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HomeMy WebLinkAbout80-034 HemsleyMr. William T. Hemsley President Nassaux - Hemsley, Inc. NHI Building 56 North Second Street Chambersburg, PA 17201 Dear Mr. Hemsley: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 August 20, 1980 OPINION OF THE COMMISSION 80 -034 In your letter of May 8, 1980, you requested an Opinion from the State Ethics Commission concerning whether consistent with Act 170 employees of your engineering firm..could perform sewage enforcement services for a township concerning the suitability of on -site disposal of a subdivision and whether your firm could subsequently accept employment from the de- veloper to perform design services for. the subdivision. You explained that your firm is not presently employed as Township Engineer for the Township in question. You further requested an Opinion from the Commission relative to whether an employee of an engineering firm that provides sewage enforcement services at a subdivision could purchase a lot in the subdivision. Act 170 applies to "public officials" and "public employees" of the Commonwealth and political subdivisions thereof. The Commission is charged with liberally construing the Act to assure that public officials and employees "present neither a conflict nor the appearance of a conflict with the public trust." It is the Commission's opinion that where an engineering firm provides sewage enforcement services to a township on an infrequent and limited basis, Act 170 does not prohibit the firm from subsequently accepting employment from a developer within the township. If the engineering firm has provided professional services to a developer relative to sewage disposal, Act 170 would prohibit the engineering firm from performing enforcement services for a township with respect to that development. If an engineering firm provides sewage enforcement services to a township on a regular and continuing basis, a prohibited conflict of interest would arise if the engineering firm would (1) accept employment from a developer which would require the firm to inspect and approve its own work, or (2) inspect or advise the James D. Flower, Esquire August 20, 1980 Page 3 Pennsylvania, Inc. #80 -016. There the entity involved was simply a collection agency under contract with various political subdivisions. The Bureau in #80 -016 had no discretionary duties or authority and was not created pursuant to any statutory power. It was merely a private collection organization. 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 other 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. PJS /jc cc: Martha Bryer / re,G,"1 . PAUL J . KITH Chairmari