HomeMy WebLinkAbout84-600 StillwagonWilliam C. Stillwagon, Esquire
319 South Maple Avenue
Greensburg, PA 15601
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
August 16, 1984
ADVICE OF COUNSEL
Re: Township Engineer, Private Client's Plans
84 -600
Dear Mr. Stillwagon:
This responds to your letter of July 31, 1984, in which you, as
solicitor for a municipality in Westmoreland County, requested advice from
the State Ethics Commission.
Issue: You ask whether the municipal engineer may also serve as engineer and
prepare plans for prospective applicants submitting applications to the
municipal planning commission.
Facts: You indicate that you are solicitor for a municipality in Westmoreland
County, hereinafter, the Municipality. The Municipality has appointed an
engineer, hereinafter, the Engineer who, as an Engineer, also provides
services to private clients. On occasion, these plans must be submitted to
the Municipal Planning Commission, hereinafter, the Planning Commission, for
approval by the Planning Commission. The plans submitted are submitted on
behalf of the individual clients and only the field work and actual drafting
is done by the Municipal Engineer.
You ask whether this is a situation which gives rise to a conflict of
interest and should be avoided or whether the Municipal Engineer may prepare
and present such plans on behalf of private clients to the Planning
Commission.
Discussion: Initially we note that the Pennsylvania State Ethics Act, 65 P.S.
401 et seq. was enacted to insure the public that the financial interests of
holders of or candidates for public office "present neither a conflict of
interest nor the appearance of a conflict with the public trust." As
Municipal Engineer, your client is a public employee - official and, therefore
is required to comply with the provisions of the State Ethics Act. See Bryan,
80 -014.
William C. Stillwagon, Esquire
August 16, 1984
Page 2
As you have indicated, this Municipal Engineer also works for private
clients. On occasion, these clients must present plans to the Planning
Commission, which we have concluded in prior opinions, a separate distinct
entity from the Municipality which established the Planning Commission.
Crosswell, 83 -565. However, we must also recognize that a relationship does
exist between the Planning Commission and the Municipality which is served by
the Planning Commission. Specifically, the purpose, according to our
understanding of the Planning Commission and its responsibilities, is to make
reports and recommendations to the Municipality regarding the approval of
plans, for example. Likewise, with respect to the Engineer's duties and
responsibilities vis -a -vis the Municipality, it is clear that he must be in a
position to provide professional services and recommendations on an impartial
basis to the Municipality with regard to plans and their approval or
rejection, given the recommendations of the Planning Commission.
Given these duties and responsibilities we must also review the
requirements of the State Ethics Act as applicable to public officials and
public employees. Specifically, the Ethics Act provides that no public
official may use his public office or confidential information received
through his holding public office to obtain finanical gain for himself or a
businesss with which he is associated and no public official may receive
anything of value, including the promise of future employment, on the
understanding that his official conduct will be influenced thereby. See
Section 3(a) and (b) of the Ethics Act, 65 P.S. 403(a) and (b). Thus, as a
public official /employee within the Municipality this Engineer must observe
these specific requirements of the Ethics Act when he undertakes his functions
of providing professional services and recommending approval or disapproval of
plans to the Municipality as reviewed by the Planning Commission.
As a Municipal Engineer, this Engineer may be faced with a situation
where the Planning Commission has been asked to approve or make a
recommendation to the Municipality with respect to plans prepared by this
Engineer as a private Engineer or by a member of his firm. In such a
situation, the Engineer should publicly disclose the extent of his involvement
in the preparation of the plans that are being submitted to the Municipality,
following the Planning Commission's review for acceptance or rejection and,
additionally, he should abstain from participating in review, recommendations
and discussions regarding the Municipality's action on such plans. Such
disclosure shoud be made at a public meeting and should be incorporated in the
minutes of that meeting. See Sowers, 80 -050.
This conclusion derives from the fact that the Engineer must insure that
his conduct presents neither a conflict or the appearance of a conflict with
the public trust. Previously rulings of the Commission indicate that as a
general rule, a public official or employee may not review, approve, or
inspect or take any official action in which he might be interested as an
individual. For example, the Commission concluded that a zoning officer who
William C. Stillwagon, Esquire
August 16, 1984
Page 3
is also a developer could not issue permits to himself. Simmons, 79 -056.
Similarly, the Commission has concluded that a developer who is an elected
township supervisor could not inspect or approve his own work as a developer.
See Sowers, supra. With respect to auditing, Commission rulings also indicate
that an auditor may not audit the township books, where the spouse of the
auditor serves as supervisor. Restivo, 80 -518 and Detweiler, 81 -648.
Conclusion: As a public official /public employee serving as Engineer for this
Municipality, this Engineer's conduct in relation to his public post and his
private employment should be governed by guidelines expressed above.
Specifically, this Engineer, in his capacity as Municipal Engineer must:
1. not use his official position to obtain any business in a private
capacity as Engineer;
2. not utilize confidential information gained through his official
position as Municipal Engineer;
3. refrain from participating in discussions, review, or recommendations
on matters which directly relate to clients he has served as a private
Engineer which may have been subject to the review and approval and
recommendation authority of a planning commission and subsequently reviewed by
the Municipality itself.
4. make public his relationship to such a private client with respect to
any plans or recommendations that may come before the Municipalality for final
or further review and approval; and
5. not review in his capacity as Municipal Engineer on behalf of the
Municipality any plans on which he worked as a private Engineer.
If the guidelines discussed above are adhered to, the Municipal Engineer
may concurrently serve as Municipal Engineer and private Engineer for clients
even where those clients may be required to submit plans to the Planning
Commission and /or the Municipality.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good
faith conduct in any other civil or criminal proceeding, providing the
requestor has disclosed truthfully all the material facts and committed the
acts complained of in reliance on the Advice given.
This letter is a public record and will be made available as such.
William C. Stillwagon, Esquire
August 16, 1984
Page 4
Finally, if you disagree with this Advice or if you have any reason to
challenge same, you may request that the full Commission review this Advice.
A personal appearance before the full Commission will be scheduled and a
formal Opinion from the Commission will be issued. Any such appeal must be
made, in writing, to the Commission within 15 days of service of this Advice
pursuant to 51 Pa. Code 2.12.
SSC /na
Sincerely,
Sa dra S. Ch
General Coun /el
tianson