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HomeMy WebLinkAbout14-4647Fit ED - OF 11-1E PROTHONIL CUMBERLAND PENNSYLVAICOUNTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL CLUB OF SHIPPENSBURG ) (OHIO SPRINGS, INC. T/A SHEETZ, Applicant), ) CIVIL DIVISION Petitioner/Protestant, ) a ) ) ) STATUTORY APPEAL ) CASE NO. ) —1- Lib y ) vs. ) PETITION FOR APPEAL FROM ) DECISION OF PENNSYLVANIA ) LIQUOR CONTROL BOARD ) PENNSYLVANIA LIQUOR CONTROL ) BOARD, ) Respondent. ) Filed on Behalf of Petitioner, ) CIVIL CLUB OF SHIPPENSBURG ) ) Counsel of Record for this Party: ) ) Charles L. Caputo, Esq. ) Pa. I.D. #86058 ) ) Nicholas A. Miller, Esq. ) Pa. I.D. #204141 ) ) Caputo, Caputo & Regan, P.C. ) Buhl Building, 5th Floor ) 204 Fifth Avenue ) Pittsburgh, PA 15222 ) 412-325-0693 ) 412-690-2350 (facsimile) ) info@caputolawoffice.com awkA skl spa C,ILA aosL1g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIL CLUB OF SHIPPENSBURG ) (OHIO SPRINGS, INC. T/A SHEETZ, Applicant), ) ) Petitioner, ) ) ) vs. ) ) ) ) PENNSYLVANIA LIQUOR CONTROL ) BOARD, ) Respondent. ) CASE NO. PETITION FOR APPEAL FROM DECISION OF PENNSYLVANIA LIQUOR CONTROL BOARD Petitioner, Civic Club of Shippensburg, by and through its counsel, Charles L. Caputo, Esquire, Caputo, Caputo & Regan, P.C., hereby appeals from the July 17, 2014, Decision and Order of the Pennsylvania Liquor Control Board (the "Board") in Case No. 13-9164, and in support thereof, avers as follows: 1. Petitioner is a non-profit corporation subsisting and doing business under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 352 E. King Street, Shippensburg, Pennsylvania 17257. 2. Petitioner is a restrictive institution located within 300 feet of the proposed licensed premises under the Pennsylvania Liquor Code and has been granted protestant status by the Board. 3. Petitioner filed a protest letter with the Board and appeared at the administrative hearing held on March 18-19, 2014 to contest the application for transfer filed by Ohio Springs, Inc. t/a Sheetz. 4. Petitioner appeals from the July 17, 2014, Decision and Order of the Board in Case No. 13-9164, which approved the double inter -municipal transfer of Pennsylvania Restaurant Liquor License No. R-19377 (the "License") to Ohio Springs, Inc. t/a Sheetz for use at premises located at 359 E. King Street, Shippensburg, Pennsylvania 17257 (the "Licensed Premises"). A copy of the Board's Order is attached hereto, made a part hereof and marked as Exhibit "A". 5. The Board's Order is not supported by any Findings of Fact, Conclusions of Law or Opinion, which would inform the Petitioner as to the basis for the Board's approval of Ohio Springs' application, although the same is required by 47 P.S. §4-464. 6. Petitioner avers that the Board's decision was arbitrary, capricious, an abuse of discretion and contrary to law in that it was not supported by the testimony and evidence offered at the evidentiary hearing of March 18-19, 2014, and the Order is not fully in accord with existing law. 7. The Liquor Code does not provide any discretion on the part of the Board to allow transfers to places, properties or locations which sell gasoline, stating that the Board "shall refuse any application for a new license, the transfer of any license to a new location ... where the sale of liquid fuels or oil is conducted." See 47 P.S. § 404 (emphasis added). Additionally, Section 468 of the Liquor Code Provides: "fnlo license shall be transferred to any place or property upon which is located as a business the sale of liquid fuels and oil." 47 P.S. §4- 468(a)(3) (emphasis added). 8. It is clear from the record that Ohio Springs, Inc. t/a Sheetz sells liquid fuels from the same place, property and location for which the License was approved by the Board. 9. By reason of the foregoing it is asserted that the Board erred and abused its discretion in approving the double inter -municipal transfer of Pennsylvania Restaurant Liquor License No. R-19377 to Ohio Springs, Inc. t/a Sheetz for use at premises located at 359 E. King Street, Shippensburg, Pennsylvania. 10. Petitioner asserts that the Cumberland County Court of Common Pleas is empowered to hear this appeal de novo and determine this matter independently of the Order entered by the Board, with the requirement that this Court's decision be based upon findings of fact supported by the evidence. WHEREFORE, Petitioner prays that a hearing be held to review the decision of the Pennsylvania Liquor Control Board, and that this Honorable Court enter an Order reversing the Order of the Board and refusing the double inter -municipal transfer of Pennsylvania Restaurant Liquor License No. R-19377 to Ohio Springs, Inc. t/a Sheetz. Dated: August 4, 2014 Respectfully Submitted, Charles Laputo, Esquire Pa. I.D. No. 86058 Caputo, Caputo & Regan, P.C. Buhl Building, 5th Floor 204 Fifth Avenue Pittsburgh, PA 15222 412-325-0693 412-690-2350 (facsimile) info@caputolawoffice.com Attorneys for Petitioner Civic Club of Shippensburg 3 VERIFICATION I, CHARLES L. CAPUTO, ESQUIRE of CAPUTO, CAPUTO & REGAN, P.C., state that I am the attorney of record for Petitioner, Civic Club of Shippensburg, and that I am authorized to make this verification on behalf of Petitioner, and that the facts and averments set forth in the foregoing Petition for Appeal from Decision of Pennsylvania Liquor Control Board and Application for Supersedeas are true and correct based upon the knowledge, information and belief as provided to the undersigned by Petitioner. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn statements to authorities, which provides for criminal penalties if a person, with the intent to mislead, makes a written false statement which he does not believe to be true. This Verification is made by counsel due to the fact that Petitioner is not available to review and verify the Petition due to the limitations of time for submitting this Petition. Additional verifications will be obtained upon request. Dated: August 4, 2014 4 Charles . Caputo, Esquire LTRBDPRAPP 07/12 pennsyhrania LIQUOR CONTROL BOARD Northwest Office Building Harrisburg, Pennsylvania 17124-0001 ww,+.Icb.state.pa.us July 17, 2014 MARK FLAHERTY ESQUIRE 610 SMITHFIELD STREET SUITE 300 PITTSBURGH PA 15222 RE: License No. R-19377 LID No. 67077 Ohio Springs, Inc. Sheetz 359 East King Street Shippensburg, PA 17257-1424 Dear Attorney Flaherty: After considering the evidence presented at the hearing held on March 18, 2014 and March 19, 2014, the Pennsylvania Liquor Control Board, at its June 4, 2014 Board Session, approved the application for "Intermunicipal" double transfer of Restaurant Liquor License R-19377 to the above captioned location, from Ruby Tuesday, Inc., Hampden 8 Centre, Hampden Township, Mechanicsburg. Section 3.52(b) of the Board's Regulations states, "Licensed premises may not have an inside passage or communication to or with any business conducted by the licensee or other persons except as approved by the Board." Section 404 of the Liquor Code states in part, "The Board shall refuse any application for a new license or the transfer of any license to a location where the sale of liquid fuels or oil is conducted." After considering the circumstances in the instant case, the Board also approved the gas pumps located 80 feet distant and the request for interior connections with an unlicensed convenience store. The approval is subject to the following conditions: 1. The transferred license, which will now be issued in the name of the licensee for the premises listed in the application, shall be held in safekeeping by the Board pending completion of the premises and verification of full compliance with all statutory requirements. AN EQUAL OPPORTUNITY EMPLOYER EXHIBIT PROCEEDS BENEFIT ALL PENNSYLVANIANS 2 Mark Flaherty, Esquire July 17, 2014 2. PLCB-1854TP, "Certification of Completion," affirming all financial arrangements except the costs of construction/renovations to the licensed premises were completed as originally reported. Both parties must sign and date the Certification of Completion. The Certification of Completion must be returned to the Board within 15 days of the formal transaction completion date (settlement). Failure to conclude settlement within 30 days of the date of this letter may result in the approval being rescinded. 3. Completion of the premises and compliance with the requirements shall be accomplished within six (6) months from this date. Failure to comply with these requirements shall be considered cause for revocation of the license. 4. Upon completion of the premises, the following will be required to initiate final inspection: • Form PLCB-1689, "Application For Return of License From Safekeeping" and requisite fee. • PLCB-1854-TPF, "Certification of Completion," affirming all financial arrangements including the costs of construction/renovations to the licensed premises were completed as originally reported. If the financing has been modified the changes will be verified by the investigating officer during the final inspection of the premises. • One photograph at least 4" x 6" in size, of the exterior and main serving room. The photographs must have a matte finish. Documentary evidence that a valid health license is displayed on the premises. This may be in the form of a photocopy or a written statement from the issuing authority. • At the time of the investigation,the premises must be ready for operation as a bona fide restaurant. • Upon completion of the premises the attached forms should be completed naming a manager and returned to this office together with the required fee. One recent photograph of this individual must also be submitted. The photograph must have a matte finish. All above mentioned forms are attached for your client's convenience. Please retain for use when construction and/or alterations are completed. Your client's application is being approved in accordance with Section 461 of the Liquor Code which provides, in part, that this license cannot be transferred from the receiving municipality for a period of five (5) years after the date the licensed premises is operational. AN EQUAL OPPORTUNITY EMPLOYER PROCEEDS BENEFIT ALL PENNSYLVANIANS 3 Mark Flaherty, Esquire July 17, 2014 If you intend to conduct any catered functions during the calendar year in which the license is released from safekeeping, even though no functions have been scheduled, you must submit an Application for Off -Premises Catering Permit (form PLCB-2403) with the $500.00 filing fee within sixty (60) days of the premises becoming operational. Failure to submit the application and fee within that sixty (60) day period will disqualify you from obtaining permits for catered events during that calendar year. • A copy of the Board's Order is attached. Please see that your client receives the attached copy of this letter. Sincerely, —7-7 W . Gu �✓. Jerry W. Waters, Sr., Director Office of Regulatory Affairs Refer to: Licensing Board Case Section (717)787-6728 Hours:7:30 AM to 4:00 PM JWW:ch AN EQUAL OPPORTUNITY EMPLOYER PROCEEDS BENEFIT ALL PENNSYLVANIANS ITRBDPRAPP 07/12 pennsyLvania LIQUOR CONTROL BOARD Northwest Office Building Harrisburg, Pennsylvania 17124-0001 uww.Icb.state.pa.us July 31, 2014 MARK FLAHERTY ESQUIRE 610 SMITHFIELD STREET SUITE 300 PITTSBURGH PA 15222 AMENDED RE: License No. R-19377 LID No. 67077 Ohio Springs, Inc. Sheetz 359 East King Street Shippensburg, PA 17257-1424 Dear Attorney Flaherty: After considering the evidence presented at the hearing held on March 18, 2014 and March 19, 2014, the Pennsylvania Liquor Control Board, at its July 16, 2014 Board Session, approved the application for "Intermunicipal" double transfer of Restaurant Liquor License R-19377 to the above captioned location, from Ruby Tuesday, Inc., Hampden 8 Centre, Hampden Township, Mechanicsburg. Section 3.52(b) of the Board's Regulations states, "Licensed premises may not have an inside passage or communication to or with any business conducted by the licensee or other persons except as approved by the Board." Section 404 of the Liquor Code states in part, "The Board shall refuse any application for a new license or the transfer of any license to a location where the sale of liquid fuels or oil is conducted." After considering the circumstances in the instant case, the Board also approved the gas pumps located 80 feet distant and the request for interior connections with an unlicensed convenience store. The approval is subject to the following conditions: 1. The transferred license, which will now be issued in the name of the licensee for the premises listed in the application, shall be held in safekeeping by the Board pending completion of the premises and verification of full compliance with all statutory requirements. AN EQUAL OPPORTUNITY EMPLOYER PROCEEDS BENEFIT ALL PENNSYLVANIANS 2 Mark Flaherty, Esquire July 31, 2014 2. PLCB-1854TP, "Certification of Completion," affirming all financial arrangements except the costs of construction/renovations to the licensed premises were completed as originally reported. Both parties must sign and date the Certification of Completion. The Certification of Completion must be returned to the Board within 15 days of the formal transaction completion date (settlement). Failure to conclude settlement within 30 days of the date of this letter may result in the approval being rescinded. 3. Completion of the premises and compliance with the requirements shall be accomplished within six (6) months from this date. Failure to comply with these requirements shall be considered cause for revocation of the license. 4. Upon completion of the premises, the following will be required to initiate final inspection: • Form PLCB-1689, "Application For Return of License From Safekeeping" and requisite fee. • PLCB-1854-TPF, "Certification of Completion," affirming all financial arrangements including the costs of construction/renovations to the licensed premises were completed as originally reported. If the financing has been modified the changes will be verified by the investigating officer during the final inspection of the premises. • One photograph at least 4" x 6" in size, of the exterior and main serving room. The photographs must have a matte finish. • Documentary evidence that a valid health license is displayed on the premises. This may be in the form of a photocopy or a written statement from the issuing authority. • At the time of the investigation, the premises must be ready for operation as a bona fide restaurant. • Upon completion of the premises the attached forms should be completed naming a manager and returned to this office together with the required fee. One recent photograph of this individual must also be submitted. The photograph must have a matte finish. All above mentioned forms are attached for your client's convenience. Please retain for use when construction and/or alterations are completed. Your client's application is being approved in accordance with Section 461 of the Liquor Code which provides, in part, that this license cannot be transferred from the receiving municipality for a period of five (5) years after the date the licensed premises is operational. AN EQUAL OPPORTUNITY EMPLOYER PROCEEDS BENEFIT ALL PENNSYLVANIANS 3 Mark Flaherty, Esquire July 31, 2014 If you intend to conduct any catered functions during the calendar year in which the license is released from safekeeping, even though no functions have been scheduled, you must submit an Application for Off -Premises Catering Permit (form PLCB-2403) with the $500.00 filing fee within sixty (60) days of the premises becoming operational. Failure to submit the application and. fee within that sixty (60) day period will disqualify you from obtaining permits for catered events during that calendar year. A copy of the Board's Order is attached. Please see that your client receives the attached copy of this letter. Sincerely, / w Jerry W. Waters, Sr., Director Office of Regulatory Affairs Refer to: Licensing Board Case Section (717)787-6728 Hours:7:30 AM to 4:00 PM JWW:ch AN EQUAL OPPORTUNITY EMPLOYER PROCEEDS BENEFIT ALL PENNSYLVANIANS ORDER 11/07 BEFORE THE PENNSYLVANIA LIQUOR CONTROL BOARD OHIO SPRINGS, INC. Sheetz 359 East King Street Shippensburg, PA 17257-1424 Case No. 13-9164 LID No. 67077 Application filed on a Prior Approval Basis for "Intetrmunicipal" Double Transfer of Restaurant Liquor License R-19377 The Board, after giving careful consideration to all of the facts established at the hearing, and in the exercise of its discretion, makes the following Order: ORDER AND NOW, July 17, 2014, it is ordered and decreed that the Pennsylvania Liquor Control Board approved the application for "Intermunicipal" double transfer of Restaurant Liquor License R-19377 applied for by Ohio Springs, Inc., Sheetz for premises at 359 East King Street, Shippensburg, Cumberland County. In the event an appeal is filed an Opinion will be issued. Alvin Oberholtzer, Sharon Hershey, Lewis Deardorff, and Luke and Lois Martin should not be granted standing as intervenors in this matter because they did not attend and testify at the hearing on how they would be would be directly aggrieved by the approval of Applicant's application. Jaye Alleman should be granted standing as a protestant in the instant matter because he resides within 500 feet of the proposed licensed premises. The Civic Club of Shippensburg should be granted standing as a protestant in the instant matter because it is a charitable institution that is located within 300 feet of the proposed licensed premises. John Mummau should not be granted standing as an intervenor in this matter because he did not provide sufficient non -speculative evidence on how he would be directly aggrieved by the approval of Applicant's application. James Andrews should not be granted standing•as an intervenor he did not provide sufficient non -speculative evidence on how aggrieved by the approval of Applicant's application. Terry Helm should not be granted standing as an intervenor in did not provide sufficient good cause for his late -filed petition. Gabler's Beverage Distributor should be granted standing as matter based on the Ohio Springs and Wegmans' decisions. in this matter because he would be directly this matter because he an intervenor in this Ohio Springs, Inc. July 17, 2014 PKD, Inc. should be granted standing as an intervenor in this matter based on the Ohio Springs and s' decisions. Malt Beverage Distributors Association should be granted standing as an intervenor in this matter based on the Ohio Springs and Wegmans' decisions. PENNSYLVANIA LIQUOR CONTROL BOARD Joseph E. Brion BY: Chairman Robert S. Marcus Member Tim Holden Member ATTEST: John K. Stark Secretary CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within PETITION FOR APPEAL FROM DECISION OF PENNSYLVANIA LIQUOR CONTROL BOARD was forwarded to the parties and counsel listed below by facsimile and U.S. Mail, postage prepaid, this 5 th day of August, 2014. Faith S. Diehl, Esquire Pennsylvania Liquor Control Board Office of Chief Counsel 401 Northwest Office Building Capital and Forster Streets Harrisburg, PA 17124-0001 Commonwealth of Pennsylvania Pennsylvania Liquor Control Board Bureau of Licensing Northwest Office Building, Room 108 Harrisburg, PA 17124-0001 ATTENTION: Tisha Albert Mark Flaherty, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15222 Charles 1/Caputo, Esquire Counsel for Petitioner 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, applicant), Petitioner/Protestant, vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. {F1074233.1} CIVIL DIVISION STATUTORY APPEAL CASE NO. 14-4647 NOTICE OF INTERVENTION Filed on behalf of Intervenor, Ohio Springs, Inc. t/a SHEETZ Counsel of Record for this Party Mark F. Flaherty, Esquire Pa. I.D. #46596 Stanley J. Wolowski, Esquire Pa. I.D. # 32978 Mark E. Kozar, Esquire Pa. I.D. No. 78541 Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15212 412-456-2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIL CLUB OF SHIPPENSBURG ) (OHIO SPRINGS, INC. T/A SHEETZ, applicant), ) ) ) Petitioner/Protestant, ) ) ) vs. ) ) ) PENNSYLVANIA LIQUOR CONTROL ) BOARD ) Respondent. ) CASE NO. 14-4647 NOTICE OF INTERVENTION Notice is hereby given that Ohio Springs, Inc. t/a SHEETZ, a party below, hereby intervenes in this matter. Stanley J. Wolowski, Esquire Pa. I.D. No. 32978 Mark E. Kozar, Esquire Pa. I.D. No. 78541 Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15222 {F1074233.1 } CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within NOTICE OF INTERVENTION was forwarded to the parties and counsel listed below by facsimile and U.S. Mail, postage prepaid, this g day of August, 2014: Faith S. Diehl Pennsylvania Liquor Control Board PA Liquor Control Board 401 NW Ofc Bldg Harrisburg, PA 17124-0001 (717) 783-9454 Commonwealth of Pennsylvania Pennsylvania Liquor Control Board Bureau of Licensing Northwest Office Building, Room 108 Capital and Forster Streets Harrisburg, PA 17124-0001 Charles L. Caputo, Esq. Caputo, Caputo & Regan, P.C. 204 5th Ave, Floor 5 Pittsburgh, PA 15222-2706 (412) 325-0693 Nicholas A. Miller, Esq. Caputo, Caputo & Regan, P.C. 204 5th Ave, Floor 5 Pittsburgh, PA 15222-2706 {F1074233.1} la erty, Counsel for Interve squire or 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIL CLUB OF SHIPPENSBURG ) (OHIO SPRINGS, INC. T/A SHEETZ, Applicant), ) Petitioner, ) Ou; (, fCASE NO. )4, vs. ) PENNSYLVANIA LIQUOR CONTROL ) BOARD, ) Respondent. ) ORDER OF COURT AND NOW, to -wit, this heday of aural, , 2014, upon consideration of the within Petition for Appeal it is hereby ORDERED, ADJUDGED and DECREED as follows: A hearing on the Appeal of the Petitioner is hereby scheduled for the qday of ?J, 2011, before the Honorable Judge 7(.jytJ at /d : 3e o'clock 4 .m in Courtroom No. / 044-11 !.tafizliY BY THE COURT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIL CLUB OF SHIPPENSBURG ) (OHIO SPRINGS, INC. T/A SHEETZ, applicant), ) ) ) Petitioner/Protestant, ) ) ) vs. ) ) ) PENNSYLVANIA LIQUOR CONTROL ) BOARD ) Respondent. ) ORDER CASE NO. 14-4647 AND NOW, this / 3 v day of 41 w» , 2014, upon consideration of the Notice to Intervene filed by Ohio Springs, Inc. t/a SHEETZ, it is hereby ORDERED that Intervenor status to Ohio Spring, Inc. T/A SHEETZ is GRANTED. {F1074233.1} BY THE COURT: .4 ,/ BEFORE THE PENNSYLVANIA LIQUOR CONTROL BOARD IN RE: • • OHIO SPRINGS, INC. • t/a Sheetz • 359 East King Street : Shippensburg, PA 17257-14241 : 19-(449117 Case No. 13-91.€4 Application for Intermunicipal Double Transfer of Restaurant Liquor License No. R-19377 (LID 67077) OPINION Ohio Springs, Inc. t/a Sheetz ("Applicant") filed its application on a prior approval basis with the Pennsylvania Liquor Control Board ("Board") for the intermunicipal double transfer of Restaurant Liquor License No. R-19377 to 359 East King Street, Shippensburg, Pennsylvania ("proposed licensed premises"). The Board's Bureau of Licensing ("Licensing"), pursuant to section 464 of the Liquor Code [47 P.S. § 4-464], ordered that a hearing be held with respect to Applicant's transfer application regarding thirteen (13) specific objections. Hearings were held in Harrisburg, Pennsylvania, on March 18 and 19, 2014, before the same Board hearing examiner. Based upon its review of the record from that hearing, the Board, by Order dated July 17, 2014, granted prior 1 Last four (4) digits of zip code were not specified in caption. 1 approval of Applicant's intermunicipal double transfer application.2 This Opinion is issued in support of the Board's Order. FINDINGS OF FACT 1. On July 30, 2012, Applicant filed a prior approval application for the intermunicipal double transfer of Restaurant Liquor License No. R-19377 from Ruby Tuesday, Inc., located at Hampden 8 Centre, Mechanicsburg, Pennsylvania, to Applicant, for its premises located at 359 East King Street, Shippensburg, Pennsylvania. Ruby Tuesday, Inc. is located in Hampden Township; the proposed licensed premises is located in the Borough of Shippensburg. Both locations are located in Cumberland County. (N.T. 03/18/2014 at 5-8; Ex. B-1). 2. Applicant requested that its application be considered for prior approval.3 (N.T. 03/18/2014 at 5-8; Ex. B-1). 3. Applicant's proposed licensed areas are: a serving area measuring thirty-two (32) feet eighteen (18) feet that will accommodate thirty-eight (38) patrons; two (2) serving areas with no 2 The Board granted standing as intervenors in the instant matter to Gabler's Beverage Distributor, Inc., PKD, Inc., and Malt Beverage Distributor's Association. The Board denied intervenor standing to Alvin Oberholtzer, Sharon Hershey, Lewis Deardorff, Luke and Lois Martin, John Mummau, James Andrews, and Terry Helm. The Board granted standing as protestants to Jaye Alleman and the Civic Club of Shippensburg. 3 The Board may grant prior approval to an applicant whose proposed licensed prernises is not yet complete. 2 seating for patrons, measuring eighty (80) feet by thirty-seven (37) feet and ten (10) feet by six (6) feet; two (2) kitchen areas, measuring thirty (30) feet by twenty-three (23) feet and fifty-eight (58) feet by twelve (12) feet; an office area measuring nine (9) feet by ten (10) feet; and seven (7) storage areas, measuring twenty-two (22) feet by thirty-eight (38) feet, twenty (20) feet by thirty-two (32) feet, thirteen (13) feet by nine (9) feet, thirteen (13) feet by seventeen (17) feet, seven (7) feet by seven (7) feet, seventeen (17) feet by seven (7) feet, and thirteen (13) feet by six (6) feet. (N.T. 03/18/2014 at 5-8; Ex. B-1). 4. The quota of retail licenses in Shippensburg Borough, Cumberland County, is one (1), and there are three (3) restaurant liquor licenses and one (1) eating place malt beverage license in effect counted against the quota, plus two (2) hotel liquor licenses and four (4) catering club liquor licenses not counted against the quota. (N.T. 03/18/2014 at 6-8; Ex. B-2). 5. By letter dated October 23, 2013, Licensing informed Applicant, through its attorney, that a hearing would be held in Harrisburg, Pennsylvania on November 19, 2013 and will continue on November 20, 2013, if necessary, for the purpose of taking testimony regarding the following objections: 3 1. The applicant has failed to submit individual photographs of proposed corporate officers, Thomas Luciano, Thomas Patton[,] and Gary Zimmerman. 2. The Board shall take evidence to determine if it should permit an interior connection with the unlicensed convenience store in accordance with Section 3.52(b) of the Board's Regulations [(40 Pa. Code § 3.52(b))]. The Board shall take evidence to determine what "take home products" consist of which are intended to be sold in the adjacent unlicensed area. 4. The Board shall take evidence to determine what convenience store items the applicant intends to sell on the licensed premises. 5. The Board shall take evidence to determine whether it should permit the applicant to operate another business (convenience store items) on the licensed premises in accordance with Section 3.52(c) of the Board's Regulations [(40 Pa. Code § 3.52(c))]. 6. The Board shall take evidence to determine if the applicant will allow minors to frequent its licensed premises, in violation of Section 493(14) of the Liquor Code [(47 P.S. § 4-493(14))]. 7. The Board shall take evidence concerning the sale of liquid fuels or oil at the same location as the proposed licensed premises, which is prohibited by Section 404 of the Liquor Code [(47 P.S. § 4-404)]. 8 The Board shall take evidence to determine if there are valid reasons for filing their petitions -to -intervene late and if Alvin Oberholtzer, Terry Helm, and Sharon Hershey would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 4 9. The Board shall take evidence to determine if John Mummau, Lewis Deardorff, Luke and Lois Martin, James Andrews{,] and the Civic Club of Shippensburg would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 10. The Board shall take evidence to determine if the Malt Beverage Distributors Association (MBDA), Gabler's Beverage Distributor, Inc.[,] and PKD, Inc. would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. See In re Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 (1983); Malt Bevs. Distribs. Ass'n v. Pa. Liquor Control Bd., 881 A.2d 37 (Pa. Cmwlth. 2005). 11. The Board shall take evidence to determine that the approval of this application will not adversely affect the health, welfare, peace and morals of the neighborhood within a radius of 500 feet of the proposed licensed premises. 12. A timely -filed, valid protest was received from Jaye Alleman, a resident within 500 feet of the proposed licensed premises. (N.T. 03/18/2014 at 6-8; Ex. B-3). 6. By letter dated November 8, 2013, Licensing informed Applicant, through its attorney, that a hearing would be held in Harrisburg, Pennsylvania on November 19, 2013 and will continue on November 20, 2013, if necessary, for the purpose of taking testimony regarding the following amended objections: 5 1. The applicant has failed to submit individual photographs of proposed corporate officers, Thomas Luciano, Thomas Patton[,] and Gary Zimmerman. 2. The Board shall take evidence to determine if it should permit an interior connection with the unlicensed convenience store in accordance with Section 3.52(b) of the Board's Regulations [(40 Pa. Code § 3.52(b))]. The Board shall take evidence to determine what "take home products" consist of which are intended to be sold in the adjacent unlicensed area. 4. The Board shall take evidence to determine what convenience store items the applicant intends to sell on the licensed premises. 5. The Board shall take evidence to determine whether it should permit the applicant to operate another business (convenience store items) on the licensed premises in accordance with Section 3.52(c) of the Board's Regulations [(40 Pa. Code § 3.52(c))]. 6. The Board shall take evidence to determine if the applicant will allow minors to frequent its licensed premises, in violation of Section 493(14) of the Liquor Code [(47 P.S. § 4-493(14))]. 7. The Board shall take evidence concerning the sale of liquid fuels or oil at the same location as the proposed licensed premises, which is prohibited by Sections 404 and/or 468 of the Liquor Code [(47 P.S. §§ 4-404, 4-468)]. 8. The Board shall take evidence to determine if there are valid reasons for filing their petitions -to -intervene late and if Alvin Oberholtzer, Terry Helm, and Sharon Hershey would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 6 9. The Board shall take evidence to determine if John Mummau, Lewis Deardorff, Luke and Lois Martin, James Andrews[,] and the Civic Club of Shippensburg would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 10. The Board shall take evidence to determine if the Malt Beverage Distributors Association (MBDA), Gabler's Beverage Distributor, Inc.[,] and PKD, Inc. would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. See In re Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 (1983); Malt Bevs. Distribs. Ass'n v. Pa. Liquor Control Bd., 881 A.2d 37 (Pa. Cmwlth. 2005). 11. The Board shall take evidence to determine that the approval of this application will not adversely affect the health, welfare, peace and morals of the neighborhood within a radius of 500 feet of the proposed licensed premises. 12. A timely -filed, valid protest was received from Jaye Alleman, a resident within 500 feet of the proposed licensed premises. (N.T. 03/18/2014 at 6-8; Ex. B-4). 7. By letter dated February 10, 2014, Licensing informed Applicant, through its attorney, that the hearing that was scheduled for November 19, 2013 and postponed, would be rescheduled for March 18, 2014 and continued to March 19, 2014, if needed, in Harrisburg, Pennsylvania for the purpose of taking testimony regarding the following amended objections: 7 1. The Board shall take evidence to determine if it should permit an interior connection with the unlicensed convenience store in accordance with Section 3.52(b) of the Board's Regulations [(40 Pa. Code § 3.52(b))]. 2. The Board shall take evidence to determine what "take home products" consist of which are intended to be sold in the adjacent unlicensed area. The Board shall take evidence to determine what convenience store items the applicant intends to sell on the licensed premises. 4. The Board shall take evidence to determine whether it should permit the applicant to operate another business (convenience store items) on the licensed premises in accordance with Section 3.52(c) of the Board's Regulations [(40 Pa. Code § 3.52(c))]. 5. The Board shall take evidence to determine if the applicant will allow minors to frequent its licensed premises, in violation of Section 493(14) of the Liquor Code [(47 P.S. § 4-493(14))]. 6. The Board shall take evidence concerning the sale of liquid fuels or oil at the same location as the proposed licensed premises, which is prohibited by Sections 404 and/or 468 of the Liquor Code [(47 P.S. §§ 4-404, 4-468)]. 7. The Board shall take evidence to determine if there are valid reasons for filing their petitions -to -intervene late and if Alvin Oberholtzer, Terry Helm, and Sharon Hershey would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 8. The Board shall take evidence to determine if John Mummau, Lewis Deardorff, Luke and Lois Martin, James Andrews[,] and the Civic Club of Shippensburg 8 would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 9. The Board shall take evidence to determine if the Malt Beverage Distributors Association (MBDA), Gabler's Beverage Distributor, Inc.[,] and PKD, Inc. would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. See In re Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 (1983); Malt Bevs. Distribs. Ass'n v. Pa. Liquor Control Bd., 881 A.2d 37 (Pa. Cmwlth. 2005). 10. The Board shall take evidence to determine that the approval of this application will not adversely affect the health, welfare, peace and morals of the neighborhood within a radius of 500 feet of the proposed licensed premises. 11. A timely -filed, valid protest was received from Jaye Alieman, a resident within 500 feet of the proposed licensed premises. (N.T. 03/18/2014 at 6-8; Ex. B-5). 8. By letter dated March 3, 2014, Licensing informed Applicant, through its attorney, that a hearing would be held in Harrisburg, Pennsylvania on March 18, 2014 and would continue on March 19, 2014, if necessary, for the purpose of taking testimony regarding the following amended objections: 1. The Board shall take evidence to determine if the proposed licensed premises will be located within 300 feet of a charitable institution as defined by Section 404 of the Liquor Code [(47 P.S. § 4-404)]. 9 2. The Board shall take evidence to determine if it should permit an interior connection with the unlicensed convenience store in accordance with Section 3.52(b) of the Board's Regulations [(40 Pa. Code § 3.52(b))]. 3. The Board shall take evidence to determine what "take home products" consist of which are intended to be sold in the adjacent unlicensed area. 4. The Board shall take evidence to determine what convenience store items the applicant intends to sell on the licensed premises. 5. The Board shall take evidence to determine whether it should permit the applicant to operate another business (convenience store items) on the licensed premises in accordance with Section 3.52(c) of the Board's Regulations [(40 Pa. Code § 3.52(c))]. 6. The Board shall take evidence to determine if the applicant will allow minors to frequent its licensed premises, in violation of Section 493(14) of the Liquor Code [(47 P.S. § 4-493(14))]. 7. The Board shall take evidence concerning the sale of liquid fuels or oil at the same location as the proposed licensed premises, which is prohibited by Sections 404 and/or 468 of the Liquor Code [(47 P.S. §§ 4-404, 4-468)]. 8. The Board shall take evidence to determine if there are valid reasons for filing their petitions -to -intervene late and if Alvin Oberholtzer, Terry Helm, and Sharon Hershey would be directly aggrieved by the granting of this application, which would qualify them as intervenors in this matter. 9. The Board shall take evidence to determine if John Mummau, Lewis Deardorff, Luke and Lois Martin, James Andrews [would] be directly aggrieved by the 10 granting of this application, which would qualify them as intervenors in this matter. 10. The Board shall take evidence to determine if the Civic Club of Shippensburg meets the requirements of a charitable institution as defined under Section 404 of the Liquor Code and any relevant case law and/or if they would be directly aggrieved by the granting of this application, which would qualify them as an intervenor in this matter [(47 P.S. § 4-404)]. 11. The Board shall take evidence to determine if the Malt Beverage Distributors Association (MBDA), Gabler's Beverage Distributor, Inc. and [PKD, Inc. would be directly aggrieved by the granting of this application,] which would qualify them as intervenors in this matter. See In re Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 PKD, Inc. would be directly aggrieved by the granting of this application, (sic) (1983); Malt Bevs. Distribs. Ass'n v. Pa. Liquor Control Bd., 881 A.2d 37 (Pa. Cmwlth. 2005). 12. The Board shall take evidence to determine that the approval of this application will not adversely affect the health, welfare, peace and morals of the neighborhood within a radius of 500 feet of the proposed licensed premises. 13. A timely -filed, valid protest was received from Jaye Alleman, a resident within 500 feet of the proposed licensed premises. (N.T. 03/18/2014 at 6-8; Ex. B-6). 9. On July 17, 2012, the Borough of Shippensburg adopted Resolution No. 12-015, approving the proposed intermunicipal transfer of Restaurant Liquor License No. R-19377 into the Borough of 11 Shippensburg by Applicant. (N.T. 03/18/2014 at 7-8; Ex. B-8). 10. Timothy Lamark is a Licensing supervisor and he was assigned to investigate Applicant's transfer application. (N.T. 03/18/2014 at 9). 11. The Civic Club of Shippensburg ("Civic Club") is the only restrictive institution located within three hundred (300) feet of the proposed licensed premises. It is located one hundred ninety-four (194) feet from the proposed licensed premises' property line and two hundred five (205) feet from Applicant's building. (N.T. 03/18/2014 at 10). 12. The Civic Club was closed when Mr. Lamark initially went to the proposed licensed premises, but he talked to two (2) of the Civic Club's members, Priscilla Smith and Jean Eschenman, via the telephone regarding the Civic Club. (N.T. 03/18/2014 at 12-13). 13. Ms. Smith and Ms. Eschenman told Mr. Lamark the Civic Club had artifacts, provided tours, and had digs on its side lawn for artifacts, but he did not remember "exactly what" the Civic Club did. The Civic Club did not have the "typical things" that Mr. Lamark normally sees in a restrictive institution. (N.T. 03/18/2014 at 12, 30). 14. Mr. Lamark did not conduct an investigation of the Civic Club's non-profit status nor did he recall inquiring as to what the Civic Club's mission and purpose was. (N.T. 03/18/2014 at 28-30). 12 15. During the telephone call, Mr. Lamark advised Ms. Smith and Ms. Eschenman to contact Licensing if "they wanted to pursue further action." (N.T. 03/18/2014 at 12). 16. The neighborhood within a radius of five hundred (500) feet of the proposed licensed premises is sixty percent (60%) residential and forty percent (40%) commercial. (N.T. 03/18/2014 at 14). 17. The proposed licensed premises will have three (3) serving rooms, seven (7) storage rooms, two (2) kitchens, and an office. There will be an adjoining but separate smaller unlicensed convenience store area with an interior connection to the proposed licensed premises being four (4) feet wide. (N.T. 03/18/2014 at 14). 18. Mr. Lamark understood the premises would "act as a normal Sheetz convenience store;" it will provide food via "made to order screen[s]" and it will also have food items, such as chips and snacks in the aisles. The proposed licensed premises will permit on -premises consumption of beer and food. (N.T. 03/18/2014 at 15-16). 19. Applicant's unlicensed premises will provide "take-home products," such as dairy, bulk soda, and candy. Also, this area will have coolers for its refrigerated products. (N.T. 03/18/2014 at 15- 16). 20. Applicant's plan provided to Mr. Lamark showed that Applicant 13 would accept payment for gasoline at the unlicensed area of its convenience store. However, Mr. Lamark testified that based on his prior discussions with Applicant, he was not able to contradict the statement that Applicant's gasoline sales would occur at the pumps and no payment for gasoline would occur at the unlicensed area of the convenience store. (N.T. 03/18/2014 at 64-67). 21. Applicant provided Mr. Lamark with a site plan that showed it was planning on selling liquid fuels at drive -up fuel pumps located approximately eighty (80) feet from the proposed licensed premises. Also, the site plan shows a continuous speed bump between the unlicensed gas pump area and the proposed licensed premises, approximately five (5) feet from the gas pump area. Lastly, the site plan showed a parking lot with parking lanes, curb, bumper posts, patio area, and sidewalk, between the speed bump and proposed licensed premises. (N.T. 03/18/2014 at 16-17, 49-51 53-55, 67-68; Ex. B-7). 22. Applicant initially advised Mr. Lamark that kerosene would be sold at an unlicensed area at the Shippensburg Sheetz facility, approximately forty-five (45) feet from the proposed licensed premises. However, Applicant's attorney, Mr. Flaherty, later advised Licensing that kerosene would not be sold on the premises. (N.T. 14 03/18/2014 at 17, 49, 55-58; Ex. B-7). 23. Mr. Lamark acknowledged that it is not unusual for an applicant of a liquor license to make changes to its site plan or floor plan after the Licensing's analyst's initial investigation had been completed, but before the Board had approved the license. Applicant did not provide Mr. Lamark with an updated site plan. (N.T. 03/18/2014 at 62-63, 65-66). 24. Applicant advised Mr. Lamark that propane canisters would be sold on the unlicensed premises. (N.T. 03/18/2014 at 49, 72-74). 25. The unlicensed portion of Applicant's building will have its own cash register and the proposed licensed premises will have three (3) cash registers. Mr. Lamark's understanding is that Applicant's patrons can purchase food, beer, and non-alcoholic beverages only at the proposed licensed premises' cash registers. (N.T. 03/18/2014 at 17- 18). 26. Applicant did not indicate to Mr. Lamark the steps it was planning on taking to prevent sales to minors. (N.T. 03/18/2014 at 18). 27. Mr. Lamark indicated that an applicant provides Licensing with its proposed plans for an application submitted for prior approval and Licensing conducts an inspection when the construction of the 15 proposed licensed premises has been completed. (N.T. 03/18/2014 at 21-22). 28. There will be one (1) direct interior connection between the proposed licensed premises and unlicensed convenience store area. There will be two (2) proposed exterior entrances to Applicant's unlicensed area and three (3) proposed exterior entrances to the proposed licensed premises. Mr. Lamark was not sure how many of the exterior entrances will be open to the public. (N.T. 03/18/2014 at 22; Ex. B-7). 29. There are no other licensees located within five hundred (500) feet of the proposed licensed premises that sell alcohol. (N.T. 03/18/2014 at 26). 30. Applicant provided Mr. Lamark with a copy of a lease, which was separated into two (2) units, one (1) being the proposed licensed premises and the second being the unlicensed premises. The parties to the lease are the owner, CSP Investments, Inc. (lessor) and Applicant (lessee). (N.T. 03/18/2014 at 30-33, 35). 31. Any time Licensing receives an application for a liquor license which has a connection to an unlicensed business, Licensing reviews the lease and makes a determination who owns and operates the building. (N.T. 03/18/2014 at 32-33). 16 32. Applicant provided its sources of funds for the construction of the building where Applicant's premises will be located to Licensing. (N.T. 03/18/2014 at 39-40). 33. Applicant will not have any licensed outside serving areas, but there will be outside seating areas. The outside seating areas will be located in front of the common foyer, in front of the twenty-two (22) feet by thirty-eight (38) feet walk-in cooler storage area, and to the left of the thirty (30) feet by twenty-three (23) feet kitchen area. (N.T. 03/18/2014 at 41-44; Ex. B-7). 34. Applicant advised Mr. Lamark that it estimated ninety-five percent (95%) of its anticipated beer sales will be attributable to take- out beer. (N.T. 03/18/2014 at 46-47). 35. Mr. Lamark verified that the street address of 359 East King Street was the correct street address for Applicant's premises. (N.T. 03/18/2014 at 59-60). 36. Mr. Lamark determined that Applicant's Notice of Application was properly posted on August 6, 2012, with a posting date of July 30, 2012. (N.T. 03/18/2014 at 60, 71-72). 37. Terry Helm resides at 225 East Garfield Street in Shippensburg; his residence is located a couple blocks from the proposed licensed premises. Mr. Helm filed a petition to intervene in 17 the instant matter. (N.T. 03/18/2014 at 78-80). 38. Mr. Helm indicated that where he previously lived, a licensee opened and there was trash, urinating in the streets, and a report of vandalism to a neighbor's car. Mr. Helm believed licensing the proposed licensed premises would add "fuel to the fire/' because there would be traffic problems, public drunkenness, and parking problems. (N.T. 03/18/2014 at 81-83). 39. Mr. Helm believes the more alcohol that is sold, the more problems that will occur and he is opposed to any licensed establishment operating in the Borough of Shippensburg, not just Applicant. Mr. Helm also is opposed to having the Board's Wine and Spirits Stores located in the Borough of Shippensburg. (N.T. 03/18/2014 at 83-84, 87). 40. Mr. Helm indicated that the current Shippensburg Sheetz location is a "madhouse" because "[t]he college comes, football games, and all of that." He also expressed a concern regarding a bad intersection located near the proposed licensed premises. (N.T. 03/18/2014 at 92). 41. Mr. Helm also expressed a concern, albeit mistaken, that the Civic Club and two (2) churches are located within five hundred (500) feet of the proposed licensed premises. (N.T. 03/18/2014 at 84-85). 18 42. Mr. Helm's petition to intervene was postmarked September 7, 2012 and he provided no explanation at the instant hearing as to why it was not filed timely within thirty (30) days of the July 30, 2012 posting of Applicant's Notice of Application. (N.T. 03/18/2014 at 89). 43. Mr. Helm did not attend the July 2012 Shippensburg Borough Council public hearing regarding the proposed licensed premises. (N.T. 03/18/2014 at 91). 44. The following petitioners did not attend the instant hearing: Alvin Oberhultzer, Sharon Hershey, Louis Deardorff, and Luke and Lois Martin. (N.T. 03/18/2014 at 93, 100). 45. John Mummau resides at 7001 Molly Pitcher Highway, which is located approximately four (4) miles south of the proposed licensed premises. Mr. Mummau has lived at this location since 1966 and he filed a petition to intervene in the instant matter. (N.T. 03/18/2014 at 93-94). 46. Mr. Mummau opposes the proposed licensed premises because in 2005, his sister-in-law and brother-in-law were killed by a seventeen (17) -year-old drunk driver in the state of Indiana. (N.T. 03/18/2014 at 94-95). 47. Mr. Mummau testified regarding an incident that involved his son, who was attending Penn State University at the time of the 19 incident. Mr. Mummau related that his son came home after work and encountered an unconscious, intoxicated twenty-one (21)-year-old student in the backyard of a neighboring home. Mr. Mummau's son and another individual transported this unconscious individual to the hospital and were told that if they had not acted, the unconscious individual would have died. (N.T. 03/18/2014 at 95-96). 48. Mr. Mummau has been opposed to drinking all of his life and he believes there are "too many stores and alcohol places in Shippensburg." (N.T. 03/18/2014 at 96). 49. Mr. Mummau indicated the proposed licensed premises is located two (2) blocks from Shippensburg University, which has approximately six thousand (6,000) students. Mr. Mummau is concerned that if Applicant's transfer application is approved, there may be incidents of driving under the influence and public drunkenness. (N.T. 03/18/2014 at 96-97). 50. Mr. Mummau is generally opposed to the sale of alcohol at the proposed licensed premises and his opposition is not related to Applicant or its business. Mr. Mummau indicated that if the proposed premises is licensed, "it's the last time I will buy gas at any Sheetz store." (N.T. 03/18/2014 at 98). 51. James Andrews resides at 7009 Molly Pitcher Highway, which 20 is located approximately four (4) miles from the proposed licensed premises. Mr. Andrews has lived at this location on and off for sixty (60) years and he filed a petition to intervene in the instant matter. (N.T. 03/18/2014 at 100-102). 52. Mr. Andrews is opposed to the application because "children" will have access twenty-four (24) hours a day to the proposed licensed premises, and will be able to see alcohol being purchased and consumed. (N.T. 03/18/2014 at 102). 53. Mr. Andrews is concerned that with Shippensburg University being two (2) blocks from the proposed licensed premises, it would be "very accessible for anyone to buy alcohol and allow these college students to consume it." Mr. Andrews is also concerned about "lives being destroyed by impaired drivers." (N.T. 03/18/2014 at 103). 54. Mr. Andrews is against a convenience store being licensed to sell alcohol where it can be "accessed by anybody." Mr. Andrews is opposed to the sale of alcohol at the proposed licensed premises by any type of entity, but he probably would not have testified against the application if it was solely a restaurant operation at this location. (N.T. 03/18/2014 at 103-109). 55. Mr. Andrews was "raised by an alcoholic father" and he is "totally against alcohol." (N.T. 03/18/2014 at 109). 21 56. Priscilla Marie Smith resides at 9996 McCreary Road, which is located approximately five (5) miles from the proposed licensed premises. Ms. Smith has been the Civic Club's president since January 2014 and she has been a member of said organization for seventeen (17) years. Ms. Smith has chaired committees and has been the vice president for the Civic Club. Ms. Smith testified at the instant hearing on behalf of the Civic Club. (N.T. 03/18/2014 at 111-113). 57. The Civic Club is not incorporated, has approximately ninety (90) members, and has been in existence since 1911. Ms. Smith indicated the Civic Club is a "women's club," and its purpose is to educate women and make them aware of community needs. (N.T. 03/18/2014 at 113-114, 116, 119-120). 58. The Civic Club sponsors a community nurse who provides nursing care to individuals who either do not have the money or transportation to get medical assistance. This nurse does not charge for his/her services. The community nurse program was started around 1911. (N.T. 03/18/2014 at 114-115, 118-120). 59. The Civic Club provides scholarships to "students of the month." (N.T. 03/18/2014 at 114-115, 119). 60. The Civic Club is a non-profit organization and funding for the Civic Club comes from dues, and public and private donations. Ms. 22 Smith believed she may receive twenty-five dollars ($25.00) a year as the Civic Club's president, but she did not think the other officers are paid for their service. (N.T. 03/18/2014 at 117-118). 61. The Civic Club conducts private tours of its building and during the summer months it has open houses the second Saturday of every month. The Civic Club's building houses artifacts, such as a deed between Edward Shippen and William Penn's sons, old pictures, antique furniture, and deeds from early settlers. The Civic Club's building was the courthouse for Cumberland County for one (1) year in 1750, when Cumberland County was formed, and its building is listed on the National Register of Historic Places. The Civic Club maintains gardens on the side of its building, which are open to the public. (N.T. 03/18/2014 at 136-138). 62. The Civic Club conducted approximately three (3) or four (4) private tours during 2013 and the hours for its monthly open houses during the summer months are between 1:00 p.m. and 4:00 p.m. (N.T. 03/18/2014 at 151). 63. The Civic Club does not engage in administrative activity at its building on a daily basis and the nursing care activities do not occur at its building. (N.T. 03/18/2014 at 152). 64. The Civic Club does not charge a fee for its tours, but people 23 can give donations, which go to the nurse's committee. Tour guides are volunteers. (N.T. 03/18/2014 at 139). 65. The Civic Club holds an executive committee meeting the first Wednesday of each month and a general meeting the third Wednesday of each month. (N.T. 03/18/2014 at 144, 157). 66. The Civic Club filed a protest regarding Applicant's proposed licensed premises and it is located directly across the street from the proposed licensed premises. (N.T. 03/18/2014 at 122-123). 67. Ms. Smith had no disagreement with Mr. Lamark's measurement of two hundred five (205) feet from the Civic Club's building to the proposed licensed premises. (N.T. 03/18/2014 at 140- 141). 68. Ms. Smith believed the Civic Club meets the definition of a charitable organization because it is a non-profit organization that centers on non-profit and philanthropic goals. (N.T. 03/18/2014 at 145-146). 69. The Civic Club is opposed to Applicant's transfer application because there is already an issue with trash and debris that is discarded by the current Sheetz customers, and she anticipates this will get worse if Applicant's transfer application is granted. Ms. Smith indicated that some of the trash comes from the neighboring 24 McDonald's. Also, the Civic Club is concerned that Applicant's patrons will utilize the Civic Club's public gardens to "party and leave all their stuff" and that Applicant's patrons may damage the Civic Club's building. (N.T. 03/18/2014 at 123, 126, 142, 149). 70. Ms. Smith believes that the granting of a liquor license will make it too easy for people to purchase alcohol at a business where gasoline is sold. (N.T. 03/18/2014 at 123-124). 71. Ms. Smith is concerned that because the area where the proposed licensed premises is already very congested, licensing this location would increase a lot of problems that are already issues. (N.T. 03/18/2014 at 125). 72. Ms. Smith is opposed to the licensing of a location where people go to buy their food because "there are too many people who will spend money on . . . the alcohol instead of food for their family." (N.T. 03/18/2014 at 127). 73. Ms. Smith pointed out there is a McDonald's located next to the proposed licensed premises, which has an enclosed outside playground. (N.T. 03/18/2014 at 128-130). 74. Ms. Smith indicated that the Civic Club would not oppose a restaurant selling alcohol, such as Ruby Tuesday's; the Civic Club is concerned with a convenience store selling alcohol and gasoline. (N.T. 25 03/18/2014 at 131-132, 147). 75. A security officer employed for the proposed licensed premises would allay some of the Civic Club's concerns. (N.T. 03/18/2014 at 144). 76. If Applicant would not permit patrons to consume beer in any of its outdoor seating areas or the parking lot, this would change the Civic Club's objections a "small amount." However, the Civic Club would still be concerned about "people being able to drive in and get their gasoline and pick up their six-pack while they're at it." (N.T. 03/18/2014 at 153). 77. Sandra Hummel is the Civic Club's treasurer and she has held this position for seven (7) years. Ms. Hummel was a member of the Junior Civic Club in her 20s, became inactive, and subsequently returned to the Civic Club when she was in her 40s. (N.T. 03/18/2014 at 155-156). 78. The Civic Club's charter is to educate the women of the community, to offer assistance, and to promote the betterment of the community. Presently, the Civic Club has five (5) scholarships and two (2) nurse -related scholarships this year; whereas, normally there is only one (1) nurse -related scholarship per year. (N.T. 03/18/2014 at 158). 26 79. The Civic Club has informative programs during its monthly meetings which help educate its members. At these meetings, the Civic Club has different speakers who talk on a wide variety of topics, such as identity theft and restoration of documents within the building. (N.T. 03/18/2014 at 159). 80. The Civic Club's community nurse is paid from the Civic Club's finances, a grant, a trust that was set up for this specific purpose, the Episcopal Church, and the United Way. The nurse works between one hundred (100) and one hundred twenty (120) hours per month. The nurse visits the homes of patients who have been authorized by a physician for care; the nursing care provided is free to the patient. (N.T. 03/18/2014 at 160-161, 163-164). 81. The Civic Club maintains a 501(c)(3) status with the Internal Revenue Service. (N.T. 03/18/2014 at 162). 82. The Civic Club receives dues of twenty dollars ($20.00) per year from members and maintains three (3) checkbooks: general fund account, nurse's account, and maintenance of building account. (N.T. 03/18/2014 at 163-164). 83. Ms. Hummel agreed with Ms. Smith's testimony regarding the Civic Club's opposition to Applicants' transfer application. (N.T. 03/18/2014 at 161). 27 84. Ms. Hummel is on the executive committee and attended the executive committee meeting that was held to discuss the filing of a protest to Applicant's transfer application. (N.T. 03/18/2014 at 165- 167). 85. The Civic Club does not pay its officers or members a salary. (N.T. 03/18/2014 at 169-170). 86. Jaye Alleman resides at 324 East Burd Street in Shippensburg and has lived at this location for twenty-eight (28) years. Mr. Alleman's residence is located approximately one hundred fifty (150) feet from the proposed licensed premises and he filed a protest in the instant matter. (N.T. 03/18/2014 at 171-174). 87. Mr. Alleman's residence is located approximately one and one- half (11/2) blocks from licensee, Wib's Bar, which is located on North Queen Street. Mr. Alleman's residence is located between the proposed licensed premises and Shippensburg University. (N.T. 03/18/2014 at 174-175, 184). 88. Mr. Alleman's property receives a lot of vandalism from college students and his porch bannister has been vandalized three (3) times. Mr. Alleman has to clean Applicant's and McDonald's trash from his lawn in the summer before he can mow, and he is concerned the trash will increase from Applicant if its transfer is approved. (N.T. 28 03/18/2014 at 175-176). 89. Mr. Alleman was assaulted by a drunk college student on New Year's Eve in 2004, which resulted in him receiving a broken hip. Mr. Alleman observed the assailant was coming from the vicinity of Wib's Bar. Mr. Alleman is afraid that approval of Applicant's transfer application will "increase the possibilities of that happening" again. (N.T. 03/18/2014 at 177, 185). 90. Mr. Alleman believes there are enough liquor licensees in the Borough of Shippensburg and another license is not needed. (N.T. 03/18/2014 at 177). 91. Mr. Alleman declined an offer from Applicant to build him a fence in 2012, because he "would be required to fix it as often as it's broken because of the experience with the porch banister. That same situation would happen. In addition to that, cans could be thrown over the fence. That wouldn't stop it at all." (N.T. 03/18/2014 at 177, 185). 92. Mr. Alleman attended the Borough Council's meeting in 2012, regarding Applicant's proposed transfer. (N.T. 03/18/2014 at 185). 93. Based on his observations, Mr. Alleman believes there is a relationship between the consumption of alcohol and littering. Also, Mr. Alleman believes that Applicant's patrons would drink to 29 intoxication. (NJ. 03/18/2014 at 178-180). 94. Mr. Alleman has had problems with littering in his yard during the twenty-eight (28) years he has lived at his current location. The current Sheetz establishment predates Mr. Alleman moving to his residence. (N.T. 03/18/2014 at 180-181). 95. There is significant foot traffic on Friday and Saturday nights on East Martin Avenue, which is the roadway that borders the rear of Applicant's premises, and Mr. Alleman estimates this foot traffic to be ninety-five percent (95%) college students. (N.T. 03/18/2014 at 181- 183). 96. Mr. Alleman has had problems with foot traffic coming from the Sheetz convenience store because the people walk across his yard, and he thinks this foot traffic may increase with the proposed licensed premises. (N.T. 03/18/2014 at 188-189). 97. Mr. Alleman finds the littering and noise to be worse on weekends and he has been awakened between 2:00 am and 3:00 a.m., despite having his windows closed and air conditioner turned on. Mr. Alleman has called the police different times regarding the noise coming from foot traffic on East Martin Avenue. (N.T. 03/18/2014 at 183). 98. Mr. Alleman does not have too many problems with noise 30 coming from Sheetz's premises, but he is concerned this may change because the proposed licensed premises will be located closer to his residence. (N.T. 03/18/2014 at 183). 99. Mr. Alleman is opposed to the sale and consumption of alcoholic beverages. He would object to any type of establishment selling alcoholic beverages at the proposed licensed premises. (N.T. 03/18/2014 at 186). 100. Fred A. Scott is Chief of the Shippensburg Borough Police Department and he has held that position for almost fourteen (14) years. Previously, Chief Scott was employed by the Pennsylvania state Police for twenty-nine (29) years. Chief Scott is familiar with the current Sheetz establishment, which is within the jurisdiction of the Shippensburg Borough Police Department. (N.T. 03/18/2014 at 199- 200). 101. The Sheetz premises is popular with Shippensburg University students because of the availability of food, particularly late-night food, and being able to purchase gasoline. (N.T. 03/18/2014 at 200- 201). 102. The Shippensburg Borough Police Department is comprised of nine (9) police officers, include Chief Scott. The police department is able to provide 24/7 coverage for the Borough. (N.T. 03/18/2014 at 31 213). 103. There are three (3) Shippensburg Borough police officers on duty on Thursday, Friday, and Saturday nights. There are usually two (2) police officers on duty the other nights of the week. (N.T. 03/18/2014 at 201). 104. Since July 2012, Shippensburg Borough police officers have responded to the Sheetz establishment concerning retail theft (ninety- five percent (95%) of which is committed by intoxicated students), disturbances, harassment of employees, public intoxication, underage drinking, and driving under the influence. A lot of the calls the police receive at night concerning incidents at Applicant's establishment are alcohol-related. (N.T. 03/18/2014 at 201-203). 105. Chief Scott checked the Borough of Shippensburg's Police Department's statistics for the years 2011 through 2013 and specifically checked for incidents occurring at Applicant's location. For 2011, there were: • thirty-five (35) retail theft arrests in the Borough, thirty (30) occurred at Applicant's establishment; • forty-three (43) public drunkenness arrests in the Borough, eight (8) occurred at Applicant's premises; • eighty-seven (87) underage drinking arrests in the Borough, 32 fifteen (15) occurred at Applicant's premises; • thirteen (13) arrests of minors driving under influence of alcohol in the Borough, two (2) occurred at Applicant's premises; and • seventy-eight (78) non -minors driving under the influence of alcohol arrests in the Borough, fifteen (15) occurred at Applicant's premises. (N.T. 03/18/2014 at 202-205). 106. The Borough of Shippensburg's Police Department's statistics for 2012 were: • twenty-eight (28) retail theft arrests in the Borough, twenty- four (24) occurred at Applicant's establishment; • forty-six (46) public drunkenness arrests in the Borough, eight (8) occurred at Applicant's premises; • sixty-two (62) underage drinking arrests in the Borough, fifteen (15) occurred at Applicant's premises; • six (6) arrests of minors driving under influence of alcohol in the Borough, one (1) occurred at Applicant's premises; and • eighty (80) non -minors driving under the influence of alcohol arrests in the Borough, seventeen (17) occurred at Applicant's premises. (N.T. 03/18/2014 at 205). 107. The Borough of Shippensburg's Police Department's 33 statistics for 2013 were: • thirty-seven (37) retail theft arrests in the Borough, twenty- seven (27) occurred at Applicant's establishment; • fifty-two (52) public drunkenness arrests in the Borough, two (2) occurred at Applicant's premises; • seventy-three (73) underage drinking arrests in the Borough, nine (9) occurred at Applicant's premises; • no arrests of minors driving under influence of alcohol occurred at Applicant's premises; and • fifty-five (55) non -minors driving under the influence of alcohol arrests in the Borough, six (6) occurred at Applicant's premises. (N.T. 03/18/2014 at 205). 108. On Thursday, Friday, and Saturday nights, Chief Scott routinely has a patrolman stationed at the Sheetz premises and this "takes away" from the police's response to the rest of the Borough. The Chief indicated there are no other establishments in the Borough of Shippensburg which require this type of attention from the police department. (N.T. 03/18/2014 at 206). 109. Chief Scoot has observed that after 12:00 a.m., the Sheetz convenience store is primarily patronized by college students. (N.T. 03/18/2014 at 206-207). 34 110. Approximately three (3) years prior to the instant hearing, Chief Scott asked the local manager of Sheetz convenience store to contact corporate headquarters and request increased staffing and security for outside its store. (N.T. 03/18/2014 at 207). 111. One (1) of the biggest concerns of Shippensburg's police officers is the delay in time at the Sheetz convenience store when ordering food because while one (1) student may be buying sandwiches, there may be two (2) friends waiting for the student, and this waiting period is when incidents occur. (N.T. 03/18/2014 at 208). 112. As of the date of the instant hearing, the Borough of Shippensburg has approximately nine (9) or ten (10) licensed establishments, all located in Cumberland County. (N.T. 03/18/2014 at 210). 113. Chief Scott pointed out that Sheetz's employees call the police for many of the incidents because "when the bars close down there, everybody goes to Sheetz to eat." Also, he pointed out that people come to Sheetz's premises intoxicated, Sheetz "doesn't make them intoxicated." (N.T. 03/18/2014 at 212). 114. Chief Scott believes that Sheetz's current security is inadequate and it needs to have security employees monitoring inside and outside its establishment, and having an Act 235 -certified security 35 employee "would help." (N.T. 03/18/2014 at 215-216, 224-225). 115. Chief Scott believes that Sheetz's video surveillance system has been very beneficial to the police and it has provided video recordings to the police upon request. Also, many of the retail theft arrests were based on these recordings and Sheetz's employees are always cooperative with the police. (N.T. 03/18/2014 at 216-217). 116. At the Shippensburg Borough Council's intermunicipal transfer hearing held in July 2012 regarding Applicant's transfer request, Chief Scott expressed his concerns to the Borough Council, but the Borough Council still approved Applicant's request. The Borough Council did not give the Chief authorization to appear at the instant hearing and testify on their behalf. (N.T. 03/18/2014 at 217- 218). 117. Chief Scott acknowledged that Sheetz's convenience store does not sell alcohol and it has had to deal with the problem of intoxicated patrons coming from other licensed establishments. The Chief indicated that he investigates licensed establishments regarding the over -service of alcohol and service to minors when he receives a complaint, but most of the time the individuals have been "shut off" by the establishments and then go to Sheetz's convenience store. (N.T. 03/18/2014 at 219-220). 36 118. Chief Scott expressed a safety concern at Applicant's proposed licensed premises when a liquor license is added to an already volatile situation. (N.T. 03/18/2014 at 229-230). 119. Chief Scott acknowledged that beer distributors in the Borough of Shippensburg sell their products to college students and the Chief has not asked intoxicated individuals who have been arrested where they purchased the alcohol because it has not be relevant to the arrests. (N.T. 03/18/2014 at 231-232). 120. Chief Scott indicated the Shippensburg Police Department has not had a problem with loitering at the Sheetz convenience store, other than "Amish kids . . . congregat[ing] at their horse and buggies out front of the Sheetz and talk[ing]." The police have not had any issues with alcohol involving the Amish kids. (N.T. 03/18/2014 at 232-233. 121. Chief Scott has observed the scattering of "rubbish" on North Queen Street and Martin Avenue behind Mr. Alieman's house, which the Chief characterized as being "like a garbage dump." When asked if the Chief was able to identify the source of the "rubbish," he testified that "Sheetz labels their stuff rather nicely. So it's not hard to tell where it came from." Regarding "rubbish" on Sheetz's premises, the Chief indicated that Sheetz takes care of its property and he has "no 37 complaints." (N.T. 03/18/2014 at 233-234). 122. Chief Scott has observed security at Sheetz's convenience store on Friday and Saturday nights. There are usually two (2) people, but these employees "get swamped just trying to stay on top of the retail thefts within the store. They don't have time to be outside." `(N.T. 03/18/2014 at 234-235). 123. John Campbell is the regional director of operations for Sheetz, Inc. and he has held this position for thirteen (13) years. Mr. Campbell oversees daily operations of thirteen (13) districts, which include the eastern half of Pennsylvania, Maryland, "parts of West Virginia," and "parts of Virginia." There are one hundred fifty-eight (158) Sheetz stores within these thirteen (13) districts, and Mr. Campbell oversees and has responsibility for the day-to-day operations of these stores. (N.T. 03/18/2014 at 239-241). 124. Construction of the new Sheetz facility at 359 East King Street in Shippensburg commenced approximately a month prior to the instant hearing and the projected opening of the new premises is late May 2014. (N.T. 03/18/2014 at 241). 125. The Sheetz store currently operating at 359 East King Street sells food, drink, health and beauty items, soda packs, sunglasses, lighters, tobacco, cigarettes, coffee and made-to-order ("MTO") food. 38 There has been a Sheetz store at this location for approximately thirty (30) years. (N.T. 03/18/2014 at 241-242). 126. The new Sheetz facility will be constructed adjacent to the existing store on newly acquired property, which is to the left and to the rear, as you face the present building at the corner of East King Street and Queen Street. Upon completion of the new Sheetz facility, the current Sheetz store will be closed. (N.T. 03/18/2014 at 242). 127. There will be two (2) separate businesses operating in the new Sheetz facility; one (1) business will be a Sheetz convenience store that will be operated by Sheetz, Inc. and the other business will be a Sheetz restaurant that will be operated by Applicant. (N.T. 03/18/2014 at 242-243). 128. Sheetz, Inc. will also operate the gas pumps. (N.T. 03/18/2014 at 243). 129. Applicant is a subsidiary of Sheetz, Inc. (N.T. 03/18/2014 at 243). 130. The new Sheetz facility is not owned by Sheetz, Inc. or Applicant, but Sheetz, Inc. and Applicant will each of have their own lease for their respective premises. (N.T. 03/18/2014 at 243-244; Exs. MBDA-7, MBDA-8). 131. The Sheetz convenience store will be under the same roof 39 and adjacent to Applicant's proposed licensed premises. The convenience store portion of the premises will be five hundred twenty- six (526) square feet and the convenience store will be responsible for the gasoline pumps. (N.T. 03/18/2014 at 246-248; Ex. A-1). 132. Applicant's proposed licensed premises will operate under the trade name of Sheetz Restaurant, the convenience store will operate under the trade name of Sheetz Convenience Store, and the gasoline pumps will operate under the trade name of Sheetz. (N.T. 03/18/2014 at 247). 133. The proposed licensed premises4 will cover six thousand five hundred sixty-seven (6,567) square feet and will have its own entrance through double doors, patrons will be able to enter the proposed licensed premises without going into the Sheetz Convenience Store. The proposed licensed premises will have a dining area with booths, tables, chairs, and a counter, which will have seating for thirty-seven (37) patrons. (N.T. 03/18/2014 at 249-252; Ex. A-2). 134. Applicant will provide the following made to order food items at the proposed licensed premises "24/7:" a complete hamburger line, including gourmet hamburgers similar to what a Red Robin restaurant would have; gourmet chicken sandwiches similar to what a Red Robin 40 restaurant would have; subs and sandwiches, both hot and cold; twelve (12) different types of wraps, as well as burritos and burrito bowls; different types of french fries and wings; different types of salads; pizza with many different toppings; and breakfast foods, such as biscuits, bagels, croissants, oatmeal, fruit, and sandwiches. (N.T. 03/18/2014 at 253-256, 262-264). 135. Mr. Campbell believes that Applicant's coffee line, Sheetz Brothers Coffee, is competitive with Starbucks. (N.T. 03/18/2014 at 266-267). 136. Mr. Campbell opined that Applicant's food would mirror eight (8) to ten (10) different competing restaurants, such as Pizza Hut, Chipotle, and Starbucks. Mr. Campbell pointed out that Applicant's food will be a higher -grade product than McDonald's. (N.T. 03/18/2014 at 257). 137. Food will be ordered at the proposed licensed premises at four (4) "order points," via MTO screens. (N.T. 03/18/2014 at 258- 259; Ex. A-2). 138. Mr. Campbell believed it would take a customer approximately ten (10) minutes to review Applicant's menu, because Applicant has such a "broad menu." Applicant will have three (3) 4 The proposed licensed premises is outlined in yellow on Exhibit A-2. 41 registers located in the proposed licensed premises for patrons to pay for food items and it will have two (2) areas within the proposed licensed premises for patrons to pick-up their food purchases. (N.T. 03/18/2014 at 259-261; Ex. A-2). 139. Applicant will have a dining area that will accommodate thirty-seven (37) patrons. Purchased food may be consumed at the proposed licensed premises or removed from the premises. (N.T. 262- 264; Ex. A-2). 140. Applicant's kitchen area is located directly behind the order points and contains sophisticated equipment that will be used for food preparation. Mr. Campbell pointed out that you would have to "put a couple of different restaurants together to get all of our equipment" used in Applicant's kitchen. (N.T. 03/18/2014 at 264-269 Ex. A-2). 141. The proposed licensed premises will have a large walk-in freezer and cooler. According to Mr. Campbell, the coolers will be used "solely to support Applicant's kitchen." Applicant will have food products delivered three (3) times a week to its proposed licensed premises and it will also receive delivery of bakery items daily. (N.T. 03/18/2014 at 269-270; Ex. A-2). 142. There will be sixty-six (66) linear square feet of beverages called the "Big Six" at the proposed licensed premises. This area will 42 have thirty-seven (37) flavors of milkshakes, forty-four (44) different fountainheads, eight (8) head frozen carbonated beverage unit, brewed tea units; and iced coffee units. (N.T. 03/18/2014 at 271- 273; Ex. A-2). 143. The proposed licensed premises will have coolers that customers can access containing single -size bottled non-alcoholic beverages, such as iced tea, water, and soda. (N.T. 03/18/2014 at 273-275; Ex. A-2). 144. Applicant will sell single -serve packages of snack foods and it will not sell large bags of snack foods at the proposed licensed premises. Applicant will also sell candy, gum, and similar items at the proposed licensed premises. (N.T. 03/18/2014 at 275-276; Ex. A-2). 145. Applicant will sell single -serving bakery items, such as doughnuts, cookies, and muffins in an bakery section at the proposed licensed premises. (N.T. 03/18/2014 at 276-277; Ex. A-2). 146. The proposed licensed premises will have approximately eight (8) flavors of frozen yogurt, two (2) flavors of ice cream, and a number of different toppings. (N.T. 03/18/2014 at 277-278; Ex. A-2). 147. Applicant will have a twelve (12) -foot "RTE" case that will have prepared sandwiches, which will be shipped to the proposed licensed premises daily. Applicant will also provide single -serving 43 prepackages of fresh fruit and cheese. (N.T. 03/18/2014 at 278-279; Ex. A-2). 148. Applicant will sell tobacco products, which willl be located behind each of the three (3) registers at the proposed licensed premises. (N.T. 03/18/2014 at 279; Ex. A-2). 149. Butane lighters will not be sold at the proposed licensed premises, but will be sold in the Sheetz Convenience Store. (N.T. 03/18/2014 at 365-366). 150. Applicant's patrons will not be able to purchase items located in the proposed licensed premises at the unlicensed Sheetz Convenience Store, and the items located in the convenience store cannot be purchase at the proposed licensed premises. Signage will be posted on both sides of the four (4) -foot interior connection between the proposed licensed premises and the unlicensed convenience store, prohibiting merchandise from being taken from the proposed licensed premises to the convenience store, and vice -versa. Applicant's employees and management will be trained to monitor this situation. (N.T. 03/18/2014 at 279-280, 300-301). 151. Applicant will not sell convenience store items in the proposed licensed restaurant, other than tobacco products. Health/beauty products, automotive supplies, cleaning supplies, pet 44 food, office supplies, two (2) liter bottles of soft drinks, and food packed in larger than single -serving sizes will not be sold in the proposed licensed restaurant. (N.T. 03/18/2014 at 280-282). 152. Tobacco products will be the only items that will be sold at both the Sheetz Convenience Store and the proposed licensed premises. (N.T. 03/18/2014 at 300). 153. Mr. Campbell indicated that if a customer of the proposed licensed premises wanted to buy a large bag of potato chips and a six (6) -pack of beer, he/she would be required to complete two (2) separate transactions, purchase the large bag of potato chips on the convenience store side and purchase the beer at the proposed licensed premises. A patron could bring a completed purchase of the potato chips from the convenience store into the proposed licensed premises or a purchased six (6) -pack of beer into the convenience store, but they would not be permitted to take merchandise from the convenience store section to the proposed licensed premises, or vice versa, without purchasing the product in the appropriate area first. Mr. Campbell noted that employees will enforce this rule by checking receipts and ensuring that items purchased are bagged. (N.T. 03/18/2014 at 364-365). 154. Applicant will sell only beer at the proposed licensed 45 288; Ex. A-2). 158. Applicant will have signage posted on the exterior of the proposed licensed premises to identify its establishment as "Sheetz Restaurant." (N.T. 03/18/2014 at 289-290). 159. Applicant will have as many as eight (8) employees working in the kitchen area, with approximately three (3) other employees working outside the kitchen area. The proposed licensed premises will have a separate manager who will devote full time and attention to Applicant's operation. Applicant will keep records of the food sales, and non-alcoholic and alcoholic beverages. (N.T. 03/18/2014 at 290). • 160. Applicant will not have any exterior licensed areas. (N.T. 03/18/2014 at 290-291). 161. The proposed licensed premises will be well lit. Applicant will provide easy listening music and it will have approximately two (2) televisions. It will not have speakers on the exterior of the building. Applicant will not have any video games, jukebox, pool tables, or live entertainment. (N.T. 03/18/2014 at 291-292). 162. The unlicensed Sheetz Convenience Store will be located adjacent to Applicant's premises and it has approximately five hundred fifty (550) square foot. The Sheetz Convenience Store has its own lease and it will have a separate exterior entrance; patrons will be able 47 to enter the convenience store without entering the proposed licensed premises. (N.T. 03/18/2014 at 292-293; Ex. A-2), 163. The Sheetz Convenience Store will sell take-home food items that you would not consume in one (1) sitting, such as loaves of bread, gallons of milk, packages of cheese and bologna, cases of soda, large bags of chips, and large containers of orange juice. The Sheetz Convenience Store will also sell health and beauty items. The Sheetz Convenience Store will have one (1) cash register where items sold at the convenience store will be purchased. (N.T. 03/18/2014 at 293- 294; Ex. A-2). 164. The Sheetz Convenience Store will not sell motor oil antifreeze, or other automotive supplies. Mr. Campbell does not believe there will be overflow stocking of convenience store items on the proposed licensed premises because deliveries will be received three (3) times a week and seven (7) days a week on the "SPC truck," and the remaining vendors service their products on the shelves themselves. (N.T. 03/18/2014 at 362-363). 165. The Sheetz Convenience Store will be separated from the proposed licensed premises by an approximately eight (8)-foot high wall, which will have a four (4)-foot opening between a vestibule area and the convenience store. There is also a sliding door or retractable 48 gate interior opening that will be used by employees only, this opening will be at least three (3) feet wide and forty-eight (48) inches high. (N.T. 03/18/2014 at 295-2961 298-299; Ex. A-2). 166. Mr. Campbell believes that part of the vestibule area would be part of Applicant's leased premises, but this area will not be licensed. Patrons would be able to walk from the licensed premises through the vestibule into the Sheetz Convenience Store, and vice - versa. (N.T. 03/18/2014 at 296-297; Ex. A-2). 167. The Sheetz Convenience Store will have "Sheetz Convenience Store" signage posted on the exterior and the convenience store will be open "24/7." The Sheetz Convenience Store will have a shift supervisor who will not have any duties or responsibilities with regard to the proposed licensed premises. (N.T. 03/18/2014 at 299-300). 168. All of Applicant's employees will have Responsible Alcohol Management Program ("RAMP") training and Applicant will also be RAMP -certified. All new employees hired by Applicant will be required to become RAMP -certified. (N.T. 03/18/2014 at 301-302). 169. Applicant's employees who are eighteen (18) or older will have to undergo TIPS training. (N.T. 03/18/2014 at 303). 170. Applicant's carding policy is to card every person who purchases beer at the proposed licensed premises. Applicant will 49 accept the following forms of identification: a valid state issued driver's license, a valid state issued non -driver's license photo identification, a military issued photo identification, and passport photo identification. (N.T. 03/18/2014 at 303-304). 171. The procedure Applicant's employees will follow when a patron purchases beer is as follows: inspect for any alteration; compare the information on the identification with the patron's physical characteristics; ask the patron questions, such as whether the patron is twenty-one (21) years of age or what his/her address is; and scan the patron's identification with an identification scanner. If any of the above checks result in a problem, the sale to the patron is refused. (N.T. 03/18/2014 at 304-306). 172. Applicant's employees will be trained concerning third party sales (somebody buying beer for someone else) through the RAMP training and Applicant's tobacco training. For example, if two (2) people come in seeking to purchase beer, both individuals will be carded; if both individuals cannot produce identification, the sale would be refused. Another example would be when an employee sees a group of people "hanging out" outside the establishment, an alcohol sale would be refused to one (1) of the members of the group, unless all the group members produce valid identification. (N.T. 03/18/2014 50 at 307-308). 173. Applicant will have a zero tolerance policy regarding selling alcohol to minors, visibly intoxicated patrons, and an amount for take- out in excess of one hundred ninety-two (192) fluid ounces. Employees who violate this policy will have their employment terminated on the first violation. (N.T. 03/18/2014 at 308, 323-324). 174. There will be a total of sixty-four (64) surveillance cameras located inside and outside the building where the proposed licensed premises will be located. This system includes a digital video record ("DVR") and Mr. Campbell opined that this video system is one (1) of the best in the industry. (N.T. 03/18/2014 at 308-309). 175. Mr. Campbell did not know the breakdown of the number of cameras located inside as compared to outside the premises, but he indicated that "pretty much every inch of the inside and outside will be covered." The DVR system writes over itself at ninety (90) days, unless particular footage is tagged. (N.T. 03/18/2014 at 359-360). 176. The surveillance cameras will be operational "24/7" and will be monitored in real time at the Security Operations Center ("SOC"), which is located at headquarters in Altoona, Pennsylvania. Mr. Campbell oversees the SOC, which has a bank of monitors covering every camera at every store location. (N.T. 03/18/2014 at 311-312). 51 177. The SOC also performs "[V]oice downs at every location" to check on employees and any time there is a problem, the employee has a pendant which they can press. Also, there is a pendant located at each register that can be pressed in the event of a problem. (N.T. 03/18/2014 at 311-312). 178. Someone at SOC headquarters can zoom in on a camera and then talk to an employee, inquiring as to whether the employee needs assistance. Signage concerning this extensive video surveillance will be posted at the "entrances of the location." Video recordings from the cameras are stored at SOC headquarters and when an incident occurs at a location, the store has the ability to tag the surveillance system and save the recording, which is permanently saved until it is deleted. (N.T. 03/18/2014 at 312-313). 179. The Sheetz Convenience Store and vestibule area will have surveillance cameras. (N.T. 03/18/2014 at 310). 180. The surveillance cameras will cover the exterior of the building, including the dumpsters and parking stalls, as well as each entrance with a telescopic lens. There will also be video surveillance inside the proposed licensed premises, with cameras focused on the patrons' seating area, walk-in cooler and its entrance, and three (3) cash registers. Applicant will cooperate with law enforcement by 52 providing copies of its surveillance recordings. (N.T. 03/18/2014 at 309-310). 181. When a patron is refused an alcohol sale, Applicant's policy is to place the transaction is placed in a log with the reason for the refusal and a description of the patron. Also, a picture of the patron is printed from the DVR system and kept on file. (N.T. 03/18/2014 at 310). 182. At the time of the hearing, at the current Sheetz location, two (2) security employees work from Thursday, Friday, and Saturday from 8:00 p.m. until 4:00 a.m. When the new Sheetz facility opens, Applicant is planning on having security working at all hours that beer is sold, which would be Monday through Saturday from 7:00 a.m. to 2:00 a.m. and Sunday from 9:00 a.m. to 2:00 a.m. Mr. Campbell indicated that Applicant will "probably" extend the 2:00 a.m. time to 4:00 a.m. (N.T. 03/18/2014 at 314). 183. The two (2) security employees will be working with a minimum of two (2) employees from the loss investigation team ("LIT") department. The LIT employees have undergone RAMP and TIPS training and would be on-site working with security advising them on what to do, what to look for, and how to intervene. (N.T. 03/18/2014 at 314-315). 53 184. Mr. Campbell was unaware as to how many LIT personnel will be on-site on a permanent basis, but he indicated in the beginning there could be as many as four (4) working. (N.T. 03/18/2014 at 346- 347). 185. The security employees will be in uniform and will be required to monitor the inside and outside premises. Armed security guards are not employed at any Sheetz stores. (N.T. 03/18/2014 at 315-316, 349). 186. The security employees are being hired for a deterrent and for customer safety, not to specifically monitor for retail theft. Security employees will be independent contractors and Applicant will contract with a number of different companies. Mr. Campbell did not know the names of the companies that currently provide the security employees from the Shippensburg Sheetz store. (N.T. 03/18/2014 at 347-348). 187. Mr. Campbell is going to have the manager at the current Shippensburg Sheetz store, Kathy Soloman, follow-up with Chief Scott and the security companies to determine the security employees at the current Shippensburg Sheetz store who are "good." (N.T. 03/18/2014 at 348-349). 188. Employees are to advise the manager if security employees 54 are not performing their job. The LIT employees supervise security personnel and perform audits at the sites when security are working. (N.T. 03/18/2014 at 349-350). 189. Mr. Campbell believes the LIT personnel will probably start working after the security employees start working, so they can work during the early morning hours, after the Board-approved manager has left. (N.T. 03/18/2014 at 350). 190. The security employees are not to physically restrain anyone, but to intervene and prevent incidents from occurring. Security can call the police, request that one (1) of the employees call the police, or have one (1) of the clerks push the safety pendant to contact SOC headquarters in Altoona. SOC has a particular camera view and the phone numbers of every local police department for every store and SOC can quickly call the police. (N.T. 03/19/2014 at 379-380). 191. When an employee depresses his/her pendant to alert SOC, SOC will be notified of the store number and where the emergency is. (N.T. 03/19/2014 at 405-407). 192. The proposed licensed premises will have a bank of DVRs with each DVR accommodating sixteen (16) cameras and the convenience store area would have a separate DVR system with multiple cameras. The employees' pendants are tied to the DVR 55 systems. (N.T. 03/19/2014 at 407-408). 193. Mr. Campbell acknowledged that when a pendant button is pressed by an employee, SOC could review all the cameras, but he did not know if they would do so. Mr. Campbell is not aware of a procedure with regard to a disturbance and the viewing of the surveillance cameras at the SOC location. (N.T. 03/19/2014 at 412- 413). 194. Applicant's patrons will be permitted to consume beer only in the interior seating area of the proposed licensed premises. Patrons will not be permitted to take open containers of beer outside the proposed licensed premises and Applicant's employees will be trained to prevent this from occurring. (N.T. 03/18/2014 at 316-317). 195. When a patron takes alcoholic beverages into the proposed licensed premises' seating area, Applicant's policy will be to log the patron entering the seating area and check the area every fifteen (15) minutes to monitor the patron's consumption. (N.T. 03/18/2014 at 317-318). 196. During the period from 10:00 p.m. to 2:00 a.m., the seating area would be monitored by either an assistant, shift supervisor, or another employee. Someone would be designated to inspect that area every twenty (20) minutes and keep a log of same, and this would 56 require a walk-through and contact with the patrons. The seating area could be monitored via video by the SOC in Altoona, as well as the store's monitor. To the extent that SOC observes a disturbance in the seating area, it would alert the supervisor via a call to the store. (N.T. 03/19/2014 at 514-516). 197. The maximum amount of malt or brewed beverages that a patron will be permitted to purchase for take-out in a single sale is one hundred ninety-two (192) fluid ounces. A patron wanting to purchase additional quantities would have to take the initial purchase to his/her vehicle and come back later to purchase additional malt or brewed beverages. A patron who leaves Applicant's establishment after a purchase would have his/her identification scanned again for additional purchases. (N.T. 03/18/2014 at 318-320). 198. Mr. Campbell did not disagree with the Licensing's analyst testimony that ninety-five percent (95%) of Applicant's beer sales will be for takeout. (N.T. 03/19/2014 at 458-459) 199. For situations where an intoxicated individual attempts to purchase beer at the proposed licensed premises, Applicant's employees will refuse service to this individual, and it will document the incident in its log book. Applicant will attempt to arrange transportation for the intoxicated person and will offer a free 57 doughnut, french fries, or fountain drink to the person. If necessary, SOC would notify the police to respond and if the intoxicated individual was to leave in a vehicle, an effort would be made to obtain the license number so it could be provided to the police. (N.T. 03/18/2014 at 320-322). 200. Applicant's policy for a patron who purchases beer at proposed licensed premises and then attempts to drink said beer in the parking lot, security would advise the patron that consumption has to occur in dining area of the proposed licensed premises. If the patron refuses to cooperate, local police would be notified. (N.T. 03/18/2014 at 322-323). 201. Minors will be permitted to purchase food and non-alcoholic beverages at the proposed licensed premises because Applicant's sales of food and non-alcoholic beverages are expected to be much greater than fifty percent (50%) of Applicant's total sales. Mr. Campbell is aware that minors cannot sit at a table where alcohol is being consumed unless the minors are accompanied by a parent, legal guardian, or are under proper supervision. (N.T. 03/18/2014 at 326- 328). 202. Applicant has had a licensed establishment located in Altoona, Pennsylvania ("Altoona Licensee") since 2007, and the 58 Altoona Licensee has an interior connection with a convenience store. The Altoona Licensee had had over one-half million (500,000) beer sales and it utilizes the same RAMP server policies and procedures that Applicant will use at the proposed licensed premises. (N.T. 03/18/2014 at 328-330). 203. The Altoona Licensee has received two (2) citations, sales to a minor and failure to require its manager to obtain RAMP certification within the required time. The sales to the minor incident occurred shortly after the Altoona Licensee opened and the employee who sold the beer to the minor had his employment terminated. (N.T. 03/18/2014 at 330-332). 204, Mr. Campbell testified at the Shippensburg Borough Council intermunicipal transfer hearing in July 2012 regarding Applicant's transfer application. He provided much of the same testimony as he did at the instant hearing. (N.T. 03/18/2014 at 332-333). 205. Sheetz, Inc. will operate five (5) gas pumps, and the area containing the gas pumps will be on the lease between the owner of the property and Sheetz, Inc. (N.T. 03/18/2014 at 333-334; Ex. A-1). 206. The distance between the nearest point of the proposed licensed establishment and the gas pumps is eighty (80) feet. Between the proposed licensed premises and the gas pumps, there will 59 be a sidewalk, ballards, parking stalls, a macadam drive area, and a speed bump. Also, there will be a steel fence approximately four (4) feet high between the parking lot and the outside tables. (N.T. 03/18/2014 at 334-336, 361-362). 207. Sheetz, Inc. will not have a kerosene pump on the property and Mr. Campbell believed that an oversight caused the site plan to show a kerosene pump be located approximately forty-five (45) feet from the proposed licensed premises. (N.T. 03/18/2014 at 336-337; Ex. A-1). 208. Sheetz, Inc. will sell gas "24/7" and gas customers can only pay at one (1) of the five (5) gas pumps. Customers will not be able to pay with cash for their gas purchases, only credit and debit cards will be accepted at the gas pumps. Customers will not be able to pay for gas at the Sheetz Convenience Store or the proposed licensed premises. (N.T. 03/18/2014 at 337, 340-341). 209. Propane will not be sold on the unlicensed or proposed licensed premises. (N.T. 03/18/2014 at 337-338). 210. An employee working in the Sheetz Convenience Store will observe and supervise the gas pumps. This employee will have the ability to shut down the gas pumps during an emergency via a shut-off switch located near the cash register in the convenience store. This 60 employee would not have the ability to turn the pumps back on, but would instead call a technician to deal with the issue. (N.T. 03/18/2014 at 338-339). 211. Applicant's employees, including the Board -approved manager, will not have any duties or responsibilities in regard to the gas pumps. (N.T. 03/18/2014 at 339). 212. Mr. Campbell acknowledged that Applicant's proposed licensed premises is located a couple blocks from Shippensburg University, but he indicated this location was chosen because the existing Sheetz store "was targeted to be rebuilt" and it is much easier to transfer a liquor license into a newly constructed store. The close proximity of college students was not factored in Applicant's decision. (N.T. 03/18/2014 at 342-344). 213. Applicant is requesting a Sunday sales permit and an extended hours food permit for the proposed licensed premises. (N.T. 03/18/2014 at 344; Ex. B-1). 214. An employee manning the SPC or fountain area would also be a customer greeter and would be in charge of monitoring the proposed licensed premises' dining area. If this employee is unavailable to monitor the dining area, either the manager or one (1) of the cashiers "would potentially be required" to monitor the dining 61 area. (N.T. 03/18/2014 at 353-354). 215. The only customer entrance to the proposed licensed premises will be via the vestibule area. (N.T. 03/18/2014 at 355). 216. Applicant's management will observe the video monitors inside the proposed licensed premises real time, which would permit management to surveil the exterior seating area concerning the presence of individuals consuming alcoholic beverages. Applicant will have a manager, two (2) assistants, and approximately eight (8) shift supervisors. (N.T. 03/18/2014 at 356). 217. Mr. Campbell plans on having someone follow-up with the Borough of Shippensburg concerning more frequent emptying of the Borough's trash can located in the vicinity of the Civic Club. (N.T. 03/18/2014 at 357). 218. There will be an emergency door located on the right wall of the proposed licensed premises, which will be locked from the outside and an alarm will sound if this door is opened. Video cameras will be pointed focused on this door, both inside and outside. (N.T. 03/18/2014 at 369-371; Ex. A-2). 219. Mr. Campbell would refer to the Sheetz Convenience Store, Sheetz Restaurant (the proposed licensed premises), and Sheetz (gas pump area) as three (3) separate businesses located on a parcel of 62 land in Shippensburg. Mr. Campbell indicated that Sheetz would like to have a one-stop shopping at each one (1) of the three (3) individual locations, but he did not believe it was doable to have one-stop shopping at all three (3) locations. (N.T. 03/19/2014 at 394-396). 220. The Sheetz logo will be prevalent at the Sheetz Convenience Store, proposed licensed premises, and gas pump area. There will be different branding inside the proposed licensed premises, such as "Sheetz MTO/To-Go" and "Sheetz Brothers Coffee." (N.T. 03/19/2014 at 397-398). 221. Mr. Campbell does not know if the Shippensburg Sheetz location will have an exterior sign that advertises the Sheetz Convenience Store, proposed licensed premises, and Sheetz Gas, similar to what is done at the location for the Altoona Licensee. (N.T. 03/19/2014 at 399-400). 222. Mr. Campbell indicated that it is not unusual for Sheetz to advertise food that it sells inside its building on the gas pumps, but the Shippensburg Sheetz location does not plan on advertising food, beer, or cigarettes that will be sold at the proposed licensed premises on the fuel pumps. (N.T. 03/19/2014 at 402-403). 223. Mr. Campbell provided an estimated cost to Shippensburg Borough Council at the time of Applicant's intermunicipal transfer 63 hearing, representing the cost of the rebuild at the subject site, including the cost of the building and the fuel pumps. (N.T. 03/19/2014 at 403-405). 224. The proposed licensed premises will not display warm beer because it does not have sufficient extra square footage to allow for this. The Altoona Licensee displays warm beer because it has a much larger facility, as compared to the proposed licensed premises. (N.T. 03/19/2014 at 413, 417-418). 225. The proposed licensed premises will have more food items than the Altoona Licensee. Also, the proposed licensed premises will have a walk-in cooler for beer, which the Altoona Licensee does not have. Lastly, the Altoona location allows customers to pay at the pump with cash, via a cash acceptor, and credit cards, but the Shippensburg location will not allow customers to pay with cash at the gas pumps. (N.T. 03/19/2014 at 418- 420). 226. At the location of the Altoona Licensee, there is a speed bump separating the pumps from the licensed premises and the Altoona location is the only Sheetz location where there is a speed bump between the fuel pumps and the building. This separation is very similar to what is proposed at the Shippensburg site in regard to the speed bump, drive -out, parking stalls, and sidewalk (N.T. 64 03/19/2014 at 423-428). 227. The contracted security at the Shippensburg facility will be paid by Sheetz. Also, the employees at the Sheetz Convenience Store and proposed licensed premises will be Sheetz employees. An employee will not work at the convenience store and proposed licensed premises at the same time. (N.T. 03/19/2014 at 429-432). 228. The employees who will be working in the Sheetz Convenience Store and the employees working at the proposed licensed premises will receive the same benefits, including the overtime policy. (N.T. 03/19/2014 at 435). 229. "ZFORCE" is a computer-based training program that Sheetz employees receive in the office of the particular Sheetz premises. All employees have to go through this training which deals with the sale of restricted items, such as cigarettes, alcohol, fuel sales, and gas pump monitoring. Mr. Campbell was not aware if all Sheetz employees are required to go through all aspects of the "ZFORCE" training. (N.T. 03/19/2014 at 432-435). 230. There is a training department at Sheetz that is responsible for maintaining training policies and procedures, which are utilized in the training. Training is done with the ZFORCE modules by managers at the store location. (N.T. 03/19/2014 at 435-436). 65 231. Mr. Campbell indicated there would be a minimum of one (1) manager on-site at any given time, but as many as three (3) managers may be on-site at any given time. A normal Sheetz store would have one (1) manager, two (2) assistants, and "an average of four (4) shifts." Some stores have as many as eight (8) shifts, three (3) assistants, and a manager. (N.T. 03/19/2014 at 436-437). 232. All employees at a Sheetz location report to the same manager, which includes employees from the proposed licensed premises and convenience store. (N.T. 03/19/2014 at 437). 233. Sheetz customers can obtain a gas card in exchange for their email address, which gives them three cents ($.03) off a gallon of gas. Points are not earned for gas based on store purchases. The process for obtaining a gas card starts in the store, but must be finished online. Mr. Campbell did not know whether there will be gas card brochures displayed at the proposed licensed premises. (N.T. 03/19/2014 at 437-439). 234. Cigarettes would be sold at the Sheetz Convenience Store and the proposed licensed premises. Mr. Campbell acknowledged that Sheetz is not concerned where a customer buys cigarettes because it all goes to the same company. The supplier of cigarettes will come to the Sheetz location three (3) times a week with cigarettes for both the 66 proposed licensed premises and the Sheetz Convenience Store. Mr. Campbell did not know whether the proposed licensed premises and the Sheetz Convenience Store would be invoiced separately for the cigarettes. (N.T. 03/19/2014 at 440-441). 235. Sheetz has one (1) centralized distribution center in Pennsylvania and products from that center will stock the store in Shippensburg. Products will be delivered from the same trucks regardless of whether they are for the proposed licensed premises or the convenience store area. (N.T. 03/19/2014 at 441-442). 236. The number of items sold at the Shippensburg Convenience Store will be scaled back, as compared to other Sheetz convenience stores, due to space constraints. (N.T. 03/19/2014 at 442-444). 237. If a customer came in to the Shippensburg facility and attempted to purchase twenty dollars ($20.00) worth of gas with cash, the customer would be offered a Z -Card (a gift card), which can be used at any Sheetz location to purchase gas at the pumps or other items in the stores. The Sheetz stores have been selling Z -Cards for approximately eight (8) or ten (10) years. (N.T. 03/19/2014 at 444- 447, 478). 238. Employees will not be specifically instructed that if a customer comes in with cash for the purchase of gas, that they are to 67 suggest the purchase of a Z -Card for use at the gas pump. Z -Cards will be sold at the proposed licensed premises. (N.T. 03/19/2014 at 488-489). 239. If there is an emergency at the gas pumps, an employee from the proposed licensed premises could go into the unlicensed convenience store area and turn off the pumps using the emergency shut-off switch, if the employee working at the convenience store is not able to. (N.T. 03/19/2014 at 447-448). 240. The canopy above the fuel pumps at the Shippensburg Sheetz location will have the Sheetz insignia on it. Mr. Campbell did not know whether there would be two (2) -way communication available at the gas pumps at the Shippensburg facility. (N.T. 03/19/2014 at 450-451). 241. Mr. Campbell agreed that under the law fuel cannot be dispensed within the four (4) walls of the proposed licensed premises. (N.T. 03/19/2014 at 453). 242. There will be four (4) fuel tanks located at the Shippensburg Sheetz location, as well as a kerosene tank. (N.T. 03/19/2014 at 454- 455; Ex. MBDA-4). 243. Applicant will not sell individual bottles of beer and cans, just six (6) -packs and twelve (12) -packs. The six (6) -packs and twelve 68 (12) -packs will not be comprised of loose bottles, just pre-packaged manufacturers' six (6) -packs and twelve (12) -packs. (N.T. 03/19/2014 at 459-460). 244. Applicant does not intend to compete with beer distributors but merely to supply its customers with a product. (N.T. 03/19/2014 at 463-465; Ex. MBDA-5). 245. The new Sheetz facility located in Shippensburg will proceed with construction, regardless of the outcome of Applicant's transfer application. (N.T. 03/19/2014 at 465). 246. The parties stipulated that as a result of a conditional use hearing held in Shippensburg Borough on October 4, 2011, the Borough granted Sheetz, Inc. permission to expand the dimensions of the structure on the subject premises and to relocate the gas pumps to a different area within this site. Further, the Borough permitted outdoor seating on the immediate exterior of the structure. (N.T. 03/19/2014 at 469-470). 247. The new Sheetz facility will have three (3) outdoor seating areas, but patrons will not be permitted to consume alcoholic beverages in these areas. (N.T. 03/19/2014 at 472-473). 248. Mr. Campbell was aware that the Board required a speed bump to be installed at the location of the Altoona Licensee. A speed 69 bump is being installed at the Shippensburg facility to increase the chances of Applicant's transfer application being approved. (N.T. 03/19/2014 at 479-480). 249. Applicant's minimum age for hiring employees will be sixteen (16)-year-old. A sixteen (16)-year-old will not be precluded from operating the cash registers at the proposed licensed premises, but the minor will not be permitted to sell beer and will have to turn over the cash register to another employee if a patron wants to purchase beer. (N.T. 03/19/2014 at 487-488). 250. There will not be a monitor located within the proposed licensed premises that would depict camera views of the gas pumps, but there will be a monitor inside the Sheetz Convenience Store. (N.T. 03/19/2014 at 490-493). 251. The wall separating the Sheetz Convenience Store and the proposed licensed premises will be different than the separation that was utilized by the Altoona Licensee because the Altoona facility uses shelving, instead of a wall, to separate the areas. (N.T. 03/19/2014 at 493-494). 252. If an intoxicated individual came to the proposed licensed premises to purchase food, Mr. Campbell opined that this individual would be offered something free to eat, but would not be sold food 70 knowing that there would be a wait for the food preparation. (N.T. 03/19/2014 at 511-513). 253. There will be a video monitor in the manager's office. The utility room where the centrally-located lighting controls would be located will be in the proposed licensed area. (N.T. 03/19/2014 at 517-518). 254. The existing Shippensburg Sheetz building will be completely demolished upon completion of the new Sheetz facility. (N.T. 03/19/2014 at 529-530). 255. John Kachur has been real estate counsel for Sheetz, Inc. for approximately fourteen (14) years. Mr. Kachur confirmed that the Sheetz building that presently exists at the Shippensburg location will be replaced by a new larger building. (N.T. 03/19/2014 at 530-531). 256. Both Sheetz, Inc. and its wholly owned subsidiary, Applicant, have the right to use the Sheetz name. (N.T. 03/18/2014 at 532- 534). 257. Applicant operates other properties for Sheetz that hold liquor licenses, primarily in Ohio and one (1) in Pennsylvania. (N.T. 03/18/2014 at 536). 258. C.S.P. Investments, Inc. is related to Sheetz, Inc., but Sheetz, Inc. owns no stock in C.S.P. Investments, unlike Sheetz, Inc.'s 71 complete ownership of Applicant. The officers and directors of C.S.P. Investments, Inc. are all Sheetz employees. (N.T. 03/19/2014 at 534- 535; Ex. MBDA-1). 259. In order to have an interest in C.S.P. Investments, Inc., one (1) would have to be employed by Sheetz, Inc. and hold a director or higher position, and the shares must be purchased. (N.T. 03/19/2014 at 535). 260. C.S.P. Investments, Inc. purchases various properties which it then only leases back to Sheetz, Inc.; it is essentially a holding company. (N.T. 03/19/2014 at 536). 261. In March 2012, C.S.P. Investments, Inc. purchased the tract adjacent to the present Sheetz facility and one (1) week later it purchased the land where the current Sheetz is located from Sheetz, Inc. C.S.P. Investments, Inc. created a two (2) -unit retail condominium ("Unit 1" and "Unit 2") and a common areas, pursuant to a Declaration of Condominium of Shippensburg King & Queen Retail Condominium dated November 29, 2012 ("Declaration of Condominium"). (N.T. 03/19/2014 at 532-533, 536-537, 546; Ex. A- 3). 'The common area is colored green on Exhibit A-4. 72 262. Unit 1 and Unit 2 are both owned by C.S.P. Investments, Inc. Applicant is leasing Unit 16 from C.S.P. Investments, Inc., which will be used for the proposed licensed premises and Unit l's street address will be 345 East King Street. (N.T. 03/19/2014 at 538-540; Exs. A- 31 A-4, MBDA-7), 263. Sheetz, Inc. is leasing Unit 27 from C.S.P. Investments, Inc. and Unit 2's street address is 359 East King Street. Unit 2's leased area includes the convenience store, gas pumps, and underground gas tanks. (N.T. 03/19/2014 at 540-542, 558-559; Exs. A-3, A-4, MBDA- 8). 264, Unit 1 and Unit 2 each have their own real estate tax numbers. The tax parcel identifications were not assigned to Unit 1 and Unit 2 until November 2013. The new address would not have been assigned until November or December 2013. The application, which was filed July 30, 2012, lists an address for the entire property of 359 East King Street. Applicant's attorney indicated that it is not uncommon for an address to change for new construction and that Applicant will have do an address change. (N.T. 03/19/2014 at 542- 5431 554-557; Ex. B-1). 6 Unit l's leased area is colored red on Exhibit A-4. 7 Unit 2's leased area is colored purple on Exhibit A-4. 73 265. Section 8.1 of the Declaration of Condominium mandates that Unit 1 shall not be used for automobile fuel sales and Section 8.2 of the Declaration of Condominium mandates that Unit 2 shall not be used for alcohol sales. Mr. Kachur indicated that both of these sections are akin to a deed restriction. (N.T. 03/19/2014 at 540, 542; Ex. A-3). 266. The real estate acquisition by C.S.P. Investments, Inc. and configuration of the Sheetz facility was completed in anticipation of building a licensed establishment which complied with the Board's requirements for the sale of beer. (N.T. 03/19/2014 at 544-545). 267. Unit 1 and Unit 2 would be assessed separately for their areas. The tax assessment of the common area would be based on Unit 1 and Unit 2's percentage interest, which is defined in Section 3.1 of the Declaration of Condominium. Applicant would be responsible for approximately thirty percent (30%) of the taxes for the common area and Sheetz, Inc. would be responsible for paying approximately seventy percent (70%) of the taxes for the common area. (N.T. 03/19/2014 at 546-547; Ex. A-3). 268. The kerosene tank at the current Shippensburg Sheetz facility will be removed upon demolition of that store and a new kerosene tank will not be installed for the new Shippensburg Sheetz 74 facility. Applicant's attorney pointed out that although Applicant's original site plan specified kerosene, it has been subsequently removed from the plan. (N.T. 03/18/2014 at 547-550). 269. The new Shippensburg Sheetz facility being developed is one and sixty-four hundredths (1.64) acres, as consolidated. (N.T. 03/19/2014 at 550-551). 270. The non-conforming use extension granted by Shippensburg Borough Council was given to Sheetz, Inc. concerning approvals for gasoline, outdoor seating, and a convenience store. (N.T. 03/19/2014 at 553). 271. There will not be a physical demarcation on the exterior of new Sheetz facility to differentiate between Unit 2's area and the common area. (N.T. 03/19/2014 at 559-560; Ex. A-4). 272. The separation of the subject property into condominium units was not a subdivision under municipal law or municipal ordinances, but was a legal subdivision as far as creating separate estates or interests in land. (N.T. 03/19/2014 at 561). 273. C.S.P. Investments, Inc.'s intention is that no fuel operations will occur in the common areas of the condominium site. (N.T. 03/19/2014 at 569). 274. The cleaning and maintenance of the common areas will be 75 performed by a condominium association consisting of the two (2) members, Applicant and Sheetz, Inc. Each unit owner would be separately assessed based on their percentage interest. The condominium apportionment of the Shippensburg tract would not have been done if Applicant was not applying for a liquor license. (N.T. 03/19/2014 at 570-571, 583-589; Ex. A-3). 275. Mr. Kachur believes that Unit 1 and Unit 2 are two (2) separate properties and two (2) separate locations. (N.T. 03/19/2014 at 572). 276. There are employees or shareholders of Applicant who are shareholders or officers in C.S.P. Investments, Inc. One (1) can be a shareholder of C.S.P. Investments without being an officer in Applicant, as long as that person is an employee. (N.T. 03/19/2014 at 579-580; Ex. A-3). 277. The new Sheetz facility will have five (5) multiple product dispensers ("MPDs"). A new gas tank may be installed to replace the kerosene tank which had a five thousand (5,000) gallon capacity. (N.T. 03/19/2014 at 581-582; Ex. A-1). 278. James Rega has been a licensed private investigator for approximately three (3) years. Prior to becoming a private investigator, Mr. Rega was a lieutenant for the Southwest Regional 76 Police Department in Belle Vernon, Pennsylvania and a county detective for the Washington County District Attorney's Office. (N.T. 03/19/2014 at 592). 279. Mr. Rega was employed by MBDA to conduct a field observation at the Altoona Licensee's location on Pleasant Valley Boulevard and Mr. Rega conducted said field observation on November 15, 2013. (N.T. 03/19/2014 at 592-593). 280. During the course of his observations Mr. Rega took photographs of the Altoona Licensee's premises. (N.T. 03/19/2014 at 593; Ex. MBDA-3). 281. During Mr. Rega's field observation, he did not see anything at the Altoona Licensee's premises that indicated to him that it was not an integrated business. The only separation between the fuel pumps and the building was the presence of a plastic molded speed barrier or bump that ran "pretty much the length of the fuel aisle." Mr. Rega did not know the purpose of this speed bump and he had not seen this before at any other Sheetz location. (N.T. 03/19/2014 at 593-594; Ex. MBDA-3). 282. There was an elevated outside sign at the Altoona Licensee which advertised coffee, car wash, drive-thru, dining, carry -out, and gas prices. (N.T. 03/19/2014 at 595; Ex. MBDA-3). 77 283. Mr. Rega estimated the distance from the curb to the fuel pumps at the Altoona Licensee's location to be between fifty (50) and sixty (60) feet and the distance from the building to the gas pumps to be approximately seventy-five (75) feet. (N.T. 03/19/2014 at 596; Ex. MBDA-3). 284. Mr. Rega observed a sign on a fuel pump at the Altoona Licensee's location that read "pay inside." Mr. Rega also observed an employee during his visit who was wearing a pin with his name and the Sheetz logo. (N.T. 03/19/2014 at 597-598; Ex. MBDA-3). 285. Mr. Rega observed a banner at the Altoona Licensee's location that indicated there was a three cents ($.03) discount on gas with a gas card. (N.T. 03/19/2014 at 598; Ex. MBDA-3). 286. Mr. Rega observed there were some individual cans of beer, but the bulk of the beer at the Altoona Licensee were twelve (12) - packs and six (6) -packs. He also observed four (4) pallets of warm beer displayed on the floor at the Altoona Licensee's premises. (N.T. 03/19/2014 at 600; Ex. MBDA-3). 287. During Mr. Rega's visit to the Altoona Licensee, he ordered a made-to-order sandwich and his order confirmation had Sheetz store number 354, which is the number for the Altoona Licensee's store. Mr. Rega paid for his made-to-order sandwich, a six (6) -pack of Red's 78 Apple Ale beer, a Sheetz Z -Card, and STP oil treatment at a cash register in the licensed area. (N.T. 03/19/2014 at 600-602; Ex. MBDA-10). 288. As Mr. Rega was purchasing his items at the cash register in the licensed area, he attempted to purchase ten dollars ($10.00) worth of gas and was told by the cashier that he could not after the cashier consulted with another employee. The cashier advised Mr. Rega that he could purchase a Z -Card and use that at the pump, which Mr. Rega subsequently did. (N.T. 03/19/2014 at 603-604; Ex. MBDA- 10). 289. The oil treatment that Mr. Rega purchased was located on the shelf with supplies. (N.T. 03/19/2014 at 616-617). 290. Mr. Rega was asked during his visit at the Altoona Licensee if he wanted a Sheetz card, which he accepted. On the back of the Sheetz card, it indicated that the card entitled the holder "to earn rewards for purchases made at Sheetz and is powered by Pump First, which allows the approved user to bypass prepayment for gasoline at the designated Sheetz stores." (N.T. 03/19/2014 at 605-606; Ex. MBDA-10). 291. Upon further questioning, Mr. Rega did not know what the term "rewards" really meant that was specified on the back of the 79 card. Also, Mr. Rega did not go to the website specified on the back of his Sheetz card to find out additional information regarding the use of the card. (N.T. 03/19/2014 at 609, 616; Ex. MBDA-10). 292. Mr. Rega indicated that he was told by an employee during the visit to Altoona Licensee's establishment that his Sheetz card had been activated at the time of his November 15, 2013 visit. He did not use his Sheetz card to obtain a three cents ($.03) discount on gas during his visit. (N.T. 03/19/2014 at 615-616). 293. Mr. Rega indicated that he walked around at the Altoona Licensee's establishment for approximately ten (10) minutes with a six (6) -pack of beer and a sandwich, and he was not "challenged." (N.T. 03/19/2014 at 606-607). 294. Mr. Rega was not aware that the Altoona Licensee and the Board had entered into a conditional licensing agreement regarding certain aspects of how the fuel pumps would be operated, and how the convenience store and restaurant would be operated. (N.T. 03/19/2014 at 609). 295. Mr. Rega acknowledged that prior to visiting the Altoona Licensee's location he was looking for the sale of liquid fuels and alcohol at the same place. (N.T. 03/19/2014 at 613). 296. Mr. Rega believed that fuel treatment was also displayed in 80 the Altoona store and he was not able to give a reason why he purchased the oil treatment instead of the fuel treatment. He did not know if he would have been able to purchase fuel treatment with his beer at the cash register in the licensed area. (N.T. 03/19/2014 at 617-618). 297. Mr. Rega estimated the speed bump at the Altoona Licensee's location to be approximately six (6) inches high and approximately one (1) foot wide; the speed bump ran the length of the fuel islands. (N.T. 03/19/2014 at 618-619). 298. Mr. Rega observed during his visit to the Altoona Licensee's location that between the gas pumps and the building, there was a sidewalk, metal posts, parking area, and a speed bump. (N.T. 03/19/2014 at 621-623; Ex. MBDA-3). 299. Mr. Rega was asked by one (1) of Altoona Licensee's employees for his driver's license when he purchased his beer at the cash register. (N.T. 03/19/2014 at 623-624). 300. Steve Gabler is the owner of Gabler's Beverage Distributor ("Gabiers") in Shippensburg, a licensed beer distributor. Gablers sells to the general public, bars, taverns, and clubs, and Mr. Gabler indicated that sales to retail licensees is a very small portion of his business. (N.T. 03/19/2014 at 626). 81 301. Gablers is located at 29 North Seneca Street in Shippensburg, which is between four (4) and four and one-half (41/2) blocks from Applicant's proposed licensed premises. (N.T. 03/19/2014 at 627). 302. Mr. Gabler has owned Gablers for over twenty-eight (28) years and its licensed premises is between two thousand (2,000) and two thousand five hundred (2,500) square feet. (N.T. 03/19/2014 at 627). 303. Mr. Gabler works at Gablers full-time and Gablers has five (5) part-time employees, four (4) of whom are college students at Shippensburg University. (N.T. 03/19/2014 at 628). 304. Ninety-five percent (95%) of Gablers' sales come from beer. Gablers sells over one hundred (100) verities of domestic, import, and craft beers. Gablers also sells cigarettes, chips, pretzels, beef jerky, soda, water, and similar items. (N.T. 03/19/2014 at 628-629). 305. Gablers' beer is sold by the case, thirty (30)-packs, and kegs. The cases of beer are prepackaged and Gablers is not allowed to adulterate or change this packaging in any way. Gablers is not permitted to sell two (2) different twelve (12)-packs of beer and it cannot sell a single twelve (12)-pack. (N.T. 03/19/2014 at 629-630). 306. Mr. Gabler described the Shippensburg Sheetz store as being 82 a typical convenience store selling "MTO food, snacks, candy bars, cigarettes, milk, [and] soda." (N.T. 03/19/2014 at 632). 307. Mr. Gabler believes that if Applicant sells six (6)-packs and twelve (12)-packs of beer to go, it will harm his business. The bars and taverns in Shippensburg that sell take-out beer do not offer a Targe variety and their pricing in not too competitive with beer distributors. (N.T. 03/19/2014 at 633). 308. Mr. Gabler acknowledged there are many items Gablers is permitted to sell, pursuant to Board guidelines, but it chooses not to sell many of those items. Mr. Gabler pointed out that Applicant will be able to sell a large number of items that Gablers cannot sell. (N.T. 03/19/2014 at 636-637). 309. Mr. Gabler indicated that Gablers cannot compete with a Sheetz facility that is able to sell gasoline and convenience items because it does not have the purchasing power. Mr. Gabler pointed out that Applicant already has a retail liquor license for the Altoona Licensee and he is only permitted by law to own one (1) distributor license or any other type of license. Mr. Gabler believes that owning multiple establishments would allow for better price negotiations. (N.T. 03/19/2014 at 637-639). 310. Mr. Gabler did not believe that Gablers is permitted to sell 83 prepared foods at his distributorship, such as burrito bowls, breakfast sandwiches, and made-to-order sandwiches. (N.T. 03/19/2014 at 639- 640). 311. Applicant would be able to purchase beer from Gablers, if it chose to, but Mr. Gabler indicated that it could also purchase directly from an importing distributor. Mr. Gabler believed he would not be able to compete with the prices of an importing distributor because an import distributor obtains it beer directly from the manufacturer. (N.T. 03/19/2014 at 641-642). 312. Mr. Gabler believed the one-stop shop aspect of the Shippensburg Sheetz facility makes it very attractive for people to purchase their gas, food, and beverages, alcohol or non-alcohol, all at one (1) time as opposed to making two (2) or three (3) stops. (N.T. 03/19/2014 at 642-643). 313. Mr. Gabler's objection to Applicant's transfer application is his belief that Applicant should not be able to sell gasoline and alcohol from the same property and he would not have a reason to object to Applicant's application if the Sheetz facility decided not to have gas pumps. (N.T. 03/19/2014 at 644-646). 314. Mr. Gabler acknowledged there are a lot of items that the Sheetz Convenience Store sells that Gablers would also be able to sell, 84 but Gablers made a business decision not to sell them because it does not have the demand from its customers. (N.T. 03/19/2014 at 647- 649). 315. Mr. Gabler was not aware that he could apply to the Board to operate a convenience store adjacent to his distributorship with an interior connection, nor was he aware of any other beer distributors that have that type of setup. (N.T. 03/19/2014 at 649-650). 316. Gablers' employees are not all RAMP -certified. (N.T. 03/19/2014 at 652). 317. Mr. Gabler believed that the majority of the retail licensed establishments in the Borough of Shippensburg sell six (6) -packs of beer -to -go. (N.T. 03/19/2014 at 652-653). 318. Gablers does not place malt or brewed beverages on sale on its own. However, it will reduce its price if its supplier puts a particular product on sale, which it then passes along to the customer. (N.T. 03/19/2014 at 656-657). 319. Mr. Gabler acknowledged he is allowed to deliver beer to consumers, which he did when he first went into business for a couple of years, but later decided to stop this service because it was not "worth our while." Gablers does delver to retail licensees. (N.T. 03/19/2014 at 655-658). 85 320. Mr. Gabler has never considered converting his distributor license to an importing distributor license. (N.T. 03/19/2014 at 658- 659). 321. Mr. Gabler believes the liquid fuel prohibition addressed in the Liquor Code should be handled by the Legislature and not the Board or the judiciary because he believes the Board and judiciary's interpretation is arbitrary. Mr. Gabler does not know what the future holds for his business; he is at the mercy of "who's interpreting the laws and what they say." Mr. Gabler is a member of MBDA. (N.T. 03/19/2014 at 659-660). 322. Mr. Gabler opined that unless the law is changed, grocery stores and convenience stores, whether or not they are selling gasoline, should not be permitted to sell beer. (N.T. 03/19/2014 at 677-678). 323. Gabiers is open Monday through Saturday from 8:00 a.m. until 9:00 p.m. Mr. Gabler pointed out that his distributorship could be open until 11:00 p.m., Monday through Saturday, and on Sunday from 9:00 a.m. until 9:00 p.m. (N.T. 03/19/2014 at 662-663). 324. Mr. Gabler anticipates having a loss of revenue if Applicant's transfer application is approved because he believed that Gabiers would lose business based on information he received from a 86 distributor in Gettysburg, whose business is located close to a licensed Giant grocery store. (N.T. 03/19/2014 at 664-667). 325. Mr. Gabler acknowledged that Gablers must collect six percent (6%) sales tax on every beer sale it makes and that if a retail licensee does not have to charge sales tax on its beer sales, the retail licensee's price would be six percent (6%) lower. (N.T. 03/19/2014 at 671-673). 326. Mr. Gabler further acknowledged he is not aware of any licensed restaurants in Shippensburg that stack warm beer in the middle of their premises, have advertisements in publications comparing their prices to beer distributors, sell gasoline, discourage their patrons from staying and drinking on the premises, sell ninety- five percent (95%) of their beer -to -go, or that hold a restaurant liquor license yet choose not to sell wine or spirits. (N.T. 03/19/2014 at 673-675). 327. Mr. Gabler believes that the proposed licensed premises will have problems with college students purchasing food and consuming beer on the premises while they are eating their food, particularly late in the evening, in view of the proximity of the college campus and nearby student housing. (N.T. 03/19/2014 at 681). 328. Gablers purchases beer only from importing distributors and 87 it has signed territorial agreements in regard to the territory for particular products sold by the importing distributors. Gablers is required to buy beer from the importing distributor who has the territorial rights or the franchise rights to that product for the Shippensburg area. Gablers believes it cannot buy directly from the manufacturer, even if it is a small craft brewery. Gablers buys eighty percent (80%) of its beer from two (2) importing distributors in Harrisburg and it receives some slight price variations for quantity purchases. (N.T. 03/19/2014 at 685-688). 329. Patrick Diehl is the owner and president of PKD, Inc., which holds a distributor license in Shippensburg Borough and is located approximately four (4) blocks from the proposed licensed premises. Mr. Diehl has owned this distributorship for nine (9) years. (N.T. 03/19/2014 at 689-691). 330. PKD, Inc. has five (5) employees, including Mr. Diehl and ninety percent (90%) of its sales are from beer. PKD, Inc. also sells miscellaneous items, such as snacks, ice, cups, and tobacco. (N.T. 03/19/2014 at 690-691). 331. Mr. Diehl is opposed to Applicant's transfer application because Applicant will be located on a parcel that is going to be selling liquid fuels and alcohol and he believes this is prohibited by the Liquor 88 Code. (N.T. 03/19/2014 at 692). 332. Mr. Diehl, "for the most part," agreed with the testimony of Mr. Gabler at the instant hearing. (N.T. 03/19/2014 at 692). 333. PKD, Inc. sells a case of Yuengling Lager twelve (12) -ounce bottles for nineteen dollars and ninety-five cents ($19.95) plus tax, and Mr. Diehl agreed that this was more than the Altoona Licensee was charging for two (2) twelve (12) -packs of beer. Mr. Diehl pointed out that his distributorship cannot sell twelve (12) -packs and it cannot mix a case with different varieties of beer. Mr. Diehl believes the proposed licensed premises is going to be a detriment to his business because it will be clear competition. (N.T. 03/19/2014 at 693-694). 334. Mr. Diehl acknowledged there are many items that he could sell at his distributorship, but he has chosen to not sell those items. Also, Mr. Diehl indicated that he does not want to have an interior connection with a convenience store at his distributorship because he believes he could not sell these items for "anywhere near the price that the convenience store does." (N.T. 03/19/2014 at 695). 335. One-half (1/2) of PKD, Inc.'s employees are RAMP -certified. Mr. Diehl believes the RAMP training is generic and the training that he provides to his employees is much more beneficial. (N.T. 03/19/2014 at 696). 89 336. Mark Tanczos is president of MBDA and he has held this position for approximately three (3) years. Mr. Tanczos has been a member of MBDA since taking over his family distributorship in Bethlehem in 1988. (N.T. 03/19/2014 at 698-699). 337. MBDA is a trade association for Pennsylvania's beer distributors. MBDA's purpose is to promote the advancement of the business of malt beverage distributors; to foster, develop, and maintain the ethical practice of distributors of malt beverages; and to furnish information relative to the malt beverage business, with a view of facilitating the conduct of the business for the distributor members and to maintain better relations between distributors, manufacturers, retail licensees, and the public. Membership in MBDA is open to distributors and import distributors, and it has an annual membership. (N.T. 03/19/2014 at 699-700). 338. As of June 30, 2013, MBDA had approximately five hundred seventeen (517) members in Pennsylvania. There are two (2) members from the Shippensburg area: Gabler's Beverage Distributor, Inc. and PKD, Inc. (N.T. 03/19/2014 at 700-701). 339. The decision by MBDA to file a petition to intervene was made at an executive committee meeting and later ratified by MBDA's Board of Directors. Mr. Tanczos indicated that MBDA is objecting to 90 Applicant's transfer application because it believes the Liquor Code prohibits beer and gasoline sales at the same location, place, or property and MBDA believes that the proposed licensed premises and gasoline pumps are at the same location, place or property. (N.T. 03/19/2014 at 701-702). 340. Mr. Tanczos is aware of the efforts over the years to remove the liquid fuel prohibition from the Liquor Code, in particular the "FreeMyBeer.com" website. MBDA opposes these attempts to amend the Liquor Code because it is a highly regulated and complicated set of laws creating niche markets and the fact that beer distributors get into the business with the understanding that alcohol would not be sold at places where gasoline or liquid fuel is sold; MBDA wants to protect its niche market of off -premises beer sales. (N.T. 03/19/2014 at 703- 704). 341. Mr. Tanczos' distributorship competes with other distributors, as well as retail licensees who sell six (6) -packs of beer. His distributorship does not compete with any licensed business, such as that proposed by Applicant. (N.T. 03/19/2014 at 704-705). 342. MBDA is also opposed to Applicant's transfer application because it would allow Applicant to sell a huge array of food from its proposed licensed establishment and be able to sell beer without sales 91 tax. Also, there would be convenience items and gasoline for sale at the Sheetz facility. Mr. Tanczos believes this one-stop shopping provides the ability to attract customers that the average distributor does not have. (N.T. 03/19/2014 at 705). 343. Also, Mr. Tanczos believes the sale of liquid fuel is a draw for a business because everyone has to fuel their vehicles but not everyone has to buy beer. If someone has to stop at a convenience store and purchase gas, that person has ability to pick up beer and there is no longer a need for a beer distributor. (N.T. 03/19/2014 at 710). 344. Mr. Tanczos believes that the proposed licensed operation will be a de facto beer distributorship, due to anticipated take-out beer sales of ninety-five percent (95%) and a lack of encouragement of consumption on -premises. Mr. Tanczos also believes with transient customers who are purchasing gas, it will be an advantage in competition that will be catastrophic to beer distributors located in the vicinity of the proposed licensed premises. (N.T. 03/19/2014 at 706). 345. Mr. Tanczos indicated the type and number of products that a Sheetz convenience store can sell are much larger than what a beer distributor would be allowed to sell. (N.T. 03/19/2014 at 706-707). 346. Mr. Tanczos pointed out that the niche market of beer 92 distributors is off-premises beer sales and distributors are not grocery stores or convenience stores. (N.T. 03/19/2014 at 708-709). 347. Mr. Tanczos opined that an average distributor would not have the assets to invest in its business commensurate with what Sheetz invests in a single store. (N.T. 03/19/2014 at 710). 348. MBDA's information indicates that between eighty-five percent (85%) and ninety-five percent (95%) of an average beer distributor's sales is derived from beer sales. (N.T. 03/19/2014 at 711) 349. Mr. Tanczos has observed chain operations with out-of-state relationships that have the ability to purchase alcohol to the detriment of beer distributors and as a result, distributors cannot get that brand of beer because the Targe corporate chains have "sort of cornered the market." (N.T. 03/19/2014 at 712). 350. Mr. Tanczos' business formerly held an importing distributor license until 2013. Mr. Tanczos advised that large retail accounts are serviced by importing distributors. There are agreements between the manufacturer and the importing distributor concerning merchandising, quality control, signage, and sales support of its product. Mr. Tanczos indicated that a small distributor does not have the resources to compete with an importing distributor for large retail accounts. (N.T. 93 03/19/2014 at 713-714). 351. A retail licensee pays sales tax when it makes a purchase from a distributor and/or importing distributor, resulting in the retailer not charging sales tax on beer purchases by a consumer. A consumer purchasing beer from a distributor pays sales tax on his/her purchase to the distributor. Mr. Tanczos is concerned that when a consumer purchases gas at a convenience store and sees the price of beer is cheaper at the licensed establishment located next to the convenience store than at a distributor, the consumer will purchase the beer from the licensed establishment instead of at a distributor. (N.T. 03/19/2014 at 715-716). 352. MBDA is the only trade association for distributors and importing distributors in Pennsylvania, which number between one thousand two hundred (1,200) and one thousand three hundred (1,300); only five hundred seventeen (517) of these distributors and importing distributors are members of MBDA. (N.T. 03/19/2014 at 717). 353 Board Advisory Notice No. 9, Fifth Revision, dated April 25, 2012, substantially expanded the items that a distributor can sell. Mr. Tanczos indicated this was done pursuant to a list of items, that were not convenience or grocery store items, submitted by MBDA from its 94 members. Some of the expanded items were not on MBDA's list, but were items that distributors in the past may have requested to sell. (N.T. 03/19/2014 at 718-720). 354. Mr. Tanczos advised that presently Wegmans, Giant, and Weis are obtaining beer that his distributorship cannot obtain because he believes that large corporate chains are able to dictate a market. He believes the added benefit of the gasoline attraction would make the situation worse. (N.T. 03/19/2014 at 723-724). 355. There is a beer distributor located across the street from the Altoona Licensee's operation and Mr. Tanczos does not know if this distributor is still in business. (N.T. 03/19/2014 at 724). 356. In regard to the presence of a distributor in a strip mall with a licensed grocery store that has gas pumps, Mr. Tanczos opined that the distributor does not have any connection to the grocery store selling the liquid fuels, with the entity itself being the location and there being "a clear bright line there, where there isn't here." (N.T. 03/19/2014 at 726). 357. Mr. Tanczos indicated that MBDA would not have filed a petition to intervene in the instant matter if gasoline was not being sold at the new Sheetz facility. (N.T. 03/19/2014 at 728). 358. As president of MBDA, Mr. Tanczos indicated that he receives 95 calls and communications from non-member distributors. MBDA sends out a newsletter two (2) times a year to all distributors, which provides news and a solicitation to join the organization. Mr. Tanczos indicated that some distributors do not want to pay the membership dues to MBDA, while other non-members contribute to MBDA's legal fund. (N.T. 03/19/2014 at 732). 359. Mr. Tanczos indicated that it is becoming more common for large retailers, such as licensed grocery stores, to bypass distributors and purchase strictly from importing distributors, skipping the three- tier system. Particularly, for specialty seasonal beers it is becoming common practice and there have been instances where "chains" are getting pricing lower than beer distributors on popular mainstream beers. (N.T. 03/19/2014 at 732-733). 360. Mr. Tanczos' opinion, on behalf of MBDA, is that the granting of the application will be catastrophic for its members, but this opinion is not based on any real knowledge gained from the experiences of MBDA's members in Altoona. (N.T. 03/19/2014 at 733-734). 96 DISCUSSION Licensing raised thirteen (13) objections to Applicant's application for the intermunicipal double transfer of Restaurant Liquor License No. R-19377. Each objection will be addressed below. Licensing's first and tenth objections will be addressed together. Section 404 of the Liquor Code provides that: in the case of ... the transfer of any license to a new location ... the board may, in its discretion, grant or refuse such new license, transfer or extension if such place proposed to be licensed is within three hundred feet of any church, hospital, charitable institution, school, or public playground.... [47 P.S. § 4-404] . As with other licensees within two hundred (200) feet, section 404 of the Liquor Code [47 P.S. § 4-404] gives the Board discretion to grant or deny a new license when the proposed licensed premises is located within three hundred (300) feet of any church, hospital, charitable institution, school or public playground. Such proximity permits the Board to exercise its discretion, because the very existence of these restrictive institutions within the statutory distance, standing alone, is a sufficient basis for denial of the application. See Altshuler v. Pennsylvania Liquor Control Bd., 729 A.2d 1272 (Pa. 97 Cmwith. 1999); Pennsylvania Liquor Control Bd. v. DeMutis, 97 Pa. CmwIth. 507, 510 A.2d 154 (1986). However, as with other licensees, such denial is not required, and the Board can exercise its discretion to grant the application despite the presence of restrictive institutions. West Reading Tavern, Inc. v. Pennsylvania Liquor Control Bd., 710 A.2d 648 (Pa. CmwIth. 1998). Again, the presence or absence of a protest by the restrictive institution is not determinative in the Board's decision to grant or deny the application. In re Her-Bell Inc., 176 Pa. Super. 206, 107 A.2d 572 (1954). The record shows that the Civic Club is located two hundred five (205) feet from the proposed licensed premises, well within the three hundred (300) feet constraint of section 404 of the Liquor Code, inter alia. In determining whether an organization constitutes a charitable institution under the Liquor Code, "evidence as to the actual 'origin, organization, function, objects and methods of operation' ... must be examined." Irem Temple AAONMS v. Pennsylvania Liquor Control Bd., 87 A.3d 983 (Pa. CmwIth. 2014) [quoting Subers Liquor License Case, 173 Pa. Super. 558, 98 A.2d 639, 640 (1953)]. 98 The record shows that Sandra Hummel, the Civic Club's treasurer of seven (7) years, related that the purpose of the Civic Club is to educate women of the community and offer assistance and services. The unincorporated civic organization is non-profit and generates its funding from dues, donations, both public and private, and a trust. Its members are not compensated. The Civic Club provides public and private tours of its historic premises free of charge while the gardens surrounding the Civic Club's headquarters are always open to the public. More significantly, the Civic Club sponsors a community nurse who provides free need-based nursing care to physician-recommended patients. Speakers are enlisted to lecture on a wide range of topics and educate the Civic Club's members at monthly meetings. Further, the Civic Club provides scholarship money to a student of the month. While charity to all who apply for it is not realistic due to the limitations of the Civic Club's resources, its nursing care and scholarships are charitable by any definition. The benevolent purpose and educational objectives of the Civic Club are clearly being achieved free of any profit motive. 99 Therefore the Civic Club, located within three hundred (300) feet of the proposed licensed premises, is a charitable institution under section 404 of the Liquor Code. The Civic Club filed a timely protest to Applicant's intermunicipal transfer application and would have standing as a protestant in the instant matter. The Civic Club's representatives at the instant hearing, Ms. Smith and Ms. Hummel, expressed concerns regarding trash and debris discarded by customers from the existing Sheetz location, even though Ms. Smith testified that some of the trash was came from the neighboring McDonald's. Also, the Civic Club was concerned that Applicant's patrons would party and leave their trash in the Civic Club's garden, the area neighboring the proposed licensed premises is already congested, the problems in the area would increase, and that gasoline would be sold near the proposed licensed premises. Although the Civic Club expressed concerns regarding the proposed licensed premises, the Board finds there was not enough non -speculative evidence presented by the Civic Club to suggest that Applicant's proposed licensed premises in particular presents any harm to the Civic Club. Therefore, although the Board has the discretion to 100 refuse Applicant's application based on its proximity to the restrictive institution, it found no compelling reason to do so in this case. 8 Licensing's second objection required the Board to take evidence to determine if it should permit an interior connection with the unlicensed convenience in accordance with section 3.52(b) of the Board's Regulations, which provides that a licensed premises "may not have an inside passage or communication to or with any business conducted by the licensee or other persons except as approved by the Board." [40 Pa. Code § 3.52(b)]. It is well established that an agency's interpretation of the statutes and regulations that it is authorized to enforce and implement is entitled to deference. Sunoco, Inc. v. Department of Environmental Protection, 865 A.2d 960 (Pa. Cmwlth. 2005). Where a statutory scheme is technically complex, "a reviewing court must put aside its discretion [in favor of] the expertise of the administrative agency." Id. at 970. See also Pennsylvania Liquor Control Bd. v. Ripley, 107 Pa, Cmwlth. 425, 529 A.2d 39 (1987). Historically, interior connections have been approved in licensed establishments that had interior connections to a number of 'The Board did not have to decide whether the Civic Club of Shippensburg had standing as an intervenor because the Board determined that it has standing as a protestant. 101 commercial establishments. Section 3.52 of the Board's Regulations, adopted in 1970, and its predecessors, Regulation 103 (effective 1952 Pa. Bulletin Vol. 1, No. 2, p. 78) and Regulation R-37-27 (effective on August 18, 1937) reflect over seventy (70) years of policy that has given the Board discretion to approve interior connections between restaurant or eating place licenses and commercial establishments, such as department stores, convenience stores, delicatessens, and grocery stores. In 2004, the Board approved an interior connection between a Sheetz convenience store and the restaurant being licensed, although that decision was reversed for other reasons. See Malt Beverages Distributors Ass'n v. Pennsylvania Liquor Control Bd. ("Ohio Springs II"), 918 A.2d 171 (Pa. Cmwlth. 2007), aff'd, 601 Pa. 449, 974 A.2d 1144 (2009). Also, the Board has permitted interior connections with grocery stores, which were similar to the one (1) at issue here, and the decisions of the Board were affirmed by this Honorable Court and the Pennsylvania Supreme Court. (See Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 965 A.2d 1254 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 965 A.2d 1269 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor 102 Control Bd., 966 A.2d 1165 (Pa. CmwIth. 2009); aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 966 A.2d 1172 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 966 A.2d 1180 (Pa. CmwIth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010)). Applicant's site plans show the proposed licensed premises of the new Sheetz facility will be a lot larger than the Sheetz Convenience Store. The businesses will be separated by an eight (8) foot wall having a one (1) four (4) -foot wide interior opening for use by the general public. Operations between these two (2) businesses will be equally separated, with their respective products being stored, displayed, and sold only within their particular areas. Aside from tobacco products, candy, and gum, there will be no commonality of merchandise. Applicant intends only to sell malt or brewed beverages in six (6) -pack and twelve (12) -pack quantities, with the possession of these beverages prohibited within the convenience store, unless previously purchased in the proposed licensed premises. Applicant's proposed separation between the unlicensed convenience store and proposed licensed premises would be in 103 compliance with section 468(e) of the Liquor Code [47 P.S. § 4- 468(e)]9 and section 3.54 of the Board's Regulations [40 Pa. Code § 3 54 Ji.0 Testimony was also provided that Applicant will have three (3) cash registers located at its proposed licensed premises where all malt and brewed beverages must be purchased, as well as food items prepared in Applicant's proposed licensed kitchen and other items located at the proposed licensed premises. Applicant provided testimony that patrons would not be permitted to take items from the convenience store and purchase said items at the proposed licensed premises. In view of such arrangements, the clear delineation of these enterprises, and prior approval by the Board of other similar operations, the Board sees no reason to not approve the interior connection between the proposed licensed premises and the unlicensed convenience store. 9 Section 468(e) of the Liquor Code states the Board "may not approve an interior connection that is greater than ten feet wide between a licensed business and another business." [47 P.S. § 4-468(e)]. I° Section 3.54 of the Board's Regulations states that where the Board "has approved the operation of another business which has an inside passage or communication to or with the licensed premises, the extent of the licensed area shall be clearly indicated by a permanent partition at least 4 feet in height." [40 Pa. Code § 3.54]. 104 Licensing's third objection required the Board to take evidence to determine what "take home products" consist of which are intended to be sold in the adjacent unlicensed convenience store. Mr. Campbell testified the unlicensed convenience store will sell take-home food items (items that someone normally could not consume in one (1) sitting), such as loaves of bread, gallons of milk, cheese, bologna, cases of soda, large bags of chips, and large containers of orange juice. Also, Mr. Campbell testified that health and beauty items will be sold in the unlicensed convenience store. There was no evidence that these products will be sold or stored in the proposed licensed premises. The Board sees no issue with the products being sold in the unlicensed convenience store. Licensing's fourth objection required the Board to take evidence to determine what convenience store items Applicant intends to sell on the proposed licensed premises. Mr. Campbell testified that Applicant will not sell convenience store items in the proposed licensed premises, other than tobacco products, gum, and candy. Mr. Campbell testified that Applicant will not display or sell bulk items, such as two (2) liter bottles of soda in the proposed licensed premises. The Board finds that Applicant is not 105 using the proposed licensed premises to operate a convenience store business. Licensing's fifth objection is similar to the second objection and required the Board to take evidence to determine whether it should permit Applicant to operate another business (convenience store items) on the licensed premises, in accordance with section 3.52(c) of the Board's Regulations, which provides that a licensee "may not conduct another business on the licensed premises without Board approval." [40 Pa. Code § 3.52(c)]. As with section 3.52(b), a decision as to whether to approve such other business is left to the Board's discretion. The record shows that Applicant will be making and providing an extensive food selection and a variety of single -serve non-alcoholic beverages for the proposed licensed premises. Also, the record shows that the products at the proposed licensed premises must be paid for at any one (1) of the three (3) cash registers at the proposed licensed premises. Lastly, the record shows that not only will the convenience store's inventory of non-food and bulk food items not be displayed or stored in the proposed licensed restaurant, Applicant's employees will be trained to refuse the purchase of these items at the proposed licensed premises' three (3) cash registers. 106 The Board finds that Applicant is not operating another business on the proposed licensed premises. Licensing's sixth objection required the Board to take evidence to determine if Applicant will allow minors to frequent its licensed premises, in violation of section 493(14) of the Liquor Code. Section 493(14) of the Liquor Code provides that a hotel, restaurant, club, or retail dispenser licensee is in violation of the Code if it allows minors (persons under twenty-one (21) years of age) to frequent the licensed premises. Minors may only frequent licensed premises if: (a) they are accompanied by a parent; (b) they are accompanied by a legal guardian; (c) they are under proper supervision; (d) they are attending a social gathering; or (e) the hotel, restaurant or retail dispenser licensee has gross sales of food and nonalcoholic beverages equal to fifty per centum or more of its combined gross sale of both food and alcoholic beverages. If a minor is frequenting a hotel, restaurant or retail dispenser licensee under subsection (e), then the minor may not sit at the bar section of the premises, nor may any alcoholic beverages be served at the table or booth at which the said minor is seated unless said minor is with a parent, legal guardian or under proper supervision. Further, if a hotel, restaurant, club liquor licensee or retail dispenser is hosting a social gathering under subsection (d), then written notice at least forty-eight hours in advance of such gathering shall be given to the Bureau of Enforcement. If a minor is frequenting licensed premises with proper 107 supervision under subsection (c), each supervisor can supervise up to twenty minors, except for premises located in cities of the first class, where each supervisor can supervise up to five minors. Notwithstanding any other provisions of this section, if the minors are on the premises as part of a school -endorsed function, then each supervisor can supervise fifty minors. Nothing in this clause shall be construed to make it unlawful for minors to frequent public venues or performing arts facilities. [47 P.S. § 4-493(14)]. Section 102 of the Liquor Code defines proper supervision as "Proper supervision" shall mean a person twenty-five (25) years of age or older who is directly responsible for the care and conduct of a minor or minors while on the licensed premises and who keeps the minor or minors within his or her sight or hearing. If the licensee, an employee of a licensee or anyone else paid by the licensee is performing as proper supervisor, then that person may not perform any other employment-related duties; otherwise proper supervision shall consist of unpaid volunteers. [47 P.S. § 1-102]. The requirement set forth in part (e) of section 493(14) is generally referred to as the "Pizza Hut Rule." Ignoring the other issues regarding the interior connections and operation of another business and focusing exclusively on the proposed licensed premises, the Board finds it to be unlikely that Applicant's proposed cafe will violate the Pizza Hut Rule, or any other provision of section 493(14). 108 Minors will be permitted to frequent the proposed licensed premises. Mr. Campbell provided great detail concerning the extent of Applicant's menu and the plans to provide food similar to that of nationally franchised restaurants under one (1) roof, with the resultant estimation that food and non-alcoholic beverage sales will greatly exceed fifty percent (50%) of sales of food and alcoholic beverages. Ali employees in the restaurant portion of the premises will be RAMP -certified and will also receive TIPS training concerning intervention procedures. The seating area will be monitored by video cameras, with Applicant's manager, shift supervisors, and Security Operations Center employees having the ability to view this surveillance real time on -premises and remotely. Log entries of monitoring will be required at fifteen (15) to twenty (20) minute intervals whenever patrons are in this seating area consuming alcoholic beverages. Additionally, the proposed licensed premises' three (3) cashiers will be assigned the duty to monitor the area directly and presumably via video monitors located above the registers, as will the shift supervisor from 10:00 p.m. to 2:00 a.m. Applicant's customer greeter, who is also assigned the maintenance of the soda dispensers, will have this duty as well. 109 Further, two (2) security employees and at least initially, two (2) Loss Investigation Team employees, will be on the premises during hours that alcoholic beverages are sold and will be instructed to monitor the seating areas and parking lot for consumption issues including third party purchases, possession and consumption by minors. Every alcohol sale will require acceptable photo identification that will be scanned at the register before the sale can be completed. Each malt beverage transaction at each register in the restaurant will be monitored by video, which registers are again the only locations where alcoholic beverages can be purchased. Additionally, employees will be trained to inspect patrons' identifications to ensure their validity and to question the customers regarding the biographical information they reference. Third party sales will again be discouraged through apparent vigilant observation of the parking lot by security and group purchase of beer will require each member of the group to produce valid identification. The proposed licensed premises will not have a bar, will not sell liquor or wine, and will not offer amusements that might attract minors. 110 Based on the above, the Board is convinced that despite the likelihood that minors will be present at the proposed licensed premises, Applicant has sufficient safeguards in place and will take every precaution necessary to operate with the rules and regulations set forth by the Board and the legislature with regard to minors. Licensing's seventh objection required the Board to take evidence concerning the sale of liquid fuels or oil at the same location as the proposed licensed premises, which is prohibited under sections 404 and 468 of the Liquor Code [47 P.S. §§ 4-404, 4-468]. Section 404 of the Liquor Code provides in pertinent part: The board shall refuse any application for a new license, the transfer of any license to a new location or the extension of any license to cover an additional area where the sale of liquid fuels or oil is conducted. [47 P.S. § 4-404]. Section 431(b) of the Liquor Code provides in pertinent part: The board shall refuse any application for a new license or the transfer of any license to a location where the sale of liquid fuels or oil is conducted. [47 P.S. § 4-431(b)]. Section 432(d) of the Liquor Code provides in pertinent part: The board shall refuse any application for a new license, the transfer of any license to a location where the sale of liquid 111 fuels or oil is conducted or the extension of an existing license to cover an additional area . [47 P.S. § 4-432(d)]. Section 468(a)(3) of the Liquor Code provides in pertinent part: No license shall be transferred to any place or property upon which is located as a business the sale of liquid fuels and oil. [47 P.S. § 4-468(a)(3)]. Sections 431(b) (malt and brewed beverages manufacturers', distributors', and importing distributors' licenses), 432(d) (malt and brewed beverages retail licenses), 404 (hotel, restaurant, and club liquor licenses), and 468(a)(3) (transfer of licenses) each have language dealing with the prohibition of liquid fuels and oil. Sections 431(b) and 432(d) specify "to a location where the sale of liquid fuels or oil is conducted," and 404 specifies "to a new location . . . where the sale of liquid fuels or oil is conducted." Section 468(a)(3) specifies "to any place or property upon which is located as a business the sale of liquid fuels and oil." Although the terms of "location," "place," and "property" are not defined in the Liquor Code, the Commonwealth Court in Water Street Beverage, Ltd. v. Pennsylvania Liquor Control Bd., 84 A.3d 786 (Pa. Cmwlth. 2014) ), appeal denied, held that the Board's decision to allow 112 an applicant applying for an eating place malt beverage license to have gasoline pumps located off its proposed licensed premises was a valid interpretation of the term "location" in section 432(d) of the Liquor Code because the term "location" is defined in relation to the particular area of the licensed premises. The rules of statutory construction indicate that when words are not defined by a statute, they should be given their common and approved usage. [1 Pa. C.S. § 1903(a)]. As to the terms "place" and "property" as used in section 468(a)(3) of the Liquor Code, one (1) must look at 431(b), 432(d), 404, and 468(a)(3) together. Sections 431(b), 432(d), and 404 address a new license and the transfer of an existing license, whereas section 468(a)(2) only addresses the transfer of a license. Since the terms "place" and "property" are not defined in the Liquor Code, the Board concludes that said terms as used in section 468(a)(3) should be interpreted similar to the term "location" in section 431(b), 432(d), and 404 of the Liquor Code because any other interpretation would lead to an absurd result. The record shows the gasoline pumps will be located approximately eighty (80) feet from Applicant's proposed licensed premises, and between the proposed licensed premises and the gas 113 pumps, there will be a sidewalk, ballards, parking stalls, macadam drive area, and a speed bump. The record provides that Sheetz, Inc. will have an employee located inside the unlicensed convenience store who will be responsible for the proposed gas pumps. Also, the record provides that gasoline may only be purchased at the gas pumps and the employees who are working at Applicant's proposed licensed premises will not have any involvement with the gas pumps. Therefore, the Board finds that liquid fuels will not be sold at the same location as the proposed licensed premises, and as such, there is no violation of sections 404 and 468 of the Liquor Code. Licensing's eighth objection required the Board to take evidence to determine if there are valid reasons for Alvin Oberholtzer, Terry Helm, and Sharon Hershey to file late petitions to intervene and whether they would be directly aggrieved by the Board granting Applicant's transfer application. Section 17.13(b) of the Board's Regulations provides that the Board "may accept an untimely filed protest or petition to intervene, but only upon good cause shown." [40 Pa. Code § 17.13(b)]. The record shows that Mr. Oberholtzer and Ms. Hershey failed to attend and testify at the instant hearing. Therefore, Mr. Oberholtzer 114 and Ms. Hershey would not have standing as intervenors in the instant matter. Mr. Helm did attend and testify at the instant hearing. However, he failed to offer any explanation for his late -filed petition to intervene. Therefore, Mr. Helm would not have standing as an intervenor in the instant matter. Licensing's ninth objection required the Board to take evidence to determine if John Mummau, Lewis Deardorff, Luke and Lois Martin, and James Andrews would be directly aggrieved by the granting of Applicant's application. Section 17.11 of the Board's Regulations provides that when an application is filed for the transfer of a liquor license, a protest may be filed with the Board by any of the following: a licensee whose licensed premises is located within two hundred (200) feet of the proposed licensed premises; a church, hospital, charitable institution, school or public playground located within three hundred (300) feet of the proposed licensed premises; or a resident of the neighborhood within a radius of five hundred (500) feet of the proposed licensed premises. [40 Pa. Code § 17.11(a)]. Only valid protests by the above -listed groups render the protestant a party to the proceeding; otherwise, a petition to intervene must be filed. [40 Pa. Code § 17.11(e)]. 115 A person who can demonstrate a direct interest in such an application, and who can further demonstrate that a Board decision contrary to the person's direct interest will cause the person to be aggrieved, may file a petition to intervene. [40 Pa. Code § 17.12(a)]. A petition to intervene may be granted at the discretion of the Board, which may grant or deny the petition in whole or in part, or authorize limited participation. [40 Pa. Code § 17.12(b)]. A petition to intervene must be filed within thirty (30) days of the posting of the Notice of Application; the Board may only accept an untimely -filed protest or petition to intervene upon good cause shown. [40 Pa. Code § 17.13(b)]. Failure to appear or testify at the scheduled hearing on the matter may remove the reasons for protest or intervention from the Board's consideration. [40 Pa. Code § 17.13(e)]. Finally, if the Board determines that two (2) or more protestants or intervenors have substantially similar interests and positions, the Board may limit the testimony to one (1) or more representatives. [40 Pa. Code § 17.13(f)]. The record shows that Mr. Deardorff and Luke and Lois Martin failed to attend and testify at the instant hearing. Therefore, they would not have standing as intervenors in the instant matter. 116 Mr. Mummau and Mr. Andrews did attend the hearing and testified. Mr. Mummau expressed concerns with Shippensburg University being within blocks of the proposed licensed premises, his sister-in-law and brother-in-law were killed by a seventeen (17) -year- old drunk driver, an incident where an intoxicated college student almost died, his belief that there are already too many licensees, and possibility of more incidents of driving under the influence of alcohol and public drunkenness. Mr. Andrews expressed concerns with regard to minors having access to the proposed licensed premises twenty-four (24) hours a day, the close proximity of the proposed licensed premises to Shippensburg University, individuals' lives being destroyed by impaired drivers, and the proximity of the convenience store. Clearly the evidence offered by Mr. Mummau and Mr. Andrews was speculative in nature. The Board finds that Mr. Andrews and Mr. Mummau failed to provide sufficient non -speculative evidence to show how they would be directly aggrieved by the granting of Applicant's transfer application. Therefore, they do not have standing as intervenors in the instant matter. Licensing's eleventh objection required the Board to take evidence to determine if Malt Beverage Distributors Association, 117 Gabler's Beverage Distributor, Inc., and PKD, Inc. would be directly aggrieved by the granting of this application, which would qualify them as a intervenors in this matter. See In re Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 (1983); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd. ("Ohio Springs 881 A.2d 37 (Pa. Cmwlth. 2005), appeal denied, 586 Pa. 775, 895 A.2d 1264 (2006). When determining the status of intervenors, it is important to keep in mind the following framework. When location is at issue in a license transfer case, as it is herein, certain persons/entities are permitted to file a protest to the application, as long as they do so in a timely manner. [47 P.S. § 4- 404; 40 Pa. Code § 17.11(a)]. Such entities include other licensees within two hundred (200) feet; churches, hospitals, charitable institutions, schools, or public playgrounds within three hundred (300) feet; and residents of the neighborhood with a radius of five hundred (500) feet. [47 P.S. § 4-404; 40 Pa. Code § 17.11(a)]. Only valid protests render the protestant a party to the proceeding. [40 Pa. Code § 17.11(e)]. All other persons/entities that wish to protest the application must file a petition to intervene. [Id.]. 118 A person who can demonstrate a direct interest in a transfer application, and who can further demonstrate that a Board decision contrary to the person's direct interest will cause the person to be aggrieved, may file a petition to intervene. [40 Pa. Code § 17.12(a)]. A petition to intervene may be granted at the discretion of the Board, which may grant or deny the petitions in whole or in part, or authorize limited participation. [40 Pa. Code § 17.12(b)]. A petition to intervene must be filed within thirty (30) days of the posting of the Notice of Application; the Board may only accept an untimely -filed protest or petition to intervene upon good cause shown. [40 Pa. Code § 17.13(b)]. Failure to appear or testify at the scheduled hearing on the matter may remove the reasons for protest or intervention from the Board's consideration. [40 Pa. Code § 17.13(e)]. Finally, if the Board determines that two (2) or more protestants or intervenors have substantially similar interest and positions, the Board may limit the testimony to one (1) or more representatives. [40 Pa. Code § 17.13(f)]. To show direct aggrievement, a petitioner must show that it has a direct and substantial interest in the outcome of the matter and must show a sufficiently close causal relation between the decision and the petitioner's asserted injury to qualify his/her interest as 119 immediate. William Penn Parking Garage, Inc. v. City of Pittsburgh, 464 Pa. 168, 346 A.2d 269 (1975). An interest is considered to be substantial when there is a discernible adverse effect to an interest of the aggrieved person/entity that differs from the abstract interest of the public generally in having others comply with the law. Id. An interest is direct when the aggrieved person/entity can show a causal connection between the alleged harm to his/her/its interest and the matter at hand. Id. An interest is immediate when the causal connection is not too remote. Id. An association, as a representative of its members, may have standing to bring a cause of action even in the absence of injury to itself, but it must allege, and show, that at least one (1) of its members is suffering immediate or threatened injury as a result of the challenged action. Pennsylvania School Boards Ass'n v. Commonwealth Ass'n of School Administrators, Teamsters Local 502, 696 A.2d 859 (Pa. Cmwlth. 1997); see also In re Application of Family Style Restaurant, Inc., 503 Pa. 109, 468 A.2d 1088 (1983); Tacony Civic Ass'n v. Pennsylvania Liquor Control Bd., 668 A.2d 584 (Pa. Cmwlth. 1995). Malt Beverage Distributors Association, Gabler's Beverage Distributor, Inc., and PKD, Inc. all filed timely petitions to intervene in this matter. 120 Stephen Gabler attended the instant hearing and testified on behalf of Gabler's Beverage Distributors, Inc. Mr. Gabler is the owner of Gabler's Beverage Distributors, Inc., which is located four and one- half (41/2) blocks from the proposed licensed premises. Gabler's Beverage Distributors, Inc. has been in operation for twenty-five (25) years. Patrick Diehl attended the instant hearing and testified on behalf of PKD, Inc. Mr. Diehl is the president of PKD, Inc., which is located four (4) blocks from the proposed licensed premises. PKD, Inc. has been in business for nine (9) years. On behalf of their licensed businesses, Mr. Gabler and Mr. Diehl testified that the approval of Applicant's application would cause financial hardship due to an inability to compete. These mutual opinions were based upon the presumed purchasing power of Applicant, which has numerous licensed convenience store operations and pools its purchases in quantity directly from import distributors, subverting the distribution system in Pennsylvania and selling directly to the public at competitive prices without the obligation of charging or collecting sales tax. In addition, both owners expressed concerns regarding Applicant's ability to sell malt or brewed beverages cheaper than 121 distributors, Applicant being able to sell smaller quantities of no more than one hundred ninety-two (192) fluid ounces per transaction, and Applicant being able to sell different varieties of beer within the same six (6) -pack or twelve (12) -pack." These distributor owners also alleged direct aggrievement from unfair competition based upon the proximity of gas pumps and the convenience store operation to the proposed licensed premises, which would provide a one-stop shopping enticement, though acknowledging that their businesses could potentially be configured similarly. However these distributors could not, unless they chose to construct a further adjoining restaurant, sell the variety of prepared food items the Applicant will offer. Mark Tanczos attended the instant hearing and testified on behalf of MBDA. Mr. Tanczos, as MBDA's president, expressed MBDA's opposition to the sale of liquid fuels and alcoholic beverages at a single location, and opined the result in this case would be catastrophic for its members. Mr. Tanczos referenced the Liquor Code's creation of niche markets with the distributors' niche being the sale of beer for off - premises consumption and argued this should be kept intact to protect "The sale of smaller quantities of malt or brewed beverages is a right given to all retail licensees who hold restaurant liquor licenses, not just Applicant. 122 this market. On behalf of the MBDA, he viewed the proposed premises as being a de facto distributor because of Sheetz's exploitation of its out-of-state relationship with manufacturers, particularly concerning seasonal beers. This issue is not new to the Board. In Ohio Springs I, MBDA (among others) filed a petition to intervene in a double transfer application filed by Ohio Springs, Inc., which operates a Sheetz convenience store in Altoona, and wished to add the sale of malt or brewed beverages to its restaurant offerings. The issues raised by MBDA in that application were remarkably similar to those raised in the instant case. The Board initially refused intervenor standing to MBDA on the basis that it failed to show a direct, substantial, and immediate interest or immediate harm to the organization or its members. However, the Commonwealth Court reversed the Board's decision regarding intervention, holding that MBDA should have been granted intervenor status. In doing so, the Court noted: The Court is persuaded that the Board's denial of MBDA's petition in the present case must be classified as an abuse of discretion and an error of law. First, even under the narrowest interpretation of association standing principles, MBDA presented evidence in the form of the testimony of Hogan and Shipula that retail sales of beer by this Sheetz store will be damaging to any nearby D distributorship because the Sheetz will offer many items that the distributor cannot offer, including food for consumption on 123 the premises, gasoline and convenience store items. If beer for takeout is available as well, it will likely be purchased by customers who went there originally for some other purpose, thereby taking sales from distributors. Hogan testified that the results would likely be catastrophic for a nearby D distributor and that there was such a member distributor [nearby]. An association need only allege that one member is suffering immediate or threatened injury. North-Central Pennsylvania Trail Lawyers Ass'n. More generally, however, the Court also agrees that the Board should have exercised its discretion to grant standing to MBDA because of the new and very different nature of the application. As MBDA points out, even in Application of El Rancho Grande, 496 Pa. at 508, 437 A.2d at 1156, the Supreme Court referred to a statement of the United States Supreme Court in Association of Data Processing Serv. Orgs., Inc. v. Camp, 397 U.S. 150, 154, 25 L. Ed. 2d 184, 90 S. Ct. 827 (1970), that where statutes are concerned "the trend is toward enlargement of the class of people who may protest administrative action." In NEC Pennsylvania Racing the applicable regulation permitted consideration of the best interests of horse racing generally, and the Horse Racing Commission concluded there that granting the application was in the best interest of racing. The Court stated that MEC had standing akin to that of the "local community" in Cashdollar v. State Horse Racing Commission, 143 Pa. Cmwlth. 650, 600 A.2d 646 (Pa. Cmwlth. 1991), which had standing to appeal where the statute required consideration of the public interest and the Court held that when an agency was directed in its enabling statute to consider the effect of its decision on a particular class of individuals, then they might have standing to challenge a decision on the ground that the agency did not fulfill it statutory duty. With 400 beer distributor members, MBDA certainly is integrally involved in the regulated distribution of beer and malt beverages generally. The Liquor Code created the D Distributor class and to some extent protects that class. A 124 statewide trade association, such as MBDA, is likely much better suited than any individual distributor to represent the interests of the class when a proposal is made that has the potential to alter dramatically the current balance under applicable statutory provisions. Ohio Springs I, 881 A.2d at 42-43 (footnotes omitted). Similarly, the Commonwealth Court has considered the appropriateness of numerous petitions to intervene by MBDA and certain local distributors in a series of applications filed by Weg ans. In those cases, Wegmans applied for double transfers of restaurant liquor licenses to its Market Cafe restaurants located in its Pennsylvania grocery stores. In most of these cases, MBDA and certain local distributors filed petitions to intervene, on similar reasoning to that presented herein. On the basis of this Court's reasoning in Ohio Springs I, the Board granted these entities standing in situations where the petitions were timely -filed and the entities offered testimony at the hearings to show direct aggrievement, and the Board's decisions on intervention were affirmed by this Honorable Court. See Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 965 A.2d 1254 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 965 A.2d 1269 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. 125 Pennsylvania Liquor Control Bd., 966 A.2d 1165 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 966 A.2d 1172 (Pa. CmwIth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010); Malt Beverage Distributors Ass'n v. Pennsylvania Liquor Control Bd., 966 A.2d 1180 (Pa. Cmwlth. 2009), aff'd, 607 Pa. 560, 8 A.3d 885 (2010). Given the Supreme Court's reversal of the Board's decision denying standing to MBDA in Ohio Springs I, this Court's affirmance of the Board's decisions to grant standing to MBDA and/or certain local distributors in the Wegmans cases and most recently in Water Street Beverage, Ltd. v. Pennsylvania Liquor Control Bd., 84 A.3d 786 (Pa. Cmwlth. 2014), and given the similar nature of the issues raised in those cases with what has been raised by Malt Beverage Distributors Association, Gabler's Beverage Distributor, Inc., and PKD, Inc. in the instant case, the Board finds that each would have standing as an intervenor in the instant matter. Licensing's thirteenth objection deals with the timely protest of Jaye Alleman. Mr. Alleman attended the hearing and provided testimony that he lives within five hundred (500) feet of the proposed licensed premises. Therefore, Mr. Alleman has protestant status in the 126 instant matter due to his timely -filed protest and appearance at the instant hearing. Finally, Licensing's twelfth objection required the Board to take evidence to determine that the approval of this application will not adversely affect the health, welfare, peace and morals of the neighborhood within a radius of five hundred (500) feet of the proposed licensed premises. In the case of any new license or the transfer of any license to a new location, the Board may, in its discretion, grant or refuse such new license or transfer if such a place proposed to be licensed is within three hundred (300) feet of any church, hospital, charitable institution, school, or public playground or if such new license or transfer is applied for a place which is within two hundred (200) feet of any other premises which is licensed by the Board. [47 P.S. § 4.404]. In this case, one (1) restrictive institution is located within three hundred (300) feet; no other licensees are in this area. Further, the Board shall refuse any application for a transfer of any license to a new location if, in the Board's opinion, such new license or transfer would be detrimental to the welfare, health, peace and morals of the neighborhood within a radius of five hundred (500) 127 feet of the place proposed to be licensed. [Id.] However, the Board must consider refusing a transfer only where the nature of the neighborhood and the nature of the proposed licensed premises are such that approval of the license would be detrimental. K & K Enterprises, Inc. v. Pennsylvania Liquor Control Bd., 145 Pa. CmwIth. 118, 602 A.2d 476 (1992). A perceived threat to a neighborhood is not sufficient cause for the Board to deny a transfer application. Arrington v. Pennsylvania Liquor Control Bd., 667 A.2d 439 (Pa. Cmwlth. 1995). Licensing's supervisor, Mr. Lamark, estimated Applicant's surrounding neighborhood to be sixty percent (60%) residential and forty percent (40%) commercial. The building in which the proposed licensed premises will be located will have three (3) outdoor seating areas, where the consumption of alcoholic beverages will be forbidden. As discussed above, Applicant's operation at the new Sheetz facility will have eight (8) or more Sheetz employees working at any given time, will have three (3) serving areas, seven (7) storage areas, two (2) kitchens, and an office where additional video monitors will be located. Access to the proposed licensed premises can be gained by 128 one (1) exterior door available to the public located off a vestibule which will also contain an entrance to a convenience store. Sixty-four (64) video cameras connected to ninety (90) -day DVRs will surveil the interior and exterior of the entire location, including the self-service walk-in beer cooler. The DVR system is tied in with panic button pendants apparently presently worn by employees who deal with customers or patrol outside and which will be placed at the restaurant's three (3) registers. When depressed, these pendants alert Sheetz's Security Operations Center in Altoona ("SOC"), which can then communicate with the summoning employee, contact the police and/or control the surveillance cameras to zoom in and preserve the recording. In that regard the SOC is notified of all alcohol sale refusals, which are logged with the involved party being photographed. Chief Scott indicated the Sheetz premises is a late-night catchall for the community after the Borough's licensed establishments have closed, and the security is currently ineffective and insufficient. The Chief expressed his concern that licensing this Sheetz location could worsen an already volatile late-night situation where presently one (1) of the Borough's three (3) third shift police officers is stationed every Thursday, Friday, and Saturday night as a deterrent. Chief Scott 129 related, however, that the Sheetz video system is good and that most of the time he is provided with recordings upon request. It appears that Applicant is going to work with Chief Scott to address his concerns with security at the Sheetz premises. Also, Applicant is going to have security monitor the inside and outside of the premises, and this security will work with SOC and the Sheetz's Loss Investigation Team members. Applicant will' have numerous precautions to prevent sales to minors, as discussed concerning objection 6 above, as well as the visibly intoxicated. Applicant is planning on having the appropriate staffing available and has purchased sophisticated kitchen equipment to help alleviate the wait times for prepared foods. Applicant will frequently monitor its interior seating area, where on -premises consumption will solely be permitted, by both employees and the SOC. Many of the concerns of the Civic Club and nearby resident Mr. Alleman regarding littering should be addressed by Applicant contacting the Borough to see if the Borough's trash receptacle can be emptied more often so it does not overflow. There was no evidence presented that Applicant is not a financially responsible entity or that any of its officers have criminal 130 records. Therefore, the Board finds that the approval of this application would not adversely affect the health, welfare, peace, and morals of the neighborhood within five hundred (500) feet. 131 CONCLUSIONS OF LAW 1. Applicant received the requisite notice of Licensing's objections to its application and of the date, time, and place of the hearing regarding the application. 2. The proposed licensed premises will be located within three hundred (300) feet of the Civic Club of Shippensburg, a charitable institution. 3. Applicant's interior connection to the unlicensed grocery store is approved, in accordance with section 3.52(b) of the Board's Regulations. 4. Bulk food, large size non-alcoholic beverages, and non-food items such as, health and beauty aids, will be sold as take-home products in the unlicensed convenience store. 5. Applicant will not sell convenience store items on the licensed premises other than tobacco and single serve candy. 6. Applicant will not be operating another business on the proposed licensed premises. 7. If operated as proposed, Applicant has safeguards in place to not allow minors to frequent its proposed licensed premises, in violation of section 493(14) of the Liquor Code. 132 8. Liquid fuels will not be sold at the location of the proposed licensed premises, in violation of sections 404 and 468 of the Liquor Code. 9. Terry Helm failed to provide sufficient good for his late -filed petition to intervene and he is not granted intervenor status in the instant matter. 10. Alvin Oberholtzer, Sharon Hershey, Lewis Deardorff, and Luke and Lois Martin failed to appear for hearing and they are not granted intervenor status in the instant matter. 11. John Mummau failed to provide sufficient non -speculative evidence on how he would be directly aggrieved by the approval of Applicant's transfer application. 12. James Andrews failed to provide sufficient non -speculative evidence on how he would be directly aggrieved by the approval of Applicant's transfer application. 13. The Civic Club of Shippensburg has standing as a protestant in the instant matter because it is a charitable institution that is located within three hundred (300) feet of the proposed licensed premises. 133 14. Gabler's Beverage Distributor, Inc., PKD, Inc., and Malt Beverage Distributors Association are each granted intervenor status in this matter. 15. Jaye Alleman has standing as an intervenor in the instant matter because he resides within five hundred (500) feet of the proposed licensed premises. 16. The approval of this application will not adversely affect the health, welfare, peace, and morals of the neighborhood within a radius of five hundred (500) feet of the proposed licensed premises. 17. The application for the intermunicipal double transfer of Restaurant Liquor License No. 19377 is granted prior approval by the Board. PENNSYLAN RCNTR9L BOARD 134 oafd 'Secretary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIC CLUB OF SHIPPENSBURG ) CIVIL DIVISION (OHIO SPRINGS, INC. T/A SHEETZ, ) t= Applicant) ) STATUTORY APPEAL , :/ Petitioner ) C) -� 1--,-1 ) -0-_,7 N c41 F,,-. vs. ) CASE NO. 14-4647 r`cn; -;z:. D`' , c: PENNSYLVANIA LIQUOR CONTROL ) -4..„..• ---'' BOARD ) �� - o 7 n Respondent. ) - �.•" y,l J / J .-.4rr .moi �4^ ANSWER TO PETITION FOR APPEAL FROM DECISION OF PENNSYLVANIA LIQUOR CONTROL BOARD NOW COMES Pennsylvania Liquor Control Board ("PLCB"), Respondent by and through its Counsel, Rodrigo J. Diaz, Esquire and hereby files this Answer to Petition for Appeal from the decision of the PLCB and in support thereof, and avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of further answer, the Board's decision in this matter was also appealed to the Commonwealth Court of Pennsylvania by the Malt Beverage Distributors Association, Gabler's Beverage Distribution, Inc. and PKD, Inc. That appeal can be found at number 1352 CD 2014. Respondent, Board, as filed an application with the Commonwealth Court to consolidate both appeals. That application remains pending. 5. Paragraph five (5) states a conclusion of law for which no further response is necessary. If a further response is necessary, the averment is denied. By way of further answer the Commonwealth Court recently rejected the argument that Section 464 of the Liquor Code requires the Board to include the reasons for its decision when it issues an initial Order on an application. See Arena Bev. Corp. v. Pa. Liquor Control Bd., Pa. Comm. LEXIS 389 (Pa. Commw. July 30, 2014). 6. necessary. 7. response is Paragraph six (6) states a conclusion of law for which no further response is If a further response is deemed necessary, the averment is denied. Paragraph seven (7) states a conclusion of law for which no further necessary. 8. Paragraph eight (8) states a conclusion of law for which no further response is necessary. If a further response is deemed necessary, the averment is denied. 9. Paragraph nine (9) states a conclusion of law for which no further response is necessary. If a further response is deemed necessary, the averment is denied. 10. Paragraph ten (10) is a conclusion of law for which no further response is necessary. WHEREFORE, Respondent asks this Honorable Court to affirm the Board's Order in this matter and approve the transfer of Pennsylvania Restaurant Liquor License No. R-19377 to Ohio Springs, Inc. September 16, 2014 Respectfully submitted, RODRIGOIAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIC CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. ) CIVIL DIVISION ) ) ) ) ) ) ) ) ) STATUTORY APPEAL CASE NO. 14-4647 CERTIFICATE OF SERVICE I hereby certify that I am on this date serving a copy of the foregoing Answer to Petition for Appeal from Decision of Pennsylvania Liquor Control Board via U.S. Regular mail to the following persons: Charles L. Caputo, Esquire Caputo, Caputo & Regan, P.C. 204 Fifth Avenue, 5th Floor Pittsburgh, PA 15222 Mark F. Flaherty, Esquire Flaherty & O'Hara, P.C. Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15222 September 16, 2014 Stanley J. Wolowski, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Mark E. Kozar, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Respectfully submitted, RODRIGO J. DIAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. CIVIL DIVISION STATUTORY APPEAL CASE NO. 14-4647 MOTION FOR CONTINUANCE NOW COMES the Pennsylvania Liquor Control Board ("Board"), Respondent by and through its Counsel, Rodrigo J. Diaz, Esquire and hereby files this Motion for Continuance and in support thereof, and avers as follows: 1 Movant, Board, is the respondent in the above -referenced matter. 2. On or about August 5, 2014 the Civic Club of Shippensburg ("Petitioner") filed an appeal from the Board's decision of July 17, 2014, in which the Board had approved the transfer of Restaurant Liquor License R-19377 to Ohio Springs, Inc. ("Sheetz") for use by it at 359 East King Street, Shippensburg, Pennsylvania 17257-1424. 3. On August 6, 2014 the Malt Beverage Distributors Association, Gabler's Beverage Distributor, Inc. and PKD, Inc. (hereinafter "MBDA") filed a Petition for Review with the Commonwealth Court from the aforementioned decision by the Board. That Petition is docketed at No. 1352 CD 2014. 4. On September 5, 2014 the Board filed an Application for Consolidation of appeals with the Commonwealth Court. A copy of that application (without exhibits) is attached as Exhibit A. The Board did so to prevent the possibility that it would be presented with two orders from two separate courts which are contrary to each other. See Player's Bench, Inc. vs. Pennsylvania Liquor Control Board, 751 A.2d 1221 (Pa. Cmwlth. 2000). 5. Commonwealth Court, by order dated September 8, 2014, directed that all responses to the Application for Consolidation be filed and served by September 15, 2014. A copy of that Order is attached as Exhibit B. 6. In its answer opposing the Application for Consolidation the MBDA noted that a hearing before this Honorable Court in the instant matter was scheduled for September 24, 2014. 7. This was the first time the Board was put on notice that a hearing was scheduled in this matter before this Honorable Court. 8. The Office of Chief Counsel contacted the Prothonotary's Office which indicated that a copy of the Order which had scheduled the hearing had not been provided to the Board because copies of the Order and the envelopes to mail the Order required by local rule 208.3 (a) (6) had not been provided to that office. 9. The Commonwealth Court has not yet ruled on the Motion for Consolidation. 10. The hearing in this matter should be continued until the Commonwealth Court has ruled on the Application for Consolidation for the following reasons: 2 a. If the Commonwealth Court directs that the instant matter be transferred to it, then this Honorable Court will no longer have jurisdiction in this matter and there will be no need for a hearing. b. If the Commonwealth Court transfers No. 1352 CD 2014, to this Honorable Court, then the MBDA will become parties to this proceeding and would therefore be entitled to participate in the hearing on this matter. 11. Counsel for the Intervener, Ohio Springs, Inc. has been contacted and they are in support of this Motion for Continuance. Counsel for the Civic Club of Shippensburg has also been contacted and he would support a thirty (30) day continuance, but not a general continuance. WHEREFORE, respondent asks this Honorable Court to continue this matter until the Commonwealth Court has ruled on the Motion to Consolidate the instant matter with the matter pending before Commonwealth Court, after which the hearing could be rescheduled, by motion of any party, if necessary. September 17, 2014 Respectfully submitted, RODRIGO J. DIAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner vs. PENNSYLVANIA LIQUOR CONI ROL BOARD Respondent. CIVIL DIVISION STATUTORY APPEAL CASE NO. 14-4647 CERTIFICATE OF SERVICE I hereby certify that I am on this date serving a copy of the foregoing Motion for Continuance and Proposed Order via UPS Overnight delivery to the following persons: Charles L. Caputo, Esquire Caputo, Caputo & Regan, P.C. 204 Fifth Avenue, 5th Floor Pittsburgh, PA 15222 Mark F. Flaherty, Esquire Flaherty & O'Hara, P.C. Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15222 September 17, 2014 Stanley J. Wolowski, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Mark E. Kozar, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Respectfully submitted, RODRIGO J. DIAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 Exhibit A IN THE COMMONWEALTH COURT OF PENNSYLVANIA Malt Beverage Distributors Association, Gabler's Beverage Distributor, Inc. and PKD, Inc., Petitioners No. 1352 C.D. 2014 v. Pennsylvania Liquor Control Board, Respondent APPLICATION FOR CONSOLIDATION OF APPEALS PURSUANT TO PA.R.A.P. 513 Pennsylvania Liquor Control Board, Respondent in Case No. 1352 C.D. 2014, which is currently pending before this Honorable Court, and Respondent in Case No. 14-4647, which is currently pending before the Court of Common Pleas of Cumberland County, requests this Honorable Court to consolidate the appeals in this matter for the following reasons: 1. The Petition for Review at 1352 CD 2014 is before this Honorable Court. It is a Petition for Review, subsequently amended,' filed by Malt Beverage Distributors Association, Gabler's Beverage Distributor, Inc. and PKD, Inc. (hereinafter "Petitioners") from the Board's decision of July 17, 2014 which had approved the transfer of Restaurant Liquor License No. R-19377 to The Amended Petition corrected the proper name for one of the Petitioners. Ohio Springs Inc. for use at premises located at 359 East King Street, Shippensburg, Pennsylvania 15257. 2. In the matter captioned Civil (sic) Club of Shippensburg (Ohio Springs Inc. trading as Sheetz, Applicant) vs. Pennsylvania Liquor Control Board, Case No. 14-4647, the Civic Club of Shippensburg filed an appeal in the Court of Common Pleas of Cumberland County from the Board decision of July 17, 2014 which had approved the transfer of Restaurant Liquor License No. R- 19377 to Ohio Springs Inc. ("Sheetz"). 3. The Amended Petition for Review and appeal raise the identical issue for judicial review, to wit, whether the approval of Sheetz's application violates section 468 of the Liquor Code. A copy of the Amended Petition for Review is attached as Exhibit A. A copy of the appeal is attached as Exhibit B. 4. This Honorable Court has previously held when there is more than one appeal in more than one court of a decision by the Board regarding a particular liquor license, those matters must be consolidated to avoid absurd and conflicting results. See Player's Bench, Inc. vs. Pennsylvania Liquor 2 Control Board, 751 A.2d 1221 (Pa. Cmwlth. 2000). See Also Nilo, Inc. vs. Pennsylvania Liquor Control Board, 805 A.2d 698 (Pa. Cmwlth. 2002), affirmed by equally divided Court, Nilo, Inc. vs. Pennsylvania Liquor Control Board, 580 Pa. 336, 861 A.2d 248 (2004) (holding that when five applicants vie for two licenses, the five applications must be consolidated into a single matter). 5. Consolidation of these two matters is necessary because not doing so could result in contrary decisions on whether the Respondent should issue the license in question to Sheetz. 6. Charles Caputo, Esquire, who filed the appeal in Case No. 14-4647 on behalf of the Civic Club of Shippensburg, and is one of the attorneys for the Petitioner in No. 1352 C.D. 2014, was contacted by undersigned last week and indicated that, notwithstanding the above, he would not be filing anything to have the matters consolidated. 7. While the end result in Player's Bench was that this Honorable Court remanded the matter to the Court of Common Pleas, Respondent believes that this matter should be consolidated in this Court for the following reasons: a. This Honorable Court has already granted Petitioners' Motion to Expedite this matter and consolidating these cases in Commonwealth Court would be consistent with that Order. b. While the Civic Club of Shippensburg would be entitled to an additional evidentiary hearing before the Court of Common Pleas, the only issue it is pursing in its appeal is whether Sheetz is precluded from acquiring the license because it sells liquid fuels in close proximity to the licensed premises. As to that issue, the facts are not in dispute and an evidentiary record was already made at the administrative hearing. There is therefore no need for an additional hearing. c. The question at issue is solely a legal one and one which this Honorable Court has recently addressed. See WaterStreet Bev., LTD vs Pa. Liquor Control Bd. 84 A.3d 786 (Pa. Cmwlth. 2014), Appeal denied, Water St. Bev. L 1ll vs Pa. Liquor Control Bd., 2014 Pal Lexis 2042 (Pa. Aug. 12, 2014). Since the Court of Common Pleas 4 cannot overrule that decision it would be in the interest of judicial economy for this Honorable Court to address these matters. See Irem Temple AAONMS v. Pa. Liquor Control Board, 87 A.3d 983 (Pa. Cmwlth. 2014) (In which this Honorable Court consolidated five appeals involving the same location into a single matter for purposes of judicial economy). 8. In that Rule 513 of the Rules of Appellant Procedure contemplates consolidation of appeals through agreement of the parties, undersigned has contacted counsel for the parties included. Stanley J. Wolowski, Esquire, has indicated on behalf of Ohio Springs, Inc. that he concurs with this Application. Joshua John Voss, Esquire, on behalf of Petitioners, has indicated that he does nat concur with this Application. Charles L. Caputo, Esquire, who represents the Civic Club of Shippensburg and is also listed as counsel for Petitioners has indicated that he does not concur with this Application. Wherefore, Pennsylvania Liquor Control Board requests this Honorable Court to consolidate these two (2) matters by directing the Court of Common Pleas of Cumberland County to transfer Case No. 14-4647 to this Honorable Court. In the 5 alternative, the Pennsylvania Liquor Control Board requests this Honorable Court to remand Case No. 1352 C.D. 2014 to the Court of Common Pleas of Cumberland County for consolidation with Case No. 14-4647. Respectfully submitted, RODRIG EXECUTIVE DEPUTY CHIEF COUNSEL Attorney ID No. 62259 FAITH S. DIEHL CHIEF COUNSEL PENNSYLVANIA LIQUOR CONTROL BOARD Office of Chief Counsel 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 Fax: (717) 787-8820 6 Exhibit B SEP/08/2014/M0N 12:56 PM FAX No. IN THB. COMMONWEALTH COURT OF PENNSYLV1A Malt Beverage Distributors Association, Gabler's Beverage Distributor, Inc. and Plc.D, Inc., Petitioners v. Pennsylvania Liquor Control Board, Respondent No. 1352 C.D. 2014 ORDER P. 002/002 NOW, September 8, 2014, any response to the Application. for Consolidation of Appeals pursuant to Pa.R.A.P. 513 filed by the Pennsylvania Liquor Control Board shall be filed and served on or before September 15, 2014. Dan Pellegrini, Preside . udge Miffed tom the Record SEP 2014 and Order Exit Pennsylvania LIQUOR CONTROL BOARD September 17, 2014 David D. Buell Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 VIA UPS OVERNIGHT RE: Civil Club of Shippensburg (Ohio Springs, Inc., t/a Sheetz) v. Pennsylvania Liquor Control Board Docket No. 14-4647 License No. R-19377/LID 67077 Dear Mr. Buell: I am enclosing an original and two (2) copies of the Motion for Continuance and Proposed Order filed by Respondent, Pennsylvania Liquor Control Board, in the above - referenced matter. I am also enclosing additional copies of the Proposed Order and stamped envelopes as required by Rule 208.3(a)(6). Please file the original of record and kindly return a date stamped copy in the self- addressed stamped envelope provided. Thank you in advance for your assistance regarding this matter. If you have any questions with respect to the foregoing, please contact me at (717) 783-9454. Very truly yours, RODRIGO JeDIAZ EXECUTIVE DEPUTY CHIEF COUNSEL Enclosure cc: Charles L. Caputo, Esq. (w/enclosures via UPS Overnight ) Mark F. Flaherty, Esq. (w/enclosures via UPS Overnight ) Stanley J. Wolowski, Esq. (w/enclosures via UPS Overnight ) Mark E. Kozar, Esq. (w/enclosures via UPS Overnight ) Chief Counsel 401 Northwest Office Building 1 Harrisburg, PA 17124 1 717.783.9454 1 F 717.787.8820 1 Icb.state.pa.us PLCB-1039 08/14 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. CIVIL DIVISION STATUTORY CASE NO. 14- APPEAcl,C. 4647 PRAECIPE TO WITHDRAW MOTION FOR CONTINUANCE Please withdraw the Motion for Continuance previously filed by the Pennsylvania Liquor Control Board. September 18, 2014 Respectfully submitted, RODRIGO J. DIAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 CIVIC CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, applicant) Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : Case No: 14-4647 CIVIL PENNSYLVANIA LIQUOR CONTROL : BOARD, Respondent. IN RE: PETITIONERS MOTION FOR CONTINUANCE ORDER AND NOW, this 23rd day of September, 2014, the within Motion for Continuance is DENIED with the understanding that, at the hearing, the Court will entertain a request by the Petitioner to keep the record open for the purpose of adducing the remaining testimony which it regards as essential. ✓Rodrigo J. Diaz, Esquire Counsel for Respondent BY THE COURT, .1Glark Flaherty, Esquire -Stanley Wolowski, Esquire ,IVIark E. Kozar, Esquire •e`ounsel for Applicant r rri • cc �Cliarles L. Caputo, Esquire Counsel for Petitioner "." CD :rim >E- ..,:... e op I ,�I1 ) f g/cbliy • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIC CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner, vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. CIVIL DIVISION STATUTORY APPEAL CASE NO. 14-4647 MOTION FOR CONTINUANCE c: AND, NOW, comes the Petitioner, CIVIC CLUB OF SHIPPENSBURG, by and through its counsel Charles L. Caputo, Esq. of Caputo, Caputo & Regan, P.C., and presents the within Motion for Continuance and, in support thereof, avers as follows: 1. On or about August 5, 2014 the Civic Club of Shippensburg ("Petitioner") filed an appeal from the July 17, 2014 decision of the Pennsylvania Liquor Control Board (the "Board"), which approved a liquor license to Ohio Springs, Inc. ("Sheetz") for use at premises located at 359 E. King Street, Shippensburg, PA 17257-1424 (the "Premises"). 2. In response to the aforesaid filing, and by Order dated August 12, 2014, this Honorable Court scheduled a hearing for September 24, 2014, at 10:30 a.m. in front of the Honorable Judge Hess. 3. By Order dated August 13, 2014, this Court granted intervenor status to Sheetz. 1 4. On September 17, 2014, the Board filed a Motion for Continuance in this matter asking the Court to continue the matter generally pending the Commonwealth Court's decision on a petition for consolidation filed by the Board in the Commonwealth Court. 5. Both Sheetz and the Civic Club consented to the Board's request for a continuance in this matter. 6. On September 18, 2014, the Board notified counsel for the Civic Club that it was withdrawing its request for a continuance because the Commonwealth Court denied its petition for consolidation. 7. A witnesses planning to appear and testify in support of the Civic Club is unable to attend the hearing scheduled for September 24, 2014. We view this witness as essential to our case. 8. Counsel for the Board has been contacted and would not oppose a continuance, but would ask that the hearing be rescheduled as soon as possible. Counsel for Sheetz has been contacted and will not consent to the continuance. 9. This is Petitioner's first request for a continuance in this matter. Petitioner apologizes for the tardiness of this request, but we have been diligently attempting to get our witnesses and evidence in order after having previously consented to a continuance in this case. The Petitioner respectfully suggests that a short continuance of this hearing will not prejudice any party. 10. Petitioner requests that the hearing not be rescheduled between October 10 and October 20, 2014 as the President of the Civic Club will be out of town during these dates. 2 WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter an Order in the form attached hereto continuing the hearing scheduled for September 24, 2014, to the next available date after October 1, 2014. Dated: September 23, 2014 By: Charles L. Caputo, Esquire Pa. I.D. No. 86058 Respectfully submitted, Caputo, Caputo & Regan, P.C. Buhl Building, 5th Floor 204 Fifth Avenue Pittsburgh, PA 15222 Tel: 412.325.0693 Fax:412.690.2350 Counsel for Civic Club of Shippensburg 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Motion for Continuance was served upon the parties listed below by facsimile and overnight mail, on this 23`d day of September, 2014. Rodrigo J. Diaz, Esquire Pennsylvania Liquor Control Board Office of Chief Counsel 401 Northwest Office Building Capital and Forster Streets Harrisburg, PA 17124-0001 Mark Flaherty, Esquire Stanley Wolowski, Esquire Mark E. Kozar, Esquire FLAHERTY & O'HARA, PC 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 5 By: Charles L. .puto, Esquire Counsel for Petitioner Civic Club of Shippensburg 'FILED:OFFICE OF THE PROTHOH01t, : 2Diti SEP 29 10: j IN THE COURT;�,;'Al-110F" 'S(OF CUMBERLAND COUNTY "PE M,VANIA CIVIC CLUB OF SHIPPENSBURG ) CIVIL DIVISION ) STATUTORY APPEAL Petitioner/Protestant, ) ) CASE NO. 14-4647 ) v. ) MOTION TO VACATE AUTOMATIC SUPERSEDEAS ) ) Filed on behalf of ) Intervenor, PENNSYLVANIA LIQUOR CONTROL BOARD) Ohio Springs, Inc. t/a ) Sheetz Respondent, ) ) Counsel of Record for this ) ) ) Mark F. Flaherty, Esq. ) Pa. I.D. #46596 v. ) ) Stanley J. Wolowski, Esq. ) Pa. I.D. # 32978 ) ) ) Pa. I.D. No. 78541 Intervenor ) ) ) Flaherty & O'Hara, P.C. ) 610 Smithfield Street ) Suite 300 ) Pittsburgh, PA 15212 ) 412-456-2001 Party OHIO SPRINGS, INC. T/A SHEETZ (F1107790.1) Mark E. Kozar, Esq. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIC CLUB OF SHIPPENSBURG Petitioner/Protestant, CASE NO. 14-4647 v. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent, v. OHIO SPRINGS, INC. T/A SHEETZ Intervenor. MOTION TO VACATE AUTOMATIC SUPERSEDEAS AND NOW, comes Intervenor OHIO SPRINGS, INC. t/a SHEETZ ("Sheetz"), pursuant to Local Rule 208 by and through its counsel, Mark F. Flaherty, Stanley J. Wolowski, and Mark E. Kozar, and respectfully requests this Court vacate the automatic supersedeas that arose as a result of an appeal filed by the Civic Club of Shippensburg ("Club") at the above referenced case number. In the support of this motion Sheetz states the following: Procedural History 1. This matter arose when Sheetz applied to the Borough of Shippensburg for the intermunicipal transfer of a restaurant liquor license to its new (F1107790.1) facility that it was building in Shippensburg; Sheetz would sell beer, primarily for take-out, as a convenience for its customers and as a complement to its extensive made-to-order food offerings. Sheetz would not sell wine or distilled spirits. 2. On July 17, 2012 the Borough of Shippensburg approved the inter- municipal transfer of Restaurant Liquor License No. R-19377 into Shippensburg Borough after an advertised public hearing in which testimony was heard for and against the transfer including from the Borough's Chief of Police. 3. On July 17, 2012 the Borough Council of Shippensburg adopted Resolution No. 12-015 approving said transfer into Shippensburg Borough. In that resolution the Borough Council specifically stated the liquor license transfer would not be detrimental to the welfare, health, peace, and morals of the Borough of Shippensburg or its inhabitants. 4. After receiving Borough approval, Sheetz, on July 27, 2012, filed for the transfer of the liquor license with the Pennsylvania Liquor Control Board ("Board") thereafter the Club filed a protest to the transfer. 5. On January 29, 2014 the Commonwealth Court in Water Street Beverage, LTD. v. Pennsylvania Liquor Control Bd., held that the term "location" as used in Sections 432 and 436 of the Liquor Code referred to the particular area of the licensed premise. 84 A.3d 786, 796-97 (Pa. Commw. Ct. 2014). {F1107790.1} 2 6. In addition, the Commonwealth Court did not address Water Street's arguments relating to Section 468(a)(3) of the Liquor Code because Water Street had waived such argument by failing to make specific references to Section 468(a)(3) in its petition to intervene. Water Street, 84 A.3d at 794. 7. Thereafter, on February 20, 2014, Water Street filed a Petition for Allowance of Appeal with the Pennsylvania Supreme Court asking the Court to review the decision of the Commonwealth Court. 8. On March 13, 2014 the Malt Beverage Distributor's Association ("MBDA") and the intervening beer distributors in this Sheetz case filed an Application for Extraordinary Relief with the Pennsylvania Supreme Court. 9. Therein the MBDA and intervening beer distributors urged the Supreme Court to exercise its King's Bench power and take the Sheetz case out of the Board's hands and to determine the meaning of location, place, and property. 10. On March 18, 2014 and March 19, 2014 the Board held hearings regarding the double inter -municipal transfer of Restaurant License R- 19377 to Sheetz at 359 East King Street, Shippensburg, PA 17257. At this hearing both Sheetz and the Club, along with other protestants presented testimony and evidence on behalf of their positions. (F1107790.1) 3 11. On May 21, 2014 the Supreme Court denied the MBDA's Application for Extraordinary Relief in this matter. 12. On July 17, 2014 the Board approved a double inter -municipal transfer of Restaurant License R-19377 to Sheetz at 359 East King Street, Shippensburg, PA 17257, notwithstanding the Club's protests and testimony. 13. On August 5, 2014 the Club filed an appeal from the decision of the Board to this Court, pursuant to Section 464 of the Liquor Code. 47 P.S. § 4-464. 14. On August 6, 2014 the MBDA and beer distributor intervenors filed a Petition for Review in the Commonwealth Court arguing that the terms "location," "place," and "property" contained in sections 404 and 468(a)(3) prohibit the Board from approving this transfer of a liquor license to Sheetz at the Shippensburg location. The Commonwealth Court on September 18, 2014 stayed that petition for review pending the decision of this Court. 15. On August 12, 2014, the Supreme Court denied Water Street's Petition for Allowance of Appeal letting stand the Commonwealth Court decision. See attached Supreme Court Order. The Automatic Supersedeas Should be Vacated (F 1107790.1) 4 16. Under Section 464 of the Liquor Code the appeal filed by the Club acts as an automatic supersedeas. Section 464 provides that "said appeal shall act as a supersedeas unless upon sufficient cause shown the court shall determine otherwise." 47 P.S. § 4-464. This automatic supersedeas has the effect of denying Sheetz the right to serve alcohol pursuant to the license approved by the Board until the pending appeal has been decided. 17. The party who seeks to vacate an automatic supersedeas has the burden of proving that it will be irreparably harmed if the automatic supersedeas is not vacated. Elizabeth Forward Sch. Dist. v. Pennsylvania Labor Relations Bd., 149 Pa. Cmwlth. 235, 241, 613 A.2d 68, 70 (1992). 18. The Commonwealth Court explained that to prevail on a motion to vacate an automatic supersedeas, the petitioner must establish (1) that he is likely to prevail on the merits; (2) that without the requested relief he will suffer irreparable injury; and (3) that the removal of the automatic supersedeas will not substantially harm other interested parties or adversely affect the public interest. Rickert v. Latimore Twp., 960 A.2d 912, 923 (Pa. Cmwlth. 2008) (citing Solano v. Pennsylvania Bd. of Prob. & Parole, 884 A.2d 943, 944 (Pa. Cmwlth. 2005)). 19. The Liquor Control Board and Sheetz are likely to prevail on the merits for the following reasons: a. The Board has interpreted place, property, and location to mean the licensed premises. The Board's interpretation of the Liquor Code is {F1107790.1 } 5 entitled to deference unless clearly erroneous. St. Rd. Bar & Grille, Inc. v. Pennsylvania Control Bd., 583 Pa. 72, 84, 876 A.2d 246, 353 (2005). The Board's interpretation in this matter has been upheld by the Commonwealth Court in Water Street Beverage, Ltd. v. Pennsylvania Liquor Control Bd., 84 A.3d 786 (Pa. Cmwlth. 2014), petition for allowance of appeal denied, No. 104 MAL 2014, 2014 WL 3931117 (Pa. 2014). b. Contrary to Petitioner's assertion, there is no legislative history with regard to Sections 404 and 468(a)(3) of the Liquor Code. Petitioner has not cited to or referred to any legislative comments or debate regarding the purpose of these provisions when they were enacted or amended. Furthermore, Petitioner's argument that the General Assembly intended the liquid fuel prohibition in the Liquor Code to be interpreted very broadly was rejected in the Commonwealth Court's Water Street decision and implicitly rejected by the Supreme Court when it denied to take the case. c. If the Pennsylvania Supreme Court had disagreed with the Board's interpretation of "location" as affirmed by the Commonwealth Court in Water Street, it would have granted the MBDA's Petition for Allowance of Appeal. Moreover, the Supreme Court denied the MBDA's Application for Extraordinary Relief in this case, wherein the MBDA requested the Supreme Court to take the case away from {F1107790 1 } 6 the Board and to interpret the terms location, place, and property. The Supreme Court in denying the Petition for Allowance of Appeal and the Application for Extraordinary Relief has left the Commonwealth Court's decision in Water Street as precedent. Water Street Beverage, Ltd. v. Pennsylvania Liquor Control Bd., 84 A.3d 786 (Pa. Cmwlth. 2014), appeal denied, No. 104 MAL 2014, 2014 WL 3931117 (Pa. Aug. 12, 2014). d. Sections 404 and 468(a)(3) refer to the same concept of the transfer of a liquor license to a proposed licensed premises in proximity to gas pumps. Also, under Section 404, the legislature effectively defines "place" as the licensed premises.' Consequently, the Code sections must be read in paria materia. 1 Pa.C.S.A. § 1932. Any other reading of the Code would lead to absurd results. For there to be any alternative reading of the Liquor Code, the Board would have to de -license any licensee who is on the same tract of land where liquid fuels are sold. Forexample, the Board would be required to de -license any restaurant selling alcohol located in a strip mall where a gas station is also a tenant. ' In Section 404 of the Liquor Code 47 P.S. § 4-404 the legislature stated: "That in case of any new license or the transfer of any license to a new location...the Board may, in its discretion, grant or refuse such new license or transfer if such place proposed to be licensed is within three hundred feet of any church, hospital, charitable institution, school or public playground, or if such new license, transfer or extension is applied for a place which is within two hundred feet of any other premises which is licensed by the Board." (emphasis added). {F1107790.1 } 7 e. Petitioner may try to argue that its interpretation of place, property, and location would not necessarily lead to the catastrophic and absurd result of requiring the Board to de-license restaurants locating in malls and commercial developments where there are also gas pumps. Petitioner would argue that in those situations, even though there is one tract of land and one owner, there are separate tenants and that factor mitigates against a finding of co-locations. However, in the instant case there are two separate tenants, Ohio Spings, Inc. who uses the licensed premises for its restaurant, and Sheetz, Inc. who uses its site for the sale of liquid fuels. f. Indeed, not to define the terms location, place, and property in pari materia under the Liquor Code would lead to the further absurd result that the Board could grant a new license to a location, i.e. licensed premises, near the sale of liquid fuels, but the Board could not approve the transfer of that same license to another person pursuant to section 468(a)(3) because liquid fuels are sold at the same site. g. The Board's decision is not one that is sanctioning gas stations to sell alcohol. The Board's decision merely grants a license to an applicant that meets all requirements for a restaurant liquor license pursuant to the Liquor Code and that does not sell fuel or conduct any fuel related activities on the licensed premises. The Supreme Court's decision in Malt Beverage Dist. Ass 'n. v. Pennsylvania Liquor . {F1107790.1} 8 Control Bd. ("Wegmans") supports the Board's decision in this case. 8 A.3d 885 (Pa. 2010). In Wegmans the MBDA argued that the Board improperly issued a license to Wegmans because the legislature had not approved liquor licenses for grocery stores and the Wegman's restaurant and Wegman's grocery store were one in the same in that they were in the same building and were both owned and operated by Wegmans. However, the Supreme Court rejected the MBDA's argument and held that because the restaurant was separated physically and operationally from the grocery store, the Board properly approved the license. Wegmans, 8 A.3d at 895. Here, the approved licensed restaurant and the gas pumps are also separated physically and operationally as concluded by the Board after two days of testimony. 20. With regard to the other factor this Court must look at in lifting the automatic supersedeas, Sheetz is being irreparably harmed by the automatic supersedeas. After approval of the license by the Board, Sheetz began beer sales at the Shippensburg restaurant on July 24, 2014. On August 6, 2014 the Board informed Sheetz it must cease beer sales. Each and every day the supersedeas is in place Sheetz is unable to exercise its rights and privileges under its restaurant liquor license. 21. Moreover, the removal of the supersedeas will not substantially harm other interested parties or adversely affect the public interest. Both the (F1107790.1) 9 Borough of Shippensburg, the municipal authority most intimately attuned to the public interest of the residents of Shippensburg, and the Board both found that a liquor license at the Sheetz restaurant in Shippensburg would not adversely affect the welfare, health, peace and morals of the Borough of Shippensburg or its residents. 22. The Board concurs in this request by Sheetz to vacate the automatic supersedeas. WHEREFORE, Ohio Springs, Inc. t/a Sheetz respectfully requests that this Honorable Court vacate the automatic supersedeas as a result of the appeal filed by the Civic Club of Shippensburg. {F1107790.1) 10 Respectfully Sub i By: Mark E. Kozar, Esquire Pa. I.D. No. 78541 Mark F. Flaherty, Esquire Pa. I.D. No. 46596 Stanley J. Wolowski, Esquire Pa. I.D. No. 32978 Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15222 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within MOTION TO VACATE Automatic SUPERSEDEAS was forwarded to the parties and counsel listed below by U.S. Mail, postage prepaid, this Z()day of September, 2014: Rodrigo J. Diaz, Esq. Pennsylvania Liquor Control Board PA Liquor Control Board 401 NW Ofc Bldg Harrisburg, PA 17124-0001 (717) 783-9454 Commonwealth of Pennsylvania Pennsylvania Liquor Control Board Bureau of Licensing Northwest Office Building, Room 108 Capital and Forster Streets Harrisburg, PA 17124-0001 Charles L. Caputo, Esq. Caputo, Caputo & Regan, P.C. 204 5th Ave, Floor 5 Pittsburgh, PA 15222-2706 (412) 325-0693 Nicholas A. Miller, Esq. Caputo, Caputo & Regan, P.C. 204 5th Ave, Floor 5 Pittsburgh, PA 15222-2706 {F1107790.1 } ark ' . Kozar, E iinre Counsel for Intervenor FiLEO-OFFICE THE PROTHONOTAi'f' 2014 OCT —6 El I: CUMCERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIC CLUB OF SHIPPENSBURG, Petitioner, vs. PENNSYLVANIA LIQUOR CONTROL BOARD, Respondent, vs. OHIO SPRINGS, INC. t/a SHEETZ, Intervenor. CIVIL DIVISION STATUTORY APPEAL CASE NO. 14-4647 PETITIONER'S RESPONSE TO INTERVENOR'S MOTION TO VACATE AUTOMATIC SUPERSEDEAS Filed on Behalf of Petitioner CIVIC CLUB OF SHIPPENSBURG Counsel of Record for this Party: Charles L. Caputo, Esq. PA. I.D. #86058 Nicholas A. Miller, Esq. Pa. I.D. #204141 CAPUTO, CAPUTO & REGAN, PC The B-uhl Building, 5th Floor _ 204 Fifth Avenue Pittsburgh, PA 15222 412-690-0300 412-690-2350 (facsimile) info@caputolawoffice.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIC CLUB OF SHIPPENSBURG, Petitioner, vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent, vs. OHIO SPRINGS, NC. t/a SHEETZ, Intervenor. CIVIL DIVISION STATUTORY APPEAL CASE NO. 14-4647 PETITIONER'S RESPONSE TO INIERVENOR'S MOTION TO VACATE AUTOMATIC SUPERSEDEAS AND, NOW, comes the Petitioner, CIVIC CLUB OF SHIPPENSBURG ("Petitioner"), by and through its counsel Charles L. Caputo, Esq. of Caputo, Caputo & Regan, P.C., and files this Response to Intervenor's Motion to Vacate Automatic Supersedeas and, in support thereof, avers as follows: 1. DENIED. Petitioner is without knowledge or infoimation sufficient to form a belief as to the truth of the allegations contained in paragraph 1 of Intervenor's Motion to Vacate Automatic Supersedeas (the "Motion") and, therefore, these allegations are denied. 2. ADMITTED. Although the Borough ultimately approved the inter -municipal transfer of the liquor license to Sheetz, the issue was the subject of significant debate among the members of Borough Council and the transcript of these proceedings (available on the Shippensburg Borough website or from Petitioner upon request) indicates the Borough Council was misinformed of the appropriate standard when considering a request for inter -municipal transfer of a liquor license. The Borough Council also had concerns about the cost of an appeal if the liquor license was denied at the inter -municipal phase. See Councilman Brenzie Comment, Transcript, P. 64 ("most of the evidence is just us seeing it and concerns which to us are fact but aren't part of the evidence, they would probably end up getting it [the License] anyway.") 3. ADMITTED. 4. ADMITTED. 5. The averments in paragraph 5 of Intervenor's Motion constitute a conclusion of law to which no response is required. By way of further response, the Commonwealth Court's Opinion in Water Street is a document which speaks for itself. 6. The averments in paragraph 6 of Intervenor's Motion constitute a conclusion of law to which no response is required. By way of further response, the Commonwealth Court's Opinion in Water Street is a document which speaks for itself. To the extent further response in required, it is admitted that the Commonwealth Court in Water Street did not address arguments related to Section 468(a)(3) of the Liquor Code. 7. ADMITTED. 8. ADMITTED. 9. The averments in paragraph 9 of Intervenor's Motion constitute a conclusion of law to which no response is required. By way of further response, the Application for Extraordinary Relief filed by other intervening parties with the Pennsylvania Supreme Court is a document which speaks for itself. 10. ADMITTED. 11. ADMITTED. 12. ADMITTED. 13. ADMITTED. 14. ADMITTED IN PART. It is admitted that the MBDA and other beer distributors filed a Petition for Review and that such action has been stayed in the Commonwealth Court. The remaining averments in paragraph 14 of Intervenor's Motion constitute conclusions of law to which no response is required. By way of further response, the filings of these other parties and the Commonwealth Court are documents which speak for themselves. 15. ADMITTED. 16. ADMITTED IN PART. It is admitted that Petitioner's appeal acts as an automatic supersedeas under section 464 of the Liquor Code. The remaining averments in paragraph 16 of Intervenor's Motion constitute conclusions of law to which no response is required. By way of further response, section 464 of the Liquor Code is a document which speaks for itself. 17. The averments in paragraph 17 of Intervenor's Motion constitute a conclusion of law to which no response is required. To the extent a response is required, Petitioner agrees Sheetz has the burden of proving the automatic supersedeas should be vacated in this matter. 18. The averments in paragraph 18 of Intervenor's Motion constitute a conclusion of law to which no response is required. 19. The averments in paragraph 19 of Intervenor's Motion constitute a conclusion of law to which no response is required. To the extent a response is required, it is denied that the Board and Sheetz are likely to prevail on the merits. Sheetz has the burden of proof in this matter and they have failed to cite to any cases which are analogous to this case or which support the relief requested herein. i a. The averments in paragraph 19a of Intervenor's Motion constitute a conclusion of law to which no response is required. To the extent a response is required, the Board's interpretation of the Liquor Code is not entitled to deference in this case because it conflicts with the express provisions of the statute. Despite the strong deference standard, courts are not bound by an agency's interpretation when it conflicts with the governing statute. See Bureau of Liquor Control Enforcement v. American Serbian Club, 750 A.2d 405, 408 (Pa. Commw. Ct. 2000) (trial court's reversal of the Board was affirmed because Board's interpretation of section 5.83 of the regulations conflicted with the Liquor Code and lead to an absurd result). Our Supreme Court has noted "[w]hile courts traditionally accord the interpretation of the agency charged with administration of [an] act some deference, the meaning of a statute is essentially a question of law for the court ..." Popowsky v. Pa. PUC, 910 A.2d 38, 53 (Pa. 2006). The Board is not entitled to deference in this case because its interpretation conflicts with the explicit and unambiguous provisions of the Liquor Code; and the only reasonable interpretation of the statute requires refusal of the Sheetz application. Contrary to Intervenor's averments, the Commonwealth Court has not affirmed the Board's interpretation of Section 468(a)(3) of the Liquor Code. See Intervenor's Motion, paragraph 6. b. The averments in paragraph 19b of Intervenor's Motion constitute conclusions of law to which no response is required. To the extent a response is required, the core principals of the Liquor Code are the restrain the sale of alcohol. See 104(a) of the Liquor Code, which provides: Interpretation of Act. (a) This act shall be deemed an exercise of the police power of the Commonwealth for the protection of the public welfare, health, peace and morals of the people of the Commonwealth and to prohibit forever the open saloon, and all of the provisions of this act shall be liberally construed for the accomplishment of this purpose. Petitioner's interpretation is consistent with these overarching principals of the Liquor Code. The interpretation argued by Sheetz is not. c. The averments in paragraph 19c of Intervenor's Motion constitute conclusions of law to which no response is required. To the extent a response is required, Intervenor admits in paragraph 6 of its Motion that the appellate courts have not interpreted section 468(a)(3) of the Liquor Code, which is precisely the provision the Board's own hearing examiner concluded mandates denial of the Sheetz application in this case. Intervenor has also attempted to speculate as to the Supreme Court's reasons for denying review in other cases, which in no way supports Intervenor's request to vacate the automatic supersedeas or assists Sheetz in carrying its heavy burden in connection with this Motion. d. The averments in paragraph 19d of Intervenor's Motion constitute conclusions of law to which no response is required. To the extent a response is required, the Board's Hearing Examiner conducted a reasoned and lengthy analysis on these issues — including relying on the common and approved usage of the terms "place", "property" and "location" - and concluded the Sheetz application should have been refused. See Recommended Op. at 117-126, 146. There is no way Sheetz can meet its burden of proving it is likely to prevail on the merits when the Hearing Officer who presided over the two (2) day trial in this case recommended denying the application. e. The averments in paragraph 19e of Intervenor's Motion constitute speculation and conclusions of law to which no response is required. To the extent a response is required, Petitioner's interpretation will not lead to catastrophic consequences and there is absolutely no evidence to support that allegation in the record. The argument proffered by Sheetz that there are two separate tenants in this case is a legal facade. Sheetz does not even dispute that these entities are intimately related (Sheetz Inc. is the sole shareholder of Ohio Springs, Inc.) and the only reason Sheetz structured the "leasehold interests" in this manner is to attempt to circumvent the express prohibitions of the Liquor Code. The Board's Hearing Examiner noted the continuity of this business model with the Sheetz logo prominently displayed throughout the property. Sheetz admits that these businesses are all related and it does not care where a customer purchases certain items from because it all goes to the same place. f. The averments in paragraph 19f of Intervenor's Motion constitute speculation and conclusions of law to which no response is required. To the extent a response is required, it is denied Petitioner's interpretation will lead to absurd results. Petitioner is simply asking the Court to enforce the express terms of the statute. The other parties to this action are the ones trying to fabricate a method to circumvent the statute and intent of the General Assembly, which is to prohibit alcohol sales at places, properties and locations which sell gasoline. Sheetz is one of the largest gas retailers in the region and the only absurdity in this case is the claim that Sheetz does not sell gasoline from its Shippensburg place of business. g. The averments in paragraph 19g of Intervenor's Motion constitute conclusions of law to which no response is required. To the extent a response is required, it is denied that the Wegmans case supports Intervenor's arguments. The Wegmans case dealt with a licensed business that had an interconnection with a grocery store. A licensee is not prohibited from selling groceries under the Liquor Code so the applicant in Wegmans did not have the same legal hurdle that Sheetz faces in this case. A licensee is expressly prohibited through multiple sections of the Liquor Code from selling gasoline. 20. DENIED. The averments in paragraph 20 of Intervenor's Motion constitute conclusions of law to which no response is required. By way of further response, it is denied that Sheetz is being irreparably harmed by the automatic supersedeas. The holding of a license is a privilege between the Board and the licensee. See 47 P.S. § 4-468(d). Sheetz's rights and privileges with respect to the License are subject to the provisions of the Liquor Code, which expressly provide for the automatic supersedeas under these circumstances. Additionally, Sheetz has operated its gas station, food service and convenience store business at the Shippensburg location for over thirty (30) years without a liquor license and without irreparable harm for lack of one. Denying the Sheetz motion will result in preserving the status quo which has existed for decades. Gas stations in Pennsylvania are not legally allowed to sell beer. This reality dating back to the era of prohibition (and solidified as recently as 1987 when the Liquor Code was amended to make it more restrictive) should not be ignored and changed via a motion. 21. DENTED. The averments in paragraph 21 of Intervenor's Motion constitute a conclusion of law to which no response is required. To the extent a response is required, in addition to Petitioner, the Board has concluded that at least four (4) other interested parties will be directly aggrieved by the Board's decision to approve a liquor license to Sheetz. See Board's Order dated July 17, 2014. Three (3) of those other interested parties have appeals pending in the Commonwealth Court. Petitioner ncorporates its response to paragraph 2 of the Board's Motion above. To the contrary, members of the Borough Council were concerned about approving a license to Sheetz. The Chief of Police in Shippensburg has grave concerns about Sheetz selling alcoholic beverages and he testified extensively at the Board's administrative hearing. Additionally, vacating the automatic supersedeas at this stage in the proceedings would be contrary to the core principals of the Liquor Code, which are the restrain the sale of alcohol. See 104(a) of the Liquor Code, supra. 22. DENIED. Petitioner is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 22 of Intervenor's Motion and, therefore, these allegations are denied. By way of further response, and for the reasons set forth herein, Petitioner does not concur with Intervenor's request to vacate the automatic supersedeas. WHEREFORE, the Civic Club of Shippensburg, respectfully requests that this Honorable Court deny the Intervenor's Motion to Vacate Automatic Supersedeas, thus maintaining the status quo. Respectfully Submitted, Charles L. Caputo, Esquire Pa. I.D. No. 86058 Caputo, Caputo & Regan, P.C. Buhl Building, 5th Floor 204 Fifth Avenue Pittsburgh, PA 15222 412-690-0300 info@caputolawoffice. corn Attorneys for Petitioner, Civic Club of Shippensburg CERTIFICATE OF SERVICE I hereby certify that true and correct copies of the within Petitioner's Response to Respondent's Motion to Vacate Automatic Supersedeas were forwarded to the parties and counsel listed below by facsimile and U.S. Mail, postage prepaid, this 3rd day of October, 2014. Rodrigo J. Diaz, Esquire Pennsylvania Liquor Control Board Office of Chief Counsel 401 Northwest Office Building Capital and Forster Streets Harrisburg, PA 17124-0001 Mark Flaherty, Esquire Stanley Wolowski, Esquire Mark E. Kozar, Esquire FLAHERTY & O'HARA, PC 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Charl s L. Caputo, Esquire Counsel for Petitioner THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIL CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner VS. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. CASE NO. 14-4647 ANSWER TO MOTION TO VACATE AUTOMATIC SUPERSEDEAS AND NOW comes Respondent, Pennsylvania Liquor Control Board ("Board") through its counsel, Rodrigo J. Diaz, and files this response to the Motion to Vacate Automatic Supersedeas, filed by Intervener, Ohio Springs, Inc., t/a Sheetz ("Sheetz"), and avers the following: Procedural History 1. Admitted in part; Denied in Part. It is admitted that Sheetz has applied for the transfer of Restaurant Liquor License No. R-19377. Such license would authorize Sheetz to sell beer, wine and spirits at its premises. After reasonable investigation, the Board is unaware of which of these products Sheetz will actually sell, so the remaining portion of this paragraph is denied. 2. Admitted. 3. Admitted. 4. Admitted. 5. Paragragh 5 states a conclusion of law for which no further response is required. By way of further answer, the Commonwealth Court specifically held that the Board's interpretation of the Liquor Code's prohibition on licensing locations that sell liquid fuels, to wit, that liquid fuels cannot be sold on the licensed portion of a premises, was correct. 6. Paragraph 6 states a conclusion of law for which no further response is required. By way of further answer, the Commonwealth Court specifically held that the Board's interpretation of the Liquor Code's prohibition on licensing locations that sell liquid fuels, to wit, that liquid fuels cannot be sold on the licensed portion of a premises, was correct. 7. Admitted. 8. Admitted. By way of further answer, those parties (Malt Beverage Distributors Association, Gabler's Beverage Distribution, Inc., and PKD, Inc., hereinafter collective referred to as "MBDA") would ultimately file an appeal of the Board's decision as well. That matter is before the Commonwealth Court, at 1352 C.D. 2014, and proceedings in that matter have been stayed by the Commonwealth Court until this matter is resolved. 9. Admitted. 10. Admitted. 11. Admitted. 12. Admitted. 2 13. Admitted. By way of further answer, that appeal preserved a single issue for this Honorable Court to review, to wit, whether the liquid fuels prohibition found in the Liquor Code prevented the issuance of this license. 14. Admitted. By way of further answer, MBDA concurrently filed an Application for Expedited and En Banc Review, arguing that en banc review was necessary because, inter alia, Water Street Beverage, Ltd. V. Pennsylvania Liquor Control Board, 84 A.3d 786 (Pa. Cmwlth. 2014) was wrongly decided. 15. Admitted. The Automatic Supersedeas Should be Vacated 16. Paragraph 16 states a conclusion of law for which no further response is required. If further response is required, it is admitted. 17. Paragraph 17 states a conclusion of law for which no further response is required. If further response is required, it is admitted. 18. Paragraph 18 states a conclusion of law for which no further response is required. If further response is required, it is admitted. 19. a. Admitted. By way of further answer, regardless of the deference this Honorable Court may or may not have to give to a Board's decision, the Commonwealth Court decision in Water Street means that the Commonwealth Court has adopted the Board's reasoning. Their decision is clearly binding on this Honorable Court. 19. b. Paragraph 19 (b) states a conclusion of law for which no further response is required. If further answer is required, it is admitted. By way of further 3 answer, the legislative history provided by Petitioner at the hearing held before this Honorable Court does not establish that the Commonwealth Court decision in Water Street was wrongly decided. At best, it establishes that no liquid fuels activity can occur on locations licensed by the Board whereas prior to 1987, certain activity could occur. That change does not address the core issue in both Water Street and the instant case, to wit, what is the area subject to the prohibition. 19. c. Paragraph 19(c) states a conclusion of law for which no further answer is required. If further answer is required, it is admitted that the Pennsylvania Supreme Court's decision to not accept an appeal in Water Street means that Water Street remains the law on this issue. By way of further answer, MBDA, which is also represented by Petitioner's counsel and which has filed its own appeal to the Commonwealth Court, concurrently filed with the Commonwealth Court an Application for Expedited and En Banc Review, arguing that en banc review was necessary because inter alia, Water Street was wrongly decided 19. d. Paragraph 19(d) states a conclusion of law for which no further answer is required. If further answer is required, it is admitted that the Board interprets the four sections of the Liquor Code that prohibit liquid fuels in pari materia See Roberts v. Com. Pennsylvania Liquor Control Bd., 604 A2d. 1152 (Pa. Cmwlth 1992). Further, the Commonwealth Court, in adopting the Board's interpretation, noted that such interpretation was appropriate, even though the Liquor Code and the Board's Regulations use different words - premise, place, location, portion - to essentially mean the same 4 thing. It is further admitted that a contrary interpretation would lead to absurd results.' Finally, it is noted that if the Legislature wanted to prohibit the holder of a liquor license (or associated persons) from selling liquid fuels, rather than limiting where such sales could occur, it would have written a prohibition similar to what is found in section 492(12) of the Liquor Code (prohibiting distributor or importing distributor or its servants agents or employees from engaging in any other business without Board approval) and section 492(14) (prohibiting and malt or brewed beverage licensee and its servants agents or employees from manufacturing, importing, selling, storing, trading or bartering any liquor or alcohol). 47 P.S. §§ 4-492(12), 4-492(14). 19. e. Admitted in part. It is admitted that two related separate legal entities are located within the same building and parking lot. The rest of the paragraph constitutes speculation for which no response is required. 19. f. Paragraph 19(0 states a conclusion of law for which no further answer is required. If further answer is required, interpreting the different liquid fuel provisions is the Liquor Code differently would be contrary to Water Street. Again as noted earlier, when MBDA, who is also represented by Petitioner's counsel, filed its appeal to the Commonwealth Court, it also asked the Commonwealth Court to have the matter heard en banc because they knew that they can only prevail if Water Street is overturned. 1 It should be noted that at the hearing before this Honorable Court, Petitioners have argued that this Honorable Court should ignore the Board's and the Commonwealth Court's interpretation of the liquor fuels prohibition and instead adopt the hearing examiner's interpretation. To be clear, the hearing examiner is not a fact finder. Rather, he is more akin to the judicial clerk who provides a recommendation to this Honorable Court. His opinion has no precedential value. 5 19. g. Paragraph 19(g) state a conclusion of law for which no further answer if required. 20. It is admitted that Intervener is harmed if it is unable to sell alcohol notwithstanding the fact that the Board in accordance with the Commonwealth Court's decision in Water Street granted its application. The remaining portion of paragraph 20 states a conclusion of law for which no further answer is required. 21. Paragraph 21 states a conclusion of law for which no response is required. If further response is required, the Board is unaware of anyone who would be irreparably harmed if the motion is granted. 22. Admitted. WHEREFORE, The Pennsylvania Liquor Control Board respectfully requests that this Honorable Court to vacate the automatic supersedeas in this matter. October 9, 2014 Respectfully Submitted, °-11///- RODRIGO J. bIAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 6 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION, STATUTORY APPEAL CIVIL CLUB OF SHIPPENSBURG (OHIO SPRINGS, INC. T/A SHEETZ, Applicant) Petitioner vs. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. CASE NO. 14-4647 CERTIFICATE OF SERVICE I hereby certify that I am on this date serving a copy of the foregoing Answer to Motion to Vacate Automatic Supersedeas via UPS Overnight delivery to the following persons: Charles L. Caputo, Esquire Caputo, Caputo & Regan, P.C. 204 Fifth Avenue, 5th Floor Pittsburgh, PA 15222 Mark F. Flaherty, Esquire Flaherty & O'Hara, P.C. Flaherty & O'Hara, P.C. 610 Smithfield Street, Suite 300 Pittsburgh, PA 15222 October 9, 2014 Stanley J. Wolowski, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Mark E. Kozar, Esquire Flaherty & O'Hara, P.C. 610 Smithfield Street Suite 300 Pittsburgh, PA 15222 Respectfully submitted, RODRIGO J. 4IAZ Executive Deputy Chief Counsel Attorney I.D. No. 62259 PENNSYLVANIA LIQUOR CONTROL BOARD 401 Northwest Office Building Harrisburg, PA 17124-0001 Telephone: (717) 783-9454 FAX: (717) 787-8820 CIVIC CLUB OF SHIPPENSBURG IN THE COURT OF COMMON PLEAS OF (OHIO SPRINGS, INC. T/A SHEETZ, CUMBERLAND COUNTY, PENNSYLVANIA Applicant) Petitioner, Case No. 14-4647 CIVIL c V. --T,--3: - -f PENNSYLVANIA LIQUOR CONTROL r-n BOARD Respondent. C4 c { IN RE: PETITION FOR APPEAL FROM DECISION OF PLCB : BEFORE HESS, P.J. ORDER AND NOW, this �� day of October, 2014, it is hereby ordered that the Pennsylvania Liquor Control Board (PLCB) Decision and Order dated July 17, 2014 approving the double transfer application of Pennsylvania Restaurant Liquor License No. R-19377 to Ohio Springs, Inc. for use at premises located at 345 King Street, Shippensburg, Pennsylvania 17257 is AFFIRMED and said transfer shall be GRANTED. BY THE COURT: Kevi Hess, P.J. ✓Charles L. Caputo, Esquire For the Petitioner ✓Rodrigo J. Diaz, Esquire For PLCB Mark F. Flaherty, Esquire Stanley J. Wolowski, Esquire Mark E. Kozar, Esquire For Ohio Springs, Inc. CIVIC CLUB OF SHIPPENSBURG IN THE COURT OF COMMON PLEAS OF (OHIO SPRINGS, INC. T/A SHEETZ, CUMBERLAND COUNTY, PENNSYLVANIA Applicant) Petitioner, Case No. 14-4647 CIVIL V. PENNSYLVANIA LIQUOR CONTROL BOARD Respondent. IN RE: PETITION FOR APPEAL FROM DECISION OF PLCB BEFORE HESS, P.J. OPINION AND ORDER Civic Club of Shippensburg (CCS) brought the instant matter by way of appeal from the Pennsylvania Liquor Control Board's (PLCB) granting of an application for a double inter-municipal transfer of Restaurant Liquor License No. R-19377 by Ohio Springs, Inc. T/A Sheetz (Sheetz). A hearing was held on March 18-19, 2014 before a PLCB hearing examiner pursuant to section 464 of the Liquor Code (47 P.S. § 4-464). The hearing examiner filed an opinion recommending to the PLCB that the application be denied. Notwithstanding, the PLCB filed an order granting the transfer of R-19377 to Sheetz. Upon appeal by CCS, the PLCB filed a comprehensive opinion in support of its order. CCS filed their appeal to this Court under 47 P.S. § 4-464 maintaining standing as a non-profit organization located within 300 feet of the proposed licensed premises. There is also a concurrent appeal by separate interveners before the Commonwealth Court of Pennsylvania, 1352 C.D. 2014, which has stayed its proceedings pending the resolution of the matter before us. A common pleas court hears appeals under 47 P.S. § 4-464 de novo. The Pennsylvania Supreme Court has further defined the standard noting that "an appeal from a decision of the Board ... required the court of common pleas to conduct a de novo review, and in the exercise of its statutory discretion, to make findings and conclusions. [The Supreme Court] also held that this language permitted a court of common pleas, based upon its de novo review, to sustain, alter, change, or modify a penalty imposed by the Board whether or not it makes findings which are materially different from those found by the Board." Pa. Liquor Control Bd. v. Richard E. Craft Am. Legion Home Corp., 718 A.2d 276, 282 (Pa. 1992). In light of the above standard, we find no error in the PLCB's findings of fact, as such, and adopt them. Accordingly, ¶¶1-360 of the PLCB Opinion are herein incorporated by reference. Despite the seemingly broad nature of de novo review, at the hearing before this Court the parties only addressed the issue of the co-location of the sale of liquid fuels and alcohol. This issue was labeled, in the PLCB's opinion, as objection 7. (PLCB Opinion, 10). We adopt the PLCB's conclusions with respect to the 12 other objections. Therefore, this opinion addresses only the narrow issue of whether both alcohol and gasoline are sold at the proposed licensed premises in violation the Liquor Code, specifically 47 P.S. §§ 4-404, 4-468. 47 P.S. § 4-404, in relevant part, states "[t]he board shall refuse any application for a new license, the transfer of any license to a new location or the extension of any license to cover an additional area where the sale of liquid fuels or oil is conducted." Meanwhile, 47 P.S. § 4-468(a)(3) states "[n]o license shall be transferred to any place or property upon which is located as a business the sale of liquid fuels and oil." Therefore, the question before this Court is whether the proposed licensed premises is the same location, place, or property upon which gasoline will be sold. 2 CCS argues that the plain language of the controlling statutes compels this Court to deny Sheetz' application, since the proposed licensed premises would be co-located with the location, place, or property where gasoline is sold. Both Sheetz and the PLCB state that the Sheetz Restaurant (where beer will be sold) and the Sheetz Convenience Store (where gasoline is dispensed) are separate properties and, therefore, the license is proper. The land upon which the proposed licensed premises would be situated is owned by C.S.P. Investments, Inc. (CSP). (Notes of Testimony, In Re: R-19377 Application, 537, March 19, 2014 (hereinafter "N.T. at_")). CSP subdivided the entire property into two condominium units—Unit 1 and Unit 2—and a common area. (N.T. at 537-538). The condominium units would have separate tax assessments, as well as different real estate tax numbers. (N.T. at 542-543, 546-547). Unit 1, the location of the proposed license premises, is being leased from CSP by Ohio Springs. (N.T. at 539-540). Ohio Springs' parent company, Sheetz, Inc., is leasing Unit 2 of the condominium, and the common area would be shared between the two entities. (N.T. at 541). The Declaration of Condominium restricts the use of each unit such that Unit 1 cannot be used for the sale of gasoline and Unit 2 cannot be used for the sale of alcohol. (N.T. at 540, 542). Under Pennsylvania law, a condominium is defined as "[r]eal estate, portions of which are designated for separate ownership and the remainder of which is designated for common ownership solely by the owners of those portions." 68 Pa.C.S.A. § 3103. The portions referenced in the definition are further defined as units. Id. Therefore, it is the clear intention of the state legislature that, when a Declaration of Condominium has 3 been filed, the units are considered distinct properties, able to be owned by different entities and treated as separate interests. Here, CSP has duly filed a Declaration of Condominium, dividing the property into Unit 1, Unit 2, and the common area. CSP has retained ownership over the units, as well as the common area. The units were then leased by CSP to Ohio Springs and Sheetz. This is no longer merely one property, but is instead one parcel with separate and distinct subdivisions which are freely transferrable. The proposition that subdivision by Declaration of Condominium is sufficient to comply with 47 P.S. §§ 4-404, 4-468 is further bolstered by the PLCB's statements and past interpretations of the Liquor Code. We initially note that "[t]he Board's interpretation of the Liquor Code and the regulations is given deference unless it is clearly erroneous." Irem Temple AAONMS v. Pa. Liquor Control Bd., 87 A.3d 983, 997 (Pa. Commw. Ct. 2014) (citing Pa. Liquor Control Bd. v. Richard E. Craft Am. Legion Home Corp., 718 A.2d 276, 278 (Pa. 1998)). Further, "[b]ecause the Liquor Code is remedial legislation, its provisions must be liberally construed to accomplish its purpose." Id. at 995. The PLCB decision discussed in WaterStreet Bev., LTD v. Pa. Liquor Control Bd., 84 A.3d 786, 796 (Pa. Commw. Ct. 2014), defined the term "location," as used in 47 P.S. § 4-432, to be in relation to the particular area to be licensed. The WaterStreet court agreed. While WaterStreet addressed a different numerical section of the Liquor Code, the language of the section in WaterStreet, 47 P.S. § 4-432, and the section at issue before us, 47 P.S. § 4-404, is identical. Counsel for PLCB, Mr. Diaz, articulated that the sections of the Liquor Code at issue were focused on the specific bounds of the licensed premises, as opposed to 4 other Liquor Code regulations which focus on the identity of the applicant. Mr. Diaz's argument comports with the interpretation stated in WaterStreet. Here, the application states that the licensed premises will be Unit 1 of the condominiums located at 345 King Street, Shippensburg, PA. (N.T. at 557). Unit 1 is distinct from Unit 2, enough that Unit 2 is identified by a separate mailing address, 359 King Street, Shippensburg, PA. (Id.). Unit 1 has clearly delineated borders and is separated from both Unit 2 and the common areas by walls and doorways. Unit 1 is a fixed area comprised of 6,567 sq. ft. (MBDA 7) while Unit 2 is 15,207 sq. ft. (MBDA 8). Based on Sheetz' testimony and the restrictions set forth in the Declaration of Condominium, no gasoline or other liquid fuel will be sold within the boundaries, confines, or area defined as Unit 1, the proposed licensed premises. Additionally, at trial there was much comparison between the Shippensburg and Altoona Sheetz locations because Altoona is the only other Sheetz location in Pennsylvania to have been granted a liquor license. In Altoona, the land was subdivided into two separate parcels. (N.T. at 561). That not being possible in Shippensburg (N.T. at 533-534), the Declaration of Condominium was filed to create separate legal interest within the parcel. At the PLCB hearing, Sheetz indicated that it was not attempting to circumvent Liquor Code regulations, but to comply with them. (N.T. at 545, 561). It appears that they have done so. Finally, CCS argues that to grant this license would be to go against the policy set forth by the Liquor Code. Specifically, CCS argues that the purpose of the Liquor Code is to restrain the sale of alcohol and protect the public welfare, health, peace, and morals of our citizens. There have been no meritorious allegations as to corruption of the public welfare, health, peace, or morals of the citizenry. Nor do we find any upon 5 review of the record. In fact, the entity arguably in the best position to determine any detrimental effects upon the community, the Borough of Shippensburg, had the chance to let such concerns be known prior to Sheetz filing the instant application when the Borough considered Resolution No. 12-015. Instead, the resolution passed. More importantly, however, the PLCB's role is to restrain and regulate the sale of alcohol, not prohibit it in its entirety. Sheetz has met its burden under the statutes set forth by the legislature and, absent any finding of corruption to the community, the PLCB duly granted the transfer of the license. Therefore, in light of the clear separation between the sale of gasoline and alcohol, in addition to the incorporated conclusions with respect to the other objections from the PLCB opinion, we grant the application for the double inter-municipal transfer of Restaurant Liquor License No. R-19377 by Ohio Springs, Inc. T/A Sheetz (Sheetz). ORDER AND NOW, this day of October, 2014, it is hereby ordered that the Pennsylvania Liquor Control Board (PLCB) Decision and Order dated July 17, 2014 approving the double transfer application of Pennsylvania Restaurant Liquor License No. R-19377 to Ohio Springs, Inc. for use at premises located at 345 King Street, Shippensburg, Pennsylvania 17257 is AFFIRMED and said transfer shall be GRANTED. BY THE COURT: - /� J'_ Kevin . Hess, P.J. 6