Not to elongate it, Mr. Chairman, but just I'm thinking those people in Chicago and Seattle, they're appointed by somebody in government, right?
Well, you'll like it in Seattle. The City Council actually appoints them.
Never mind. It just seems -- I mean, you'd know a whole lot about it. It just seems like it's almost overcomplicating it, 149 10/16/07 - L&I - RES. 070355 because you're not talking about doing away with --
We're not talking about doing away with enforcement, but I'm saying that if you were to rethink what agencies do and departments do, that maybe the mission of enforcement for L&I should maybe -- or maybe you set up something else, because they have a lot of stuff on their plate and the world has become much more complicated for them, and unless we're going to give them the resources to really fully do their job, if you can have -- if we're talking about having computers that interact and talk to each other -- and that may be a hard task because it gets Streets Department and Water Department and all the departments to use the same system and talk to each other -- we should be looking that what agencies are doing these days. If you were to develop it along sustainability and let's say that you are now to have the Department of 150 10/16/07 - L&I - RES. 070355 Environmental Protection for the City of Philadelphia, it wouldn't just be the Water Department. You would have other things that you would look at. And maybe Philadelphia needs its own department like that that brings some of the disciplines together. And maybe the thing that L&I does well is review applications, review plans and does those kinds of things. Maybe there's a different department that should be charged with closing up buildings and those kinds of things that is not necessarily -- that's something that L&I has done over the years, but maybe so that you can free up people to do certain things. As you say, you want to target hot areas where maybe you can generate fees or generate income. Also make it easier for your citizens to be able to get permits, to be able to know what quality of life is supposed to be in their neighborhood. So if somebody is doing -- so... 151 10/16/07 - L&I - RES. 070355
I'm trying to think out of the box a little bit, that's all.
Thank you, Mr. Pollack. I appreciate you taking the time to come here and testify.
The next witness is Paul Lonie. Good afternoon and thank you for your patience. I appreciate you taking the time here and being patient. I know it's been a long wait.
Thank you, Mr. Chairman, members of the Committee on Licenses and Inspections. My name is Paul Lonie, Philadelphia Projects Director for Westrum Development Company. Today I'm here to testify on Resolution 11 No. 070355 submitted by Councilman Savage on April 26, 2007. I have been with Westrum Development Company for over three years, and in that time, I've directed all of Westrum's Philadelphia projects until they are well into construction. They include the various phases of Packer Park in South Philadelphia, Brewerytown in North Philadelphia, Schuylkill Falls in the northwestern part of the City, Byberry in the greater Northeast and our future project at the old Philly Coke property in Bridesburg. Prior to that, as many of you know, I spent 36 years in 153 10/16/07 - L&I - RES. 070355 the City Streets Department. Needless to say, I've been around a while. L&I, like all City agencies, was set up in 1954 with the Home Rule Charter. With different administrations and priorities changing, the basic set-up of the Department didn't change very much. What it did do was shrink. Like other departments, it lost most of its people from areas that did not have responsibilities for health or safety, including zoning, building plan examiners and other engineers that were expensive and difficult to replace. During the '80s and '90s, there was not a great deal of residential building going on, so it seemed to be an easy target. I know this because the same thing happened in the Streets Department. But that is for the next administration to deal with. I would like to relate my dealings with L&I from the developer's perspective. Time spent at L&I for zoning and building permits is mostly waiting. 154 10/16/07 - L&I - RES. 070355 As I previously stated, this is not surprising due to the personnel restrictions. The Zoning Code is voluminous and open to overlays that make planning difficult at best. There are discrepancies between L&I's plumbing code and the Water Department's watershed's requirements, for example, that makes approvals very challenging. However, L&I and its administration is probably one of the best departments in returning phone calls, and they're willing to listen if your professional architect has interpreted the building code differently, not always agreeing but not dismissing you out of hand as some other departments will do. I believe much of this comes from the direction of the Commissioner and his department heads, and I would like to commend that effort. Change is difficult, and for L&I to change, it must reflect the needs 155 10/16/07 - L&I - RES. 070355 of many different groups that L&I serves. I feel we need to redefine the City departments to best serve the needs of the citizens for the 21st century, not the 20th. Councilman Savage, by holding this hearing, it shows that this Council is looking for input from many sectors of the City to help solve these problems. I think this is the key to making the City government more representative and better able to help all Philadelphians as we move into the future. I thank this Committee for letting me testify and be glad to answer any questions.
Thank you for coming here. In your opinion, how can we coordinate the efforts of the different departments to avoid duplication of effort and delay?
I think one of the departments, as people have cited before 156 10/16/07 - L&I - RES. 070355 in the "If You Build It, They Shall Come" book, I was quoted in there as having a separate department out of the Managing Director's Office that would kind of coordinate all the different development agencies together. I felt that way when I worked for the Streets Department. I feel that way now on the outside. So many times everybody is concerned with their little section of the code. When I was in the Streets Department, I knew Section 11 of the code inside and out, but I really didn't know very much about what was going on in the plumbing code or what was going on in the water code. Someone from the Managing Director's Office whose responsibility is not to be specifically known on one thing but to have the general overall view of development and, say, when a project gets held up somewhere why is it, where it is and what can I do to help I think is really necessary.
Okay. How 157 10/16/07 - L&I - RES. 070355 can we merge the different legal requirements of different entities? For example, you point out conflicts between the City's plumbing code and the Water Department's watershed's requirements. What is your suggestion for overcoming those conflicts?
The conflicts again, as they've been already started, is negotiation. The plumbing code is dealing with the way things were in the '60s and '70s. Watersheds was not even dreamed of when the plumbing code first came into existence. And, again, it's this Council's responsibility to amend that code. And the code is amended all the time. And if a group would come and say, This is a better way of doing this and they came to the Council and they amended the code, it can be done. Again, going back to one of my responsibilities when I was with the Survey Bureau, this Council was tied up with every small minimal curb change that 158 10/16/07 - L&I - RES. 070355 happened in the City of Philadelphia, because the curb required -- or the code required that Council have an ordinance 5 for every time you moved a curb line six inches, up or down or horizontally. Well, I said that was rather silly. I came to the Chairman of the Streets and Services Committee and said, This is really something that should be dealt with administratively. Would you mind if I put through an ordinance to kind of dump that over onto the Streets Department? He said, Well, let's see how it works. And it did, and that probably cut down at least 50 hearings a year on these silly little things. It's possible to do. It really is. And if you have an administration and the people in the departments that are willing to get behind that program, it's very doable.
Thank you, Mr. Lonie. I appreciate your testimony 159 10/16/07 - L&I - RES. 070355 and your patience and your time. Thank you. Denise Earley from the Greater Philadelphia Chamber of Commerce, she had to leave. I would like to enter her testimony, her written testimony, in the record. Also we have here to testify Pam Pendleton from Yorktown Community Stakeholders Committee. Good afternoon.
Good afternoon. Thank you, Mr. Chairman and the distinguished members of Council, for this opportunity to testify in the interest of Council collecting data to improve License and Inspections. My name is Pamela Pendleton-Smith. I am a member of the Yorktown Community Stakeholders Committee. Yorktown is a single-family dwelling district plagued by illegal rooming houses established in our midst. This problem was acknowledged by City Council in 2005 and resulted in a special 160 10/16/07 - L&I - RES. 070355 district being established. Its purpose was in order to preserve and protect this area of the City through the enactment of the North Central Philadelphia Community Special District Controls. It is recognized that this section of the City is unique and is a vital single-family residential district. This pattern contributes to the distinctive atmosphere of this area. Council recognized the need to establish a special land use and zoning controls to protect this community from the conversions of houses into apartments, tenements and multi-family dwellings which would de-stabilize the community by taking on the transient character inherent in apartment and tenement living, to sustain and promote single-family residential uses and to prevent declining property values. This legislation, which is Chapter 14 -- Title 14-1629, was enacted. Yet in spite of constant communication between the Committee and License and 161 10/16/07 - L&I - RES. 070355 Inspections, the administration of the Department insists this legislation is a paper tiger of sorts, that it cannot be enforced. Therefore, the problem still exists and it serves to de-stabilize the community. Now, the problem that we have as a result of this rooming house activity, we have construction or rehabs that are done without permits or licenses, which we report to License and Inspections, but a lot of times the response to those complaints are not timely. Therefore, the construction of the rehab is completed. We have the situation where the rooming house activity -- which is made up of more than three unrelated people in one property. Now, License and Inspections said that it's almost impossible to enforce that restriction because due to constitutional considerations, you can't just do gestapo, going into a property, which we 162 10/16/07 - L&I - RES. 070355 understand, but our question is, how do they enforce that regulation elsewhere in the City? When that regulation was passed, wasn't that taken into consideration on how do you prove that these four or six people in a property are unrelated? We have also had instances of fraud or deceit used by the property owner in acquiring the permit or licenses. There are members of our community that have formed a sort of watchdog entity where we've been checking with the records, the zoning records in the Department, to see if what we see on site in the community matches up with what they have applied for in the licenses and the permits, and a lot of times there are differences. There are also reports of non-occupancy. The tenants have reported themselves that the property owner has asked them to lie to the inspectors when the inspectors come. License and 163 10/16/07 - L&I - RES. 070355 Inspections has advised us that whenever there's a cease and desist notice placed on a property, that we're to call 9-1-1, to call the police, and they pick up the enforcement piece of that, but, of course, when we call 9-1-1, in their priority list, this doesn't even show on the list to be attended to because with what we have with the violence and everything, we understand that that does take precedence. So we're left with the cease and desist that is of non-effect. We just wanted to go on record as saying that this situation exists in our community and the findings that the Council acknowledged at the time the legislation was passed, those findings still exist.
Now, maybe the restricted or the prohibited uses are unenforceable, but the findings and the purpose still exist, and we would just make an appeal to this body to maybe rethink it to see if maybe we can have some things done that would help with the stabilization of 164 10/16/07 - L&I - RES. 070355 our community. Thank you very much.
Thank you. One question for you. This legislation that you're speaking of, can you elaborate more on that?
It's Title under Zoning and Inspections of 10 the City Code, Title 14-1629, North 11 Central Philadelphia Community Special 12 District Controls. And that stated that 13 with our community being a single-family 14 district, there's been recent activity of speculators coming into our community, taking the single-family properties and sometimes cutting them up physically, but most times just loading them with five, six tenants where they would charge $600 to $800 per tenant per month in that one property.
Thank you, Mr. Chairman. 165 10/16/07 - L&I - RES. 070355 I was wondering on -- the woman here, the witness, is talking about a specific area, but I know rooming houses generally are a problem. Could I ask the Commissioner to come back for a second? Could I ask him a question on that?
Commissioner, just generally on rooming houses, not specifically in Yorktown, I know that's a problem because, as the witness stated, you just can't go in and demand who everybody is, but I guess when the property is broken up, it's easier to give the violation, right, when it's clear it's separate? COMMISSIONER SOLVIBILE: Let's say we go into a property and there's five bedrooms and they're all locked, the doors. We write it up as a rooming unit automatically. We know that's what it is. It's not a single-family house where a group of people exist as a group to live and work in Philadelphia. It's more 166 10/16/07 - L&I - RES. 070355 than that. So we write it up, because then it requires fire alarms and zoning, the key being zoning. And in this district, you need to -- you cannot rent to Temple students and then -- we're beyond that and we've been working with -- there's a list of about 9 properties that I saw a report on 10 yesterday or the other day that they've 11 all been inspected. Now, I didn't have 12 time to read it. I know there's a 13 follow-up meeting in the Managing 14 Director's Office with the Yorktown 15 community, and the violations will then 16 be discussed with the community at that 17 point. 18
Often times is it students that cause the -- when I say "bigger problem," I mean the less enforceable problem? COMMISSIONER SOLVIBILE: You know, Councilman, say you go into a building and it really hasn't physically changed, but there's ten people living in 167 10/16/07 - L&I - RES. 070355 there, but it's during the day and everybody is out doing their thing, and our inspectors as a whole are there during the day, not in off hours. So it is difficult, but there are certain telltale signs that we look for and our inspectors look for. You know, we take all the codes seriously, but we take the life safety issues where, God forbid, a fire could happen to be the most serious violations, and the young lady mentioned the cease operations. We would automatically cease for that. If there was, say, five people and no fire alarm, it's a cease operations. And we deal with that situation one on one sort of.
Would you say the code is sufficient right now as talking about the general purpose of this hearing to talk about improvements? Is there something that needs to be changed in the code, in your opinion? COMMISSIONER SOLVIBILE: 168 10/16/07 - L&I - RES. 070355 There's a whole -- the Zoning Code is now being looked at, as you're aware of, and this is Title 14, which comes under -- anything with zoning I have to turn behind me. I have two experts right behind me. It's not one of my favorite topics, zoning, in the world. -- (continued) is going to be changed. And I think that we -- I think that there's a lot of room for improvement in the whole Zoning Code from everybody's prospect, from the developers and from the communities, and I think that if we make it simpler, which is what I believe the goal should be to the Zoning Commission, then it's more enforceable and more understandable and is easier to deal with, and that benefits everybody. So the answer is yes, I think it can be improved upon.
And would you say this is one of the tougher zoning problems because of the -- trying to 169 10/16/07 - L&I - RES. 070355 figure out who lives in a property and all? COMMISSIONER SOLVIBILE: I could write a book on zoning. I can't tell you what I really think of zoning, because they would kick me out of here, but --
Well, you're going to retire eventually anyway. Go ahead. COMMISSIONER SOLVIBILE: I've been kicked out of places like this, I guess. But I always say when -- this is what I found in my professional career: When it sounds like you should be able to do it, it's simple, zoning says no, you can't. And that's really -- and then where it seems like you can have 20 people living in a cardboard box, it says yes. So it goes from really common sense -- and I think we're beyond common sense in the code, and that's what this Commission should bring back into the 170 10/16/07 - L&I - RES. 070355 process, a common sense, easily understood zoning code that benefits the community, the Department, the inspectors, the development community. It benefits everybody.
Excuse me, Mr. Chairman. May I offer into the record, I have a five-page document that the community got together, and it's just some suggestions and it's titled "What Can License and Inspections Do?" A lot of this came from the current City code of saying that it would help alleviate the problems that we're having in our community. We understand that it's not one magic bullet to dispel the entire problem. It has to be piecemealed together. So I have -- I think over the six pages it's about maybe ten suggestions of what License and Inspections can do and I have a one10/16/07 - L&I - RES. 070355 of what City Council can do, if I can offer it for the record, please.
I just want to add I'm glad we only have one page and they have six. COMMISSIONER SOLVIBILE: That's always the case, and you all write the code.
Well, thank you for your testimony. I appreciate your time you took to come down here. Is there anyone else left to testify?
Are you asking for members of the public to come up and testify?
I didn't know if there were other people on your list that you were asking for. 172 10/16/07 - L&I - RES. 070355
My name is Al Alston. I'm President of an organization known as the African-American Business and Residents Association, and I am Secretary of a companion organization, the African-American Business and Residents Association CDC. Regretfully, we are so overwhelmed with other things that we actually didn't find out about this hearing until Pam sent an e-mail to our organization and let us know, so I don't have comprehensive testimony. This is a really important issue, and L&I, its procedures need to be examined for sure. But I wanted to offer a few statements. First of all, we run a community center. We call it Songhai City Cultural Center at 3117 Master Street, and we have had to go through just maybe ten different L&I inspectors over the last three years to make sure 173 10/16/07 - L&I - RES. 070355 that our building was fully up to code, and they made things, we thought, just much harder than they needed to be, but in the end, we received all of our approvals. We just had two inspections last month, and we had to spend an additional $5,000 to make some additional changes, but in the end, we have a building that is safer, that is better, that is a place that we can be even more proud of than we had before. And this is an important building for our community. It's the only community center we have in Brewerytown, and it's privately run, privately owned and its public-private partnership runs it. So on the plus side, we would like to say that from our experience with L&I, their inspectors tend to be tough but fair. And so overall on average, we think that that's great, that's a good thing that L&I is doing the right thing in terms of inspections. However, there are very serious problems, and there are 174 10/16/07 - L&I - RES. 070355 just three that I'd like to talk about. The first one is that while most inspectors seem to be just doing their jobs, there is often selective enforcement. And we find selective enforcement for purposes that we believe are political or sometimes personal, and I'll give you three quick examples. Rosemary Cubas and Lisa Sigurres of the Community Leadership Institute -- and Rosemary Cubas left us last year, may she rest in peace. They were active in eminent domain issues several years ago, and what they determined by communicating with L&I inspectors is that at a time when the City and the Redevelopment Authority really wanted to find properties they could take through eminent domain, the inspectors were given an order -- and we don't know how high up in L&I it came -- to, quote, go out and see what you can see, find essentially any property that looks abandoned and put an imminently 175 10/16/07 - L&I - RES. 070355 dangerous sign on it, whether or not it was imminently dangerous. " That's a political use of eminent domain, and it had nothing to do with the code. A second example of a political or personal purpose is that we wrote to Commissioner Solvibile when he was Acting Commissioner about three or four years ago. We complained about a developer that we believed had obtained zoning approval through the violation of ZBA Regulation 3. ZBA Regulation 3 talks about how long you're supposed to post your zoning notices so there's community notification. In fact, a zoning inspector's report stated that there was not the proper notice to the community. Yet the Zoning Board still heard the case and the community was not represented properly there, and so we argued to the -- and the Zoning Board granted 176 10/16/07 - L&I - RES. 070355 approval to this developer. And we argued in a letter to the Commissioner, the Acting Commissioner at the time, that any permits that follow from a violation of Regulation 3 are subject to Regulation 17, which says that that zoning approval didn't matter anymore, didn't count, it was null and void.
So we expect -- we cited court cases, we cited everything that was needed to show the Commissioner that he had the enforcement power to revoke any permits that were issued as a result of that improperly retained zoning. This was an enforcement matter. It wasn't even a legal matter at that point. But what did the Commissioner do -- and I'm glad he's here, because he denied us any meeting. Three months it took him to get back to us. Three months it took him. We've made follow-up phone calls. We visited his office. We did everything we could to meet with this man, but for three months he did nothing 177 10/16/07 - L&I - RES. 070355 that we could discern until he sent us a letter, and the letter simply said that he wasn't going to do anything and we had to go back to the Zoning Board to have them enforce their own decision or to reverse themselves. So the point is, for a political reason, we believe that he did some inaction. And I'm getting back to -- the point is, this is an example of --
Excuse me for one second. I appreciate you taking the time to come here and testify, but this is more of a private matter. The resolution was basically centered on the permit process and L&I and efficiencies.
And I understand that, and if I'm longwinded on this second example of what's wrong with L&I, I do apologize and I can move on so that -- but the point is, I was simply saying that there are times when L&I makes decisions that's based on politics 178 10/16/07 - L&I - RES. 070355 and not based on the Zoning Code. And a third example is what's happening right now to us. And I don't know what else to cite but things that we know for sure, but I'll just say it in two sentences. A developer is tearing down a wall that adjoins us, and we wanted to make sure that there was an engineer's report, that there was going to be proper enforcement of the Zoning Code -- excuse me; proper enforcement of the building code in terms of demolishing a shared wall essentially. So what we did is, we filed a complaint with L&I, and the inspector who came out started talking to us about his political beliefs and siding with the developer and not us. And what we found interesting here is that the -- we believe that the inaction that this inspector took was also based on politics. And we won't get into a lot of the details here or any more of the details, but we have situations where we 179 10/16/07 - L&I - RES. 070355 believe that L&I acts specifically because of political objectives, and because of that, we believe that there needs to be --
Sir, if you were here at the beginning of the hearing, I specifically said this isn't a critique of the License and Inspections Department.
So to get to three improvements that we are suggesting, I had to cite what examples we have of concerns. Well, the final -- and I won't give an example. I'll simply say that when you have a complaint against an inspector, you typically go to a supervisor, and there doesn't seem to be any standard that the supervisor uses to pull in another inspector that you believe perhaps has less bias or things of that sort. So essentially -- I'm sorry. That's a separate matter. And the final matter is that 180 10/16/07 - L&I - RES. 070355 you don't get notice if you're a neighbor of any demolition that's occurring on your block or in your community. There is no requirement, for instance, that the home next door to a building that's being demolished receives any notice. So you get a lot of unpleasant outcomes that occur, such as what we're experiencing now. So there are three things that we believe the City Council should investigate further when -- and I'm certain this resolution will be approved and we certainly hope that there is fact-finding that is significant and detailed, but there are three things we think that need to be included in that. One, a requirement of community notification of any demolition. So a public posting perhaps two weeks in advance, unless something is imminently dangerous, but a public posting on the actual property and a certified mail notice to the immediate neighbors, so 181 10/16/07 - L&I - RES. 070355 that if there are issues that an examiner has missed or if there are issues that a particular contractor is hiding, then the neighbors, such as a shared wall, the neighbors can point out to L&I, You know what, that permit shouldn't have been issued or it should be modified. Secondly, we believe that there needs to be a community/business watchdog created to address questions of bias within L&I. And bias can take any number of forms, from petty citations to non-uniform rules enforced throughout the City. This watchdog group should ensure that instructions given by L&I hierarchy are per the City Charter, and I'll cite the Rosemary Cubas example. And also receive whistleblower calls from within L&I. So the comments made by Attorney Pollack go directly to this point, and he cited great examples in Seattle, a Seattle independent bureau. And I think all of his reasons were 182 10/16/07 - L&I - RES. 070355 eloquently argued, and I think we really have to take them seriously. I know he spoke on an ad hoc basis, but I think that there is an important need to create an entity that polices the enforcement that L&I does or that perhaps just takes over the enforcement, because L&I too often is susceptible to political persuasion or just bias for some other reason. So while many of the individual inspectors I think do a fair job, when things go wrong, they really go wrong in L&I. And, finally, the third thing that I hope you focus on is that do nothing to rush through permits. Developers want permits to rush through and everybody would like them to happen as quickly as possible, but do nothing to rush them through unless you also include further community involvement in the permitting process. So if you're going to speed up the permitting process, make sure you're increasing community 183 10/16/07 - L&I - RES. 070355 notification and community participation so that unpleasant outcomes don't occur. So I do apologize if in fact you thought I wanted to resolve some personal matters here, but in fact, my only objective was to cite examples so that I could get to our conclusion. That's all. If there are any questions, I'd be happy to answer.
Good afternoon. Could you please identify yourself for the record.
Yes. My name is Eunice Birch and I'm a tenant, and the reason why I'm here is because I heard this morning on KYW that City Council is having some kind of meeting regarding 184 10/16/07 - L&I - RES. 070355 License and Inspection. And what my problem is is that I'm a tenant and in December I had notified License and Inspection of the property being without any heat. It took an inspector about like two weeks to come out and inspect the property, but after he inspected the property, the inspector never returned. And from December all the way up until June, there was no heat in the property. When I contacted the Commissioner, the Commissioner had the Deputy Commissioner to acknowledge my correspondence, and the Deputy Commissioner did inform me that the owner was to become prosecuted in the court, but what happened was, enforcement never enforced any code violations, and in June, they said that the owner had came into compliance, and in August, they said he did not have to be prosecuted, nor did the owner have to pay any fines that was associated with the code violations. And my concern was that I was a tenant, and he was supposed to be 185 10/16/07 - L&I - RES. 070355 providing -- and if License and Inspection is the agency that was responsible for ensuring that tenants receive heat, License and Inspections did not do this. And then by me not having heat for over seven months, the owner gets a pat on the back when the owner never really came into any kind of compliance. And if he was in violation and you're in violation and fines and penalties are associated with these violations, I don't understand how any person, not just an owner, any person can be in violation for about seven months and then all of a sudden you don't have to pay no fines, no nothing associated with these violations, and the tenant is the one that's still the victim. Ever since Saturday I've been trying to get heat.
We can look -- you have Councilman Savage here and Councilman Greenlee. We can look into that, and we have the Commissioner 186 10/16/07 - L&I - RES. 070355 behind you. But I thank you for taking the time out.
Yes, sir. That's the only reason why I'm here, and I thank you for allowing me the opportunity to be heard.
Thank you. This will be concluding the hearing on License and Inspections. I'd like to thank everybody that came out today. And, once again, I'd like to commend the L&I Department, Commissioner Solvibile, Deputy Commissioner Evans and Mr. Murray. You guys are doing a good job, and I think we're all in agreement that everyone that was here says -- you got a lot of accolades, but everyone is in agreement that we still need to go forward. You are doing a lot of great changes and there's still more changes that need to be made, and we will see recommendations. I appreciate everyone for coming out, and I conclude this hearing. 187 10/16/07 - L&I - RES. 070355 Thank you. (Committee on Licenses and Inspections adjourned at 4:10 p.m.) - - - 188 CERTIFICATE I HEREBY CERTIFY that the proceedings, evidence and objections are contained fully and accurately in the stenographic notes taken by me upon the foregoing matter on October 16, 2007, and that this is a true and correct transcript of same. ______________________________ MICHELE L. MURPHY RPR-Notary Public (The foregoing certification of this transcript does not apply to any reproduction of the same by any means, unless under the direct control and/or supervision of the certifying reporter.)