78 Dealing with Tax sales and Code Enforcement

My suggestion is that the City of Sharon Council members at a work session discuss and consider directing City staff in doing the following at the

Judicial Tax Sale(s) as well as at Upset Tax Sales  and Private Tax Sales for delinquent property taxes. Eighty percent of positive revitalization efforts begin with code enforcement. 

The law controlling the sale of tax delinquent properties clearly states that the delinquent owner is not relieved of civil or criminal

liability or for an obligation for maintenance or for nuisance remediation until the Tax Claim Office  transfers the deed to a

purchaser. (See: 72 P.S. Section 5860.642 Ownership Interests and Responsibilities of Delinquent Property Owner.)

1.) New owners of properties should be promptly informed if their winning bid has bought them a property that is not

in compliance with the building maintenance code. They should be served with a citation for all code deficiencies.

The code violations should be pursued to the fullest extent of the law.

2.) As the properties for sale prior to a Judicial Sale are identified and known beforehand, the code status of

each property should be in hand before a sale is conducted. As the Judicial Sale is an in-person public auction a City Code

employee should attend and serve a Code citation upon the winning bidder at the sale in the Mercer Courthouse. At that

time the address and identification for the winning bidder can be verified as the citation should also be mailed by Certified

return receipt mail. 

3.) As the properties for sale prior to a Private Tax Sale are known beforehand but the Private Tax Sale is essentially administrative

in nature; the buyer should be notified of code violations through certified return receipt mail. This would have to be coordinated

through the Tax Claim Office / Bureau which is directly supervised by the County Commissioners. Two notices should be mailed via 

certified return receipt mail. First, when public notice is advertised by the Tax Claim Office of a forthcoming Private Tax Sale the 

person(s) who made the bid / application for a private tax sale of an eligible property should have the code status information mailed

to them with the July public notice. The Tax Office stay would do that. Second, when the administrative sale decision is made in

September, the person who bought the property, their name and address should be given to the Code Office so that they can

mail the Code citation to the new owner. Notice should be made to a winning competitive bidder in those cases where objections

are filed prior to September subsequent to public notice in the newspaper.

4.) Few properties are cleared at the annual Upset Tax Sale auction. The Tax Claim Office should inform the Code Office

when a sale occurs in order that the Code Office can send a citation to the new owner.

The suggestions for Private Tax Sale and the Upset Tax Sale coordination with the Code Office requires that the County Commissioners

direct the Tax Claim office staff to comply, be cooperative and proactive.

The suggestion for the Judicial Tax Sale requires only a courtesy notification to the Tax Claim Office as the Judicial Tax Sale

is a public meeting.

77. It should be named: Structure and Land Revitalization Bank

LAND BANK?
"Land bank" is a stupid name for a catalyst for revitalization. That's the misleading name applied to a government administrative procedure that can effect community revitalization, reinvigoration, restoration. ( If I were Johnny Cash, I would sing, " And if I ever have a son, I think I'm gonna name himm... Bill or George! Anything but Sue.") But, "Land bank" is what the appellation is. How about calling it "THE STRUCTURE AND LAND REVITALIZATION BANK?

A land bank must conform to the provisions of Act 153 of 2012 (HB 1682), 68 Pa. CS. Sections 2101 et.seq. The authorizing ordinance for a land bank is reviewed by the Department of Community Affairs (DCED). DCED has an annual audit oversight of a land bank. As the land bank is an entity with the authority to contract, the land bank's name is registered with the Department of State. A land bank can sue and be sued in its own name and be a party in a civil action, including an action to clear title to a land bank. The land bank can enter into contracts and other instruments necessary, incidental or convenient to the performance of its duties and the exercise of its powers. A land bank can and should create a hierarchical ranking of priorities such as owner occupied houses, affordable housing architectural preservation as part of rehabilitation, open public land, public space, conservation area, etc. 

While land bank may borrow and issue bonds, a municipality can bootstrap a land bank. For example, a land bank can begin by purchasing all or some properties on a list published by the Mercer County Tax Claim Bureau as being eligible for a private tax sale. It is the cheapest way to go. 

Funding of the land bank would come from sale proceeds or rental income. Once acquired by the private tax sale method, The school district and County by provisions of the Land Bank Act forego half of their real estate tax base that is restored through land bank revitalization as a funding stream for the land bank. Such a funding stream can not exceed five years.

76 A Miracle on Third Avenue?

A Miracle on Third Avenue in Sharon, PA on 12/20/19. A grant combined with tax incentivized private funds will fund demolition of abandoned and blighted houses. The resulting vacant lots will be managed through a program that will be called “Lots to Love.” The vacant lots may be bought or adopted. If adopted, the lot will be cut and maintained by the person committing to the adoption. The local Community Action Partnership of Mercer County PA will administer the  “Lots to Love” program. Local middle school students have developed an app to be used in association with house demolition to keep track of the grass height of vacant lots and be a basis to manage City Beautification Commission assets.

Assemblyman Mark Longietti and Pennsylvania Commonwealth Secretary Department Community and Economic Development, Dennis Daven on Third Avenue. Announce revitalization efforts for Sharon, PA 12/20/19.

Sharon community spark plug and catalyst, Karen Winner-Sed on Third Avenue with Assemblyman Longietti.

On Third Avenue at 224, an abandoned and blighted house will be demolished in 2020 using scarce grant funding from the DCED Department Of Commnunity and Economic Development and private funding that has tax incentives.

Typical of Sharon, the deteriorated properties are like a random checkerboard pattern. On Third Avenue to the right of 224 is 218. It has a new roof and It looks as if it has maintained and shrubbery trimmed and grooms grass. The owner says he has been there for 55 years and he looks forward for 224 to be a vacant lot.

Here is the long time Sharon resident of the house at 218. His well maintained house, is  a Third Avenue story of responsibility.

School Teacher D. Tomko with some of the students who have helped create an app to manage the condition and status of properties and lots for management of grass, weeds and scrub growth. The students have built upon the 2018 mapping by some 80 volunteers who on a September Saturday using smartphones surveyed 5700 houses in Sharon. The resulting GIS map data is the foundation information for planning revitalization.

The students pose in on Third Avenue in front of 217. It is abandoned and blighted. Its owner has 152 other structures in Sharon. Sadly some 40 or more by this owner were identified by volunteer map surveyors in 2018 as being either abandoned or in poor condition. Pennsylvania trespass law provides for a defense to trespass that the trespass happened in an abandoned structure. 271 could easily be the site for squatters or persons bent upon criminal activity. The TRESPASS LAW contributes to community decline as it is written.

The City of Sharon's Community Development guru is Melissa Phillips seen here being interviewed on Third Avenue. She along the the members of City Council, the City Manager, Code Enforcement staff are going to correct the abandoned and blighted property problem in Sharon in the coming years. Some 690 houses are candidates for demolition. It is a big job that will get done in the forthcoming couple of years.



















Read more »

75 Letter to Editor: Severance Tax for Revitalization

LETTERS

A severance tax would help PA where it needs it the most

Samuel Walker

Sharon

 

Pennsylvania is the only natural gas producing state without a severance tax.

 

A severance tax is a state tax imposed on the extraction of non-renewable natural resources that are not intended for consumption in other states.

 

Pennsylvania produces more natural gas than any other state except Texas. Texas is the number one producer. Pennsylvania is second.

Most of Pennsylvania’s natural gas production or withdrawals is from fracked wells.

 

In 2017 the Pennsylvania percentage of withdrawals in comparison to Texas natural gas withdrawals was 68%. (United States Department of Energy, Energy Information Agency, www.eia.gov).

Texas in 2017 had $1,527,000,000 (One billion and five hundred twenty seven million dollars) in natural gas severance tax revenue. (Comptroller, Texas Gov).

 

Sixty-eight (68%) of Texas natural gas severance 2017 revenue would be $1,068,000,000 (One billion and sixty-eight billion dollars).

 

Pennsylvania has a greater portion of its natural gas moved over state lines and thus into interstate commerce than Texas does. The estimated foregone PA severance tax revenue would be $685,000,000 (Six hundred and eighty five million dollars).

 

Pennsylvania does not have a natural gas severance tax. 

Pennsylvania is the only natural gas producing state without a natural gas severance tax.

 

It is puzzling to this Pennsylvanian that there is no natural gas severance tax.

 

Revenue from a Pennsylvania natural gas severance tax could fund the elimination of blight in Pennsylvania towns and cities, fund storm recovery, enhance and extend internet capacity, and encourage natural gas based manufacturing investment.

 

74 A Roadmap for a Mercer County, PA Homeowner - Private Tax Sale - Cheap Acquisition of Adjacent Vacant Side Lot

Thoughts About Acquiring Vacant Lots for Sharon and Mercer County homeowners:

Homeowners interested in acquiring a vacant parcel lot have options to do so. It is suggested that a homeowner proceed first by having a person skilled as a title searcher examine the history of the parcel in order to identify private and public liens that may be on the record for the parcel. A title report can generally be done for $150.00. The report will identify the risks that might exist for a lien holder to come forward to make a claim against the parcel. Names of persons with their contact information who will do a title search for individuals are below. There may be others but these are the persons who responded to survey efforts.

Armed with the data from the title search report, the homeowner can make
decisions as to how to proceed.

If the vacant parcel lot is listed as eligible by the Tax Claim Bureau, there are advantages to act using the provisions of the Pennsylvania Tax Sale Act that guides the Tax Claim Bureau for private tax sale or judicial tax sale procedures.

Identifying the vacant lot - some useful information:

The first step is for the homeowner to use Google Maps to locate the vacant parcel lot. By using Google Maps to do so provides a reference
point to find the vacant parcel lot on the Mercer County Tax Parcel viewer.
When the parcel is located on the parcel viewer information for the lot includes its parcel ID number, its annual taxes for the county, municipality and school district and owner of last record. The key information is
the parcel ID. ( Google Maps - https://www.google.com/maps/ ).
( Tax Parcel Viewer - https://www.mcc.co.mercer.pa.us/GIS/TaxparcelViewer.htm ).

With the parcel ID number, the homeowner can search the Tax Claim Bureau list of properties eligible for private tax sale or judicial tax sale.
( https://www.mcc.co.mercer.pa.us/tax/PrivateSaleDisclaimer.htm ).

If the vacant parcel lot is listed, the homeowner should check to assure
from the Tax Parcel Viewer that the Tax Claim Bureau reflects that the
taxes being assessed reflect that a structure is no longer on the vacant
parcel lot. In most cases the vacant lot is assessed as a vacant lot. But, checking beforehand the tax rate status is important as that should be addressed before acquisition of a vacant lot.

The most cost effective procedure to acquire an eligible vacant parcel lot is  the private tax sale. A parcel purchased via a private tax sale has all public liens (county, municipal, school district) cleared. Private liens remain. It is recommended to begin the acquisition of a vacant parcel lot with a title search report to identify private liens that may be on the record. That knowledge will guide the homeowner as to what they intend to do with vacant parcel lot. For example. if there are a number of contemporaneous liens, the homeowner may elect to acquire the vacant lot for nothing more than enlarging a lawn. For anything beyond, such as building a garage, for example, or using the lot for a new loan by the homeowner, additional steps will need to be taken.

The acquisition process through private tax sale will be explained:
A buyer of a parcel in a private tax sale does so by making an application / bid before April 15th. An application bid form is available at the Tax Claim Bureau website. ( https://www.mcc.co.mercer.pa.us/tax/PrivateSaleDisclaimer.htm ). The form asks for a bid amount. The bid amount will not be the only cost to the buyer. An administrative fee will be required by the Tax Claim Bureau. The administrative fee is $250.00. The Tax Claim Bureau will advertise that the vacant parcel lot has had a private tax sale bid application submitted in July. In rare case that public notice causes another interested party to come forth expressing their interest in
buying the vacant parcel lot. In such case, the Tax Claim Bureau under the supervision of the County Court of Appeals conducts a competitive auction among or between the interested parties. Typically though, the Tax Claim Bureau makes an administrative decision in late August or September accepting the application / bid submitted before April 15th.

There are other costs. For example, one that comes to mind is that there
will be a realty transfer fee to record the sale at the Recorders Office at the
court house. For more information: ( https://www.mcc.co.mercer.pa.us/recorders/services.htm ).




Title Search Talent:

David Gloss
dgloss@davidgloss.com

Jenny Laslow
jenny@a-1abstract.com

Matthew Greleski
mattgreleskis@hotmail.com

Becky Rizzonelli
rrizzonelli@neo.rr.com



Contact for the above:

Samuel Walker
1354 Heinz Avenue
Sharon, PA 16146
724-342-3503
walker6959722@gmail.com

Samuel Walker’s blog about blight in Pennsylvania municipalities:

www.blighttodelight.blogspot.com




   

73 Disordered PUBLIC NUISANCE - Corrected by Code Office

The Code office for the City of Sharon, PA was confronted with a property owner who suspended work on a demolition. The property required major rehabilitation. The owner opted for demolition. Neighbors informed this writer that the demolition had been suspended for months. They observed that the contractor was either an Amish owned firm or a firm using Amish people as employees. They thought that the Amish had been cheated by the owner and simply left the project incomplete. The Amish will not use the courts when they are cheated. They simply suspend and move on. So, from mid February to mid May the house sat with demolition spoil surrounding it. The neighbors reported
that the unfinished demolition created a rodent and roach problem.

The dangerous demolition spoil and danger it posed was corrected through the efforts of the Code office staff using the full force of law to deal with the property owner and the public nuisance of his creation. The demolition was completed in mid May.

One option available to the Code office was a daily fine of $1,000. That did the trick in getting compliance.

True to form, the owner does not live in the City of Sharon. All too often errant rental property owners live elsewhere.

150 4th Avenue in 2014 before fire and condemnation.

150 4th Avenue suspended demolition.

2014 street view of 150 4th Avenue.

Second floor walls and roof demolition spoil of suspended demolition-

-PUBLIC NUISANCE!!

72 Public Nuisance Tools Explained

PENNSYLVANIA LEGISLATOR’S MUNICIPAL DESKBOOK | 5th Ed. (2017) 

 Public Nuisances
A nuisance has been defined as the unreasonable or unlawful use of property that causes damage, injury, inconvenience or annoyance to another in the enjoyment of his or her reasonable rights.1
A nuisance can be a public nuisance or a private nuisance. The important difference between public and private nuisances is not the nature of the activity itself, but the party the nuisance af- fects.2 In the case of a public nuisance, it is the general public, and not merely one or more pri- vate individuals that is impacted.3 However, it is possible for a nuisance to be both a public and a private one because of the injury it causes to a single individual or group of individuals.4 

This discussion focuses on the topic of public nuisances because they are of most concern to local governments. 

Definition
A public nuisance is an unreasonable interference with a right common to the general public. Circumstances considered by courts in determining whether an interference with a public right is unreasonable include the following: 

o Whether the conduct involves a significant interference with the public health, the public safety, the public peace, the public comfort or the public convenience; or 

o Whether the conduct is proscribed by a statute,ordinance or administrative regulation; or 

o Whether the conduct is of a continuing nature or has produced a permanent or long lasting effect, and, as the person knows or has reason to know, has a significant effect upon the public right.5 

A public nuisance does not have to be explicitly prohibited by statute, and certain acts or conditions have been declared a public nuisance as a matter of common law.6 What is required is a showing that the act or condition unreasonably interferes with the rights of the public.7 Interference with a public right is unreasonable when the conduct involves a significant interference with the 

1 See Kramer v. Pittsburgh Coal Co., 341 Pa. 379 (1941).
2 Phillips v. Donaldson, 269 Pa. 244 (1920).
3 Duquesne Light Company v. Pennsylvania American Water Company, 850 A.2d 701 (Pa. Super. 2004); Muehlieb v. City of Philadelphia, 574 A.2d 1208 (Pa. Cmwlth. 1990). See also Jeff Feirick, “Pennsylvania Nuisance Law,” The Agricultural Law Research and Education Center, The Pennsylvania State University, The Dickinson School of Law, 2000.
4 See, e.g., Com. ex rel. Shumaker v. New York & Pennsylvania Co., 367 Pa. 40, 47 (1951).
5 574 A.2d at 1211, citing Restatement of Torts (Second) § 821B; see also Feirick, supra, note 3.
6 Com. v. MacDonald, 464 Pa. 435 (1975), cert. denied, Pennsylvania v. MacDonald, 429 U.S. 816 (1976); see also Feirick, supra, note 3.
7 Id.

public’s safety, the public peace, the public comfort or the public convenience.8 To be a public nuisance, the conduct must be continuous and repeated, not a single isolated act. In order for the offender to be held criminally liable, the nuisance complained of must be the natural and direct result of the offender’s act.9 

Nuisance can be distinguished from trespass. Trespass is a direct infringement of one’s right of property; nuisance is the result of an act that is not necessarily unlawful in and of itself, but which is harmful because of the consequences that may result from it.10 

Also, a nuisance does not necessarily involve negligence, and whether one has exercised due care or failed to do so is not a necessary element in determining whether a nuisance exists. However, nuisance and negligence are frequently viewed as partners, with nuisance presupposing negligence “when the omission to remove the nuisance after notice constitutes negligence.”11 

Municipal Regulation
In addition to prosecution of a public nuisance as a misdemeanor under the Pennsylvania Crimes Code,12 municipalities are authorized to provide for the prohibition of, and seek the abatement of, a public nuisance through the exercise of their police power. However, this au- thority is justified only by the ability to demonstrate that the act constituting a violation of the ordinance did in fact cause a public nuisance. Stated another way, municipalities are not author- ized to simply prohibit a nuisance per se—that is declare that a particular act results in interference so severe that it would constitute a nuisance under any circumstance.13 

Municipalities that enact ordinances to provide for the prosecution of public nuisances which exist within the municipalities have often sought to establish the specific conduct that would violate the ordinance. This appears to be facially supported by the special powers provisions of the various municipal codes. For example, Section 1529 of the Second Class Township Code states: 

8 See 574 A.2d at 1211; see also Feirick, supra, note 3. 9 5B Summ. Pa. Jur. 2d, Criminal Law § 33:2 (2017). 10 341 Pa. at 381.
11 Reedy v. City of Pittsburgh, 363 Pa. 365, 368 (1949). 12 18 Pa.C.S. § 6504:
§ 6504. Public nuisances.
Whoever erects, sets up, establishes, maintains, keeps or continues, or causes to be erected, set up, established, maintained, kept or continued, any public or common nuisance is guilty of a misdemeanor of the second degree. Where the nuisance is in existence at the time of the conviction and sentence, the court, in its discretion, may direct either the defendant or the sheriff of the county at the expense of the defendant to abate the same.
13 23 Summ. Pa. Jur. 2d Municipal and Local § 19:22 (2017); see, e.g., Com. v. Creighton, 639 A.2d 1296 (Pa. Cmwlth. 1994); Talley v. Borough of Trainer, 394 A.2d 645 (Pa. Cmwlth. 1978).

Nuisances.--The board of supervisors may by ordinance prohibit nuisances, includ- ing, but not limited to, the storage of abandoned or junked automobiles, on private and public property and the carrying on of any offensive manufacture or business.14 

However, courts in the Commonwealth have repeatedly interpreted provisions like Section 1529, above, “as authorizing the local governing bodies to declare such activities to be nuisances when, based upon the actual conditions in the [municipality], they constitute nuisances in fact.”15 

 Commonwealth Court has also addressed whether a municipality not limited to express powers, but enabled by statute to “confer the greatest power of local self-government consistent with the Constitution of this State” such as a home rule municipality, would be authorized to establish a nuisance per se. The Court found that it could not on the basis that doing so would exceed constitu- tional limitations on the exercise of the municipality’s police power. “What is not an infringement upon public safety and is not a nuisance cannot be made one by legislative fiat and then prohibited.”16
Nevertheless, ordinances which appear to establish a nuisance per se are not necessarily void, but courts in Pennsylvania are likely to “adopt an interpretation of the ordinance which requires the [municipality] to prove that a nuisance in fact exists in any given case.”17 

Similarly, the converse is also true. Although a person is acting in compliance with other laws and regulations, such as a zoning ordinance, his or her conduct, nevertheless, may constitute a nuisance.18 

Abatement 

Where a nuisance continues at the time of the conviction and sentence, under the Crimes Code nuisance provisions, the court may direct the abatement of the nuisance either by the defendant or by the appropriate governmental authority at the defendant’s expense.19 However, “[w]here a nuisance in fact exists, neither the municipality nor the courts may devise a remedy harsher than the minimum necessary to properly abate the nuisance.”20 

Two considerations are critical in the adoption of ordinances to abate nuisances. One, the nuisance must be a nuisance in fact—not one merely defined as a nuisance by the municipality. And, two, if the remedy includes abatement as part of the penalty, such remedy should be the min- imum required to eliminate the nuisance. For example, in the case of a structure, this may mean requiring a sealing or repairing before the municipality seeks to have the structure demolished. 

14 Act 69 of 1933 (53 P.S. § 66529).
15 Kadash v. Williamsport, 340 A.2d 617, 619 (Pa. Cmwlth. 1975)(quoting Commonwealth of Pa v. Hanzlik, 400 Pa. 134 (1960).
16 340 A.2d at 621 (citing Commonwealth of Pa. v. Christopher, 132 A.2d 714 (Pa. Super. 1957)).
17 340 A.2d at 621; Dole v. Philadelphia, 337 Pa. 375 (1940) (“Where a reasonable interpretation can be adopted, which will save the constitutionality of an ordinance, it is the court’s duty to adopt it.”).
18 23 Summ. Pa. Jur. 2d, Municipal and Local Law § 19:22 (2017). 19 18 Pa.C.S. § 6504.
20 23 Summ. Pa. Jur. 2d, Municipal and Local Law § 19:24 (2017), citing King v. Township of Leacock, 552 A.2d 741 (Pa. Cmwlth. 1989), Groffv. Borough ofSellersville, 314 A.2d 328 (Pa. Cmwlth. 1974).

In Pennsylvania, the Commonwealth has delegated authority to control public nuisances to municipalities by enabling them to enact ordinances under their respective municipal codes or the Pennsylvania Municipalities Planning Code (MPC), although the Commonwealth also con- trols nuisances in certain instances. Under the MPC, municipalities may adopt zoning and subdi- vision and land development ordinances to avoid or prevent nuisance situations. For example, a zoning ordinance can avoid or minimize incompatible land use districts, such as residential and industrial, by separating uses from each other with a transitional district, or by providing for a large setback or buffer along the border of the land use that could impact an adjacent, more sen- sitive land use. Also, subdivision and land development ordinance provisions can require land- scaping and screening in commercial developments and larger subdivisions and compliance with environmental protection standards as a condition of approval. Relevant environmental protection standards can cover erosion and sedimentation control, natural feature (e.g., wetland, floodplain, stream, steep slope, aquifer and tree) protection, and mine subsidence or karst (sinkhole) hazards. 

In addition to municipalities’ ability to exercise their powers and enact and enforce ordinances to abate nuisances, the federal and state governments have the authority to do the same on a range of potential impacts, ranging from water pollution to visual impacts. For example, a transporta- tion-related protection lies with the Junkyard and Automotive Recycler Screening Law,21 which requires a 1,000-foot buffer from the edge of a highway right-of-way for all junkyards or auto- motive dismantlers and recyclers established after January 1, 1967. Generally, junkyards or au- tomotive dismantlers and recyclers, which are within 1,000 feet of the edge of the highway right- of-way, must be screened.22 This state law is based on Federal-Aid Policy Guide for Junkyard Control and Acquisition,23 which “prescribes Federal Highway Administration policies and pro- cedures relating to the exercise of effective control by the States of junkyards in areas adjacent to the interstate and Federal-aid primary systems.” 

ILLUSTRATION: A   government ordinance to abate unsafe structures is rationally related to the promotion of the public welfare and is a proper and necessary exercise of a government’s police power as long as there is factual evidence to support its application to a specific structure.24 The process to abate an unsafe structure must still be carried out in a manner that gives the property owner proper notice and the chance to abate the nuisance.25 If the property owner fails to repair or eliminate the dangerous condition within a reasonable time, then the municipality has the ability to tear down the structure and charge the landowner the cost of disposal.26

21 Act 4, Special Session 3, of 1996 (36 P.S. § 2719.1 et seq.); see also 67 Pa. Code § 451.1 et seq.
22 Junkyard and Automotive Recycler Screening Law, § 6; 67 Pa. Code §§ 451.2, 451.4.
23 23 C.F.R. § 751.1 et seq. (2006).
24 21Herrit v. Code Mgmt. Appeal Bd. of City of Butler, 704 A.2d 186 (Pa. Cmwlth. 1997), citing City of Pittsburgh v. Kronzek, 280 A.2d 488 (Pa. Cmwlth. 1971).
25 Feirick, supra, note 3, citing Keystone Commercial Properties, Inc. v. City of Pittsburgh, 464 Pa. 607 (1975). 26 Id.; 23 Summ. Pa. Jur. 2d, Municipal and Local Law § 19:25 (2017).

80 | Pennsylvania General Assembly ∙ Local Government Commission