HomeMy WebLinkAbout91-549 HeverlingSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
June 12, 1991
Mr. Jeffrey M. Heverling 91 -549
Four Fox Chase Drive
Harrisburg, PA 17111
Re: Former Public Employee; Section 3(g); Office of Attorney
General, Office of Consumer Advocate; Senior Regulatory Analyst.
Dear Mr. Heverling:
This responds to your letter of April 29, 1991, in which you
requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Law
presents any restrictions upon your employment following
termination of service as a Senior Regulatory Analyst at the
Office of Attorney General, Office of Consumer Advocate (OCA).
Facts: As a former Senior Regulatory Analyst at the Office of
the Attorney General, Office of Consumer Advocate (OCA), you seek
the advice of this Commission. You have provided a memorandum
which sets forth the facts and a discussion pertinent to your
request which memorandum is incorporated herein by reference.
OCA represents consumers in public utility matters before
the PUC and federal regulatory agencies and courts. The OCA is
an independent office within the Office of Attorney General, an
executive branch state agency. The Consumer Advocate is
appointed by the Attorney General and confirmed by the Senate.
The Consumer Advocate appoints all attorneys and professional
staff with the approval of the Attorney General. OCA is charged
with the responsibility to represent the interests of utility
consumers when and in a manner determined to be in the public
interest by the Consumer Advocate.
You were employed as a Senior Regulatory Analyst at OCA from
September 1, 1987 until your resignation on March 1, 1991. Your
responsibilities included analysis and review of tax and
accounting issues of utilities; advising OCA on issues and cases
Mr. Jeffrey M. Heverling
Page 2
presented to it; participating in discovery, preparation and
submission of testimony; and assisting OCA trial counsel in the
preparation of briefs in public utility rate cases litigated
before the Pennsylvania Public Utility Commission (PUC).
Following your resignation from OCA on March 1, 1991, you
commenced employment on March 11, 1991, with Buchart -Horn, Inc.,
a consulting firm where you hold a professional staff position as
a Senior Project Accountant.
However, you note that prior to your employment with OCA you
were employed with the. PUC from July, 1984 to September, 1987,
where you state that your responsibilities were identical to
those of your employment at OCA. The PUC regulates the investor -
owned public utilities which provide service within the
Commonwealth of Pennsylvania. The PUC is authorized by statute
to set just and reasonable rates that are charged to customers
for utility service, assure reliable and adequate service to all
customers, ensure compliance with its own regulations and the
Public Utility Code, and to develop public utility policy which
is in the public interest.
You have not been employed with the PUC since September 1,
1987. It is noted that upon your termination of employment with
the PUC in 1987, you sought the advice of this Commission
resulting in the issuance of Advice 88 -540.
You state as the primary issue in this case, whether you are
prohibited from representing your new, private employer's clients
before the PUC for the one -year period following your termination
of service with OCA. You admit that you were a "public employee"
as defined by the Ethics Law while serving with OCA. You further
admit that because of your status as a public employee subject to
the Ethics Law, the restrictions of the Ethics Law would apply to
you and would prohibit you as a "former public employee" from
representing any person before OCA for a one -year period
following your termination of service with OCA. (Although you
cite Section 3(e) of the Ethics Act, it is noted that effective
June 26, 1989, the relevant statutory provision is embodied at
Section 3(g) of the reenacted and amended Ethics Law, Act 9 of
1989, 65 P. S. §401,et
However, you opine that it is not clear that you should be
prohibited from representing your private employer's clients
before the PUC since there is a related adversarial role
performed by the OCA in PUC matters. Your current employment
would not necessarily require your direct representation before
OCA, but would involve the development and filing, as well as
testimony in support of, utility rate filings before the PUC but
not OCA. Your current employment would not provide the
opportunity to privately or otherwise influence the outcome of
Mr. Jeffrey M. Heverling
Page 3
any utility rate increase request reviewed by OCA. Furthermore,
OCA takes on an adversarial role when involved in a specific
utility rate filing, representing ratepayers against the filing.
OCA carries out this responsibility when specific rate filings
are litigated before the PUC by intervening in formal hearings
conducted before an Administrative Law Judge. When specific rate
filings are not litigated, OCA informally participates by
reviewing utility rate filings to determine if there is a
ratepayer interest of sufficient magnitude to justify
intervention and litigation. Only a small percentage of cases
that are filed with the PUC involve full litigation.
You state your belief that the danger that the Legislature
sought to address when drafting the State Ethics Act was the
potential that former employees would use their past employment
associations to provide a financial benefit to themselves or
their new employer to the detriment of the public. You believe
that that danger is not present under these circumstances and
that you should not be prohibited from representing (as defined
in the Ethics Law) your firm's clients.
Discussion: As a Senior Regulatory Analyst for OCA, you are to
be considered a "public employee" within the definition of that
term as set forth in the Public Official and Employee Ethics Law
and the Regulations of this Commission. 65 P.S. Section 402; 51
Pa. Code Section 1.1. This conclusion is based upon the above
submitted facts, which when reviewed on an objective basis,
indicate clearly that the power exists to take or recommend
official action of a non- ministerial nature with respect to
contracting, procurement, planning, inspecting, administering or
monitoring grants, leasing, regulating, auditing or other
activities where the economic impact is greater than de minimus
on the interests of another person.
Consequently, upon termination of public service, you would
become a "former public employee" subject to Section 3(g) of the
Public Official and Employee Ethics Law. Section 3(g) of the
Ethics Act provides that:
Section 3. Restricted activities.
(g) No former public official or public
employee shall represent a person, with
promised or actual compensation, on any
matter before the governmental body with
which he has been associated for one year
after he leaves that body.
Mr. Jeffrey M. Heverling
Page 4
Initially, to answer your request the governmental body with
which you were associated while working with OCA must be
identified. Then, the scope of the prohibitions associated with
the concept and term of "representation" must be reviewed.
The term "governmental body with which a public official or
public employee is or has been associated" is defined under the
Ethics Law as follows:
Section 2. Definitions.
"Governmental body with which a public
official or public employee is or has been
associated." The governmental body within
State government or a political subdivision
by which the public official or employee is
or has been employed or to which the public
official or employee is or has been appointed
or elected and subdivisions and offices
within that governmental body.
In applying the above definition to the instant matter, we
must conclude that the governmental body with which you were
associated upon termination of public service would be the Office
of Attorney General, including but not limited to OCA. The above
is based upon the language of the Ethics Law, the legislative
intent (Legislative Journal of House, 1989 Session, No. 15 at
290, 291) and the prior precedent of this Commission. Thus, in
Sirolli, Opinion 90 -006, the Commission found that a former
Division Director of the Department of Public Welfare (DPW) was
not merely restricted to the particular Division as was
contended but was in fact restricted to all of DPW regarding the
one year representation restriction. Similarly in Sharp, Opinion
90- 009 -R, it was determined that a former legislative assistant
to a state senator was not merely restricted to that particular
senator but to the entire Senate as his former governmental body.
Therefore, within the first year after termination of
service with OCA, Section 3(g) of the Ethics Law would apply and
restrict representation of persons or new employers vis -a -vis
the Office of Attorney General, including but not limited to OCA.
It is noted that Act 9 of 1989 significantly broadened the
definition of the term "governmental body with which a public
official or public employee is or has been associated." It was
the specific intent of the General Assembly to define the above
term so that it was not merely limited to the area where a public
official /employee had influence or control but extended to the
entire governmental body with which the public official /employee
Mr. Jeffrey M. Heverling
Page 5
was associated. The foregoing intent is reflected in the
legislative debate relative to the amendatory language for the
above term:
We sought to make particularly clear
that when we are prohibiting for 1 year that
revolving -door kind of conduct, we are
dealing not only with a particular
subdivision of an agency or a local
government but the entire unit..."
Legislative Journal of House, 1989 Session,
No. 15 at 290, 291.
Therefore, since the Ethics Law must be construed to
ascertain and effectuate the intent of the General Assembly under
1 Pa. C.S.A. 1901, it is clear that the governmental body with
which you were associated is the Office of Attorney General
including but not limited to OCA.
Turning now to the scope of the restrictions under Section
3(g), the Ethics Law does not affect one's ability to appear
before agencies or entities other than with respect to the former
governmental body. Likewise, there is no general limitation on
the type of employment in which a person may engage, following
departure from their governmental body. It is noted, however,
that the conflicts of interest law is primarily concerned with
financial conflicts and violations of the public trust. The
intent of the law generally is that during the term of a person's
public employment he must act consistently with the public trust
and upon departure from the public sector, that individual should
not be allowed to utilize his association with the public sector,
officials or employees to secure for himself or a new employer,
treatment or benefits that may be obtainable only because of his
association with his former governmental body.
In respect to the one year representation, the Ethics Law
defines "Represent" as follows:
Section 2. Definitions.
"Represent." To act on behalf of any
other person in any activity which includes,
but is not limited to, the following:
personal appearances, negotiations, lobbying
and submitting bid or contract proposals
which are signed by or contain the name of a
former public official or public employee.
Mr. Jeffrey M. Heverling
Page 6
In addition, the term "Person" is defined as follows under
the Ethics Law:
Section 2. Definitions.
"Person." A business, governmental
body, individual, corporation, union,
association, firm, partnership, committee,
club or other organization or group of
persons.
The Commission, in Popovich, Opinion 89 -005, has also
interpreted the term "representation" as used in Section 3(g) of
the Ethics Law to prohibit:
1. Personal appearances before the former governmental
body or bodies, including, but not limited to, negotiations or
renegotiations in general or as to contracts;
2. Attempts to influence;
3. Submission of bid or contract proposals which are
signed or contain the name of the former public
official /employee;
4. Participating in any matters before the former
governmental body as to acting on behalf of a person;
5. Lobbying, that is representing the interests of any
person or employer before the former governmental body in
relation to legislation, regulations, etc.
The Commission has also held that listing one's name as the
person who will provide technical assistance on such proposal,
document, or bid, if submitted to or reviewed by the former
governmental body constitutes an attempt to influence the former
governmental body. Therefore, within the first year after
termination of service, you should not engage in the type of
activity outlined above.
You may, assist in the preparation of any documents
presented to the Office of Attorney General so long as you are
not identified as the preparer. You may also counsel any person
regarding that person's appearance before the Office of
Attorney General. Once again, however, the activity in this
respect should not be revealed to the Office of Attorney
General. Of course, any ban under the Ethics Law would not
prohibit or preclude the making of general informational
inquiries of the Office of Attorney General to secure
information which is available to the general public. This must
Mr. Jeffrey M. Heverling
Page 7
not be done in an effort to indirectly influence the former
governmental body or to otherwise make known to that body the
representation of, or work for the new employer.
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 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.
Turning to your specific inquiry, your former governmental
body for present purposes is the Office. of Attorney General -not
the PUC. Although the PUC was your former governmental body for
purposes of the one-year restriction when you terminated your
employment with the PUC in 1987, that one -year prohibition has
long since expired. The Office of Attorney General is a distinct
and separate body from the PUC, and the prohibitions of Section
3(g) of the Ethics Law which apply to you at this time apply with
respect to the Office of Attorney General as your former
governmental body. Therefore, the Ethics Law would not prohibit
you from testifying at PUC proceedings on behalf of Buchart-
Horn's utility clients in an adversarial posture to OCA, subject
to the restrictions set forth herein.
Lastly, 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 Act has not been considered in that they do
not involve an interpretation of the Ethics Law.
Conclusion: As a Senior Regulatory Analyst for the Office of
Attorney General, Office of Consumer Advocate (OCA), you are to
be considered a "public employee" as defined in the Ethics Law.
Upon termination of service with OCA, you would become a "former
public employee" subject to Section 3(g) of the Ethics Law. The
former governmental body is the Office of Attorney General
including but not limited to OCA. The restrictions as to
representation outlined above must be followed. However, the
restrictions as to representation reply with respect to the
Office of Attorney General as your former governmental body,
rather than the PUC. The Ethics Law would not prohibit you from
testifying at PUC proceedings on behalf of Buchart- Horn's utility
clients in an adversarial posture to OCA. The propriety of the
proposed conduct has only been addressed under the Ethics Law.
Mr. Jeffrey M. Heverling
Page 8
such.
Further, should service be terminated, as outlined above,
the Ethics Law also requires that a Statement of Financial
Interests be filed for the year following termination of service.
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
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
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 52.12.
Sincerely,
vwc
Ccytti
Vincent J. Dopko,
Chief Counsel