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HARRISBURG, PA 17120-0400
In Re: Gary Deck, File Docket: 24-0135-C
Respondent Order No. 1850
Date Decided: 10/10/25
Date Mailed: 10/10/25
Before: David L. Reddecliff, Vice Chair
Paul E. Parsells
Robert P. Caruso
Emilia McKee Vassallo
This is a final adjudication of the State Ethics Commission.t
FACSIMILE: 717-787-0805
WEBSITE: www.ethics,pa.gov
Procedurally, the Investigative Division of the State Ethics Commission conducted an
investigation regarding possible violation(s) of the Public Official and Employee Ethics Act
(`Ethics Act"), 65 Pa.C.S. § 1101 et sect., by the above -named Respondent. At the commencement
of its investigation, the Investigative Division served upon Respondent written notice of the
specific allegations. Upon completion of its investigation, the Investigative Division issued and
served upon Respondent a Findings Report identified as an "Investigative Complaint." A
Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to
the Commission for consideration. The Findings in this Order are derived from the parties'
Stipulation of Findings. The Consent Agreement has been approved.
L ALLEGATIONS:
That Gary Deck, a public official in his capacity as a Supervisor for Tulpehocken
Township, Berks County, Pennsylvania, violated Sections 1103(a) and 1105(b)(3) of the Ethics
Act:
(1) When he used the authority of his office to award a contract to H&K Group, Inc., a
business with which he is associated, resulting in a private pecuniary benefit to
H&K Group, Inc.; and
(2) Whcn he failed to disclose any direct or indirect interest in any real estate which
was sold or leased to the Commonwealth, any of its agencies or political
subdivisions, or purchased or leased from the Commonwealth, any of its agencies
or political subdivisions, or which was the subject of any condemnation
proceedings by the Commonwealth, any of its agencies or political subdivisions,
on his Statement of Financial Interests for calendar year 2023.
E Chair Michael A. Schwartz recused himself from this platter and did not participate in the deliberations involving
this case.
Deck, 24-0135-C
Page 2
II. FINDINGS:
1. Tulpehocken Township ("Township") is a Second Class Township in Berks County,
Pemisylvania, and it is governed by a Board of Supervisors ("Board") that consists of three
Members.
2. Gary Deck ("Deck") has served as a Township Supervisor since 2012.
a. Deck was appointed as the Board's Chairperson in January 2014.
3. Deck is employed as a Regional Superintendent with the H&K Group, Inc. ("H&K
Group").
a. H&K Group employs approximately 2,000 employees that provide heavy civil
contracting and construction materials and services.
4. Deck is a salaried employee of H&K Group.
a. His responsibilities as Regional Superintendent include the oversight of scheduling
personnel, assets, and materials for a project and ensuring completion, and
addressing any issues that arise during such projects.
5. During a Board meeting held on February 9, 2022, Township Supervisor and Township
Roadmaster Lester Feick ("Feick") discussed his intent to resurface Witman Road.
a. The Township Roadmaster determines and suggests annual roadway projects to the
Board for approval.
6. During that same meeting, Feick made a motion to authorize the packet preparation and
advertise the bid for resurfacing Witman Road.
a. The motion was seconded by Vice Chairperson Harry Reinhold ("Reinhold") and
passed unanimously (2-0).
Deck was absent from the meeting.
7. On May 5, 2022, the Township prepared and submitted, through the "MediaNews Group,"
a Request for Proposal in the Reading Eagle and Reading Eagle Digital to solicit sealed
bids for the Witman Road paving project.
a, The advertisement ran on May 6, 2022, and May 12, 2022.
b. The deadline to submit sealed proposals for the project was listed as May 24, 2022,
at 10:00 a.m.
8. The minutes of the May 11, 2022, Board meeting show the following:
Deck, 24-0135-C
Page 3
a. Feick, during the Township Roadmaster's Report, referenced "meeting with
PemiDOT for the road paving project this summer," and cited numerous meetings
with the Township Engineer.
b. Feick made a motion to advertise a special meeting to be held at the Township
Building on Tuesday, May 24, 2022, at 5:00 p.m., for bid opening related to the
Witman Road paving project and any other business.
This motion was seconded by Reinhold and passed unanimously (3-0), with
Deck participating in the vote.
aa. The Township typically opens sealed bids and awards contracts for
roadway projects during regularly scheduled and advertised Board
meetings.
bb. Citing contractor scheduling concerns, project completion prior to
the school year and potential impact on bus routes, and the
fluctuating liquid fuels price, Feick motioned for the special meeting
to expedite the process.
C. Reinhold submitted a resignation letter effective May 12, 2022.
d. Feick made a motion to accept Reinhold's resignation which was seconded by Deck
and passed (2-0), with Reinhold abstaining from the vote.
e. There was no mention of tabling the special meeting and actions regarding the
award of the road paving contract to be held on May 24, 2022.
f. There was no mention of asking Reinhold to remain on the Board for the sealed bid
opening and defer his resignation effective date until after May 24, 2022.
9. Reinhold resigned on May 12, 2022.
10. Deck advised Commission Investigators that he did not consider tabling or delaying the
May 24, 2022, special meeting in light of Reinhold's resignation.
11. Deck advised Commission Investigators that he did not consider asking Reinhold to delay
his resignation in light of the upcoming May 24, 2022, special meeting.
12. On May 12, 2022, the Township, through the "MediaNews Group," advertised a notice to
hold a special meeting in the Reading Eagle and Reading Eagle Digital for the purpose of
opening sealed bids for the Witman Road paving project.
a. The meeting date was advertised for Tuesday, May 24, 2022, at 5:00 p.m. at the
Township Municipal Building.
13. The special meeting for the purpose of opening the sealed bids for the Witman Road paving
project was held on May 24, 2022.
Deck, 24-0135-C
Page 4
a. The following people were in attendance: Deck, Feick, and Harold Zimmerman
("Zimmerman"), and Deck's wife.
1. The third Township Supervisor seat was vacant.
2. The Township Solicitor was not present.
Zimmerman submitted a letter of interest for the vacant Township
Supervisor seat at this inneeting.
b. Despite being presented with Zimmerman's interest in the Board vacancy, there
was no suggestion made to table the vote to award the Witman Road paving project
until a full Board was seated.
14. The Township is required to accept the lowest responsible bid (payment and performance
bonds and insured), subject to final review by the Township Solicitor.
15. The sealed bids are opened, read aloud, and passed annong the Township Supervisors for
review before action.
16. The bids obtained by the Township for the Witman Road paving project and opened for
review during the May 24, 2022, special meeting included;
• CMS - $119,685.00
• H&K Group - $103,675.65
• New Enterprise Stone & Lime - $104,777.70
17. Deck seconded Feick's motion to award the Witman Road paving project to H&K Group
for the amount of $103,675.65.
a. After revealing the bid values, Feick advised that there was room in the budget to
add an additional 2110" of depth to the paving project.
b. Subsequent project changes and price index adjustments for materials increased the
final total cost of the Witman Road paving project to $121,795.84.
18. Deck voted to award the Witman Road paving project to H&K Group.
a. Previous meeting minutes show that Deck had abstained in the past from votes that
would benefit H&K Group.
b. Investigation revealed that discussion took place at this meeting regarding Deck's
concerns about voting.
The minutes of the special meeting on May 24, 2022, do not indicate that
any such discussion took place.
Deck, 24-0I35-C
Page 5
19. Project documentation from H&K Group contained copies of a completed and signed
PennDOT Form MS-944, "Proposal and Contract (When Executed)."
a. H. Christian Budenz, the Executive Vice President and the Director of
Administration for H&K Group, signed the completed PennDOT Form MS-944 on
behalf of the contractor for the Witman Road paving project.
b. The form was signed and accepted on behalf of the Township by Township
Supervisors Deck, Feick, and Zimmerman on June 14, 2022.
20. Deck had no direct involvement in the planning, estimating, or completion of this project
as an employee of H&K Group.
a. H&K Group did not award any commission or bonus to Deck as the direct result of
this project.
21. On September 14, 2022, the Township issued check #228 made payable to "H&K Group,
Inc." in the amount of $121,795.84.
a. The check possessed the signatures, or representations thereof, of Deck, Feick, and
Zimmerman, along with that of the Township Secretary/Treasurer.
22. Deck filed a deficient Statement of Financial Interests For the 2023 calendar year when he
failed to report any direct or indirect interest in any real estate which was sold or leased to
the Commonwealth or any of its agencies or political subdivisions.
III. DISCUSSION:
As a Supervisor for Tulpehocken Township ("Township"), Berks County, Pennsylvania,
since 2012, Gary Deck ("Deck") has been a public official subject to the provisions of the Public
Official and Employee Ethics Act ("Ethics Act"), 65 Pa. C.S. § 1101 et se.�..,
The relevant allegations in this matter are that Deck violated Sections 1103(a) and
1105(b)(3) of the Ethics Act:
(1) When he used the authority of his office to award a contract to H&K Group, Inc., a
business with which he is associated, resulting in a private pecuniary benefit to
H&K Group, Inc.; and
(2) When he failed to disclose any direct or indirect interest in any real estate which
was sold or leased to the Commonwealth, any of its agencies or political
subdivisions, or purchased or leased from the Commonwealth, any of its agencies
or political subdivisions, or which was the subject of any condemnation
proceedings by the Commonwealth, any of its agencies or political subdivisions,
on his Statement of Financial Interests ("SFI") for calendar year 2023.
Sections 1103(a) and 11030) of the Ethics Act provide;
Deck, 24-0135-C
Page 6
§ 1103. Restricted activities
(a) Conflict of interest. -- No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
0) Voting conflict. -- Where voting conflicts are not
otherwise addressed by the Constitution of Pernisylvania or by any
law, rule, regulation, order or ordinance, the following procedure
shall be employed. Any public official or public employee who in
the discharge of his official duties would be required to vote on a
matter that would result in a conflict of interest shall abstain from
voting and, prior to the vote being taken, publicly announce and
disclose the nature of his interest as a public record in a written
memorandum filed with the person responsible for recording the
minutes of the meeting at which the vote is taken, provided that
whenever a governing body would be unable to take any action on
a matter before it because the number of members of the body
required to abstain from voting under the provisions of this section
makes the majority or other legally required vote of approval
unattainable, then such members shall be permitted to vote if
disclosures are made as otherwise provided herein. In the case of a
three -member governing body of a political subdivision, where one
member has abstained from voting as a result of a conflict of interest
and the remaining two members of the governing body have cast
opposing votes, the member who has abstained shall be permitted to
vote to break the tie vote if disclosure is made as otherwise provided
herein.
65 Pa.C.S. §§ 1103(a), 11030).
The following terms related to Section 1103(a) are defined in the Ethics Act as follows:
§ 1102. 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.
The term 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.
Deck, 24-0135-C
Page 7
"Authority of office or employment." The actual power
provided by law, the exercise of which is necessary to the
performance of duties and responsibilities unique to a particular
public office or position of public employment.
"Business." Any corporation, partnership, sole
proprietorship, firm, enterprise, franchise, association, organization,
self-employed individual, holding company, joint stock company,
receivership, trust or any legal entity organized for profit.
"Business with which he is associated." Any business in
which the person or a member of the person's immediate family is a
director, officer, owner, employee or has a financial interest.
65 Pa.C.S. § 1102.
Subject to the statutory exclusions to the Ethics Act's definition of the term "conflict" or
"conflict of interest," 65 Pa.C.S. § 1102, a public official/public employee is prohibited from using
the authority of public office or confidential information received by holding such a public position
for the private pecuniary (financial) 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. The use of authority of office is not limited merely to voting but extends to any use
of authority of office including, but not limited to, discussing, conferring with others, and lobbying
for a particular result. 3uliante, Order 809.
In each instance of a conflict of interest, a public official/public employee would be
required to abstain from participation, which would include voting unless one of the statutory
exceptions of Section 11030) of the Ethics Act would be applicable. Additionally, the disclosure
requirements of Section 11030) of the Ethics Act would have to be satisfied in the event of a voting
conflict.
In Garner, Opinion 93-004, this Commission concluded that Section 11030) of the Ethics
Act would allow a member of a three -member board of supervisors with a conflict of interest to
second a motion where the remaining two non -conflicted members would have opposing views or
where one of the two non -conflicted members would be absent. As long as the member with a
conflict would initially abstain from the vote and fully satisfy the disclosure requirements of
Section 11030), the member with a conflict would then be permitted to vote to break the tie if the
two non -conflicted members would cast opposing votes. Garner, supra. However, even if there
is a vacancy on a three -member board of supervisors or one of two non -conflicted members is
absent, there is no basis under Section 11030) for voting by a member who has a conflict of
interest. See, Urtz, Order 1274,
Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a
person required to file the SFI form must provide.
Section 1105(b)(3) of the Ethics Act requires the filer to disclose on the SFI any direct or
indirect interest in any real estate which was sold or leased to or purchased or leased from the
Commonwealth, any of its agencies or political subdivisions, or which was the subject of any
condemnation proceedings by the Conunonwealth or any of its agencies or political subdivisions.
Deck, 24-0135-C
Page 8
As noted above, the parties have submitted a Consent Agreement and a Stipulation of
Findings. The Findings of this Commission set forth above are derived from the parties'
Stipulation of Findings. We shall now summarize the relevant facts in this matter.
The Township is governed by a three -Member Board of Supervisors ("Board"). Deck has
served as a Township Supervisor since 2012, and he was appointed as Chairperson of the Board
in 2014.
In a private capacity, Deck is employed as a Regional Superintendent with H&K Group,
Inc. ("H&K Group"), which provides heavy civil contracting and construction materials and
services. Deck is a salaried employee of H&K Group, and his responsibilities include the oversight
of project -related matters.
During a Board meeting held on February 9, 2022, Township Supervisor and Township
Roadmaster Lester Feick ("Feick") discussed his intent to resurface Witman Road. A motion that
Feick made to authorize the packet preparation and advertise the bid for resurfacing Witman Road
passed by a vote of 2-0, with Feick and Vice Chairperson Harry Reinhold ("Reinhold") voting in
favor of the motion. Deck was absent from the meeting.
On May 6 and May 12, 2022, the Township advertised a Request for Proposal in the
Reading Eagle and Reading Eagle Digital to solicit sealed bids for the Witman Road paving
project. The deadline to submit sealed bids for the paving project was listed as May 24, 2022, at
10:00 a.m.
The Township typically opens sealed bids and awards contracts for roadway projects during
regularly scheduled and advertised Board meetings. However, at the May 11, 2022, Board
meeting, Feick, citing contractor scheduling concerns and other issues and in order to expedite the
process, made a motion to advertise a special meeting to be held on May 24, 2022, for bid opening
for the Witman Road paving project and any other business. The motion passed by a vote of 3-0.
During the May 11 meeting, Reinhold submitted a letter of resignation effective May 12, 2022.
The individuals present at the special meeting on May 24, 2022, included, in pertinent part,
Deck, Feick, Harold Zimmerman ("Zimmerman"). The Township Solicitor did not attend the
special meeting. During the special meeting Zimmerman submitted a letter of interest for the
vacant Township Supervisor seat. Despite being presented with Zirnmerinan's interest in the
Board vacancy, no suggestion was made to table the vote to award the Witman Road paving project
until a fiill Board was seated.
The Township is required to accept the lowest responsible bid, subject to final review by
the Township Solicitor. During the special meeting, three sealed bids for the Witman Road paving
project were opened for review: (1) H&K Group - $103,675.65; (2) New Enterprise Stone & Lime
- $104,777.70; and (3) CMS - $119,685.00. After the bids were reviewed, Feick made a motion
to award the Witman Road paving project to H&K Group for the amount of $103,675.65. Deck
seconded Feick's motion and voted in favor of the motion, which passed by a vote of 2-0.
Subsequent project changes and price index adjustments for materials increased the final total cost
of the Witman Road paving project to $121,795.84.
Deck, 24-0135-C
Page 9
Deck had no direct involvement as an employee of H&K Group in the planning, estimating,
or completion of the Witman Road paving project. H&K Group did not award any commission or
bonus to Deck as a direct result of the Witman Road paving project.
With respect to Deck's SFI for calendar year 2023, Deck failed to disclose any direct or
indirect interest in real estate that was sold or leased to or purchased or leased from the
Commonwealth or its agencies or political subdivisions, or that was the subject of condemnation
proceedings by the Commonwealth or its agencies or political subdivisions.
Having highlighted the Stipulated Findings and issues before us, we shall now apply the
Ethics Act to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations as
follows:
3. The Investigative Division will reconunend the following in relation to the
above allegations:
a. That a technical violation of Section 1.103(a) of the Public
Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a),
occurred in relation to when Deck used the authority of his
office to award a contract to H&K Group, Inc., a business
with which he is associated.
b. That a violation of Section 1105(b)(3) of the Public Official
and Employee Ethics Act, 65 Pa.C.S. § 1105(b)(3), occurred
in relation to when Deck failed to disclose any direct or
indirect interest in any real estate which was sold or leased
to the Commonwealth, any of its agencies or political
subdivisions, or purchased or leased from the
Conuhhonwealtlh, any of its agencies or political subdivisions,
or which was the subject of any condemnation proceedings
by the Commonwealth, any of its agencies or political
subdivisions, on his Statement of Financial Interests for
calendar year 2023.
4. Deck agrees to make payment in the amount of $250 in settlement of this
matter payable to the Commonwealth of Pennsylvania, and forwarded to the
Pennsylvania State Ethics Commission, within thirty (30) days of the
issuance of the final adjudication in this matter.
a. There is no financial penalty assessed to Deck for the
violation of Section 1103(a) as the financial gain was
realized by a business with which Deck is associated and not
Deck himself.
Deck, 24-0135-C
Page 10
5. To the extent that lie has not already done so, Deck agrees to file a complete
and accurate amended Statement of Financial Interests with Tulpehocken
Township, through the Pennsylvania State Ethics Commission, for calendar
year 2023 within thirty (30) days of the issuance of the final adjudication in
this matter.
6. Deck agrees to not accept any reimbursement, compensation or other
payment from Tulpehocken Township representing a full or partial
reimbursement of the amount paid in settlement of this matter.
7. The Investigative Division will recommend that the State Ethics
Commission take no further action in this matter and make no specific
recommendations to any law enforcement or other authority to take action
in this matter. Such, however, does not prohibit the Commission from
initiating appropriate enforcement actions in the event of Deck's failure to
comply with this agreement or the Commission's order or cooperating with
any other authority who may so choose to review this matter further.
a. Deck has been advised that as a matter of course, all orders
from the Commission are provided to the Attorney General,
albeit without any specific recommendations pursuant to
Paragraph 7 above.
b. Deck has been advised that all orders become public records
and may be acted upon by law enforcement as they deem
appropriate.
The non -referral language contained in this paragraph is
considered an essential part of the negotiated Consent
Agreement.
Consent Agreement, at 1-3.
In considering the Consent Agreement, we accept the parties' recommendation for a
finding of a technical violation of Section 1103(a) of the Ethics Act with respect to Deck's actions
as a Township Supervisor. H&K Group is a business with which Deck is associated in his capacity
as an employee. Because the arnount of H&K Group's bid for the Witman Road paving project
was more than de ininimis, Deck had a conflict of interest under Section 1103(a) of the Ethics Act
with regard to participating in awarding the Witman Road paving project to H&K Group. Deck
used the authority of his public office when, at the Board's meeting on May 24, 2022, he seconded
a motion by Township Supervisor Feick to award the Witman Road paving project to H&K Group
for the amount of $103,675.65 and then voted in favor of the inotion, which passed by a vote of 2-
0. Although Section 11030) of the Ethics Act permitted Deck to second Feick's motion because
there was no third Township Supervisor to second the motion, see, Garner, supra, there was no
basis under Section 11030) for Deck to then vote on the motion despite his conflict of interest.
See, Urtz, supra.
Deck, 24-0135-C
Page 11
Based upon the Stipulated Findings and Consent Agreement, we hold that a technical
violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to when
Deck used the authority of his office to award a contract to H&K Group, a business with which he
is associated.
We agree with the parties, and we hold, that a violation of Section 1105(b)(3) of the Ethics
Act, 65 Pa.C.S. § 1105(b)(3), occurred in relation to when Deck failed to disclose any direct or
indirect interest in any real estate which was sold or leased to the Commonwealth, any of its
agencies or political subdivisions, or purchased or leased from the Commonwealth, any of its
agencies or political subdivisions, or which was the subject of any condemnation proceedings by
the Commonwealth, any of its agencies or political subdivisions, on his SFI for calendar year 2023.
As part of the Consent Agreement, Deck has agreed to make payment in the amount of
$250.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission within
thirty (30) days of the issuance of the final adjudication in this matter. Deck has further agreed to
not accept any reimbursement, compensation or other payment from the Township representing a
full or partial reimbursement of the amount paid in settlement of this matter. Additionally, to the
extent he has not already done so, Deck has agreed to file a complete and accurate amended SFI
for calendar year 2023 with the Township, through this Commission, within thirty (30) days of the
issuance of the final adjudication in this matter.
We determine that the Consent Agreement submitted by the parties sets forth a proper
disposition of this case, based upon our review as reflected in the above analysis and the totality
of the facts and circumstances.
IV, CONCLUSIONS OF LAW;
1. As a Supervisor for Tulpehocken Township ("Township"), Berks County, Pennsylvania,
since 2012, Gary Deck ("Deck") has been a public official subject to the provisions of the
Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et sec .
2. A technical violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred
in relation to when Deck used the authority of his office to award a contract to H&K Group,
Inc., a business with which he is associated.
3. A violation of Section 1105(b)(3) of the Ethics Act, 65 Pa.C.S. § 1105(b)(3), occurred in
relation to when Deck failed to disclose any direct or indirect interest in any real estate
which was sold or leased to the Commonwealth, any of its agencies or political
subdivisions, or purchased or leased from the Commonwealth, any of its agencies or
political subdivisions, or which was the subject of any condemnation proceedings by the
Commonwealth, any of its agencies or political subdivisions, on his Statement of Financial
Interests for calendar year 2023.
In Re: Gary Deck, File Docket: 24-0135-C
Respondent Date Decided: 10/10/25
Date Mailed: 10/10/25
ORDER NO. 1850
A technical violation of Section 1103(a) of the Public Official and Employee Ethics Act
("Ethics Act"), 65 Pa, C.S, § 1103(a), occurred in relation to when Gary Deck ("Deck"), as
a Supervisor for Tulpehocken Township, Berks County, Pennsylvania, used the authority
of his office to award a contract to H&K Group, Inc., a business with which he is
associated.
2. A violation of Section 1105(b)(3) of the Ethics Act, 65 Pa,C.S, § 1105(b)(3), occurred in
relation to when Deck failed to disclose any direct or indirect interest in any real estate
which was sold or leased to the Commonwealth, any of its agencies or political
subdivisions, or purchased or leased from the Commonwealth, any of its agencies or
political subdivisions, or which was the subject of any condemnation proceedings by the
Commonwealth, any of its agencies or political subdivisions, on his Statement of Financial
Interests for calendar year 2023.
3. Per the Consent Agreement of the parties, Deck is directed to make payment in the amount
of $250.00 payable to the Commonwealth of Pennsylvania and forwarded to the
Pennsylvania State Ethics Commission within thirty (30) days of the issuance of this Order.
4. Deck is directed to not accept any reimbursement, compensation or other payment from
Tulpehocken Township representing a firll or partial reimbursement of the amount paid in
settlement of this matter.
5. To the extent he has not already done so, Deck is directed to file a complete and accurate
amended Statement of Financial Interests for calendar year 2023 with Tulpehocken
Township, through this Commission, by no later than the thirtieth (30"') day after the
mailing date of this Order.
6. Compliance with paragraphs 3, 4, and 5 of this Order will result in the closing of this case
with no further action by this Commission.
a. Non-compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
David L. Reddecliff, Vice Ch r