HomeMy WebLinkAbout1124 HawkinsIn Re: William Hawkins
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Daneen E. Reese, Chair
Austin M. Lee, Vice Chair
Julius Uehlein
Louis W. Fryman
John J. Bolger
Frank M. Brown
Susan Mosites Bicket
97- 023 -C2
Order No.1 124
6/1/99
6/10/99
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission
conducted an investigation regarding a possible violation of the Public Official and
Employee Ethics Law, Act 9 of 1989, P.L. 26, 65 P.S. §401 gt ems., by the above -
named Respondent. At the commencement of its investigation, the Investigative
Division served upon Respondent written notice of the specific allegation(s). Upon
completion of its investigation, the Investigative Division issued and served upon
Respondent a Findings Report identified as an "Investigative Complaint." An Answer
was filed and a hearing was waived. A Consent Agreement was submitted by the
parties to the Commission for consideration which was subsequently approved.
Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by
Chapter 11, Act 93 of 1998, which essentially repeats Act 9 of 1989 and provides
for the completion of pending matters under Act 93 of 1998.
This adjudication of the State Ethics Commission is issued under Act 93 of
1998 and will be made available as a public document thirty days after the mailing
date noted above. However, reconsideration may be requested. Any reconsideration
request must be received at this Commission within thirty days of the mailing date and
must include a detailed explanation of the reasons as to why reconsideration should
be granted in conformity with 51 Pa. Code §21.29(b). A request for reconsideration
will not affect the finality of this adjudication but will defer its public release pending
action on the request by the Commission.
The files in this case will remain confidential in accordance with Chapter 11 of
Act 93 of 1998. Any person who violates confidentiality of the Ethics Act is guilty of
a misdemeanor subject to a fine of not more than $ 1,000 or imprisonment for not
more than one year. Confidentiality does not preclude discussing this case with an
attorney at law.
Hawkins, 97- 023 -C2
Page 2
I. ALLEGATION:
That William Hawkins, a public official /public employee, in his capacity as a member
of the Cumberland County Transportation Authority (CCTA) violated the following
provisions of the State Ethics Act (Act 9 of 1989) when he used the authority of his
office for the private pecuniary benefit of himself and /or a business with which he is
associated by participating in actions, discussions and decisions of the CCTA resulting
in the awarding of a contract to a business to do a study for the CCTA at a time when
he was being compensated by that business; and when the contract with Buchan Horn
was awarded without an open and public process and when he failed to file SFI's for
the 1995 calendar year.
Section 1103. Restricted activities.
(a) Conflict of interest. - -No public official or public
employee shall engage in conduct that constitutes a conflict
of interest.
65 Pa.C.S. §1103(a).
Section 1102. 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. The term 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.
65 Pa.C.S. §1102.
65 Pa.C.S. §1103(c).
(c) Accepting improper influence. —No public official,
public employee or nominee or candidate for public office
shall solicit or accept, anything of monetary value, including
a gift, loan, political contribution, reward, or promise of
future employment based on any understanding of that
public official, public employee or nominee that the vote,
official action, or judgment of the public official or public
employee or nominee or candidate for public office would
be influenced thereby.
(f) Contract. —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
Hawkins, 97- 023 -C2
Page 3
65 Pa.C.S. §1103(f).
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.
Section 1104. Statement of financial interests required to be filed.
(a) Public official or public employee. - -Each public
official of the Commonwealth shall file a statement of
financial interests for the preceding calendar year with the
commission no later than May 1 of each year that he holds
such a position and of the year after he leaves such a
position. Each public employee and public official of the
Commonwealth shall file a statement of financial interests
for the preceding calendar year with the department,
agency, body or bureau in which he is employed or to which
he is appointed or elected no later than May 1 of each year
that he holds such a position and of the year after he leaves
such a position. Any other public employee or public official
shall file a statement of financial interests with the
governing authority of the political subdivision by which he
is employed or within which he is appointed or elected no
later than May 1 of each year that he holds such a position
and of the year after he leaves such a position. Persons
who are full -time or part-time solicitors for political
subdivisions are required to file under this section.
65 Pa.C.S. §1104(a).
II. FINDINGS:
1. William Hawkins served as a board member for the Cumberland County
Transportation Authority (CCTA) from 1990 through 1996.
a. Hawkins was appointed to the CCTA by the Cumberland County
Commissioners.
b. Hawkins served as Board Secretary during his service on the board.
c. Hawkins was appointed to the Air Transportation Committee in 1990.
d. Hawkins was appointed Chairman of the Study Management Committee
in 1992.
Hawkins, 97- 023 -C2
Page 4
2. William Hawkins is the president and owner of a lobbying firm, W.A. Hawkins
Associates.
a. Hawkins' occupation is a Government and Corporate Affairs Consultant.
3. William Hawkins is the president and owner of a consulting firm, W.A. Hawkins
Associates.
a. Hawkins filed registration statements with the Secretary of the Senate
which indicated he was employed or engaged for compensation, or would
make expenditures or incur obligations for businesses whose interest he
was representing.
4. The CCTA has been in existence since March 1990.
a. Articles of Incorporation were filed on March 16, 1990.
b. The CCTA was formed by the county commissioners, pursuant to the
Municipal Authorities Act of 1945.
5. The CCTA enacted by -laws on March 28, 1990, which provide, in part:
a. The business and property of the CCTA are to be managed and controlled
by the CCTA board.
b. The board is to be composed of seven members appointed for staggered
terms by the county commissioners.
c. The board is to meet on a monthly basis in Cumberland County.
6. The powers and duties of the CCTA board consist of general management and
control of the business of the authority.
7. The officers of the CCTA board include a chairman, vice chairman, treasurer,
secretary, assistant secretary and an assistant treasurer.
a. Officers shall be elected at the January meeting of the board held each
year and succeeding until their respective successors are duly elected and
qualified.
8. William Hawkins was appointed to the CCTA board in December 1989 to a four
year term.
9. In 1991, the CCTA board considered conducting an airport study for the
county.
10. The concept of a regional airport was discussed by the CCTA board during the
period 03/27/91 until 03/25/92.
11. On March 25, 1992, the CCTA formed a Study Management Committee with
a primary function to select a consultant to perform an airport study.
a. William Hawkins was appointed chairman of the Study Management
Committee at the CCTA board meeting on March 25, 1992.
b. Other members appointed were Ralph Peters and Joyce Zeigler.
Hawkins, 97- 023 -C2
Page 5
12. Prior to seeking written proposals from any interested consultants, the CCTA
held an open forum on June 16, 1992.
a. Any consultants interested in attending the open forum discussion were
requested to notify William Hawkins.
13. On June 16, 1992, Hawkins participated in a Study Management Committee
meeting to discuss the airport study.
a. The other CCTA board member present was Joyce Zeigler.
b. The consultants present included representatives from Buchart. Horn, LPA
Group, Arthur Little, Inc., Air Tech and Edwards and Kelcey, Inc.
14. At the June 16, 1992, Study Management Committee meeting, William
Hawkins identified the following criteria indicated in the request for proposal and
qualifications, as being particularly important to the Study Management
Committee in choosing a consultant:
a. Capability of performing all aspects of project.
b. Recent experience in similar studies clearly defining consultants' past
performance in both prime and subcontractors' roles.
c. Familiarity with the proximity to the geographic location of the study.
d. Demonstrated understanding of the project's potential problems.
e. Experience in advising similar clients in carrying out public meetings
required in the planning process.
15. As the chairman of the Study Management Committee, William Hawkins
directed that Request for Proposals (RFP's) and Qualifications to be sent to
firms interested in performing an airport study.
a. William Hawkins sent Request for Proposals and Qualifications to thirty -
five companies.
b. Buchart Horn was one of the companies sent an RFP.
16. The RFP's sent by Hawkins identified the broad purposes of the airport study
and what was required of the successful bidder.
17. At the June 24, 1992, meeting of the CCTA, William Hawkins reported that the
Study Management Committee for the proposed county airport study developed
a scope of work which had been mailed to thirty -five (35) consultants and a pre -
proposal conference was held on June 16, 1992.
a. Hawkins listed the timetable for the consultant selection as follows:
1. July 7 Proposals due
2. July 14 - Short list developed
3. July 22 - Interviews and consultant selection
Hawkins, 97- 023 -C2
Page 6
c. A motion was approved for the Study Management Committee to select
an independent firm to provide a cost estimate of the airport study.
Hawkins participated in approving the motion.
18. The following firms submitted proposals for the CCTA Air Demand Study:
a.
b.
c.
d.
e.
f.
Two of the five consultants who attended the pre - proposal conference did not
submit proposals. Likewise, three of the six consultants submitted proposals
even though they didn't attend the pre - proposal meeting.
19. On July 10, 1992, a short list was developed by the Study Management
Committee of the firms being considered for the airport study.
a.
b.
c.
b. Hawkins made a motion for the Study Management Committee to
interview selected firms, rank the candidates, and present the slate to the
CCTA for their approval. Motion carried with Hawkins participating in the
vote.
Air Tech
BTI Consultants
Buch Horn
C &S Engineers
Comsis
LPA Group
Included in the short list were Air Tech, Buchart Horn and LPA Group.
The short list was determined after a review of the proposals by Study
Management Committee Members Zeigler and Peters.
Hawkins was present for the review.
20. By July 10, 1992, board member Zeigler was aware that Chairman Hawkins
represented Buchart Horn in matters not related to the CCTA.
a. Hawkins participated in the meeting but did not evaluate or tabulate the
forms submitted by the consultants.
21. The fact that Hawkins had recused himself was never entered in the records of
CCTA or discussed with the full board.
22. As chairman of the Study Management Committee, William Hawkins was
involved in the process of determining the scope of the study, reviewing the
proposals submitted including being present for interviews of the firms.
23. On July 22, 1992, Hawkins participated in the Study Management Committee
interviews with the three short listed firms.
a. As chairman of the committee, Hawkins conducted the interviews and
posed questions to the applicants.
Hawkins, 97- 023 -C2
Page 7
24. The short listed firms were ranked as follows by the Study Management
Committee:
a. Buchart Horn
b. Airport Technology and Planning Groups, Inc.
c. LPA Group
d. The final ranking of Buchart Horn as the top ranked firm was determined
after the July 22, 1992, interviews by the Study Management
Committee.
25. On July 23, 1992, the Study Management Committee ranked Buchart Horn as
the finalist to prepare the CCTA airport study.
a. Hawkins did not participate.
26 During the CCTA meeting of July 29, 1992, William Hawkins reported that the
Study Management Committee had short listed three firms and Buchart Horn
was chosen as the finalist to begin contract negotiations.
a. Hawkins made a motion that the CCTA board concur wit the Study
Management Committee's ranking of the three firms in which Buchart
Horn was ranked first, and have the CCTA's approval to begin
negotiations with the ranked consultants. The motion was seconded by
Peters and passed by a 4 to 1 vote with Hawkins voting with the
majority.
27. During the CCTA meeting for August 26, 1992, Buchart Horn was selected to
perform the CCTA airport study.
a. Hawkins was present for the meeting.
b. No vote was taken to formally approve Buchart Horn.
c. No vote was taken because the Study Management Committee had
negotiated and agreed upon a contract price with Buchart Horn, the top
ranked company.
28. The Study Management Committee, which included Hawkins, Peters and
Zeigler, negotiated with Buchart Horn to perform the airport study at a cost of
$124,200.
29. On November 19, 1992, Hawkins participated in a meeting with members of
the CCTA and Buchart Horn.
a. Ralph Peters was to be the CCTA liaison with Buchart Horn and all
communications were to be sent to him for action and distribution
because Chairman Hawkins had recused himself.
b. Hawkins had questions on how services would be handled by Buchart
Horn beyond the contract scope.
c. The meeting occurred prior to a contract being entered into between
CCTA and Buchart Horn.
Hawkins, 97- 023 -C2
Page 8
30. At the time he was serving on the CCTA Board, William Hawkins was serving
as a registered lobbyist for Buchan Horn.
a. Hawkins had a contractual agreement with Buchart Horn as of May 16,
1990.
b. On May 16, 1990, William Hawkins filed notice with the Secretary of the
Senate that as a registered lobbyist, he was representing Buchan Horn,
Incorporated, (Buchan Horn) for an indefinite duration of employment.
c. On February 19, 1992, William Hawkins submitted a sworn affidavit to
the Secretary of the Senate stating he was employed or engaged for
compensation, or would make expenditures to incur obligations, and
lobby for the interests of various firms, one of which was Buchart Horn.
31. Hawkins' duties as a lobbyist for Buchan Horn were identified in a letter to Peta
Richkus, Vice President of Buchart Horn, on May 16, 1990.
a. OBJECTIVE: To provide Buchart Horn with an awareness of
planned projects in which the company could participate and to provide
Buchan Horn with an opportunity to establish a relationship with key
decision makers such that will result in additional business opportunities.
b. METHOD: To utilize contacts and existing relationships with selected
county and municipal officials to provide introductions, information and
access for Buchart Horn personnel as designate.
c. FOCUS: Initial efforts will be directed to the counties of Delaware
and Montgomery, municipalities and municipal authorities therein.
Buchart Horn will remain open to other opportunities which may appear
throughout the SE counties.
d. REPORTING: Working with the direction of Peta N. Richkus, I'II
provide a briefing paper on planned projects every two weeks, along with
other relevant information, where an "introductory" meeting, lunch, etc.,
is planned. In addition, I'II submit a monthly report showing all activity,
including time spent, contacts made, results of contacts and planned
follow -up.
e. AUTHORITY: While I will have neither authority nor responsibility
to bind the firm or otherwise represent Buchart Horn in an assignment, •
I will remain available to assist in maintaining an effective relationship
with the prospect.
f. Hawkins' duties, as a lobbyist for Buchart Horn, have remained the same
since 1990.
32. Hawkins has paid a monthly retainer fee for serving as a lobbyist for Buchart
Horn from 1990 until 1998.
33. William Hawkins was the only registered lobbyist in the state of Pennsylvania
for Buchart Horn in 1992.
34. As part of his agreement with Buchart Horn, Hawkins provided monthly activity
reports to Peta Richkus, vice president of Buchart Horn, which report delineates
Hawkins' activities on behalf of Buchart-Horn.
Hawkins, 97- 023 -C2
Page 9
35. Between April 27, 1992, and April 26, 1995, Hawkins specifically listed 15
meetings with identified Cumberland County and CCTA officials on business
related to the CCTA Airport Study as part of the monthly activity reports
provided to Buchart-Horn.
36. During the CCTA board meeting of August 25, 1993, Hawkins expressed
concerns that Buchart Horn was not being paid on time for the air demand study
and the timing of the federal budgetary process.
37. On three occasions between February 23, 1994, and June 16, 1995, Hawkins
voted, in unanimous votes, to approve various payments to Buchart-Horn for
services rendered in the course of the airport study.
38. During the CCTA meetings for July 28, 1993, August 25, 1993, and December
15, 1993, the board members discussed payments to Buchart Horn.
a. Hawkins approved the minutes of those meetings.
39. William Hawkins failed to file a Statement of Financial Interests with the CCTA
for the 1995 calendar year because he had never received the form from
Cumberland County.
40. During the 1995 calendar year, William Hawkins filed a Statement of Financial
Interests with the State Ethics Commission.
a. Hawkins' filing was as a member of the Unemployment Compensation
Board of Review.
41. When Hawkins was advised as part of this investigation that he had not filed
a Statement of Financial Interests for 1995, he secured a statement and filed
it with the State Ethics Commission.
III. DISCUSSION:
At all times relevant to this matter, the Respondent, William Hawkins,
hereinafter Hawkins, has been a public official subject to the provisions of the Public
Official and Employee Ethics Act ( "Ethics Act "), Act 9 of 1989, Pamphlet Law 26, 65
P.S. §401, at seq. /Act 93 of 1998, Chapter 11, 65 Pa.C.S. §1101, sue.
The issue is whether Hawkins violated Sections 1103(a), 1103(c), 1103(f) and
1104(a) of the Ethics Act as to the allegations that he used the authority of his office
for the private pecuniary benefit of himself or a business with which he is associated
by participating in actions of the CCTA resulting in the award of a contract to a
business to do a study for the CCTA at a time when he was being compensated by
that business; when the contract with that business was awarded without an open
and public process; and when he failed to file an SFI for the 1995 calendar year.
Section 1 103(a) of the Ethics Act prohibits a public official /public employee
from using the authority of public office /employment or confidential information
received by holding such a public position for the private pecuniary benefit of the
public official /public employee himself, any member of his immediate family, or a
business with which he or a member of his immediate family is associated.
Hawkins, 97- 023 -C2
Page 10
Section 1103(c) of the Ethics Act provides in part that a public official /public
employee shall not solicit or accept anything of monetary value based upon any
understanding that his vote, official action or judgment would be influenced thereby.
Section 1103(f) provides in part that no public official /public employee or
spouse or child or business with which he or the spouse or child is associated may
enter into a contract with his governmental body valued at five hundred dollars or more
or any subcontract valued at five hundred dollars or more with any person who has
been awarded a contract with the governmental body with which the public
official /public employee is associated unless the contract is awarded through an open
and public process including prior public notice and subsequent public disclosure.
Finally, Section 1104(a) of the Ethics Act requires that each public official /public
employee must file a Statement of Financial Interests for the preceding calendar year,
each year that he holds the position and the year after he leaves it.
Having noted the issues and applicable law, we shall now summarize the
relevant facts.
Hawkins served as a Board Member of the Cumberland County Transportation
Authority (CCTA) from 1990 through 1996. In a private capacity, Hawkins is the
president and owner of a lobbying /consulting firm, W.A. Hawkins Associates.
In 1991, the CCTA Board contemplated performing a county airport study.
Hawkins was appointed to a Study Management Committee (Committee) which was
charged with finding a consultant to perform the study. After the CCTA held an open
forum to discuss the study, proposals were requested by the Committee. Six firms
submitted proposals. Following a review of the applicants by the three .Committee
members, a short list of three of those firms was agreed upon by the Committee: Air
Tech, Buchart Horn, and LPA Group.
As Committee Chair, Hawkins was involved in the process of determining the
scope of the study, the review of the proposals submitted and the interviews of the
three firms. Without the participation of Hawkins, the Committee ranked Buchart Horn
as the top candidate of the three firms.
At a July, 1992 CCTA Board meeting, Hawkins made a motion and voted with
the majority to adopt the Committee ranking of the three firms with Buchart Horn as
number one in ranking.
Hawkins was present at the CCTA Board meeting in August, 1992, at which
Buchart Horn was selected to perform the airport study. No formal vote was taken
because the Committee had already negotiated and agreed on a contract price with
Buchart Horn of $124,200. At a November, 1992, Board meeting, it was decided that
Peters would be the CCTA liaison for Buchart Horn because Hawkins recused himself.
At that time Hawkins was acting as a registered lobbyist for Buchart Horn as
per a contract which began in 1990. One of the functions of Hawkins as a lobbyist for
Buchart Horn was to apprise his client of planned projects and opportunities to
establish relationships to create additional business opportunities. Hawkins was the
only registered lobbyist on retainer for Buchart Horn in Pennsylvania in 1992.
During the August, 1992 CCTA Board meeting, Hawkins raised a concern that
Buchart Horn was not being paid on time for the airport study. In addition, Hawkins
voted at CCTA Board meetings to approve various payments to Buchart Horn.
Hawkins, 97- 023 -C2
Page 11
Lastly, Hawkins failed to file an SFI for the calendar year 1995 but did so after
he received notice of this investigation.
Having summarized the above relevant facts, we must now determine whether
the actions of Hawkins violated the above quoted provisions of the Ethics Act.
As to Section 1 103(a) of the Ethics Act, it is clear that there was a use of
authority of office on the part of Hawkins. See, Juliante, Order 809. But for the fact
that Hawkins was a member of the Committee and CCTA, he could not have
participated in the process leading up to the selection of Buchart Horn for the airport
study contract. The private pecuniary benefit inured to Buchart Horn, a business client
of Hawkins. Hence, Hawkins violated Section 1103(a) when he used the authority of
office to obtain a private pecuniary benefit for Buchart Horn by participating in the
process leading up to the selection of that firm to conduct an airport study. See,
Schubenski, Order 1066.
As to Section 1 103(c) of the Ethics Act, we find no violation of this provision
which prohibits a public official /public employee from soliciting or accepting anything
of value based upon an understanding that the vote, official action, or judgment of the
public official /public employee would be influenced thereby. In this case there is no
evidence to establish any type of improper understanding. Accordingly, Hawkins did
not violate Section 1 103(c) regarding the selection of Buchart Horn to conduct an
airport study for CCTA, based upon an insufficiency of evidence.
Turning to Section 1103(f) of the Ethics Act, a contract was awarded by CCTA
to Buchart Horn. The contract exceeded the $500 threshold of Section 1103(f) of the
Ethics Act and was awarded through an open and public process. In addition, Buchart
Horn is not a business with which Hawkins is associated as that term is defined under
the Ethics Act. Hence, Hawkins did not violate Section 1103(f) of the Ethics Act as
to the award of a contract of $500 or more to Buchart Horn, because the firm is not
a business with which Hawkins is associated and because the contract was awarded
through an open and public process.
The last section of the allegation concerns the SFI for the calendar year 1995.
In that the Findings reflect that Hawkins has now filed the SFI and that the
Investigative Division is no longer prosecuting this aspect of the case, we believe that
this particular issue has been concluded.
The parties have submitted a Consent Agreement together with a Stipulation of
Findings wherein it is proposed to resolve the case by finding violations of Section
1103(a), no violations of Sections 1103(c) and 1103(f), and a payment of $6,000 by
Hawkins through this Commission to CCTA. Accordingly, Hawkins is directed to make
payment of $6,000 in a timely manner through this Commission to CCTA. Compliance
with the foregoing will result in the closing of this case with no further action.
Noncompliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. Hawkins, as a Board Member of the Cumberland County Transportation
Authority, was a public official subject to the provisions of Act 9 of 1989/Act
93 of 1998, 65 Pa.C.S.
2. Hawkins violated Section 1103(a) of the Ethics Act when he participated in the
process leading up to the selection of Buchart Horn, a firm with which he had
business relationship, as the contractor for an airport study for the Cumberland
County Transportation Authority.
Hawkins, 97- 023 -C2
Page 12
3. Hawkins did not violate Section 1103(c) of the Ethics Act as to the selection
of Buchart Horn to conduct an airport study based upon an insufficiency of
evidence.
4. Hawkins did not violate Section 1103(f) of the Ethics Act as to the contract of
CCTA to Buchart Horn to conduct an airport study in that the firm is not a
business with which Hawkins is associated and the contract was awarded
through an open and public process.
In Re: William Hawkins File Docket:. 97- 023 -C2
. Date Decided: 6/1/99
Date Mailed: 6/10/99
ORDER NO. 1124
1. Hawkins, as a Board Member of the Cumberland County Transportation
Authority (CCTA), violated Section 1103(a) of the Ethics Act when he
participated in the process leading up to the selection of Buchan Horn, a firm
with which he had business relationship, as the contractor for an airport study
for the Cumberland County Transportation Authority.
2. Hawkins did not violate Section 1103(c) of the Ethics Act as to the selection
of Buchart Horn to conduct an airport study based upon an insufficiency of
evidence.
3. Hawkins did not violate Section 1103(f) of the Ethics Act as to the contract of
CCTA to Buchart Horn to conduct an airport study in that the firm is not a
business with which Hawkins is associated and the contract was awarded
through an open and public process.
4. As per the consent agreement of the parties, Hawkins is directed to make
payment of $6,000 in a timely manner through this Commission to CCTA.
a. Compliance with the foregoing will result in the closing of this case
with no further action.
b. Noncompliance will result in the institution of an order enforcement
action.
BY THE COMMISSION,
aYmtuAu E etiAL
DANEEN E. REESE, CHAIR