HAYDEN, Judge.
Since 1991 the petitioner, On With Life, Inc., has operated a twenty-two-bed post-acute brain injury rehabilitation facility for young adults. Pursuant to Iowa Code section 135.63 (1993), the petitioner filed with the Iowa Department of Public Health in April 1993 an application for a certificate of need to construct a twenty-two-bed addition to the facility. The respondent, State Health
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