HomeMy WebLinkAbout24-562 BonacciPHONE: 717-783-1610
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To the Requester:
Jeffery J. Bonacci
Dear Mr. Bonacci:
STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
ADVICE OF COUNSEL
September 13, 2024
FACSIMILE: 717-787-0806
WEBSITE: www.ethics.ya.�4ov
24-562
This responds to your letter dated August 12, 2024, by which you requested an advisory
from the Pennsylvania State Ethics Commission ("Commission"), seeking guidance as to the issue
presented below:
Issue:
Whether the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et
sec would impose restrictions upon you with regard to performing work for an
engineering firm following termination of your employment as a Transportation
Construction Manager 2 with the Pennsylvania Department of Transportation
("PennDOT").
Brief Answer: YES. During the first year following termination of your employment with
PennDOT, Section 1103(g) of the Ethics Act would apply and restrict you from engaging
in any activity that would involve "representing" a "person" including but not limited
to a new employer such as an engineering firm before your "former governmental
body," PennDOT.
Facts:
You request an advisory from the Commission based upon submitted facts that may be
fairly summarized as follows.
You are currently employed as a Transportation Construction Manager 2 with PennDOT
in the Construction Division within Engineering District 4-0. You have submitted a copy of the
job classification specifications for the position of Transportation Construction Manager 2 (job
code 10650), which document is incorporated herein by reference.
Bonacci, 24-562
September 13, 2024
Page 2
For the last six years in your position with PennDOT, you have served as a Project
Manager. Your work has included managing staff from two consultant firms that perform field
inspections of construction projects. You have also been involved in project status meetings and
other project plan support activities with the designer of your last two construction projects.
You are considering retiring from your Commonwealth employment in the near future and
seeking employment with an engineering firm that does business with PennDOT and other
governmental bodies such as the Pennsylvania Turnpike Commission, the U.S. Department of
Defense, the Virginia Department of Transportation and other states' Departments of
Transportation, school districts, and other organizations and entities. The duties of your new
position with an engineering firm would include reviewing potential employees, training
employees to perform field inspections for construction work for governmental bodies, developing
submissions for Mentor Prot6g6 and SBA Programs to appropriate organizations, and performing
design -build contract work. You state that per PennDOT Publication 442, Specifications for
Consultant Agreements for Project Development Services, Section 2.5, you will not be employed
by any consultant on any PennDOT Agreement during the first year after you retire from
PennDOT. You further state that you will not be employed in any capacity by any firm that you
performed work with during your career with PennDOT.
You seek guidance as to whether the Ethics Act would impose prohibitions or restrictions
upon you with regard to working for an engineering firm that does business with PennDOT and
other governmental bodies, organizations, and entities following termination of your employment
with PennDOT.
Discussion:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of the Ethics Act, 65
Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester based upon the facts that the
requester has submitted. In issuing the advisory based upon the facts that the requester has
submitted, the Commission does not engage in an independent investigation of the facts, nor does
it speculate as to facts that have not been submitted. It is the burden of the requester to truthfully
disclose all of the material facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory
only affords a defense to the extent the requester has truthfully disclosed all of the material facts.
The post -employment restrictions of Section 1103(g) of the Ethics Act apply to former
public officials/public employees. While Section 1103(g) does not prohibit a former public
official/public employee from accepting a position of employment, it does restrict the former
public official/public employee with regard to "representing" a "person" before "the governmental
body with which he has been associated":
§ 1103. Restricted activities
(g) Former official or employee. --No former public
official or public employee shall represent a person, with promised
or actual compensation, on any matter before the governmental body
with which he has been associated for one year after he leaves that
body.
Bonacci, 24-562
September 13, 2024
Page 3
65 Pa.C.S. § 1103(g) (Emphasis added).
The terms "represent," "person," and "governmental body with which a public official or
public employee is or has been associated" are specifically defined in the Ethics Act as follows:
§ 1102. Definitions
"Represent." To act on behalf of any other person in any
activity which includes, but is not limited to, the following: personal
appearances, negotiations, lobbying and submitting bid or contract
proposals which are signed by or contain the name of a former
public official or public employee.
"Person." A business, governmental body, individual,
corporation, union, association, firm, partnership, committee, club
or other organization or group of persons.
"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.
65 Pa.C.S. § 1102.
The term "person" is very broadly defined. It includes, inter alia, corporations and other
businesses. It also includes the former public official/public employee himself, Confidential
Opinion, 93-005, as well as a new governmental employer. Ledebur, Opinion 95-007.
The term "represent" is also broadly defined to prohibit acting on behalf of any person in
y activity. Examples of prohibited representation include: (1) personal appearances before the
former governmental body or bodies; (2) attempts to influence; (3) submission of bid or contract
proposals which are signed by or contain the name of the former public official/public employee;
(4) participating in any matters before the former governmental body as to acting on behalf of a
person; and (5) lobbying. Popovich, Opinion 89-005.
Listing one's name as the person who will provide technical assistance on a proposal,
document, or bid, if submitted to or reviewed by the former governmental body, constitutes an
attempt to influence the former governmental body. Section 1103(g) also generally prohibits the
inclusion of the name of a former public official/public employee on invoices submitted by his
new employer to the former governmental body, even if the invoices pertain to a contract that
existed prior to termination of service with such governmental body. Shay, Opinion 91-012.
However, if such a pre-existing contract does not involve the unit where a former public employee
worked, the name of the former public employee may appear on routine invoices if required by
the regulations of the agency to which the billing is being submitted. Abrams/Webster, Opinion
95-011.
Bonacci, 24-562
September 13, 2024
Page 4
A former public official/public employee may assist in the preparation of any documents
presented to his former governmental body. However, the former public official/public employee
may not be identified on documents submitted to the former governmental body. The former
public official/public employee may also counsel any person regarding that person's appearance
before his former governmental body. Once again, however, the activity in this respect should not
be revealed to the former governmental body. The Ethics Act would not prohibit or preclude
making general informational inquiries to the former governmental body to secure information
which is available to the general public, but this must not be done in an effort to indirectly influence
the former governmental body or to otherwise make known to that body the representation of, or
work for, the new employer.
Section 1103(g) only restricts the former public official/public employee with regard to
representation before his former governmental body. The former public official/public employee
is not restricted as to representation before other agencies or entities. However, the "governmental
body with which a public official/public employee is or has been associated" is not limited to the
particular subdivision of the agency or other governmental body where the public official/public
employee had influence or control but extends to the entire body. See, Legislative Journal of
House, 1989 Session, No. 15 at 290, 291; Sirolli, Opinion 90-006; Sharp, Opinion 90-009-R.
Conclusion:
As a Transportation Construction Manager 2 with PennDOT, you are a "public employee"
subject to the Ethics Act and the Regulations of the State Ethics Commission. See, 65 Pa.C.S. §
1102; 51 Pa. Code § 11.1. This conclusion is based upon the submitted facts, which when reviewed
on an objective basis, indicate clearly that the power exists to take or recommend official action
of a non -ministerial nature with respect to one or more of the following: contracting; procurement;
administering or monitoring grants or subsidies; planning or zoning; inspecting; licensing;
regulating; auditing; or other activity(ies) where the economic impact is greater than de minimis
on the interests of another person.
Consequently, upon termination of your employment with PennDOT, you would become
a "former public employee" subject to Section 1103(g) of the Ethics Act. The governmental body
with which you would be deemed to have been associated upon termination of your employment
with PennDOT would be PennDOT in its entirety, including Engineering District 4-0. Therefore,
for the first year following termination of your employment with PennDOT, Section 1103(g) of
the Ethics Act would apply and restrict "representation" of a "person" including but not limited
to a new employer before PennDOT. The restrictions as to representation outlined above must
be followed.
You are advised that Section 1103(g) of the Ethics Act would not prohibit you from
accepting employment with an engineering firm that does business with PennDOT and other
governmental bodies, organizations, and entities. However, during the first year following
termination of your employment with PennDOT, Section 1103(g) of the Ethics Act would prohibit
you from performing any job duties for the engineering firm that would involve prohibited
representation of the engineering firm before PennDOT.
Lastly, the propriety of the proposed conduct has only been addressed under the Ethics Act;
the applicability of any other statute, code, ordinance, regulation or other code of conduct other
than the Ethics Act has not been considered.
Bonacci, 24-562
September 13, 2024
Page 5
Pursuant to Section 1107(11) of the Ethics Act, an Advice 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, provided the requester 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.
Finally, if you disagree with this Advice or if you have any reason to challenge same, you
may appeal the Advice to the full Commission. A personal appearance before the Commission
will be scheduled and a formal Opinion will be issued by the Commission.
Any such appeal must be in writing and must be actually received at the Commission within
thirty (30) days of the date of this Advice pursuant to 51 Pa. Code § 13.2(h). The appeal may be
received at the Commission by hand delivery, United States mail, delivery service, or by FAX
transmission (717-787-0806). Failure to file such an appeal at the Commission within thirty (30)
days may result in the dismissal of the appeal.
Respectfully,
Bridget K. Guilfoyle
Chief Counsel