	parties.
A
negotiated
	agreement
	is
	currently
	in
	effect
	between
	the
Association
	and
	the
	District
	covering 	the 	period
	from
July 	1,
	1978
	until
	July
	1,
	1981.
The
	position
	of
	Language, 	Speech
	and
	Hearing
	Specialist
	has
been
	included
	in
	the
	overall
	certificated
	unit
	since
recognition
	was
	granted 	to 	the
	Association.
	The
	District's
petition
	to
	exclude 	the
	positions
	of
	School
	Nurse
	and
	the
Language, 	Speech
	and
	Hearing
	Specialist
	as
	management
	employees
was
	the
	result
	of 	the
	governing
	board's 	action
	on
November
	15,
	1979
	approving 	the
	designations 	of
	School 	Nurse
and
	the
	Language, 	Speech
	and
	Hearing
	Specialist
	in 	concept 	as
management
	employees
	and
	directing
	the
	District
	Superintendent
to
	file
	the
	petition
	to
	remove
	the
	positions
	from
	the
	unit.
The
	Association's
	response
	in 	opposition 	to 	the
	change
	in
unit
	determination	
of	
both
	classifications 	stated 	that	
no
change
	in 	circumstance
	had
	occurred 	since 	recognition 	in
	1976
and	
that
	these
	classifications
	were
	properly 	included 	in 	the
unit.
As	
previously 	noted, 	the
	position 	of
	School 	Nurse 	was
determined	
to	
be
	properly 	included 	in 	the	
certificated 	unit.
Therefore,
	this 	decision 	will	
deal 	only 	with 	the 	issue 	of
whether 	or 	not 	the 	Language, 	Speech 	and	
Hearing	
Specialist 	is
	a
management 	employee.
4

The
	Language,
	Speech
	and
	Hearing
	Specialist 	is
	responsible
for
	evaluating
	both
	English
	and
	Spanish 	speaking
	children 	to
determine 	the
	extent
	of
	any
	language,
	speech
	or 	hearing
disorders.
	If
	a
	child
	is
	found
	to
	be
	deficient
	in
	any
	of
	these
areas,
	therapy
	will
	be
	provided
	on
	either
	an
	individual 	or
group
	basis.
	No
	teaching
	responsibilities
	are 	assigned
	to
	the
position,
	as 	the
	position
	of
	Language, 	Speech 	and
	Hearing
Specialist 	is
	a
	full-time
	one.
A
communication
	aide
	is
	assigned
	to
	assist
	the
	Language,
Speech
	and
	Hearing
	Specialist.
	The
	Language, 	Speech 	and
Hearing
	Specialist's
	present
	communication
	aide
	was
	already
employed
	by
	the
	District
	in 	another
	capacity,
	and 	was
	hired
with 	the 	concurrence 	of 	the
	District
	Superintendent.
	The
Language, 	Speech 	and
	Hearing
	Specialist 	stated 	that
	evaluating
her
	communications
	aide
	would 	be
	her
	responsibility,
	but
	that
she	
had
	not
	done
	so
	in 	the
	past. 	If
	she 	were
	dissatisfied
	with
her
	aide's
	performance, 	she
	would 	have
	to 	take 	the 	matter
	up
with 	the
	District
	Superintendent,
	who 	would
	have
	final
authority
	on 	any
	disciplinary 	action 	to
	be
	taken.
	The
procedure
	is 	essentially	
the	
same	
for
	all
	other	
certificated
personnel	
who	
supervise 	aides.
The 	Language, 	Speech 	and
	Hearing	
Specialist 	receives	
her
referrals	
for	
evaluation
	from	
parents, 	doctors, 	nurses	
and
	the
classroom 	teachers.	
Her
	office 	is	
located 	in 	the 	Finley
Elementary 	School 	and 	she 	has 	occasion 	to 	service	
all
	schools
5

in
	the
	District.
	She
	has
	interaction
	with
	the 	classroom
teachers
	and
	shares
	their
	facilities.
	She
	is
	encouraged
	to
discuss
	the
	children's
	progress
	with
	the
	classroom
	teachers
	and
parents
	involved
	in
	her
	program.
An
	example
	of
	an
	area
	where
	the
	Language, 	Speech 	and
Hearing
	Specialist
	has
	played
	a
	role 	in
	the
	development
	of
District
	programs
	and
	the
	extent
	of
	that 	role, 	is
	as
	follows:
Under
	the
	direction
	of 	the
	Migrant
	Aide
Coordinator, 	the
	Language, 	Speech
	and
Hearing
	Specialist
	prepared
	and
	conducted
six
	one-half
	hour 	workshops
	for 	the 	migrant
aides 	in
	the
	District.
	Approval
	for
	this
program
	was
	the
	responsibility
	of 	the
Migrant
	Aide
	Coordinator
	who
	supervises
	all
migrant
	aides 	in 	the
	District.
The
	incumbent 	Language, 	Speech
	and
	Hearing
	Specialist
	has
been
	employed	
by	
the
	District
	for 	approximately
	15
	years.
	At
time
	of
	hire,
	she
	was
	put
	on
	the
	teacher's 	salary
	schedule 	plus
10
	percent.
	She
	received
	this
	additional
	amount
	until
	the
1978-79
	school 	year.
	When
	she
	returned 	to
	school
	in
	September,
she
	was
	told 	that
	she
	would 	no
	longer 	receive
	a 	10
	percent
differential
	and
	that
	the
	salary
	differential
	would 	be
	frozen
at
	the
	amount
	she
	was
	then 	receiving
	and 	become 	a
	constant
amount. 	Although 	she 	has	
continued 	to 	receive	
her
	salary
increases	
according 	to
	her 	placement
	on
	the 	negotiated
teacher's 	salary 	schedule, 	she 	continues 	to 	receive 	the
constant
	amount 	above 	the 	teacher's 	salary	
set	
in 	the 	1978-79
school 	year, 	not	
10
	percent.
6

She 	is 	not 	responsible 	for 	the 	budget 	to 	administer 	her
program. 	She 	receives 	her 	supplies 	in 	the 	same 	manner 	as 	a
classroom 	teacher. 	She 	orders 	her 	supplies 	through 	the
District 	Superintendent, 	who 	has 	the 	authority 	to 	approve 	or
disapprove 	the 	request.
In 	conjunction 	with 	other 	professionals, 	she 	acts 	in 	an
advisory 	capacity 	in 	the 	District 	and 	the 	community 	concerning
children's 	speech, 	language 	and 	hearing 	deficiencies.
ISSUE
Whether 	the 	position 	of 	Language, 	Speech 	and 	Hearing
Specialist 	is 	a 	management 	employee 	within 	the 	meaning 	of
Government 	Code 	section 	3540.l(g) 	and 	therefore 	properly
excluded 	from 	the 	unit.
CONCLUSIONS 	OF 	LAW
Government 	Code 	section 	3540.l(g) 	defines 	a 	"management
employee" 	as 	"any 	employee 	in 	a 	position 	having 	significant
responsibilities 	for 	formulating 	district 	policies 	or
administering 	district 	programs."
The 	PERB 	has 	previously 	concluded 	that 	a 	management
employee 	must 	possess 	significant 	responsibilities 	for 	both
formulating 	district 	policies 	and 	administering 	district
programs.4 	The 	EERA's 	requirement 	that 	a management 	employee
4Lomeoc_~nified 	School 	District 	(3/17/77) 	EERB 	Decision
No. 	13, 	at 	20-21.
7

"formulate
	district
	policies"
	requires
	that
	an 	employee
	possess
discretionary 	authority
	to
	develop
	or
	modify
	institutional
goals
	and
	priorities.
	"Administering
	district
	programs"
requires 	authority
	to
	implement
	district
	programs
	through
	the
exercise
	of
	independent 	judgment.5
The
	Language, 	Speech
	and
	Hearing
	Specialist
	has
	the
responsibility
	for
	evaluating
	the 	language,
	speech
	and
	hearing
difficulties
	of
	the
	children
	in 	the
	District
	and
	providing
	a
program
	of 	therapy,
	if
	needed.
She
	has
	continued
	to 	maintain
	her
	professional
	competency
in
	her
	field
	by
	attendance
	at
	conferences,
	workshops 	and
monthly
	specialists
	meetings.
	She
	possesses 	the 	necessary
credentials
	to
	perform
	her
	job,
	but 	does
	not 	possess
	an
administrative
	credential,
	as
	one
	is
	not 	required 	for 	her
position.
She
	has, 	in
	conjunction 	with
	other 	professionals, 	acted 	in
an
	advisory 	capacity 	in 	the
	community
	as 	well 	as 	the 	school
district
	on
	the
	needs
	of 	the
	children's
	language, 	speech
	and
hearing 	problems.
Although	
sufficient	
evidence	
was	
presented
	at
	the 	hearing
to
	attest
	to	
the 	competency
	of
	the 	incumbent's	
work
performance,	
insufficient	
evidence	
was
	produced
	by
	the
incumbent	
and
	the	
District 	to	
determine 	that 	the
	position	
is
one	
of
	management.
5Hartnell
	Community
	College 	District
	(1/2/79)	
PERB
Decision
	No. 	81, 	at 	13. 8

The
	incumbent
	is
	not
	responsible
	for
	the
	budget 	development
necessary 	to
	run
	her 	programs.
	When
	monies
	or
	supplies
	are
needed, 	she
	places
	a
	request
	with
	the
	District
	Superintendent
in
	the
	same 	manner
	as
	other
	certificated
	employees.
	The
District
	Superintendent
	has
	the
	authority 	to
	approve
	or
disapprove
	all
	requests.
Reference
	was 	made
	to
	the
	training
	and
	supervision 	of
	a
communication
	aide
	by
	the
	incumbent.
	Training
	and
	supervision
of
	an
	aide
	does
	not
	make
	an 	employee 	management.
	Other
certificated
	employees
	in 	the
	District
	have
	responsibilities
for
	their
	aides.
	The
	incumbent
	may
	participate
	in 	the
	hiring
and
	evaluation 	of 	her
	aide,
	but 	the
	final
	authority
	for
	hiring
and
	firing
	of
	all
	the
	aides
	lies
	with 	the
	superintendent.
	She
does 	not
	supervise
	any
	credentialed
	employees.
Participation
	of 	the
	incumbent
	in 	the
	preparation 	of
workshops
	for 	migrant
	aides
	was
	clearly
	authorized
	by
	the
Migrant
	Aide
	Coordinator
	who
	is
	a 	management 	employee
	of 	the
District.
	The
	incumbent
	testified 	that
	she
	was 	unaware
	of
	how
authorization
	was
	obtained 	to
	conduct 	and	
finance 	the 	program.
Although 	the 	incumbent 	must 	use 	independent
	judgment 	on	
the
basis 	of
	what
	therapy
	may 	be 	needed 	for	
a	
particular
	child,
	she
must	
obtain 	prior 	authorization	
from	
the	
District
Superintendent	
if	
any	
expenditures 	of
	funds	
are	
needed	
to
finance 	the 	therapy.
9

Discussion 	by 	the 	incumbent 	showed 	some 	dissatisfaction
with 	her 	present 	salary 	situation. 	She 	stated 	that 	since 	the
inception 	of 	collective 	bargaining 	under 	the 	EERA, 	she 	has 	been
placed 	on 	the 	teacher's 	salary 	schedule, 	but 	has 	been 	denied
the 	promised 	10 	percent 	additional 	salary 	amount 	escalating 	at
the 	same 	rate 	as 	her 	raises. 	She 	had 	been 	receiving 	the
additional 	10 	percent 	above 	her 	salary 	since 	she 	was 	employed
by 	the 	District 	approximately 	15 	years 	ago. 	It 	was 	unclear
from 	the 	record 	as 	to 	how much 	involvement, 	if 	any, 	the
exclusive 	representative 	had 	in 	trying 	to 	help 	the 	incumbent
rectify 	this 	situation, 	which 	she 	considers 	unjust. 	Since 	the
additional 	pay 	amount 	of 	the 	incumbent 	had 	been 	effectuated
15 	years 	ago, 	the 	fact 	that 	she 	receives 	an 	additional 	amount
above 	the 	teacher's 	salaries 	will 	not 	be 	considered, 	as 	it
appears 	to 	have 	been 	given 	as 	an 	incentive 	based 	on 	the
incumbent 1 s 	expertise 	in 	her 	field, 	not 	for 	managerial
activities.
Considering 	the 	record 	as 	a 	whole, 	insufficient 	evidence
was 	presented 	by 	the 	District 	or 	the 	incumbent 	to 	support 	the
position 	that 	the 	Language, 	Speech 	and 	Hearing 	Specialist 	is 	a
management 	employee 	pursuant 	to 	section 	3540.l(g).
She 	does 	not 	have 	significant 	responsibilities 	for
formulating 	and/or 	administrating 	district 	programs. 	All 	of
her 	decisions 	must 	be 	submitted 	to 	the 	District 	Superintendent
for 	final 	approval.
10

Therefore, 	it 	is 	determined 	that 	the 	position 	of 	Language,
Speech 	and 	Hearing 	Specialist 	is 	properly 	included 	in 	the 	unit.
PROPOSED 	ORDER
Based 	on 	the 	foregoing 	findings 	of 	fact, 	conclusions 	of 	law
and 	the 	entire 	record 	in 	this 	matter, 	it 	is 	the 	proposed
decision 	and 	order 	that:
The 	position 	of 	Language, 	Speech 	and 	Hearing
Specialist 	is 	not 	a 	management 	position
within 	the 	meaning 	of 	Government 	Code
section 	3540.l(g) 	and 	is, 	therefore,
included 	in 	the 	certificated 	unit.
Pursuant 	to 	California 	Administrative 	Code, 	title 	8, 	part
III, 	section 	32305, 	this 	Proposed 	Decision 	and 	Order 	shall
become 	final 	on 	February 	16, 	1981 	unless 	a 	party 	files 	a 	timely
statement 	of 	exceptions 	and 	supporting 	brief 	within 	twenty 	(20)
calendar 	days 	following 	the 	date 	of 	service 	of 	this 	decision.
Such 	statement 	of 	exceptions 	and 	supporting 	brief 	must 	be
actually 	received 	by 	the 	Executive 	Assistant 	to 	the 	Board 	at
headquarters 	office 	in 	Sacramento 	before 	the 	close 	of 	business
(5:00 	p.m.) 	on 	February 	16, 	1981 	in 	order 	to 	be 	timely 	filed.
(See 	California 	Administrative 	Code, 	title 	8, 	part 	III, 	section
33135.) 	Any 	statement 	of 	exceptions 	and 	supporting 	brief 	must
be 	served 	concurrently 	with 	its 	filing 	upon 	each 	party 	to 	this
proceeding. 	Proof 	of 	service 	shall 	be 	filed 	with 	the 	Board
itself. 	(See 	California 	Administrative 	, 	tit 	8, 	part
III, 	sections 	32300 	and 	32305, 	as 	ame
Dated: 	January 	26, 	1981
11
Dee 	Crippen
Hearing 	Officer
,-,~