Even though Access/Rhode Island did not have standing to file this complaint, we reviewed this complaint consistent with this Department's independent statutory authority as described in West Warwick School Department, PR 15-23. Access/Rhode Island alleged that the Town violated the APRA when it failed to provide APRA certification forms to this Department evidencing APRA training pursuant to R.I. Gen. Laws § 38-2-3.16 and when it failed to promulgate and post APRA procedures to its website. These violations have since been remedied. The Town provided no substantive response to the underlying allegations, and therefore, we found the allegations meritorious. Because the Town did not provide a substantive response or explanation concerning the violations, we deemed it appropriate to direct the Town to provide a supplemental response addressing the underlying violations so that this Department could determine whether the violations were willful and knowing, or reckless, which would subject the Town to civil fines.