HomeMy WebLinkAbout82-534 CashmanMr. David R. Cashman, Esquire
Cauley, Birsic, and Conflenti
1212 Manor Building
564 Forbes Avenue
Pittsburgh, PA 15219
Mailing Address:
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
April 21, 1982
ADVICE OF COUNSEL
82 -534
RE: Financial Interest Statement - Consulting Engineer to Municipal
Authority
Dear Mr. Cashman:
This responds to your letter of March 11, 1982 in which you, as Solicitor
for the Allegheny County Sanitary Authority, requested an opinion from the
State Ethics Commission.
Issue: Is a consulting engineering firm, hired on an annual basis by a County
Sanitary Authority, subject to the provisions of the Ethics Act requiring the
annual filing of a Financial Interest Statement?
Facts: You write the Commission in your capacity as solicitor for the
Allegheny County Sanitary Authority. The Authority, created in 1949, provides
sanitary sewage disposal to approximately 77 communities within Allegheny
County. In the process of providing the service, the Authority has found it
necessary to borrow funds and to secure the borrowing of the funds by issuing
debentures. To issue debentures, the Authority executed a trust agreement.
The trustee, Mellon Bank, required that a consulting engineer be hired on an
annual basis. One of the engineer's functions, as required by the Bank,
would be to prepare the Authority's budget for each operating year.
The Authority has retained a consulting engineer. In addition to
preparing the budget, the engineer helps prepare and review specifications for
contract bids. The consulting engineer also he 1p sevaluate problems within
the plant and makes certain recommendations concerning the methods in which
problems, both internal and external, to the operation of the Authority are to
be handled.
State Ethics Commission • 308 Finance Building • Harrisburg, Pennsylvania
Mr. David R. Cashman, Esquire
April 21, 1.982
Page 2
The company employed as the consulting engineer is a division of a
corporation, which corporation is not engaged primarily in the engineering
business. The consulting engineer has assigned as the project engineer one
engineer to oversee all the work to be done for and on behalf of the
Authority. The project engineer attends the Board meetings and is the
individual to whom all initial inquiries are made. This does not mean,
however, that there are not other engineers who provide service to the
Authority and make recommendations to it. You believe that the consulting
engineer employs other engineers who also make recommendations to the
Authority.
You question, specifically, the Financial Interest Statement filing
requirements, if any, of the consulting engineer and of individuals employed
by the consulting engineer.
Discussion: The Ethics Act, 65 P.S. §401 et seq. requires that public
employees and officials shall file Statements of Financial Interests with the
governing authority of the political subdivision by which he is employed no
later than May 1 of each year that he holds such a position and of the year
after he leaves such a position. 65 P.S. §404(a). Whether a consulting
engineer, employed by a political subdivision - such as a County sanitary
authority - is a public employee for purposes of the Ethics Act depends on the
nature of the engineer's employment.
When an engineer is brought in for a particular job because of its unique
expertise in a particular area, e.g. hydrology, and is not the regular
consulting engineer employed by the political subdivision, the engineer or
engineering firm is not considered a public employee. No member of the firm
or person hired by that firm would be required by the State Ethics Act to
file a Statement of Financial Interests.
On the other hand, a consulting engineering firm employed by a political
subdivision as needed is subject to the Ethics Act as a public employee. The
Act applies whether the firm performs on a retainer or on a "per job" basis.
The "public employee" classification applies, notwithstanding an arguable
independent contractor status under common law, because of the definition of
public employee in the Ethics Act: a person responsible for taking or
recommending official action of a nonministerial natue with regard to ..
contracting or procurement... or any other activity where the official action
has an economic impact of greater than a de mimimus nature of any person." 65
P.S. 402.
The engineer or firm, whose duties you have described, appears
representative of a "public employee" as defined in the preceding paragraph.
The engineer or firm is retained on an annual basis, pursuant to a separate
trust agreement, and performs a variety of important duties. The engineer or
firm takes official action with respect to the preparation and review of
contract bids. They recommend official action with respect to plant operation
and evaluate internal and external authority problems. Thus, the consulting
engineer or firm in this case, is subject to the provisions of the Ethics Act
as a public employee. The consulting engineering firm, therefore, must comply
with the Act's Financial Interest Statement filing requirements. See Bryan,
80 -014; Hemsley, 80 -034.
Mr. David R. Cashman, Esquire
April 21, 1982
Page 3
Because the consulting engineering company i:y a public employee, as set
forth above, the Authority's governing body must, in accordance with 51 Pa.
Code 4.7 of the Commission's regulations, designate the individual(s) within
the firm responsible for filing the Financial Interest Statement. Typically,
this designee is someone within the firm of a position of management. The
data to be provided relates to the designee. The description of the project
engineer which you supplied, if he is management level, suggests that he
would be the logical individual designated to file. Other employees of the
engineer or individuals employed by the engineer to do authority work are not
to be considered "public employees" because of this work assignment alone. As
noted, the Authority should designate the filer, and other employees of the
engineer need not be considered "public employees" for filing purposes.
Conclusion: As discussed above, in this case, the consulting engineering firm
to the Allegheny County Sanitary Authority is a public emloyee subject to the
Ethics Act and required by the Act to file a Statement of Financial Interests
pursuant to Section 4(a). Persons associated with the consulting engineer, in
particular the project engineer, do not become public employees as defined by
the Act simply because they work for the consulting engineer. The governing
body of the Authority must designate the "filer" within the consulting
engineering company.
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 may be scheduled and a formal
Opinion from the Commission will be issued. You should make such a request or
indicate your disapproval of this Advice within the next 30 days.
BF /rdp
Sincerely,
Jkdia
Sandra S. Christianson
General Counsel