Philadelphia is notorious for "making" their own laws/regulations regarding LTCF. For years they wouldn't even issue them (they lost that fight), then tried to delay the process (they lost that fight), then tried charging more $ (they lost that fight), then they wanted 2 photo's instead of the state standard of one (which they also lost on) and the "references" battle keeps going back and forth (they'll change/alter it, then revert back, so on and so forth). They also use a non standard references form which asks "why should this person be issued a LTCF" (rather than "should this person NOT be issued a LTCF"). They clearly treat it as a "may issue" state (via questioning) when they know full well that it's a "SHALL issue" state (meaning they MUST issue unless valid conditions for refusal).
Do not be fooled, they know the law, they simply have the bully attitude of "We'll get away with whatever we want to" (until they are challenged).
On my coworkers reference I wrote "because he is an upstanding law abiding citizen, to which you MUST issue an LTCF as per PA law".