HomeMy WebLinkAbout82-592 EwaysMr. M. J. Eways, P.E., President
Mast Engineering Co., Inc.
438 Walnut Street
Reading, PA 19601
Mailin Address
STATE ETHICS COMMISSION
P.O. BOX 1 179
HARRISBURG, PA 17108
TELEPHONE: (717) 783 -1610
December 6, 1982
ADVICE OF COUNSEL
RE: Conflict of Interest; Planning Commission
Dear Mr. Eways:
82 - 592
This is in response to your letter dated November 1, 1982, in which you,
as President of Mast Engineering Co., Inc., requested advice from the State
Ethics Commission.
Issue: You requested advice as to whether you, as Township Engineer, should
continue to advise the Township Planning Commission on a matter in which you
have substantial interest where approval of that issue by membrs of the Board
of Supervisors apparently is not unanimous and the Board itself has not yet
taken official action on the matter.
Facts: Mast Engineering Co., Inc. was appointed Township Engineer for Robeson
Township, Berks County, hereinafter the Township. There is no retainer set or
paid, and you work with the Township on a job -by -job basis. You do not attend
Township meetings unless requested to do so, but you do attend Planning
Commission meetings.
A property owner has engaged you to prepare plans for a landfill, Phase I
of which required topography, which you prepared, and geological information
for which an outside geologist was hired by the developer. Prior to your
submitting any items to DER you made a complete disclosure to the Township of
your role as Engineer for the property owner. As a result of such disclosure
questions were raised to the Board of Supervisors particularly by one member
who also works for a neighboring school district as to the propriety of your
role in this project. That school district board has since passed a
resolution expressing concern over the proposed landfill but to your knowlege,
the Board of Township Supervisors has not yet taken any official action in
opposition to the landfill.
State Ethics Commission / 308 Finance Building • Harrisburg, Pennsylvania
Mr. M. J. Eways, P.E., President
December 6, 1982
Page 2
Prior to these activities, DER and the Chamber of Commerce sponsored a
meeting at the Berks County Campus of Penn State with all elected officials
and Planning Commission members and the County Commissioners present, at which
time the officials were presented with evidence of the urgent need for
landfills and asked not to oppose such landfills. In view of this expression
of need for a landfill and the fact that you have already undertaken efforts
on behalf of the property owner, you ask whether advising the Planning
Commission and representing the developer concurrently constitutes a conflict
or the appearance of a conflict of interest.
Discussion: The Ethics Act, 65 P.S. §401 et. seq., was enacted to issure that
public officials "present neither a conflict nor the appearance of a conflict
with the public trust." In your case, your serving as the Township Engineer
in this matter concurrently with your representing the private developer
constitutes at least the appearance of a conflict with the public trust. You
are, therefore, required to avoid even the appearance of a conflict of
interest under the Act.
In its opinion in Alfano, 80 -007, the Ethics Commission held that a
conflict of interest exists when an individual represents two or more persons
with adverse interests. As you point out, the Board of Township Supervisors
has not yet taken any official action on the matter, but your duties with
respect to your position as Township Engineer are to advise the Planning
Commission and the Board and to review all items submitted to them in the best
public interest. Your duty to the private developer is to further his
interests to your best abilities. While the landfill may indeed be in the
best public interest, your advising the Board and the Commission in favor of
the project would necessarily appear as lobbying in favor of your other
client, the land owner, whether the Board adopts your view or not. You must
avoid this situation, particularly where, as here, the Township and Planning
Commission which you serve may have to decide upon the landfill design, plans,
etc. and may call upon the Township Engineer to assist in this review and
decision. Clearly you could not assist the Board or Commission in this
process because of your association with the developer. See Simmons, 79 -056
and Sowers, 80 -050.
In your letter, you presented two solutions to the problem: a) withdraw
from representing the developer or b) have another engineer advise the
Planning Commission and the Board on this matter. In this case, the second
alternative appears to be the more reasonable. While you have, in effect,
stated that you would support development of the landfill as being in the
public interest whether you were involved in the project or not, it would
appear that you were representing the interest of the developer, if you
Mr. M. J. Eways, P.E., President
December 6, 1982
Page 3
advise the Board and the Commission to support the landfill and they followed
your advice. Likewise, if both the Board and the Commissioners decided not to
follow your advice to support the project, you would indeed be representing
two or more persons with adverse interests, and your duties toward one body
would suffer or appear to suffer while you fulfilled your obligations to the
other.
Conclusion: In order to avoid even the appearance of a conflict of interest,
you may not advise the Planning Commission on the Board of Supervisors on this
particular landfill project, especially as it relates to your private client,
the developer. You may plan no role in reviewing, advising upon or otherwise
obtaining approval of the plans to be submitted to the Township or Planning
Commission you serve as Engineer by your private client.
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 be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
CW /rdp
Sincer -ly,
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alfdra S. Chrisfanson
General Counsel