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HomeMy WebLinkAbout1593 Kaltenbaugh In Re: Jack Kaltenbaugh, : File Docket: 10-019 Respondent : X-ref: Order No. 1593 : Date Decided: 9/27/11 : Date Mailed: 10/6/11 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.” An Answer was filed and a hearing was requested. A Stipulation of Findings and a Consent Agreement 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 Jack Kaltenbaugh, a public official/public employee in his capacity as a Supervisor for Connoquenessing Township, Butler County, violated Section 1103(a) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. § 1103(a), when he used the authority of his public position for [the] private pecuniary benefit of himself and/or a business with which he is associated by participating in discussions and actions of the Board of Supervisors to approve matters regarding a subdivision/land development application being considered by the Board at a time when his company was performing excavating and construction services in relation to the project that was the subject of the application or when he had a reasonable expectation that his company would be considered for or receive contracts in relation to that project. II.FINDINGS: 1. Jack Kaltenbaugh has served as a Supervisor for Connoquenessing Township (hereafter “Township”), Butler County since January 7, 2008. a. Kaltenbaugh has served as Vice Chairman of the Board of Supervisors from January 7, 2008, to the present. b. Kaltenbaugh has served as Township Road Master from January 7, 2008, to the present. Kaltenbaugh, 10-019 Page 2 c. Kaltenbaugh served as Township Code Enforcement Officer from January 7, 2008, to December 31, 2008. 2. Kaltenbaugh previously served as a Township Supervisor for two consecutive terms spanning from January 6, 1992, to December 31, 2003. a. Kaltenbaugh served as Vice-Chairman of the Board of Supervisors from 1992 to 1998. b. Kaltenbaugh served as Chairman of the Board of Supervisors from 1999 to 2003. 3. Connoquenessing Township is governed by a three-Member Board of Supervisors. a. Supervisors hold legislative meetings on the first Wednesday of each month at 7:00 p.m. b. Supervisors hold special meetings as necessary. 4. Township Supervisors are compensated $156.25 (gross) and $137.93 (net) monthly for their service. a. Attendance at the monthly meeting is not required in order to receive the monthly stipend. 5. Board voting occurs in roll call fashion after a motion is made and seconded. a. All objections and abstentions are noted in the minutes. 1. The minutes of each meeting are approved for accuracy at each subsequent meeting. 6. The Township Supervisors are responsible for appointing Members of the Township Planning Commission (hereafter “Planning Commission”). a. Appointments generally are made at the Supervisors' re-organizational meeting held in January of each year. b. Exceptions to this practice occur due to resignations, untimely death, etc. 7. The Planning Commission is advisory to the Board of Supervisors and is to be composed of five Members. a. The Planning Commission was composed of four Members in 2009 due to a lack of community interest in serving on the Planning Commission. b. Appointees to the Planning Commission serve staggered terms ranging from one-year terms to five-year terms. 1. Planning Commission Members were appointed/re-appointed annually by the Board of Supervisors prior to 2007. 8. Developers interested in developing land within Connoquenessing Township are required to submit a land development application and plans to the Township approximately fifteen days prior to a Planning Commission meeting. Kaltenbaugh, 10-019 Page 3 a. The Township Engineer, Bill Braun, has approximately fifteen days prior to a Planning Commission meeting to review the application and plans submitted for consideration. b. Braun generates and submits a letter of recommendation to the Planning Commission/Supervisors advising them of the potential issues that the development might cause if the plans are approved as submitted. c. The Planning Commission is required to take action on plans within ninety days of them being submitted to the Township. 1. Actions that the Planning Commission can take include recommending the approval of the plans to the Supervisors, recommending a denial of the plans to the Supervisors, or taking no official action. 2. If no official action is taken by the Planning Commission, the plans are forwarded to the Supervisors for review as if they were recommended for approval by the Planning Commission. d. Plans are ultimately approved by the Supervisors after the developer and the Supervisors can come to a mutual agreement as to how the development is to be constructed. e. Both the Planning Commission and Supervisors have the opportunity to ask for an extension of time to review the plans. 1. Approximately three extensions is the maximum of extensions allowed to be taken by the Planning Commission and/or Supervisors. 9. Ronald Kaltenbaugh is Kaltenbaugh’s brother and a resident of the Township. 10. Ronald Kaltenbaugh has served as a Member of the Planning Commission from January 3, 2006, to the present. a. Ronald Kaltenbaugh was initially appointed to the Planning Commission on January 3, 2006, to serve a one-year term. 1. Kaltenbaugh was not a Supervisor in 2006 when his brother was appointed to serve on the Planning Commission. b. Ronald Kaltenbaugh was re-appointed to the Planning Commission on January 2, 2007, to serve a three-year term. 1. Jack Kaltenbaugh was not a Supervisor in 2007 when his brother was appointed to serve on the Planning Commission. c. Jack Kaltenbaugh seconded the motion to appoint his brother to a five-year term on the Planning Commission at the January 4, 2010, Supervisors' re- organizational meeting. 1. The vote at the January 4, 2010, re-organizational meeting extended Ronald Kaltenbaugh’s term into 2015. 11. Since or about 1982, Kaltenbaugh and his brother have each owned a 50% interest in JL & RE Building and Excavating (hereafter “JL & RE”), a business located within the geographical boundaries of the Township. Kaltenbaugh, 10-019 Page 4 a. The physical address of JL & RE is 184 Stevenson Road, Renfrew, PA 16053. b. The telephone numbers associated with JL & RE are listed below: 1. 724-321-0044: JL & RE business number 2. 724-321-2912: Ron Kaltenbaugh business cell number 3. 724-321-2479: Wayne Kaltenbaugh business cell number 4. 724-789-7555: JL & RE office number 5. 724-321-2910: Jack Kaltenbaugh business cell number c. JL & RE specializes in excavation work. d. JL & RE is not incorporated in the Commonwealth of Pennsylvania. 12. Honda North is an automobile dealership that has been operating within the geographical boundaries of the Township since approximately 2005. a. Honda North is owned by Joe Palmiero (hereafter “Palmiero”), John Palmiero (Joe Palmiero's son), and Howard Neff. 13. Honda North was located at and operated from 630 Evans City Road, Butler, PA 16001 from approximately 2005 to July 31, 2010. a. Honda North was renting building space and property from Robert Hollack during the time period that Honda North was located at 630 Evans City Road, Butler, PA 16001. b. The five-year rental agreement was set to expire on May 1, 2010. 14. Palmiero determined in early to mid-2007 that Honda North needed to expand in order to accommodate the growing number of Honda customers in Northwestern Pennsylvania. a. Palmiero’s decision was encouraged by the Honda corporation. 15. Palmiero began negotiations with Hollack in approximately early to mid-2007 for a new rental agreement between Honda North and Hollack. a. If unsuccessful in negotiating a new rental agreement, Palmiero was hopeful of purchasing the building and property located at 630 Evans City Road, Butler, PA 16001 from Hollack. 16. During the time period that Palmiero was negotiating with Hollack, Palmiero learned that Township residents Rick and Robb Ritenour were interested in selling approximately eight acres of property at the intersection of Route 68 and Kriess Road in the Township. a. The land for sale by the Ritenours was located less than one mile south of where Palmiero was renting building space and property from Hollack. Kaltenbaugh, 10-019 Page 5 17. The property for sale by the Ritenours consisted of two parcels of land, as identified below: a. Parcel #120-3F47-2AB-0000 (Lot 5R) consisting of 4.796 acres. b. Parcel #120-3F47-2Y-0000 (Lot 4R) consisting of 3.153 acres. 18. On April 25, 2007, a Land Purchase Option was entered into between the Ritenours and Palmiero. a. The agreement provided that the "Optionors" (Ritenours) agreed to give "Optionee" (Palmiero) two 6-month options to purchase Lot 4 and Lot 5 "containing 7.95 acres located at the intersection of Route 68 and Kriess Road, and referred to by the Butler County Tax Assessment Office as D/M/P120-3F47-2AB-0000 and D/M/P120-3F47-2Y-0000." 19. Palmiero contacted Paul Buettell, then Vice-President of Associated Contractors Inc. (“ACI”), in approximately mid to late 2007 to discuss ACI serving as project manager for construction of a new Honda North dealership at the location of the property owned by the Ritenours. a. Palmiero was still negotiating with Hollack at the time, but negotiations had stalled. b. Buettell started the planning of the new Honda North facility in approximately late 2007/early 2008. c. Buettell and Palmiero had maintained a business relationship from at least 2005. 1. ACI and Palmiero have maintained a business relationship for approximately fifteen years. 2. Palmiero was Buettell’s main contact at Honda North. 20. Buettell started the planning of the new Honda North facility prior to a written contract between Honda North and ACI due to Buettell's established business relationship with Palmiero. a. In late 2007/early 2008, Buettell utilized the services of an architectural firm, 4-Most Group, and an engineer, Engineering Development, to generate the preliminary plans for the new Honda North dealership. b. Buettell’s primary contact at 4-Most Group was architect/part-owner Richard Forsythe. [c]. Buettell’s primary contact at Engineering Development was engineer/owner Larry Smith. 21. Forsythe, on behalf of Honda North, submitted correspondence to the Township Planning Commission dated March 13, 2008, in preparation for a Pre-Application Conference with the Planning Commission scheduled for March 19, 2008. a. The correspondence documented Honda North's intentions to develop the property owned by the Ritenours. Kaltenbaugh, 10-019 Page 6 b. Palmiero did not own the Ritenours’ property at the time that the correspondence was sent to the Township. 22. On March 19, 2008, Forsythe met with the Planning Commission to discuss Honda North's intentions to build a new car dealership at the intersection of Route 68 and Kriess Road. a. Ronald Kaltenbaugh was present at the meeting as a Member of the Planning Commission. b. Members of the Planning Commission were not opposed to the plan presented by Forsythe. 23. The Planning Commission suggested to Forsythe that a traffic study be completed prior to land development plans being submitted to the Township Board of Supervisors for approval. a. The Planning Commission was concerned that a turning lane may be needed to avoid congestion at the intersection of the proposed dealership due to heavy traffic on Route 68. 24. On or about April 9, 2008, Forsythe contracted with David E. Wooster and Associates to conduct a traffic study at the intersection of Route 68 and Kriess Road to determine if any roadway changes would be needed to accommodate the additional traffic to the proposed dealership. a. David E. Wooster & Associates performed a traffic study from April 15, 2008, through April 19, 2008. 25. The results of the traffic study were published on or about May 20, 2008, and concluded that a turning lane on Route 68 would not be needed. a. The study recommended that a 110' northbound auxiliary right turn lane be constructed on Kriess Road, and that the traffic timing signals be optimized at the intersection of Route 68 and Kriess Road. b. Scott Snyder, District 10-0 Permit Engineer, PennDOT, reviewed the traffic study and concurred with the analysis done by David E. Wooster and Associates. c. Snyder forwarded correspondence dated June 4, 2008, to John Balay, Engineering Technician, David E. Wooster and Associates, advising that the traffic study be submitted to the Township for review. 26. The traffic study was submitted to the Township and discussed at the August 6, 2008, Supervisors’ meeting. a. Kaltenbaugh was present at the meeting. b. No action was taken by the Board to accept the study submitted on behalf of Honda North. 27. Both the Planning Commission and the Supervisors disagreed with the study’s conclusion that a left-hand turning lane was not needed on Route 68. Kaltenbaugh, 10-019 Page 7 a. Kaltenbaugh and his brother discussed the results of the study outside of a formal meeting setting and believed that a left-hand turning lane was needed on Route 68 regardless of what the results of the traffic study indicated. 28. On September 15, 2008, Palmiero finalized the purchase of the Ritenours’ parcels of land for 1.1 million dollars. a. The 4.796 acre parcel (#120-3F47-2AB-0000) (Lot 5R) sold for $700,000.00. b. The 3.153 acre parcel (#120-3F47-2Y-0000) (Lot 4R) sold for $400,000.00. 29. In or about March 2009, ACI’s construction project manager for the Honda North project began soliciting quotes from subcontractors. a. Then ACI Assistant Project Manager/Estimator Bryan Sealer was responsible for obtaining initial price quotes from subcontractors needed in relation to the construction of the Honda North project. 30. Sealer began obtaining price quotes from subcontractors in relation to the Honda North project as early as March 18, 2009. a. Sealer obtained price quotes to generate a pool of subcontractors to select from once Township approval was given for the project to begin. 1. The Township had not approved any Honda North plans by March 2009. b. Sealer did not solicit any quotes from JL & RE Excavating. c. Sealer left employment at ACI in June of 2009 without ever hearing of or contacting Kaltenbaugh’s business, JL & RE. 31. On June 1, 2009, a Subdivision and Land Development application and plans for the Honda North project were submitted to the Township for review by 4Most Group/Engineering Development. 32. Township Engineer Bill Braun reviewed the application and plans related to the new Honda North dealership between June 1, 2009, and June 15, 2009. a. On June 15, 2009, Braun issued a letter to the Planning Commission Members outlining twenty-three concerns he had with the Honda North land development plans. 1. Of the twenty-three concerns, Braun was most concerned with storm water management issues and turning lane issues that would result if the plans were approved as submitted. 33. On June 17, 2009, the Planning Commission (including Ronald Kaltenbaugh) discussed Braun's letter with Braun and Smith of Engineering Development, Honda North’s engineer. a. The Planning Commission tabled the Honda North land development plans to be reviewed at a later date. 1. The Planning Commission made no recommendation to the Township Supervisors to approve the Honda North land development plans at that time. Kaltenbaugh, 10-019 Page 8 b. The Planning Commission tabled the plans to provide Honda North time to revise the plans in order to address the twenty-three issues outlined in Braun's letter. 34. Kaltenbaugh, Sherry Lokhaiser (Planning Commission Member), and Township Engineer Braun met at the location of the proposed Honda North dealership subsequent to the June 17, 2009, Planning Commission meeting. a. Kaltenbaugh, Lokhaiser, and Braun primarily discussed the storm water management issues that would result via the construction of the proposed dealership. b. Township officials were concerned that if the storm water runoff was not managed correctly that businesses/residents located downhill from the proposed dealership might sue the Township for negligence if flooding problems occurred on their property subsequent to the construction of the dealership. 35. On or about June 19, 2009, Supervisor Hockenberry received correspondence from the Butler County Planning Commission (“BCPC”) indicating that the BCPC reviewed the Honda North plans in accordance with Section 502 (b) of the Pennsylvania Municipalities Planning Code. a. The BCPC advised Hockenberry of concerns of increased traffic that would result on Kriess Road due to the construction of the Honda North dealership. b. The BCPC further advised Hockenberry that PennDOT should review the plans to determine whether a turning lane would be needed both east and west on Route 68. 36. On June 26, 2009, Township Engineer Braun emailed Larry Smith, Engineer for Honda North (Palmiero) to inform him of his concerns with the storm water management being proposed by Engineering Development. a. Braun’s concerns were outlined in his email as follows: “Larry: 1. I am concerned about the storm water. You are adding approx. 8.8cfs (100 yr storm) to the Henry Kriess property which it does not currently receive. The storm system thru his property already appears inadequate. It is unclear if you have accounted for the entire tributary watershed for the Kriess storm system in the calcs. and does the inlet on Kriess rd surcharge. The location of the new point of interest is unclear. I suggest that the storm system thru the Kriess property be studied and replaced as necessary or you install a “parallel” storm system thru the Kriess (sic) property for the Honda North discharge only. 2. I am concerned about the additional runoff conveyed to the SR 68 storm system due to the additional pavement widening on Kriess Rd. Approval from PennDOT should be obtained.” 37. On June 30, 2009, Smith responded to the storm water concerns and the Route 68 turning lane issue via correspondence. Kaltenbaugh, 10-019 Page 9 a. Smith addressed Braun’s storm water concerns without proposing any changes to the storm water management plan submitted previously, and indicated that he was opposed to a parallel storm water system. b. Smith’s response also provided that “the installation of a turn lane on Route 68 was analyzed by David Wooster and Associates as a part of the traffic study for this project. It was deemed to not be required as confirmed in Wooster’s response dated June 16 that was previously submitted. In addition, PennDOT has reviewed and approved the results of the traffic study in their letter of August 6, 2008.” 38. On June 30, 2009, the Planning Commission recommended that the Supervisors approve the plans related to the new Honda North dealership contingent upon the Supervisors’ approval of the storm water management plan for the development. a. Ronald Kaltenbaugh was present at the June 30, 2009, meeting. b. The plans were recommended to the Supervisors for approval via a 4-0 vote with Ronald Kaltenbaugh voting affirmatively. 39. At the June 30, 2009, meeting, the Planning Commission approved a motion recommending the Supervisors contact PennDOT to discuss the potential need for a turning lane on Route 68. a. The motion passed unanimously via a 4-0 vote with Ronald Kaltenbaugh voting affirmatively. 40. At the July 1, 2009, meeting of the Township Supervisors, the Honda North plans were reviewed and discussed. a. Kaltenbaugh was present at the meeting. b. The Supervisors decided to table the plans for approval due to concerns regarding the need for a left-hand turning lane on Route 68, and the storm water management issues. 41. On July 10, 2009, correspondence was faxed to the Supervisors by Robert Bailey, Counsel to Joe Palmiero, which addressed the concerns expressed by the Supervisors at the July 1, 2009, meeting regarding the new Honda North facility. a. Bailey's correspondence indicated that his firm has been in contact with PennDOT representative David Tomaswick and that it was PennDOT's position based upon the David E. Wooster and Associates traffic study that a left-hand turning lane was not justified on Route 68 and that PennDOT would not allow the construction of a left-hand turning lane by a private developer without PennDOT approval. b. Additionally, Bailey addressed the Supervisors’ concern that possible legal action may come against the Township as a result of storm water draining from the new Honda North dealership onto the property of downstream landowners by citing LaForm v. Bethlehem Township and advised the Supervisors that "pursuant to Section 1501 of the Township SALDO" the owner (Palmiero) is required to release the Township from any responsibility related to storm water. c. Bailey concluded his correspondence by stating: Kaltenbaugh, 10-019 Page 10 "We understand that the advertisement for the township meeting on Monday July 13th did not include reference to the Honda North project. In light of the rapidly passing summer building season, we respectfully request a special meeting to be set before the end of July for consideration of the Honda North project approval. Honda North is willing to pay the advertising costs for such a meeting. Thank you for your kind consideration." 42. The Supervisors did not hold a special meeting in July 2009 to discuss the Honda North project as requested by Palmiero's attorney. a. The next regularly scheduled Supervisor meeting did not occur until August 5, 2009. 43. Palmiero was concerned that the Honda North project was losing valuable construction time due to the Township tabling the approval of the project on June 17, 2009, by the Planning Commission and July 1, 2009, by the Township Supervisors. a. Palmiero also wanted the project to proceed so that the project would be completed prior to the expiration of his rental agreement with Hollack. 44. As a result of the concerns raised by the Township Engineer and the Township Supervisors with Honda North’s plans, a relative of Palmiero contacted Donald Domhoff, a Township resident, for assistance in obtaining Township approval of Honda North’s plans. a. Domhoff previously served as a Member of the Township Planning Commission from approximately 2000 to 2008. 45. Domhoff met with Palmiero at Palmiero's Honda North office in or about June of 2009 to discuss the situation involving Honda North and the Township. a. The meeting was arranged by Palmiero or at Palmiero’s direction. b. Domhoff was informed that Honda North was having problems getting the plans approved. c. Domhoff advised Palmiero that he would assist Honda North in receiving Township approval. 46. In or about June and July 2009, Palmiero had discussions with ACI Manager Buettell, Domhoff, architect Forsythe, and engineer Smith in order to strategize ways to obtain Township approval of the Honda North project. a. The majority of the discussions took place via the telephone or at Palmiero's prior Honda North office. 47. Beginning on or about July 21, 2009, Kaltenbaugh began receiving telephone calls from individuals associated with the Honda North project. a. Domhoff and Palmiero both contacted Kaltenbaugh eight times between July 21, 2009, and July 23, 2009. 48. Kaltenbaugh maintains a cellular telephone through Sprint-Nextel. a. The telephone number assigned to Kaltenbaugh’s cellular telephone is 724- 321-2910. Kaltenbaugh, 10-019 Page 11 b. Kaltenbaugh maintained the cellular telephone at all times spanning the time frame of the Honda North project. c. Kaltenbaugh maintains a landline home telephone number through CenturyLink. 1. The telephone number associated with Kaltenbaugh’s home telephone number is [telephone number redacted]. 49. Kaltenbaugh's cellular telephone records reflect that the first receipt of telephone calls on his cellular telephone from Honda North representatives occurred after Kaltenbaugh’s tabling of the Honda North plans at the July 1, 2009, Supervisors’ meeting. a. Approximately one hour after Domhoff called Kaltenbaugh on July 21, 2009, Palmiero called Domhoff at 9:49 a.m. and at 11:30 a.m. 1. Palmiero and Domhoff spoke for sixteen minutes during their second conversation spanning the time frame of approximately 11:30 a.m. to 11:46 a.m. b. Approximately twenty-three minutes after Domhoff spoke with Palmiero for the second time on July 21, 2009, Domhoff called Kaltenbaugh at 12:09 p.m. and at 12:22 p.m. c. Palmiero talked to Domhoff and Buettell on July 22, 2009, for a combined total of fifteen minutes prior to a telephone call being placed from the Honda North dealership to Kaltenbaugh at 11:54 a.m. on July 22, 2009. 1. Palmiero subsequently called Kaltenbaugh three times during the evening of July 22, 2009. d. On July 23, 2009, Palmiero placed calls to Domhoff and Buettell for a combined total of forty-three minutes prior to Domhoff’s call to Kaltenbaugh on July 23, 2009, at 2:24 p.m. 50. Twenty-nine telephone calls totaling at least 128 minutes are documented as having occurred between representatives of Honda North, ACI, and JL & RE representatives between the dates of July 20, 2009, and July 23, 2009. 51. Neither Supervisors Evelyn Hockenberry nor Steve Misko were contacted outside of Township meetings by Honda North representatives during the same time period that Palmiero and Domhoff contacted Kaltenbaugh. 52. On or about July 16, 2009, Bailey, Counsel to Palmiero/Honda North, forwarded a letter to then Township Solicitor Robert Hawk documenting his conversation with Hawk on July 15, 2009. a. Bailey asserts in his letter that his client, Joe Palmiero/Honda North, is in full compliance with the Township’s requirements by referencing outcomes of various court cases. b. Bailey summarizes his letter by stating: “Time is of the essence and damages continue to mount because of the delays in approving this plan despite full compliance. We urge Kaltenbaugh, 10-019 Page 12 Connoquenessing Township to promptly approve this plan so Honda North can begin construction. Further delay will leave my client no choice but to consider alternative methods of obtaining approval and recovering the damages lost.” 53. Kaltenbaugh met with Palmiero at Palmiero’s Honda North office on at least one occasion between July 1, 2009, and August 4, 2009. a. Kaltenbaugh met with Palmiero to discuss how the Township and Honda North could come to an agreement in regards to addressing the storm water management aspects related to the Honda North project. 54. A letter dated August 4, 2009, was submitted to the Board of Supervisors by Palmiero, proposing a resolution to the Board’s primary concerns with the Honda North plans (Route 68 turning lane and storm water management). a. The letter was to be reviewed by the Board at its August 5, 2009, meeting. b. Palmiero’s letter provided that Honda North would reimburse the Township $87,500.00 for expenses actually incurred by Connoquenessing Township in its efforts to accomplish the completion of a left turn lane on Route 68 contingent upon the following five conditions: 1. “That Honda North receives, at the August 5, 2009 Township meeting, final approval of its plans and approval to proceed immediately with construction of its development project at the intersection of Kriess Road and Route 68. Time is very much of the essence and if such approval is not received on August 5, 2009, the above offer of contribution shall be automatically withdrawn.” 2. “This contribution offer is on the further condition that the Township selects between the Kriess Road and Route 68 storm-water management system proposed by Honda North, but if the Kress [sic] Road Storm-Water System is chosen by the Township, Honda North’s construction obligations shall be limited to those appearing on the Kriess Road Storm-Water Management drawings previously supplied to the Township by Honda North. If the Township desires any downstream work on the Kriess Road Storm-Water System, any such work shall be at the sole option and expense of the Township.” 3. “If the Township removes the requirement of Honda North to construct a turn-lane on Kriess Road, Honda North will raise the above contribution by the sum of Twenty-Five Thousand ($25,000) Dollars.” 4. “That the above offer of contribution is made as a legal commitment but is not to be paid unless and until the Township actually incurs expenses related to the Route 68 turn-lane, at which time Honda North will reimburse the Township for costs as and when incurred by the Township.” 5. “Any portion of the above contribution that is not expended by August 5, 2014 shall automatically expire on that date.” c. The Supervisors did not take any actions on the stipulations outlined within Palmiero’s August 4, 2009, proposal. Kaltenbaugh, 10-019 Page 13 55. The Board of Supervisors reviewed the Honda North plans at its August 5, 2009, meeting and voted to approve the plans subject to conditions. a. Kaltenbaugh was present at the meeting and participated in the discussions and the vote. b. A motion was made by Hockenberry and seconded by Kaltenbaugh to grant preliminary and final approval to the Honda North Development at Kriess Road and Route 68 contingent upon engineer review and approval of storm water plans and contingent upon signing of legal agreements requiring Honda North to deposit $87,500.00 in a Township account for improvements to Route 68. Bonding amount required is 110% of construction cost, which is $618,881.96. The motion was unanimously approved. 56. Honda North (Palmiero) was opposed to the contingencies approved by the Board. 57. On August 6, 2009, the day after the Board gave contingent approval to Honda North’s plans, Palmiero, Domhoff and Kaltenbaugh were engaged in a series of telephone calls. a. The calls were initiated by Palmiero at 11:15 a.m. on August 6, 2009, with a call to Domhoff. b. Domhoff had a return call to Palmiero at 2:26 p.m., which lasted nine (9) minutes. c. Immediately after ending the call with Palmiero, Domhoff had a five (5) minute call with Kaltenbaugh, which concluded at approximately 2:40 p.m. d. Domhoff then called Palmiero at 2:52 p.m. e. Also receiving calls from Palmiero during the 11:00 a.m. to 3:00 p.m. time frame was ACI Project Manager Paul Buettell. 58. No other Connoquenessing Township officials were contacted on August 6, 2009. 59. On August 7, 2009, Palmiero hosted a groundbreaking ceremony at the future Honda North location. a. Kaltenbaugh attended the August 7, 2009, groundbreaking ceremony with Palmiero, Domhoff, Buettell (ACI Project Manager) and other various individuals associated with the Honda North project. b. Kaltenbaugh was invited to the ceremony by Domhoff. c. No other Member of the Township Board of Supervisors was invited. 60. At the groundbreaking ceremony of August 7, 2009, Kaltenbaugh spoke with Buettell, ACI Construction Manager, regarding whether subcontractors were chosen for the preliminary site preparation related to the project. a. Buettell questioned Kaltenbaugh if Kaltenbaugh’s company was interested in fencing of the septic area of the project. b. Buettell later commented to Forsythe (architect for the Honda North project) that he (Buettell) would have to issue Kaltenbaugh a purchase order for an Kaltenbaugh, 10-019 Page 14 unknown dollar amount since Buettell had not obtained a quote or estimate from Kaltenbaugh to do the preliminary site work. 1. Quotes had previously been obtained from subcontractors intended to be used on the project. 2. Kaltenbaugh’s company, JL & RE, was not being considered for any project work prior to or about August 2009. 61. Kaltenbaugh called Buettell on August 10, 2009, from his business landline (724- 789-7555), at 7:20 a.m. with the call lasting 2 minutes. a. Buettell’s ACI cellular telephone (814-720-0502) records indicate that he was in the Connoquenessing Township area on August 10, 2009. 62. As of August 11, 2009, the Board of Supervisors and Palmiero had not reached an agreement in relation to a Route 68 turning lane and the storm water management. 63. On August 11, 2009, counsel for Honda North directed correspondence to the Board of Supervisors, which provided as follows: “Thank you very much for faxing me the appropriate pages of the draft Minutes of th the August 5 Township meeting dealing with the Honda North development project approval. I do, however, have one correction which should be made. th Our payment proposal at the August 5 meeting was to reimburse the Township (rather than deposit $87,500 at this time) as and when expenses are incurred related to the Route 68 turn lane. In a draft letter I provided to the Township Supervisors and your solicitor, the night of the meeting and earlier provided to Engineer, William Braun (copy attached), the agreement is that Honda North will legally obligate itself to reimburse Connoquenessing Township up to a maximum of $87,500 for expenses actually incurred by Connoquenessing Township in its efforts to accomplish the completion of a left turn lane on Rt. 68. Honda North agrees to reimburse for not only construction costs but also engineering drawings and expenses incurred in any grant applications as well as actual construction. As drafted, the Minutes speak of a deposit being made to Connoquenessing Township. A critical term of the negotiations with Mr. Braun prior to last week’s meeting, was that the expenditure by Honda North, while legally binding, would only occur if and when actual expenses were incurred directly related to the Rt. 68 turn lane. On behalf of my client, I request that you check with Mr. Braun to confirm this arrangement (i.e. that it is a reimbursement, not a deposit at this time) and make the appropriate changes in the minutes of the meeting and the resolution.” 64. At the August 5, 2009, Board meeting, the Supervisors (including Kaltenbaugh) did not agree to the proposal that Honda North would only reimburse the Township a maximum of $87,500.00 for expenses actually incurred by the Township in its efforts to accomplish the completion of a left turn lane on Route 68. 65. JL & RE began work on the Honda North project on August 12, 2009, two days after Kaltenbaugh called Buettell and six [sic] days after Kaltenbaugh participated in the conditional approval of the Honda North project. Kaltenbaugh, 10-019 Page 15 66. A JL & RE Job Order Form for “Customer Honda North” reflects that JL & RE performed work between August 12, 2009, and August 14, 2009, related to the construction of the new Honda North facility, as detailed below: JOB ORDER FORM JL & RE KALTENBAUGH Date Phone # Customer: Honda North Septic 8-12-09 Jack Install Chain Link Fence 8-13-09 Jack Labor 7hr, 7hr $175.00 8-14-09 Jack Labor 5 1/2hrs, 5 1/2 $137.50 8-13-09 Jack Home Depot 3x5 post $84.84 8-13-09 Jack Trader Horn Alum. Wire $21.00 Rental on Fence $381.50 Chain link - 6'H 400'L $763.00 plus tax $8,900.50 Paul @ Asso Contractors Cell 814-720-0502 Office 814-724-8200 a. Attached to the JL & RE Job Order Form was a “Celtic Healthcare” post-it note that stated the following: “Need Wayne’s hrs also. 8-13-09 10=5 (410) drove fence post 7hrs $490.00 8-14-09 7-12:30 Install fence – labor 5 ½ &137.50 <724-285-4000> Lowe’s” b. A yellow post-it note appended to the JL & RE order form stated: st “1 Worked Performed Verbal Contract Between Paul from Asso. Contractors + Jack K. Date Invoiced 8/31/2009. Start Date on Fence 8/12/2009 11/6/2009 CK 44886” c. Paul from Assoc. Contractors refers to Paul Buettell. 67. A letter dated August 11, 2009, from Palmiero’s attorney to the Supervisors was faxed to the Township on August 13, 2009, outlining Honda North’s understanding of the conditions set by the Board of Supervisors regarding costs of a turn lane and providing a consent and approval for the Board to sign. The letter noted the following: “Attached please find a proposed final letter outlining the specifics of the obligation of Honda North to contribute up to $87,500 towards costs related to the Rt. 68 to Kriess Road turn lane. The letter is substantially the same as the draft presented at th the August 5 meeting with the following exceptions: 1. The paragraph giving the Township the option of increasing the contribution by eliminating of the Kriess Road left turn lane has been eliminated at the request of the Township. Kaltenbaugh, 10-019 Page 16 2. Paragraphs 5 and 6 address the extent to which Honda North might receive some reimbursement of its payments to the Township in the event grants are obtained to pay all of or part of the cost of the Rt. 68 turn lane. Paragraph 5 deals with the situation on where full grant money is obtained with paragraph 6 addressing a situation where only part of the project costs are covered by grants. My client is prepared to sign the attached letter as soon as the Township approves its format. You will see I have also added at the end a “Consent and Approval” under which the Township consents to the terms and conditions of the letter and references the Resolution passed at the August 5, 2009 meeting.” 68. The August 13, 2009, proposed agreement submitted by Honda North to the Township Supervisors contained the following: “Subject to the terms and conditions set forth below, Honda North herby agrees to be legally obligated to reimburse Connoquenessing Township up to a maximum amount of Eighty-seven Thousand Five Hundred and 00/100 ($87,500) Dollars for expenses actually incurred by Connoquenessing Township in its efforts to accomplish the completion of a left turn lane on Route 68 (on to Kriess Road). This would include reimbursement for actual expenses incurred in any grant applications and, of course, actual construction costs incurred by the Township. This offer is, however, under and subject to the following conditions: 1. That Honda North receives, at the August 5, 2009 Township meeting, final approval of its plans and approval to proceed immediately with construction of its development project at the intersection of Kriess Road and Route 68. Time is very much of the essence and if such approval is not received on August 5, 2009, the above offer of contribution shall be automatically withdrawn. 2. This contribution offer is on the further condition that the Township selects between the Kriess Road and Route 68 storm-water management system proposed by Honda North, but if the Kriess Road Storm-Water System is chosen by the Township, Honda North’s construction obligations shall be limited to those appearing on the Kriess Road Storm-Water Management drawings previously supplied to the Township by Honda North. If the Township desires any downstream work on the Kriess Road Storm-Water System, any such work shall be at the sole option and expense of the Township. 3. That the above offer of contribution is made as a legal commitment but is not to be paid unless and until the Township actually incurs expenses related to the Route 68 turn-lane at which time Honda North will reimburse the Township for costs as and when incurred by the Township. 4. Any portion of Honda North’s obligation to reimburse that has not been expended by August 5, 2014 shall automatically expire on that date. 5. In the event Connoquenessing Township receives any sum or sums of money, other than from township tax receipts, not requiring repayment and/or reimbursement by Township and said payments are used to pay the costs of the design and construction of the Rt. 68 turn lane, (including but not limited to state and federal grants which sums Kaltenbaugh, 10-019 Page 17 (collectively referred to as “Grant Money”)) and said sum or sums equal to exceed the cost of the design and construction of the Rt. 68 turn lane, Honda North shall be released from any obligations to reimburse Township for said costs and Township shall repay to Honda North, all sums Honda North has reimbursed to Township. 6. If the Total Grant Money received by Township or paid directly for project costs does not pay the entire cost of the design and construction of the Rt. 68 turn lane, Honda North shall be reimbursed by Township for payments made and relieved of future payment obligations to pay Township in an amount equal to ½ of the total Grant Money received by Township or applied against Route 68 turn lane project.” 69. Kaltenbaugh/JL & RE was actively working at the Honda North site during the time period that the August 13, 2009, agreement was submitted to the Township for consideration of meeting the contingencies cited by the Board at the August 5, 2009, meeting. 70. Between August 24, 2009, and September 9, 2009, Kaltenbaugh and Buettell (Honda North Project Manager) maintained regular telephonic contact. a. Palmiero also telephonically contacted Kaltenbaugh during this time. b. These contacts occurred during the period when the Township had placed contingencies on Honda North’s plans, which had not been implemented. 71. Between August 24 and September 9, 2009, Kaltenbaugh and Buettell spoke by telephone on seventeen occasions for a total of thirty-three minutes. a. Buettell’s ACI cellular records show that he was in the Connoquenessing Township area on the following dates: 1. August 31, 2009 2. September 1, 2009 3. September 2, 2009 4. September 4, 2009 5. September 9, 2009 6. September 16, 2009 7. September 17, 2009 b. Buettell and/or Palmiero contacted and/or were contacted by Kaltenbaugh via telephone on the following five days that Buettell was in the Connoquenessing Township area: 1. August 31, 2009 2. September 1, 2009 3. September 2, 2009 Kaltenbaugh, 10-019 Page 18 4. September 4, 2009 5. September 9, 2009 c. Supervisors Hockenberry and Misko were not contacted during this time frame by any Honda North representative. 72. Kaltenbaugh called Buettell on September 2, 2009, at 7:37 a.m. and spoke for five minutes on the same day as the Board of Supervisors was scheduled to meet to act on Honda North’s August 13, 2009, proposal. 73. On September 2, 2009, Buettell and ACI Project Manager Kevin Tinko traveled to the Honda North site together. a. Buettell was familiarizing Tinko with the Honda North project since Buettell was leaving the project and Tinko was to take over for him as Project Manager. b. Buettell made him aware of several subcontractors including JL & RE. 1. Buettell made Tinko aware of Supervisor Kaltenbaugh’s association with JL & RE. 74. At the September 2, 2009, Supervisor meeting, the Supervisors reviewed the August 13, 2009, agreement proposed by Honda North via fax. a. Kaltenbaugh was present at the September 2, 2009, meeting and participated in the discussions regarding the agreement. b. Supervisor Steve Misko stated that he opposed paragraphs three, five, and six of the agreement. c. The Supervisors (including Kaltenbaugh) voted 3-0 to not accept the agreement proposed by Honda North. 75. Tinko’s ACI cellular telephone (814-720-9784) records reflect that on September 16, 2009, at 8:29 a.m., Tinko called Kaltenbaugh’s residence. 76. Kaltenbaugh and his brother submitted a proposal to ACI on September 16, 2009, in relation to digging footers for the structure of the Honda North dealership. a. Kaltenbaugh and his brother previously presented their verbal bid to Tinko at the Honda North project work site. b. The bid was memorialized on an ACI Phone Bid sheet dated September 16, 2009. c. The initial bid provided by JL & RE was in the amount of $36,800.00. 77. On September 17, 2009, ACI negotiated with Kaltenbaugh and his brother a reduction in the JL & RE bid from $36,800.00 to $33,200.00. a. Kaltenbaugh and his brother agreed to perform the footer work for the negotiated price of $33,200.00. b. The negotiated price of $33,200.00 was memorialized on the ACI Phone Bid sheet dated September 16, 2009, indicating an addendum had occurred on Kaltenbaugh, 10-019 Page 19 September 17, 2009, reducing the cost of the work from $36,800.00 to $33,200.00. 78. JL & RE entered into a contract with ACI on September 18, 2009, to perform work related to the Honda North project to include “the installation of concrete footings and piers, to include rebar and foundation insulation installation, excavation, and backfill” for $33,200.00. a. The agreement provided that the subcontract sum of $33,200.00 included “labor, materials, equipment, services, and other items required to complete the agreed upon work.” b. The agreement also stipulated that the subcontract sum of $33,200.00 was “subject to additions and deductions as provided within the subcontract documents.” c. Kaltenbaugh executed the agreement on behalf of JL & RE on September 18, 2009. 79. At the time Kaltenbaugh/JL & RE submitted the bid to ACI and signed the contract for the footer work at the Honda North job site, the Township had not approved the contingencies for the project. 80. ACI Superintendent Daily Reports confirm that JL & RE performed work at the Honda North job site on seventeen occasions from September 21, 2009, through October 20, 2009, until its contractual agreement with ACI was complete. 81. Additional ACI Superintendent Daily Reports reflect that JL & RE performed miscellaneous work at the Honda North job site between October 21, 2009, and November 3, 2009, as shown below: Report Date Description of Work Completed by JL & RE ACI Superintendent's Signature 10-21-2009 Load out dirt, J & R 8 loads Unknown 10-22-2009 Load out dirt, J & R 4 loads Unknown 10-30-2009 ACI – clean up job site, called Jack to take fence down Steve Minor at septic location 11-3-2009 J & R – demo fence that was in our way Steve Minor a. The JL & RE work described above was performed at no charge to ACI. 82. At the October 7, 2009, Board of Supervisors meeting, Township Engineer Braun informed the Board that storm water running off of the Honda North facility was to be discharged via a pipe down Kriess Road to an existing outlet. a. No other discussions regarding the contingencies of the Honda North project [occurred]. 83. Kaltenbaugh kept in telephonic contact with Minor and Tinko while JL & RE was performing work related to the footers of the Honda North dealership as well as performing other miscellaneous work. Kaltenbaugh and Minor were in telephonic contact eight times on September 23 and September 29, 2009, for a total of in excess of 13 minutes. Kaltenbaugh and Tinko were in telephonic contact six times between October 19 and November 3, 2009, for a total of 13 minutes. Kaltenbaugh, 10-019 Page 20 84. On or about November 4, 2009, Kaltenbaugh and Hockenberry, in their capacities as Township Supervisors, agreed to Honda North’s proposal to resolve the outstanding issues (turn lane and storm water management). a. Kaltenbaugh consented to and approved the August 13, 2009, agreement proposal by Honda North. b. Kaltenbaugh’s and Hockenberry’s signing of the agreement enabled Honda North to proceed with the project. 85. There was no vote of the Board of Supervisors approving the proposal. a. Minutes of the Board of Supervisors’ meeting of November 4, 2009, confirm no vote or action of the Board. b. Minutes reflect under Solicitor’s report the following: “The agreement between Honda North and Connoquenessing Township that Honda North contribute $87,000 to the building of a turning lane on Rt. 68 when construction of lane begins and if said lane is to be paid with taxpayer monies only. The agreement was signed by Hockenberry and Kaltenbaugh. Misko, opposed.” 86. The agreement proposed by Honda North contains the signatures of Kaltenbaugh and Hockenberry approving the terms and condition set forth by Honda North. a. Supervisor Misko was opposed to the agreement and refused to sign the document. 87. Without Kaltenbaugh’s signature on the agreement approving the terms, Honda North would not have been able to complete the project. a. Honda North wanted the project to advance as it considered time of the essence due to the passing of the building season. 88. By signing the agreement proposed by Honda North, Kaltenbaugh agreed to the following: a. To accept the storm water management systems proposed by Honda North. b. Not requiring Honda North to escrow an amount of $87,500.00 in a Township-controlled escrow account for the completion of a left turn lane on Route 68 onto Kriess Road. 89. Palmiero and Domhoff and Kaltenbaugh maintained telephonic contact immediately prior to and after the November 4, 2009, Board meeting by 14 phone calls between the parties totaling in excess of 112 minutes. a. Kaltenbaugh was contacted by both Domhoff and Palmiero on November 5, 2009, after Kaltenbaugh signed the consent for the Route 68 agreement at the November 4, 2009, Supervisor meeting. 90. Supervisor Hockenberry was not contacted by Palmiero or Domhoff before or after the November 5, 2009, meeting. 91. Supervisor Misko received a telephone call from Domhoff on or about November 4, 2009, requesting him to reconsider his position on the Honda North proposal. Kaltenbaugh, 10-019 Page 21 a. Misko had been opposed because the agreement did not require Honda North to escrow funds for any improvements deemed necessary. 92. Six days after [Kaltenbaugh signed] the consent authorizing Honda North to continue with the project, Kaltenbaugh’s company was authorized to complete additional work on Honda North’s site. a. On November 10, 2009, Tinko faxed Kaltenbaugh a description of work that needed to be completed at the Honda North work site, as follows: “Per our conversation….SK-1 & SK-2 reflect additional footing needed ASAP at front entrance. SK-3 reflects revised gas meter location & line routing to Kriess Road. Please provide costs for footing ASAP & coordinate w/Steve. Call me w/ any?” b. An ACI Phone Bid sheet confirmed that Kaltenbaugh provided a telephonic quote to Tinko on November 16, 2009, regarding the completion of additional work at the Honda North work site. c. The additional work Kaltenbaugh bid on included the following: 1. Excavate and install main entrance radius footer and foundation wall, $5,000.00. 2. Installation of gas service main line from Kriess Road to building, $2,750.00. 3. Installation of sand mound system including septic/dousing tank, pump & discharge, $9,400.00. 93. An AIA Document G701-2001 Change Order form for the ACI/Honda North project was generated by ACI on November 24, 2009. a. The form identified the change order as number “001” for JL & RE. b. The form indicated that the change order was for the following work to be completed by JL & RE: 1. Excavate and install main entrance radius footer and foundation wall, $5,000.00. 2. Installation of gas service main line from Kriess Road to building, $2,750.00. 3. Installation of sand mound system including septic/dousing tank, pump & discharge, $9,400.00. c. The change order was for a total of $17,150.00 in work to be completed by JL & RE. d. Kaltenbaugh signed the form on behalf of JL & RE on December 8, 2009. 94. ACI Superintendent Daily Reports indicate that JL & RE was at the Honda North job site fulfilling two aspects of Change Order 001 on four occasions between November 20, 2009, and December 15, 2009. Kaltenbaugh, 10-019 Page 22 a. JL & RE did not begin working on the installation of the sand mound until approximately late March/early April 2009 [sic]. 95. In or about November 2009, Honda North expressed interest to the Township in developing a parking lot on Lot 4R. a. The Honda North land development plans approved by the Supervisors on August 5, 2009, were only in relation to the construction of a dealership building and parking lot areas on Lot 5R. 1. The plans approved by the Supervisors included an oversized retention pond on Lot 5R. b. The plans did not include the development of Lot 4R. c. The original plans included an oversized retention pond to handle storm water runoff from Lot 5R and Lot 4R. 96. The Township Land Development Ordinances (Ordinance 45, July 14, 1987, as amended through Ordinance 59, September 9, 1997) require that a ten foot buffer area separate commercial properties from each other. a. Any kind of shrubbery is considered an adequate buffer. b. The Honda North land development plans approved by the Supervisors on August 5, 2009, reflected a ten foot buffer area between Lot 5R and Lot 4R. 97. Township approval was required to have the ten foot buffer area removed from the plans previously approved by the Supervisors on August 5, 2009, in order to begin the process of developing the area [of] Lot 4R as a parking lot. 98. At the December 16, 2009, Planning Commission meeting, the Planning Commission recommended the approval of the removal of all buffers on the east side of the Lot 5R property between the Honda North dealership and Lot 4R. a. Ron Kaltenbaugh was present at the meeting and voted in favor of recommending to the Supervisors the removal of the ten foot buffers between Lot 5R and Lot 4R. b. JL & RE was recorded as working at the Honda North job site just one day prior to the December 16, 2009, Planning Commission meeting. 99. The Planning Commission recommendation was not binding on the Township Board of Supervisors. a. Supervisor action was required to remove the buffer area. 100. Kaltenbaugh began receiving calls from Palmiero the day after the December 16, 2009, Planning Commission meeting. a. Kaltenbaugh was the only Supervisor contacted by Honda North/ACI representatives outside of public Township meetings during this time period. 101. Palmiero called Kaltenbaugh on his cellular telephone (#724-321-2910) and his business landline (#724-789-7555) three times on December 17 and 18, 2009, for a total of approximately five minutes. Kaltenbaugh, 10-019 Page 23 102. The Honda North plan revisions to eliminate the buffer zone were to be considered by the Board of Supervisors on January 6, 2010. a. Prior to the January 6, 2010, Supervisors meeting to consider the removal of the ten foot buffer between Lot 5R and Lot 4R, Kaltenbaugh received a telephone call on December 28, 2009, and six telephone calls on January 4, 2010, on his cellular telephone (#724-321-2910) from Palmiero and Domhoff totaling seventeen minutes. b. Domhoff called Kaltenbaugh on January 4, 2010, shortly after conversing with Palmiero. 1. Palmiero then telephoned Domhoff shortly after Domhoff called Kaltenbaugh. c. Kaltenbaugh was the only Supervisor contacted by Honda North/ACI representatives outside of public Township meetings during this time period. 103. At the January 6, 2010, Supervisors’ meeting, the Supervisors approved the removal of a ten foot buffer between Lot 5R and Lot 4R. a. Kaltenbaugh and Hockenberry were the only Supervisors present at the meeting. b. Kaltenbaugh suggested that Honda North add a one-hundred foot buffer to the rear of the dealership since Honda North was requesting the removal of the ten foot buffer between Lot 5R and Lot 4R. c. [Kaltenbaugh seconded a motion by Hockenberry for] the removal of the ten foot buffer area between Lot 4R and Lot 5R from the original Honda North land development plans and [the addition of] a one hundred foot buffer … to the rear of Lot 5R. 1. Kaltenbaugh cast the deciding vote to remove the buffer. 2. Kaltenbaugh voted at a time when his company was contracting with Honda North to perform site improvements to Lot 4R and Lot 5R. 104. In February 2010, Palmiero and Domhoff maintained telephonic contact with Kaltenbaugh, as shown below: Calling Individual Number Individual Date Time Min. of Call Number Calling Called Called 814-282-6990 Palmiero 724-789-2430 Domhoff 2-3-10 10:13 a.m. 8 724-789-2430 Domhoff 724-321-2910 Kaltenbaugh 2-3-10 10:20 a.m. 3 (24 sec) 814-282-6990 Palmiero 724-789-2430 Domhoff 2-3-10 10:24 a.m. 7 814-282-6990 Palmiero 724-789-2430 Domhoff 2-3-10 6:54 p.m. 7 814-282-6990 Palmiero 724-789-2430 Domhoff 2-3-10 9:07 p.m. 6 724-789-2430 Domhoff 724-321-2910 Kaltenbaugh 2-3-10 9:13 p.m. 2 (2 sec) 814-720-6038 Minor 724-321-2910 Kaltenbaugh 2-18-10 10:42 a.m. 1 (57 sec) 724-789-2430 Domhoff 724-321-2910 Kaltenbaugh 2-20-10 1:09 p.m. 3 (33 sec) 814-720-6038 Minor 724-321-2910 Kaltenbaugh 2-26-10 10:01 a.m. (58 sec) a. Kaltenbaugh was the only Supervisor contacted by Honda North/ACI representatives via telephone outside of public Township meetings during this time period. Kaltenbaugh, 10-019 Page 24 105. In March of 2010, bids were solicited by ACI to develop Lot 4R into a gravel parking lot and to install a catch basin at the southeast area between Lot 5R and Lot 4R. a. A catch basin was recommended to be installed prior to the southeast parking lot of Lot 5R being graded, graveled, and chipped so that the work related to the southeast Lot 5R parking lot would not have to be disturbed to install the catch basin for Lot 4R at a later date. 106. ACI solicited four bids between March 17, 2010, and March 29, 2010, related to graveling Lot 4R and installing a catch basin between Lot 5R and Lot 4R, as show below: Company Date Catch Basin Cost Parking Lot Cost Total Bid Solicited Forbes Excavating 3-17-2010 $6,327.00 (no basin) $102,191.00 $108,518.00 JL & RE 3-18-2010 $3,200.00 (w/ basin) $126,300.00 $129,500.00 Sonntag Excavating 3-19-2010 $4,010.00 (w/ basin) $71,600.00 $75,610.00 Blain Excavating/ 3-29-2010 $4,061.00 (w/ basin) $115,834.00 $119,895.00 Spangler Bros. Paving a. JL & RE was the lowest bidder regarding the catch basin work as of March 29, 2010. b. JL & RE was the highest bidder regarding the gravel parking lot work as of March 29, 2010. c. Kaltenbaugh prepared the JL & RE bid. 107. In March 2010, JL & RE installed septic tanks and grading work at the Honda North job site as reflected by the following ACI Superintendent Daily Reports: Report Date Description of Work Completed by JL &RE ACI Superintendent’s Signature 3-11-2010 J & R - dug & set septic tanks Steve Minor 3-19-2010 J & R - start 2' pipe from septic to sand mound Steve Minor 3-24-2010 J & R - making grade at south site near car wash Steve Minor 3-25-2010 J & R - Exterior grading Steve Minor 3-26-2010 J & R - grade at east side Steve Minor a. JL & RE was not solicited by ACI for a formal quote and/or bid to perform the grading work performed from March 24, 2010, to March 26, 2010. b. Kaltenbaugh and Tinko verbally agreed that JL & RE could perform grading work at the east and south side of the dealership to correct previous grading work that was performed by Forbes Excavating but ruined by weather conditions. 108. In or about late March/early April 2010, the developers associated with the Honda North project decided to delay the graveling of Lot 4R. a. Instead of graveling Lot 4R, it was decided to proceed just with the installation of the catch basin between Lot 5R and Lot 4R. 109. JL & RE submitted a follow-up bid to [its] March 29, 2010, bid on April 1, 2010. Kaltenbaugh, 10-019 Page 25 a. The follow-up bid was related to the catch basin work only. b. The JL & RE bid to install the catch basin was $460.00 more than previously bid on March 29, 2010. 110. JL & RE’s March 18, 2010, bid was accepted by ACI on or about April 5, 2010. a. ACI Change Order number 002 was issued on or about April 13, 2010, indicating that JL & RE was awarded the additional payment of $3,660.00 related to the catch basin work. b. Ron Kaltenbaugh signed the change order on behalf of JL & RE. 111. In April of 2010, JL & RE completed grading, septic system and catch basin [work] at the Honda North job site as reflected by ACI Superintendent Daily Reports, as detailed below: 4-1-2010 J+R - started sand mound + grading behind building 4-2-2010 J+R - continue w/ sand mound and grading 4-5-2010 J+R - set catch basin + pipe on east side, continue to grade parking lot for limestone 4-6-2010 J+R - grade behind building 4-7-2010 J+R - making grade S/E corner 4-8-2010 J+R - grading East + South lot 4-9-2010 J+R - set catch basin + make grade 4-12-2010 J+R - grading south end 4-15-2010 J+R - grade lot, at South 4-16-2010 J+R - grade south side 4-19-2010 J+R - grade at south side 4-20-2010 J+R - grade at south entrance a. JL & RE performed work related to Lot 4R by setting the catch basin between April 5, 2010, and April 9, 2010. b. The Supervisors had not approved any work to be done at Lot 4R during the time that the catch basin was being set by JL & RE. c. The grading work performed was a continuation of the corrective grading work that was started in late March. 1. JL & RE was not solicited by ACI for a formal quote and/or bid to perform the grading work performed from April 1, 2010, to April 20, 2010. 112. Domhoff on behalf of Honda North attended the May 5, 2010, Supervisors’ meeting to seek approval to move and level off the topsoil located on Lot 4R and to seed the lot. a. Honda North planned on using the area as a parking lot. b. Kaltenbaugh and Hockenberry were the only Supervisors present at the meeting. 113. Minutes of the May 5, 2010, Board meeting reflect that Hockenberry questioned Domhoff’s request by asking, “So they are going to plant grass and then park cars on it so the grass won’t grow?” Kaltenbaugh, 10-019 Page 26 a. Braun stated that he did not see a problem with the request as it relates to ground cover and storm water management. b. Kaltenbaugh stated that he did not know they were planning that but did not see a problem either. c. No formal vote of approval was given by the Supervisors in regards to Domhoff’s request. 114. Immediately after the May 5, 2010, meeting adjourned, Palmiero received a call from Kaltenbaugh’s son’s cellular telephone ([telephone number redacted]) at 9:11 p.m. a. The duration of the call was two minutes and thirty seconds. 115. Between May 10, 2010, and May 17, 2010, Kaltenbaugh kept in contact with Honda North and ACI representatives by telephone on nine occasions totaling in excess of 16 minutes. a. Kaltenbaugh was the only Supervisor contacted by Honda North/ACI representatives via telephone outside of public Township meetings during this time period. 116. Domhoff, on behalf of Honda North, attended the May 19, 2010, Planning Commission meeting to seek Planning Commission approval to grade and gravel Lot 4R for use as a parking lot. a. The Planning Commission informed Domhoff that he must come back to the Planning Commission with “numbers and figures” regarding the proposed modifications to Lot 4R as well as present storm water management plans. b. The Planning Commission did not recommend that the Supervisors approve Domhoff’s request. 117. JL & RE submitted invoices #246 dated June 1, 2010, and #253 dated June 24, 2010, for work completed related to development of the area between Lot 5R and Lot 4R, as shown below: Invoice #246 Quantity Item Code Description Price Amount Each Extra work performed for parking lot from 5/22 - 5/25/2010 1 Silk fence Silk fence $167.98 $167.98 27 Straw 27 bales of straw $3.00 $81.00 8.5 Labor Labor $25.00 $212.50 22 410 Backhoe $70.00 $1,540.00 9.5 700 Dozer $90.00 $855.00 26 130 Big skid steer $60.00 $1,560.00 257.93 2A Limestone 257.93 Tons Delivered $18.00 $4,642.74 Limestone 42.4 Limestone Note ***** Limestone **** Special $19.50 $826.80 Better looking stone 42.40 Tons Kaltenbaugh, 10-019 Page 27 Quantity Item Code Description Price Amount Each Total: $9,886.02 Invoice #253 Quantity Item Description Price Amount Code Each Add Dandy sack in parking lot, from rain wash outs, more straw bales to divert water and silk fence. 5/25/10 & 6/2/10 21 Straw 21 bales of straw $4.00 $84.00 1 Dandy Dandy Sack $70.70 $70.70 Sack 8 Labor Labor 8 hrs $25.00 $200.00 1 Silk Fence $63.99 $63.99 Fence Total: $418.69 a. JL & RE invoices #246 and #253 dated June 1, 2010, and June 24, 2010, respectively, for a combined total of $10,304.71, were submitted to Honda North for payment related to work completed between Lot 5R and Lot 4R. 1. JL & RE was authorized to do the work via a verbal agreement between Kaltenbaugh and Palmiero. b. Palmiero did not solicit competitive bids for the work invoiced by JL & RE. 118. Work performed for Honda North/Palmiero reflected in JL & RE invoices #246 and #253 included the installation of a swale, a limestone-slanted parking lot area between Lot 5R and Lot 4R, and steps taken to control storm water runoff. a. The swale, catch basin, and limestone-slanted parking lot area between Lot 5R and Lot 4R were not originally a part of the Honda North land development plans approved by the Supervisors on August [5], 2009. 119. The Supervisors had not approved the swale, catch basin, and limestone parking lot of Lot 5R and Lot 4R related to the Honda North project. a. Supervisor approval was required since this work constituted a change from the original plans approved by the Board. 120. Plans to develop Lot 4R were not formally submitted by Smith to the Township until on or about July 7, 2010. a. Township Engineer Braun issued a letter to the Supervisors on or about July 13, 2010, documenting five concerns he had with the Lot 4R plans. b. On August 25, 2010, Braun emailed Hockenberry, informing her that after several revisions of the Lot 4R plans with Smith, it was being recommended Kaltenbaugh, 10-019 Page 28 that the Lot 4R plans be determined to be consistent with the Township Storm Water Management Ordinance. c. On August 25, 2010, Hockenberry issued a letter to Honda North stating that the Lot 4R plans had been determined to be consistent with the Township Storm Water Management Ordinance. 121. At the November 4, 2010, Supervisors’ Meeting, Braun informed the Supervisors that Honda North had decided to blacktop Lot 4R instead of tarring and chipping it. a. Kaltenbaugh disagreed with Honda North’s decision and indicated that the surface should be tarred and chipped due to storm water management concerns. b. The Supervisors did not approve of Honda North paving Lot 4R at the meeting. 122. At the December 1, 2010, Supervisors’ meeting, Braun informed the Supervisors that he had received Honda North’s “as-built” plans to pave Lot 4R, but was still working with Smith to get the plans corrected. a. At the December 29, 2010, Supervisors’ meeting, Domhoff on behalf of Honda North showed the plans to the Supervisors regarding the blacktopping of Lot 4R. 1. Kaltenbaugh said the as-built drawings related to Lot 4R needed to be changed and reviewed by Braun before the Supervisors would vote to approve them. b. The Supervisors have not yet approved any plans for Lot 4R. 123. Kaltenbaugh and his company JL & RE entered into contracts with Honda North/Palmiero beginning in or about August 2009 to perform services in relation to a project that required approval of the Connoquenessing Township Supervisors. a. Kaltenbaugh voted on August 5, 2009, to grant approval of Honda North’s land development subject to conditions, and seven days later his company began performing services in relation to Honda North’s project. b. Kaltenbaugh’s company performed services between August 2009 and October 2009, prior to the Supervisors final acceptance of Honda North’s plans and contingencies. 1. Kaltenbaugh accepted contingencies proposed by Honda North on or about November 5, 2009, even though his company was a Honda North subcontractor. c. Kaltenbaugh’s company continued to contract with Honda North after Kaltenbaugh signed the agreement accepting Honda North’s proposal. 124. During the time period of August 2009 through October 2009, JL & RE submitted invoices to ACI in relation to the development of Lot 5R totaling $34,805.80. a. During the time period that JL & RE invoiced ACI for work performed in relation to the development of Lot 5R, the Supervisors had not approved Honda North’s proposal to meet contingencies required by the Board. Kaltenbaugh, 10-019 Page 29 1. The Supervisors did not come to an agreement as to how the contingencies of the project would be met until November 4, 2009. 125. Between December 4, 2009, and June 1, 2010, JL & RE billed ACI an additional $40,721.75 in relation to the development of Lot 5R and the area between Lot 5R and Lot 4R subsequent to the November 4, 2009, agreement. a. Of the $40,721.75 invoiced to ACI, $4,974.25 was related to catch basin work. 1. At the time the catch basin work was completed between Lot 5R and Lot 4R, the Supervisors had yet to approve any plans for the installation of said catch basin. 126. JL & RE invoiced Honda North $10,304.71 on invoices dated June 1 and 24, 2010, in relation to the development of the area between Lot 5R and Lot 4R prior to any Supervisor approval. a. The work performed between Lot 5R and Lot 4R for Honda North occurred in late May/early June 2010. b. Plans to develop the area were not submitted to the Township for approval until July 7, 2010. 127. JL & RE was paid a total of $85,832.75 for work completed for ACI/Honda North covering the time period of August 2009 through June 2010. a. ACI did not pay the full amount of JL & RE invoices 162, 164, 179, 186, 223, and 235 at that time that payment was issued. 1. ACI did not pay a certain percent of the total initially invoiced to ACI. 2. The percentage withheld from payment acted as a retainer fee to be paid at the completion of the project. 3. JL & RE received reimbursement of the retainer fees previously taken via ACI check 047187. b. ACI overpaid what was invoiced by JL & RE by $0.49. 128. JL & RE has maintained a bank account ([account number redacted]) at First National Bank since at least January 18, 1982. a. Kaltenbaugh and Ron Kaltenbaugh both have signature authority over the bank account for JL & RE. 129. Payments issued to JL & RE by ACI totaling $75,528.04 and Honda North totaling $10,304.71 in relation to the Honda North development were deposited into the business bank account for JL & RE. a. The majority of the checks issued to JL & RE were deposited in 2010. b. The only check deposited in 2009 was ACI check no. 044886 dated October 30, 2009, in the amount of $1,325.00. c. A total of $85,832.75 was paid to JL & RE for work performed for the Honda North project. Kaltenbaugh, 10-019 Page 30 130. U.S. Return of Partnership Income forms (#1065) for JL & RE for calendar years 2008, 2009, and 2010 reflect that JL & RE realized a profit percentage, as shown below: Year Gross Profit Net Profit Profit Percentage 2008 $354,131.00 $42,241.00 11.9% 2009 $255,440.00 $55,530.00 21.7% 2010 $277,167.00 $57,534.00 20.7% a. The Honda North project was not yet approved by the Supervisors in 2008 when JL & RE realized a profit percentage of 11.9%. b. JL & RE realized a profit percentage of 21.7% in 2009. 1. Of the $255,440.00 gross profit realized by JL & RE in 2009, $1,325.00 was related to the Honda North project. 2. Only one ACI check (#044886) related to the Honda North project was deposited into the JL & RE bank account in 2009. c. JL & RE realized a profit percentage of 20.7% in 2010. 1. Of the $277,167.00 gross profit realized by JL & RE in 2010, $84,507.75 was related to the Honda North project. 131. JL & RE realized a total net profit of $287.52 ($1,325.00 x 21.7[%] = 287.52) in 2009 in relation to work the business with which Kaltenbaugh is associated performed for Honda North/ACI. a. Kaltenbaugh’s portion of the profit was $143.76 ($287.52 / 2 = 143.76) in 2009 in relation to work performed for Honda North/ACI. 132. JL & RE, the business with which Kaltenbaugh is associated, realized a total net profit of $17,493.10 ($84,507.75 x 20.7[%] = $17,493.10) in 2010 in relation to work performed for Honda North/ACI. a. Kaltenbaugh’s portion of the profit was $8,746.55 (17,493.10 / 2 = 8,746.55) in 2010 in relation to work performed for Honda North/ACI. 133. Kaltenbaugh received net profits of $8,890.31 in relation to completing work for Honda North/ACI in 2009 and 2010. a. JL & RE net profits for 2009 and 2010 from contracting services performed on behalf of Honda North totaled $17,780.62. 134. Kaltenbaugh provided SEC Investigators with sworn testimony on June 7, 2011, during which he averred in part as follows: a. Kaltenbaugh admitted he was telephonically contacted by Palmiero and Domhoff prior to the August 5, 2009, Supervisors’ meeting. 1. He denied answering the calls that were placed by Palmiero and Domhoff to his cellular telephone. b. He is in favor of new development within the Township because of the economic impact it brings to the community. Kaltenbaugh, 10-019 Page 31 c. Kaltenbaugh was in favor of Honda North’s intentions to construct a new dealership at the intersection of Route 68 and Kriess Road. d. He admitted that if Honda North had decided to develop in an area outside the geographical area of Connoquenessing Township, it would have been difficult for JL & RE to obtain any work in relation to the project. e. He voted to give preliminary and final approval to the Honda North project at the August 5, 2009, meeting with the understanding that two contingencies (storm water management and turning lane on Route 68) needed to be resolved by the Township and Honda North in the future. 1. He was aware of the 2009 time constraints Honda North was under to begin development prior to weather conditions worsening subsequent to August 2009. 2. He acknowledged granting leniency to Honda North by granting Honda North partial approval at the August 5, 2009, meeting so that Honda North could begin development prior to the 2009 weather conditions worsening for outdoor development. f. He attended the August 7, 2009, Honda North groundbreaking ceremony at the request of Don Domhoff. 1. Kaltenbaugh claimed that he attended in his capacity as a representative of the Township. 2. At the groundbreaking ceremony, he conversed with Joe Palmiero for the first time. g. He spoke with Paul Buettell at the groundbreaking ceremony regarding what subcontractors were going to be used for certain aspects of the development. 1. He told Buettell that he would be interested in the work and stated that he would supply Buettell with a quote in the near future. h. He telephoned Buettell approximately a day or so after the groundbreaking ceremony to provide Buettell with a quote for the fence work. 1. Buettell/ACI accepted the quote, and shortly thereafter, JL & RE began working at the Honda North job site. i. His main contact with ACI was Buettell until Buettell became ill and was replaced by Kevin Tinko. 1. He also kept in close contact with the ACI Honda North site supervisor, Steve Minor, who was at the work site on a daily basis. j. As JL & RE was performing the fence work, an ACI representative asked Kaltenbaugh if he would be interested in doing footer work for the project. 1. He expressed interest in the work, and he and his brother generated several quotes and submitted them to ACI to perform the footer work. Kaltenbaugh, 10-019 Page 32 k. He admitted that during the time frame that JL & RE was performing the fence work and footer work for Honda North/ACI, the Supervisors had not yet come to an agreement with Honda North as to how the contingencies would be met. 1. He was aware while he was working at the Honda North site … that as a Supervisor, he would have to come to an agreement with Honda North regarding the contingencies at a later date. l. It was not until he and Supervisor Evelyn Hockenberry signed the Honda North agreement dated August 13, 2009, at the November 4, 2009, Supervisor meeting, that the storm water contingency and turning lane contingency were agreed upon as to how they would be met. m. He and/or his brother were approached while working at the Honda North job site by ACI representatives (either Tinko or Minor) to determine if JL & RE would be interested in completing additional work. 1. Prior to JL & RE finishing one project, they were approached to see if they were interested in completing a future project, and that one project lead to another. 2. Kaltenbaugh acknowledged that if JL & RE had not obtained the fence work, JL & RE may not have been solicited to perform additional work for the Honda North project. n. Some of the work JL & RE completed at the Honda North work site was not approved by the Supervisors nor indicated on the plans originally provided to the Township for approval. 1. His business installed a stone swale, a slanted stone parking lot, and a catch basin between Lot 4R and Lot 5R that were items not approved by the Supervisors for construction at the August 5, 2009, Supervisor meeting. 2. He was aware that when he voted at the January 6, 2010, meeting to remove the buffers between Lot 4R and Lot 5R, it was because Honda North was interested in developing the area between Lot 4R and Lot 5R. 135. Kaltenbaugh’s use of the authority of his public position included participation in decisions and motions [sic] of the Board of Supervisors from August 5, 2009, through 2010, regarding development plans of Honda North and resulted in a private pecuniary benefit to him and JL & RE, a business with which he is associated. a. Within one week of voting on August 5, 2009, to accept Honda North’s development plans with conditions, Kaltenbaugh’s company, JL & RE Excavating, received a contract from Honda North valued at least at $8,900.00. b. Kaltenbaugh approved and consented to Honda North conditions on November 4, 2009. c. On January 6, 2010, Kaltenbaugh cast the deciding vote to permit Honda North to remove a buffer zone between Lot 5R and Lot 4R. Kaltenbaugh, 10-019 Page 33 136. Kaltenbaugh received a private pecuniary gain of $8,890.31 as a result of contracts received from Honda North. III.DISCUSSION: As a Supervisor for Connoquenessing Township (“Township”) since January 7, 2008, Respondent Jack Kaltenbaugh, hereinafter also referred to as “Respondent,” “Respondent Kaltenbaugh,” and “Kaltenbaugh,” has been a public official subject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. The allegations are that Kaltenbaugh violated Section 1103(a) of the Ethics Act when he used the authority of his public position for the private pecuniary benefit of himself and/or a business with which he is associated by participating in discussions and actions of the Township Board of Supervisors (“Board”) to approve matters regarding a subdivision/land development application being considered by the Board at a time when his company was performing excavating and construction services in relation to the project that was the subject of the application or when he had a reasonable expectation that his company would be considered for or receive contracts in relation to that project. Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a)Conflict of interest.— No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official/public employee from using the authority of public office/employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official/public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Kaltenbaugh, 10-019 Page 34 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. Kaltenbaugh has served as a Township Supervisor since January 7, 2008. The Township is governed by a three-Member Board. Kaltenbaugh has served as Vice Chairman of the Board from January 7, 2008, to the present. The Township Planning Commission (“Planning Commission”) is advisory to the Board. Developers interested in developing land within the Township are required to submit a land development application and plans to the Township approximately fifteen days prior to a Planning Commission meeting. The Planning Commission can recommend the approval or denial of the plans to the Supervisors or take no official action, in which case the plans are forwarded to the Supervisors for review as if they were recommended for approval by the Planning Commission. Plans are ultimately approved by the Supervisors after the developer and the Supervisors can come to a mutual agreement as to how the development is to be constructed. Respondent’s brother, Ronald Kaltenbaugh, has served as a Member of the Planning Commission since January 3, 2006. Since approximately 1982, Respondent Kaltenbaugh and Ronald Kaltenbaugh have each owned a 50% interest in a business named “JL & RE Building and Excavating” (“JL & RE”). JL & RE is located in the Township and specializes in excavation work. Honda North, an automobile dealership, has been operating within the geographical boundaries of the Township since approximately 2005. Honda North is owned by Joe Palmiero (“Palmiero”) and two other individuals. Palmiero determined in early to mid-2007 that Honda North needed to expand. Palmiero learned that two Township residents were interested in selling approximately eight acres of property, hereinafter referred to as “Property,” at the intersection of Route 68 and Kriess Road in the Township. The Property consisted of two parcels of land, hereinafter referred to as “Lot 4R” and “Lot 5R,” and it was located less than one mile south of Honda North’s then-current location. On April 25, 2007, Palmiero entered into a Land Purchase Option which gave him two 6-month options to purchase Lot 4R and Lot 5R. In approximately mid to late 2007, Palmiero contacted Paul Buettell (“Buettell”), then Vice-President of Associated Contractors Inc. (“ACI”), to discuss ACI serving as project manager for the construction of a new Honda North dealership at the Property. Buettell started the planning of the new Honda North facility in approximately late 2007 or early 2008. Subsequently, on March 19, 2008, an architect met with the Planning Commission on behalf of Honda North to discuss Honda North's intentions for the Property. The Planning Commission suggested to the architect that a traffic study be completed prior to land development plans being submitted to the Board for approval in order to determine whether a left-hand turning lane might be needed at the intersection of Route 68 and Kriess Road to avoid traffic congestion. A traffic study conducted on behalf of Honda North from April 15, 2008, through April 19, 2008, concluded that a left-hand turning lane on Route 68 would not be needed. The traffic study recommended the construction of an auxiliary right turn lane on Kriess Road. The traffic study was submitted to the Township and was discussed at the August 6, 2008, Board meeting. Kaltenbaugh was present at the meeting. No action was taken by the Board to accept the study submitted on behalf of Honda North. Kaltenbaugh, 10-019 Page 35 On September 15, 2008, Palmiero finalized the purchase of the Property. In or about March 2009, ACI’s construction project manager for the Honda North project began soliciting quotes from subcontractors to generate a pool of subcontractors to select from once Township approval was given for the project to begin. The construction project manager did not solicit any quotes from JL & RE. On June 1, 2009, a Subdivision and Land Development application and plans for the Honda North project were submitted by the project’s architect and engineer to the Township for review. At its meeting on June 17, 2009, the Planning Commission discussed with Township Engineer Bill Braun (“Braun”) and the project engineer twenty- three concerns that Braun had with the Honda North land development plans, including storm water management issues and turning lane issues. The Planning Commission tabled the Honda North land development plans to be reviewed at a later date. Kaltenbaugh, Braun, and Planning Commission Member Sherry Lokhaiser (“Lokhaiser”) met at the location of the proposed Honda North dealership subsequent to the June 17, 2009, Planning Commission meeting. Kaltenbaugh, Lokhaiser, and Braun primarily discussed the storm water management issues that would result via the construction of the proposed dealership. On June 30, 2009, the Planning Commission recommended that the Supervisors approve the plans related to the new Honda North dealership contingent upon the Supervisors’ approval of the storm water management plan for the development. At the July 1, 2009, Board meeting, the Honda North plans were reviewed and discussed. Kaltenbaugh was present at the meeting. The Supervisors decided to table the plans for approval due to concerns regarding the need for a left-hand turning lane on Route 68 and storm water management issues. Palmiero was concerned that the Honda North project was losing valuable construction time. As a result of the concerns raised by Braun and the Supervisors with Honda North’s plans, a relative of Palmiero contacted Donald Domhoff (“Domhoff”), a Township resident and former Planning Commission Member, for assistance in obtaining Township approval of Honda North’s plans. In or about June and July 2009, Palmiero had discussions with Buettell, Domhoff, and the Honda North project architect and engineer in order to strategize ways to obtain Township approval of the project. Beginning on or about July 21, 2009, Kaltenbaugh began receiving telephone calls from individuals associated with the Honda North project. Domhoff and Palmiero both contacted Kaltenbaugh eight times between July 21, 2009, and July 23, 2009. Kaltenbaugh met with Palmiero at his Honda North office on at least one occasion between July 1, 2009, and August 4, 2009, to discuss how the Township and Honda North could come to an agreement with regard to addressing the storm water management issues related to the Honda North project. Palmiero submitted a letter to the Board dated August 4, 2009, proposing, in pertinent part, that Honda North would reimburse the Township $87,500.00 for expenses actually incurred by the Township in its efforts to accomplish the completion of a left-hand turning lane on Route 68 contingent upon five conditions, including that Honda North would receive final approval of its plans and approval to immediately proceed with construction of its project at the next Board meeting on August 5, 2009. The Supervisors did not take any action on Palmiero’s August 4, 2009, proposal. At the August 5, 2009, Board meeting, Kaltenbaugh participated in discussions regarding the Honda North project. Kaltenbaugh seconded a motion and participated in a unanimous vote of the Board to grant preliminary and final approval to Honda North’s plans for the proposed dealership for the Property, contingent upon engineer review and approval of storm water plans and upon signing of legal agreements requiring Honda North Kaltenbaugh, 10-019 Page 36 to deposit $87,500.00 in a Township account for improvements to Route 68. Palmiero opposed the contingencies approved by the Board. On August 6, 2009, Domhoff and Kaltenbaugh were engaged in a series of telephone calls. At Domhoff’s invitation, Kaltenbaugh attended a groundbreaking ceremony hosted by Palmiero at the future Honda North location on August 7, 2009. At the groundbreaking ceremony, Kaltenbaugh spoke with Buettell, ACI’s manager for the Honda North project, about whether subcontractors had been chosen for the preliminary site preparation related to the project. Kaltenbaugh’s company, JL & RE, was not being considered for any project work prior to or around August 2009. Buettell asked Kaltenbaugh if his company was interested in fencing the septic area of the project. Kaltenbaugh telephoned Buettell approximately a day or so after the groundbreaking ceremony to provide Buettell with a quote for the fence work. JL & RE began work on the Honda North project on August 12, 2009, seven days after Kaltenbaugh participated in the Board’s conditional approval of the project. Between August 12, 2009, and August 14, 2009, JL & RE performed work related to the construction of the new Honda North facility as detailed in Fact Finding 66. On August 13, 2009, Honda North submitted to the Township a proposed agreement regarding the contingencies approved by the Board for the Honda North project. Kaltenbaugh/JL & RE was actively working at the Honda North job site during the time period that the August 13, 2009, agreement was submitted to the Township for consideration. At the September 2, 2009, Board meeting, Kaltenbaugh participated in a unanimous vote of the Board to not accept Honda North’s proposed agreement. Meanwhile, between August 24, 2009, and September 9, 2009, Kaltenbaugh and Buettell maintained regular telephonic contact. On September 16, 2009, Kaltenbaugh and his brother submitted a bid in the amount of $36,800.00 to ACI in relation to digging footers for the structure of the Honda North dealership. On September 18, 2009, JL & RE entered into a contract with ACI to perform the footer work at the Honda North job site for the negotiated price of $33,200.00. JL & RE performed work at the Honda North job site on seventeen occasions from September 21, 2009, through October 20, 2009, until JL & RE’s contractual agreement with ACI was completed. Between October 21, 2009, and November 3, 2009, JL & RE performed miscellaneous work at the Honda North job site at no charge to ACI. From August 2009 through October 2009, JL & RE submitted to ACI invoices totaling $34,805.80 in relation to the Honda North project. During this time period, the Supervisors had not approved Honda North’s proposal to meet the contingencies required by the Board. On or about November 4, 2009, Kaltenbaugh and Supervisor Evelyn Hockenberry (“Hockenberry”), in their capacities as Township Supervisors, agreed to Honda North’s proposal to resolve the outstanding issues pertaining to the Honda North project. Kaltenbaugh and Hockenberry signed the August 13, 2009, agreement proposed by Honda North. The third Supervisor opposed the agreement and refused to sign it. Without Kaltenbaugh’s signature on the agreement, Honda North would not have been able to complete the project. Six days after Kaltenbaugh signed the August 13, 2009, agreement, JL & RE was authorized to complete additional work on Honda North’s job site. On December 8, 2009, Kaltenbaugh, on behalf of JL & RE, signed an ACI Change Order form for a total of $17,150.00 of additional work to be completed by JL & RE at the Honda North job site. Kaltenbaugh, 10-019 Page 37 In or about November 2009, Honda North expressed interest to the Township in developing a parking lot on Lot 4R. The Honda North land development plans approved by the Supervisors on August 5, 2009, were only related to the construction of a dealership building and parking lot areas on Lot 5R and did not include the development of Lot 4R. In order to begin the process of developing the area of Lot 4R as a parking lot, Township approval was required to remove from the Honda North plans a ten foot buffer area between Lot 5R and Lot 4R that was required by the Township land development ordinances. At the January 6, 2010, Board meeting, Kaltenbaugh seconded the motion and participated in the Board’s vote to approve the removal of the ten foot buffer area between Lot 5R and Lot 4R from the Honda North plans and the addition of a one hundred foot buffer area to the rear of Lot 5R. Kaltenbaugh voted at a time when his company was contracting with Honda North to perform site improvements to Lot 4R and Lot 5R. In March 2010, JL & RE installed septic tanks and performed corrective grading work at the Honda North job site. On or about April 5, 2010, ACI accepted a bid by JL & RE to install a catch basin between Lot 5R and Lot 4R at the cost of $3,660.00. Between April 1, 2010, and April 20, 2010, JL & RE completed grading, septic system, and catch basin work at the Honda North job site. Between December 4, 2009, and June 1, 2010, JL & RE billed ACI for $40,721.75 in relation to the development of Lot 5R and the area between Lot 5R and Lot 4R subsequent to the November 4, 2009, agreement. JL & RE submitted to Honda North two invoices dated June 1, 2010, and June 24, 2010, in the total amount of $10,304.71, for work completed in late May/early June 2010 relative to the development of the area between Lot 5R and Lot 4R, including the installation of a swale and a limestone-slanted parking lot area and steps taken to control storm water runoff. The swale, catch basin, and limestone-slanted parking lot area between Lot 5R and Lot 4R were not originally part of the Honda North land development plans and had not been approved by the Supervisors on August 5, 2009. Supervisor approval was required since this work constituted a change from the original plans approved by the Board. Plans to develop Lot 4R were not formally submitted by the Honda North project engineer to the Township until on or about July 7, 2010. Honda North and ACI paid JL & RE a total of $85,832.75 for work performed in relation to the Honda North project for the time period from August 2009 through June 2010. The parties have stipulated that JL & RE realized total net profits of $287.52 in 2009 and $17,493.10 in 2010 in relation to work performed for Honda North/ACI and that Kaltenbaugh received a total net profit of $8,890.31 from such work. 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 Kaltenbaugh’s approval regarding a subdivision/land development application when his company was performing excavating and construction services Kaltenbaugh, 10-019 Page 38 in relation to the project that was the subject of the application or when he had a reasonable expectation that his company would be considered for or receive contracts in relation to that project. 4. Kaltenbaugh agrees to make payment in the amount of $8,890.31 in settlement of this matter payable to the Connoquenessing Township and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. 5. Kaltenbaugh agrees to not accept any reimbursement, compensation or other payment from Connoquenessing Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 6. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Consent Agreement, at 2. In considering the Consent Agreement, we accept the parties’ recommendation for a finding of a violation of Section 1103(a) of the Ethics Act. On August 5, 2009, Kaltenbaugh participated in discussions regarding the Honda North project. Kaltenbaugh seconded a motion and participated in a unanimous vote of the Board to grant preliminary and final approval to Honda North’s plans for the proposed dealership for the Property, subject to conditions. Two days after Kaltenbaugh participated in the Board’s conditional approval of the Honda North plans, he attended the groundbreaking ceremony at the future Honda North location and spoke with Buettell, ACI’s manager for the Honda North project, about whether subcontractors had been chosen for the preliminary site preparation related to the project. Kaltenbaugh provided Buettell with a quote for fencing the septic area of the project, and from August 12, 2009, to August 14, 2009, JL & RE worked on the Honda North project. JL & RE is a business with which both Kaltenbaugh and his brother, Ronald Kaltenbaugh, are associated as owners of JL & RE. JL & RE performed additional work at the Honda North job site under a contract with ACI from September 21, 2009, through October 20, 2009, when the Supervisors had not approved Honda North’s proposal to meet the contingencies required by the Board. On or about November 4, 2009, Kaltenbaugh used the authority of his office when he signed Honda North’s August 13, 2009, agreement to resolve outstanding issues pertaining to the Honda North project. Six days after Kaltenbaugh signed the aforesaid agreement, JL & RE was authorized to complete additional work on Honda North’s job site. On December 8, 2009, Kaltenbaugh, on behalf of JL & RE, signed an ACI Change Order form for a total of $17,150.00 of additional work to be completed by JL & RE at the Honda North job site. On January 6, 2010, Kaltenbaugh used the authority of his office when he participated in actions of the Board to approve the removal of the ten foot buffer area between Lot 5R and Lot 4R of the Property from the Honda North plans and the addition of Kaltenbaugh, 10-019 Page 39 a one hundred foot buffer area to the rear of Lot 5R, at a time when his company was contracting with Honda North to perform site improvements to Lot 4R and Lot 5R. The parties have stipulated that JL & RE realized total net profits of $287.52 in 2009 and $17,493.10 in 2010 in relation to work performed for Honda North/ACI and that Kaltenbaugh received a total net profit of $8,890.31 from such work. Based upon the totality of the circumstances, we accept the disposition proposed by the parties. We hold that a violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Kaltenbaugh’s approval regarding a subdivision/land development application when his company was performing excavating and construction services in relation to the project that was the subject of the application or when he had a reasonable expectation that his company would be considered for or receive contracts in relation to that project. As part of the Consent Agreement, Kaltenbaugh has agreed to make payment in the amount of $8,890.31 payable to Connoquenessing Township and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Kaltenbaugh has further agreed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 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, Kaltenbaugh is directed to make payment in the amount of $8,890.31 payable to Connoquenessing Township and th forwarded to this Commission by no later than the thirtieth (30) day after the mailing date of this adjudication and Order. Kaltenbaugh is further directed to not accept any reimbursement, compensation or other payment from Connoquenessing Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 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 Supervisor for Connoquenessing Township since January 7, 2008, Respondent Jack Kaltenbaugh (“Kaltenbaugh”) 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. Kaltenbaugh violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to his approval regarding a subdivision/land development application when his company was performing excavating and construction services in relation to the project that was the subject of the application or when he had a reasonable expectation that his company would be considered for or receive contracts in relation to that project. Kaltenbaugh, 10-019 Page 40 In Re: Jack Kaltenbaugh, : File Docket: 10-019 Respondent : Date Decided: 9/27/11 : Date Mailed: 10/6/11 ORDER NO. 1593 1. As a Supervisor for Connoquenessing Township (“Township”), Jack Kaltenbaugh (“Kaltenbaugh”) violated Section 1103(a) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1103(a), in relation to his approval regarding a subdivision/land development application when his company was performing excavating and construction services in relation to the project that was the subject of the application or when he had a reasonable expectation that his company would be considered for or receive contracts in relation to that project 2. Per the Consent Agreement of the parties, Kaltenbaugh is directed to make payment in the amount of $8,890.31 payable to Connoquenessing Township and forwarded to the Pennsylvania State Ethics Commission by no later than the th thirtieth (30) day after the mailing date of this Order. 3. Per the Consent Agreement of the parties, Kaltenbaugh is further directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 4. Compliance with Paragraphs 2 and 3 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