HomeMy WebLinkAbout13-003 Raphael
OPINION OF THE COMMISSION
Before: John J. Bolger, Chair
Nicholas A. Colafella, Vice Chair
Raquel K. Bergen
Mark R. Corrigan
Roger Nick
Kathryn Streeter Lewis
DATE DECIDED: 7/10/13
DATE MAILED: 7/18/13
13-003
David J. Raphael, Esquire
Chief Counsel
Pennsylvania Department of Environmental Protection
Rachel Carson State Office Building
P.O. Box 8464
Harrisburg, PA 17105
Dear Mr. Raphael:
This Opinion is issued in response to your letter of January 23, 2013, by which you
requested an advisory from this Commission.
I.ISSUE:
Whether the Public Official and Employee Ethics Act would impose any prohibitions
or restrictions upon an individual serving as the Director of the Bureau of District Oil and
Gas Operations (“Bureau”) within the Pennsylvania Department of Environmental
Protection (“Department”) with regard to performing the duties of his Commonwealth
position where: (1) in a private capacity, the individual is a protector of a family trust that
includes rental and royalty interests in gas leases on family-owned property in the
Commonwealth; (2) no drilling activity is currently taking place on such property and no
royalties are currently being paid or accrued; and (3) the drilling of oil or gas wells on such
property and related activities would be subject to the Bureau’s regulatory oversight.
II.FACTUAL BASIS FOR DETERMINATION:
As Chief Counsel of the Department, you have been authorized by John W. Ryder
(“Mr. Ryder”), who is currently employed with the Department as the Director of the
Bureau, to request an advisory from this Commission on his behalf. You have submitted
facts that may be fairly summarized as follows.
Mr. Ryder became the Director of the Bureau effective April 7, 2012. You have
submitted a copy of a position description for the position of Director of the Bureau, which
Raphael, Opinion 13-003
July 18, 2013
Page 2
document is incorporated herein by reference.
You state that as the Director of the Bureau, Mr. Ryder performs professional
managerial work directing the activities of professional, administrative and technical staff
engaged in a variety of duties involving the permitting, inspection, enforcement, and
compliance activities of the statewide oil and gas program. You state that while Mr. Ryder
does not personally perform well site inspections, he directs the activities of other Bureau
employees engaged in permitting and inspecting well operations and enforcing oil and gas
laws, regulations and policies. You further state that a finding by Mr. Ryder that a well
operation is not in compliance with law or regulation could lead to enforcement action
against the responsible operators, which in turn could result in obligations by the operators
to take corrective action and pay financial penalties.
In a private capacity, Mr. Ryder is one of three protectors of a family trust (“Trust”)
that includes rental and royalty interests in gas leases on family-owned property (the “Trust
Property”) in Lycoming County, Pennsylvania. As a protector of the Trust, Mr. Ryder is a
beneficiary of the Trust and has some power to direct the trustee in the handling of Trust
assets.
The gas leases on the Trust Property are held by a single gas company (the “Gas
Company”). No drilling activity is currently taking place on the Trust Property, and no
royalties are currently being paid or accrued. If oil or gas wells would be drilled on the
Trust Property, the drilling and related activities would be subject to the Bureau’s
regulatory oversight.
You state that since Mr. Ryder learned of his appointment as Director of the Bureau,
he has had no involvement in overseeing the Bureau’s regulatory activities with respect to
the operations of the Gas Company and has had no input into his subordinates’ decisions
regarding regulatory oversight of the Gas Company’s activities. You further state that Mr.
Ryder has agreed to recuse himself from any Department activity regarding the Gas
Company.
Based upon the above submitted facts, you seek guidance as to whether the Ethics
Act would impose any prohibitions or restrictions upon Mr. Ryder with regard to performing
the duties of his position as the Director of the Bureau--including management duties--as a
result of his role in his private capacity as a protector of the Trust.
By letter dated May 30, 2013, you were notified of the date, time and location of the
public meeting at which your request would be considered.
III.DISCUSSION:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of the Ethics
Act, 65 Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester based upon the
facts that the requester has submitted. In issuing the advisory based upon the facts that
the requester has submitted, this Commission does not engage in an independent
investigation of the facts, nor does it speculate as to facts that have not been submitted. It
is the burden of the requester to truthfully disclose all of the material facts relevant to the
inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only affords a defense to the extent
the requester has truthfully disclosed all of the material facts.
It is further initially noted that, pursuant to the same aforesaid Sections of the Ethics
Act, an opinion/advice may be given only as to prospective (future) conduct. If the activity
in question has already occurred, this Commission may not issue an Opinion but any
person may then submit a signed and sworn complaint, which will be investigated by this
Commission if there are allegations of Ethics Act violations by a person who is subject to
the Ethics Act. To the extent you have inquired as to conduct that has already occurred,
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July 18, 2013
Page 3
such past conduct may not be addressed in the context of an advisory Opinion. However,
to the extent you have inquired as to future conduct, your inquiry may, and shall, be
addressed.
In the capacity as the Director of the Bureau, Mr. Ryder would be considered a
“public employee” subject to the Ethics Act and the Regulations of this Commission. See,
65 Pa.C.S. § 1102; 51 Pa. Code § 11.1. This conclusion is based upon the position
description, which when reviewed on an objective basis, indicates clearly that the power
exists to take or recommend official action of a non-ministerial nature with respect to one
or more of the following: contracting; procurement; administering or monitoring grants or
subsidies; planning or zoning; inspecting; licensing; regulating; auditing; or other
activity(ies) where the economic impact is greater than de minimis on the interests of
another person.
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 following terms pertaining to conflicts of interest are 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.
“Authority of office or employment.”
The actual
power provided by law, the exercise of which is necessary to
the performance of duties and responsibilities unique to a
particular public office or position of public employment.
“Immediate family.”
A parent, spouse, child, brother
or sister.
"Business."
Any corporation, partnership, sole
proprietorship, firm, enterprise, franchise, association,
organization, self-employed individual, holding company, joint
stock company, receivership, trust or any legal entity
organized for profit.
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July 18, 2013
Page 4
“Business with which he is associated.”
Any
business in which the person or a member of the person’s
immediate family is a director, officer, owner, employee or has
a financial interest.
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. The use of authority of office includes more
than mere voting; for example, it includes discussing, conferring with others, and lobbying
for a particular result. Juliante, Order 809.
Sections 1103(b) and 1103(c) of the Ethics Act, 65 Pa.C.S. §§ 1103(b), (c), provide
in part that no person shall offer or give to a public official/public employee anything of
monetary value and no public official/public employee shall solicit or accept anything of
monetary value based upon the understanding that the vote, official action, or judgment of
the public official/public employee would be influenced thereby. Reference is made to
these provisions of the law not to imply that there has been or will be any transgression
thereof but merely to provide a complete response to the question presented.
In his capacity as the Director of the Bureau, Mr. Ryder generally would have a
conflict of interest under Section 1103(a) of the Ethics Act in matters that would financially
impact him, a member of his immediate family, or a business with which he or a member of
his immediate family is associated.
The Pennsylvania Supreme Court has held that in order to violate Section 1103(a)
of the Ethics Act, a public official/public employee “must be consciously aware of a private
pecuniary benefit for himself, his family, or his business, and then must take action in the
form of one or more specific steps to attain that benefit.” Kistler v. State Ethics
Commission, 610 Pa. 516, 528, 22 A.3d 223, 231 (2011). Based upon Kistler, the
existence of a violation of Section 1103(a) would depend upon the circumstances in a
given case.
You are advised that Mr. Ryder would have a conflict of interest and would violate
Section 1103(a) of the Ethics Act in performing the duties of his position as the Director of
the Bureau--including but not limited to management duties--to the extent that: (1) he
would be consciously aware of a private pecuniary benefit for himself, a member of his
immediate family, or a business with which he or a member of his immediate family is
associated; and (2) his action(s) would constitute one or more specific steps to attain that
benefit. Kistler, supra. In each instance of a conflict of interest, Mr. Ryder would be
required to abstain from participation.
The propriety of the proposed conduct has only been addressed under the Ethics
Act; the applicability of any other statute, code, ordinance, regulation or other code of
conduct other than the Ethics Act has not been considered in that they do not involve an
interpretation of the Ethics Act. Specifically not addressed herein is the applicability of the
Governor’s Code of Conduct.
IV.CONCLUSION:
In the capacity as the Director of the Bureau of District Oil and Gas Operations
(“Bureau”) within the Pennsylvania Department of Environmental Protection
(“Department”), John W. Ryder (“Mr. Ryder”) would be considered a “public employee”
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July 18, 2013
Page 5
subject to the provisions of the Public Official and Employee Ethics Act (“Ethics Act”), 65
Pa.C.S. § 1101 et seq., and the Regulations of the State Ethics Commission, 51 Pa. Code
§ 11.1 et seq. Based upon the submitted facts that: (1) Mr. Ryder became the Director of
the Bureau effective April 7, 2012; (2) as the Director of the Bureau, Mr. Ryder performs
professional managerial work directing the activities of professional, administrative and
technical staff engaged in a variety of duties involving the permitting, inspection,
enforcement, and compliance activities of the statewide oil and gas program; (3) while Mr.
Ryder does not personally perform well site inspections, he directs the activities of other
Bureau employees engaged in permitting and inspecting well operations and enforcing oil
and gas laws, regulations and policies; (4) in a private capacity, Mr. Ryder is one of three
protectors of a family trust (“Trust”) that includes rental and royalty interests in gas leases
on family-owned property (the “Trust Property”) in Lycoming County, Pennsylvania; (5) as
a protector of the Trust, Mr. Ryder is a beneficiary of the Trust and has some power to
direct the trustee in the handling of Trust assets; (6) the gas leases on the Trust Property
are held by a single gas company (the “Gas Company”); (7) no drilling activity is currently
taking place on the Trust Property, and no royalties are currently being paid or accrued;
(8) if oil or gas wells would be drilled on the Trust Property, the drilling and related
activities would be subject to the Bureau’s regulatory oversight; (9) since Mr. Ryder
learned of his appointment as Director of the Bureau, he has had no involvement in
overseeing the Bureau’s regulatory activities with respect to the operations of the Gas
Company and has had no input into his subordinates’ decisions regarding regulatory
oversight of the Gas Company’s activities; and (10) Mr. Ryder has agreed to recuse
himself from any Department activity regarding the Gas Company, you are advised as
follows.
In his capacity as the Director of the Bureau, Mr. Ryder generally would have a
conflict of interest under Section 1103(a) of the Ethics Act in matters that would financially
impact him, a member of his immediate family, or a business with which he or a member of
his immediate family is associated. Mr. Ryder would have a conflict of interest and would
violate Section 1103(a) of the Ethics Act in performing the duties of his position as the
Director of the Bureau--including but not limited to management duties--to the extent that:
(1) he would be consciously aware of a private pecuniary benefit for himself, a member of
his immediate family, or a business with which he or a member of his immediate family is
associated; and (2) his action(s) would constitute one or more specific steps to attain that
benefit. In each instance of a conflict of interest, Mr. Ryder would be required to abstain
from participation.
The propriety of the proposed conduct has only been addressed under the Ethics
Act.
Pursuant to Section 1107(10) of the Ethics Act, the person who acts in good faith on
this Opinion issued to him shall not be subject to criminal or civil penalties for so acting
provided the material facts are as stated in the request.
This letter is a public record and will be made available as such.
By the Commission,
John J. Bolger
Chair