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HomeMy WebLinkAbout84-004 MontgomeryBruce E. Montgomery 301 Edison Avenue New Castle, PA 16101 II. Factual Basis for Determination: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 OPINION OF THE COMMISSION February 24, 1984 84 -004 RE: Civil Engineer II, Financial Interests Statement, Advice No. 83 -616 Dear Mr. Montgomery: I. Issue: You ask the Commission to review the question of whether the Ethics Act applies to you as a Civil Engineer II and requires you to file a Financial Interest Statement as a "public employee" as Advice No. 83 -616 concluded. You currently serve as and are classified as a Civil Engineer II serving within the Pennsylvania Department of Transportation, hereinafter PennDot. Previous to this Commission's review of your question an Advice of Counsel No. 83 -616 had been issued in this case on November 23, 1983, and that Advice is incorporated herein by reference. That Advice concluded that you were a "public employee" within the meaning of the Ethics Act and, therefore, you were advised that you should be filing a Financial Interest Statement pursuant to the Ethics Act. That Advice relied primarily upon the job description of your duties as a Civil Engineer II as set forth in your official job description which is incorporated herein by reference. In addition, we have referred to and relied upon and incorporate herein by reference, the class specification relative to the position of Civil Engineer II. Your job description, as set forth in the Advice of Counsel and as repeated here for purposes of completeness, indicates that you initiate at least one feasibility study per month which includes producing the best available base plan sheets through the use of airial photographs, historical plans, and other survey and mapping data; the designing and drawing of alternate roadways on the base plan sheets according to acceptable standards; and determining preliminary cost estimates by competing quantities and cost of the materials for all alternatives designed. You also participate in the local coordination and planning and programming to a limited degree, as determined by a supervisor, and you are responsible for reviewing requests for federal authorizations which were submitted by in- house, consultant, and /or local designers. Bruce E. Montgomery February 24, 1984 Page 2 Additionally, class specification for a Civil Engineer II include as examples of work to be performed by such an individual the following: 1. participating in the collection, validation, analysis and projection of multi -modal transportation planning data including assisting in developing alternative transportation plans; 2. serving as a construction engineer for the less complex roadways, bridges, buildings, and other civil engineering projects undertaken by PennDot, including checking contractor's work for compliance with contract stipulations and specifications, assigning inspection of sections of projects to assistants, and making changes in design as indicated by on-site conditions; 3. performing preliminary highway location studies for less complex projects by determining probable line through the use of photographs, geological survey data, and field inspection and investigation information; and 4. reviewing highway design plans for less complex projects in order to insure proper and effective traffic control. Additionally, these class specifications in defining this type of position indicate that the work involves independently performing preliminary engineering studies, conducting location or foundation investigations, preparing plans and specifications and serving as a construction engineer on less complex projects or assisting a higher -level engineer on substantial portions of complex projects. Although the Office of Administration, PennDot and the Advice of Counsel have previously determined that you should be considered a "public employee ", you argue that as a Civil Engineer II you do not fall within the definition of "public employee." Specifically, you indicate that your work, in your estimation, is performed in a prescribed manner in obedience with the mandate of legal authority. You basically state that you simply check for comformity of the designer's form to the mandates issued by the Deputy Secretary for Highway Administration within PennDot. You state that if a form is completed satisfactorily, your immediate supervisor will review it, initial it, and signify that he is in agreement with its conformity to PennDot regulations. You state that in this process, you have no authority to take or recommend official action with respect to any of the categories, particularly category (4) or (5) as set forth in the definition of "public employee" in the Ethics Act. Bruce E. Montgomery February 24, 1984 Page 3 III. Applicable Law: The law to be applied to this question is as follows: Section 2. Definitions.. "Public employee." Any individual employed by the Commonwealth or a political subdivision who is responsible for taking or recommending official action of a nonmi ni steri al nature with regard to: (1) contracting or procurement; (2) administering or monitoring grants or subsidies; (3) planning or zoning; (4) inspecting, licensing, regulating or auditing any person; or (5) any other activity where the official action has an economic impact of greater than a de minimus nature on the interests of any person. "Public employee" shall not include individuals who are employed by the State or any political subdivision thereof in teaching as distinguished from administrative duties. 65 P.S. 402. State Ethics Commission regulations further state: Public employee - -- (i) The term includes any individual: (A) who is employed by the Commonwealth or a political subdivision and who is responsible for taking or recommending official action of a nonministerial nature with regard to: I) contracting or procurement; II) administering or monitoring grants or subsidies; (III) planning or zoning; (IV) inspecting, licensing, regulating, or auditing any person; or (V) any other activity where the official action has greater than a de minimis economic impact; and Bruce E. Montgomery February 24, 1984 Page 4 (8) who meets the criteria of either subclause (I) or (II) of this clause: (I) The individual is: ( -a -) a person who normally performs his responsibility in the field without on -site supervision; ( -b -) the immediate supervisor of a person who normally performs his responsibility in the field without on -site supervision; or ( -c -) the supervisor of any highest level field office. (II) The individual is a person: ( -a -) who: ( -1 -) has the authority to make final decisions; ( -2 -) has the authority to forward or stop recommendations from being sent to the person or body with the authority to make final decisions; ( -3 -) prepares or supervises the preparation of final recommendations; or ( -4 -) makes the final technical recommendations; and ( -b -) whose recommendations or actions: ( -1 -) are an inherent and recurring part of his position; and ( -2 -) affect organizations other than his own organization. (ii) The term does not include individuals who are employed by the Commonwealth or a political subdivision of the Commonwealth in teaching as distinguished from administrative duties. (iii) Persons in the positions listed below are generally considered public employees. (A) Executive and special directors or assistants reporting directly to the agency head or governing body. (8) Commonwealth bureau directors, division chiefs, or heads of equivalent organization elements; and other governmental body department heads. Bruce E. Montgomery February 24, 1984 Page 5 (C) Staff attorneys engaged in representing the department, agency, or other governmental bodies before the public. (D) Solicitors, engineers, managers, secretary- treasurers acting as managers, police chiefs, chief clerks, chief purchasing agents, grant and contract managers, housing and building inspectors, sewer enforcement officers, and zoning officers in all governmental bodies. (E) Court administrators, assistants for fiscal affairs, and deputies for the minor judiciary. (F) School business managers and principals. (iv) Persons in the positions listed below are generally not considered public employees. (A) City clerks, other clerical staff, road masters, secretaries, police officers, welfare case workers, maintenance workers, construction workers, detectives, equipment operators, and recreation directors. (8) Law clerks, court criers, court reporters, probation officers, security guards, and writ servers. (C) School teachers and clerks of the schools. 51 Pa. Code 1.1. IV. Discussion: The question to be addressed by this Commission is simply stated as follows: Is a Civil Engineer II in your position to be considered a "public employee" as defined in the Ethics Act and, therefore, required to file a Financial Interest Statement under the Ethics Act. This question must be reviewed and answered in relation to the Ethics Act, its purpose, and of course, the Commission's regulations on this point. This question must be reviewed and answered in light of your own duties and obligations as those duties are ennunciated in the class specification applicable to the position of a Civil Engineer II and your own individual job description which is derrived therefrom. This inquiry must focus on the job description itself and not upon the individual incumbent in the position, the variable functions, or the manner in which a particular individual occupying a position may carry out those functions. See Phillips v. State Ethics Commission, No. 1574 C.D. 1982, Opinion filed January 11, 1984, Pa. Cmwlth. In the Phillips case. the Court acknowledged and accepted the Commission s use of an objective test in deciding whether persons in particular positions are to be considered "public employees" or not. Additionally, in this case, the Court concluded that: Bruce E. Montgomery February 24, 1984 Page 6 The Ethics Act, being remedial legislation, is to be liberally construed. See, Kremer v. State Ethics Commission, 56 Pa. Cmwlth. Ct. 160, 424 A.2d 968 (1981). Thus, coverage under the Act should be broadly, rather than narrowly, determined; conversely, exclusions under the Act should be narrowly, rather than broadly, - determined. Phillips, slip opinion, page 4. With these thoughts in mind, we undertake a review of the Advice of Counsel, the classification specification for your position, your individual job description and other available data, including your arguments as set forth above. Reviewing all these facts in an objective manner and given the liberal construction to be ascribed to the Ethics Act and the Court's admonition that exclusions under the Act should be narrowly, rather than broadly, construed, we must conclude that you are a "public employee" subject to the filing requirements of the Ethics Act. Specifically, even though you assert, as did the Petitioner in the Phillips case, that your responsibilities are performed largely in response to regulations and legal mandates, the class specification for this position and your job description indicate a degree of independence in performing engineering studies and conducting location investigations that are not necessarily limited to or mandated by regulations or requirements so as to preclude your exercise of independent judgment and authority. In the performance of any such study, your evaluation and reporting process must, of necessity, entail the exercise of judgment which produces a recommendation regarding the degree to which a particular designers' forms or proposals are in conformity with the mandates. With respect to your service as a construction engineer on less complex projects, we must conclude that you have responsibility to take or recommend action with respect to these projects. It was argued in Phillips, as here, that because work which you performed is reviewed by several, perhaps many, levels of supervisors, there should be an automatic or other exclusion of your position from the definition of "public employee." See the Commission's opinion in Phillips, 82 -006. However, here, as in Phillips, the mere fact that other persons review your recommendations and 'nave fne final authority to act upon those recommendations does not alter our conclusion that you are within the classification of "public employee" as defined in the Ethics Act. V. Conclusion: Upon consideration of all the evidence submitted and referred to herein we will affirm Advice No. 83 -616 and issue this Opinion holding that for the reasons enunciated above, you should be considered a "public employee" subject to the Ethics Act and as such you must file Financial Interests Statement under the Ethics Act. This statement must be filed within thirty (30) days of this Opinion. Bruce E. Montgomery February 24, 1984 Page 7 Pursuant to Section 7(9)(i), this opinion is a complete defense in any enforcement proceeding initiated by the Commission, and evidence of good faith conduct in any civil or criminal proceeding, providing the requestor has disclosed truthfully all the material facts and committed the acts complained of in reliance of the advice given. This letter is a public record and will be made available as such. Finally, any person may request within 15 days of service of the opinion that the Commission reconsider its opinion. The person requesting reconside- ration should present a detailed explanation setting forth the reasons why the opinion requires reconsideration. SSC /rdp Enclosure By the Commission,