HomeMy WebLinkAbout1335 StevensonIn Re: Cecil Stevenson
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Daneen E. Reese
Donald M. McCurdy
Paul M. Henry
Raquel K. Bergen
03 -060
Order No. 1335
7/15/04
7/20/04
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted
an investigation regarding a possible violation of the Public Official and Employee Ethics
Act, Act 9 of 1989, P.L. 26, 65 P.S. § 401 et seq., as codified by Act 93 of 1998, Chapter
11, 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of
its investigation, the Investigative Division served upon Respondent written notice of the
specific allegation(s). Upon completion of its investigation, the Investigative Division
issued and served upon Respondent a Findings Report identified as an "Investigative
Complaint." An Answer was not filed and a hearing was deemed waived. The record is
complete.
Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by Chapter
11 of Act 93 of 1998, 65 Pa.C.S. § 1101 et seq., which essentially repeats Act 9 of 1989
and provides for the completion of pending matters under Act 93 of 1998.
This adjudication of the State Ethics Commission is issued under Act 93 of 1998
and will be made available as a public document thirty days after the mailing date noted
above. However, reconsideration may be requested. Any reconsideration request must be
received at this Commission within thirty days of the mailing date and must include a
detailed explanation of the reasons as to why reconsideration should be granted in
conformity with 51 Pa. Code § 21.29(b). A request for reconsideration will not affect the
finality of this adjudication but will defer its public release pending action on the request by
the Commission.
The files in this case will remain confidential in accordance with Chapter 11 of Act
93 of 1998. Any person who violates confidentiality of the Ethics Act is guilty of a
misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than
one year. Confidentiality does not preclude discussing this case with an attorney at law.
Stevenson, 03 -060
Page 2
I. ALLEGATION:
That Cecil Stevenson, a (public official /public employee) in his capacity as a Supervisor
of Greenwood Township, Crawford County, violated the following provisions of the State
Ethics Act (Act 93 of 1998) when he used the authority of his office for the private
pecuniary gain of himself and /or a business with which he is associated, including but not
limited to participating in discussions and actions of the board of supervisors resulting in
his company, Stevenson Enterprises, being utilized by the township for welding and
fabricating services; and when Stevenson participated in approving payments to
Stevenson Enterprises.
Section 1103. Restricted activities.
(a) Conflict of interest. - -No public official or public
employee shall engage in conduct that constitutes a conflict
of interest.
65 Pa. C. S. §1103(a).
Section 2. Definitions
"Conflict" or "conflict of interest." Use by a public official or
public employee of the authority of his office or employment or
any confidential information received through his holding
public office or employment for the private pecuniary benefit of
himself, a member of his immediate family or a business with
which he or a member of his immediate family is associated.
"Conflict" or "conflict of interest" does not include an action
having a de minimis economic impact or which affects to the
same degree a class consisting of the general public or a
subclass consisting of an industry, occupation or other group
which includes the public official or public employee, a
member of his immediate family or a business with which he or
a member of his immediate family is associated.
65 P.S. §1102.
II. FINDINGS:
1. The Investigative Division of the State Ethics Commission received information
alleging that Cecil Stevenson violated provisions of the State Ethics Act (Act 93 of
1998).
2. Upon review of the information the Investigative Division initiated an own - motion
preliminary inquiry on October 21, 2003.
3. The preliminary inquiry was completed within sixty days.
4. On December 15, 2003, a letter was forwarded to Cecil Stevenson by the
Investigative Division of the State Ethics Commission informing him that a complaint
against him was received by the Investigative Division and that a full investigation
was being commenced.
a. Said letter was forwarded by certified mail, no. 7002 3150 0000 6075 5096.
b. The domestic return receipt bore the signature of Cecil Stevenson, with a
delivery date of December 17, 2003.
5. Periodic notice letters were forwarded to Cecil Stevenson in accordance with the
provisions of the Ethics Law advising him of the general status of the investigation.
Stevenson, 03 -060
Page 3
6. The Investigative Complaint was mailed to the Respondent on June 4, 2004.
7. Cecil L. Stevenson has served as a Supervisor for Greenwood Township, Crawford
County from January 1992 through the present.
a. Stevenson has served as the Chairman of the Board of Supervisors in each
of the years since 1992.
b. Stevenson served a previous term as supervisor prior to his current service.
8. Greenwood Township is a second -class township governed by a three - member
board of supervisors.
a. The board typically holds one regularly scheduled public meeting per month.
9. The township does not have an administrative building or office.
a. A part -time township secretary works from her home.
b. Bills and invoices for the township are typically sent to the township
secretary at her home.
c. The secretary prepares a bill list of all bills received from the date of the last
supervisors meeting to present to the supervisors at their meetings.
d. All invoices are pre- approved for payment by the supervisors.
e. The secretary prepares checks for the supervisors to sign after the approval
of the bill lists.
10. The supervisors vote to pay outstanding bills at regular public meetings.
a. Bill lists are voted on in their entirety.
b. Motions made and seconds are recorded but individual votes are not noted.
c. Abstentions and negative votes are noted in the meeting minutes when they
occur.
11. All three of the supervisors and the township secretary have signature authority on
township financial accounts.
a. Township checks require the signatures of the secretary and any two
supervisors.
b. Checks are signed randomly by the supervisors present at a meeting after
the approval of the bill lists.
11. Since 1979 Stevenson has operated a private business known as Stevenson
Enterprises.
a. Stevenson Enterprises is a welding, repair, and fabrication business
operated from a garage at Stevenson's residence.
b. Stevenson Enterprises was registered as a Fictitious Name with the PA
Department of State on May 14, 1979.
c. Cecil L. Stevenson and Joyce J. Stevenson are listed as the owners of
Stevenson Enterprises.
1. Joyce J. Stevenson is Stevenson's wife.
Stevenson, 03 -060
Page 4
d. From July 1995 through 1998, Stevenson Enterprises was operated as a
partnership between Stevenson and his son Douglas Stevenson.
1. The partnership was dissolved in 1998 because the business could
not support two partners.
e. From 1998 through the present, Cecil Stevenson has been the only
employee of the business.
12. For numerous years, Stevenson Enterprises has done various welding, fabrication,
and repairs for the Township.
a. Stevenson has done work for the Township prior to, in between, and during
his service as a supervisor for the Township.
13. Township employees have initiated repair services performed by Stevenson.
a. The township employees contact Stevenson either telephonically or deliver
the vehicles or equipment to Stevenson's shop when work is needed.
1. The township employees were aware of Stevenson's business.
b. The township employees were not directed or encouraged to utilize the
services of Stevenson Enterprises by Stevenson or other members of the
board of supervisors.
c. Several of the township employees have personally utilized the services of
Stevenson Enterprises.
14. The township employees were required to receive the approval of a supervisor to
have repairs of township vehicles or equipment completed by an outside contractor.
a. This included work performed by Stevenson Enterprises.
15. Stevenson was typically the supervisor who gave the approval to the employees for
repairs due to his availability.
a. Stevenson's shop was located in the township and he was typically available
during normal workdays.
b. The other supervisors were not readily available during normal work hours
because of their full -time employment.
16. Stevenson authorized the repairs of Township vehicles and equipment be made by
his company.
a. Stevenson did not seek formal approval of the other supervisors regarding
the repairs.
b. From November 2001 through December 2003 Supervisor Ray Nader
served as the full -time roadmaster and would have been aware of repairs
performed by Stevenson.
1. Only two repairs were performed by Stevenson after Nader's hiring as
township roadmaster.
17. Stevenson submitted invoices from Stevenson Enterprises directly to the township
secretary for payment.
a. None of the individual repairs completed by Stevenson Enterprises
exceeded $500.00.
Invoice
Date
(No.)
Amount
Description
08 -04 -98
$250.00
Balance Due on Account
09 -22 -98
313
Case Loader
Weld and Remach Bucket Pins
Mach New Bushings- 5 Hrs.
R/R Shoes on Bucket
Assemble Unit- 3 Hrs.
HT Bushings- $25.00
09 -28 -98
54.00
R/R Lift Knuckle for Blade on Grader- 1.5 Hrs
11 -04 -98
591.47
Weld and Patch on Int. (79) Bed Floor- $54.00
Mach & Sleeve Axle for Int. (79)- $180.00
Install New Packing and Piston Rod w/ Hyd. Cyl. for
Chevy Dump- $357.47
11 -20 -98
108.00
Fabricate Guard for Blinker Lite
Remachine Ratchet bracket for Spreader (3 Hrs)
12 -22 -98
54.00
Straighten and Repair Spreader on '91 Int. Truck -
1.5 Hrs.
01 -13 -99
32.00
4- Plow Pins
5 1/2" LG 1 1/4 Drill p End- $8.00 Each
01 -20 -99
72.00
Weld Eye of Lift Cylinder '90 Int- 2 Hrs
03 -22 -99
18.00
Straighten Lift Arm for Plow
03 -26 -99
69.61
3/4 Drop 12 "X60"
04 -02 -99
142.00
Weld Guard Rails (Hafers)- $72.00
3/4 Drop 12 "X60 " - $70.00
06 -02 -99
165.74
Repair and Rebuild Pump (Brine)- 4 Hrs.
Brg- 6202 2RS- $8.05
Brg- 6302 2RS- $13.69
06 -28 -99
54.00
Weld Lifting Ball on Grader #80- $27.00
Weld Wheel for Massey Ferguson #100- $27.00
02 -04 -00
25.00
Machine Pin for '00 Truck
02 -21 -00
224.00
6 Pcs. -1 1 /2 "X6 1/2"X15"- $194.00
6 Pcs. -1 /8 "X1 1/2"X12"- $30.00
04 -15 -00
16.00
1 -3/8 Pitch 72 Links Chainsaw Chain- $16.00
06 -13 -00
(483313)
78.00
20-1/2" 5 "X12- $3.90 Each
06 -16 -00
(483319)
45.00
Rent Welder 1 Day
08 -07 -00
(483354)
108.00
Weld and Remachine Hydraulic Pump Shaft for
Tiger- 3 Hrs.
1 Seal Kit
Stevenson, 03 -060
Page 5
b. Some repairs to multiple vehicles were included on one invoices.
18. Stevenson Enterprises submitted twenty -five (25) invoices, totaling $3,457.12, to
the Township from August 1998 through April 2002 as follows:
Invoice
Date
(No.)
Amount
Description
10-16-00
Vote
to
Pay
(481145)
60.00
Face Flywheel to Clean (Tiger Mower)
$250.00
08 -04 -98
Repair Housing for Tiger Mower- $25.00
10 -27 -00
(481153)
65.00
New Pivot Pin
751 -State
367.00
Repair and Install Bushings- $40.00
12 -04 -00
(481174)
315.00
Fabricate (7) Shoes for Snowplow- $45.00 Each
03 -09 -01
(481215)
72.00
Weld Eye on Piston Cyl. for International `90
11 -04 -98
11 -20 -98
No
2 -1 /2 "X12X20- $30.60
12 -05 -01
43.30
1-1/4X3X34X30- $5.00
(423281)
12 -22 -98
1 -8 "'C' 11.5 #X20 " - $7.70
3 -0
Yes
Mat'I for Rockcreek Bridge
03 -05 -02
104.00
8 -Plow Shoes Fabricate ($55.00 Each)- $440.00
423311
( )
482.00
5 -Flat Shoes Drill /Tap CFM.- $42.00
Total:
$3457.12
87.61
Check
Date
Check
No./
Fund
Check
Amount
Date of
Invoice(s)
(Invoice
No.(s))
Sign
Check
Vote
to
Pay
Official
Action
08 -03 -98
729 -State
$250.00
08 -04 -98
No
3 -0
Yes
10 -05 -98
751 -State
367.00
09 -22 -98
09 -28 -98
No
3 -0
Yes
12 -07 -98
779 -State
699.47
11 -04 -98
11 -20 -98
No
3 -0
Second
12 -30 -98
785 -State
54.00
12 -22 -98
Yes
3 -0
Yes
02 -01 -99
797 -State
104.00
01 -13 -99
01 -20 -99
Yes
2 -0
Second
04 -05 -99
816 -State
87.61
03 -22 -99
03 -26 -99
No
3 -0
Yes
05 -03 -99
823 -State
142.00
04 -02 -99
No
2 -0
Absent
06 -07 -99
836 -State
165.74
06 -02 -99
Yes
3 -0
Yes
07 -06 -99
843 -State
54.00
06 -28 -99
No
3 -0
Yes
02 -07 -00
2832 -Gen
25.00
02 -04 -00
Yes
2 -0
Second
03 -06 -00
2866 -Gen
224.00
02 -21 -00
No
3 -0
Yes
05 -01 -00
911 -State
16.00
04 -15 -00
Yes
3 -0
Yes
Stevenson, 03 -060
Page 6
19. The board of supervisors took no official action at board meetings to approve
Stevenson Enterprise to perform any work for which the Township was invoiced.
a. The remaining members of the board of supervisors were aware that
Stevenson was performing the work and informally agreed Stevenson could
complete the service.
20. Between August 1998 and April 2002 nineteen (19) checks were issued by the
Township in payment of the invoices submitted by Stevenson Enterprises.
21. Stevenson participated in board actions approving payment to Stevenson
Enterprises and signed checks, as an authorized signer of the Township issued to
Stevenson Enterprises as follows:
Check
Date
Check
No./
Fund
Check
Amount
Date of
Invoice(s)
(Invoice
No.(s))
Sign
Check
Vote
to
Pay
Official
Action
07 -03 -00
927 -State
123.00
483313
483319
Yes
3 -0
Yes
09 -05 -00
948 -State
108.00
483354
No
3 -0
Second
11 -06 -00
969 -State
125.00
481145
481153
Yes
3 -0
Second
12 -28 -00
3244 -Gen
315.00
481174
No
3 -0
Yes
04 -02 -01
3373 -Gen
72.00
481215
No
3 -0
Yes
12 -28 -01
3664 -Gen
43.30
423281
No
3 -0
Yes
04 -01 -02
1222 -State
482.00
422211
No
2 -0 -1
Abstain
Total:
$3457.12
Stevenson, 03 -060
Page 7
22. Stevenson voted to approve payment of 17 of 19 checks issued to Stevenson
Enterprises.
a. Stevenson was absent from the meeting that check no. 823 was approved
for payment.
b. Stevenson abstained from the vote to approve payment of check no. 1222.
1. No reason is noted nor could Stevenson recall the reason for the
abstention.
2. The Department of Auditor General was auditing the township liquid
fuel account during this period.
c. Stevenson did not publicly disclose his affiliation with Stevenson Enterprises
at any time when voting to approve payments to his company.
23. Stevenson signed 7 of 19 checks issued Stevenson Enterprises.
a. Stevenson utilized a signature stamp to affix his signature on some of the
checks.
b. The signature stamp was not utilized by anyone other than Stevenson.
c. Stevenson utilized the signature stamp rather than writing his name on
numerous documents.
24. Stevenson Enterprises received income from Greenwood Township totaling
$3,457.12 from August 1998 through April 2002 by year as follows:
a. 1998: $1,370.47
b. 1999: $ 553.35
c. 2000: $ 936.00
d. 2001: $ 115.30
e. 2002: $ 482.00
25. Stevenson Enterprises typically charges $42.00 per hour for labor and a mark -up of
30% on materials.
a. Stevenson did charge the township these rates when repairing township
equipment.
Year
Gross Income
(Total Income)
Net Profit
(Ord. Income)
Percent of
Profit
1998
$53,076
- $2,166
(Loss)
1999
$11,602
$3,406
29.4
2000
$22,739
- $9,460
(Loss)
2001
$23,199
$1,693
7.3
2002
$10,655
- $7,183
(Loss)
2003
$28,754
$14,146
49.1
Stevenson, 03 -060
Page 8
26. In or around May 2002, the Department of Auditor General concluded its audit of
the township's Liquid Fuels Tax Fund for the period of January 1, 1999 through
December 31, 2000.
a. The audit report noted possible related party transactions including
transactions involving Stevenson Enterprises.
b. The audit report recommended that the township comply with the Second
Class Township Code.
c. The township officials offered no official response to this finding.
1. The township secretary and a member of the board of auditors signed
off on the audit report.
27. In a Sworn Statement provided to an investigator of the State Ethics Commission on
May 14, 2004 and May 24, 2004, Stevenson confirmed the following:
a. He made the decision to have his company complete work for the Township.
b. There was never any official board action approving his business to do work
for the Township.
c. He participated in board actions, including approving payments and signing
checks, related to Stevenson Enterprises.
d. He gave a discount (less than $42.00 per hour for labor) on many of the jobs
or did not charge the Township for work performed.
e. He was not aware of the provisions of the State Ethics Act as they relate to
conflicts of interest.
f. He has not done any work for the Township since April 2002 following
Nader's hiring as roadmaster.
1. Nader has the expertise to do the work that Stevenson Enterprises
did for the Township.
28. Stevenson Enterprises percent of profit in each of the years 1998 through 2003,
based on IRS tax filings, were as follows:
a. Stevenson did no business with the township in 2003.
b. The percent of profit was calculated by dividing the business' gross income
(total income) by its net profit (ordinary income) in each year.
29. Stevenson's average annual profit for the period 1998 through 2002 was 7.24 %.
a. Based on $3,457.12 in payments made by the township divided by the
average annual profit Stevenson realized a private pecuniary gain of
$250.30.
Stevenson, 03 -060
Page 9
III. DISCUSSION:
At all times relevant to this matter, the Respondent, Cecil Stevenson, hereinafter
Stevenson, has been a public official subject to the provisions of the Public Official and
Employee Ethics Law, Act 9 of 1989, Pamphlet Law 26, 65 P.S. § 401, et seq., as codified
by the Public Official and Employee Ethics Act, Act 93 of 1998, Chapter 11, 65 Pa.C.S. §
1101 et seq., which Acts are referred to herein as the "Ethics Act."
The allegations are that Stevenson, as a Supervisor of Greenwood Township,
Crawford County, violated Section 3(a)/1103(a) of the Ethics Act when he approved his
company, Stevenson Enterprises, to be used for township welding and fabricating services
and participated in approving payments to Stevenson Enterprises.
Pursuant to Section 3(a)/1103a) of the Ethics Act quoted above, a public official/
public employee is prohibited from engaging in conduct that constitutes a conflict of
interest.
Section 3(a)/1103(a) of the Ethics Act prohibits a public official /public employee
from using the authority of public office /employment or confidential information received by
holding such a public position for the private pecuniary benefit of the public official /public
employee himself, any member of his immediate family, or a business with which he or a
member of his immediate family is associated.
facts.
Having noted the issues and applicable law, we shall now summarize the relevant
Stevenson has served as supervisor on the three - member board in Greenwood
Township, Crawford County, since January of 1992. The supervisors vote to pay outstanding
bills at regular public meetings. Motions and seconds are recorded but individual votes
are not. Abstentions and negative votes are noted. All three supervisors and the township
secretary have signature authority on township financial accounts. Township checks
require the signatures of the secretary and any two supervisors.
In a private capacity, Stevenson operates a private business known as Stevenson
Enterprises which is a welding, repair, and fabrication business. Stevenson Enterprises is
a registered fictitious name with Stevenson and his spouse listed as the co- owners. For
many years, Stevenson Enterprises has done various welding, fabrication, and repairs for
the township.
Township employees typically initiate repair services by contacting Stevenson.
Such employees are neither directed nor encouraged to utilize the services of Stevenson
Enterprises by Stevenson or other board members. However, the township employees are
required to receive approval of a supervisor for repairs of township vehicles or equipment
when provided by an outside contractor. Since Stevenson as a supervisor was most
readily available during normal work hours, the employees typically went to Stevenson to
obtain approval for repair services.
Stevenson authorized repairs of township vehicles and equipment by Stevenson
Enterprises without seeking formal approval of the other two supervisors. Stevenson then
submitted the invoices from Stevenson Enterprises directly to the township secretary for
payment. None of the repairs individually exceeded $500.00. The details of the various
jobs performed by Stevenson Enterprises for the township as well as the amounts of
invoices and dates are delineated in Fact Finding 18.
Although the board of supervisors never took official action to approve Stevenson
Enterprises to perform any work for the township, the other two supervisors knew that
Stevenson performed the work and then agreed that Stevenson could perform such
services. Between August 1998 and April 2002, 19 checks were issued by the township to
Stevenson, 03 -060
Page 10
Stevenson Enterprises totaling $3,457.12. The particulars as to the individual checks are
detailed in Fact Finding 21. Stevenson voted to approve payment of 17 of the 19 checks
issued to Stevenson Enterprises and also co- signed 7 of those checks.
In May of 2002, when the Department of Auditor General concluded an audit of the
township's liquid fuels tax fund, the audit noted possible related party transactions
involving Stevenson Enterprises and recommended the township comply with the Second
Class Township Code.
Stevenson has confirmed the following: he made the decisions to have his
company perform work for the township, the board never took official action to approve his
business to do the work, he participated in board actions including approving payments
and co- signing checks to his business, he gave a discount or did not charge the township
for work performed as to certain jobs, he did not know the provisions of the State Ethics
Act as they relate to conflicts of interest, and he has not done any work for the township
since April of 2002 with the hiring of the roadmaster. Of the $3,457.12 in payments to
Stevenson Enterprises by the township, Stevenson obtained a private pecuniary gain of
$250.30, based upon an average annualized profit of 7.24 %.
Having summarized the above relevant facts, we must now determine whether the
actions of Stevenson violated Section 3(a)1103(a) of Act 9 of 1989.
In applying Section 3(a)/1103(a) of the Ethics Act to the instant matter, there were
uses of authority of office on the part of Stevenson. But for the fact that Stevenson is a
township supervisor, he would not have been in a position to give the approvals to
township employees who wanted to utilize Stevenson Enterprises to perform various
repairs or services as to township property. In addition, Stevenson participated in
approving invoices as to Stevenson Enterprises as well as co- signing checks to Stevenson
Enterprises in payment for services rendered to the township. All such actions were uses
of authority of office. See, Juliante, Order 809. The uses of authority of office resulted in
private pecuniary benefits consisting of the profits that Stevenson Enterprises made on the
repair and service contracts with the township. Lastly, the private pecuniary benefits
inured to either Stevenson individually or Stevenson Enterprises, "a business with which . .
.. associated" as that term is defined under the Ethics Act. See, 65 P.S. § 402/65 Pa.C.S.
§1102. Accordingly, Stevenson violated Section 3(a)/1103(a) of the Ethics Act when he
gave approvals to township employees to utilize Stevenson Enterprises, a business with
which he is associated, to perform repair services for the township. Further, Stevenson
technically violated Section 3(a)/1103(a) of the Ethics Act when he participated in
approving invoices and co- signed checks in payment to Stevenson Enterprises for various
repairs or services performed as to township property. See, Luzier, Order 1300; Doaty,
Order 1221.
Section 7(13)/1107(13) of the Ethics Act empowers this Commission to impose
restitution in instances where a public official /public employee has obtained a financial
gain in violation of the Ethics Act. Accordingly, Stevenson is directed within 30 days of the
date of mailing of this Order to make payment of restitution to the Commonwealth of
Pennsylvania through this Commission in the amount of $250.30. Compliance with the
foregoing will result in the closing of this case with no further action by this Commission.
Non - compliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. Stevenson, as a Supervisor in Greenwood Township, is a public official subject to
the provisions of Act 9 of 1989 as codified by Act 93 of 1998.
2. Stevenson violated Section 3(a)/1103(a) of the Ethics Act when he gave approvals
to township employees to utilize Stevenson Enterprises, a business with which he is
associated, to perform repair services for the township.
Stevenson, 03 -060
Page 11
3. Stevenson technically violated Section 3(a)/1103(a) of the Ethics Act when he
participated in approving invoices and co- signed checks in payment to Stevenson
Enterprises for various repairs or services performed for the township.
In Re: Cecil Stevenson
File Docket: 03 -060
Date Decided: 7/15/04
Date Mailed: 7/20/04
ORDER NO. 1335
1 Stevenson, as a Supervisor in Greenwood Township, Crawford County, violated
Section 3(a)/1103(a) of the Ethics Act when he gave approvals to township
employees to utilize Stevenson Enterprises, a business with which he is associated,
to perform repair services for the township.
2. Stevenson technically violated Section 3(a)/1103(a) of the Ethics Act when he
participated in approving invoices and co- signed checks in payment to Stevenson
Enterprises for various repairs or services performed for the township.
3. Stevenson is directed within 30 days of the date of mailing of this Order to make
payment in the amount of $250.30 to the Commonwealth of Pennsylvania through
this Commission.
a. Compliance with the foregoing will result in the closing of this case with no
further action by this Commission.
b. Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
Louis W. Fryman, Chair