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HomeMy WebLinkAbout95-605 DAlessandroSamuel M. D'Alessandro Box 302 Swiftwater, PA 18370 STATE ETHICS COMMISSION 309 FINANCE BUILDING P.O. BOX 11470 HARRISBURG, PA 17108 -1470 TELEPHONE (717) 783 -1610 ADVICE OF COUNSEL October 11, 1995 95 -605 Re: Conflict, Public Official /Employee, Supervisor, Engineer, Consulting Engineer, County Planning Commission Dear Mr. D'Alessandro: This responds to your letter of September 6, 1995 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 township supervisor from participating or voting on plans which have been submitted to the County Planning Commission for which his engineering firm has reviewed the plans as a consulting engineer. Facts: You are a Township Supervisor and also a partner in an engineering firm which acts as a consulting engineer for the County Planning Commission. Your firm reviews plan submissions forwarded to the County Planning Commission for advisory review under the requirements of the MPC. Your firm conducts these plan reviews pursuant to a January 10, 1994 memorandum from the Planning Commission which outlines seven areas for the consulting engineer to cover in his review of plans as per an enclosure which is incorporated herein by reference. In this capacity, your firm reviews plans for projects October 11, 1995 Page 2 located in the Township in which you are a Supervisor. Your firm reviews the plans on behalf of the Planning Commission, but has no part in the production of these plans. Your firm does not work on the project for the owner, the developer, or the consulting engineer who prepared the plans. When these plans come before the Board of Supervisors, you ask whether you may vote concerning these plans, that is, either to approve, reject or approve with conditions. You inquire as to whether your voting on these plans constitutes a conflict of interest under the Ethics Law. You assert that there is no conflict of interest since your firm reviews the plans on behalf of the County Planning Commission, an advisory body, and not for the developer or property owner. When you vote as a Township Supervisor, you state that you are voting on behalf of the Township and not for the developer or property owner. Discussion: It is initially noted that pursuant to Sections 7(10) and 7(11) of the Ethics Law, 65 P.S. § §407(10), (11), advisories are issued to the requestor based upon the facts which the requestor has submitted. In issuing the advisory based upon the facts which the requestor has submitted, the Commission does not engage in an independent investigation of the facts, nor does it speculate as to facts which have not been submitted. It is the burden of the requestor to truthfully disclose all of the material facts relevant to the inquiry. 65 P.S. § §407(10), (11). An advisory only affords a defense to the extent the requestor has truthfully disclosed all of the material facts. As Township Supervisor you are a public official as that term is defined under the Ethics Law, and hence you are 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. October 11, 1995 Page 3 The following terms are defined in the Ethics Law as. follows: Section 2. Definit'ons. "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 of his immediate family or a business with which he or a member of his immediate family is associated. "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. 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 anything 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 been or will be any transgression thereof but merely to provide a complete response to the question presented. October 11, 1995 Page 4 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 and to publicly disclose the abstention and reasons for same, both orally and by filing a written memorandum to that effect with the person recording the minutes or supervisor. October 11, 1995 Page 5 In applying the provision of Section 3 (a) of Act 9 of 1989 to the instant matter, a conflict would exist as to your review of plans before the township board as to which your engineering provided consulting services to the county planning commission. The fact that the engineering firm, the business which you are associated, provides the consulting services to another governmental body, as opposed to a developer or private client makes no difference. Ledeber, Opinion 95 -007. In this case, your engineering firm has performed consulting engineering services as to plans. When these plans, for which your firm received a certain fee for performing its review, come before the township board, you would be reviewing plans as a public official wherein your engineering firm in a private capacity performed engineering services for profit. Such participation on your part as a public official would be a conflict of interest under the Ethics Law. Consequently, you could not participate and must observe the written and oral discloser requirements of Section 3(j) of the Ethics Law quoted above. 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 respective municipal code. Conclusion: As Township Supervisor, Samuel D'Alessandro is a public official subject to the provisions of the Ethics Law. Under Section 3(a) of the Ethics Law, D'Alessandro would have a conflict as to participating or voting on plans before the township board of supervisors where his engineering firm provided consulting services on the plans to the county planning 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 proceeding, providing the requestor has disclosed truthfully all the material facts and committed the acts complained of in reliance on the Advice given. October 11, 1995 Page 6 such. 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 appeal the Advice to the full Commission. A personal appearance before the Commission will be scheduled and a formal Opinion will be issued by the Commission. Any such appeal must be in writing and must be actually received at the Commission within thirty (30) days of the date of this Advice pursuant to 51 Pa.Code §13.2(h). The appeal may be received at the Commission by hand delivery, United States mail, delivery service, or by FAX transmission (717- 787 - 0806). Failure to file such an appeal at the Commission within thirty (30) days may result in the dismissal of the appeal. Vincent J. Dopko Chief Counsel