HomeMy WebLinkAbout99-559 GauthierCatherine H. Gauthier
1331 Birchwood Avenue
Roslyn, PA 19001
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
(717) 783 -1610
1- 800 - 932 -0936
ADVICE OF COUNSEL
June 18, 1999
99 -559
Re: Former Public Employee; Section 1 103(g); Planner; County Planning Commission.
Dear Ms. Gauthier:
This responds to your letter of May 21, 1999 by which you requested advice;from
the State Ethics Commission.
Issue: Whether the Public Official and Employee Ethics Act ( "Ethics Act ") presents
any restrictions upon employment of a planner following termination of service with a
county planning commission.
Facts: On May 7, 1999, you resigned as Planner for the Bucks County Planning
Commission (BCPC). Your duties included reviewing development proposals and
ordinance amendments pursuant to Act 247 of the Pennsylvania Municipalities Planning
Code. On occasion you worked pursuant to a contract agreement between the County
and a municipality in which you were project manager, to assist in the preparation of
comprehensive plans, zoning and subdivision ordinance amendments, and other special
planning studies. You also attended municipal level planning commission and board of
supervisors or council meetings upon request. You attended the meetings for -the
Planning Commission of Bedminster Township on a regular basis.
You now have a job with the Heritage Conservancy as a part -time Senior
Community Planner. The Conservancy is a nonprofit organization dedicated to
preserving the natural and historic heritage of the region, that is, promoting open space,
natural resource protection, wildlife habitat restoration, and biodiversity through land use
planning and design, adaptive reuse of historic structures and innovative land
conservation strategies. Funds are generated through private donations, foundation and
government grants, contract services and property stewardship programs.
Since you began working for the Conservancy you have learned that Bedminster
has provided the BCPC with written notification of its intent to terminate the existing
planning contract. You understand the Bedminster Township has entered into an
agreement with the Heritage Conservancy to act as its planning consultant. The
Township has requested that you, as Heritage Conservancy staff member, attend
Township meetings and continue to provide planning assistance.
You inquire about the propriety of your job change as to providing planning
assistance and attending the Township meetings for Bedminster Township through your
new job with the Heritage Conservancy.
FAX: (717) 787 -0806 • Web Site: www.ethics.state.pa.us • e -mail: ethics @state.pa.us
Gauthier, 99 -559
June 18, 1999
Page 2
Discussion: In the former capacity as Planner for Bucks County Planning
Commission, you would be considered a "public employee" subject to the Ethics Act and
the Regulations of the State Ethics Commission. See 65 Pa.C.S. §1102; 51 Pa.Code
§11.1. This conclusion is based upon your stated job duties, which indicate that the
power exists to take or recommend official action of a non - ministerial nature with
respect to one or more of the following: contracting; procurement; planning; inspecting;
administering or monitoring grants; leasing; regulating; auditing; or other activities where
the economic impact is greater than de minimis on the interests of another person.
Consequently, upon termination of public service, you became a "former public
employee" subject to Section 1103(g) of the Ethics Act.
While Section 1103(g) does not prohibit a former public official /public employee
from accepting a position of employment, it does restrict the former public official /public
employee with regard to "representing" a "person" before "the governmental body with
which he has been associated ":
Section 1103. Restricted activities.
(g) Former official or employee. - -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.
65 Pa.C.S. §1103(g) (Emphasis added).
The terms "represent," "person," and "governmental body with which a public
official or public employee is or has been associated" are specifically defined in the
Ethics Act as follows:
Section 1102. 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.
"Person." A business, governmental body, individual,
corporation, union, association, firm, partnership, committee,
club or other organization or group of persons.
"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.
65 Pa.C.S. §1102.
Gauthier, 99 -559
June 18, 1999
Page 3
The term "Person" is very broadly defined. It includes, inter alia, corporations and
other businesses. It also includes the former public employee himself, Confidential
Opinion 93 -005, as well as a new governmental employer. Ledebur, Opinion 95 -007.
The term "representation" is also broadly defined to prohibit acting on behalf of
any person in any activity. Examples of prohibited representation include: (1) personal
appearances before the former governmental body or bodies; (2) attempts to influence;
(3) submission of bid or contract proposals which are signed by or contain the name of
the former public official /public employee; (4) participating in any matters before the
former governmental body as to acting on behalf of a person; and (5) lobbying.
Popovich, Opinion 89 -005.
Listing one's name as the person who will provide technical assistance on a
proposal, document, or bid, if submitted to or reviewed by the former governmental
body, constitutes an attempt to influence the former governmental body. Section
1103(g) also generally prohibits the inclusion of the name of a former public
official /public employee on invoices submitted by his new employer to the former
governmental body, even though the invoices pertain to a contract that existed prior to
termination of public service, Shay, Opinion 91 -012. However, if such a pre - existing
contract does not involve the unit where the former public employee worked, the name
of the former public employee may appear on routine invoices if required bX the
regulations of the agency to which the billing is being submitted. Abrams /Webster,
Opinion 95 -011.
A former public official /public employee may assist in the preparation of any
documents presented to his former governmental body. However, the public
official /public employee may not be identified on documents submitted to the former
governmental body. The public official /public employee may also counsel any person
regarding that person's appearance before his former governmental body. Once again,
however, the activity in this respect should not be revealed to the former governmental
body. The Ethics Act would not prohibit or preclude making general informational
inquiries to the former governmental body to secure information which is available to the
general public, but this must 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.
Section 1103(g) only restricts the former public official /public employee with
regard to representation before his former governmental body. The former public
official /public employee is not restricted as to representation before other agencies or
entities. However, the "governmental body with which a public official /public employee
is or has been associated" is not limited to the particular subdivision of the agency or
other governmental body where the public official /public employee had influence or
control but extends to the entire body. See, Legislative Journal of House, 1989 Session,
No. 15 at 290, 291; Sirolli, Opinion No. 90 -006; Sharp, Opinion 90- 009 -R.
The governmental body with which you were associated upon termination of
public service is BCPC in its entirety. Therefore, for the first year after termination of you
service with BCPC, Section 1103(g) of the Ethics Act would apply and restrict
"representation" of "persons" before BCPC. Your former governmental body would not
include Bedminster Township. Therefore, although you would be prohibited in
representing persons before your former governmental body, BCPC, the restriction of
Section 1 103(g) would not extend to such representation as to Bedminster Township.
Based upon the facts which have been submitted, this Advice has addressed the
applicability of Section 1 103(g) only. It is expressly assumed that there has been no use
of authority of office for a private pecuniary benefit as prohibited by Section 1 103(a) of
Gauthier, 99 -559
June 18, 1999
Page 4
the Ethics Act. Further, you are advised that Sections 1103(b) and 1103(c) of the Ethics
Act provide in part that no person shall offer to a public official /public employee and no
public official /public employee shall solicit or accept anything of monetary value based
upon the understanding that the vote, official action, or judgment of the public
official /public 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.
Lastly, the propriety of the proposed conduct has only been addressed under the
Ethics Act; 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 Act.
Conclusion: In the former capacity as Planner with Bucks County Planning
Commission (BCPC), you would be considered a "public employee" as defined in the
Public Official and Employee Ethics Act ( "Ethics Act "), Act 93 of 1998, Chapter 11.
Upon termination of service with BCPC, you would become a "former public employee"
subject to Section 1103(g) of the Ethics Act. The former governmental body is BCPC.
The restrictions as to representation outlined above must be followed. The propriety of
the proposed conduct has only been addressed under the Ethics Act.
Further, should service be terminated, as outlined above, the Ethics Act vould
require that a Statement of Financial Interests be filed by no later than May 1 of the :: year
after termination of service.
Pursuant to Section 1107(11), an 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, provided 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 appeal the Advice to the full Commission. A
personal appearance before the Commission will be scheduled and a forma/
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. l7opko
Chief Counsel