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The issue of exactly what constitutes 'on-campus' crime is still the subject of national debate. Although an extensive federal investigation upheld the University's interpretation of crime reporting laws, Penn officials and some of the University's most outspoken critics agree that the current system's definition of "on campus" may not realistically describe crime in areas students commonly frequent. The U.S. Department of Education issued its report to the University last Friday after a nearly year-long review of Penn's 1994-96 crime statistics. The University made the report public Monday. Investigators concluded that, contrary to suggestions in a 1996 Philadelphia Inquirer article, Penn did not engage in a systematic effort to cover up crime that occurred in the area patrolled by University Police. But the report also listed six violations the University committed -- including omitting an alleged 1994 on-campus rape from its statistics. The incident is currently the subject of a lawsuit. Critics of the University's crime-reporting techniques blasted the DOE conclusions, but acknowledged that Penn may have been following the letter -- if not the spirit -- of the law. "I'm forced to concede that that probably is the letter of the law, and we probably have to do something about that," said Daniel Carter, vice president of Security on Campus Inc., the victims-rights group that asked the DOE to audit Penn's statistics. Federal law currently states that any "property owned or controlled by an institution within the same reasonably contiguous geographic area and used by the institution in direct support of, or in a manner related to, the institution's educational purposes" is to be considered on campus. But it is unclear whether such a definition can suffice for an urban university like Penn, which contains areas that are not clearly on or off campus. More isolated, rural institutions tend to be more clearly demarcated from the outside world. For example, federal law considers sidewalks in front of University buildings on campus. Public roads, by contrast, are off campus. Therefore, a student walking across the street from Williams Hall at 36th and Spruce streets to the Quadrangle's lower entrance would be off campus while on the asphalt of Spruce Street, but on campus at all other times. Beyond the street-sidewalk issue, administrators wonder about how to best define what constitutes the campus of a school such as Penn. "We've been struggling with this all year," University President Judith Rodin said earlier this week. "Is [the border] 41st Street? Is it 40th Street?" And Managing Director of Public Safety Tom Seamon explained that "we need a clear definition of the geographical reporting area." "It may be that there can't be one standard," he said. "It may be that there has to be one for urban and one for suburban campuses." Neither Seamon nor Rodin -- nor any other University official or independent source contacted -- could easily define what the boundary for an urban campus should be. "Our whole premise [that there is a simple border] may be flawed," Seamon said. Rodin suggested that a more reasonable way to report crime may be to divide the report into separate categories, such as "University-owned on campus," "University-owned off campus" and "geographical region around the University but not owned by it." Even if Penn officials could find a more urban-based reporting technique, attempting to use it to satisfy federal regulations would make it impossible to compare different universities. "If you have a different standard for every university, you're in the same place you were before you had regulations," Seamon noted. Police officials also indicated that they feel they are being unfairly criticized for patrolling an area that goes beyond campus to protect students and neighborhood residents. University Police patrol the area from Market Street to Baltimore Avenue and the Schuylkill River to 43rd Street. "[The department] gets criticized for projecting out into the community, which I think is what students and parents and faculty want," Seamon said. Howard Clery -- who founded the King of Prussia, Pa.-based Security on Campus Inc. after his daughter was brutally raped, tortured and murdered in her Lehigh University dormitory room in 1986 -- said Penn and other universities are "guilty of aiding and abetting crime through their negligent actions." Clery criticized the University for not enforcing alcohol and narcotics laws. He said Penn should include statistics from its entire patrol area in addition to on-campus crime. "You can always [put an] asterisk and say you had 181 [robberies] in the vicinity and 18 on campus if you want to define it that way," he said. "The purpose of the law is not a Talmudic interpretation." A bill that may expand universities' crime-reporting responsibilities is scheduled to come before the U.S. House of Representatives sometime this spring. Clery supports the bill, H.R. 715. If passed, the law would require all campus officials who know of crimes to report them to the government, meaning that athletic coaches and rape crisis center administrators, in addition to police, would have reporting duties. H.R. 715 would also require schools to report "incidents" instead of "arrests" -- meaning that crimes handled without a formal arrest would still be included. Some experts warn, however, that the change would mask crime statistics. For example, the arrest of 50 students at once for a liquor violation may be logged as one incident. The bill would add new categories to the crime report -- larceny, arson, simple assault and vandalism -- and subdivide the murder category into "murder or nonnegligent manslaughter" and "negligent manslaughter." H.R. 715 also contains provisions that would drastically change the University's internal judiciary system, a move opposed by some campus administrators.

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