HomeMy WebLinkAbout91-512 GuiseMr. Dennis T. Guise
Pa. Fish Commission
P.O. Box 1673
Harrisburg, PA 17105 -1673
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
February 7, 1991
91 -512
Re: Conflict, Public Official, Commissioner, Pennsylvania Fish
Commission, Vote, Contracting Bid Process, Business with
Which Associated.
Dear Mr. Guise:
This responds to your letter of January 7, 1991, in which
you requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any prohibition or restrictions upon a member of the
Pennsylvania Fish Commission regarding future contracting between
the Commission and the Commissioner's business.
Facts: As Chief Counsel for the Pennsylvania Fish Commission,
and with the authorization of Fish. Commissioner Howard E.
Pflugfelder, Jr., you inquire with the State Ethics Commission
regarding future contracting between the Commissioner's business
and the Pennsylvania Fish Commission. The Pennsylvania Fish
Commission is an independent administrative commission consisting
of ten citizens appointed by the Governor with the advice and
consent of two - thirds of the Pennsylvania Senate. The
commissioners serve for eight -year terms, with two commissioners
serving "at- large" and representing boating interests and the
remaining commissioners representing districts. The
commissioners serve as the "board of directors" for the Fish
Commission and they promulgate rules and regulations, establish
agency policies and oversee agency programs. The commissioners
serve without compensation other than reimbursement for their
travel expenses. The commissioners appoint the Executive
Director of the Commission, who is the Chief Executive Officer of
the Commission.
Commissioner on November 16, 1990 sworn
complete t member
Fish Commission unexpired
Mr. Dennis T. Guise
Page 2
term of a deceased Commissioner. The Commissioner is one of the
two "boater" members of the Commission. He is also the President
of his business, Harrisburg Seaplane Base, a full- service boat
dealership with which the Commission has contracted for numerous
boating related serves for many years prior to Commissioner
Pflugfelder's appointment to the Fish Commission. For example,
the Commission had a service purchase contract with the
Harrisburg Seaplane Base for boat repairs on an "as- needed"
basis. The Commission has purchased boat accessories from this
business through the Department of General Services, and has
contracted to moor Commission boats at the business location.
All contracts have been let through the public bidding process.
For some of the services, including the boat mooring contract,
Harrisburg Seaplane Base may have been the only bidder as the
only source offering such serves in the vicinity. In 1990, the
Commission contracted with Harrisburg Seaplane Base for goods and
services totalling approximately $20,000.
As a member of the Fish Commission, Commissioner Pflugfelder
would have no direct role in the award or administration of
contracts with his business because these functions are performed
by the Executive Director and the staff pursuant to the authority
of the Fish and Boat Code. It is assumed that Commissioner
Pflugfelder has not been appointed the Executive Director. The
commissioners are not directly involved in the contracting
process, and they do not review contracts, oversee contract
administration, or even vote to approve contracts between the
Commission and private firms.
You have reviewed the State Adverse Interest Act and the
State Ethics Act and you have reached some tentative conclusions
on the issues which Commissioner Pflugfelder has raised. You
submit your opinion that contracts between the Commission and the
Commissioner's business do not appear to violate the State
Adverse Interest Act. You recognize that Commissioner
Pflugfelder is a "public official" as defined in the State Ethics
Act. You acknowledge that although the Commissioner does not
receive compensation other than reimbursement for travel
expenses, the Fish Commission is not an "advisory board" and it
does exercise authority to spend public funds. You submit that
based upon your review of Section 3 of the Ethics Act you feel
that Section 3(a) and 3(f) are implicated by contracts between
the Fish Commission and Harrisburg Seaplane Base. You state your
belief that these contracts do not violate either provision.
With respect to Section 3(a), although you acknowledge that
arguably all Fish Commission contracts derive from the authority
of the commissioners, you do not believe that this would mean
Mr. Dennis T. Guise
Page 3
direct involvement in the contracting process and do not review
any confidential information related to contracting, you submit
that there would not appear to be a conflict of interest. With
regard to Section 3(f) of the Ethics Law, you submit that all
Fish Commission contracts are awarded through an open public
process, with invitations for bids being publicized through
solicitations to names on bidders lists and, when deemed
appropriate, publication of notices through the Office of
Procurement Information. Although the list of bidders and
contract awards are public information, the Commission has not
ordinarily published a formal notice of contract awards listing
the bidders. You acknowledge that the Commission could publish
such notices with respect to contracts with Harrisburg Seaplane
Base if required.
In addition to the statutory issues, Commissioner
Pflugfelder is sensitive to appearance issues with regard to
contracts between the Commission and his business. Because
contracts with the Fish Commission are not a major part of the
Commissioner's business, he would willingly forego them to avoid
any appearance of an ethical problem. However, the Commission
staff is concerned that the elimination of Harrisburg Seaplane
Base from the bidders lists would make the acquisition of
necessary boating goods and services more difficult and expensive
for the Commission. Comparable facilities for boat mooring may
not be conveniently or reasonably available to the Commission in
required locations. You state that the Commission staff is more
interested in continuing to seek bids from Harrisburg Seaplane
Base then the Commissioner is interested in continuing to submit
bids for such work.
You request advice on the following five specific
questions:
1. Is it legal for the Fish Commission to solicit bids from
Harrisburg Seaplane Base for boating goods and services?
2. Is it legal for Harrisburg Seaplane Base, acting through its
president, Howard E. Pflugfelder, Jr., to respond to an
invitation for bids or request for proposals issued by the
Fish Commission?
3. Does a Fish Commissioner have a conflict of interest with
respect to a contract between the Commission and a business
operated by him when the Commissioner has not used any
confidential information to obtain the contract and the
contract is not subject to review or approval by the
commissioners?
Mr. Dennis T. Guise
Page 4
4. Whether a contract between the Fish Commission and a
business operated by a Fish Commissioner is not illegal
under Section 3(f) of the Ethics Law as long as the
Commission meets the public notice and disclosure provisions
of the Act?
5. What administrative requirements must the Commission follow
under Section 3(f) of the State Ethics Act for providing
public notice of bids and public disclosure of the results
of the bidding process with respect to a contract between
the Fish Commission and a business operated by a Fish
Commissioner?
Discussion: As a Commissioner for the Pennsylvania Fish
Commission, Howard E. Pflugfelder, Jr. is a public official as
that term is defined under the Ethics Law, and hence Commissioner
Pflugfelder is subject to the provisions of that law.
Section 3(a) of the Ethics Law provides:
Section 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
The following terms are defined in the Ethics Law as
follows:
Section 2. 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. "Conflict" or
"conflict of interest" 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
or his immediate family or a business with
which he or a member of his immediate family
is associated.
Mr. Dennis T. Guise
Page 5
"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.
"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.
"Financial interest." Any financial
interest in a legal entity engaged in
business for profit which comprises more
than 5% of the equity of the business or more
than 5% of the assets of the economic
interest in indebtedness.
"Contract." An agreement or arrangement
for the acquisition, use or disposal by the
Commonwealth or a political subdivision of
consulting or other services or of supplies,
materials, equipment, land or other personal
or real property. "Contract" shall not mean
an agreement or arrangement between the State
or political subdivision as one party and a
public official or public employee as the
other party, concerning his expense,
reimbursement, salary, wage, retirement or
other benefit, tenure or other matters in
consideration of his current public
employment with the Commonwealth or a
political subdivision.
In addition, Sections 3(b) and 3(c) of the Ethics Law
provide in part that no person shall offer to a public
official /employee anything of monetary value and no public
official /employee shall solicit or accept any thing of monetary
value based upon the understanding that the vote, official
action, or judgement of the public official /employee would be
influenced thereby. Reference is made to these provisions of the
law not to imply that there has or will be any transgression
thereof but merely to provide a complete response to the question
presented.
Section 3(f) of the Ethics Law provides:
Mr. Dennis T. Guise
Page 6
Section 3. Restricted activities.
(f) No public official or public
employee or his spouse or child or any
business in which the person or his spouse or
child is associated shall enter into any
contract valued at $500 or more with the
governmental body with which the public
official or public employee is associated or
any subcontract valued at $500 or more with
any person who has been awarded a contract
with the governmental body with which the
public official or public employee is
associated, unless the contract has been
awarded through an open and public process,
including prior public notice and subsequent
public disclosure of all proposals
considered and contracts awarded. In such a
case, the public official or public employee
shall not have any supervisory or overall
responsibility for the implementation or
administration of the contract. Any contract
or subcontract made in violation of this
subsection shall be voidable by a court of
competent jurisdiction if the suit is
commenced within 90 days of the making of the
contract or subcontract.
Parenthetically, where contracting is otherwise allowed or
where there appears to be no expressed prohibitions to such
contracting, the above particular provision of law would require
that an open and public process must be used in all situations
where a public official /employee is otherwise appropriately
contracting with his own governmental body in an amount of
$500.00 or more. This open and public process would require:
(1) prior public notice of the employment or
contracting possibility;
(2) sufficient time for a reasonable and prudent
competitor /applicant to be able to prepare and
present an application or proposal;
(3) public disclosure of all applications or proposals
considered and;
(4) public disclosure of the contract awarded and
offered and accepted.
Mr. Dennis T. Guise
Page 7
Section 3(f) of the Ethics Law also requires that the public
official /employee may not have any supervisory or overall
responsibility as to the implementation or administration of the
contract.
Section 3(j) of the Ethics Law provides as follows:
Section 3. Restricted activities.
(j) Where voting conflicts are not
otherwise addressed by the Constitution of
Pennsylvania or by any law, rule, regulation,
order or ordinance, the following procedure
shall be employed. Any public official or
public employee, who in the discharge of his
official duties, would be required to vote on
a matter that would result in a conflict of
interest shall abstain from voting and, prior
to the vote being taken, publicly announce
and disclose the nature of his interest as a
public record in a written memorandum filed
with the person responsible for recording the
minutes of the meeting at which the vote is
taken, provided that whenever a governing
body would be unable to take any action on a
matter before it because the number of
members of the body required to abstain from
voting under the provisions of this section
makes the majority or other legally required
vote of approval unattainable, then such
members shall be permitted to vote if
disclosures are made as otherwise provided
herein. In the case of a three - member
governing body of a political subdivision,
where one member has abstained from voting as
a result of a conflict of interest, and the
remaining two members of the governing body
have cast opposing votes, the member who has
abstained shall be permitted to vote to break
the tie vote if disclosure is made as
otherwise provided herein.
If a conflict exists, Section 3(j) requires the public
official /employee to abstain as well as file a written memorandum
to that effect with the person recording the minutes or
supervisor.
In the event that the required abstention results in the
inability of the governmental body to take action because a
majority is unattainable due to the abstention(s), then in that
Mr. Dennis T. Guise
Page 8
event participation is permissible provided the disclosure
requirements noted above are followed.
In applying the above provisions of the Ethics Law, under
Section 3(a) of the Ethics Law quoted above, a public official
may not use the authority of office or confidential information
to obtain a private pecuniary benefit for himself, a member of
his immediate family or a business with which he or a member of
immediate family is associated. As president of Harrisburg
Seaplane Base, it is clear that the foregoing entity is a
business with which Commissioner Pflugfelder is associated as
defined under the Ethics Law.
Under Section 3(a), Commissioner Pflugfelder as President of
Harrisburg Seaplane Base is not precluded from contracting with
the Pennsylvania Fish Commission, but Commissioner Pflugfelder
could not participate or vote on matters involving contracts
between the Fish Commission and Harrisburg Seaplane Base. In
addition, the requirements of Section 3(j) of the Ethics Law must
be followed whereby the reasons for the abstention must be
publicly noted as well as a written memorandum to that effect
being filed with the secretary recording the minutes. Although
you have stated that Commissioner Pflugfelder would have no
direct role in the award or administration of contracts with his
business, would not vote to approve contracts between the
Commission and private firms including his own, and would not
review contracts or oversee contract administration, all of which
functions are performed by the Executive Director and staff, the
above restrictions are set forth to provide a complete response
to the question presented.
Focusing upon your specific inquiries, the propriety of the
proposed conduct may only be addressed under the Ethics Law; the
applicability of any other statute, code, ordinance, regulation
or any other code of conduct other than the Ethics Law may not be
considered in that they do not involve an interpretation of the
Ethics Law. Specifically not addressed herein is the
applicability of the State Adverse Interest Act (71 P.S. S776.1
et sea.).
With regard to the question presented in your first inquiry,
since our jurisdiction relates to public officials, public
employees, candidates, nominees and persons having involvement
with them, the scope of our response must be limited to reviewing
this matter from the perspective of Commissioner Pflugfelder as a
Commission member.
With regard to your second inquiry, although you have asked
what Commissioner Pflugfelder can do vis -a -vis the business, we
can only look at the perspective of the public official. Under
Mr. Dennis T. Guise
Page 9
the Ethics Law, Commissioner Pflugfelder is not precluded from
contracting with the Pennsylvania Fish Commission subject to the
restrictions of Sections 3(a), (b), (c), (f) and (j) discussed
above. The Commissioner may respond to an invitation for bids or
request for proposals issued by the Fish Commission which
conforms to the requirements for an open and public process set
forth in Section 3(f). Thus, the process would entail the
Commission advertising for requests for proposals as opposed to a
situation of actively soliciting a bid from Commissioner
Pflugfelder or this particular business. In addition, the open
and public process would require that the process truly be open
and public rather than a solicitation directed to selective
bidders lists.
With regard to your third inquiry, under the facts and
circumstances as you have submitted them, a Fish Commissioner
would not transgress Section 3(a) of the Ethics Law by
contracting with the Fish Commission subject to the express
condition that the Commissioner complies with the restrictions
set forth herein.
With regard to your fourth inquiry, this question may only
be addressed from the perspective of the public official.
Commissioner Pflugfelder would not transgress Section 3(f) of the
Ethics Law by virtue of a contract between the Fish Commission
and Harrisburg Seaplane Base as long as the restrictions of
Section 3(f) are observed and subject to the express condition
that there is no violation of Sections 3(a), (b), (c) or (j).
In response to your fifth and final inquiry, the
requirements of the Ethics Law with respect to an open and public
process, have been set forth above. (See also, Williamson, Advice
90 -601 (later supplemented in Advice 90- 601 -S)).
In addition to the above provisions and restrictions,
Commissioner Pflugfelder may find general guidance in the
principles of the legislative purpose set forth at Section 1 of
the State Ethics Act. Although public officials should not be
discouraged from maintaining their community contacts through
their occupations and professions, "...public office is a public
trust" and "...any effort to realize personal financial gain
through public office other than compensation provided by law is
a violation of that trust." 65 P.S. §401(a). The public has a
right to be assured that the financial interests of public
officials do not conflict with the public trust. Id. Given
these enunciated principles, the public interest must be
paramount. In Crisci, Opinion 89 -013, the Commission cautioned
a public official who did not consider the public interest to be
paramount:
Mr. Dennis T. Guise
Page 10
Additionally, you have advised this
Commission specifically and most directly
that your first loyalty is to your private
employer and not the governmental body on
which you serve or the public. This is at
odds with the stated purpose of the Ethics
Law. With this line now clearly marked, we
feel obligated to advise you in the clearest
language possible that you must exercise the
utmost caution in any action that you take
that may be at variance with the provisions
of the Law.
Id. at 4.
The propriety of the proposed conduct has only been
addressed under the Ethics Law; the applicability of any other
statute, code, ordinance, regulation or other code of conduct
other than the Ethics Law has not been considered in that they do
not involve an interpretation of the Ethics Law. Specifically
not addressed herein is the applicability of the State Adverse
Interest Act.
Conclusion: As a Commissioner for the Pennsylvania Fish
Commission, Howard E. Pflugfelder, Jr. is a public official
subject to the provisions of the Ethics Law. The Ethics Law
would not preclude Commissioner Pflugfelder as president for
Harrisburg Seaplane Base from contracting with the Pennsylvania
Fish Commission subject to the restrictions herein. Under
Section 3(a) of the Ethics Law, the Commissioners is precluded
from participating or voting on matters involving contracts
between the Fish Commission and Harrisburg Seaplane Base. The
disclosure requirements of Section 3(j) outlined above must be
observed. If the contract is valued at $500 or more,
Commissioner Pflugfelder may not contract in response to a
"solicited" bid from the Commission which is not truly open and
public, but rather the requirements of Section 3(f) regarding an
open and public process as outlined above must be accomplished.
Commissioner Pflugfelder, as President of Harrisburg Seaplane
Base, may respond to requests for proposals subject to the
restrictions of Section 3(b), (c) and (f). Commissioner
Pflugfelder may not have any supervisory or overall
responsibility as to the implementation or administration of such
contracts between Harrisburg Seaplane Base and the Fish
Commission. Lastly, the propriety of the proposed conduct has
only been addressed under the Ethics Law.
Pursuant to Section 7(11), 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
Mr. Dennis T. Guise
Page 11
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 in writing
and must be received at the Commission within 15 days of the date
of this Advice pursuant to 51 Pa. Code §2.12.
ncerely,
ncent J'. Dopko,
Chief Counsel