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HomeMy WebLinkAbout1591 Rhone In Re: Kirk Rhone, : File Docket: 10-014 Respondent : X-ref: Order No. 1591 : Date Decided: 9/27/11 : Date Mailed: 10/4/11 Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Raquel K. Bergen Nicholas A. Colafella Mark Volk This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) 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. I.ALLEGATIONS: That Kirk Rhone, a public official/public employee in his capacity as a Member of Starrucca Borough Council, Wayne County, violated Sections 1103(a) and 1104(a) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. §§ 1103(a) and 1104(a), when he used the authority of his office for a private pecuniary benefit of himself and/or members of his immediate family and/or a business with which he and members of his immediate family are associated when he participated in discussions and actions of the Borough Council to authorize repairs and/or improvements to a bridge using Borough funds for the benefit [of] Rhone and/or members of his immediate family and Buck Brothers Farm, a business with which he is associated; and when he failed to file Statements of Financial Interests for the 2005, 2006, 2007, 2008, and 2009 calendar years. II.FINDINGS: 1. Kirk Rhone has served as a Member of Starrucca Borough Council, Wayne County, since or about December 2004. a. Rhone has served as President of Council continuously since January 2006. 2. Starrucca Borough is located in Wayne County, Pennsylvania. a. The Borough is located entirely in Wayne County. Rhone, 10-014 Page 2 3. Seven Members serve on the Borough Council. a. Two Borough Councilmembers are elected to 2 year terms, and five Borough Councilmembers are elected to 4 year terms. 4. Voting at Council meetings occurs by a yes or no vote and a raising of hands after a motion is made and properly seconded. a. Any abstentions or objections made to a motion are specifically noted in the minutes. 5. Rhone and his wife, Alice K. Rhone, are 50% owners of the Buck Brothers Farm that is partially located in Starrucca Borough. a. Robert Buck (Rhone’s brother-in-law) and Buck’s wife, Lillian S. Buck, are the other 50% owners of the farm. 1. Robert Buck also served as a Member of Starrucca Borough Council. b. The Buck Brothers Farm encompasses in excess of 450 acres, located in Starrucca Borough and Thompson Township. 1. Thompson Township is located adjacent to the Borough and is located entirely in Susquehanna County. 2. The boundary line between the Borough and Thompson Township is also the dividing line between Wayne and Susquehanna Counties. c. The Buck Brothers Farm operated as a dairy farm. 1. The Buck Brothers Farm is no longer functioning as a dairy farm. 6. Robert and Lillian Buck and Kirk and Alice Rhone purchased the parcel where the Buck Brothers Farm is located from Roland and Reva Buck on April 10, 1974, as evidenced by a deed filed in the Wayne County Register and Recorders office in book no. 306 p. 1135, and also filed in the Susquehanna County Register and Recorder’s office in book no. 356 p. 798. a. A corrective deed dated June 18, 1984, was filed with the Susquehanna County Register and Recorder’s Office in book no. 421 p. 427, correcting an error that had been made in the conveyance of the original deed. 7. Starrucca Creek runs through a portion of the Buck Brothers Farm that is located in the Borough. a. Starrucca Creek and Route 671 cross in a portion of the Buck Brothers Farm that is located in the Borough. b. A bridge (known as Buck Road Bridge, Buck Bridge, Erk Bridge, or Erk Road Bridge) is located on Rte. 671 where it crosses the Starrucca Creek. 8. The only access to the Buck Brothers Farm is Buck Road Bridge via Route 671. 9. For purposes of this [matter], Route 671 has been considered in four separate sections: Rhone, 10-014 Page 3 a. Section 1: This section is located in the Borough and passes through the Buck Brothers Farm. This section contains the Buck Bridge. b. Section 2: This section of Route 671 begins at the Borough/Township line and runs westerly through the Buck Brothers Farm for approximately 1.3 miles. This section comes to a dead end on the Buck Brothers Farm. This section of Route 671 is located entirely in Thompson Township. There are no residences located along this section of Route 671. c. Section 3: This is a middle section of Route 671 and is located entirely in Thompson Township. Section 3 of Route 671 was vacated by the Township by Ordinance dated September 8, 1953, for the reason that, “it is useless, burdensome, and unnecessary to the convenience of the traveling public.” d. Section 4: The western-most section of Route 671 that, historically, connected with Route 171 and is located entirely in Thompson Township. Section 4 of Route 671 was vacated by the Township in 2001, and is located in the Shelley Nature Preserve with no access to any open sections of Route 671. 10. The following Assessment map, filed with the Susquehanna County Assessment Office, shows the approximate location of Route 671 and the land accessible through Route 671: a. As shown in the above map, Route 671 ends on the 216.2 acre parcel of land owned by Buck Brothers Farm. Rhone, 10-014 Page 4 11. Other properties surrounding the historical location of Route 671 include the following: a. Approximately 153 acres currently owned by Nicholas P. Krehel, James D. Sanderson, and Bernard J. Povanda. 1. This parcel is mostly forested and is not used for farming. 2. This parcel is located entirely in Thompson Township, Susquehanna County. b. Approximately 175 acres owned by Robert Gilleran, Jr. 1. This parcel is primarily used for recreational purposes including hunting and fishing. 2. There are no permanent structures on this parcel. 3. This parcel is not used for farming and is partially forested. 4. Robert B. Gilleran normally utilizes ATVs as a means of access to his 175 acres. 5. This parcel is located entirely in Thompson Township. c. Two parcels – one approximately 92.7 acres, and another approximately 4.9 acres - owned by Robert Aillery. 1. Robert Aillery’s 4.9 acre parcel, which borders his 92.7 acre parcel, has substantial frontage on LR 57054 (Little Ireland Road). 2. These two parcels are located entirely in Thompson Township, Susquehanna County. 3. Aillery accesses his land, house, and garage via a driveway that is located off Little Ireland Road. 4. Aillery has a house and a garage on his land that he uses as a summer home. 5. Aillery has not accessed his land by way of the Buck Road for approximately ten years. a. Aillery cannot access his land by way of the Buck Road unless he uses a four-wheel drive vehicle or ATV. d. Four parcels totaling approximately 380 acres are owned by the Nature Conservancy. 1. These four parcels have frontage on LR 57054 (Little Ireland Road) and Route 171. 2. These four parcels are used as a nature conservancy and are not used for dairy farming. 3. The portion of Route 671 in these four parcels was abandoned by Thompson Township in 2001. Rhone, 10-014 Page 5 4. These four parcels are located entirely in Thompson Township, Susquehanna County. 12. The only parcels that would be accessed by Route 671 that are located in Starrucca Borough are those parcels owned by Robert Buck and Kirk Rhone. 13. Buck Road Bridge is used nearly exclusively by Robert Buck, Kirk Rhone and Buck Brothers Farm. 14. Since at least 1986 the Borough has incurred costs to repair the Buck Bridge. a. At a Borough Council meeting on June 12, 1986, the Councilmembers voted to make repairs to the Buck Bridge in the amount of $6,590.00. b. At Borough Council meetings on October 6, 1986, and November 3, 1986, Council discussed how the Borough should pay for Bridge repairs and voted in favor of the Borough bearing the cost for the repairs. 15. Until 2006, the Buck Bridge was inspected approximately every two years by the Wayne County engineers as part of a regular inspection of all County bridges. a. Those inspections concluded that the road to the west (Buck/Rhone property) was a dead end and that the bridge serves little traffic. b. A November 8, 1985, inspection report indicated that the Buck Bridge should be closed due to its poor condition. 1. The report indicated that the existing pipe railing on the bridge collapsed and they are more of a hazard than a protection to traffic. aa. The bridge railing had been removed in the 1980’s by Buck and Rhone to accommodate farm equipment. 2. Bridge repairs were completed in 1986. c. Bridge inspection reports of Wayne County Engineer Stephen Knash from November 23, 1987, and October 27, 1989, increased the posted load capacity to 18 tons. 1. Both reports indicate that the bridge is not serving much traffic and there is no high priority on replacing it. 2. Both reports indicate that the road to the west is a dead end. 3. Both reports indicate that there are no rails, approach rails or any other kind of safety devices. d. An October 24, 1991, bridge inspection report by Wayne County Engineer Stephen Knash indicated the following: 1. (The bridge) is on a dead end road serving one farm. 2. There were pipe rails on the deck, which are now missing. 3. It may be difficult to justify a new structure to serve one property. Rhone, 10-014 Page 6 4. The bridge should be posted for a three-ton weight limit. e. Bridge inspection reports from May 16, 2000, October 11, 2001, and October 8, 2003, all completed by Stephen Knash, indicated the following: 1. The bridge is located on a dead end road, which services one farm. 2. The advanced sign on the west end of Bucks road is not required because the road is a dead end. 3. The bridge has no railing. The original steel pipe railing on the structure has been torn off. There are remnants of the railing which remain on the far left end of the bridge. 4. The bridge deck width is narrow. The narrow width of the structure would probably not accommodate farm equipment if the railing was installed. 5. The structure is obsolete with a limited load carrying capacity. The expense of replacement may not be justifiable considering the number of properties served and the low ADT (Average Daily Traffic) of the structure. f. A bridge inspection report from October 16, 2005, completed by Stephen Knash, indicated the following: 1. The bridge is located on a dead end road, which services one farm. 2. The bridge has no railing. The original steel pipe railing has been torn off. 3. The bridge deck is narrow. g. From 1991 on, the County Engineer consistently recommended that the bridge should be subject to a three-ton weight limit. 1. A three-ton weight limit would be detrimental to the Buck/Rhone planned uses of the bridge. 16. In 2004, the Thompson Township Supervisors began discussion to vacate Section 2 of Route 671. a. Section 2 of Route 671 begins at the Borough/Township line and runs through the Buck Brothers Farm and dead ends on the Buck Brothers Farm. b. The Township Supervisors considered closing Section 2 due to the poor condition of the Buck Bridge. c. In order to vacate the road, the Supervisors were required to give the public 60 days notice. d. Buck and Rhone were opposed to the closing. 1. Robert and Lillian Buck and Kirk and Alice Rhone signed a letter dated August 18, 2004, to the Township Supervisors, stating that they strongly agree that Route 671 should remain open and under control of Thompson Township. Rhone, 10-014 Page 7 aa. If Section 2 of Route 671 were closed, the Bucks and Rhones would have had to maintain the road themselves to keep it in a usable condition. 2. Buck and Rhone sought to have the Township initiate repairs to the bridge, but the Township refused. 17. At the Township’s September 7, 2004, meeting, the Township Supervisors voted to temporarily close Section 2 of Route 671 instead of vacating it. a. The reason given for temporarily closing Section 2 of Route 671 is set forth in the September 7, 2004, meeting minutes as follows: “Presently the road is inaccessible because a bridge in Starrucca Borough Wayne County is in disrepair and has a weight limit of three (3) tons. Township maintenance vehicles weigh in excess of (10) tons and cannot safely cross the bridge to maintain the road. Private landowners have offered right of way (ROW) across their properties, including relieving the township of liability for damage to their land, to maintain the road. After consulting with the township insurance carrier and solicitor the supervisors feel that the increased risk of liability to the township was too great if personal injury to employees or property damage to township equipment resulted from an accident on the ROW.” b. The Township closed the road until the bridge in Starrucca was repaired or replaced so that Township road maintenance equipment could safely traverse the bridge. 18. At the time the Bucks and Rhones signed the petition opposing the closing of Section 2 of Route 671, the Buck Brothers Farm was an operating dairy farm that utilized hayfields on the western side of the Buck Road Bridge. a. In order to utilize and maintain the fields, the Buck Brothers Farm needed to cross the Buck Road Bridge with tractors and manure trucks. 1. Tractors can weigh up to seven or eight tons. 2. A manure truck can weigh in excess of twenty tons. b. Equipment that is needed to maintain the farm weighed significantly more than the three-ton weight limit that was posted on the bridge. c. The three-ton weight limit that was posted on the bridge would have legally restricted the Buck Brothers Farm use of the bridge for farming purposes. 1. The Buck Brothers Farm continued to use the bridge for farming purposes even though its equipment exceeded the weight limit. 19. After Thompson Township’s closing of Route 671, there was significant discussion as to the ownership of the Buck Bridge in late 2004 and early 2005 by Borough Council. a. These discussions started after Kirk Rhone took office as a Borough Councilman. Rhone, 10-014 Page 8 1. Rhone was an advocate of the Borough assuming ownership of the bridge and the responsibility for maintenance and repairs of the bridge. b. Kirk Rhone was a member of Council at this time and participated in Council discussions and decisions. c. As Borough Solicitor at that time, Michael Lehutsky’s position was that the Buck Bridge was a County bridge, and therefore it was the responsibility of the County to repair the Bridge. d. The County asserted the Buck Bridge was a Borough bridge and refused to pay for repairs. 1. Rhone asserts that the Buck Bridge is owned by Starrucca Borough. 20. In or about November 2004, Buck and Rhone contacted Delta Engineers to conduct a study of the Buck Road Bridge to determine the costs of repairing the bridge. a. On November 8, 2004, Robert Buck and Kirk Rhone, acting as representatives of Buck Brothers Farm, met with Delta Engineers representative David Kennicutt regarding the Buck Bridge. 1. During the meeting, Buck and Rhone indicated that they wished for the load capacity of the bridge to be increased in order to support heavy truck traffic. 2. On November 16, 2004, Delta Engineers submitted a proposal to Buck and Rhone to prepare a Bridge Type Study that would present options for repairs to the Buck Bridge. 3. The cost of the Engineers study was $3,000.00. 21. On December 9, 2004, Delta Engineers completed its preliminary study of Buck Bridge. a. The study presented two alternatives for repairing the Buck Bridge. i. Alternative 1 – Rehabilitation Utilizing Existing Concrete Slab as a Structural Member – had a total estimated cost of approximately $36,000.00. ii. Alternative 2 – Construct New Slab over Existing – had a total estimated cost of approximately $60,000.00. b. Buck Brothers Farm was billed $3,000.00 and privately paid for the personal study that it commissioned. c. Both Kirk Rhone and Darl Haynes were in contact with Delta Engineers regarding the Bridge Type Study. 1. Haynes is a close friend of both Kirk Rhone and Robert Buck. 2. Haynes served on Starrucca Borough’s Bridge Committee with Kirk Rhone beginning in 2006. Rhone, 10-014 Page 9 22. On December 30, 2004, Darl Haynes informed David Kennicutt from Delta Engineers that the decision was made by Buck and Rhone to pursue Alternative 2, the more expensive option with more extensive repairs. a. As of December 30, 2004, Delta’s study results had not been presented to Council. 1. Buck was not a Member of Council at this time. 2. Kirk Rhone was appointed to Council in or about December 2004. b. Haynes also requested that Kennicutt attend a Borough Council meeting in February 2005 to present the study to Council. 23. On January 14, 2005, Kirk Rhone advised Kennicutt that he wanted Delta Engineers to present Alternative 2, the more expensive option, to the Borough Council. a. Rhone further told Kennicutt that he wanted Alternative 1 to be “set aside.” b. Kirk Rhone was a Member of Borough Council when he gave this direction to Kennicutt. 24. On January 25, 2005, Darl Haynes again spoke with Kennicutt on behalf of Buck and Rhone regarding presenting the study to Starrucca Borough Council. a. Kennicutt’s notes from his January 25, 2005, conversation with Darl Haynes reflect that Haynes wanted Kennicutt “…to speak with authority and reassure the board that this project is a viable solution that meets their objectives.” b. Kennicutt’s notes also reflect that Darl Haynes asked Kennicutt if the bridge rehab would be suitable if a major development was built (20-25 homes). 1. Rhone asserts that he and Buck had no intention of building a major development across the Bridge. c. Haynes also expressed concern whether the bridge could support truck traffic related to gravel mining. 1. The Buck Brothers previously had a stone quarry across the bridge. 25. The sole purpose for Buck and Rhone authorizing the study by Delta was to obtain estimates for the bridge improvements to accommodate their plans for personal uses of their property. a. The study was then presented to Council, so that Council would pay for the costs to improve the bridge. 26. Since at least January 2005 Kirk Rhone has participated in discussions of actions of Borough Council relating to repairs to the bridge to his property, including advocating that the Borough assume financial responsibility for any maintenance and rehabilitation. a. Rhone abstained from votes on January 3, 2006, and January 12, 2006, but participated in every action of Council regarding Buck Bridge from January 2005 through 2008. Rhone, 10-014 Page 10 b. Rhone’s actions included voting to authorize repairs, borrow money, and select contractors, approving payments to contractors, and serving as the Borough’s primary point of contact with contractors and engineers. c. Rhone’s property was the only Borough property to benefit from the renovations to the bridge. 1. Rhone asserts that the renovations to the bridge benefitted other property owners as well as the general public. 27. At the Starrucca Borough Council meeting that occurred on January 3, 2005, the Buck Road Bridge was discussed. The minutes show the following relevant discussion: “Kirk Rhone reported the Borough is eligible to apply for a grant at 3.75% for 10 years. The bridge will cost approximately $40,000 to $50,000 with design costs of $10,000 to $11,000 (paid privately). A preliminary plan will be presented by Delta Engineers at the next meeting in February. Kirk Rhone will contact DEP. Brigitte D’Agati asked what the cost would be to the taxpayers. Kirk Rhone and Andy Bennett emphasized that this was a preliminary plan – nothing is final at this time.” a. At the time Rhone represented to Council costs of $40,000 to $50,000 to repair the bridge, he knew that Delta estimates of the plan he favored were at least $60,000. 28. An emergency meeting of the Starrucca Borough Council was held on January 12, 2005. The Buck Bridge was discussed at the meeting. a. During the discussion, Kirk Rhone advised that design costs will be paid for privately regardless of escalating costs and the costs for permits should come off the cost of the bridge. b. After further discussion, Kirk Rhone made a motion to pursue a Community Development Block Grant (“CDBG”) for Buck Road Bridge. The motion was seconded by Helen Haynes and passed by a vote of 5 to 1. 1. Robert Buck was not a Member of Borough Council at this time. c. The events that occurred at this meeting were found to be in violation of the Sunshine Law by the Borough Council and any actions taken at this meeting were rescinded by Borough Council at the February 7, 2005, meeting of Council. 29. At the February 7, 2005, Borough Council Meeting, Kennicutt presented the preliminary plan to Council for the Buck Road Bridge. a. Kennicutt stated that the cost of the bridge could realistically be addressed for about $35,000, and that the projected cost of $50,000 was based on a limited amount of work for the project. b. A Borough resident expressed concerns about the burden on the Borough for a share of the cost of repair to the Bridge. c. Lillian Buck, Robert Buck’s wife, stated her concern that if the bridge is closed the road will be vacated by Thompson Township. Rhone, 10-014 Page 11 1. If the portion of the road in Thompson Township was closed, the Thompson Township portion of the road within the Buck Brothers Farm would no longer be maintained by government entities and would become the responsibility of the property owners (Buck and Rhone). 30. At the Borough Council meeting on May 2, 2005, a motion by Councilman Robert Weldy to temporarily close the Buck Road Bridge failed to pass. The minutes read as follows: “Robert Weldy offered a motion to temporarily close Buck Road Bridge to prevent public access for safety reasons. The motion was seconded by Lou Gurske and resulted in a tie vote (3 yes – 3 no, Paul Everett abstained). Mayor Mroczka was asked to vote because of the tie and voted no.” a. Kirk Rhone voted against the temporary closing of the bridge. b. If not for the vote of Councilman Kirk Rhone, the Buck Road Bridge would have been closed at the May 2, 2005, meeting. 31. Robert Buck won election to Starrucca Borough Council during the November 2005 General Election and began serving on January 3, 2006. 32. On December 20, 2005, Kirk Rhone contacted David Kennicutt of Delta Engineers regarding the Buck Bridge. a. Rhone inquired if the design fee for the project would remain the same as the fee previously set forth in the December 9, 2004, Bridge study prepared by Delta Engineers for the Buck Brothers Farm and informed Kennicutt that the Borough was interested in moving forward with the project. b. At the time of Rhone’s call to Kennicutt, no formal action was taken by the Borough to proceed with the project. 33. During a telephone conversation of December 22, 2005, with Kirk Rhone, Kennicutt provided an updated design fee of $10,450, not including bid documents for option two with bridge widened to 15.5 foot curb to curb was given to Rhone [sic]. a. Kennicutt informed Rhone that he could estimate costs for construction by escalating numbers in the December 2004 report by four percent. b. Rhone told Kennicutt that he would discuss this with Council and get back to him in early January. 34. In January 2006, the makeup of the Borough Council changed substantially. a. New Members of Council included friends and/or family members of Kirk Rhone who were supportive of the Borough incurring the costs to upgrade the Buck Bridge. b. Beginning in January 2006, the Borough Council was comprised of the following individuals: Robert Buck, Kirk Rhone, Fred Rhone, Donald Haynes, Helen Haynes, Anthony Palonis, and Lou Gurske. 1. Robert Buck is co-owner of the Buck Brothers Farm with Kirk Rhone who is married to Buck’s sister. Rhone, 10-014 Page 12 2. Fred Rhone is the brother of Kirk Rhone. 3. Donald Haynes and Helen Haynes are son and mother, and are friends of the Buck and Rhone families. 35. At the January 3, 2006, reorganization meeting of Borough Council, Council discussed ownership of Buck Road Bridge and approved a motion to apply for a CDBG grant for repairs to the Buck Road Bridge. a. The motion passed by a vote of 4 to 1 with Robert Buck and Kirk Rhone abstaining. b. Both Kirk Rhone and Robert Buck participated in discussions regarding bridge ownership and grant application. 36. At the January 12, 2006, special meeting of Borough Council, a motion was made to advertise for Engineers design for the Buck Road Bridge. a. Robert Buck and Kirk Rhone abstained from voting. b. The motion passed 4 to 1. c. Councilmember Lou Gurske, who cast the dissenting vote, stated that a conflict of interest existed. 37. The Borough advertised for the bridge upgrade design in the Wayne Independent under legal notices. a. The advertisement contained the following: Starrucca Borough is requesting bids for a bridge upgrade design on borough road 671, Buck Road, for specifications and information contact 570-727-2807. Sealed bids will be opened at the regular borough meeting February 6, 2006 at 7 pm. Location: 1 Little Ireland Road. Please mail bids to: Starrucca Borough, PO Box 83, Starrucca, PA 18462. Starrucca Borough reserves the right to accept or reject all bids. b. The telephone number listed, 570-727-2807, is the telephone number listed for both Kirk Rhone and Robert Buck. c. Interested bidders were provided information for the design quote by letter dated January 21, 2006, signed by Kirk Rhone. 1. Both Buck’s and Rhone’s telephone number (570-727-2807) is listed as a point of contact. 2. Rhone’s letter states that expected upgrade costs will be approximately $60,000. 38. At the February 6, 2006, Borough Council meeting, Council reviewed the only bid it had received for the design of the Buck Road Bridge. a. The sole bid was from Delta Engineers, in the amount of $16,500.00. b. Kirk Rhone read Delta’s proposal into the record. c. Kirk Rhone called for an executive session to review the bid. Rhone, 10-014 Page 13 d. After objection from the audience, Council decided to hold a special public meeting on February 10, 2006, to hear all concerns related to the project. e. Robert Buck seconded the motion to hold the special meeting on February 10, 2006. 39. In or about January 2006 Borough Council formed a Bridge Committee for the purpose of reviewing options related to Buck Bridge and Stefano Bridge. a. Appointed to the Committee were Council President Kirk Rhone, Mayor Andy Bennett and Darl Haynes. 1. Haynes is a Borough resident who has close personal ties to Robert Buck and Kirk Rhone. b. The action appointing Kirk Rhone, Andy Bennett and Darl Haynes to the Bridge Committee occurred during Council’s reorganization meeting of January 3, 2006. 1. Robert Buck and Kirk Rhone voted in favor of the motion, which passed by a 6 to 1 vote. 40. No records exist of any meetings of the Bridge Committee. a. Mayor Andy Bennett did not participate in any discussions and/or recommendations made by the Bridge Committee. b. Kirk Rhone and his appointee, Darl Haynes, made all decisions regarding the Bridge Committee. 41. On February 8, 2006, two days prior to Council’s special meeting, Kirk Rhone telephonically contacted David Kennicutt of Delta Engineers. a. Kirk Rhone advised Kennicutt of the special meeting and inquired if Delta’s price was firm. b. Rhone asked about repair costs and if the prices would be less if contingencies were not a factor. c. Rhone would contact Kennicutt if Delta could proceed. 42. At the Borough Council special meeting on February 10, 2006, to discuss the Buck Road Bridge rehabilitation, Bridge Committee member, Darl Haynes, made a presentation regarding the status, costs and funding for the Buck Road Bridge. a. Darl Haynes stated the following: 1. The original preliminary plan, at the cost of $3,000, was completed in 2004 and was paid for by landowners (Robert Buck and Kirk Rhone). 2. The Borough obtained a CDBG grant in January 2005 in the amount of $25,000, which was sent back by the previous Borough Council. 3. A new CDBG grant was requested in the amount of $30,000. Rhone, 10-014 Page 14 4. The cost to rehabilitate the Buck Road Bridge was to be approximately $60,000. 5. If the Borough were to borrow $30,000 for ten years with a rate of 4.65%, the monthly payment would be $300. 6. The rehabilitation was to include a traveling width of fifteen feet, guardrails, and a twenty-five ton limit. aa. The rehabilitation plan cited by Haynes was the one sought by Buck and Rhone. b. Citizens in attendance questioned the Borough’s ability to pay for the Buck Road Bridge project if grant funds were not received. c. Questions were raised by meeting attendees whether the bridge belonged to the County or the Borough. d. Attendees requested Council to not commit $16,500 to Delta Engineers without knowing if the Borough was going to receive a grant. 43. Darl Haynes telephoned Kennicutt of Delta on February 15, 2006, inquiring if the costs of the bridge rehabilitation would increase if the weight unit was raised from 25 to 40 tons. a. Buck and Rhone were interested in the weight limit increase so the bridge could be utilized for heavy equipment. b. Kennicutt told Haynes that it likely would cost an additional $4,000 to $5,000 due to additional concrete needed for the deck, rebar, etc. c. Haynes was further told by Kennicutt that given the age of the abutments and undermining, they would not recommend that loads exceeding 25 tons be allowed on the bridge after it is repaired. 44. The Borough held a special meeting on February 16, 2006, for the purpose of reviewing the bid from Delta Engineers for the design of the Buck Road Bridge rehabilitation. a. As President of Council, Kirk Rhone presided over the meeting. b. Bridge Committee member Darl Haynes presented a financial analysis: 1. Haynes indicated that a $30,000 grant had been recommended for award on the date of the meeting by the Wayne County Commissioners. aa. A letter from the Grant Manager with DCED to the Wayne County Redevelopment Director dated June 1, 2006, in regard to CDBG funding for the Buck Bridge stated as follows: “The proposed activity, reconstruction of the Buck Bridge, does not meet a National Objective as required for CDBG funding…[I]n this case the bridge is in an inappropriate service area. Buck Bridge and Erk Road presently have no outlet and no dwelling units, LM/I or other.” Rhone, 10-014 Page 15 2. Haynes also stated that there was $10,000 in the General Fund. c. Considerable discussions occurred during the meeting regarding the Borough’s ability to repay a loan for the bridge project. d. Following the discussion regarding citizen requests to delay awarding the contract to Delta until funds were approved, a motion was made by Councilman Donald Haynes and seconded by Councilman Fred Rhone to award the bid to Delta Engineers for the design of the bridge at the bid rate of $16,500.00. 1. Fred Rhone is the brother of Kirk Rhone. 2. The motion passed by a vote of 5 to 1. 3. Both Robert Buck and Kirk Rhone voted in favor of the motion. 45. On February 24, 2006, the Borough Council sent a letter to Congressman Donald Sherwood seeking a $10,000 grant for the Buck Bridge Rehabilitation. a. The letter is signed by Kirk Rhone. 46. On or about March 2, 2006, Borough Councilman Lou Gurske met with Delta Engineer Kennicutt to protest the project. a. Gurske was trying to stop progress on the design and construction of the project. b. Gurske told Kennicutt the following: 1. The Borough will go bankrupt if they try to fund this. 2. The bridge is not owned by the Borough, but by Wayne County. 3. The Feds will not approve this project and no grant will be issued. 4. Kirk Rhone has a conflict of interest in this bridge because he will personally benefit. 5. An injunction is being sought to prevent the Borough from constructing the bridge. c. Gurske urged that Delta Engineers suspend work on the project to give him and others time to legally stop the project. 47. On March 2, 2006, Kennicutt called Kirk Rhone to discuss Gurske’s visit to the Delta Engineers office. a. Rhone directed Kennicutt to stick to the original schedule and stated that the bridge project will go on regardless of whether the grant is approved or not. 48. At the March 6, 2006, Borough Council meeting, discussion relative to the Buck Bridge and the Buck Road occurred. a. The minutes contained the following: “Mr. Haynes made a motion to send a grant proposal ($10,000) for additional funds towards the Buck’s Bridge, Rhone, 10-014 Page 16 second Mr. F. Rhone, motion carried, except Mr. Gurske, who stated the Board is ‘rushing in’.” 1. Both Buck and Rhone voted in favor of the motion. 2. The grant application was ultimately denied by the State. b. In response to questions regarding ownership of the Buck Road Bridge, Kirk Rhone stated it is the Board’s opinion that the bridge is a Borough bridge. c. Kirk Rhone also responded to questions regarding estimates for the repairs to the Buck Bridge by advising residents that the Borough would pay the $16,500 design fee as an in-kind contribution. 49. Capital improvements, including $1,300.00 of work on the Buck Road, were also discussed at the March 6, 2006, Borough Council meeting. a. The work that was performed on the Buck Road was changing of the entrance of the road to make it easier for large trucks to access the road. 1. Rhone asserts that the work was done as required by PennDOT specifications. b. The meeting minutes contained the following: “Mr. Haynes made the motion to hire Miller Brothers to perform the work with a cap of $9,800, second Mr. Buck, motion carried, except Mr. Gurske, who was opposed, stating he ‘takes issue’ with work performed on Buck’s Road.” 1. Buck and Rhone voted to approve the motion. 50. At the Starrucca Borough Council meeting of April 5, 2006, motions were made to send easements to the landowners involved in the Buck Bridge project and to apply for all necessary permits concerning the project. a. The meeting minutes contained the following: “The Buck Road/Bridge Project was then discussed. Mr. F. Rhone made a motion to send easements to the landowners involved, (Mr. and Mrs. K. Rhone, and Mr. and Mrs. R. Buck). Second Mr. Haynes, motion carried. Mr. Gurske voting no. Mr. F. Rhone made a motion to apply for all necessary permits concerning the project, second Mr. Haynes, motion carried.” b. Both Buck and Rhone voted in favor of the motions. 51. At the Borough Council special meeting of May 25, 2006, Kirk Rhone, as Council President, stated to those in attendance that the Buck Bridge was a Borough bridge. Minutes note the following: a. When the issue of whether the Bridge was a County or Borough Bridge was raised, President Rhone interjected stating the Board has addressed this issue many times, and as far as they are concerned ‘it is a Borough bridge.’” 52. On June 5, 2006, a letter was sent by Kennicutt of Delta Engineers to the Borough of Starrucca to the attention of Kirk Rhone, advising of increased construction costs for the bridge repairs. a. The letter states that the probable construction costs for the bridge repairs were $60,000. Rhone, 10-014 Page 17 b. The reasons for the increase in construction costs were explained as follows: -- Additional environmental and erosion control measures required under the pending permit to be issued by the Pennsylvania Department of Environmental Protection. -- Severe undermining of the west abutment, which requires construction of independent stub abutments for the bridge slab. -- A longer and thicker bridge slab, required to span the new abutments. -- Inflation. 53. Kirk Rhone served as the contact with the DEP for issues regarding the Buck Bridge. a. Kirk Rhone received a letter from the DEP Permitting and Technical Services Section dated June 23, 2006, regarding the Borough’s submission of a General Permit. 54. At the July 5, 2006, Borough Council meeting, Council approved a motion to advertise for bids from lending institutions to borrow up to $70,000 for the reconstruction of Buck Road Bridge. a. The motion passed by a vote of 5 to 1. b. Buck voted in favor of the motion. c. Although Kirk Rhone was present at the meeting, there is no record of him abstaining from the vote. d. Both Buck and Rhone participated in discussions leading up to the vote and were in favor of borrowing the money. 55. On July 19, 2006, Dave Kennicutt of Delta informed Kirk Rhone of DEP’s review of the bridge project and the condition of the bridge following local flooding. a. Kennicutt advised Rhone that he had been trying to contact Peter Kawash of DEP to discuss DEP comments. b. Rhone informed Kennicutt that he has a contact who knows Kawash and will see what he can do to expedite the resolution of DEP’s review. 56. At the August 2, 2006, Borough Council meeting, bids from lending institutions to provide loans for reconstruction of Buck Road Bridge were opened and reviewed. a. Bids were received from PennStar Bank, Penn Security, Peoples National Bank, Honesdale National, Dime Bank, and Wayne Bank. b. After discussion regarding the bids, a motion was made by Councilman Donald Haynes to award the bid to PennStar Bank for a $15,000.00 loan and a $70,000.00 loan at the fixed rate of 4.64%. The $70,000.00 loan was to be used for the Buck Road Bridge. The motion was seconded by Councilman Fred Rhone and carried with all Councilmembers voting in favor except for Gurske. Rhone, 10-014 Page 18 1. It was later decided by Council to not proceed with the $15,000.00 loan. c. Both Kirk Rhone and Robert Buck participated in discussions and voted in favor of the motion which passed by a 6 to 1 vote. d. On September 6, 2006, Kirk Rhone, acting as Borough Council President, signed PennStar Bank’s offer for the borrowing of the $70,000 for the bridge project. 57. The terms of the loan provided for annual payment on the $70,000 loan of $8,907.52 due in June of each year. a. These payments represented between 19.28% and 25.28% of the total Borough revenues based on reported revenues. b. The percentage of the total yearly loan payments as compared to Borough revenue for 2004, 2005, and 2006, is as follows: Year Reported revenues Yearly loan payment Percentage of Borough’s total yearly revenues 2004 $35,240.00 $8,907.52 25.28% 2005 $37,700.00 $8,907.52 23.63% 2006 $46,200.00 $8,907.52 19.28% 58. At the October 4, 2006, Borough Council meeting, Council approved a motion to begin the process to “close” on the $70,000 loan for the Buck Bridge project. a. Both Robert Buck and Kirk Rhone voted in favor of the motion, which was approved by a vote of 5 to 1. 59. Council approved advertising for an ordinance to borrow the $70,000.00 to repair Buck Bridge at its December 6, 2006, meeting. a. The motion approving the ordinance was seconded by Robert Buck. b. The motion was approved by a 6 to 1 vote with both Buck and Kirk Rhone voting with the majority. 60. At the December 6, 2006, Borough Council meeting, Borough citizens presented a “Petition to Reject Starrucca Borough Taxpayer Funding of the Repair/Upgrade Project to the Buck Road (Route No. T-671) Bridge that Crosses over the Starrucca Creek on the Property of the Buck Brothers Farm.” a. The petition contained the signatures of 68 Borough residents. 1. The Borough’s total population in 2006 was between 216 and 228 people. b. The petition was not acknowledged or addressed by the Borough Council at its December 6, 2006, meeting, or at any subsequent meetings. 61. At the January 3, 2007, Borough Council meeting, Ordinance No. 2007-01 was approved and authorized the borrowing of $70,000 from PennStar Bank for the construction, repair or replacement of Buck Bridge. a. The minutes reflect the following: Rhone, 10-014 Page 19 “Mr. Buck made a motion to adopt the ordinance to borrow the funds ($70,000 at the rate of 4.64%) for the repair or replacement of the Buck Bridge. Mr. Gurske took issue with the word “replace” as he explained it left an “open end” for the Borough to “spend even more money in the future”. Mr. Haynes seconded the motion, motion carried. Mr. Gurske was opposed.” b. Robert Buck motioned to adopt the ordinance to borrow the money for the repair of Buck Bridge. c. Both Buck and Rhone voted in favor of the approval of the ordinance. d. Kirk Rhone signed Ordinance No. 2007-01 as Borough Council President. e. Robert Buck signed Ordinance No. 2007-01 as a Borough Councilmember. 62. The passage of Ordinance No. 2007-01 enabled the Borough to secure the necessary funds to repair the Buck Road Bridge leading to property owned by Councilmembers Robert Buck and Kirk Rhone. a. The Borough did not have sufficient funds in any accounts to repair the bridge. 1. The Borough did not have any reliable funding sources, other than the $70,000 loan to fund the bridge repair. b. The bridge would not have been repaired without the passage of Ordinance 2007-01. 63. On February 21, 2007, the Pennsylvania Department of Community and Economic Development (DCED) approved the Borough to receive the $70,000 note pursuant to the Local Government Unit Debt Act. 64. Robert Buck and Kirk Rhone participated in actions at the March 7, 2007, Borough Council meeting to approve changes that were made to the Buck Road to allow for an easier access for trucks on the road across the Buck Bridge. a. The minutes contain the following: “Mr. Buck made a motion to authorize the Borough Solicitor to draw descriptions for the Borough roads, based on the survey (Butler Land Surveying, LLC) and record the same in Wayne County. (The Stefano Road and the Buck’s Road are ready, others to follow). Mr. Haynes seconded the motion, motion carried. Mr. Gurske was opposed.” b. Both Buck and Rhone voted in favor of the motion, which was approved by a 6 to 1 vote. 65. A General Obligation Note was issued to the Borough by PennStar Government Financial Services in the amount of $70,000 on March 15, 2007, for the Buck Bridge project. a. The General Obligation Note set forth the principal amount, the interest rate, the issue date and the maturity date. Rhone, 10-014 Page 20 b. The General Obligation Note set forth that commencing June 15, 2007, and on the same day of each year thereafter, the Borough shall make payment of $8,907.52, with the final payment due June 15, 2017. c. The General Obligation Note was signed by Kirk Rhone, as President of Council, and by Robert Buck as Councilman. 66. On April 10, 2007, Robert Buck and Kirk Rhone applied for subdivision approval to Thompson Township. a. Robert and Lillian Buck and Kirk and Alice Rhone applied to Thompson Township for approval of a subdivision named “Buck-Rhone Subdivision” to be built in Thompson Township on TR 671 (Buck Road) approximately 3000 feet from the Susquehanna County/Wayne County Line. b. Access to the proposed subdivision would be by the Buck Road Bridge. c. On August 23, 2007, the Thompson Township Planning Commission denied the subdivision request, because a driveway permit could not be issued for the subdivision. 1. A driveway permit could not be obtained because TR 671 had been closed by Thompson Township. 2. TR 671 was temporarily closed in September 2004, because the Township’s equipment could not cross the Buck Bridge because of the weight restrictions on the Bridge. d. After the repairs to the Buck Bridge were completed, Buck and Rhone did not resubmit their subdivision application. e. The subdivision has not been approved by Thompson Township and no effort has been made to obtain a driveway permit by Buck and Rhone. 67. Kirk Rhone served as the Borough’s contact with PennDOT representatives regarding use of Liquid Fuels funds and approval of the bridge design. a. Kirk Rhone is listed on a project approval form dated July 6, 2006, as the person interviewed regarding use of Liquid Fuels money. 1. Rhone asserts that Randy Decker, the Municipal Services Representative for PennDOT, orally informed him that the use of the Liquid Fuels money for the Buck Road Bridge was appropriate. b. Kirk Rhone was the recipient of a fax dated July 9, 2007, from PennDOT listing structural adequacy review comments and a letter from David Kennicutt dated July 13, 2007, addressing the PennDOT comments. 68. On or about July 11, 2007, Robert Buck solicited potential bridge contractor information from David Kennicutt of Delta Engineers. a. Kennicutt sent a letter addressed to Robert Buck dated July 11, 2007, providing a listing of five contractors: Fahs Construction, ProCon Contracting, R. Devincentis Construction, Inc., Vector Construction Corporation and Economy Paving Company, Inc. b. The letter was addressed to Buck at his residence: Rhone, 10-014 Page 21 Robert Buck Buck Bros. Farms P.O. Box 42 Starrucca, PA 18462 69. On August 1, 2007, Starrucca Borough Council approved a motion to solicit bids for the Buck Bridge project. a. Both Buck and Rhone voted in favor of the motion, which was approved by a 6 to 1 vote. 70. Robert Buck and Kirk Rhone participated in the August 1, 2007, Borough Council vote approving Resolution No. 2007-02 to officially accept the Bucks Falls Road, Route 671, into the road system of the Borough. a. Robert Buck made the motion and voted for the approval of the Resolution. b. Kirk Rhone voted in favor of the motion to approve the Resolution. c. Resolution No. 2007-02 was signed by Kirk Rhone, as Borough Council President. d. Resolution No. 2007-02 was also signed by Robert Buck as Councilmember. 71. At the September 5, 2007, Borough Council meeting, bids were opened for the Buck Bridge project. a. The bids received were as follows: R. Devincentis Construction - $103,000 ProCon Contracting - $88,000 Leeward Construction - $198,200 Timz Construction - $85,000 b. After reviewing and discussing the bids, Council voted to reject all bids and contact Delta Engineers to change the specifications and re-bid the project at a later date. c. Buck and Rhone participated in the vote to reject the bids. 72. On September 10, 2007, Darl Haynes contacted David Kennicutt of Delta Engineers to discuss the reduction of the costs of the repairs to Buck Road Bridge. a. Haynes explained that the low bid received on the Buck Road Bridge project was $85,000 and that the next was $88,000. The others were in the $105,000 to $198,000 range. b. Haynes informed Kennicutt that the Borough was hoping to get the Bridge for $70,000. 1. Council authorized the borrowing of $70,000 for the project. c. Haynes wanted Delta to examine documents to see if anything could be done to reduce the bid price and rebid. Rhone, 10-014 Page 22 1. Haynes suggested removing gravel approach work, which he said they could do themselves. d. Kennicutt told Haynes that it was unlikely that they will get the project to $70,000 even if the bidding climate improves. e. Kennicutt further told Haynes that the Borough’s best bet was to narrow the structure (reduce the width of the bridge). 1. Haynes told Kennicutt that this option isn’t even on the table. 2. Buck and Rhone needed the wider width to accommodate farm equipment and heavy equipment due to a potential subdivision. 73. On September 13, 2007, a phone call occurred between Kennicutt and Darl Haynes where they again discussed the Bridge project. a. Kennicutt recommended the Borough accept the low bid and negotiate a change order to have the approach and gabion work done by the Borough. b. Haynes informed Kennicutt that all bids were already rejected and that they will need to rebid. c. Kennicutt explained that the reduction in scope may not get them down to their $70,000 funding limit. d. Haynes indicated that they may ask for donations from landowners on the dead end side of the bridge. 74. On or about September 14, 2007, a supplemental agreement to the original agreement with Delta Engineers for the Buck Bridge project was sent to the Borough, which included the additional work to change the bid specifications for the project. a. The letter modified the original agreement between Delta and the Borough to allow Delta to complete additional work relating to modifying the dates and scope of the contract work for a rebid. 1. The approach work and gabion construction was deleted from the proposal. b. The total additional cost to the Borough was $400.00. 1. The total lump sum fee for Delta Engineers’ work on the Bridge was increased from $16,500 to $16,900. c. The agreement was signed for acceptance by Kirk Rhone as Borough Council President. 75. On September 18, 2007, the Borough Council held a special meeting for the purpose of reviewing and discussing the Buck Road Bridge rehabilitation project and approving changes. a. The amended contract with Delta Engineers was presented and approved by Council to amend the bid specifications for the project by removing the approach work and gabion work. Rhone, 10-014 Page 23 1. The motion was made by Rhone and passed by a vote of 5 to 1. 2. Both Robert Buck and Kirk Rhone voted in favor of the motion. b. Also at the meeting Buck made a motion to re-bid the project with the changes as outlined by Delta Engineers and set the bid opening for October 9, 2007. 1. Both Buck and Rhone voted in favor of the motion. 76. Borough Council held a special meeting on October 9, 2007, to open the bids for the Buck Road Bridge rehabilitation project. a. The bids received were as follows: ProCon Contracting - $72,000 Pioneer Construction - $108,710 R. Devincentis Construction - $87,850 Timz Construction - $81,200 b. Borough Council made the determination to hold a special meeting on October 12, 2007, to further review and award the bid for the project. 77. At the October 12, 2007, Borough Council meeting, a contract for the construction of the Buck Bridge project was awarded to ProCon Contracting in the amount of $72,000. a. The contract was awarded upon motion by Haynes and seconded by Rhone. b. Both Buck and Rhone voted for the approval of the motion. 1. The vote to approve the contract was 4 to 1 with two Members absent. 2. Three of the four votes to approve were Buck, Rhone and Fred Rhone, Kirk Rhone’s brother. c. Prior to the vote, Kirk Rhone was questioned as to how the Borough plans to come up with the money; Kirk Rhone responded that he felt the project is “workable” using both general and state Liquid Fuels funds. 78. On October 25, 2007, an agreement between ProCon Construction and the Borough to perform the construction for the Buck Bridge project for $72,000 was signed into effect. a. The agreement was signed by Kirk Rhone as Borough Council President. 79. At the November 7, 2007, Borough Council meeting, issues related to the Buck Bridge project were discussed and addressed including the Borough purchasing gabion materials and selecting a contractor to install the gabion. a. Buck and Rhone participated in approving four motions to purchase materials and approve a contractor. b. Robert Buck made a motion to purchase materials for the Buck Road Bridge Project starting with the gabion baskets from John Bonham Road Supplies. 1. Rhone seconded the motion. Rhone, 10-014 Page 24 2. The motion passed by a vote of 5 to 1 with one Member absent. 3. Both Buck and Rhone voted in favor of the motion. c. A second motion was made by Haynes, which was seconded by Buck, to purchase the gabion stone needed from Lanesboro Materials. a. The motion passed by a 5 to 1 vote with one Member absent. b. Both Buck and Rhone voted in favor of the motion. 1. Also voting to approve the motions was Kirk Rhone’s brother, Fred Rhone. d. The third motion was made by Rhone and seconded by Haynes to hire Ozzie Miller to perform the work on the gabion baskets and the approach work and the remainder of the work for the Buck Road Bridge Project. 1. The motion was approved to a 5 to 1 vote. 2. Both Buck and Rhone voted in favor of the motion. 3. Gabion baskets were never installed on the Bridge. e. Robert Buck made the motion to hire Blue Ridge Better Builders at the cost of $3,000 to monitor the construction and oversee the Buck Road Bridge Project, which was seconded by Rhone. 1. The motion was approved by a 5 to 1 vote. 2. Buck, Rhone along with Fred Rhone were three of the five votes in favor of the motion. 3. The contract awarded to Blue Ridge Better Builders was not competitively bid because it was below the required bidding threshold set forth in the Borough Code. 4. There was no written contract for this service. 80. At the Borough Council’s May 7, 2008, meeting, Kirk Rhone made a motion and voted to have a letter sent to Thompson Township alerting it that the Buck Road Bridge would be complete at the end of May and Thompson Township would be able to work its end of the road. a. The minutes document that the Borough would inform Thompson Township when the bridge would be usable. b. At the time this motion was approved, Thompson Township’s section of Buck Road was closed due to the poor condition of the Buck Bridge. c. The closure of the road resulted in Buck’s and Rhone’s subdivision in Thompson Township not having been approved because they were not able to obtain a driveway permit. 81. The Buck Bridge construction was completed in the summer of 2008. Rhone, 10-014 Page 25 a. The Borough held an opening ceremony for the Buck Road Bridge on July 18, 2008. b. At the opening ceremony, Kirk Rhone was quoted in the Wayne Independent, a local newspaper, as stating the following, “Since the bridge was being fixed, Thompson Township has agreed to maintain their section of the road. There are as many as four houses proposed on the road, which were pending repair or replacement of the bridge. A subdivision is proposed with three building lots and another man is waiting to build a house.” 1. The proposed subdivision referred to by Rhone is a subdivision submitted by Buck and Rhone on their property. 2. Rhone asserts that he was misquoted in the Wayne Independent article regarding the four houses proposed on the road. 82. Both Robert Buck and Kirk Rhone participated in actions of Council to approve payments to contractors for services performed in relation to the repairs of the Buck Road Bridge. a. Buck and Rhone participated in issuing payments totaling $95,200 for engineering and construction services related to Buck Bridge. 83. At the Borough Council’s June 4, 2008, meeting, the Borough voted to pay the bills to ProCon and Blue Ridge Better Builders. a. A motion was approved to pay $72,000 to ProCon and $3,000 to Blue Ridge Better Builders. 1. ProCon provided an invoice dated May 13, 2008, to the Borough for the rehabilitation of Buck Road Bridge over Starrucca Creek in the amount of $72,000. aa. $18,000 was to be paid to ProCon from the State Liquid Fuels fund, and the remaining $57,000 due to ProCon and Blue Ridge Better Builders would be paid from the Borough’s General Fund. 2. Blue Ridge Better Builders had completed the inspection on Buck Road Bridge. aa. The Borough paid Blue Ridge Better Builders $3,000 for the inspection. b. The motion to pay ProCon and Blue Ridge Better Builders was made by Haynes and seconded by Fred Rhone. 1. The motion passed by a 6 to 1 vote with Buck and Kirk Rhone voting to approve. 84. Payment was issued as follows by the Borough to Blue Ridge Better Builders: a. Check no. 895 in the amount of $3,000 was issued to Blue Ridge Better Builders from the Borough’s General Fund on June 4, 2008. 1. The check was signed by Laura Travis, Treasurer, and Kirk Rhone. Rhone, 10-014 Page 26 85. Payments were issued by the Borough to ProCon as follows: a. Check no. 893 in the amount of $54,000 was issued to ProCon Construction from the Borough’s General Fund on June 4, 2008. 1. The check was signed by Laura Travis, Treasurer, and Kirk Rhone. b. Check No. 138 in the amount of $18,000 was issued to ProCon Contractors from the Borough’s State Liquid Fuels account on June 4, 2008. 1. The check was signed by Laura Travis, Treasurer, and Kirk Rhone. 86. Miller Brothers Earthmovers was hired by the Borough to complete approach work on the Bridge. a. Ozzie Miller, owner of Miller Brothers Earthmovers, is a business associate of Robert Buck and Kirk Rhone. b. Miller Brothers Earthmovers placed rip rap stone and built up a wall on the approach to the bridge. c. The Borough paid Ozzie Miller/Miller Bros. Earthmovers $3,300 for work on the Buck Road Bridge and to prepare for paving. 87. Delta Engineers was paid a total of $16,900.00 for work completed on the Buck Road Bridge. a. Rhone voted to approve payments to Delta on at least four occasions totaling at least $16,500. b. Rhone signed all Borough checks issued to Delta for work completed on the Buck Road Bridge. 88. Starrucca Borough has made the following payments to PennStar Bank for the loan for the repairs to Buck Road Bridge: Check Check Date No. Amount Signed 6/6/2007 786 $ 8,907.52 K. Rhone, Travis 7/2/2008 901 $ 8,907.52 K. Rhone, Travis 6/4/2009 989 $ 8,907.52 K. Rhone, Travis 8/2/2010 1176 $ 3,552.80 Martin, Schneyer a. A payment of only $3,552.80 was made on the loan in 2010 by the Borough. No additional payment has been made as of the beginning of April 2011 on the loan. 89. The Borough is required to pay $70,000 principal, and $19,075.15 on the PennStar loan. a. As of 2011, the Borough paid $30,275.36 on the PennStar loan. b. Late fees totaling $890.76 were assessed to the Borough relative to the PennStar loan. Rhone, 10-014 Page 27 1. The first late fee was assessed on June 30, 2008, in the amount of $445.38. 2. The second late fee was assessed to the Borough on June 30, 2010, in the amount of $445.38. 90. The Borough received the following donations from private individuals to assist paying for the Buck Road Bridge repairs. Donations: Check Date No. Amount Contributor 5/20/2008 1398 $ 1,000.00 Boy Scouts of America, Vestal, NY 5/31/2008 11613 $ 8,000.00 Buck Brothers Farm, Kirk Rhone and Robert Buck 6/1/2008 8177 $ 3,000.00 J.D. Sanderson, D.M.D. 6/5/2008 2186 $10,000.00 Root's Tax Service, Jacqueline A. Root 91. On February 26, 2007, the Pennsylvania Department of the Auditor General, Office of Special Investigations, initiated an investigation of Starrucca Borough’s Buck Road Bridge Renovation Project. a. The Special Investigation, which was completed in August 2009, found that Starrucca Borough Council approved the Buck Road Bridge renovation project, which resulted in a substantial benefit to two Members of Borough Council, without regard to other pressing needs of the Borough and the cost to the citizens of the Borough. b. The report concluded that the actions of two Members of Borough Council (Robert Buck and Kirk Rhone) may constitute a conflict of interest under Pennsylvania law. c. The attorney for Robert Buck and Kirk Rhone provided a written response to the Auditor General’s Special Investigation Report. 1. Their attorney wrote, “While in hindsight Rhone and Buck should probably have abstained on the Buck Bridge resolution, any perceived conflict must still be approached with a “but for” or “materiality” analysis.” 92. Kirk Rhone provided information to the Department of Auditor General pursuant to that agency’s investigation of the Buck Bridge project. Rhone provided: ? He worked as a dairy farmer for 42 years and he is now retired. ? He and his brother-in-law, Robert Buck, operated Buck Brothers Farm in Starrucca since 1973. ? Buck Brothers Farm is a partnership in which he is a 50% owner and his brother-in-law Robert Buck owns the other 50%. ? He was appointed to Starrucca Borough Council in December of 2004 and he has been President of Starrucca Borough Council since January of 2006. ? The bridge was built in 1926 and Starrucca Borough has maintained the bridge since then. ? Starrucca Borough owns the bridge and last made repairs to the bridge in 1986. The recent repairs in question have been completed. These repairs include a poured concrete deck. ? The bridge is now open for travel and is being used. Rhone, 10-014 Page 28 ? He and Buck and their spouses are co-owners of land in both Starrucca, Wayne County and Thompson Township that is directly accessible by the Buck Bridge and Buck Road. ? With the completion of the Buck Road Bridge, the Buck and Rhone families are in the process of subdividing two parcels of land for use by their children and two parcels for family use. ? The Rhone and Buck families are not currently marketing any of their land in the near future. ? The land being subdivided for his daughter and the daughter of Robert and Lillian Buck is in Thompson Township, Susquehanna County, Pennsylvania. ? He and Robert Buck and their wives are the only affiants that own land in Starrucca Borough, Wayne County, Pennsylvania. Rhone stated that all of the other affiants own land that is located in Thompson Township, Susquehanna County, Pennsylvania only. ? He and Buck have received approval for subdividing two parcels of their land located in Thompson Township, Susquehanna County. ? Rhone stated that the original plan for this subdivision was for each of their daughters to build houses, but the daughters do not have the money to build these houses at the present time. ? Rhone stated that the total acreage in both counties owned by him and Buck is about 763 acres. ? His involvement with the application process for the Borough’s loan at the PennStar Bank for the financing of the Buck Bridge project was limited to working with the Borough’s Secretary/Treasurer and meeting with bank representatives, but Rhone could not remember the names of the bank representatives. ? He hopes that the Borough can pay the $8,907.52 annual payment on this loan for the next ten years out of general funds and he hopes that the Borough will not have to raise taxes in order to pay off this loan. ? The Borough will raise taxes if increased revenue is required to pay off this loan. ? Rhone told OSI that the Borough has not applied for authorization to use Liquid Fuels funds for paying of this loan. ? He and Robert Buck, d/b/a Buck Brothers Farm, made a contribution in the amount of $8,000 in April or May of 2008 to Starrucca Borough for the funding of the Buck Bridge project and paying off the bank loan for this project. This payment was made with a check drawn on the Buck Brothers Farm checking account. 93. On October 20, 2009, the Pennsylvania Department of the Auditor General conducted a review of the Borough’s use of the Liquid Fuels Tax money. a. The report made four findings, three of which were directly related to $18,000 paid to ProCon Contracting on June 4, 2008, for its work on the repair of the Buck Road Bridge: 1. Finding No. 2: the Borough expended $18,000 from its Liquid Fuels Tax Fund without filing a final completion report with PennDOT. 2. Finding No. 3: the Borough failed to receive prior approval of the Department of Transportation before expending $18,000 for the renovation of the Buck Road Bridge. 3. Finding No. 4: the Borough’s payment of $18,000 for the renovation of Buck Road Bridge resulted in a substantial benefit to two Members of Rhone, 10-014 Page 29 Borough Council, without regard to other pressing needs of the Borough and the cost to the citizens of the Borough. b. The report was distributed to the Secretary of the Pennsylvania Department of Transportation. c. On December 14, 2010, Bryan T. Hanisko, Division Chief of the Financial Consulting Division of PennDOT’s Bureau of Municipal Services, sent a letter to the Borough regarding the Auditor General’s report. 1. The letter noted that PennDOT determined that the Borough should reimburse its Liquid Fuels Tax Fund in the amount of $18,000. 2. The letter also noted that future Liquid Fuels allocations would be contingent upon proper reimbursement. 94. The following chart delineates the uses of the authority of his public position by Kirk Rhone to facilitate the repairs to Buck Road Bridge, the only access to property he jointly owns with Robert Buck: Date Issue Uses of Office 1/3/2005 Discussion regarding funding and Engaged in discussion. the preliminary plan for Buck Bridge. 1/12/2005 Discussed the design costs for Engaged in discussion. Buck Bridge and how they would be paid. Moved and voted in favor. Motion to purse a CDBG grant for Buck Bridge. 5/2/2005 Motion to temporarily close Buck Voted against closing the Bridge Bridge to prevent access for safety and was the determinative vote. reasons. 12/20/2005 Phone call with Kennicutt of Delta Spoke with Kennicutt regarding Engineers. Borough’s interest in moving forward with Buck Bridge project. 12/22/2005 Phone call with Kennicutt of Delta Spoke with Kennicutt regarding Engineers. increased construction costs. Said he would speak to Council and get back to Kennicutt in January. 1/3/2006 Discussion regarding bridge Participated in discussions. ownership and the grant application. Voted in favor. Vote to appoint Kirk Rhone, Darl Haynes, and Andy Bennett to the Bridge Committee. 1/21/2006 Newspaper advertisement and Wrote letter and used his phone letter soliciting bids for bridge number as a contact. upgrade design. 2/6/2006 Reviewed the bid received for the Called an executive session. Engineering work on Buck Bridge. Read the proposal into the record. 2/8/2006 Phone call with Kennicutt of Delta Spoke with Kennicutt regarding Engineers. the price of the proposal. Told Rhone, 10-014 Page 30 Kennicutt he would call Delta if they can proceed. 2/10/2006 Bridge committee presented Participated as a member of the information regarding the Delta Bridge Committee in presenting Engineers’ preliminary plan, the the information regarding the CDBG grant, a new CDBG grant, Buck Bridge. the costs to rehabilitate the Buck Commented in favor of the Bridge Bridge, the monthly payment, and rehabilitation. the details of the rehabilitation. 2/16/2006 Motion to award bid to Delta Engaged in significant discussion Engineers at cost of $16,500. regarding financing and repairs to Buck Bridge. Seconded and voted in favor. 2/24/2006 Letter from Borough to Signed the letter. Congressman Donald Sherwood seeking $10,000 grant. 3/2/2006 Phone call with Kennicutt of Delta Spoke with Kennicutt regarding Engineers. Lou Gurske’s visit to the Delta Engineers’ office where Gurske indicated that Rhone has a conflict of interest. Told Kennicutt to stick to the original schedule, and that the bridge project would go on regardless of whether a grant is approved. 3/6/2006 Motion to send grant proposal for Seconded and voted in favor. additional funds for Buck Bridge. Motion to hire Miller Brothers to Voted in favor. perform work on the Buck Road. 4/5/2005 Motion to send easements to Made motion and voted in favor. landowners involved in the Buck Road/Bridge Project. Made motion and voted in favor. Motion to apply for all necessary permits concerning the project. 5/25/2006 Discussion related to Buck’s Road Interjected and stated that the entrance work and whether the Board has addressed this issue, Buck Bridge is a County or and as far as they are concerned, Borough Bridge. it is a Borough bridge. 6/7/2006 Motion to pay $4,950 to Delta Voted in favor. Engineers. $4,950 check to Delta Engineers. Signed check. 7/5/2006 Motion to advertise for bids from No record of Rhone abstaining lending institutions to borrow from the vote. $70,000 for Buck Bridge. Motion to pay $5,000 and $4,075 Made motion and voted in favor. to Delta Engineers. Signed check. $5,000 check to Delta Engineers. Signed check. $4,075 check to Delta Engineers. 7/19/2006 Phone call with Kennicutt of Delta Spoke with Kennicutt regarding Engineers. the Bridge’s condition after a Rhone, 10-014 Page 31 recent flood. 8/2/2006 Motion to award bid to PennStar Seconded and voted in favor. Bank for $70,000 loan at 4.64% for Buck Bridge. 9/6/2006 PennStar Bank’s offer for the Signed PennStar’s offer. borrowing of $70,000 for the Buck Bridge. 10/4/2006 Motion to close on the $70,000 Voted in favor. loan for the Buck Bridge. 12/6/2006 Motion to advertise an ordinance to Voted in favor. borrow $70,000 for the Buck Bridge. 1/3/2007 Motion to approve Ordinance Voted in favor. Signed Ordinance authorizing the borrowing of as Borough Council President. $70,000 for construction, repair, or replacement of Buck Bridge. 3/7/2007 Motion to authorize Solicitor to Voted in favor. draw description for the Borough Roads, including Buck Road. 3/15/2007 General Obligation Note issued to Signed General Obligation Note Borough by PennStar Government as Borough Council President. Financial Services for $70,000. 6/6/2007 $8,907.52 check to PennStar Bank Signed check. for loan payment for Buck Bridge. 7/11/2007 Fax to Kennicutt regarding Bridge Faxed information to Kennicutt. Unit Review Comments. 8/1/2007 Motion to solicit bids for Buck Made motion and voted in favor. Bridge project. Voted in favor. Signed Resolution Motion to approve Resolution as Borough Council President. officially accepting Bucks Falls Road into the Borough’s road system. 9/5/2007 Review of submitted bids and Voted in favor of rejecting bids. motion to reject all bids and change specifications. 9/14/2007 Supplemental agreement from Signed for acceptance of Delta Engineers for Buck Bridge supplemental agreement. project for additional work to change the bid specifications. 9/18/2007 Motion to accept amended contract Moved and voted in favor. with Delta Engineers amending the bid specifications by removing the approach work and gabion work. Motion to re-bid the project with the Voted in favor. changes and set the bid opening for October 9, 2007 10/3/2007 Subdivision in the name of Abstained. Buck/Rhone presented and approved by Borough Council. 10/12/2007 Motion to award construction for Seconded and voted in favor. Buck Bridge project to ProCon. Answered question as to how Borough plans to come up with the money and says the project is “workable” using general and Rhone, 10-014 Page 32 state Liquid Fuels funds. $400 check to Delta Engineers Signed check. 10/25/2007 Agreement between ProCon Signed as Borough Council Construction and the Borough to President. perform construction work on Buck Bridge for $72,000. 11/7/2007 Motion to purchase materials for Seconded and voted in favor. Buck Bridge. Motion to purchase gabion stone Voted in favor. for the Buck Bridge. Motion to hire Ozzie Miller to Moved and voted in favor. perform work on the gabion baskets, approach work, and the remainder of the work for the Buck Bridge. Seconded and voted in favor. Motion to hire Blue Ridge Better Builders to monitor construction and oversee the Buck Bridge Project. 12/5/2007 Motion to pay $2,475 to Delta Voted in favor. Engineers. $2,475 check to Delta Engineers. Signed check. 5/7/2008 Motion to send letter to Thompson Moved and voted in favor. Township telling them the Buck Bridge will be complete at the end of May and Thompson Township would be able to work their end of the road. 6/4/2008 Motion to pay $72,000 to ProCon Voted in favor. and $3,000 to Blue Ridge Better Builders for work on the Buck Bridge. Signed check. $3,000 check issued to Blue Ridge Better Builders for work on the Buck Bridge. Signed checks. $54,000 check and $18,000 check issued to ProCon Contractors for work on Buck Bridge. 7/2/2008 $8,907.52 check to PennStar Bank Signed check. for loan payment for Buck Bridge. 8/6/2008 $2,500 check to Miller Bros Earth Signed check. Movers. 6/4/2009 $8,907.52 check to PennStar Bank Signed check. for loan payment for Buck Bridge. 8/5/2009 $800.00 check to Miller Bros. Earth Signed check. Movers. a. Rhone’s only abstentions during the entire time period when the Buck Road Bridge was being acted on by Council occurred in 2006 when he abstained Rhone, 10-014 Page 33 from votes to apply for grants and to advertise for the selections of engineers. b. Neither Buck nor Rhone ever requested a written legal opinion from the Borough Solicitor or an advisory opinion from the State Ethics Commission as to whether they had a conflict of interest. 1. The issue of a conflict of interest was raised throughout the time when the Borough was addressing the Buck Bridge repairs. c. Rhone asserts that, with the exception of the May 2, 2005, vote to temporarily close the Buck Bridge, his vote was never the deciding vote as to issues with the Buck Bridge repair. 1. In determining whether a violation of the conflict of interest provisions of the Ethics Act has occurred, it is not relevant whether a vote was the deciding vote. d. Rhone asserts that the rehabilitation of the Buck Bridge benefitted other users of the bridge including the general public and landowners in Thompson Township, and that Thompson Township received state liquid fuels tax money for maintenance of the portion of the road accessible by the Buck Bridge located in Thompson Township. 1. Although Rhone asserts that the bridge is open to the general public, no individuals benefitted to the same degree as Buck and Rhone as a result of the Buck Bridge rehabilitation. 95. The Investigative Division asserts that Kirk Rhone realized a private pecuniary gain when he used his position as a Borough Council Member to further the rehabilitation of Buck Road Bridge. THE FOLLOWING FINDINGS RELATE TO ALLEGATIONS THAT KIRK RHONE FAILED TO FILE STATEMENTS OF FINANCIAL INTERESTS FOR THE 2005, 2006, 2007, 2008 AND 2009 CALENDAR YEARS. 96. In his official capacity as a Borough Councilmember, Rhone was required to file a Statement of Financial Interests (SFI) form by May 1 annually containing information for the prior calendar year. 97. In or about May 2010, the Investigative Division of the State Ethics Commission conducted a SFI Compliance Review of Starrucca Borough. 98. On May 18, 2010, the Starrucca Borough Secretary/Treasurer provided to the Investigative Division of the State Ethics Commission the following Statement of Financial Interests filed by Kirk Rhone with Starrucca Borough: a. The only SFI on file with the Borough for Kirk Rhone was for the 2004 calendar year and dated February 25, 2005. b. The SFI disclosed the following: Occupation: Dairy farmer Direct/Indirect Sources of Income: Buck Bros. Farm Office, Directorship, Employment: Farmer, Partnership (50/50) Rhone, 10-014 Page 34 Financial Interest in any legal entity in business for profit: Buck Bros. Farm 50% 99. No SFIs are on file with Starrucca Borough for Kirk Rhone for calendar years 2005, 2006, 2007, 2008, 2009 and 2010. 100. Kirk Rhone received $160.00 in compensation in 2009 for his services as a Starrucca Borough Councilmember, although no SFI was filed for Rhone for 2009. a. Rhone did not receive compensation in any other year for his services as a Starrucca Borough Councilmember. III.DISCUSSION: As a Member of Borough Council for Starrucca Borough (“Borough”) since approximately December 2004, Respondent Kirk Rhone, hereinafter also referred to as “Respondent,” “Respondent Rhone,” and “Rhone,” has been a public officialsubject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. The allegations are that Rhone violated Sections 1103(a) and 1104(a) of the Ethics Act: (1) when he participated in discussions and actions of the Borough Council to authorize repairs and/or improvements to a bridge using Borough funds for the benefit of Rhone and/or members of his immediate family and Buck Brothers Farm, a business with which he is associated; and (2) when he failed to file Statements of Financial Interests (“SFIs”) for the 2005, 2006, 2007, 2008, and 2009 calendar years. 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" or "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. Rhone, 10-014 Page 35 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 1104(a) of the Ethics Act provides that each public official/public employee must file a Statement of Financial Interests for the preceding calendar year, each year that he holds the position and the year after he leaves it. As noted above, 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. Respondent Rhone served as a member of Borough Council since approximately December 2004. Respondent served as President of Borough Council continuously since January 2006. Borough Council consists of seven Members. Respondent and his wife, Alice K. Rhone, are 50% owners of the “Buck Brothers Farm,” which encompasses in excess of 450 acres located in the Borough and Thompson Township (“Township”). Respondent’s brother-in-law, Robert Buck, and Robert Buck’s wife, Lillian S. Buck, are the other 50% owners of the farm. Robert and Lillian Buck and Respondent and Alice Rhone have owned the parcel where the Buck Brothers Farm is located since 1974. Starrucca Creek and Route 671 cross in a portion of the Buck Brothers Farm that is located in the Borough and Wayne County. A bridge referred to as “Buck Road Bridge,” “Buck Bridge,” “Erk Bridge,” or “Erk Road Bridge” is located on Route 671 where it crosses the Starrucca Creek. The only access to the Buck Brothers Farm is Buck Road Bridge via Route 671. The parties have identified various sections of Route 671 as set forth in Fact Findings 9 a-d. The section of Route 671 identified as “Section 1” is located in the Borough and passes through the Buck Brothers Farm. Section 1 contains the Buck Road Bridge. The section of Route 671 identified as “Section 2” begins at the Borough/Township line and runs westerly through the Buck Brothers Farm for approximately 1.3 miles. Section 2 is located entirely in the Township and comes to a dead end on the Buck Brothers Farm. There are no residences located along Section 2. The only real estate parcels located in the Borough that would be accessed by Route 671 are those parcels owned by Respondent and Robert Buck. Buck Road Bridge is used nearly exclusively by Respondent, Robert Buck, and Buck Brothers Farm. Until 2006, the Buck Road Bridge was inspected approximately every two years by the Wayne County Engineer. From 1991 on, the Wayne County Engineer consistently recommended that the bridge should be subject to a three-ton weight limit. The bridge inspection reports from 2000 through 2005 indicated that the Buck Road Bridge was located on a dead end road that serviced one farm, the bridge had no railing, the original steel pipe railing had been torn off (removed by Respondent and Robert Buck to accommodate farm equipment), and the bridge deck was narrow. In 2004, the Township Supervisors began discussing vacating/closing Section 2 of Route 671 due to the poor condition of the Buck Road Bridge. At that time, the Township road maintenance vehicles and the Buck Brothers Farm equipment needed to maintain the farm weighed significantly more than the three-ton weight limit that was posted on the Buck Road Bridge. Rhone, 10-014 Page 36 The Bucks and Rhones opposed the closing. If Section 2 of Route 671 were closed, the Bucks and Rhones would have to maintain the road themselves to keep it in a usable condition. Respondent and Robert Buck sought to have the Township initiate repairs to the bridge, but the Township refused. On September 7, 2004, the Township Supervisors voted to temporarily close Section 2 of Route 671 until the Buck Road Bridge was repaired or replaced so that Township road maintenance equipment could safely traverse the bridge. In November 2004 Respondent and Robert Buck, acting as representatives of Buck Brothers Farm, met with David Kennicutt (“Kennicutt”) of Delta Engineers (“Delta”) regarding the Buck Road Bridge. Respondent and Robert Buck indicated that they wished for the load capacity of the bridge to be increased in order to support heavy truck traffic. They authorized Delta to prepare a preliminary study with options for repairs to the Buck Road Bridge. Buck Brothers Farm paid for the study, which was completed on December 9, 2004. The preliminary study presented two alternatives for repairing the Buck Road Bridge. Alternative 1 for “Rehabilitation Utilizing Existing Concrete Slab as a Structural Member” had a total estimated cost of approximately $36,000. Alternative 2 to “Construct New Slab over Existing” had a total estimated cost of approximately $60,000. On December 30, 2004, Darl Haynes, a close friend of Respondent and Robert Buck, informed Kennicutt that the decision was made by Respondent and Robert Buck to pursue Alternative 2, the more expensive option with more extensive repairs. Darl Haynes requested that Kennicutt attend a Borough Council meeting in February 2005 to present the study to Council. Since at least January 2005 Respondent participated as a Borough Councilman in discussions and actions of Borough Council relating to repairs to the Buck Road Bridge. In 2005, it was the position of the Borough Solicitor that the Buck Road Bridge was a County bridge, and therefore it was the responsibility of the County to repair the bridge. However, the Borough had incurred costs to repair the bridge since at least 1986. The County asserted that the Buck Road Bridge was a Borough bridge and refused to pay for repairs. Respondent was an advocate of the Borough assuming ownership of the bridge and the responsibility for maintaining and repairing the bridge. At a Borough Council meeting on January 3, 2005, the Buck Road Bridge was discussed. Respondent reported to Borough Council that the Borough was eligible to apply for a grant and that the bridge would cost approximately $40,000 to $50,000, with design costs of $10,000 to $11,000 paid privately. Respondent reported that a preliminary plan would be presented by Delta at the February meeting. At a Borough Council meeting on January 12, 2005, Respondent advised that design costs for the Buck Road Bridge would be paid for privately and that the costs for permits should come off the cost of the bridge. After further discussion, Respondent made a motion to pursue a Community Development Block Grant (“CDBG”) for Buck Road Bridge. The motion passed by a vote of 5 to 1. The events that occurred at this meeting were later rescinded by Borough Council as having been in violation of the Sunshine Law. On January 14, 2005, Respondent advised Kennicutt that he wanted Delta to present Alternative 2, the more expensive option, to the Borough Council. Respondent further told Kennicutt that he wanted Alternative 1 to be “set aside.” On January 25, 2005, Darl Haynes spoke with Kennicutt on behalf of Respondent and Robert Buck regarding presenting the study to Borough Council. According to Kennicutt’s notes from the conversation, Darl Haynes wanted Kennicutt to speak with authority and reassure the Board that the project was a viable solution that met the Board’s Rhone, 10-014 Page 37 objectives. Darl Haynes also asked Kennicutt questions regarding the suitability of the bridge rehabilitation for a major development or truck traffic related to gravel mining. At the February 7, 2005, Borough Council Meeting, Kennicutt presented to Council the preliminary plan for the Buck Road Bridge. Delta’s preliminary study was presented to Council so that Council would pay for the costs to improve the bridge. At the May 2, 2005, Borough Council meeting, Councilman Robert Weldy made a motion to temporarily close the Buck Road Bridge to prevent public access for safety reasons. The motion was seconded by Councilman Lou Gurske (“Gurske”) and resulted in a 3-3 tie vote, with Councilman Paul Everett abstaining. Respondent voted against the temporary closing of the bridge. The Mayor was asked to vote because of the tie and voted no. If not for the vote of Respondent, the Buck Road Bridge would have been closed at the May 2, 2005 meeting. In December 2005 Respondent informed Kennicutt that the Borough was interested in moving forward with the Buck Road Bridge project. However, at that time, no formal action had been taken by the Borough to proceed with the project. Kennicutt provided Respondent with updated design fee and cost information. Respondent told Kennicutt that he would discuss the information with Council and get back to Kennicutt in early January. In January 2006, the makeup of Borough Council changed substantially. New Members of Council included friends or family members of Respondent who were supportive of the Borough incurring the costs to upgrade the Buck Road Bridge. Beginning in January 2006, Borough Council was comprised of the following individuals: Robert Buck, Respondent, Fred Rhone, Donald Haynes, Helen Haynes, Anthony Palonis, and Gurske. Fred Rhone is the brother of Respondent. Donald Haynes and Helen Haynes are son and mother, and are friends of the Buck and Rhone families. At the January 3, 2006, reorganization meeting of Borough Council, Council discussed ownership of Buck Road Bridge and approved a motion to apply for a CDBG grant for repairs to the Buck Road Bridge. The motion passed by a vote of 4 to 1 with Respondent and Robert Buck abstaining from the vote. Both Respondent and Robert Buck participated in discussions regarding bridge ownership and grant application. Borough Council also formed a Bridge Committee for the purpose of reviewing options related to Buck Road Bridge and another bridge. Respondent and Robert Buck voted in favor of the motion to appoint Respondent, the Mayor, and Darl Haynes to the Bridge Committee, which motion passed by a 6 to 1 vote. No records exist of any meetings of the Bridge Committee. The Mayor did not participate in any discussions and/or recommendations made by the Bridge Committee. Respondent and Darl Haynes made all decisions regarding the Bridge Committee. At the January 12, 2006, special meeting of Borough Council, a motion was made to advertise for bids for the bridge upgrade design for the Buck Road Bridge. Respondent and Robert Buck abstained from voting. The motion passed 4 to 1. Gurske, who cast the dissenting vote, stated that a conflict of interest existed. The Borough advertised for the bridge upgrade design, listing Respondent’s and Robert Buck’s telephone number as a point of contact. Interested bidders were provided information for the design quote by a letter dated January 21, 2006, signed by Respondent. At the February 6, 2006, Borough Council meeting, Council reviewed the only bid it had received for the design of the Buck Road Bridge, which was from Delta and was in the amount of $16,500. Respondent read Delta’s proposal into the record. Respondent called for an executive session to review the bid. After objection from the audience, Council Rhone, 10-014 Page 38 decided to hold a special public meeting on February 10, 2006, to hear all concerns related to the project. On February 8, 2006, Respondent advised Kennicutt of the special meeting and inquired if Delta’s price was firm. At Borough Council’s special meeting on February 10, 2006, Bridge Committee member Darl Haynes reported that a new CDBG grant in the amount of $30,000 had been requested for the Buck Road Bridge and that the cost to rehabilitate the Buck Road Bridge would be approximately $60,000, with the rehabilitation to include a traveling width of fifteen feet, guardrails, and a twenty-five ton limit. Meeting attendees raised questions regarding the ownership of the Buck Road Bridge and the Borough’s ability to pay for the Buck Road Bridge project if grant funds were not received. Attendees asked Council to not commit $16,500 to Delta without knowing if the Borough was going to receive a grant. On February 15, 2006, Darl Haynes asked Kennicutt whether the costs of the bridge rehabilitation would increase if the weight limit was raised from 25 to 40 tons. Respondent and Robert Buck were interested in the weight limit increase so the bridge could be utilized for heavy equipment. Kennicutt told Haynes that increasing the weight limit to 40 tons would likely cost an additional $4,000 to $5,000, but would not be recommended. At a special meeting of Borough Council on February 16, 2006, Bridge Committee member Darl Haynes reported that per the Pennsylvania Department of Community and Economic Development, the proposed reconstruction of the Buck Bridge did not meet requirements for CDBG funding. Considerable discussions occurred during the meeting regarding the Borough’s ability to repay a loan for the bridge project. Following discussion regarding citizen requests to delay awarding the contract to Delta until funds were approved, a motion was made by Donald Haynes and seconded by Fred Rhone to award the bid to Delta for the design of the bridge at the bid rate of $16,500. The motion passed by a vote of 5 to 1 with Respondent and Robert Buck voting in favor of the motion. On February 24, 2006, Borough Council sent a letter signed by Respondent to Congressman Donald Sherwood, seeking a $10,000 grant for the Buck Bridge rehabilitation. On or about March 2, 2006, Gurske met with Kennicutt at the Delta office. Gurske indicated that no grant would be issued and that Respondent had a conflict of interest. Gurske urged that Delta suspend work on the project to give Gurske and others time to legally stop the project. That same day, Kennicutt called Respondent to discuss Gurske’s visit. Respondent directed Kennicutt to stick to the original schedule and stated that the bridge project would go on regardless of whether the grant was approved. At a March 6, 2006, Borough Council meeting, Respondent and Robert Buck voted in favor of a motion to apply for an additional $10,000 of grant funding for the Buck Road Bridge. The grant application was ultimately denied by the Commonwealth. Also at the March 6, 2006, Borough Council meeting, Respondent answered questions regarding ownership of the Buck Road Bridge by stating that it was the Board’s opinion that the bridge is a Borough bridge. Respondent responded to questions regarding estimates for the repairs to the Buck Bridge by advising residents that the Borough would pay the $16,500 design fee. Capital improvements, including work on Buck Road to make it easier for large trucks to access the road, were also discussed at the March 6, 2006, Borough Council meeting. Respondent asserts that the work was done as required by specifications of the Pennsylvania Department of Transportation (“PennDOT”). Per the meeting minutes, Robert Buck seconded a motion to hire Miller Brothers to perform the work, and both Respondent and Robert Buck voted to approve the motion. The motion carried with Gurske opposed. Rhone, 10-014 Page 39 At the Borough Council meeting on April 5, 2006, Respondent and Robert Buck voted in favor of motions to send easements to the landowners involved in the Buck Road Bridge project and to apply for all necessary permits concerning the project. At the Borough Council special meeting on May 25, 2006, the issue of whether the Buck Road Bridge was a County or Borough Bridge was again raised, and Respondent as Council President again stated that the Buck Road Bridge was a Borough bridge. On June 5, 2006, Kennicutt sent a letter to the Borough to the attention of Respondent regarding increased construction costs for the Buck Road Bridge repairs due in part to additional environmental and erosion control measures required by the Pennsylvania Department of Environmental Protection (“DEP”). Respondent served as the contact with DEP for issues regarding the Buck Road Bridge. Respondent also served as the Borough’s contact with PennDOT representatives regarding use of Liquid Fuels funds and approval of the Buck Road Bridge design. Respondent is listed on a project approval form dated July 6, 2006, as the person interviewed regarding use of Liquid Fuels money. Respondent asserts that the Municipal Services Representative for PennDOT orally informed him that the use of the Liquid Fuels money for the Buck Road Bridge was appropriate. At the July 5, 2006, Borough Council meeting, Council approved a motion to advertise for bids from lending institutions to borrow up to $70,000 for the reconstruction of Buck Road Bridge. The motion passed by a vote of 5 to 1. Both Respondent and Robert Buck participated in discussions leading up to the vote and were in favor of borrowing the money. Robert Buck voted in favor of the motion. Respondent was present at the meeting, and there is no record of him abstaining from the vote. At the August 2, 2006, Borough Council meeting, bids from lending institutions were opened and reviewed. After discussion regarding the bids, Council approved a motion to award the bid to PennStar Bank for two loans, including a $70,000 loan to be used for the Buck Road Bridge. Respondent and Robert Buck participated in the discussions and voted in favor of the motion, which passed by a 6 to 1 vote. On September 6, 2006, Respondent, acting as Borough Council President, signed PennStar Bank’s offer for the $70,000 loan for the Buck Road Bridge project. The loan terms provided for annual payments of $8,907.52 due in June of each year. These payments represented between 19.28% and 25.28% of total Borough revenues. At the October 4, 2006, Borough Council meeting, Council approved a motion to begin the process to “close” on the $70,000 loan for the Buck Bridge project. Respondent and Robert Buck voted in favor of the motion, which was approved by a vote of 5 to 1. On December 6, 2006, Borough Council approved advertising for an ordinance to borrow the $70,000 to repair Buck Road Bridge. The motion approving the ordinance was seconded by Robert Buck and was approved by a 6 to 1 vote with both Respondent and Robert Buck voting with the majority. At the December 6, 2006, Borough Council meeting, Borough citizens presented a petition to reject Borough taxpayer funding of the repair/upgrade to the Buck Road Bridge. The petition contained the signatures of 68 Borough residents. The Borough’s total population in 2006 was between 216 and 228 people. The petition was not acknowledged or addressed by the Borough Council at its December 6, 2006, meeting, or at any subsequent meetings. Rhone, 10-014 Page 40 On January 3, 2007, Borough Council approved Ordinance No. 2007-01 authorizing the borrowing of $70,000 from PennStar Bank for the construction, repair or replacement of Buck Bridge. Robert Buck made the motion to adopt the ordinance, and Respondent and Robert Buck voted to approve the ordinance. Respondent signed Ordinance No. 2007-01 as Borough Council President. Robert Buck signed Ordinance No. 2007-01 as a Borough Councilmember. Because the Borough did not have other funds to repair the Buck Road Bridge, the bridge would not have been repaired without the passage of Ordinance No. 2007-01. At the March 7, 2007, Borough Council meeting, Respondent and Robert Buck participated in actions to approve changes to Buck Road to allow for an easier access for trucks. On March 15, 2007, PennStar Government Financial Services issued to the Borough a General Obligation Note in the amount of $70,000 for the Buck Road Bridge project. The General Obligation Note was signed by Respondent as President of Borough Council and by Robert Buck as Councilman. In April 2007 Robert and Lillian Buck and Respondent and Alice Rhone applied to the Township for approval of a subdivision to be accessed by the Buck Road Bridge. The subdivision request was denied in August 2007 due to a permit issue resulting from the closure of Section 2 of Route 671. After the Buck Road Bridge repairs were completed, Respondent and Robert Buck did not resubmit the subdivision application. On August 1, 2007, Borough Council approved a motion to solicit bids for the Buck Bridge project. Respondent and Robert Buck voted in favor of the motion, which was approved by a 6 to 1 vote. Borough Council also voted to approve Resolution No. 2007-02 to officially accept the Bucks Falls Road, Route 671, into the road system of the Borough. Robert Buck made the motion and both Respondent and Robert Buck voted to approve the Resolution. Resolution No. 2007-02 was signed by Respondent as Borough Council President and by Robert Buck as Councilmember. At the September 5, 2007, Borough Council meeting, bids for the Buck Road Bridge project were opened. The bids ranged from $85,000 to $198,200. After reviewing and discussing the bids, Council voted to reject all bids and contact Delta to change the specifications for re-bidding the project at a later date. Respondent and Robert Buck participated in the vote to reject the bids. On September 10, 2007, and September 13, 2007, Darl Haynes and Kennicutt discussed reducing the costs of the repairs to Buck Road Bridge. Kennicutt told Haynes that the Borough’s best bet was to narrow the structure. Haynes told Kennicutt that option was not “on the table.” Buck and Respondent needed the wider width. On or about September 14, 2007, a supplemental agreement to the original agreement with Delta for the Buck Bridge project was sent to the Borough, which included the additional work to change the bid specifications for the project. The total fee for Delta’s work on the bridge was increased from $16,500 to $16,900. The agreement was signed for acceptance by Respondent as Borough Council President. At a September 18, 2007, special meeting of Borough Council, the amended contract with Delta was presented and approved by Council to amend the bid specifications for the project by removing the approach work and gabion work. The motion was made by Respondent and passed by a vote of 5 to 1. Respondent and Robert Buck voted in favor of the motion. Also at this meeting, Robert Buck made a motion to re-bid the project with the changes as outlined by Delta and set the bid opening for October 9, 2007. Respondent and Robert Buck voted in favor of that motion as well. Rhone, 10-014 Page 41 At a special meeting on October 9, 2007, Borough Council opened the bids for the Buck Road Bridge rehabilitation project. The bids ranged from $72,000 to $108,710. The low bid was from ProCon Contracting. At an October 12, 2007, Borough Council meeting, Council awarded a contract in the amount of $72,000 to ProCon Contracting for the construction of the Buck Bridge project. Respondent seconded the motion to award the contract, and Respondent and Robert Buck voted to approve the motion. Prior to the vote, Respondent was questioned as to how the Borough planned to come up with the money. Respondent responded that he felt the project was “workable” using both general and state Liquid Fuels funds. On October 25, 2007, Respondent as Borough Council President signed the agreement between ProCon Construction and the Borough for the Buck Bridge project. At a November 7, 2007, Borough Council meeting, Respondent and Robert Buck participated in approving motions relating to the installation of gabion baskets at the Buck Bridge, which work ultimately was not done. Robert Buck made a motion to hire Blue Ridge Better Builders at the cost of $3,000 to monitor the construction and oversee the Buck Bridge Project. The motion was seconded by Respondent and approved by a 5 to 1 vote, with Respondent and Robert Buck voting in favor of the motion. At a May 7, 2008, Borough Council meeting, Respondent made a motion and voted to have a letter sent to the Township alerting the Township that the Buck Road Bridge would be complete at the end of May and the Township would be able to work its end of the road. Per the meeting minutes, the Borough would inform the Township when the bridge would be usable. The Buck Bridge project was completed in the summer of 2008. Respondent and Robert Buck participated in issuing Borough payments totaling $95,200 for engineering and construction services related to Buck Bridge. At a June 4, 2008, meeting of Borough Council, Respondent and Robert Buck voted in favor of a motion to pay $72,000 to ProCon and $3,000 to Blue Ridge Better Builders. The motion passed by a 6 to 1 vote. $18,000 was to be paid from the State Liquid Fuels fund, and the remaining $57,000 was to be paid from the Borough’s General Fund. As an authorized Borough signatory, Respondent signed the three Borough checks issued on June 4, 2008, to pay the aforesaid amounts from the respective funds. (Ultimately, PennDOT notified the Borough to reimburse the Borough’s Liquid Fuels Tax Fund for the $18,000 payment.) The Borough paid Delta a total of $16,900 for work on the Buck Road Bridge. Respondent voted to approve at least four Borough payments totaling $16,500 to Delta. Respondent signed all Borough checks issued to Delta for work on the Buck Road Bridge. The Borough also paid Miller Brothers Earthmovers $3,300 for work on the Buck Road Bridge and preparation for paving. In May and June of 2008, the Borough received private donations totaling $22,000 to assist with paying for the Buck Road Bridge repairs, including an $8,000 donation from Buck Brothers Farm. The difference between the Borough’s expenditures for the bridge rehabilitation ($95,200) and the donations received by the Borough ($22,000) is $73,200. From June 2007 through August 2010, the Borough made four payments totaling $30,275.36 to PennStar Bank for the loan for the repairs to Buck Road Bridge. As an authorized Borough signatory, Respondent signed three of the four Borough checks by which such payments were made. The checks signed by Respondent totaled $26,722.56. Rhone, 10-014 Page 42 The chart at Fact Finding 94 details Respondent’s uses of the authority of his public position to facilitate the repairs to Buck Road Bridge. Respondent’s actions included: (1) voting to authorize repairs, borrow money, and select contractors; (2) approving payments to contractors; and (3) serving as the Borough’s primary point of contact with contractors and engineers. Respondent’s only abstentions during the entire time period when the Buck Road Bridge was being acted on by Council occurred in 2006 when he abstained from votes to apply for grants and to advertise for the selection of engineers. Respondent’s property was the only Borough property to benefit from the renovations to the Buck Road Bridge. Although Respondent asserts that the rehabilitation of the bridge benefitted other users of the bridge including the general public and landowners in the Township, the parties have stipulated that no individuals benefitted to the same degree as Respondent and Robert Buck. As for Respondent’s SFIs, in or about May 2010, the Investigative Division of this Commission conducted an SFI Compliance Review of the Borough. The only SFI on file with the Borough for Respondent was for the 2004 calendar year. No SFIs were on file with the Borough for Respondent for calendar years 2005, 2006, 2007, 2008, 2009 and 2010. 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 Rhone’s participation in discussions and actions of the Borough Council to authorize repairs and/or improvements to a bridge using Borough funds for the benefit of Rhone and/or members of his immediate family and Buck Brothers Farm, a business with which he is associated. b. That a violation of Section 1104(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(a) occurred when Rhone failed to file Statements of Financial Interests for the 2005, 2006, 2007, 2008, and 2009 calendar years. 4. Rhone agrees to make payment in the amount of $17,500.00 in settlement of this matter as follows: a. $9,000.00 by certified check or money order payable to the Starrucca Borough State Liquid Fuels Tax account and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. b. $8,500.00 by certified check or money order payable to the Starrucca Borough and forwarded Rhone, 10-014 Page 43 to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. i. Rhone is making a non-binding request that payment of the $8,500.00 be applied to the PennStar Bank loan taken out by the Borough for bridge repairs. 5. Rhone agrees to not accept any reimbursement, compensation or other payment from Starrucca Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. 6. Rhone agrees to file accurate and complete Statements of Financial Interests for calendar years 2005, 2006, 2007, 2008, and 2009 with Starrucca Borough within thirty (30) days of the issuance of the final adjudication in this matter. Copies of said forms shall be forwarded to the State Ethics Commission for compliance verification purposes. 7. 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 1-2. In considering the Consent Agreement, we agree with the parties that a violation of Section 1103(a) of the Ethics Act occurred in relation to Respondent’s participation in discussions and actions of the Borough Council to authorize repairs and/or improvements to the Buck Road Bridge using Borough funds, which benefitted Respondent and/or members of his immediate family and Buck Brothers Farm, a business with which Respondent is associated. Each element of a violation of Section 1103(a) has been established. As President of Borough Council, Respondent was instrumental in getting Borough Council to rehabilitate the Buck Road Bridge at Borough expense and in accordance with his and Robert Buck’s desired specifications, despite the concerns of citizens and at least one other Councilman as to whether the Borough owned the Bridge or could afford to pay for the repairs. Respondent’s extensive official actions as set forth in the Stipulated Findings and detailed at Fact Finding 94 included: (1) voting to authorize repairs, borrow money, and select contractors; (2) approving payments to contractors; and (3) serving as the Borough’s primary point of contact with contractors and engineers. Respondent’s only abstentions during the entire time period when the Buck Road Bridge was being acted on by Council occurred in 2006 when he abstained from votes to apply for grants and to advertise for the selection of engineers. The private pecuniary benefit to Respondent/Respondent’s wife and Buck Brothers Farm--a business with which Respondent and his wife are associated as 50% owners-- consisted of the rehabilitation of the Buck Road Bridge at Borough expense in accordance with Respondent’s and Robert Buck’s desired specifications, and the resulting Rhone, 10-014 Page 44 responsibility of the Township--rather than the Rhones and Bucks--to maintain Section 2 of Route 671. The rehabilitation to the Buck Road Bridge included a wider traveling width and increased weight limit that met the needs of Buck Brothers Farm for crossing the bridge with heavy equipment. Respondent’s property was the only Borough property to benefit from the renovations to the Buck Road Bridge. Although Respondent asserts that the rehabilitation of the bridge benefitted other users of the bridge including the general public and landowners in the Township, no individuals benefitted to the same degree as Respondent and Robert Buck. With each element of a violation of Section 1103(a) established, we hold that a violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Respondent’s participation in discussions and actions of the Borough Council to authorize repairs and/or improvements to a bridge using Borough funds for the benefit of Respondent and/or members of his immediate family and Buck Brothers Farm, a business with which he is associated. We further hold that a violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Respondent failed to file SFIs for the 2005, 2006, 2007, 2008, and 2009 calendar years. As part of the Consent Agreement, Respondent has agreed to make payment in the amount of $17,500.00 as follows: (a) $9,000.00 by certified check or money order payable to the Starrucca Borough State Liquid Fuels Tax account and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter; and (b) $8,500.00 by certified check or money order payable to Starrucca Borough and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. We note that Respondent has made a non-binding request that payment of the $8,500.00 be applied by the Borough to the PennStar Bank loan taken out by the Borough for bridge repairs. Respondent has agreed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. Respondent has further agreed to file with the Borough accurate and complete SFIs for calendar years 2005, 2006, 2007, 2008, and 2009 within thirty (30) days of the issuance of the final adjudication in this matter, and to forward copies of all such filings to this Commission for compliance verification purposes. We determine that the Consent Agreement submitted by the parties sets forth a proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Respondent Rhone is directed to make payment in the amount of $17,500.00 as follows: (a) $9,000.00 by certified check or money order payable to the Starrucca Borough State Liquid Fuels Tax th account and forwarded to this Commission by no later than the thirtieth (30) day after the mailing date of this adjudication and Order; and (b) $8,500.00 by certified check or money order payable to Starrucca Borough and forwarded to this Commission by no later than th the thirtieth (30) day after the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Respondent Rhone is further directed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. Rhone, 10-014 Page 45 To the extent he has not already done so, Respondent Rhone is directed to file with the Borough accurate and complete SFIs for calendar years 2005, 2006, 2007, 2008, and th 2009 by no later than the thirtieth (30) day after the mailing date of this adjudication and Order, and to forward copies of all such filings to this Commission for compliance verification purposes. 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. As a Member of Borough Council for Starrucca Borough (“Borough”) since approximately December 2004, Respondent Kirk Rhone (“Rhone”) has been a public officialsubject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. 2. Rhone violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), when he participated in discussions and actions of the Borough Council to authorize repairs and/or improvements to a bridge using Borough funds for the benefit of Rhone and/or members of his immediate family and Buck Brothers Farm, a business with which he is associated. 3. A violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Rhone failed to file Statements of Financial Interests for the 2005, 2006, 2007, 2008, and 2009 calendar years. In Re: Kirk Rhone, : File Docket: 10-014 Respondent : Date Decided: 9/27/11 : Date Mailed: 10/4/11 ORDER NO. 1591 1. As a Member of Borough Council for Starrucca Borough (“Borough”), Wayne County, Kirk Rhone (“Rhone”) violated Section 1103(a) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1103(a), when he participated in discussions and actions of the Borough Council to authorize repairs and/or improvements to a bridge using Borough funds for the benefit of Rhone and/or members of his immediate family and Buck Brothers Farm, a business with which he is associated. 2. A violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Rhone failed to file Statements of Financial Interests for the 2005, 2006, 2007, 2008, and 2009 calendar years. 3. Per the Consent Agreement of the parties, Rhone is directed to make payment in the amount of $17,500.00 as follows: (a) $9,000.00 by certified check or money order payable to the Starrucca Borough State Liquid Fuels Tax account and forwarded to the Pennsylvania State Ethics Commission by no later than the th thirtieth (30) day after the mailing date of this Order; and (b) $8,500.00 by certified check or money order payable to Starrucca Borough and forwarded to the th 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, Rhone is further directed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. 5. To the extent he has not already done so, Rhone is directed to file with the Borough accurate and complete Statements of Financial Interests for calendar years 2005, th 2006, 2007, 2008, and 2009 by no later than the thirtieth (30) day after the mailing date of this Order, and to forward copies of all such filings to the Pennsylvania State Ethics Commission for compliance verification purposes. 6. Compliance with Paragraphs 3, 4, and 5 of this Order 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