HomeMy WebLinkAbout92-552Ms. Elizabeth A. Buehl
Wood Lane
Langhorne, PA 19047
STATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 1 71 08 -1 470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
March 4, 1992
92 -552
Re: Conflict, Grant Program, Participation by Public
Official /Employee, Airport Authority Member, Owner and
Operator of Private Airport.
Dear Ms. Buehl:
This responds to your letter of February 1, 1992, in which
you requested advice from the State Ethics Commission.
Issue: Whether a member of an airport authority under the Public
Official and Employee Ethics Law may participate in grant
programs administered by the state and federal government where
the airports which the member oversees as an authority member
also apply for such funding.
Facts: As a Member of the Central Bucks County Airport Authority
which oversees the management of the Quakertown and Doylestown
Airports, and as the joint owner and operator (with your husband)
of Buehl Airport located 48 nautical miles from the above two
airports, you seek the advice of the State Ethics Commission.
The Quakertown and Doylestown Airports are part of the state
and federal reliever system and therefore are able to receive
funds from these sources to improve their airport facilities so
that they will be safe and standardized in the specifications
outlined by the state and federal government. As a privately
owned public use airport, Buehl Airport is also a state reliever
and is eventually planning to become a federal reliever airport.
You state that the selection of airports for state and
federal funding is in part determined by the state and federal
government's determination of their need to improve their safety
for retaining their airport licensing, their ability to continue
and progress as an airport, and their appropriateness of request
suited to the program priorities selected during a specific year.
You also state that generally, publicly owned airports that are
public use are preferable for funding because of their ability to
move forward financially as an airport.
Ms. Elizabeth A. Buehl
March 4, 1992
Page 2
Based upon the above circumstances, you ask whether you
would have a conflict of interest. You point out that all
eligibility forms are completed by the Airport Authority's
administrative secretaries, and that final inspections are
completed by Federal Aviation Administration Inspectors or by
State Aviation Inspectors, whichever would be applicable for the
given situation. You have submitted two photocopied pages
consisting of the criteria which both the state and federal
government use in their selection of airports for funding, which
documents are incorporated herein by reference.
Discussion: As a Member of the Central Bucks County Airport
Authority, you are a "public official" as that term is defined in
the Ethics Law and hence you are subject to the provisions of
that Law. 65 P.S. §402; 51 Pa. Code S1.1.
Sections 3(a), 3(f), and 3(j) of the Ethics Law provide:
Section 3. Restricted Activities.
(a) No public official or public
employee shall engage in conduct that
constitutes a conflict of interest.
(f) 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 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 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
Ms. Elizabeth A. Kuehl
March 4, 1992
Page 3
commenced within 90 days of the making of the
contract or subcontract.
(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 ' 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.
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 or 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 respofise to the question
presented.
The following terms are defined in the Ethics Law:
Ms. Elizabeth A. Buehl
March 4, 1992
Page 4
Section 2. 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.
"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.
"Authority of office or employment."
The actual power provided by law, the
exercise of which is necessary to the
performance of duties and responsibilities
unique to a particular public office or
position of public employment.
"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.
"Immediate family." A parent, spouse,
child, brother or sister.
"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.
Ms. Elizabeth A. Buehl
March 4, 1992
Page 5
Under the Ethics Law, we must observe the stated purpose of
that Act which is to strengthen the faith and confidence of
people in their government by assuring the public that the
financial interests of the holders of or candidates for public
office do not present a conflict with the public trust.
In applying the above quoted provisions of the Ethics Law to
the instant matter, we will first consider the provisions of
Section 3(f) of the Ethics Law. Since the Central Bucks County
Airport Authority is the governmental body with which you are
associated, Section 3(f) would not apply in this case because the
contract(s) for Buehl Airport would be with the Commonwealth of
Pennsylvania and potentially the federal government, neither of
which would be the governmental' body with which you are
associated.
We will now address the propriety of the proposed conduct
under Section 3(a) of the Ethics Law. In this review, we note
and recognize the concern that arises where a public program,
funded with public monies and administered through a public
agency-, political subdivision, or governmental body is also
available to public officials or employees of that agency or
governmental body. We recognize the public concern and
criticism that may arise if a public official or public employee
who serves a- governmental body receives benefits under a program
of this nature.
It is clear that the Ethics Law, and =in particular Section
3(a), was primarily designed to restrict the activity of a public
official or employee from using the authority of office for
private pecuniary benefit. Similarly, the Commission has held
that a public official /public employee may not use his office to
the detriment of those competing for such funding or
participation in a program. Pepper, Opinion 87 -008. However, we
believe that as a general rule the - Ethics Law was not enacted nor
should it be interpreted to preclude public officials or
employees from participating in programs which might otherwise be
available to them as citizens. Wolff, Opinion 89 -030; Woodrinq,
90 -001
In order to insure that a public official or employee is not
in a conflict when he seeks to participate in a rehabilitation or
grant program, he must observe the following:
1. play no role in establishing the criteria under which the
program is to operate, particularly with reference to the
structure or administration of the program;
Ms. Elizabeth A. Buehl
March 4, 1992
Page 6
. play no role in establishing or implementing the criteria by
which selections for program participation are to be made;
3. play no - role in the process of selecting and reviewing
applicants or in awarding grants or funds;
4. use no confidential information acquired_ during the holding
of public office or public employment to apply for or to
obtain such funds, grants, etc., and
5. abstain, publicly disclose and file a memorandum with the
person responsible for recording the minutes under Section
3 (j) of the Ethics Law in cases where the public official/
employee is associated with administering the grant or
rehabilitation program not only as to his own application
but as to similarly situated individuals with whom the
:public official /employee might be competing for available
funds. In cases where Section 3(f) is applicable, the
public official /employee would be prohibited from any
supervisory or overall responsibility as to the contract or
program.
Through application of the above criteria, we seek to
eliminate the possibility that a public official /employee who is
seeking such funds or seeking to participate in these programs
would be in a position to insure that the grant funds or the
program benefits would be available for his own benefit. Thus, a
public official or public employee . in such a situation should
refrain from participating in making decisions or recommendations
about the program and regarding distribution of the limited funds
which might be available as a result of such a program.
Thus, in your capacity as a member of the Central Bucks
County Airport Authority, you would have a conflict of interest
as to any matters before the Authority involving such state and
federal funding for which Buehl Aiport competes.
Pursuant to Section 3(j), in each instance of a conflict of
interest, you would be required to abstain from any participation
of any nature whatsoever, and to publicly disclose your
abstention - and the reasons for -same, both orally and by filing a
written memorandum with the secretary recording the minutes.
Expressly conditioned upon the assumption that your proposed
conduct would be in conformance with the above criteria, you may
apply for and participate in the benefits associated with the
state and federal reliever system, including funding from these
sources. -
Ms. Elizabeth A. Buehl
March 4, 1992
Page 7
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 haw; Specifically
not addressed herein is the applicability of the Code of Federal
Regulations, the Municipality Authorities Act, or the respective
municipal code.
Conclusion: As a Member of the Central Bucks County Airport
Authority, you are a public official subject_to the provisions
of the .Ethics Law. Section 3(a) of the Ethics Law would - not
preclude you from applying on behalf of Buehl .Airport for a. State
or federal grant as a participant in the state and /or federal
reliever system provided you- played no role in establishing-the
criteria under which the program would operate, played no role in
implementing the criteria for selecting applicants,: layed`mo
role in selecting or reviewing applicants, . used •no con €identiai
information and finally had no involvement with `: the
administration of the program. You would have a conf l.,i.ct of
interest as to any matter before the Central Bucks. • Countyy_ Airport
Authority involving such state and /or federal funding for which
Buehl Airport competes. In each instance of a. "conflict . io'f
interest, you must abstain from any participation of ;*ny
whatsoever and you must observe the disclosure requirements of
Section 3(j) set forth above. You may not use the authority, pf
office to the detriment of competitors for _such 7-funding,
including the Quakertown and Doylestown Airports "presently
subject to oversight by the Central Bucks County Airport
Authority. Lastly, the propriety of the proposed conduct has
only been addressed under the Ethics Law.
Pursuant to Section 7(11), this Advice is a.compl 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.
This letter is a public record and will be made available as
such.
Final
reason to
Commission
Commission
Commission
- " 1
ly, if you disagree with this Advice -or if you have any
challenge same, you may request that :the full
review this Advice. A personal, appearance before the
will be scheduled and a formal Opinion from the
will be issued. Any such appeal must be in writing
Ms-.- Elizabeth A. Buehl
Mph 4, 1992
Page 8
and idust be received at the Commission, within 15 days of the date
of this Advice pursuant to 51 Pa. Code §2.12.
S4ncerely,
Vincent 7. . Dopko
Chief Counsel