HomeMy WebLinkAbout86-516 JordanMr. John T. Jordan
929 Spri ngwood Drive 86 -516
West Chester, PA 19382
Re: Township Supervisor, Participation Township Ordinance, Interest in
Ordinance
Dear Mr. Jordan:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
Fehruary 12, 1986
ADVICE OF COUNSEL
This responds to your letter of December 18, 1985, wherein you requested
the advice of the State Ethics Commission.
Issue: Whether the Ethics Act presents any prohihition upon the participation
of a township supervisor in a township decision to implement an Argricultural
Security Area when the supervisor is a farmer in the township.
Facts: On behalf of the township board of supervisors for the Township of
East Bradford, you have requested the advice of the State Ethics Commission
regarding the above issue. You indicate that Joel Colvin, a Township
Supervisor, is engaged in the husiness of farming in the township. You have
further advised that the township has recently considered the implementation
of an Agricultural Security District pursuant to the Agricultural Area
Security Law. 3 P.S. , 5901 et. seq. This Agricultural District was
implemented hy Ordinance. Mr. Colvin did not participate in the township's
passage of that ordinance. The purpose for his abstention in this matter was
hased upon the fact that certain citizens had raised objections to Mr.
Colvin's potential conflict of interest in this You indicate that Mr.
Colvin owns approximately 15 acres of farmland in East Bradford Township.
You further indicate that Mr. Colvin farms on approximately 1,200 acres of
land in the township. The land farmed hy Mr. Colvin is rented from area
landowners. You indicate that 650 acres of the land that Mr. Colvin currently
farms is within the Agricultural Security District and that 550 acres are
outside of the District.
Mr. John T. Jordan
February 12, 1Q86
Page 2
In addition to the foregoing, you indicate that the township has also, in
the past, considered the implementation of a zoning ordinance that would
require a 200 foot set hack area between land within the Agricultural Security
District and adjoining land. Within this 200 foot set back there would be no
development allowed. This area of space would, thus, be a buffer between the
agricultural area and the adjoining land. You do not indicate whether the 200
foot set back would be designated as part of the agricultural land or as part
of the land adjoining land.
You have requested the advice of the State Ethics Commission as to
whether there would be any conflict of interest if rir. Colvin were to
participate in the township's consideration of these decisions relating to the
Agricultural District. Mr. Colvin, as well as the third member of the hoard
of supervisors, have joined in your request for this advice.
Discussion: At the outset, it must be noted the State Ethics Commission
may only address the issue presented within the purview of the State Ethics
Act. 65 P.S. 5401 et seq. The Commission will not address your question
under other codes of conduct.
As a township supervisor in a township of the second class, Mr. Colvin is
clearly a public official within the definition of public official as that
term is provided in the State Ethics Act. 65 P.S. .5402. As such, his conduct
must conform to the requirements of the Act. Sowers, 80 -050.
Generally, the Ethics Act provides as follows:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Within the above provision of law, a public official may not use his position
in order to obtain any financial gain for himself, a memher of his family, or
a business with which he is associated. Similarly, a public official may not
use confidential information obtained in his public position for this purpose.
The Ethics Act also provides that this Commission may address other areas of
possible conflict.. See 65 P.S. 5.403(d). The parameters of the activities
encompassed by this provision of law are generally determined by reviewing the
intent and purpose of the State Ethics Act. The State Ethics Act was
promulgated in order to insure that the financial interest of public officials
Mr. John T. Jordan
February 12, 1986
Page 3
do not present a conflict of interest with their public trust. 65 P.S. §401.
As a result, this Commission has previously ruled that puhlic officials may
not act in a manner so as to serve interest that are adverse. See Alfano,
80 -007. In order to determine whether the actions of Mr. Colvin could present
a conflict of interest, we must review the applicable law and purpose of the
implementation of an Agricultural District in order to determine if Mr. Colvin
would obtain or secure any type of financial gain through the implementation
of such District or if his actions would, in any way, occasion a conflict of
i nterest.
The Agricultural Area Security Law was enacted in order to conserve,
protect and encourage the development and improvement of agricultural lands in
the Commonwealth of Pennsylvania. Pursuant to this enactment, the governing
body of a local government, such as the township board of supervisors, may
establish an agricultural area for the purpose of maintaining the agricultural
use of that area in the township. The implementation of an Agricultural
District is within the discretion and authority of the governing body, i.e.
the township board of supervisors in this case, and the request for such a
designated district may be made by any owner or owners of land that submits
such a proposal for consideration to the governing body. The governing hody,
in considering such a proposal, must evaluate the various factors to be
considered. Many of these factors are set forth in the Agricultural Security
Law. 3 P.S. §907. Participation by land owners in the Agricultural District
is voluntary. However, the addition or deletion of land in the agricultural
area may only occur after seven years or whenever the agricultural area is
subject to review by the township hoard of supervisors.
There is no doubt that pursuant to the Agricultural Area Security Law,
the township board of supervisors has the ultimate authority and power to
implement an Agricultural Security Area and approve the inclusion of specific
lands in the local jurisdiction within that area if requested by the citizens
of the township. Mr. Colvin is a member of the township hoard of supervisors
and has a public duty to review and consider such a request in accordance with
the law and based upon the evaluation criteria set forth in the law. On the
other hand, Mr. Colvin, as a farmer, has a vested interest in insuring that
sufficient land is available in order for him to conduct his livelihood.
Clearly, if land is designated as agricultural security land and the use of
such land is specifically and expressly reserved for agricultural purposes,
Mr. Colvin would reap a financial benefit in the form of continued husiness
security. In the instant situation, Mr. Colvin farms 650 acres of land within
the Agricultural Security District. This is approximately 30% of the total
land in the District. There is no doubt, that the passage of an ordinance
which restricted the use of this land as agricultural, could inure to the
benefit of Mr. Colvin. Thus, if the citizens of the township presented an
application or proposal to the township board of supervisors requesting that
Mr. John T. Jordan
February 12, 1986
Page 4
their land be designated as an Agricultural Area Security District and at the
time of this proposal P1r. Colvin was the farmer of this land or had a
reasonable belief that he would be leasing this land for fanning purposes, he
would be placed in a position of conflicting interest. On the one hand, he
would have a financial interest in insuring that this particular land which he
actually farmed or had a reasonable expectation that he would be farming,
remain as an agricultural area. On the other hand, as a public official, he
has the duty and responsibility of acting in the interest of the general
public, rather than in his own interest. Similarly, if Mr. Colvin was
involved in the original proposal presented to the township, or participated
to any extent in convincing the owners of land which he rented to submit such
a proposal, he then would he in a conflicting position if he were to
subsequently make a decision as to the designation of that land as an
agricultural district. As a result, if Mr. Colvin had an actual interest
either by ownership or rental agreement in the land that was proposed to the
board of supervisors as an agricultural district, he must abstain from
participating in deciding whether that land should be designated as such a
district. On the other hand, the mere fact that Mr. Colvin is a fanner would
not preclude him from acting in his official capacity to designate land as an
Agricultural Security Area if he has no interest either direct or indirect in
that land. Thus, Mr. Colvin could participate in a matter if it were
presented to the board of supervisors where he did not either own the land,
rent the land, or could reasonably anticipate being in an ownership or lessee
position.
As a result of the foregoing, and within provisions 3(a) and 3(d) of the
State Ethics Act, it is advised that Mr. Colvin acted properly in abstaining
from the township's decision relating to the designation of an Agricultural
Security Area if he stood in the relationship as noted above. He should
similarly be abstained in future situations if the above referenced factors
are present. With relation to the issue of the 200 foot set back, a similar
analysis is appropriate. Thus, if Mr. Colvin has an interest in the land in
which the 200 foot set back is proposed, he should abstain from participating
in the decision to have that set back implemented.
Conclusion: A township supervisor is a public official within the purview of
the State Ethics Act. Such a supervisor may not participate in the decision
to designate certain township land as an agricultural security area if that
supervisor either owns or leases the land or has a reasonable expectation that
he would own or lease the land. There is no prohibition upon this supervisors
participation in such a matter where he does not either own or lease the land.
Mr. John T. Jordan
February 12, 1986
Page 5
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.
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 Commission will be scheduled and a formal
Opinion from the Commission will be issued. Any such appeal must he made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
L
John J.-- onti no
Gene,ca1 Counsel