HomeMy WebLinkAbout07-019 GODDARDKeith Goddard
214 S. 29 Street
Harrisburg, PA 17103
Dear Mr. Goddard:
I. ISSUE:
OPINION OF THE COMMISSION
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Donald M. McCurdy
Paul M. Henry
Raquel K. Bergen
Nicholas A. Colafella
Reverend Scott Pilarz
DATE DECIDED: 10/24/07
DATE MAILED: 11/7/07
07 -019
This Opinion is issued in response to the appeal of Advice of Counsel, 07 -554,
which was issued on July 6, 2007.
Whether an individual employed as a Clerk Typist 2 with the Commonwealth of
Pennsylvania, Department of Transportation ( "PennDOT "), would upon termination of
Commonwealth service be subject to the restrictions of Section 1103(g) of the Public
Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1103(g), pertaining to former
public officials /public employees, where within the one -year period prior to terminating
Commonwealth service, the individual was employed with PennDOT as a Clerical
Supervisor I but did not supervise any PennDOT employees.
II. FACTUAL BASIS FOR DETERMINATION:
By letter dated July 30, 2007, you appealed Advice of Counsel 07 -554.
At the time of your initial inquiry, you were employed as a Clerical Supervisor I
(Secretary to the Section Chief) in the Consultant Agreement Section of PennDOT. Your
Goddard, 07 -019
November 7, 2007
Page 2
initial advisory request presented facts and arguments that were summarized in the Advice
of Counsel as follows:
You are currently employed as a Clerical Supervisor 1
(Secretary to the Section Chief) in the Consultant Agreement
Section of PennDOT. You have submitted a copy of your
position description, which is incorporated herein by reference.
A copy of the job classification specifications for your position
(job code 00190) has also been obtained and is incorporated
herein by reference.
Per your official PennDOT position description, your
duties and responsibilities include the following:
• Serving as secretary to the Section Chief, professional
engineers, and all other employees in the Consultant
Agreement section;
• Directly supervising clerical staff by planning and
organizing work assignments;
• Reviewing legal documents developed in the
Consultant Agreement Section and extracting
appropriate language and information to develop and
type correspondence to the Districts, Central Office,
Consultants, Office of Chief Counsel, and Comptroller's
Office for review and signature by the Section Chief;
• Managing the Section's Quality Assurance Program for
processing and paying consultant invoices, which
includes reviewing invoices to ensure that the invoice
amount is justifiable, in the proper format and allowable
under the terms and conditions set forth in the
Engineering Agreement, and determining invoice
document conformity based on established guidelines;
• Performing a variety of fiscal duties including:
independently checking fiscal forms for correct coding
and amount; independently reviewing current and
previous invoices, checking for fiscal accuracy;
verifying fiscal information with engineers; verifying
wage /overhead rates; and verifying contract amounts to
preclude overpayment for unauthorized items;
• Generating quarterly reports, agreement backlogs,
Disadvantaged Business Enterprise reports, and
Agreement /Supplement execution tracking using
appropriate systems and databases;
• Preparing Employee Progress Review reports,
approving employee leave, and taking appropriate
disciplinary action, if necessary; and
• Finding appropriate solutions to resolve problems with
Goddard, 07 -019
November 7, 2007
Page 3
projects according to PennDOT policies and related
material.
Per the job classification specifications under job code
00190, a Clerical Supervisor 1:
• Interviews and recommends the selection of applicants
for clerical positions within the section;
• Adjusts employee complaints and recommends
decisions on formal grievances;
• Evaluates the performance of employees in the clerical
unit supervised;
• Supervises and assigns work to the subordinate clerical
staff;
• Supervises the typing of documents and maintenance
of files, and plans and provides guidance in the
establishment and reorganization of filing systems as
needed;
• Registers, certifies, and insures outgoing mail and
demonstrates the operation of office and mail
processing machines to clerical staff;
• Determines supply needs for the work unit and
requisitions office supplies from a central stores unit;
and
• Reviews the assigning of code numbers to financial and
budgetary disbursement of funds and grants.
You state that in your position as a Clerical Supervisor
1, your core function is to develop letters and memos and
answer office telephones, while serving as secretary to the
Section Chief. You further state that during your
Commonwealth employment, you have had no involvement
with the managing and /or procuring of engineering contracts;
administering or monitoring grants or subsidies; planning or
zoning; or inspecting, licensing, regulating or auditing any
person. Since October 2006, you have been supervising a
temporary clerical pool employee, which you assert does not
give you the authority to have an economic impact on any
person.
You state that you have been pursuing an Associates
degree in Civil Engineering. You plan to resign from
Commonwealth employment effective July 13, 2007, and
pursue a career in the private sector. You state that your future
employment will consist of performing design tasks which
could include horizontal /vertical geometry, drainage design,
guide rail design, erosion control, traffic control plans, signing
Goddard, 07 -019
November 7, 2007
Page 4
stated:
and pavement marking plans, cross sections, quantity takeoffs
and cost estimating, and plan preparation.
Based upon the submitted facts, you request guidance
as to whether you would be subject to the restrictions of
Section 1103(g) of the Ethics Act upon termination of
employment with PennDOT.
Goddard, Advice of Counsel 07 -554 at 1 -3.
Advice of Counsel 07 -554 determined that in your capacity as a Clerical Supervisor
I with PennDOT, you would be considered a "public employee" subject to the Ethics Act.
The Advice of Counsel determined that you had the ability to take or recommend official
action of a non - ministerial nature that would satisfy subparagraph (5) of the statutory
definition of "public employee" (pertaining to any other activity where the official action
has an economic impact of greater than a de minimis nature on the interests of any
person" (65 Pa.C.S. § 1102)), as well as the criteria set forth in this Commission's
Regulations for determining status as a public employee, specifically at 51 Pa. Code §
11.1, subparagraphs (i) and (ii). The Advice of Counsel specifically noted your authority to
conduct interviews and make recommendations as to the selection of applicants for clerical
positions within the Consultant Agreement Section. The Advice of Counsel concluded that
in making recommendations with regard to the hiring of clerical staff in the Consultant
Agreement Section of PennDOT, your official job duties and responsibilities would have a
significant economic impact upon the interests of affected applicants as well as the
interests of taxpayers with regard to the expenditure of public funds. The Advice of
Counsel noted that your authority to prepare employee progress review reports, take
appropriate disciplinary action, recommend decisions on formal grievances, manage the
Section's Quality Assurance Program for processing and paying invoices, and perform
fiscal duties as detailed in your position description and job classification specifications,
would provide additional support for the conclusion that in your capacity as a Clerical
Supervisor I with PennDOT, you would be considered a "public employee" subject to the
provisions of the Ethics Act.
The Advice of Counsel determined that upon termination of public service with
PennDOT, you would become a "former public employee" subject to Section 1103(g) of the
Ethics Act, 65 Pa.C.S. § 1103(g). The Advice further determined that your former
governmental body would be PennDOT in its entirety, including but not limited to the
Consultant Agreement Section. The Advice set forth the restrictions of Section 1103(g) of
the Ethics Act as applicable to you. The Advice concluded that Section 1103(g) of the
Ethics Act would not prohibit you from accepting employment in the private sector. The
Advice further concluded, however, that to the extent your job duties would require
interaction with PennDOT in a manner that would constitute prohibited "representation,"
your performance of such activities would be prohibited by Section 1103(g) of the Ethics
Act during the first year following termination of your employment with PennDOT.
By letter dated July 30, 2007, you appealed Advice of Counsel 07 -554. Your letter
. I am not appealing the facts that were provided, because
they are herein true as it pertains to a Clerical Supervisor 1,
Commonwealth wide. However, I am appealing the facts that I
have not actively been supervising any one employee since
October 12, 2006, which therefore changes my entire position.
(July 30, 2007 appeal letter, at 1). You expressed your view that as of October 12, 2006,
Goddard, 07 -019
November 7, 2007
Page 5
you had absolutely no financial impact on an individual.
By way of your appeal letter and a faxed transmission received by this Commission
on October 5, 2007, you submitted the following additional facts.
Immediately following the retirement of the employee whom you had been
supervising, you submitted your resignation from Commonwealth employment, to be
effective July 13, 2007. You state that your position should have been reclassified by
PennDOT months before your departure, but because of your impending departure, a hold
was placed on reclassifying your position. At the time you submitted your request for an
Advice, the only active and /or legal position description available to you was the one that
you submitted with your initial advisory request, specifically, as a Clerical Supervisor 1.
You state that you had originally planned to begin working with an engineering firm,
Orth- Rogers & Associates ("OR &A "), in the third week of July 2007. However, you state
that after you received Advice of Counsel 07 -554, OR &A rescinded its job offer because
OR &A had planned for you to work on PennDOT projects. (You note difficulties as to the
inability of the prospective employer to submit your "billable hours" to PennDOT.) You
then rescinded your resignation, and effective July 16, 2007, you were moved to a different
position as a Clerk Typist 11 with PennDOT's Environmental Quality Assurance Division.
You state that after you left your position as a Clerical Supervisor 1, said position was
reclassified to a Clerk Typist 11 position.
You then contacted other engineering firms in an attempt to find ajob that you could
do that would not be associated with PennDOT. You state that Greenhorne & O'Mara, Inc.
( "the Firm ") offered you a position working on Pennsylvania Turnpike projects, with the
understanding that you would be unable to perform work on PennDOT projects. Since you
began employment with the Firm on August 13, 2007, you have been providing Computer
Aided Drafting (CADD) support to the engineering staff along with storm water
management calculations for the Pennsylvania Turnpike.
On October 5, 2007, you submitted a letter dated October 4, 2007, addressed to
Chief Counsel, from Michael P. Bougher, P.E., Branch Manager for the Firm's
Pennsylvania operations. Mr. Bougher stated that you are currently employed with the
Firm as an Engineering Technician 1. Your job responsibilities include providing general
engineering /CADD design support to the Firm's highway engineering group, and you have
been working internally to provide plan preparation support and general drainage
computations for the Firm's existing Pennsylvania Turnpike contracts. Mr. Bougher stated
that in your current position with the Firm, you have no involvement with the
marketing /client relations aspect of the Firm's operation. Mr. Bougher further stated that
the Firm never worked directly with you or marketed you in your previous employment with
PennDOT.
You have submitted copies of your PennDOT position descriptions for your former
positions as a Clerical Supervisor 1 (job code 00190) and a Clerk Typist 11 (job code
00220), which documents are incorporated herein by reference. Copies of the job
classification specifications for both of the aforesaid PennDOT positions have been
obtained and are also incorporated herein by reference. The Advice of Counsel accurately
summarized the material portions of your position description and job classification
specifications for your former position as a Clerical Supervisor!, which summarization we
incorporate herein by reference.
Per your PennDOT Clerk Typist 11 position description and job classification
specifications under job code 00220, your duties and responsibilities as a Clerk Typist 11
included the following:
Goddard, 07 -019
November 7, 2007
Page 6
• Performing clerical work of moderate complexity.
• Utilizing specialized clerical equipment.
• Performing skilled typing and proofreading of various documents.
• Providing secretarial services to one or more individuals.
• Determining supply needs for the mailroom and preparing supply
requisitions.
• Entering bi- weekly timesheets, maintaining the Division's leave records, and
coordinating and submitting expense statements for the Division.
• Providing training and guidance to new employees.
• Functioning as a lead worker by distributing and interpreting work
assignments, providing assistance and on-the-job training, and reviewing the
unit's work for adherence to processing standards.
• Assisting the public in completing governmental forms.
By letter dated August 9, 2007, you were notified of the date, time and location of
the public meeting at which your request would be considered.
III. DISCUSSION:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of the Ethics
Act, 65 Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester based upon the
facts that the requester has submitted. In issuing the advisory based upon the facts that
the requester has submitted, this Commission does not engage in an independent
investigation of the facts, nor does it speculate as to facts that have not been submitted. It
is the burden of the requester to truthfully disclose all of the material facts relevant to the
inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only affords a defense to the extent
the requester has truthfully disclosed all of the material facts.
Our review of this matter is de novo (Clarke, Opinion 04 -012; Spear, Opinion 04-
011): "De novo review entails, as the term suggests, full consideration of the case anew.
The reviewing body is in effect substituted for the prior decision maker and redecides the
case." D'Arciprete v. D'Arciprete, 323 Pa. Super. 430, 470 A.2d 995 (1984) (citations
omitted). See also, Hayes v. Donohue Designer Kitchen, Inc., 2003 Pa. Super. 84, 818
A.2d 1287 (2003); Commonwealth v. Krut, 311 Pa. Super. 64, 457 A.2d 114 (1983); In re
Audit of School District, 354 Pa. 232, 47 A.2d 292 (1946).
As an initial matter, we note that to determine whether the restrictions of Section
1103(g) of the Ethics Act became applicable to you upon termination of your
Commonwealth service, we must determine whether in either of your former capacities with
PennDOT, you would be considered a public employee subject to the Ethics Act.
We shall begin our analysis by reviewing the relevant provisions of the Ethics Act
and the Regulations of this Commission.
The Ethics Act defines the term "public employee" as follows:
§ 1102. Definitions
"Public employee." Any individual employed by the
Commonwealth or a political subdivision who is responsible for
taking or recommending official action of a nonministerial
nature with regard to:
Goddard, 07 -019
November 7, 2007
Page 7
(1) contracting or procurement;
(2) administering or monitoring grants or subsidies;
(3) planning or zoning;
(4) inspecting, licensing, regulating or auditing any
person; or
(5) any other activity where the official action has an
economic impact of greater than a de minimis nature on
the interests of any person.
The term shall not include individuals who are employed by
this Commonwealth or any political subdivision thereof in
teaching as distinguished from administrative duties.
65 Pa. C. S. § 1102.
The Regulations of this Commission similarly define the term "public employee"
and set forth the following additional criteria:
(ii) The following criteria will be used, in part, to
determine whether an individual is within the definition of
"public employe ":
(A) The individual normally performs his responsibility in
the field without onsite supervision.
(B) The individual is the immediate supervisor of a
person who normally performs his responsibility in the field
without onsite supervision.
(C) The individual is the supervisor of a highest level
field office.
(D) The individual has the authority to make final
decisions.
(E) The individual has the authority to forward or stop
recommendations from being sent to the person or body with
the authority to make final decisions.
(F) The individual prepares or supervises the
preparation of final recommendations.
(G) The individual makes final technical recommen-
dations.
(H) The individual's recommendations or actions are
an inherent and recurring part of his position.
(1) The individual's recommendations or actions affect
organizations other than his own organization.
(iii) The term does not include individuals who are
employed by the Commonwealth or a political subdivision of
the Commonwealth in teaching as distinguished from
administrative duties.
Goddard, 07 -019
November 7, 2007
Page 8
(iv) Persons in the following positions are generally
considered public employes:
(A) Executive and special directors or assistants
reporting directly to the agency head or governing body.
(B) Commonwealth bureau directors, division chiefs or
heads of equivalent organization elements and other
governmental body department heads.
(C) Staff attorneys engaged in representing the
department, agency or other governmental bodies.
(D) Engineers, managers and secretary- treasurers acting
as managers, police chiefs, chief clerks, chief purchasing agents,
grant and contract managers, administrative officers, housing and
building inspectors, investigators, auditors, sewer enforcement
officers and zoning officers in all governmental bodies.
(E) Court administrators, assistants for fiscal affairs
and deputies for the minor judiciary.
(F) School superintendents, assistant superintendents,
school business managers and principals.
(G) Persons who report directly to heads of executive,
legislative and independent agencies, boards and
commissions except clerical personnel.
(v) Persons in the following positions are generally not
considered public employes:
(A) City clerks, other clerical staff, road masters,
secretaries, police officers, maintenance workers, construction
workers, equipment operators and recreation directors.
(B) Law clerks, court criers, court reporters, probation
officers, security guards and writ servers.
(C) School teachers and clerks of the schools.
51 Pa. Code § 11.1.
The following terms are relevant to your inquiry and are defined in the Ethics Act as
follows:
§ 1102. Definitions
"Ministerial action." An action that a person performs
in a prescribed manner in obedience to the mandate of legal
authority, without regard to or the exercise of the person's own
judgment as to the desirability of the action being taken.
"Nonministerial actions." An action in which the
person exercises his own judgment as to the desirability of the
action taken.
Goddard, 07 -019
November 7, 2007
Page 9
65 Pa.C.S. § 1102.
As noted in the Advice of Counsel, status as a "public employee" subject to the
Ethics Act is determined by an objective test. The objective test applies the Ethics Act's
definition of the term "public employee" and the related regulatory criteria to the powers
and duties of the position itself. Typically, the powers and duties of the position are
established by objective sources that define the position, such as the job description, job
classification specifications, and organizational chart. The objective test considers what
an individual has the authority to do in a given position based upon these objective
sources, rather than the variable functions that the individual may actually perform in the
position. See, Phillips v. State Ethics Commission, 470 A.2d 659 (Pa. Cmwlth. 1984);
Eiben, Opinion 04 -002; Shienvold, Opinion 04 -001; Shearer, Opinion 03 -011. The
Commonwealth Court of Pennsylvania has specifically considered and approved this
Commission's objective test and has directed that coverage under the Ethics Act be
construed broadly and that exclusions under the Ethics Act be construed narrowly. See,
Phillips, supra.
In applying the objective test in the instant matter, we first conclude that in the
former capacity as a Clerical Supervisor I with PennDOT, you would be considered a
"public employee" subject to the Ethics Act and the Regulations of this Commission.
The first portion of the statutory definition of "public employee" includes individuals
with authority to take or recommend official action of a nonministerial nature. 65 Pa.C.S. §
1102; 51 Pa. Code § 11.1( "public employee ")(ii); see also, Reese /Gilliland, Opinion 05-
005.
The objective sources defining your position - -the official position description and job
classification specifications -- establish that as a Clerical Supervisor I with PennDOT, you
had the authority, inter alia, to do the following:
(Per Position Description)
• Prepare Employee Progress Review reports, approve employee leave, and
take appropriate disciplinary action, if necessary.
• Manage the Consultant Agreement Section's Quality Assurance Program for
processing and paying consultant invoices, which included reviewing
consultant invoices to ensure that invoice amounts were justifiable and
contractually allowable.
• Perform a variety of fiscal duties including: independently checking fiscal
forms for correct coding and amount; independently reviewing current and
previous invoices, checking for fiscal accuracy; verifying fiscal information
with engineers; verifying wage /overhead rates; and verifying contract
amounts to preclude overpayment for unauthorized items.
(Per Job Classification Specifications)
• Interview and recommend the selection of applicants for clerical positions
within the section.
• Adjust employee complaints and recommend decisions on formal grievances.
• Evaluate the performance of employees in the clerical unit supervised.
• Supervise and assign work to the subordinate clerical staff.
Based upon the above, we find that your authority included responsibility for taking
or recommending official action of a nonministerial nature with regard to category (5) of the
Goddard, 07 -019
November 7, 2007
Page 10
Ethics Act's definition of "public employee," specifically, any other activity where the
official action has an economic impact of greater than a de minimis nature on the interests
of any person." 65 Pa.C.S. § 1102.
While we agree with the Advice of Counsel that your authority to recommend the
hiring of individuals would have a significant economic impact upon the interests of
affected applicants and taxpayers, more importantly, your fiscal duties and responsibilities
as to the review of contractor invoices would bring you squarely within the Ethics Act's
definition of "public employee."
Your assertions that: (1) as of October 12, 2006, you no longer actively supervised
any one employee; and (2) PennDOT would have reclassified your position but for your
impending resignation from employment, are not controlling with regard to the
determination of your status under the Ethics Act. Rather, as noted above, status as a
"public employee" is determined based upon objective sources establishing what an
individual has the authority to do in a given position rather than on actual claimed job
performance. Given that PennDOT did not reclassify your position as a Clerical
Supervisor I while you remained employed in said position, the necessary conclusion is
that you possessed the authority provided by the official position description and job
classification specifications.
In applying the objective test to the functions of your former position as a Clerk
Typist II with PennDOT, the necessary conclusion is that in said position, you would not be
considered a "public employee" as that term is defined in the Ethics Act. Based upon an
objective review of the official position description and the job classification specifications,
as a Clerk Typist II, you were not responsible for taking or recommending official action of
a non - ministerial nature with regard to any of the five categories set forth in the Ethics
Act's definition of the term "public employee."
Having established that you would be considered a public employee subject to the
Ethics Act in the capacity as a Clerical Supervisor I with PennDOT but not in the capacity
as a Clerk Typist I I with PennDOT, we shall now apply Section 1103(g) of the Ethics Act to
the instant matter. We note that it appears to be a matter of first impression for this
Commission to address the applicability of Section 1103(g) of the Ethics Act in
circumstances where a public official /public employee shifts to a non - covered position
within the governmental body with which he is associated during the one -year period prior
to terminating public service.
Section 1103(g) of the Ethics Act applies to former public officials /public employees:
§ 1103. Restricted activities
(g) Former official or employee. - -No former public
official or public employee shall represent a person,
with promised or actual compensation, on any matter
before the governmental body with which he has been
associated for one year after he leaves that body.
65 Pa.C.S. § 1103(g). Essentially, the intendment of Section 1103(g) of the Ethics Act is
to preclude for the first year following termination of public service the obtainment of
financial gain based upon prior associations and connections with the former governmental
body, by restricting representation before the former governmental body. Confidential
Opinion, 07 -001.
Goddard, 07 -019
November 7, 2007
Page 11
Based upon the submitted fact that you served in the capacity as a Clerical
Supervisor I within the one -year period prior to terminating your Commonwealth
employment as a Clerk Typist 11, it is our conclusion that upon termination of
Commonwealth employment, you became a former public employee subject to Section
1103(g) of the Ethics Act with respect to your former position as a Clerical Supervisor 1
with PennDOT. Your shift to a Clerk Typist 11 position approximately three weeks before
leaving Commonwealth service would not alter our conclusion. To hold otherwise would
undermine the legislative intent by enabling a public official /public employee to circumvent
Section 1103(g) of the Ethics Act by simply moving to a non - covered position immediately
before leaving public office /public employment.
Based upon our analysis above, you are advised that the restrictions of Section
1103(g) of the Ethics Act would apply to you for one year following the date that you
terminated service in your former capacity as a Clerical Supervisor 1 with PennDOT.
We agree with Advice of Counsel 07-554 that your former governmental body would
be PennDOT in its entirety. See, Legislative Journal of House, 1989 Session, No. 15 at
290, 291; Sirolli, Opinion 90 -006; Sharp, Opinion 90- 009 -R.
We further determine that Advice of Counsel, 07 -554 accurately apprised you of the
nature of the Section 1103(g) restrictions and of certain important Commission precedents
pertaining to that Section. Accordingly, we adopt and incorporate herein by reference the
Advice's recitation of the Section 1103(g) restrictions.
Based upon the above analysis, we deny the appeal and affirm Goddard, Advice of
Counsel 07 -554.
Lastly, the propriety of the proposed course of conduct has only been addressed
under the Ethics Act.
IV. CONCLUSION:
As a Clerical Supervisor I employed with the Commonwealth of Pennsylvania,
Department of Transportation ( "PennDOT "), you would be considered a "public employee"
subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65
Pa.C.S. § 1101 et seq., even if you did not actually supervise any PennDOT employees.
Based upon your position description and job classification specifications for your
subsequent position as a Clerk Typist II employed with PennDOT, you would not in that
position be considered a "public employee" subject to the provisions of the Ethics Act.
Based upon the submitted facts that within the one -year period prior to termination of
Commonwealth employment with PennDOT, you held both of the aforesaid positions, you
would, upon termination of Commonwealth employment, be considered a former public
employee subject to Section 1103(g) of the Ethics Act as to your former position as a
Clerical Supervisor I with PennDOT. The restrictions of Section 1103(g) of the Ethics Act
would be applicable for one year following the date that you terminated service in your
former capacity as a Clerical Supervisor I. The former governmental body would be
PennDOT in its entirety. Advice of Counsel 07 -554 is affirmed.
Act.
The propriety of the proposed conduct has only been addressed under the Ethics
Pursuant to Section 1107(10), the person who acts in good faith on this Opinion
issued to him shall not be subject to criminal or civil penalties for so acting provided the
material facts are as stated in the request.
Goddard, 07 -019
November 7, 2007
Page 12
This letter is a public record and will be made available as such.
Finally, a party may request the Commission to reconsider its Opinion. The
reconsideration request must be received at this Commission within thirty days of the
mailing date of this Opinion. The party requesting reconsideration must include a detailed
explanation of the reasons as to why reconsideration should be granted in conformity with
51 Pa. Code § 21.29(b).
By the Commission,
Louis W. Fryman
Chair