HomeMy WebLinkAbout729 AnkeyRe: 88 -031 -C
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF TICE COMMISSION
Order No. 729
Before: Helena G. Hughes, Chair
Robert W. Brown, Vice Chair
G. Sieber Pancoast
Dennis C. Harrington
James M. Howley
Date Decided: October 26, 1989
Date Mailed: November 1989
Mr. Edward W. Ankney
R.D. #1, Box 316D
Derry, PA 15627
Dear Mr. Ankney:
The State Ethics Commission received a complaint regarding you
and a possible violation of the State Ethics Act, No. 170 of 1978, 65
P.S. 401 et. seq. You were notified in writing as to the
commencement of the investigation and as to the specific
allegation(s). The investigation has now been completed and a
Findings Report was issued to you which constituted the Complaint by
the Investigation Division of the State Ethics Commission. An Answer
was filed and a hearing was deemed waived. The record is now
completed. This Order of the Commission is hereby issued which sets
forth the individual allegations, findings, discussion and conclusion
as follows:
I. Allegation: That you, Supervisor for Derry Township,
Westmoreland County, violated the following provisions of the Ethics
Act (Act 170 of 1978), when you participated in a decision to
authorize the township road crew to excavate your property to provide
fill for a township bridge project without an open and public process:
Section 3. Restricted Activities.
(a) No public official or public employee
shall use his public office or any confidential
information received through his holding public
office to obtain financial gain other than
compensation provided by law for himself, a member
of his immediate family, or a business with which
he is associated. 65 P.S. S403(a).
Mr. Edward W. Ankney
Page 2
(c) No public official or public employee or
a member of his immediate family or any business
in which the person or a member of the person's
immediate family is a director, officer, owner or
holder of stock exceeding 5% of the equity at fair
market value of the business shall enter into any
contract valued at $500 or more with a
governmental body 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. Any contract made in violation
of this subsection shall be voidable by a court of
competent jurisdiction if the suit is commenced
within 90 days of making of the contract. 65 P.S.
5403(c).
A. Findings:
1. You served as a Derry Township Supervisor for at least the past
twelve years.
a. You have also served as township roadmaster during this
time.
(1) You have been employed in this position for almost
twelve years.
2. In 1986, the Derry Township Supervisors were considering a
community development project which included replacing the Gray
Station Bridge.
3. Minutes of the Derry Township Supervisors disclosed the following
in regards to actions taken in regard to the Gray Station Bridge
Project:
a. June 4, 1986: Motion Razza, seconded by Ankney to hire Art
Romel to survey the right -of -ways of the Lee Valley Road and
the Gray Station Bridge to determine where the right -of -ways
are located. Motion carried unanimously.
b. Motion Razza, seconded by Ankney to accept the following
allocation of funds and agree to the terms of the "Letter of
Understanding" with the Westmoreland County Planning
Department for Community Development Funds:
Bridge replacement (Gray Station) $191,000, Demolition and
site clearance (4 properties), contract amount plus
advertisement.
Mir. Edward W. Ankney
Page 3
Motion carried unanimously.
c. August 19, 1987: Special Meeting. Bids for the Gray
Station Bridge Replacement Project were received, sealed,
appended and read. Bids were received as follows:
Cilenti Construction Co.
John Gulisek Construction Co.
Independent Enterprises, Inc.
D.W. Miller, Inc.
Sciullo & Company
Anthony Tedesco Construction Co.
Upon This Rock Construction
Vicra Construction Co.
George Danko, Inc.
$326,970.57
$283,011.00
$278,580.00
$327,557.55
$295,779.08
$296,858.45
$386,972.00
$257,260.00
$265,995.79
Motion made by Ankney, seconded by Razza to accept the above
bids for study. Motion carried unanimously with all three
supervisors voting.
d. September 16, 1987: Special meeting.
Motion made by Ankney, seconded by Razza to award a contract
to Vicra Construction for the construction of the Gray
Station Bridge Replacement project at a cost of $174,179.00.
Motion carried unanimously with all supervisors voting.
Meeting recessed until September 30, 1987.
e. September 30, 1987: Motion made by Ankney, seconded by
Razza to approve the land appraisal report prepared by
Samuel J. Beatty for the purchase of land from the Urcheks
at a price of $1,100 relative to the Gray Station Bridge
Project. Motion carried unanimously, all supervisors
voting.
Motion made by Ankney, seconded by Razza to advertise bids
for road construction materials relative to the Gray Station
Bridge Project. Motion carried unanimously, all supervisors
voting.
4. Bid tabulation sheets for the Gray Station Bridge Project disclose
that bids were submitted reflecting bids for bridge construction, the
related road work and a total bid.
a. Vicra Construction Company Incorporated, the low bidder, bid
as follows:
Mr. Edward W. Ankney
Page 4
Bridge Construction: $174,179.00
Related roadwork $ 83,081.00
Total: $257,260.00
b. Bid Tabulations disclose that Vicra Construction was the law
bidder for the bridge construction phase of the project.
5. Township records confirm that no contract was awarded for the road
paving work related to the bridge construction.
6. Steven Kozar, a Derry Township Supervisor since 1986, provided the
following information in regards to the instant situation:
a. In 1986, the township received approximately $190,000 in
Community Development funds from the County for repairing
the Gray Station bridge.
b. The township advertised for bids for the project. Bids were
received estimating costs for bridge replacement, related
road work and total cost.
c. Due to the high cost of bridge replacement, the bids were
awarded for only the bridge construction. The bid was
awarded to VICRA Construction Company.
d. The Community Development funds were used for the bridge
construction while General fund monies were used to
construct the roadway.
e. The supervisors considered putting bids out for the road
material but did not once they were informed by the county
that they would have to re -bid the entire project. The
supervisors subsequently decided to do the paving part of
the project with township employees and equipment and
material obtained from yearly bids. The supervisors felt
that the township employees could do the roadwork for less
than the contractors.
f. Fill material was needed for the access road to and around
the bridge. Supervisor Aldo Razza attempted to get fill
dirt from several residents living near the bridge but they
wanted a price for the fill.
g. The coal yard at the bridge site originally agreed that the
township could take the fill needed from its supplies, but
later the company said the township would be taking too much
fill and stopped the township from taking any more.
Mr. Edward W. Ankney
Page 5
h. Ed Ankney informed them that they had this bank in back of
his home that the township could use at no cost to obtain
fill material. When the time came to get the fill, they
decided to go to Ankney for it.
i. No additional equipment was needed to get the fill. They
used the township loader, V -6 dozer and trucks. The fill
was easy to obtain in that it was loose fill and around the
hill on Ankney's property. The fill obtained was a shale
material.
. He was not aware that fill material could have been obtained
from Derry Lake. The township often went down to the lake
for fill, a truckload at a time. With the amount of fill
needed for the road project, he did not think that much fill
would be available. In addition, the Ankney property was
much closer to the bridge site, and the Ankney shale fill
would be more suitable than the sand from the lake.
k. The supervisors never added up any figures about purchasing
fill and having it delivered to the site instead of using
township employees.
1. Vicra Construction Company did the bridge work and put the
asphalt on the bridge. The township, using township
equipment and materials, did the remainder of the paving.
m. There was no pressure put on him to agree to get the fill
material from Ankney.
j
7. Aldo Razza, a Derry Township Supervisor from 1981 through 1987,
advised as follows:
a. In 1986, the township received some Community Development
Funds from Westmoreland County to replace the Gray Station
Bridge.
b. The supervisors put out bids for the project. The bids were
submitted in the form of bridge cost, paving -road cost and
total cost.
c. The bids for paving and related road work were all in the
neighborhood of $80,000. The supervisors thought this was
very high and felt that the township road crew could do the
paving cheaper.
d. A contract was awarded for the bridge but the supervisors
decided to do the road work.
Mr. Edward W. Ankney
Page 6
e. The township road crew and materials were used but he could
not recall the total cost to the township. He believes it
was much cheaper than the $80,000 bid prices.
f. A considerable amount of fill material was needed for the
access ramp to the bridge.
He contacted a number of people located near the bridge for
fill. A red dog yard near the bridge site initially said
the township could have some fill. After about one -half day
of hauling, the owner of red dog would not permit any more
hauling. He recalled that either landowner wanted paid or
thought the township was taking too much fill.
h. Ankney had a shale hillside on his property and volunteered
the shale for use as fill.
i. The shale was ideal fill material, better than the red dog
that was being used. The shale was easy to get at and load.
It was also very near the bridge site.
He did not want to get the fill from Ankney because of
potential problems, but fill was needed and Ankney offered
the fill at no cost to the township. He did not see how
Ankney could have profited.
k. He was not aware that fill material was available at Derry
Lake for the road project. The township previously obtained
fill from Derry Lake but that fill was more sandy and silt
and not suitable for the road project. The fill material
from Ankney's was probably better fill, and Ankney's
property was at least four miles closer to the bridge site.
1. There were no ulterior motives in getting the fill from
Ankney. He does not believe that Ankney profited.
8. You provided the following information regarding the instant
situation:
a. You have served as a Derry Township Supervisor for the past
twelve years. You have been a full -time employee since
1978.
j
b. When the contract for the bridge was prepared, the
supervisors agreed that the contractor would do the bridge
work and township employees would build the approaches to
the bridge. The supervisors believed that the township
would save a considerable amount of money by proceeding in
that manner.
Mr. Edward W. Ankney
Page 7
c. The bridge project was to be financed from a grant to the
township from Community Development funds administered by
the County.
d. Originally, the township was to obtain the necessary fill
for the approaches from a contractor who had property
located near the bridge. This agreement was reached with
contractor, a Mr. Keppel and Supervisor Razza. Keppel had
both red dog and fill dirt.
e. The contractor who was doing the bridge work was later told
by Keppel that the amount of fill needed was more than
Keppel wanted to donate. The township then had to look
elsewhere for fill.
f. You then volunteered fill from a bank located at the rear of
your residence. You permitted neighbors to take dirt from
the same area at no charge and you were not going to charge
the township. The township engineer saw the fill and said
that it was good material to use for the approaches to the
bridge.
Township road workers hauled the fill from your property for
six or seven work days. You had no estimate of the amount
of fill removed from your property.
h. You had no idea what the fill would be worth if the township
purchased it from you. You only gave the dirt to the
township to save the township money.
i. If you hadn't made the fill available to the township, the
township would have had to advertise for fill, pay for it,
and most likely truck from a distance farther away than
your property. By using the fill you donated and township
employees, the project was completed at virtually no cost to
the township.
The Derry Water Authority denied the township fill from
Derry Lake in the amount needed for the bridge project. The
township did get a truck load of fill, now and then, from
Derry Lake but never in the quantities needed for the bridge
project. You were told that DER only allows so much dirt to
be taken from Derry Lake each year.
k. The removal of dirt from your property did nothing to
enhance its value. You did build two garages on the
property near the spot from where the fill was taken. The
g.
j
Mr. Edward W. Ankney
Page 8
garages would have been built in any event because they were
built on property not effected by the removal of the fill
material.
1. You did not profit as a result of donating the fill to the
township.
m. You were motivated as a public servant to save the township
money by using fill from your farm property. You donated
the fill without profit to yourself. Your actions have been
misunderstood and misinterpreted.
B. Discussion:
As a supervisor in Derry Township, you are a public official as
that term is defined under the Ethics Act. 65 P.S. 402; 51 Pa. Code
S1.1. As such, your conduct is subject to the provisions of the
Ethics Act and the restrictions therein are applicable to you.
Initially, we note that since the activities in this case
occurred prior to Act 9 of 1989, Act 170 of 1978 will be applied in
determining whether your activities violated Section 3(a) and 3(c) of
the Ethics Act quoted above.
Under Section 3(a) quoted above, this Commission has determined
that use of office by a public official to obtain a financial gain for
himself or a member of his immediate family or a business with which
he is associated which is not provided for in law transgresses the
above provision of law. Thus, use of office by a public official to
obtain a financial gain which is not authorized as part of his
compensation is prohibited by Section 3(a): Hoak / McCutcheon, Orders
No. 128, 129, affirmed McCutcheon v. State Ethics Commission, 77 Pa.
Commw. Ct. 529, A.2d (1983); Yacobet, Order No. 412 -R,
affirmed Yacobet v. State Ethics Commission, Pa. Commw. Ct. ,
531 A.2d 536 (1987). Similarly, Section 3(a) of the Ethics Act would
prohibit a public official /employee from using public office to
advance his own interests; Koslow, Order 458 -R, affirmed Koslow v.
State Ethics Commission, Pa. Commw. Ct. , 540 A.2d 1374 (1988).
Likewise, a public official /employee may not use the status or
position of public office for his own personal advantage; Huff,
Opinion 84 -015.
As to Section 3(c) of the Ethics Act, it specifically provides
that no public official or member of his immediate family or business
in which the person or member of his immediate family is an officer,
director, or owner of greater than five percent of the equity at fair
market value of a contract in excess of five hundred dollars may
contract with his governmental body unless the contract has been
awarded through an open and public process.
Mr. Edward W. Ankney
Page 9
In the instant matter, Derry Township was considering a community
development project of replacing the Grace Station Bridge. The
contract was put out for bids and awarded to Vicra Construction
Company. However, the Board of Supervisors determined that the paving
aspect of the project could be done by township employees for a lesser
amount than bid by the contractors. Additionally, certain fill
material was needed for road access to the bridge and several
residents in the area were contacted regarding a price for fill. The
coal yard originally agreed to supply the fill but later advised the
township that it would not supply any further fill. Other individuals
who were also contacted wanted a high price for fill. At that time
you offered to supply fill from your property at no cost to the
township.
The specific question before us is whether your actions of
supplying fill at no cost of the township violated Sections 3(a) and
3(c) of the Ethics Act. Under these facts and circumstances we find
that you neither violated Section 3(a) or 3(c) of the Ethics Act
because you did not receive any financial gain or consideration for
supplying the fill to the township. In particular, there is no
Section 3(a) violation because you did not obtain a financial gain in
this case. Similarly, there is no Section 3(c) violation because
Section 3(c) has application only to contracts of $500 or more; in
this case, there was no consideration for this contract.
C. Conclusion:
1. As a Derry township supervisor you are a public official
subject to the provision of the Ethics Act.
2. You did not violate Sections 3(a) and 3(c) �f the Ethics Act
when you supplied fill to the township at no cost for an
access road for the Gray Station Bridge Project.
This Order is final and will be made available as a public
document fifteen days after issuance. However, you may request
reconsideration which will defer public release of this Order pending
action on your request by the Commission. A request for
reconsideration, however, does not affect the finality of this Order.
A reconsideration request must be received at this Commission within
fifteen days of issuance and must include a detailed explanation of
your reasons as to why reconsideration should be granted in conformity
with 51 Pa. Code 52.38.
The files in this case will remain confidential in accordance
with Section 8(a) of the Ethics Act, 65 P.S. 408(a) during the fifteen
day period and no one, including yourself, unless the right to
challenge this Order is waived, may violate confidentiality by
Hr. Edward W. Ankney
Page 10
releasing, discussing or circulating this Order. However,
confidentiality does not preclude you from discussing this case with
your attorney at law.
Any person who violates confidentiality of a Commission
proceeding is guilty of a misdemeanor and shall be fined not more
than $1,000 or imprisoned for not more than one year or both, 65 P.S.
409(e).
By t e Commissio ,
elena G. Hughes
Chair