The opinion
DISSENTING OPINION BY
Judge LEAVITT.
I respectfully dissent. The premise to the majority’s decision is that a petition for review must articulate specific objections to the underlying agency decision or face dismissal. That premise, however, is directly contrary to the plain language of the applicable rule of appellate procedure, Pa. R.A.P. 1513, which requires only a “general statement” of a petitioner’s objections. How specific must a general statement of objections be? Because Claimant’s petition for review complied with Rule 1513, I would deny the Boai'd’s motion to strike the petition.
The contents of a petition for review are directed by Pennsylvania Rule of Appellate Procedure 1513(d), which states:
(d) Content of appellate jurisdiction petition for review. An appellate jurisdiction petition for review shall contain: (1) a statement of the basis for the jurisdiction of the court; (2) the name of the party or person seeking review; (3) the name of the government unit that made the order or other determination sought *1269 to be reviewed; (4) reference to the order or other determination sought to be reviewed, including the date the order or other determination was entered; (5) a general statement of the objections to the order or other determination; and (6) a short statement of the relief sought. A copy of the order or other determination to be reviewed shall be attached to the petition for review as an exhibit. The statement of objections will be deemed to include every subsidiary question fairly comprised therein. No notice to plead or verification is necessary.
Pa.R.A.P. 1513(d) (emphasis added). In interpreting Rule 1513, this Court must apply the rules of statutory construction set forth in Chapter 19 of Title 1 of the Pennsylvania Consolidated Statutes. Pa. R.A.P. 107. This includes the time-honored rule that the plain language of the rule governs the rule’s meaning. 1 Pa.C.S. § 1921(a) and (b). 1
Rule 1513(d) could not be clearer. In an appellate petition for review, only a “general statement” of a petitioner’s objections to the order or determination is required. This Court must construe the rule to give effect to all of its provisions, including the word “general.” 1 Pa.C.S. § 1921(a). The word “general” in this context is free from any ambiguity, and this Court may not disregard the letter of the rule. 1 Pa.C.S. § 1921(b). Quite simply, “general” does not mean “specific;” it means the opposite of “specific.”
The official note to Rule 1513 does not require the petitioner to present specific, as opposed to general, objections. The official note states as follows:
Subdivisions (d) and (e) reflect the differences in proceeding in a court’s original and appellate jurisdiction, while preserving the need for sufficient specificity to permit the conversion of an appellate document to an original jurisdiction pleading and vice versa should such action be necessary to assure proper judicial disposition.
Pa.R.A.P. 1513, Note. This note explains the reason for the rather lengthy content requirements in Rule 1513(d), namely, that these content requirements will yield an appellate petition for review “sufficiently specific” to permit a conversion to the Court’s original jurisdiction. The note does not construe the term “general statement,” and a note cannot modify the actual language of an appellate rule. Stated otherwise, a petition for review that contains all seven elements set forth in Pa.R.A.P. 1513(d), including a “general statement” of issues, is one that is sufficiently specific to permit conversion to an original petition for review.
Accordingly, I believe the Court misconstrued the meaning of the official note in Deal v. Unemployment Compensation Board of Review, 878 A.2d 131 (Pa.Cmwlth.2005). The Court wrote:
However, while “deemed to include every subsidiary question fairly comprised therein,” a petition for review under Pa. R.A.P. 1513(d) must state its objections with “sufficient specificity to permit the conversion of an appellate document to an original jurisdiction pleading and vice *1270 versa should such action be necessary to assure proper judicial disposition.” Pa. R.A.P. 1513, Note.
Deal, 878 A.2d at 132-133 . I believe this analysis to be incorrect. The note does not, as explained above, amend Pa.R.A.P. 1513(d) to require a petitioner to “state [his] objections with sufficient specificity.”
In Pearson v. Unemployment Compensation Board of Review, 954 A.2d 1260 (Pa.Cmwlth.2008), this Court offered a better approach for evaluating whether a petition for review contains a “general statement” of issues. In that case, the claimant raised two issues in his petition for review: (1) “the Board failed to ‘review all the facts;’ ” and (2) “ ‘this case is not strong enough’ to withhold unemployment compensation benefits.” Pearson, 954 A.2d at 1263 . Applying the proviso that “[t]he statement of objections will be deemed to include every subsidiary question fairly comprised therein,” Pa.R.A.P. 1513(d), we construed the claimant’s “general statement” of issues to challenge the sufficiency of the evidence and whether the employer had sustained its burden of proof. In doing so, we looked beyond the four corners of the petition for review and noted that “[c]laimant sufficiently addresses these arguments in his handwritten appellate brief.” Pearson, 954 A.2d at 1263 .
Pearson recognizes that a petition for review should not be considered in a vacuum. Indeed, Rule 1513 requires the petitioner to attach a copy of the challenged order or determination, ie., the adjudication, to the petition for review. By putting the “general statement” together with the attached adjudication, “every subsidiary question fairly comprised” can be discussed. The Pearson approach is preferable to the drastic measure of striking a petition for review on a technicality and effectively putting a litigant out of court.
In the case sub judice, Claimant alleged the following in his petition for review:
6. The determination of the Unemployment Compensation Board of Review is not supported by substantial evidence.
7. The determination of the Unemployment Compensation Board of Review is based on errors of law.
As in Pearson , it is not difficult to interpret the meaning of Claimant’s broadly stated issues. The Board’s adjudication reveals that its “determination” was that Claimant was “ineligible for benefits under the provisions of Section 402(e) of the Pennsylvania Unemployment Compensation Law.” Board Decision and Order at 3. Stated another way, the Board found that Claimant was disqualified from receiving benefits by reason of his willful misconduct. Accordingly, it is clear that the issue is willful misconduct and whether the Board’s conclusion in this regard was correct with respect to its findings of fact and application of the law. This satisfies Pa. R.A.P. 1513(d).
In sum, the majority has inexplicably, and unjustifiably, rewritten the plain language of Rule 1513(d) to mean the opposite of what it says. Instead of a “general statement” of issues, now a “specific” statement of issues is required. The majority does so by relying on Deal , which I posit was wrongly decided based upon a misapplication of the official note to Rule 1513. I would follow Pearson 2
. These provisions state:
(a) The object of all interpretation and construction of statutes is to ascertain and effectuate the intention of the General Assembly. Every statute shall be construed, if possible, to give effect to all its provisions.
(b) When the words of a statute are clear and free from all ambiguity, the letter of it is not to be disregarded under the pretext of pursuing its spirit.
1 Pa.C.S. § 1921.
. As for the merits of Claimant's petition for review, I agree with the majority that this Court would affirm the Board’s order, for the *1271 reasons set forth in footnote 3 of the lead opinion.