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HomeMy WebLinkAbout1492 BurchfieldIn Re: David Burchfield, Sr., Respondent File Docket: X -ref: Date Decided: Date Mailed: Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Paul M. Henry Raquel K. Bergen Nicholas A. Colafella 07 -089 Order No. 1492 9/22/08 10/10/08 This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding a possible violation of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." A Stipulation of Findings and a Consent Agreement waiving an evidentiary hearing were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. This adjudication of the State Ethics Commission is issued under the Ethics Act and will be made available as a public document thirty days after the mailing date noted above. However, reconsideration may be requested. Any reconsideration request must be received at this Commission within thirty days of the mailing date and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code § 21.29(b). A request for reconsideration will not affect the finality of this adjudication but will defer its public release pending action on the request by the Commission. The files in this case will remain confidential in accordance with the Ethics Act. Burchfield, 07 -089 Page 2 I. ALLEGATIONS: That David Burchfield, a public official /public employee in his capacity as a Supervisor for Blair Township, Blair County, violated Sections 1103(a), 1105(b)(5), 1105(b)(8), and 1105(b)(9) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. § §1103(a), 1105(b)(5), 1105(b)(8), and 1105(b)(9), when he used the authority of his office for the private pecuniary gain of himself, a member of his immediate family and /or a business with which he or a member of his immediate family is associated by [conduct] including, but not limited to, participating in actions and deliberations of the Board of Supervisors to designate the Duncansville Volunteer Fire Company as the primary responding Fire Department /Emergency Responder for Blair Township; and then participating in actions and deliberations of the Board allotting funding to the Duncansville Volunteer Fire Company from the Township's E.M.S. tax; and then subsequently entering into a contract /agreement with the Duncansville Volunteer Fire Company, in excess of $500.00, to lease property /building space owned by him, and /or members of his immediate family for use by the Duncansville Volunteer Fire Company as a sub - station within Blair Township; and when [he] failed to disclose on Statements of Financial Interests filed for the 2002, 2003, 2004, 2005, 2006 and 2007 calendar years direct /indirect sources of income in excess of $1,300, [his] office, directorship, or employment in any business entity, and his financial interests in any legal entity engaged in business for profit. II. FINDINGS: 1. David Burchfield, Sr. has served as a Supervisor of Blair Township, Blair County since approximately January 1998. 2. Blair Township is designated a Township of the Second Class governed by a three (3) member Board of Supervisors. a. David Burchfield, Sr., Arlene Bush, and Palmer Brown comprised the Blair Township Board of Supervisors during calendar years 2005 through 2007. b. Blair Township Supervisors are elected to six (6) year terms. 3. Professionally, David Burchfield, Sr. has business interests including but not limited to the Burchfield Limited Partnership, the Burchfield Organization, Inc., and Burchfield Auto Sales. 4. The Burchfield Organization, Inc., was incorporated in December 1994 with its principal place of business at 713 Route 764, Duncansville, PA 16635. a. Burchfield, his wife, and two sons are employed by the Burchfield Organization. b. Burchfield and his family members hold corporate officer positions in the Burchfield Organization as follows: 1. David E. Burchfield, Sr. — Chief Executive Officer 2. Linda L. Burchfield (Burchfield's wife) — Secretary 3. David E. Burchfield, Jr. (Burchfield's son) — Vice President 4. Richard E. Burchfield (Burchfield's son) — Treasurer 5. The Burchfield Organization, Inc., was incorporated for the purpose of performing and providing services and materials for auto and truck sales and repairs, truck and equipment salvage, and other related activities. a. The Burchfield Organization, Inc., encompasses several Burchfield Burchfield, 07 -089 Page 3 businesses including Burchfield Towing & Auto Sales and Burchfield Auto & Truck Salvage. 6. Records of the Pennsylvania Department of State, Corporation Bureau, include the following information on Burchfield -owned business entities: Entity Name Burchfield Auto Sales Burchfield Auto & Truck Salvage Entity Name Burchfield Auto Sales Burchfield Auto & Truck Salvage The Burchfield Organization, Inc. The Burchfield Limited Partnership Entity Number Officers 1055269 David Burchfield, Sr. (Fictitious Name) 1055270 David Burchfield, Sr. (Fictitious Name) The Burchfield 2612090 David E. Burchfield, President Organization, Inc. Linda Burchfield, Secretary Richard E. Burchfield, Treasurer David Burchfield, Jr., Vice - President The Burchfield Limited 556596 David E. Burchfield, Sr., General Partnership Partner Filing Date 09/15/1988 09/15/1988 12/14/1994 10/25/2005 7 The Burchfield Limited Partnership was created on or about October 1, 2005, with its principal place of business at 713 Route 764, Duncansville, PA 16635. a. This is the same business address as the Burchfield Organization, Inc. b. Limited partnership applications for the Burchfield Limited Partnership were filed with the Pennsylvania Department of State on October 25, 2005. c. David E. Burchfield, Sr. is identified as the general partner. 8. David E. Burchfield, Sr. has had a 95% interest in the Burchfield Limited Partnership since October 1, 2005. a. David E. Burchfield, Sr. has had a 95% interest in the Partnership at all times relevant to this investigation. b. The remaining five (5) percent ownership is held by Burchfield's wife, Linda Burchfield, and their children. 9. Blair Township is primarily a rural township near the communities of Duncansville, Hollidaysburg and Roaring Springs. a. Prior to 2006, the Township did not have any fire protection based within the geographical boundaries of the Township. b. The Township's fire and emergency response needs were split [among] five volunteer fire companies from the surrounding communities and townships based on the location of the call. c. Five volunteer fire companies provided services to Blair Township residents including the Duncansville Volunteer Fire Company (DVFC), Hollidaysburg Burchfield, 07 -089 Page 4 (Phoenix), Geeseytown, Roaring Springs and Freedom (Freedom Township). d. Of the five volunteer fire companies providing services within Blair Township, the DVFC received the most emergency calls. 10. Prior to 2006, Blair Township would contribute to all five volunteer fire companies which provided services to portions of the Township. a. The Township split State funding it received from the Fire Relief Association Fund for fire protection equally among the companies to cover the cost of workers compensation insurance. b. The Township also would make an annual donation of approximately $3,262.50 to four (4) of the five (5) volunteer fire companies serving the Township. 1. The Friendship Volunteer Fire Company received $1,450.00 annually based on a smaller coverage area. 11. Around April of 2005, discussions by the Board of Supervisors began regarding determining a primary and backup company for emergency calls within Blair Township. a. As of April 14, 2005, Blair Township did not have a primary volunteer fire company designated to be the first responder for fire emergency calls throughout the entire Township. b. Primary and back -up responding companies were called based on the location of the incident. c. At that time, a 9 -1 -1 dispatcher would make the determination based on the location of the call with each company having designated call boxes covering specific portions of the Township. d. The Township was receiving complaints from the volunteer fire companies regarding the number of dispatch calls they were receiving and the amount of contributions being received from the Township. 12. The Duncansville Fire Company #1, d /b /a The Duncansville Volunteer Fire Company (DVFC) was receiving in excess of fifty percent of the emergency calls within Blair Township at the time based on coverage area. a. The DVFC did not have a station or substation within the geographical boundaries of Blair Township in 2005. 13. Minutes from the April 14, 2005, Blair Township Board of Supervisors Meeting confirm discussions regarding designating primary and backup fire companies for each part of the Township. a. A map of the Township was to be distributed by Supervisor Burchfield to each of the five fire companies to determine which companies could best serve an area. 14. The Pennsylvania General Assembly enacted Act 222 of 2004, Emergency and Municipal Services Tax, with an effective date of January 1, 2005. a. This amended the Local Tax Enabling Act, Act 511 of 1965, to permit Burchfield, 07 -089 Page 5 municipalities and school districts (except the Pittsburgh School District) to impose a combined Emergency and Municipal Services Tax (EMS tax) of up to $52.00 a year beginning on and after January 1, 2005. b. The EMS tax replaced the occupational privilege tax. c. The total EMS tax paid by any individual in a calendar year is limited to $52.00, regardless of the number of political subdivisions in which an individual works during the year. 15. During the Supervisors October 13, 2005, meeting, Dave Skurnick, Treasurer of the Duncansville Volunteer Fire Company, attended the meeting seeking funding for the fire company. a. Burchfield suggested the fire company look into acquiring grant funds to be used toward building a new fire station. b. Burchfield also suggested an increase in the Township's Occupational Privilege Tax to help support the fire company. c. At that time, Blair Township's Occupational Privilege Tax was set at $10.00 per year. d. During this same meeting, Skurnick requested that the Board distribute the Fireman's Relief Funds to the five fire companies based on the percentage of the Township which each serves instead of equally as has been past practice. 16. David Skurnick again addressed the Board of Supervisors during the December 8, 2005, meeting to request that the Township increase the Emergency Municipal Tax from $10.00 to $52.00 per year with $42.00 of that amount to be provided to the DVFC. a. At the time, Blair Township was only collecting $10.00 per year out of an allowable $52.00 per year. b. After discussion, Chairman Burchfield made a motion to support the Duncansville Volunteer Fire Company for a substation to be located in Blair Township. Supervisor Brown seconded the motion to approve the proposed substation plan and it passed with a unanimous vote. c. No action was taken at this meeting on Skurnick's EMS Tax allocation request; however, the Supervisors did vote to support the DVFC to locate a substation in Blair Township. 17. During the Board of Supervisors January 3, 2006, meeting, the Board approved setting the Township's EMS Tax at $39.00 annually instead of the $52.00 requested by the DVFC. a. The Board of Supervisors did not make a determination at that meeting on how the $39.00 tax would be distributed. b. Supervisor Bush suggested the Board set the E.M.S. Tax amount at $39.00 annually per person employed in the Township, which is two - thirds of the $52.00 maximum. c. Chairman Burchfield made a motion to set the E.M.S. Tax amount at $39.00 Burchfield, 07 -089 Page 6 for persons employed in the Township earning $12,000.00 or more annually and persons earning less than $12,000.00 would pay $10.00 annually. Supervisor Bush seconded the motion. The motion passed with a unanimous vote. 18. The Blair Township Board of Supervisors officially adopted ordinance number 2006- 01 establishing the Emergency and Municipal Services Tax and repealing the Occupational Privilege Tax during [its] February 9, 2006, meeting. a. Supervisor Burchfield made the motion to approve the ordinance, seconded by Supervisor Bush. "Supervisor Brown expressed his opinion that the Board may be premature in approving this due to the number of issues still being decided on by the State regarding the Municipal Services Tax. Persons employed in the township earning $12,000.00 and greater will pay $39.00 annually. Persons employed in the township earning less than $12,000.00 will pay $10.00 annually. Exemptions are those employees under 18 years of age and those that have turned 65 years of age prior to January 1 The E.M.S. Tax will be used strictly for Police, Fire, and Emergency Services. Ordinance No. 2006 -01 passed with 2 -yes votes. Supervisor Brown voted no." 19. On January 9, 2006, the DVFC submitted a letter of intent to locate a fire substation within Blair Township to the Board of Supervisors. a. In addition to advising of its intent to locate a substation within Blair Township, DVFC requested being designated the exclusive fire company for the Township. 20. The DVFC's letter of intent to locate a substation within Blair Township was discussed during the February 9, 2006, Board of Supervisors meeting. a. During that meeting, Burchfield participated in a lengthy discussion on the DVFC's letter of intent, coverage areas and the designation of a primary fire company for the Township. b. Burchfield suggested that the Board hold off on signing the Letter of Intent for six months to a year due to the rumors that are circulating, stating that this would allow an opportunity to get some money together to be able to buy something. c. Eric Schmidt of Phoenix Volunteer Fire Company commented that Blair Township would benefit from a regionalization plan allowing all five volunteer companies to serve the area. 1. Chairman Burchfield stated that he would look into this and review it with the Solicitor. Mr. Schmidt requested that in the near future the Board of Supervisors would sit down and discuss a solution with the five volunteer fire companies. 21. Between January and April 2006, representatives from the Hollidaysburg (Phoenix) Volunteer Fire Company appeared before the Board of Supervisors requesting regional fire coverage within the Township. a. Regionalizing the fire protection was discussed during the Board of Supervisors February 9, 2006, meeting and March 9, 2006, meeting. b. Burchfield was present for and participated in these discussions in his official Burchfield, 07 -089 Page 7 capacity as a member of the Township Board of Supervisors. 22. During the January to March 2006 time frame, representatives of the DVFC met with Burchfield privately to discuss leasing a building from Burchfield within the Township to serve as the temporary location of the DVFC's Blair Township Substation. 23. Between February 9, 2006, and May 11, 2006, Dave Skurnick located a building deemed suitable for use as a temporary substation within Blair Township. a. The physical location of the building was 1624 Old Route 220, Duncansville, PA. b. The property included a large block building and acreage. c. The property was adjacent to David Burchfield's salvage yard. d. The building had a for lease sign on it. 24. Skurnick discussed the property with DVFC Assistant Chief William Lloyd. a. Lloyd contacted Burchfield, Sr. inquiring who owned the property. b. Burchfield, Sr. advised Lloyd that it was owned by his family and that it was available if the DVFC was interested. c. The DVFC and Burchfield, Sr. negotiated a rental rate of $2,000.00 per month. 25. The DVFC wanted the financial support from Blair Township in order to locate a substation within the Township. a. The DVFC did not have sufficient financial resources to pay rent for a building without additional financial support from Blair Township or undertaking a large fundraising campaign. b. At the time of the property search, the DVFC had a commitment from the Township to support its efforts to locate a substation within the Township. 1. During the December 28, 2005, meeting of the Board of Supervisors, Burchfield's motion was approved to support DVFC establishing a substation in Blair Township. 26. During the Supervisors May 11, 2006, meeting, it was publicly announced that the DVFC located a building to lease on a temporary basis. a. The building's location (1624 Old Route 220, Duncansville, PA) was discussed along with action by the Board of Supervisors to approve $29.00 of the $39.00 EMS Tax collected to be given to the DVFC to establish a substation within the Township's geographical boundaries. 1. Supervisor Bush made a motion to [proceed] with making Duncansville Volunteer Fire Company Blair Township's primary fire company and forwarding the $29.00 portion of the E.M.S. tax to them. The $29.00 portion of the tax would be forwarded April 30, July 31, October 31, and January 31, following the closing of the Township's quarterly collections. Chairman Burchfield seconded the motion. The Burchfield, 07 -089 Page 8 motion passed by unanimous vote. b. Burchfield addressed the Board indicating that the property in question was owned by D.R.T.J. Partnership. 1. Burchfield disclosed to the Board that this was a partnership of his family. 2. D.R.T.J. is a non - existent partnership. 3. Burchfield did not disclose that he had an ownership interest in the property to be leased to the DVFC. c. Supervisor Brown suggested that Solicitor Gieg verify that there is no conflict involved regarding the building being leased. 1. Solicitor Gieg stated that he needs to see a copy of the lease. 2. The Duncansville Fire Company was instructed to provide Solicitor Gieg with a copy of the lease agreement. 27. The property at 1624 Old Route 220, Duncansville is owned by the Burchfield Limited Partnership. a. Respondent David E. Burchfield, Sr. is the General Partner holding a 95% interest in the Partnership. 28. Ownership of the property at 1624 Old Route 220, Duncansville, PA was transferred from David E. Burchfield and Linda L. Burchfield, husband and wife, to the Burchfield Limited Partnership on December 19, 2005. a. This transfer occurred eleven (11) days after Burchfield, Sr. participated in Board action taken in support of the DVFC locating a substation within Blair Township. 29. The D.R.T.J. Partnership referenced by Burchfield, Sr. during the May 11, 2006, meeting of the Board of Supervisors does not exist. a. D.R.T.J. Partnership is not registered with the Pennsylvania Department of State Corporation Bureau. b. D.R.T.J. are the first letters of the first names of four (4) of the five (5) one percent partners of the Burchfield Limited Partnership as noted below: (D) David E. Burchfield, Jr. (R) Richard Burchfield (T) Tina Burchfield (J) Jody Reading c. Excluded from the initials was David Burchfield, Sr. and his wife Linda Burchfield. 30. Blair Township tax records identify the property at 1624 Old Route 220 Duncansville, PA as being owned by the Burchfield Limited Partnership. a. This property is identified as tax parcel number 0400- 03 -26 -2. Burchfield, 07 -089 Page 9 b. Tax bills are sent to the Burchfield Limited Partnership, 713 Route 764, Duncansville, PA 16635. c. This property has never been owned by the D.R.T.J. Partnership. 31. During the May 24, 2006, Board of Supervisors meeting, Dave Skurnick updated the Board of Supervisors on the search for property to locate a substation within the Township. Minutes include the following: a. Mr. Skurnick stated that representatives from the fire company have met and talked with representatives from the Burchfield organization regarding the lease for the building on Old Route 220. The plan is to have a five -year, open -ended lease. This would allow the fire company flexibility in case a more suitable property or location would become available. Mr. Skurnick stated that the lease will enhance the project, allowing them to apply for grants, etc. Mr. Skurnick requested that the Board make a five -year commitment to give the Duncansville Volunteer Fire Department the EMS tax for the next five years. b. Solicitor Gieg recommended that the tax commitment be voted on yearly stating that he does not know legally how the commitment can be made for five years. Chairman Burchfield asked Solicitor Gieg to look into this. Solicitor Gieg stated that he has not yet received a copy of the lease to review. c. It was agreed by the Board that a commitment has already been made to support the establishment of the fire company at the proposed location. Supervisor Bush commented that the next meeting is scheduled for June 8 th and requested that possibly prior to that meeting the lease could be given to Solicitor Gieg to review. 32. The only representative of the Burchfield Organization Skurnick met with regarding the lease was David Burchfield, Sr. 33. During August 10, 2006, the building improvements were discussed and a conflict of interest for Burchfield was raised. a. Skurnick updated the Board on the improvements to the leased building. He advised the Board how much the volunteer fire company counts on their support. b. Solicitor Gieg stated that he reviewed the rough draft of the lease agreement for the substation and recommended that the volunteer fire company have [its] solicitor review it. The lease agreement is between the property owner and the fire company and does not involve Blair Township. c. A lengthy discussion ensued between Mr. Elder and Chairman Burchfield over the ownership of the building being leased by the volunteer fire company. Supervisor Brown commented that he did ask Solicitor Gieg if there was a conflict of interest and Solicitor Gieg told him that this was not a conflict of interest. d. Supervisor Bush commented that she did not see this as a conflict of interest. She was aware that the volunteer fire company researched finding a piece of ground, noting that she was involved in numerous pieces that they tried to agree upon. Supervisor Bush stated that she thinks the fire company discovered the building. Burchfield, 07 -089 Page 10 e. Supervisor Brown stated that if the Township leased that building that it would be a conflict of interest, but since it is the fire company leasing it, it is not a conflict of interest. f. Chairman Burchfield confirmed with Mr. Skurnick that, to date, no lease agreement has been signed. 34. The DVFC did not execute a lease with Burchfield, Sr., d /b /a the Burchfield Limited Partnership. a. All discussions and negotiations as part of the lease were handled between DVFC representatives and Burchfield, Sr. b. No other representative of the Burchfield Limited Partnership participated in any lease negotiations. c. No formal lease was ever signed. 35. Business records of the Burchfield Limited Partnership include an unsigned commercial lease agreement dated July 1, 2006, between the Burchfield Limited Partnership and the Duncansville Volunteer Fire Company d /b /a as Blair Township Fire Company for land and improvements known as 1624 Old 220 South, Duncansville, PA 16635 containing a 6,150 square foot concrete building with a flat roof. a. The lease term is July 1, 2006, through June 30, 2011, with a five year renewal option. b. Rent is specified during the initial term as $24,000.00 annually, payable in monthly installments of $2,000.00 to the landlord at 713 Route 764, P.O. Box 178, Duncansville, PA 16635. c. The lease was never signed by any representatives of either DVFC or Burchfield. 36. Based on concerns over a potential conflict of interest for Burchfield, the Board of Supervisors sought legal opinions from its Solicitor, Frederick Gieg, Esquire, and the Pennsylvania State Association of Township Supervisors. 37. On August 18, 2006, Solicitor Frederick Gieg, Esquire, issued the following opinion on the matter of Burchfield leasing property to the DVFC to the Township Board of Supervisors: In that this Lease is between the Duncansville Volunteer Fire Company and not the Township, but with a corporate entity of the Burchfield family, I see no direct conflict. However, I have advised the Duncansville Volunteer Fire Company to have their own Solicitor directly review the Lease with the Burchfield entity so that there is no conflict of interest. In that Township monies will be paid to the Duncansville Volunteer Fire Company who will then possibly use some of those monies to pay the rent, I would want the Duncansville Volunteer Fire Company's Solicitor to write an opinion that there is no conflict in an indirect manner. I enclose the conflict section that could indirectly be involved." a. Attached to Solicitor Gieg's memo was a [reference to] "subsection (c), *" No Public Official or Public Employee or member of his immediately family or any other business in which the person or a member of the person's Burchfield, 07 -089 Page 11 immediate family is a Director, Officer, Owner or Holder of stock exceeding 5% of the equity at fair market value of the business shall enter into any contract valued at $500.00 or more with a governmental body unless the contract has been awarded through an open and public process, including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. Any contract made in violation of the subsection shall be voidable by a court of competent jurisdiction if the suit is commenced within 90 days of the making of the contract. * [sic]. [The Solicitor's characterization of Section 1103(f) of the Ethics Act is not accurately stated.] b. No citation is provided with the attachment Solicitor Geig provided to the Board of Supervisors. Geig intended to cite section 1103(f) of the State Ethics Act, not subsection (c). 38. Burchfield did not publicly disclose during any Board of Supervisors meeting that he is a 95% owner of the Burchfield Limited Partnership, the entity owning 1624 Old Route 220, Duncansville, PA. a. Burchfield told representatives of the DVFC and the public that the property was owned by his children. b. Burchfield identified the family partnership of D.R.T.J. 1. No such partnership exists. 39. In addition to Solicitor Geig's opinion, Township Secretary /Treasurer Betty Robertson contacted the State Association of Township Supervisors (PSATS) to determine if a conflict of interest existed regarding Burchfield's contract to lease property to the DVFC. a. Robertson sent a memo to the Board of Supervisors and Solicitor dated August 14, 2006, outlining the information she received from PSATS. Robertson's memo read as follows. At the request of Arlene, I called PSATS Friday (8/11) to get an opinion on the `conflict issue' regarding the building being leased by the DVFC. I talked to `Lisa' in the legal department. I explained (to the best of my knowledge) the ownership of the building, who was writing the check to lease the building and that the Township gives our EMS money to the DVFC and that those funds are then distributed by the DVFC. Lisa was unsure and checked with the Assistant Executive Director who in turn was of the opinion that `there is an appearance of a conflict' but that as long as the Township `does not own' the DVFC it is not a conflict. A conflict involves the Supervisor himself, his spouse, his children, his parents, and brothers and sisters - all of these family members are regarded as one -in- the -same. If a transaction between the Township and the payee directly involves any of these parties or their businesses, unless bids are taken, it is a conflict." 40. The DVFC has been using the property at 1624 Old Route 220, Duncansville to serve as a substation within Blair Township since approximately July 1, 2006. a. Rent was paid at a rate of $2,000.00 per month. 41. Blair Township was the source of funding used by the DVFC to pay rent to the Burchfield Limited Partnership for 1624 Old Route 220, Duncansville, PA. Burchfield, 07 -089 Page 12 a. Funding came as a result of the EMS Tax and general donations from the Township. b. Funding to the DVFC was approved as part of annual Township budgets and approval of monthly bill lists which authorized funding. 42. Burchfield, d /b /a the Burchfield Limited Partnership, was accepting rental payments from the DVFC during 2006 and 2007 while at the same time participating in Board actions to provide funding to the DVFC in the form of EMS /Local Services Tax allocations. 43. The Township budget for 2007 was approved by the Board during [its] December 14, 2006, meeting. a. Minutes from that meeting reflect "Chairman Burchfield made a motion to approve the 2007 budget as presented and reviewed at the special meeting of November 14, 2006. Supervisor Brown seconded the motion. The motion passed with a unanimous vote." 44. The Board of Supervisors discussed the E.M.S. Tax rate during [its] January 2, 2007, meeting. a. During the meeting, the Board set the rate for the EMS Tax for calendar year 2007. b. Minutes of the January 2, 2007, meeting confirm that Burchfield participated in the relevant discussion and official vote taken as follows: "Chairman Burchfield made a motion to reaffirm distribution of the E.M.S. Tax; $10.00 is to be deposited in the General Fund Account and the remaining $29.00 is to be paid to Blair Township's Primary Volunteer Fire Company. Supervisor Bush seconded the motion. The motion passed with a unanimous vote." 45. During the May 10, 2007, Board meeting, Burchfield participated in actions taken to designate the "Blair Township /Duncansville Volunteer Fire Department as the primary fire company for Blair Township." Minutes included the following official action and explanation for the designation: "Chairman Burchfield made a motion to approve Resolution No. 2007 -09 designating the Blair Township /Duncansville Volunteer Fire Department as the primary fire company for Blair Township. Supervisor Bush seconded the motion. Solicitor Gieg explained that the Resolution is to approve the activity that the Volunteer Firemen can be involved in and also to specify that currently the Workmen's Compensation is paid by the Borough of Duncansville. The Resolution will aid the VFC in applying for a legal name and also in applying for grant money. The motion passed with unanimous vote." a. The DVFC was initially designated the primary fire company for Blair Township on May 11, 2006. 46. During the September 19, 2007, Board Meeting, Burchfield participated in Board action changing the Emergency and Municipal Services Tax to the Local Services Tax and establishing the rates and allocation for 2008. a. The Board discussed the Emergency and Municipal Services Tax, to be known as the Local Services Tax, beginning on 01/01/2008. Burchfield, 07 -089 Page 13 b. Supervisor Bush made a motion to approve an annual amount of $52.00 for persons earning over $12,000.00 and employed in Blair Township. Chairman Burchfield seconded the motion. This change will take effect on 01/01/08. The motion passed with a unanimous vote. c. Supervisor Bush suggested that $30.00 be allocated to the Blair Township /Duncansville Volunteer Fire Department, $11.00 be allocated to the Blair Township Police Department and the remaining $11.00 be allocated to the Blair Township Highway Department. Chairman Burchfield made a motion to approve the suggested distribution. Supervisor Brown seconded the motion. The motion passed with a unanimous vote. 47. Burchfield participated in Board action taken on October 11, 2007, approving Township Ordinance 2007 -05 establishing the Local Services Tax. a. This ordinance was passed by a 3 -0 vote. b. This ordinance repealed the former Emergency and Municipal Services Tax. 48. Burchfield participated in Board actions taken on January 7, 2008, to reappoint the Duncansville Volunteer Fire Company as Blair Township's primary volunteer fire company and reaffirm the distribution of the EMS Tax to include DVFC as follows: a. Designation of primary volunteer fire company: "Supervisor Bush made a motion to reappoint Duncansville Volunteer Fire Company as Blair Township's Primary Volunteer Fire Company. Chairman Burchfield seconded the motion. The motion passed with a unanimous vote." b. Distribution of 2008 EMS Tax: "Chairman Burchfield made a motion to reaffirm distribution of the E.M.S. Tax; $11.00 is designated for the Police Department, $11.00 is designated to the Highway Department and $30.00 is to be paid to Blair Township's Primary Volunteer Fire Company. Supervisor Bush seconded the motion. The motion passed with a unanimous vote." 49. Burchfield participated in Board actions taken during the February 12, 2008, meeting to approve the Township's 2008 operating budget. a. This budget included anticipated funding from [the] EMS /Local Services Tax to the DVFC of approximately $72,000.00. 50. Records of the DVFC include the following total revenue and disbursements of funds received from Blair Township since 2006: Revenue Donations - Municipalities Donations - General Interest Income Total Revenue Disbursements General Supplies 2006 2007 $ 62,843 $77,850.50 $ 0.00 $ 1,000.00 $ 338.07 $ 1,627.84 $63,843.00* $80,478.34 $ 1,451.66 $ 295.50 2008 to date $ 3,262.50 $ 0.00 $ 240.84 $ 3,503.34 $ 143.22 Burchfield, 07 -089 Page 14 Telephone Administrative Fire Equipment Building Rent Property /Maintenance Utilities Total Disbursements * [sic]. [The noted calculations contain discrepancies that do not affect the outcome of this case.] 51. DVFC records confirm payments received from Blair Township as a result of the EMS Tax and general donations. Payments received occurred on the following dates: Date Amount 01/26/06 $31,349.00 11/27/06 $31,494.00 01/06/07 $ 3,262.50 05/05/07 $ 6,670.00 08/06/07 $59,102.00 11/23/07 $ 8,816.00 01/22/08 $ 3,262.50 Total $143,956.00 Check Date Check # 06/12/06 4467 11/24/06 3101 12/27/06 3148 04/27/07 3355 07/27/07 3531 11/13/07 3717 12/27/07 3811 $ 219.78 $ 365.65 $ 90.91 $ 79.28 $ 6.04 $ 3,378.94 $ 3,318.12 $ 6,603.67 $ 0.00 $14,000.00 $ 8,000.00 $ 0.00 $12,062.50 $ 6,000.00 $64,000.00 $ 609.09 $ 2,773.29 $ 594.85 $31,738.43* $24,044.15 $68,207.52* Source EMS Tax EMS Tax EMS Tax EMS Tax EMS Tax EMS Tax General Donation 52. Of the $143,956.00 received by the DVFC from Blair Township, $140,693.50 was as a result of the EMS Tax collected. a. The remaining $3,262.50 was in the form of a general donation. 53. Burchfield regularly participated in the approval of Township bill lists which included funding for the DVFC. a. Since July 13, 2006, Burchfield participated in seven (7) separate Board of Supervisors actions taken approving payments totaling $143,956.00 made to the DVFC as follows: Amount $31,349.00 $31,494.00 $3,262.50 $6,670.00 $59,102.00 $8,816.00 $3,262.50 Meeting Date 07/13/06 12/14/06 01/11/07 05/10/07 08/09/07 12/11/07 01/08/08 Blair Twp Check # 4467 3101 3148 3355 3531 3717 3811 Action Vote Motion, Vote Motion, Vote Vote Motion, Vote Motion, Vote Motion, Vote Signed Bush, Robertson Bush, Robertson Bush, Robertson Bush, Robertson Bush, Robertson Bush, Robertson Bush, Robertson Recorded Vote 3 -0 3 -0 3 -0 3 -0 3 -0 3 -0 3 -0 54. The Duncansville Volunteer Fire Company received invoices from the Burchfield Limited Partnership for the lease of the property at 1624 Old Route 220, Duncansville. a. Since December 11, 2006, three (3) invoices totaling $22,000.00 were received. b. These invoices covered rents due from July 1, 2006, through April 2007. Burchfield, 07 -089 Page 15 c. No invoices were received by DVFC from Burchfield after April 2007. 1. The State Ethics Commission investigation of Burchfield was initiated on July 12, 2007. d. No invoices were received from the D.R.T.J. Partnership. 55. Rental invoices were received by DVFC from the Burchfield Limited Partnership as follows: a. Date Amount Months 12/11/06 $9,000.00 12/11/06 $4,000.00 04/11/07 $4,000.00 b. The December 11, 2006, invoice in the amount of $9,000.00 reflected a $5,000.00 payment previously being made by the DVFC. 56. Financial records of the DVFC confirm that a total of $22,000.00 in rental payments were made to the Burchfield Limited Partnership for the use of building #5, 1624 Old Route 220, Duncansville between November 2006 and May 2007. Payments were made as follows: a. Date Ch. # Amount 11/15/06 1010 $5,000 12/13/06 1008 $9,000 02/12/07 1016 $4,000 05/18/07 1025 $4,000 Total $22,000 b. c. b. c. July 1, 2006 — December 2006 January 2007 — February 2007 March 2007 — April 2007 Bank Susquehanna Bank Reliance Bank Reliance Bank Reliance Bank Endorsed Burchfield Ltd. Partnership Burchfield Ltd. Partnership Burchfield Ltd. Partnership Burchfield Ltd. Partnership These funds were received by David Burchfield, Sr., d /b /a the Burchfield Limited Partnership. No rental payments were made to the D.R.T.J. Partnership. 57. Burchfield utilized a portion of the $22,000.00 received from the DVFC for improvements, utilities, taxes, and upkeep at building #5 for DVFC use. a. Taxes: Tax Year: 2006 Hollidaysburg Area School District: Blair Township /Blair County $ 1,553.83 $ 511.39 $ 2,065.22 Tax Year: 2007 Hollidaysburg Area School District: Blair Township /Blair County Total taxes paid: $4,289.18 Electrical Upgrade: Rick Gonsman, Invoice no. 287425: $196.00 Water and Sewer: $1,619.08 $ 604.88 $2,223.96 Burchfield, 07 -089 Page 16 Water Service Sewer Service Date Amount Date Amount 02/11/07 $ 26.50 03/31/07 $47.00 03/01/07 $ 20.00 04/30/07 $47.00 04/01/07 $ 26.50 06/30/07 $47.00 05/01/07 $156.50 08/31/07 $47.00 06/01/07 $ 46.00 09/30/07 $47.00 07/31/07 $ 98.00 10/31/07 $47.00 08/31/07 $ 20.00 11/30/07 $47.00 09/01/07 $ 20.00 $329.00 10/01/07 $ 20.00 11/01/07 $ 20.00 $453.50 Total water /sewer utilities paid: $782.50. d. Electric: Date Amount 01/04/07 $55.17 02/02/07 $97.21 03/06/07 $73.89 04/04/07 $66.37 05/03/07 $65.69 06/05/07 $45.48 07/05/07 $46.56 08/02/07 $49.42 09/05/07 $53.78 10/04/07 $46.91 11/02/07 $50.43 12/03/07 $51.62 Total $702.53 e. Furnace: Power Wash, Inc. $7,547.76 58. All of the proceeds received from the DVFC for the rental of property at 1624 Old Route 220 were retained by David Burchfield, Sr. a. This income was included on joint tax returns filed by David Burchfield, Sr. along with his wife, Linda Burchfield. b. No portion of the rental payments were provided to any of the 1`)/0 partners of Burchfield Limited Partnership. 1. Linda Burchfield does hold a one percent interest in the Partnership. 59. Burchfield disclosed income received from the DVFC on PA Schedule E of his federal tax return filed for 2006. a. Burchfield reported income for Property B, Building 5, 1624 Old Route 220, Duncansville, PA of $19,000.00. He reported deductions for repairs in the amount of $196.00, utilities of $156.00 and depreciation expenses of $4,370.00 for total expenses of $4,722.00. Adjusted income of $14,278.00 was reported. Burchfield, 07 -089 Page 17 b. A net gain of $14,278.00 was reported on form 8582AMT. c. The amount of $14,278.00 is also listed as a gain on Form 8582, Capital Gains /Losses. 60. Burchfield disclosed income received from the DVFC on IRS form 4562, Depreciation and Amortization form, filed by the Burchfield Limited Partnership for calendar year 2007. a. Form 4562 identifies four (4) properties for the Burchfield Limited Partnership. 1. Property E Commercial Property — Building 5; 1624 Old Route 220, Duncansville, PA. 2. Property F Residential Property, 169 Maple Hollow Road, Duncansville, PA. 3. Property G Commercial, Inlows Drive, Duncansville, PA. 4. Property H Residential Property, 152 Maple Hollow Road, Duncansville, PA. b. Burchfield reported income from Property E, Building 5, 1624 Old Route 220, Duncansville, PA of $8,000.00. He reported deductions for taxes in the amount of $2,224.00, utilities of $830.00 and depreciation expenses of $5,452.00. 61. Burchfield's reported expenses on 1624 Old Route 220, Duncansville, PA exceeded gross rents by $506.00 for 2007. a. This was as a result of Burchfield ceasing to charge the DVFC rent. 1. Burchfield quit charging the DVFC rent at about the time of the State Ethics Commission investigation. b. No rent has been paid by the DVFC to Burchfield since May 18, 2007. 62. Burchfield, in his official capacity as a Blair Township Supervisor, was annually required to file a Statement of Financial Interests form by May 1 containing information for the prior calendar year. a. Burchfield was annually provided with blank Statement of Financial Interests forms to complete by Township Secretary /Treasurer, Elizabeth Robertson. 63. Statement of Financial Interests forms on file with Blair Township include the following filings by David E. Burchfield, Sr. in his official capacity as Township Supervisor: a. Calendar Year: 2007 Filed: 02/04/08 b. Calendar Year: 2006 Filed: 02/13/2007 c. Calendar Year: 2005 Burchfield, 07 -089 Page 18 Filed: 04/10/2006 d. Calendar Year: 2004 Filed: 02/01/2005 e. Calendar Year: 2003 Filed: 01/13/2004 f. Calendar Year: 2002 Filed: 01/20/2003 g. Calendar Year: 2001 Filed: 01/23/2002 64. Burchfield did not report sources of income on Statements of Financial Interests filed for the 2007, 2006, 2005, 2004, 2003, 2002, and 2001 calendar years. a. On each form filed in the section titled direct /indirect sources of income Burchfield reported "See Attached List." b. No listing was attached to any form which reported sources of income. c. A listing was attached which reported real estate interests. d. Burchfield did not disclose income received from any of his private business interests. e. Burchfield did not disclose income in excess of $1,300.00 received from Blair Township. 65. Burchfield did not disclose his financial interest in the Burchfield Limited Partnership on Statements of Financial Interests filed for calendar years 2005 and 2006. a. Burchfield has had a 95% ownership interest in this entity since October 1, 2005. 66. Burchfield did not disclose his office of President of the Burchfield Organization, Inc. on his Statement of Financial Interests filed for calendar year 2006. a. Burchfield has been President of the Burchfield Organization, Inc. since approximately December 1994. III. DISCUSSION: As a Supervisor for Blair Township ( "Township "), Blair County, since approximately January 1998, Respondent David Burchfield, Sr. ( "Burchfield ") has at all times relevant to this matter been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. The allegations are that Burchfield violated Sections 1103(a), 1105(b)(5), 1105(b)(8), and 1105(b)(9) of the Ethics Act when he, as a Township Supervisor, used the authority of his office for the private pecuniary gain of himself, a member of his immediate family and /or a business with which he or a member of his immediate family is associated by conduct including, but not limited to, participating in actions and deliberations of the Board of Supervisors to designate the Duncansville Volunteer Fire Company ( "DVFC ") as the primary responding fire department /emergency responder for the Township, then Burchfield, 07 -089 Page 19 participating in actions and deliberations of the Board of Supervisors allotting funding to the DVFC from the Township's E.M.S. tax, and then subsequently entering into a contract /agreement with the DVFC, in excess of $500.00, to lease property /building space owned by Burchfield and /or members of his immediate family for use by the DVFC as a sub - station within the Township; and by failing to disclose on Statements of Financial Interests ( "SFIs ") filed for the 2002, 2003, 2004, 2005, 2006 and 2007 calendar years direct /indirect sources of income in excess of $1,300, his office, directorship, or employment in any business entity, and his financial interests in any legal entity engaged in business for profit. Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official /public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official /public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1105(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. Section 1105(b)(8) of the Ethics Act requires the filer to disclose on the SFI any office, directorship or employment in any business entity. Section 1105(b)(9) of the Ethics Act requires the filer to disclose on the SFI any financial interest in any legal entity engaged in business for profit. The term "financial interest" is defined in the Ethics Act as "[a]ny financial interest in a legal entity engaged in Burchfield, 07 -089 Page 20 business for profit which comprises more than 5% of the equity of the business or more than 5% of the assets of the economic interest in indebtedness." 65 Pa.C.S. § 1102. The parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. As noted above, Burchfield has served as a Township Supervisor since approximately January 1998. The Township Board of Supervisors consists of three Members. Professionally, Burchfield has business interests in the Burchfield Limited Partnership, the Burchfield Organization, Inc. ( "the Burchfield Organization "), and Burchfield Auto Sales. Burchfield has had a 95% interest in the Burchfield Limited Partnership since its creation on about October 1, 2005. Burchfield's wife and children hold the remaining 5% ownership interest in the Burchfield Limited Partnership. Burchfield is identified as the general partner of the Burchfield Limited Partnership on the limited partnership application filed with the Pennsylvania Department of State. The Burchfield Organization was incorporated in December 1994. Burchfield has been President of the Burchfield Organization since approximately December 1994. Burchfield is also the Chief Executive Officer and an employee of the Burchfield Organization. Prior to 2006, the Township did not have fire protection based within its geographical boundaries. The Township's fire and emergency response needs were split among five volunteer fire companies located in communities surrounding the Township. The 9 -1 -1 dispatcher made the determination as to which fire company to dispatch based upon the location of the call. The DVFC, one of the aforesaid five volunteer fire companies, received more than fifty percent of the emergency calls within the Township. In 2005, the DVFC did not have a station or substation within the geographical boundaries of the Township. Prior to 2006, the Township contributed funding to each of the aforesaid five volunteer fire companies. State funding the Township received from the Fire Relief Association Fund was divided equally among the aforesaid five volunteer fire companies to cover the cost of workers compensation insurance. The Township also made annual donations in the amounts of approximately $3,262.50 to four volunteer fire companies, and $1,450.00 to the remaining volunteer fire company, as it covered a smaller area. In April 2005, the Board of Supervisors began discussing designating one of the volunteer fire companies as a primary first responder and one or more of the other volunteer fire companies as backup(s) for emergency calls within the Township. At that time, the Township was receiving complaints from the volunteer fire companies regarding the number of dispatch calls and the amount of contributions from the Township. During the Board of Supervisors October 13, 2005, meeting, the DVFC Treasurer sought funding from the Township for the DVFC. The DVFC Treasurer requested that the Township distribute funding from the Fireman's Relief Funds to the five volunteer fire companies based upon the percentage of the Township that each volunteer fire company served, instead of equally as it had previously been distributed. Burchfield suggested that the DVFC attempt to acquire grant funds to be used to build a new fire station, and that the Township increase its Occupational Privilege tax, then set at $10.00 per year, to help support the DVFC. Burchfield, 07 -089 Page 21 At the Board of Supervisors December 8, 2005, meeting, Burchfield made a motion and voted in favor of supporting the DVFC in establishing a substation within the Township. Since January 1, 2005, municipalities and most school districts have been authorized to impose an Emergency and Municipal Services Tax ( "EMS tax ") of up to $52.00 per year. At the Board of Supervisors January 3, 2006, meeting, Burchfield made a motion and voted in favor of setting the EMS tax at $39.00 for persons employed in the Township earning $12,000 or more annually and at $10.00 for persons earning less than $12,000 annually. The motion passed by unanimous vote. At the January 3, 2006, meeting, the Board of Supervisors did not make a determination as to how the $39.00 EMS tax would be distributed among the volunteer fire companies. On January 9, 2006, the DVFC submitted a letter of intent to the Board of Supervisors, informing the Supervisors of its intent to locate a fire substation within the Township and requesting to be designated the exclusive fire company for the Township. The DVFC's January 9, 2006, letter of intent was discussed during the Board of Supervisors meeting on February 9, 2006. During the meeting, Burchfield participated in a lengthy discussion regarding the DVFC's letter of intent, coverage areas, and the designation of a primary fire company for the Township. Burchfield suggested that the Board of Supervisors wait to sign the DVFC's letter of intent for six months to a year. Burchfield agreed to examine the possibility of a regionalization plan that would allow all five volunteer fire companies to serve the Township. Also during the February 9, 2006, Board of Supervisors meeting, Burchfield made a motion and voted to approve an ordinance officially repealing the Occupational Privilege tax and establishing the EMS tax at $39.00 for persons employed in the Township earning $12,000 or more annually and at $10.00 for persons earning less than $12,000 annually. The EMS tax was to be used for police, fire, and emergency services. The ordinance was approved by a 2 -1 vote. Between January and April 2006, Burchfield, as a Township Supervisor, participated in discussions regarding regionalization of fire coverage within the Township. Meanwhile, during the January to March 2006 time frame, representatives of the DVFC met with Burchfield privately to discuss leasing a building from Burchfield within the Township to serve as the temporary location of the DVFC's Blair Township substation. Between February 9, 2006, and May 11, 2006, the DVFC Treasurer located a property /building space (hereinafter referred to as the "Property ") deemed suitable for DVFC's use as a temporary substation within the Township. The Property was adjacent to Burchfield's salvage yard and displayed a for lease" sign. The DVFC Assistant Chief contacted Burchfield to ascertain the identity of the owner of the Property. Burchfield informed the DVFC Assistant Chief that the Property was owned by Burchfield's family and was available. Burchfield and the DVFC negotiated a monthly rental rate of $2,000.00 for the Property. The Property is owned by the Burchfield Limited Partnership. Burchfield and his wife transferred ownership of the Property to the Burchfield Limited Partnership on December 19, 2005, eleven days after Burchfield participated in the action of the Board of Supervisors supporting the DVFC in establishing a substation within the Township. During the Board of Supervisors May 11, 2006, meeting, it was publicly announced that the DVFC had located a building, at the Property address, to lease on a temporary basis. Burchfield seconded a motion, and the Supervisors unanimously voted, to designate the DVFC as the primary fire company for the Township and to forward a $29 portion of the $39 EMS tax to DVFC to establish a substation within the Township's Burchfield, 07 -089 Page 22 geographical boundaries. During the May 11, 2006, meeting, Burchfield addressed the Board of Supervisors and indicated that the Property was owned by D.R.T.J. Partnership ( "D.R.T.J. "), a partnership of his family. Supervisor Brown suggested that the Solicitor verify there was no conflict involved regarding the building being leased. Per the Stipulated Findings, D.R.T.J. does not exist and has never owned the Property. Burchfield never publicly disclosed during any Board of Supervisors meeting that he was a 95% owner of the Burchfield Limited Partnership, the entity that owned the Property, but told representatives of the DVFC and the public that the Property was owned by his children. At the Board of Supervisors May 24, 2006, meeting, the DVFC Treasurer stated that representatives from the DVFC had met with representatives from the Burchfield Organization regarding the lease of the Property. The DVFC Treasurer requested that the Board of Supervisors make a commitment to provide the DVFC with the EMS tax for the next five years. Burchfield asked the Township Solicitor to review whether the Township could make such commitment to the DVFC. At the Board of Supervisors August 10, 2006, meeting, the issue of whether Burchfield would have a conflict of interest as to the DVFC's lease of the Property was discussed. Based on concerns regarding a potential conflict of interest for Burchfield, the Board of Supervisors sought legal opinions from its Solicitor and the Pennsylvania State Association of Township Supervisors ( "PSATS "). On August 18, 2006, the Township Solicitor issued his opinion that because the lease would be between a corporate entity of the Burchfield family and DVFC, not the Township, he did not see a direct conflict of interest. The Township Solicitor also recommended that the DVFC Solicitor review the lease to determine whether a conflict of interest would exist. The Township Secretary /Treasurer contacted PSATS and issued a memorandum to the Board of Supervisors and Township Solicitor regarding that conversation. All discussions and negotiations with regard to the lease of the Property were handled between DVFC representatives and Burchfield. No other representative of the Burchfield Limited Partnership participated in any lease negotiations. Business records of the Burchfield Limited Partnership include an unsigned commercial lease agreement for the Property dated July 1, 2006, between the Burchfield Limited Partnership and the DVFC d /b /a as Blair Township Fire Company. The lease term is July 1, 2006, through June 30, 2011, with a five year renewal option. Rent is specified during the initial term as $24,000.00 annually, payable in monthly installments of $2,000.00. The lease was never signed by either Burchfield or representative(s) of DVFC. The DVFC has used the Property to serve as a substation within the Township since approximately July 1, 2006. The EMS tax and general donations from the Township were used by the DVFC to pay rent for the Property. Burchfield, doing business as the Burchfield Limited Partnership, accepted such rental payments from the DVFC. Burchfield, as a Township Supervisor, also participated in the following actions of the Board of Supervisors pertaining to funding for the DVFC: 1. On December 14, 2006, Burchfield made a motion and voted to approve the 2007 budget, which included funding to the DVFC (the motion passed with a unanimous vote); 2. On January 2, 2007, Burchfield made a motion and voted to reaffirm Burchfield, 07 -089 Page 23 distribution of the EMS tax so that $10.00 of the EMS tax would be deposited in the General Fund Account and the remaining $29.00 of the EMS tax would be paid to the Township's primary volunteer fire company (the motion passed with a unanimous vote); 3. On May 10, 2007, Burchfield made a motion and voted to approve a Resolution officially designating the Blair Township /Duncansville Volunteer Fire Department as the primary fire company for the Township (the motion passed with a unanimous vote); 4. On September 19, 2007, Burchfield seconded a motion and voted to replace the EMS tax with a "Local Services tax" commencing January 1, 2008, in the amount of $52.00 for persons employed in the Township earning over $12,000.00 (the motion passed with a unanimous vote); 5. On September 19, 2007, Burchfield also made a motion and voted to allocate $30.00 of the $52.00 local services tax to the Blair Township /Duncansville Volunteer Fire Department (the motion passed with a unanimous vote); 6. On October 11, 2007, Burchfield voted to pass an ordinance formally establishing the Local Services tax and repealing the former EMS tax (the ordinance was passed with a unanimous vote); 7 On January 7, 2008, Burchfield seconded a motion and voted to reappoint DVFC as the Township's primary volunteer fire company (the motion passed with a unanimous vote); 8. On January 7, 2008, Burchfield also made a motion and voted to reaffirm distribution of the $30.00 portion of the EMS /Local Services tax to DVFC (the motion passed with a unanimous vote); and 9. On February 12, 2008, Burchfield participated in actions of the Board of Supervisors to approve the Township's 2008 operating budget, which included anticipated funding in the approximate amount of $72,000.00 from the EMS /Local Services tax to the DVFC. Fact Finding 50 details revenue that the DVFC has received from the Township since 2006, as well as the DVFC's disbursements of such Township funds. Since July 13, 2006, Burchfield also regularly participated in the approval of Township bill lists which included funding for the DVFC. Burchfield participated in seven separate actions of the Board of Supervisors to approve payments totaling $143,956.00 to the DVFC, as detailed in Fact Finding 53a. Since December 11, 2006, the DVFC received three invoices totaling $22,000 from the Burchfield Limited Partnership for the lease of the Property, covering rents due from July 1, 2006, through April 2007. No invoices were received by DVFC from Burchfield after April 2007. The State Ethics Commission investigation of Burchfield was initiated on July 12, 2007. No invoices were received from the " D.R.T.J. Partnership." Between November 2006 and May 2007, the DVFC paid $22,000 in rental payments to the Burchfield Limited Partnership for use of the Property. These funds were received by Burchfield, doing business as the Burchfield Limited Partnership. No rental payments were made to the non - existent D.R.T.J. Partnership. Burchfield utilized a portion of the $22,000.00 received from the DVFC for Burchfield, 07 -089 Page 24 improvements, utilities, taxes, and upkeep to the Property. All of the proceeds received from the DVFC for rental of the Property were retained by Burchfield and reported on Burchfield's tax returns filed jointly with his spouse. Burchfield claimed a net gain of $14,278.00 for rental of the Property in 2006, and a loss of $506.00 for rental of the Property in 2007 as a result of Burchfield ceasing to charge the DVFC rent for its use of the Property. Burchfield, in his official capacity as a Township Supervisor, was required to annually file an SFI by May 1 containing information for the prior calendar year. Although Burchfield's SFIs for calendar years 2002 through 2007 were on file with the Township, Burchfield did not disclose the Township as a source of income in excess of $1,300 on such SFIs. In the section titled "direct /indirect sources of income," Burchfield wrote, "See Attached List" but did not attach any list reporting direct or indirect sources of income. Burchfield did not disclose income received from any of his private business interests. Burchfield failed to disclose his 95% ownership interest in the Burchfield Limited Partnership on his SFIs filed for calendar years 2005 and 2006 and did not did not disclose his office as President of the Burchfield Organization on his SFI for calendar year 2006. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: 3. The Investigative Division will recommend the following in relation to the above allegations: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1103(a) occurred in relation to Burchfield's participation in actions and deliberations of the Board of Supervisors to designate the Duncansville Volunteer Fire Company as the primary responding Fire Department /Emergency Responder for Blair Township; and when Burchfield participated in actions and deliberations of the Board allotting funding to the Duncansville Volunteer Fire Company from the Township's E.M.S. tax and then entered into a contract /agreement with the Duncansville Volunteer Fire Company, in excess of $500.00, to lease property /building space owned by him, and /or members of his immediate family for use by the Duncansville Volunteer Fire Company as a sub - station within Blair Township; and b. That an unintentional violation of Section 1105(b) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1105(b) occurred when Burchfield failed to disclose, on Statements of Financial Interests filed for the 2002, 2003, 2004, 2005, 2006 and 2007 calendar years, direct /indirect sources of income in excess of $1,300; office directorship or employment in any business entity; and his financial interests in any legal entity engaged in business for profit. 4. Burchfield agrees to make payment in the amount of $10,000 in settlement of this matter payable to the Commonwealth of Burchfield, 07 -089 Page 25 Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter; and that Burchfield will file amended Statements of Financial Interests for 2002, 2003, 2004, 2005, 2006, and 2007 to reflect all direct /indirect sources of income in excess of $1,300; and to fully disclose all directorship or employment in any business entity and financial interest in any legal entity or business for profit. 5. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Consent Agreement, at 2. The first recommended violation of the Consent Agreement is in relation to Burchfield participating in actions and deliberations of the Board of Supervisors to designate the DVFC as the primary responding Fire Department/Emergency Responder for the Township, participating in actions and deliberations of the Board allotting funding to the DVFC from the Township's EMS /Local Services tax, and then entering into a contract /agreement with the DVFC, in excess of $500.00, to lease property /building space owned by him, and /or members of his immediate family, for use by the DVFC as a substation within Blair Township. There were numerous uses of authority of office by Burchfield. But for the fact that Burchfield was a Township Supervisor, he would not have been in a position to take the following official actions favorable to DVFC. First, at the Board's December 8, 2005, meeting, Burchfield made a motion and voted in favor of supporting the DVFC in establishing a substation within the Township. Then, at the January 3, 2006, and February 9, 2006, meetings, Burchfield made motions and voted to establish the EMS tax which would be used for police, fire, and emergency services. Next, at the May 11, 2006, meeting, Burchfield seconded a motion and voted to designate the DVFC the primary fire company for the Township and to forward a $29.00 portion of the $39.00 EMS tax to the DVFC to establish a substation within the Township's geographical boundaries. Burchfield's aforesaid actions at the May 11, 2006, meeting occurred after representatives of the DVFC had met privately with Burchfield to discuss leasing a building from Burchfield within the Township to serve as the temporary location of the DVFC's Blair Township substation. Further, but for being a Township Supervisor, Burchfield would not have been in a position to make a motion and vote on December 14, 2006, to approve the 2007 Township budget, which included funding to the DVFC; or to make a motion and vote on January 2, 2007, to reaffirm distribution of the EMS tax so that $29.00 of the EMS tax would be paid to the Township's primary volunteer fire company; or to make a motion and vote on May 10, 2007, to officially designate the DVFC as the Township's primary fire company. Meanwhile, between November 2006 and May 2007, the DVFC issued rent payments for rent in the amount of $2,000.00 per month to the Burchfield Limited Partnership for the months of July 2006 through April 2007. But for being a Township Supervisor, Burchfield would also not have been in a position to participate in the approval of Township bill lists that included funding for the DVFC, some of which actions occurred while the DVFC was paying rent to the Burchfield Burchfield, 07 -089 Page 26 Limited Partnership. The aforesaid actions by Burchfield in his capacity as a Township Supervisor were uses of authority of office (see, Juliante, Order 809). The resulting private pecuniary benefit(s) consisted of rental payments from the DVFC to the Burchfield Limited Partnership. Given Burchfield's status as the general partner and 95% owner of the Burchfield Limited Partnership, the Burchfield Limited Partnership is a business with which Burchfield is associated as defined under the Ethics Act. See, 65 Pa.C.S. § 1102. Moreover, as noted above, all of the proceeds received from the DVFC for rental of the Property were retained by Burchfield and reported on Burchfield's tax returns filed jointly with his spouse. Burchfield claimed a net gain of $14,278.00 for rental of the Property in 2006, and a loss of $506.00 for rental of the Property in 2007 as a result of Burchfield ceasing to charge the DVFC rent for its use of the Property. The finding of a violation of Section 1103(a) of the Ethics Act under these circumstances is supported by case law and Commission precedent. This Commission has long held that a reasonable and legitimate anticipation of the development of a financial /business relationship may support a finding of a conflict of interest. See, e.q., Pavlovic, Opinion 02 -005; Confidential Opinion, 00 -006; Garner, Opinion 93 -004; Amato, Opinion 89 -002 (citing Sowers, Opinion 80 -050); Caldwell, Order 1172; Snyder, Order 979 -2, affirmed, Snyder v. State Ethics Commission, 686 A.2d 843 (Pa. Cmwlth. 1996), allocatur denied, 1997 Pa. LEXIS 2719 (Pa. Dec. 22, 1997). In Snyder v. State Ethics Commission, supra, Commonwealth Court affirmed Snyder, Order 979 -2, in which this Commission determined that a township supervisor who had participated and voted on development issues when he had actual or anticipated contracts to perform work in the developments had violated Section 3(a) (now Section 1103(a)) of the Ethics Law. Commonwealth Court, in affirming this Commission's Order, stated that Snyder "should not have considered and voted on issues involving his personal business dealings." Snyder, 686 A.2d at 849. In Kistler, Order 1441, we determined that "personal business dealings" encompass the persons or entities with which one does business or actively seeks to do business. We held that a member of an intermediate unit board of directors unintentionally violated Section 1103(a) of the Ethics Act when he voted in favor of authorizing an architect to pursue the construction of a classroom facility for the intermediate unit while he was actively engaged in seeking a contract with that same architect or the architect's company to build a transportation facility for the intermediate unit and had a reasonable expectation that he would receive such a contract. In Gerhard, Order 1460, we held that a school board member violated Section 1103(a) of the Ethics Act when he participated in actions of the school board to approve an addendum to a school district contract with a bus company, thereby increasing compensation to the bus company, at a time when the school board member was negotiating with the bus company to sell and /or lease buses to the bus company. In the instant matter, Burchfield had a conflict of interest as to matters involving DVFC during the time when he was discussing or negotiating the rental of the Property to the DVFC, because he had a reasonable and legitimate anticipation that he would be forming a financial /business relationship with the DVFC. See, Pavlovic, supra; Confidential Opinion, 00 -006, supra; Garner, supra; Amato, supra; Caldwell, supra; Snyder, supra. Further, once the DVFC began to rent the property, Burchfield and the DVFC had an ongoing business relationship. This Commission has held that it is a conflict of interest under Section 1103(a) of the Ethics Act for a public official to use the authority of office for a private pecuniary benefit as to an individual /entity with which he has an ongoing Burchfield, 07 -089 Page 27 business relationship. Cf., Johnson, Order 1338; Miller, Opinion 89 -024; Kannebecker, Opinion 92 -010. Accordingly, we hold that a violation of Section 1103(a) of the Ethics Act occurred in relation to Burchfield's participation in actions and deliberations of the Board of Supervisors to designate the DVFC as the primary responding fire department/emergency responder for the Township; participated in actions and deliberations of the Board of Supervisors allotting funding to the DVFC from the Township's EMS tax; and then entered into a contract /agreement with the DVFC, in excess of $500.00, to lease the Property for use by the DVFC as a substation within the Township. Turning to the recommended unintentional violation of Section 1105(b) of the Ethics Act, it is noted that the Allegations in this matter specifically enumerate subsections of Section 1105(b) allegedly violated by Burchfield. It would appear, however, that the parties have agreed to combine such individual alleged violations of subsections of Section 1105(b) within a single recommendation. The parties have stipulated that Burchfield, in his official capacity as a Township Supervisor, was required to annually file an SFI by May 1 containing information for the prior calendar year. Although Burchfield's SFIs for calendar years 2002 through 2007 were on file with the Township, Burchfield did not disclose the Township as a source of income in excess of $1,300 on such SFIs. In the section titled "direct /indirect sources of income," Burchfield wrote, "See Attached List" but did not attach any list reporting direct or indirect sources of income. Burchfield did not disclose income received from any of his private business interests. Burchfield failed to disclose his 95% ownership interest in the Burchfield Limited Partnership on his SFIs filed for calendar years 2005 and 2006 and did not did not disclose his office as President of the Burchfield Organization on his SFI for calendar year 2006. Accordingly, we hold that an unintentional violation of Section 1105(b) of the Ethics Act occurred when Burchfield failed to disclose, on SFIs for calendar years 2002, 2003, 2004, 2005, 2006, and 2007, direct /indirect sources of income in excess of $1,300; his office, directorship, or employment in any business entity; and his financial interests in any legal entity engaged in business for profit. As part of the Consent Agreement, Burchfield has agreed to make payment in the amount of $10,000.00 in settlement of this matter, payable to the Commonwealth of Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in the matter. Burchfield has also agreed to file amended SFIs for calendar years 2002, 2003, 2004, 2005, 2006, and 2007 to reflect all direct /indirect sources of income in excess of $1,300.00, and to fully disclose his directorship or employment in any business entity and financial interest in any legal entity or business for profit. We determine that the Consent Agreement submitted by the parties sets forth the proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Per the Consent Agreement, we direct Burchfield to make payment in the amount of $10,000.00, payable to the Commonwealth of Pennsylvania and forwarded to this Commission by no later than the thirtieth (30 day after the mailing date of this adjudication and Order. Burchfield is further directed to file amended SFIs for the 2002, 2003, 2004, 2005, 2006, and 2007 calendar years, providing complete disclosure as required by the Ethics Act, and in particular, reflecting all direct /indirect sources of income in excess of $1,300.00 Burchfield, 07 -089 Page 28 and fully disclosing his directorship or employment in any business entity and financial interest in any legal entity or business for profit, and to forward to this Commission copies of all of the aforesaid filings for compliance verification purposes by no later than the thirtieth (30 ") day after the mailing date of this adjudication and Order. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV. CONCLUSIONS OF LAW: 1. David Burchfield, Sr. ( "Burchfield "), as a Supervisor for Blair Township ( "Township ") since approximately January 1998, has at all times relevant to these proceedings been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. 2. A violation of Section 1103(a) of the Ethics Act occurred when Burchfield participated in actions and deliberations of the Township Board of Supervisors to designate the Duncansville Volunteer Fire Company ( "DVFC ") as the primary responding fire department /emergency responder for the Township; participated in actions and deliberations of the Board of Supervisors allotting funding to the DVFC from the Township's Emergency and Municipal Services tax; and then entered into a contract /agreement with the DVFC, in excess of $500.00, to lease property /building space owned by him and /or members of his immediate family through the "Burchfield Limited Partnership," for use by the DVFC as a substation within the Township. 3. An unintentional violation of Section 1105(b) of the Ethics Act occurred when Burchfield failed to disclose, on Statements of Financial Interests filed for the 2002, 2003, 2004, 2005, 2006, and 2007 calendar years, direct/indirect sources of income in excess of $1,300; his office, directorship, or employment in any business entity; and his financial interests in any legal entity engaged in business for profit. In Re: David Burchfield, Sr., Respondent ORDER NO. 1492 File Docket: 07 -089 Date Decided: 9/22/08 Date Mailed: 10/10/08 1 David Burchfield, Sr. ( "Burchfield "), a public official in his capacity as a Supervisor for Blair Township ( "Township ") since approximately January 1998, violated Section 1103(a) of the Ethics Act when he participated in actions and deliberations of the Township Board of Supervisors to designate the Duncansville Volunteer Fire Company ( "DVFC ") as the primary responding fire department /emergency responder for the Township; participated in actions and deliberations of the Board of Supervisors allotting funding to the DVFC from the Township's Emergency and Municipal Services tax; and then entered into a contract /agreement with the DVFC, in excess of $500.00, to lease property /building space owned by him and /or members of his immediate family through the "Burchfield Limited Partnership," for use by the DVFC as a substation within the Township. 2. An unintentional violation of Section 1105(b) of the Ethics Act occurred when Burchfield failed to disclose, on Statements of Financial Interests ( "SFIs ") filed for the 2002, 2003, 2004, 2005, 2006, and 2007 calendar years, direct/indirect sources of income in excess of $1,300; his office, directorship, or employment in any business entity; and his financial interests in any legal entity engaged in business for profit. 3. Per the Consent Agreement of the parties, Burchfield is directed to make payment in the amount of $10,000.00, payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (30 day after the mailing date of this Order. 4. Per the Consent Agreement of the parties, Burchfield is further directed to file amended SFIs for the 2002, 2003, 2004, 2005, 2006, and 2007 calendar years, providing complete disclosure as required by the Ethics Act, and in particular, reflecting all direct /indirect sources of income in excess of $1,300.00 and fully disclosing his directorship or employment in any business entity and financial interest in any legal entity or business for profit, and to forward to this Commission copies of all of the afgresaid filings for compliance verification purposes by no later than the thirtieth (30 day after the mailing date of this Order. 5. Compliance with paragraphs 3 and 4 above will result in the closing of this case with no further action by this Commission. a. Non - compliance will result in the institution of an order enforcement action. BY THE COMMISSION, Louis W. Fryman, Chair Name, Case # Page 30