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HomeMy WebLinkAbout1379 GradizziIn Re: Randall Gradizzi, File Docket: 04 -033 X -ref: Order No. 1379 Date Decided: 9/12/05 Date Mailed: 9/21/05 Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Raquel K. Bergen Nicholas A. Colafella This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding a possible violation of the Public Official and Employee Ethics Act, Act 9 of 1989, P.L. 26, 65 P.S. § 401 et seq., as codified by Act 93 of 1998, Chapter 11, 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." An Answer was not filed and a hearing was deemed waived. The record is complete. Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by Chapter 11 of Act 93 of 1998, 65 Pa.C.S. § 1101 et seq., which essentially repeats Act 9 of 1989 and provides for the completion of pending matters under Act 93 of 1998. This adjudication of the State Ethics Commission is issued under Act 93 of 1998 and will be made available as a public document thirty days after the mailing date noted above. However, reconsideration may be requested. Any reconsideration request must be received at this Commission within thirty days of the mailing date and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code § 21.29(b). A request for reconsideration will not affect the finality of this adjudication but will defer its public release pending action on the request by the Commission. The files in this case will remain confidential in accordance with Chapter 11 of Act 93 of 1998. Any person who violates confidentiality of the Ethics Act is guilty of a misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than one year. Confidentiality does not preclude discussing this case with an attorney at law. Gradizzi, 04 -033 Page 2 I. ALLEGATION: That Randall J. Gradizzi, a (public official /public employee) in his capacity as a Supervisor for Fox Township, Elk County, violated the following provisions of the State Ethics Act (Act 93 of 1998) when he used the authority of his office for a private pecuniary gain of himself and /or members of his immediate family by participating in actions and discussions of the board of supervisors resulting in his sister being hired to the position of Park Director, and his brother hired for a full -time position with the Road Department; and when he participated in decisions of the board of supervisors to enter into contracts with Pollino Excavating which were in excess of $500 and entered into without an open and public process; and when he approved payments to his employer in 2001 and 2002; when he participated in actions of the board of supervisors to approve a contract for the Senior Center to Micale Construction at a time when a business with which he is associated was subcontracting with Micale; and when as a member of the Fox Township Sewer Authority participated in decisions of the authority board of directors to enter into contracts with his employer, Pollino Excavating in excess of $500 without an open and public process. II. FINDINGS: 1. Randall Gradizzi has served as a Supervisor for Fox Township, Elk County since January 2000. a. Gradizzi served as vice - chairman of the board in 2000 and 2001. b. Gradizzi was appointed by the board of supervisors to the Planning Commission for a four year term commencing January 7, 2002 and lasting through December 31, 2005. c. Gradizzi served on the Fox Township Sewer Authority Board from January 4, 2000, through June 8, 2005. 1. Gradizzi resigned from the authority at the June 8, 2005 authority board meeting. d. Gradizzi has served as assistant- roadmaster since June 2, 2004. 2. Gradizzi has been employed as an equipment operator for Pollino Excavating for approximately twelve years. 3. Fox Township is a Second Class Township governed by a three member board of supervisors. a. Supervisors are compensated $1,875.00 per year. 1. Supervisors receive the compensation whether or not they attend monthly meetings. b. Supervisors serving since 2000 include Gradizzi, Michael Keller, and Jerry Zimmerman, Jr. 4. Since 2000, the Fox Township Board of Auditors have established compensation for Supervisors Gradizzi, Jerry Zimmerman and Michael Keller as follows: a. 2000: Gradizzi - $15.22 /hour (emergency only). Keller - $12.02 /hour (emergency only). Zimmerman - $15.72 /hour, as Assistant Roadmaster /Equipment Operator/Landfill/Laborer. b. 2001: Gradizzi - $15.22 /hour, as an Equipment Operator, working in Gradizzi, 04 -033 Page 3 emergency situations only. Keller - $12.26 /hour (emergency only). Zimmerman - $16.02 /hour, as Assistant Roadmaster /Equipment Operator /Landfill Laborer. The auditors set compensation for Jerry Zimmerman on March 20, 2001 after he was appointed roadmaster. The wage was $16.52 /hour, $1.00 more than the rate for his classification which was $15.52 /hour. Zimmerman's compensation as an assistant roadmaster was $.50 more per hour than his rate as an equipment operator of $15.52 /hour. c. 2002: Gradizzi - $15.77 /hour, as an Equipment Operator in emergency situations only and on an as- needed basis only. Keller - $12.51 /hour (emergency only). Zimmerman - $16.77 /hour, as Assistant Roadmaster /Equipment Operator /Landfill Laborer. The minutes incorrectly record Zimmerman's position as Assistant Roadmaster instead of Roadmaster. The pay rate was correctly set, based on the rate of an Equipment Operator, $15.77, plus $1.00 per hour for the roadmaster position. d. 2003: Gradizzi - $16.02 /hour, as an Equipment Operator (as- needed basis only). Keller - $12.76 /hour, as a laborer (emergency only). Zimmerman - $17.02 /hour, as Roadmaster /Equipment Operator /Landfill Laborer. e. 2004: Gradizzi - $16.27 /hour, as an Equipment Operator (as — needed basis). Keller - $13.01 /hour, as a laborer (emergency purposes only). Zimmerman - $17.27 /hour, as Roadmaster /Equipment Operator /Landfill Laborer. Gradizzi was appointed Assistant Roadmaster on June 2, 2004. f. 2005: Gradizzi - $16.76 /hour, as an Equipment Operator /Assistant Roadmaster as- needed basis); plus the additional $1.00 /hour when the roadmaster is off. Zimmerman - $17.76 /hour, as Roadmaster /Equipment Operator /Landfill Laborer. 5. In preparing the agenda for the 2002 auditors reorganization meeting, Mosier added the wording `as- needed' to the motion regarding Gradizzi's compensation. a. In either December 2001 or January 2002, Mosier was informed by Supervisor /Roadmaster Zimmerman that Gradizzi was going to be operating equipment rented from Pollino Excavating for township road projects, and that he would be paid as a township employee. b. Mosier was not directed by Zimmerman or any township supervisor to add the reference `as- needed' to the motion regarding Gradizzi's compensation. 1. Mosier made the change believing that Gradizzi would be operating equipment on township projects. c. Mosier did not advise the auditors that the language on the agenda was changed from emergency situations only to as needed. Gradizzi, 04 -033 Page 4 d. The auditors did not discuss the addition of as needed" by Mosier to the meeting agendas from 2002 to 2005, regarding Gradizzi's employment with the township. 1. The auditors did not notice or authorize the change in language. 6. During 2002, the board of supervisors did not appoint Gradizzi to be employed as an equipment operator or laborer. 7 In approving compensation for Gradizzi and Michael Keller for 2002 through the present, the auditors intended and believed that Gradizzi would be paid for performing work in emergency situations. The following findings relate to Gradizzi's role in the hiring of his sister, Debra Agosti, as the Fox Township Recreation Facilities Director. 8. The Fox Township Recreation Board was established by Ordinance No. 89 -5 adopted by the board of supervisors on May 17, 1989, prior to Gradizzi's service on the board. Under Article XXII, Parks, Recreation Centers and Forests, the Second Class Township Code empowers a board of supervisors to acquire land, establish facilities, purchase equipment, employ persons to maintain or supervise the use of the facilities, and to create a recreation board to supervise, regulate, equip and maintain township- funded recreation programs and facilities. a. Recreation board members are appointed to five year terms by the board of supervisors. b. A recreation board only possesses those powers delegated to it by the board of supervisors. c. Boards consist of five to seven members, who serve with no compensation. 9. In or around 2000, the township began to develop a new park with soccer and baseball fields, on property donated to the township for such use. a. The plan was to build a community park which would include: three baseball fields, two soccer fields, a football field, restroom, concession stand, and walking /bicycle track, along with parking and necessary infrastructure. b. Four years earlier a local family had donated the land to the township for the development of a soccer field, in memory of their daughter. c. The township received a $100,000.00 Keystone Recreational Grant from the PA Department of Conservation and Natural Resources, for the development of the park. 10. After his election to the board in 2000, Gradizzi became a driving force in the development of the new park. a. At the August 2, 2000, Board meeting, Chairman Keller, referred to Gradizzi as the "spark plug of the project ", and attributed the progress of the park to Gradizzi. 11. During the October 16, 2001 budget meeting of the board of supervisors the creation of a new recreational position was discussed. a. The position would be responsible for coordinating activities at and maintaining the township parks. Gradizzi, 04 -033 Page 5 b. Details of the position had not been determined. c. The position, which would be salaried, would be required to attend the functions at the parks as well as various meetings. d. For budget purposes, a preliminary salary of $25,250.00 was discussed. e. Gradizzi was present for the meeting and participated in the discussions. 12. At the March 6, 2002, Board of Supervisors meeting, Gradizzi participated in the discussion and vote to advertise for the hiring of a recreational facilities director. Minutes of the meeting reflect the following: a. Ajob description had been written and reviewed by the recreation board and the supervisors. b. Subsequent to the discussion, Gradizzi made a motion to review the job description for the recreational facilities director and then advertise to fill the position. 1. The vote to advertise to fill the position was unanimous with Gradizzi participating. c. The hours and salary for the position would be set during the review of the job description. 13. The job description for the position of recreational facilities director included the following: - Strong background and knowledge in fiscal management, grounds /facility maintenance, sports & leisure program planning /implementation and the ability to forge partnerships with public non - profit associations are required. - A degree in park and recreation administration or a related field would be helpful but not required. - Responsibilities include but are not limited to: - Administer the day -to -day operations of the township's recreation facilities. - Plan and prepare recreational and sports related programs for various age groups. - Serve as liaison between board of supervisors, recreational board and other recreational organizations utilizing township facilities. - Prepare and submit to the board of supervisors, annual budget including capital improvement program. - Schedule, coordinate and facilitate the use of all recreational facilities by outside organizations. - Operate park department vehicles and tractors in a safe and productive manner. - Maintenance and repairs of parks and public grounds to include, but no limited to: Trimming of grass, shrubbery, and trees Minor construction and renovations Assembling and positioning of various items of playground pieces Maintaining of ball fields, picnic areas, and playground equipment, walking track, etc. Prepares site and seeds lawns Picks up and disposes of trash and litter Gradizzi, 04 -033 Page 6 Check all park areas on a regular schedule to look for problems, vandalism or work needing to be done Report any vandalism to supervisors, improve and maintain security of existing facilities Maintain inventories and utilize equipment and materials in a safe manner - Supervise staff assigned to assist with this position. - Must attend meetings of the various organizations directly associated with the recreation programs utilizing township facilities including, but not limited to: Fox Township Recreation Board, Little League Association, Soccer Association and Fox Township Board of Supervisors, as needed. - Shall attend any training deemed necessary or beneficial to this position, as determined by the Fox Township Board of Supervisors. - Schedule the operation of, maintain inventory for & conduct general maintenance of concession stand(s) under the control of Fox Township. 14. At the April 3, 2002 board of supervisors meeting, Chairman Mike Keller announced that the position of recreational facilities director would be advertised beginning the following week. a. The deadline to apply for the position was April 19 with an intended start date of April 29 15. The position for the recreation facilities director was advertised in The Daily Press newspaper on April 4 th, 11 , and 15 2002. 16. Debra Agosti is the sister of Randall Gradizzi. 17. Agosti has served on the recreation board from on September 6, 2000 to the current time. a. Agosti was initially appointed to fill a vacancy on the board. b. Agosti was reappointed to a full term on January 2, 2001. 18. Debra Agosti was one of the applicants applying for the position of recreation director. 19. The board of supervisors did not conduct interviews of any of the candidates. a. Six resumes were received by the township by April 19, 2002, in response to the advertisement for a recreation facilities director, including that of Debra Agosti. 20. At the May 1, 2002 board of supervisors meeting, Board Chairman Michael Keller announced that Debra Agosti had been hired as the township recreational facilities director and would be responsible for maintaining and managing the recreational parks. a. No vote of the board was taken to approve Agosti's hiring. b. The announcement of Agosti's hiring was preceded by an executive session on May 1, 2002, at which all three supervisors, including Gradizzi, were present. 1. Agosti's hiring was discussed and agreed upon by the supervisors during this session. 21. Gradizzi was present at the executive session during which the applicants for the Gradizzi, 04 -033 Page 7 recreation facilities director position were reviewed and discussed. a. Gradizzi did not advocate the hiring of his sister. 22. Agosti was initially hired on a part -time basis at the rate of $10.00 per hour, with time and one half over 40 hours. 23. At the October 8, 2002 Budget meeting, the board of supervisors announced that Debby Agosti was offered full -time status as the recreational facilities director with an annual salary of $21,840 plus benefits. a. The action was taken during an executive session at which Gradizzi was present. b. No formal vote of the board was taken approving the change in status or the salary increase. 24. At the January 2, 2005, reorganization meeting, the board of supervisors authorized an increase in salary for the recreation facilities director from $21, 840.00 to $25,000.00 per year. a. Salaries for other township employees, including Gradizzi's brother, were also discussed. b. Gradizzi abstained on the vote, stating that his sister and brother are employees. 1. The motion included a 3% raise for the road department employees. 25. Minutes of the board of supervisors meetings for January 6, 2003; January 5, 2004; and January 5, 2005; reflect that Gradizzi voted to approve payrolls at the beginning of each year, which included the salary for Debra Agosti and all township employees. 26. Gradizzi signed 53 payroll checks totaling $52,388 issued to Debra Agosti during the time period May 2002 through April 2005. 27. Agosti's earnings as the Fox Township Recreation Facilities Director are reflected on W -2 Wage And Tax Statements for the years 2002 through 2004, as follows: 2002 - $11,940.79 2003 - 22,417.50 2004 - 22, 360.00 The following findings relate to allegation that Gradizzi participated in the hiring of Joseph Gradizzi to the township road crew. 28. Joseph Gradizzi is the brother of Randall Gradizzi. 29. In or about February 2003, Joseph Gradizzi was offered employment by Fox Township Supervisor Roadmaster Jerry Zimmerman without board action approving the hiring. a. Joseph Gradizzi began working for the Fox Township road crew on a part - time basis in 2003. b. Joseph Gradizzi previously submitted an application for employment with the township dated May 5, 2002. Gradizzi, 04 -033 Page 8 30. Jerry Zimmerman offered employment to Joseph Gradizzi based on the following: a. Gradizzi could operate equipment, drive trucks, weld, and repair the trucks and equipment. b. At an executive session held during a budget meeting in October 2003, he asked the other supervisors if he could hire Joseph Gradizzi to work as a mechanic /park maintenance employee. 1. Randall Gradizzi was opposed to hiring his brother. c. The position of mechanic /park maintenance employee was created for Joseph Gradizzi. 1. Previously the road department had the position of mechanic, but it had not been filled for several years. 2. The position of park maintenance was new. d. Joseph Gradizzi was brought in as an equipment operator because of his previous experience operating equipment. 31. The Fox Township Board of Supervisors met on October 22, 2003, for a budget workshop and during an executive session the hiring of Joseph Gradizzi as a full time employee with the road department was discussed by the board of supervisors. a. Randall Gradizzi was present but was opposed to the hiring. b. Other personnel actions were also announced at this meeting. 32. No vote was taken during the October 22, 2003 workshop by the board of supervisors to approve the hiring of Joseph Gradizzi as a full time employee. a. The board of supervisors did not formally approve the hiring of any personnel during meetings. 1. Hirings were discussed during executive sessions. 33. Gradizzi did not want his brother to be hired by the township because of the fact that his sister was already working for the township and he (Gradizzi) did not think it would look right for his brother to also be hired. 34. Gradizzi signed thirty -three payroll checks, issued to Joseph Gradizzi, between February 2003 and June 1, 2005. 35. W -2 Wage and Tax Statements reflect the total wages issued by Fox Township to Joseph Gradizzi for the years 2003 and 2004. 2003 - $20,904.91 2004 - $37,204.19 The following findings relate to the township's contracting with Gradizzi's employer Pollino Excavating without an open and public process; and Gradizzi participating in the approval of payments to Pollino. 36. Pollino Excavating is owned and operated by Raymond Pollino. a. The business provides commercial and residential excavating services. Gradizzi, 04 -033 Page 9 b. Pollino operates the business from his home. c. Pollino stores his equipment in a garage on property owned by his family. 37. Gradizzi is compensated by Pollino Excavating as an equipment operator on an hourly rate, as follows: May 2000 - $14.50/hr. May 2001 - $15.00 /hr. May 2002 - $15.45/hr. February 2003 - $15.91/hr. May 2004 - $16.39/hr. May 2005 - $16.88/hr. a. Gradizzi received pay increases in May of each year. 38. Pollino owns various equipment including: 650K Bulldozer 580L Case Backhoe International Triaxle truck Ford 10 -ton single axle truck 20 -ton trailer Utility truck Dump truck Case excavator 39. At the end of 2001, Fox Township began to rent heavy equipment from Pollino Excavating. a. The township had not previously used Pollino Excavating as a source for rental equipment. b. The township had previously used, and continued to use other equipment rental businesses to a lesser degree, including: Vollmer Brothers Excavating; PJL Trucking; Grotzingers; Apple Tractor; and Dobson's Excavating. c. The use of Pollino for rental equipment was initiated by Supervisor and Roadmaster Jerry Zimmerman as a result of road projects initiated by Zimmerman. 40. In or about December 2001, Zimmerman authorized the rental of equipment from Pollino Excavating for road widening projects on township roads, Boone Mountain and Four Points. a. Zimmerman became Roadmaster in 2001, and changed the way the road department was run. 1. The roadmaster has the authority to make decisions on the management of the road department, including the projects that will be performed. b. He chose to perform a road widening project on Boone Mountain Road during the winter months. c. He chose Pollino because of prior experiences with Pollino. d. Zimmerman talked to Gradizzi and Keller about paying Gradizzi as a township employee to operate Pollino Excavating equipment on township Invoice Date Invoice Number Item Description Amount Invoiced Total 2001 11 -02 -01 568 Backhoe Connecting water & sewage tap $ 550.00 $ 1,150.00 568 Dump truck Connecting water & sewage tap 150.00 568 Labor Connecting water & sewage tap 450.00 11 -02 -01 570 Backhoe Installing 20,000 gallon tank 925.00 4,238.00 570 Dozer Installing 20,000 gallon tank 1,125.00 570 Labor Installing 20,000 gallon tank 2,145.00 570 Equip. Rental Jackhammer 43.00 2002 03 -26 -02 593 Excavator Equip. Rental 2/20 - 3/20/02 3,400.00 7,600.00 592 Tri -axle Tri -axle Lease 4,200.00 07 -27 -02 609 Excavator Lease -195 hrs. A $40 per hour 7,800.00 18,240.00 609 Dozer Lease -190 hrs. A $30 per hour 5,700.00 609 Tri -axle Lease -158 hrs. A $30 per hour 4,740.00 07 -27 -02 610 Sandstone 115 Tri -axle loads A $25 per load 2,875.00 4,030.00 610 Sandstone 77 Single Axle loads A$15 / load 1,155.00 07 -27 -02 612 Excavator Lease -6 hrs. A $40 per hour 240.00 240.00 07 -27 -02 611 Excavator Lease -9 hrs. A $40 per hour 360.00 360.00 09 -06 -02 618 Excavator Lease -6 hrs. A $40 per hour 240.00 540.00 618 Tri -axle Lease -10 hrs. A $30 per hour 300.00 09 -06 -02 617 Excavator Lease -11 hrs. A $40 per hour 440.00 680.00 617 Dozer Lease -8 hrs. A $30 per hour 240.00 09 -06 -02 615 Excavator Lease -45.5 hrs. A $40 per hour 1,820.00 4,180.00 Gradizzi, 04 -033 Page 10 road projects. e. Zimmerman initiated the idea because he knew that it would be improper for Gradizzi to be paid as an employee of Pollino Excavating while operating his employer's equipment on township jobs. 41. In or about December 2001, Zimmerman discussed, with Pollino, the equipment to be leased. a. Zimmerman advised Pollino that he wanted to lease the equipment without an operator and that he intended to utilize Randall Gradizzi as the operator. b. Zimmerman was to use Gradizzi as a township employee operating Pollino's equipment. c. Zimmerman did not seek or receive the approval of the other board members to negotiate with Pollino. 42. Pollino agreed to Zimmerman's rental proposal because the road widening project afforded Pollino Excavating work during the winter months. a. During the winter months, Pollino generally has only sporadic work available for Gradizzi consisting mainly of snow removal. b. Gradizzi, as a result, is usually furloughed during the winder months and would be available for work with the township. c. Pollino has, on occasion, rented equipment without an operator. 43. In December 2001 or January 2002, Zimmerman also advised Township Secretary Mosier that Gradizzi would be working for the township. 44. When the township rented equipment from Pollino Excavating, Gradizzi was paid as a township employee to operate Pollino equipment. 45. Between November 2001 through September 2002, Pollino Excavating invoiced Fox Township for services which were not part of any bid process: Gradizzi, 04 -033 Page 11 46. Beginning in the fall of 2002, Supervisor /Roadmaster Jerry Zimmerman began soliciting telephone price quotes for equipment rentals for road projects in 2002 and 2003. a. The prices were solicited in the fall of 2002 for the 2002/2003 and the fall of 2003 for the 2003/2004 winter road projects. b. Prior to 2002, quotes for equipment rental were not obtained. 47. Quotes solicited by Zimmerman included the following: a. 2002/2003 (phone quotes — w /operator): Vendor: Bradco Pricing: n/a Vendor: Kahles Pricing: By week or month only Vendor: Apple Tractor Pricing: excavator - $31.00 /hour Dozer - $37.00 /hour Vendor: Pricing: Vendor: Pricing: b. 2003/2004 (Written quotes): Vendor: Subject: Date: Quote: Apple Tractor Equipment Rental Quote Undated $32.50 per hour — excavator 35,000 Ib. class (i.e. Kobelco SK150; Komatsu PC150; CASE 9020B) $40.00 per hour — Crawler tractor (i.e. CAT D4C; CASE 650H; Komatsu D38P) Vendor: Subject: Date: Equipment: Vendor: Subject: Bentley excavator - $55.00 /hour Dozer - $62.00 /hour Pollino Excavating excavator - $35.00 /hour Dozer - $35.00 /hour Triaxle - $32.00 /hour Onyx Greentree Landfill, LLC Equipment Rental Quote 9/22/03 $50 per hour — Hitachi excavator 330LC (without operator) $65 per hour - CAT D6M (without operator) Pollino Excavating Equipment Rental Proposal 615 Dozer Lease -30 hrs. (i $30 per hour 900.00 615 Tri -Axle Lease -47 hrs. (i $30 per hour 1,410.00 615 Sandstone 2 Tri -axle loads p $25 per load 50.00 09 -06 -02 616 Excavator Lease -8 hrs. (i $40 per hour 320.00 320.00 Gradizzi, 04 -033 Page 11 46. Beginning in the fall of 2002, Supervisor /Roadmaster Jerry Zimmerman began soliciting telephone price quotes for equipment rentals for road projects in 2002 and 2003. a. The prices were solicited in the fall of 2002 for the 2002/2003 and the fall of 2003 for the 2003/2004 winter road projects. b. Prior to 2002, quotes for equipment rental were not obtained. 47. Quotes solicited by Zimmerman included the following: a. 2002/2003 (phone quotes — w /operator): Vendor: Bradco Pricing: n/a Vendor: Kahles Pricing: By week or month only Vendor: Apple Tractor Pricing: excavator - $31.00 /hour Dozer - $37.00 /hour Vendor: Pricing: Vendor: Pricing: b. 2003/2004 (Written quotes): Vendor: Subject: Date: Quote: Apple Tractor Equipment Rental Quote Undated $32.50 per hour — excavator 35,000 Ib. class (i.e. Kobelco SK150; Komatsu PC150; CASE 9020B) $40.00 per hour — Crawler tractor (i.e. CAT D4C; CASE 650H; Komatsu D38P) Vendor: Subject: Date: Equipment: Vendor: Subject: Bentley excavator - $55.00 /hour Dozer - $62.00 /hour Pollino Excavating excavator - $35.00 /hour Dozer - $35.00 /hour Triaxle - $32.00 /hour Onyx Greentree Landfill, LLC Equipment Rental Quote 9/22/03 $50 per hour — Hitachi excavator 330LC (without operator) $65 per hour - CAT D6M (without operator) Pollino Excavating Equipment Rental Proposal Gradizzi, 04 -033 Page 12 Date: 9/22/03 Equipment: $27 per hour — excavator CASE 9020B $40 per hour — dozer CASE 650K (w /operator) $34 per hour — tri -axle (w /operator) 48. In the fall of 2004, the township publicly advertised for equipment rental prices for the Boone Mountain Road widening project. "Sealed proposals will be received ... until 4:00 PM., on October 6, 2004, for the lease of the following equipment for use in widening (T- 315) Boone Mt. Road from Four Points Road to Clearcut Road: 38,000- 40,000 pound excavator 650 or D4 Dozer Triaxle Lease rates shall be expressed as an hourly rate and submitted for both (1) equipment only and (2) equipment with an operator. All work will be done in co- operation with Township road crew and Township equipment. Therefore, leased equipment must be available on a twelve hour notice and may be cancelled or delayed based on the availability of the Township road crew. Project is scheduled to begin January 2005. Complete details can be obtained at the Fox Township office, 8:00 AM — 4:00 PM, Monday thru Friday. Proposals must be upon the forms furnished by the Municipality and must be accompanied with proof of at least $1 million liability insurance. The Municipality reserves the right to reject any or all proposals." 49. Two bids were received by the township in response to the advertisement. Vollmer Brothers Excavating: TD8 Dozer (with /without operator not specified) $60.00 /hr Singleaxle truck (with /without operator not specified) $50.00 /hr No price was provided for an excavator. Pollino Excavating: Case 9020 B excavator: Without operator $40.00 /hr With operator $60.00 /hr Case 650 K Dozer Without operator $35.00 /hr With operator $50.00 /hr Triaxle Without operator $30.00 /hr With operator $35.00 /hr 50. On October 6, 2004, the board of supervisors awarded the bid to Pollino Excavating. a. Gradizzi abstained on the vote to award the contract to Pollino Excavating at the October 6, 2004 Board meeting. b. The minutes of the October 6, 2004, meeting reflect that Gradizzi stated for the record that he was abstaining because his employer was one of the bidders. 51. Between December 2002 through May 2005, Pollino invoiced Fox Township for services performed which were bid through telephone quotes. Invoice Date Invoice Number Item Description Amount Invoiced Total 2002 12 -01 -02 641 Excavator Lease -34 hrs. A $40 per hour 1,360.00 2,590.00 641 Dozer Lease -25 hrs. A $30 per hour 750.00 641 Tri -Axle Lease -16 hrs. A $30 per hour 480.00 2003 03 -03 -03 648 Excavator Lease -Cherry Road 1,160.00 1,160.00 04 -02 -03 659 Excavator Lease -Boone Mt Road 8,775.00 15,315.00 659 Dozer Lease 4,200.00 659 Dump Truck Lease 1,380.00 659 Tri -Axle Lease 960.00 04 -02 -03 660 Dump Truck Lease -4 points to 153 800.00 950.00 660 Dozer Lease 150.00 04 -19 -03 665 Excavator Lease -Boone Mt Road 3,600.00 6,900.00 665 Dozer Lease 2,400.00 665 Dump Truck Lease 900.00 08 -01 -03 682 Excavator Lease -Dietz Road 2,400.00 5,280.00 682 Dozer Lease 2,040.00 682 Tri -Axle Lease 840.00 07 -23 -03 675 Excavator Install culvert pipes 560.00 560.00 07 -23 -03 676 Excavator Clean ditch - Blooms Road 200.00 200.00 08 -05 -03 683 Excavator Lease - Greene Road 2,360.00 6,070.00 683 Dozer Lease 2,010.00 683 Tri -Axle Lease 1,700.00 09 -01 -03 685 Excavator Lease - Demolition 113 1,520.00 2,495.00 Tri -Axle Lease 975.00 09 -01 -03 684 Excavator Lease - Greene Road 4,560.00 10,860.00 684 Dozer Lease 3,750.00 684 Tri -Axle Lease 2,550.00 09 -02 -03 689 Excavator Lease -New Park 1,820.00 1,820.00 09 -02 -03 690 Excavator Lease -Ridge Road 320.00 320.00 09 -30 -03 696 Dozer Lease -New Maintenance Bldg. 2,920.00 7,800.00 696 Excavator Lease 2,780.00 696 Tri -Axle Lease 100.00 09 -30 -03 695 Dozer Lease -New Park 1,000.00 1,272.00 695 Excavator Lease 160.00 695 Materials 4" SCH.35 112.00 09 -30 -03 694 Excavator Lease - Community Bldg. 200.00 09 -30 -03 693 Dumpster Lease 80.00 80.00 10 -27 -03 700 Excavator Lease - Gardner Hill 2,400.00 7,920.00 700 Dozer Lease 3,120.00 700 Tri -Axle Lease 2,400.00 11 -28 -03 703 Excavator Lease - Dallasen's Hill 5,184.00 18,515.00 703 Dozer Lease 5,400.00 703 Dump Truck Lease 2,754.00 703 Tri -Axle Lease 1,190.00 703 Shale 3,987.00 11 -28 -03 704 Backhoe Repair washouts (rainstorm) 105.00 105.00 2004 01 -31 -04 711 Excavator Lease -Boone Mt Road 4,320.00 12,635.00 711 711 Dozer Dump Truck Lease Lease 4,660.00 1,394.00 711 Tri -Axle Lease 2,261.00 03 -30 -04 719 Excavator Lease -Boone Mt Road 4,239.00 17,813.00 719 Dozer Lease 5,120.00 719 Dump Truck Lease 1,734.00 719 Tri -Axle Lease 2,720.00 04 -05 -04 724 Excavator Lease -Boone Mt Road 320.00 2,560.00 724 Dozer Lease 1,440.00 724 Dump Truck Lease 800.00 05 -03 -04 729 Excavator Lease - Senior Center 5,103.00 19,431.00 729 Dozer Lease 5,760.00 Gradizzi, 04 -033 Page 13 Gradizzi, 04 -033 Page 14 * Some of the Pollino invoices reflect charges for materials utilized in the various projects. 52. When operating Pollino equipment on township road projects Gradizzi was compensated as a township employee. 53. Between 01/01/02 and 05/27/04, township time and payroll records confirm Gradizzi worked 1,835.8 hours for the township and was compensated $25,464.24 while Pollino equipment was being rented by the township. 729 Backhoe Lease 1,836.00 729 Tri -Axle Lease 6,732.00 05 -03 -04 728 Excavator Lease -Fox Manor 513.00 1,581.00 728 Dozer Lease 660.00 728 Tri -Axle Lease 408.00 05 -03 -04 727 Excavator Lease -Boone Mt. Road 1,215.00 1,997.00 727 Tri -Axle Lease 782.00 08 -03 -04 744 Backhoe Lease - Sheeley Road & 4 of July storm 800.00 800.00 08 -30 -04 745 Excavator Lease -Cherry Road 7,755.00 20,761.00 745 Dump truck Lease -Cherry Road 5,610.00 745 Backhoe Lease -Cherry Road 4,620.00 745 Triaxle Lease -Cherry Road 1,156.00 746 Dozer Lease -new park 1,620.00 09/14/04 751 Excavator Lease - Chicken Hill 4,077.00 9,065.00 751 Dump Truck Lease - Chicken Hill 2,516.00 751 Backhoe Lease - Chicken Hill 210.00 751 Triaxle Lease - Chicken Hill 2,516.00 751 Shale Chicken Hill 520.00 10/04/04 754 Backhoe Lease for flood clean -up 9/04 280.00 2005 01/30/05 767 Excavator Lease- 6,900.00 19,115.00 767 Dozer Lease- 4,800.00 767 Dump Truck Lease 3,330.00 767 Triaxle Lease 2,925.00 767 Drilling Drilling shale pit in preparation for blasting shale 1,160.00 02/27/05 771 Excavator Lease 111 hours — Three Points 4,440.00 20,215.00 771 Dozer Lease 114 — Three Points 5,700.00 771 Dump Truck Lease 86 hours — Three Points 2,580.00 771 Triaxle Lease 111 hours — Three Points 4,995.00 771 Shale Three Points 2,500.00 04/05/05 775 Dozer Lease 138 hrs @ $50 /hr. - Three Points 6,900.00 20,770.00 775 Excavator Lease 121 hrs @ $40 /hr. — Three Points 4,840.00 775 Dump Truck Lease 78 hrs @ $30 /hr. — Three Points 2,340.00 775 Triaxle Lease 124 hrs. (i $45 /hr. -Three Points 5,580.00 775 Shale Three Points 1,110.00 05/02/05 779 Dozer Lease 150 hrs @ $50 /hr. - Three Points 7,500.00 23,160.00 779 Excavator Lease 140 hrs @ $40 /hr. — Three Points 5,000.00 779 Triaxle Lease 145 hrs @ $45 /hr. — Three Points 6,525.00 779 Dump Truck Lease 107 hrs. @ $30 /hr. -Three Points 3,210.00 779 Shale Three Points 325.00 05/02/05 780 Excavator Lease 17.5 hrs @ $40 /hr. -Boone Mt. Rd 700.00 2,500.00 780 Backhoe Lease 20 hrs A $45 /hr. —Boone Mt. Rd. 900.00 780 Triaxle Lease 20 hrs (i $45 /hr. -Boone Mt. Rd. 900.00 05/02/05 781 Dozer Repair road - Energy Resources Inc. 1,200.00 5,059.00 781 Excavator Repair road - Energy Resources Inc. 900.00 781 Triaxle Repair road - Energy Resources Inc. 1,080.00 781 #3 limestone 114.33 tons 1,879.00 Gradizzi, 04 -033 Page 14 * Some of the Pollino invoices reflect charges for materials utilized in the various projects. 52. When operating Pollino equipment on township road projects Gradizzi was compensated as a township employee. 53. Between 01/01/02 and 05/27/04, township time and payroll records confirm Gradizzi worked 1,835.8 hours for the township and was compensated $25,464.24 while Pollino equipment was being rented by the township. Gradizzi, 04 -033 Page 15 54. Gradizzi ceased operating Pollino Excavating equipment on township jobs in approximately August 2004, in order to avoid future conflict of interest. a. Gradizzi ceased operating Pollino equipment after he was notified of the State Ethics Commission investigation by letter dated July 19, 2004. 55. Gradizzi was issued W -2 Wage & Tax Statements by Fox Township which confirmed income as follows while operating Pollino equipment: 2002 - $ 9,172.31 2003 - $12,052.16 2004 - $10,400.70 a. Gradizzi was issued a separate W -2's for his supervisor compensation. b. Wages paid to Gradizzi for attendance at conventions were included in the 2002, 2003 and 2004 W -2's, for wages. 56. Gradizzi participated in approving payments to Pollino Excavating in 2001 and 2002 totaling $35,853. a. Gradizzi voted to approve payments on six occasions to Pollino Excavating totaling $35,858; at the same time he was paid by the township to operate Pollino Excavating equipment on township projects. 1. Gradizzi voted on the following dates: 12/05/01 $ 1,150 03/06/02 $ 4,238 04/03/02 $ 7,600 08/07/02 $22,870 $35, 858 b. Gradizzi began abstaining on the votes to approve payment of the bills which included payments to Pollino Excavating beginning in October 2002, and continuing into 2003, 2004, and 2005. 1. Gradizzi began abstaining after receiving information from the authority solicitor that he should abstain on Pollino matters. 57. Gradizzi signed six (6) checks totaling $51,969 authorizing payments to Pollino as follows: 12/05/01 $ 1,150 02/08/02 $ 4,238 4/03/02 $ 7,600 05/07/03 $ 6,900 10/01/03 $ 9,072 05/05/04 $23, 009 $51,969 The following findings relate to Gradizzi's participation in awarding a contract to Pollino Excavating for excavating work during the construction of the township maintenance building. 58. In or about January and February 2004 the board of supervisors made a decision to build a maintenance garage. 59. The maintenance garage project was publicly advertised and bid in The Daily Press and The Courier Express. Date Invoice E • ui • ment Service Cost 09 -01 -03 695 Excavator Lease - Demolition 113 1,520.00 Tri -Axle Lease 975.00 09 -30 -03 696 Dozer Lease -New Maintenance Bldg. 2,920.00 696 Excavator Lease 2,780.00 696 Tri -Axle Lease 100.00 TOTAL $8,295.00 Gradizzi, 04 -033 Page 16 a. Advertisements were published on 2/19/04 and 2/25/04. b. The bids were due by May 5, 2004, at 6:00 p.m. 60. Fox Township received two bids on the maintenance garage project. Hallstrom Construction, DuBois, PA- $205,100.00 Micale Construction, Kersey, PA - $202,860.00 61. Gradizzi participated in the board of supervisors vote to award the contract for the construction of a new maintenance garage to Micale Construction at the May 5, 2004 board of supervisors meeting. a. The contract was awarded by a 3/0 vote. 62. Excavation and site preparation was not part of the bid specifications. a. The site preparation required the demolition of an existing structure on the property. b. Gradizzi formulated the plan to demolish the existing structure by using an excavator. 1. Pollino Excavating owns an excavator. 63. The board of supervisors, including Gradizzi, made the decision not to include the site preparation in the bid specifications to reduce project costs to avoid paying the required prevailing wage rate. a. During the planning of the maintenance project, the board discussed the idea of saving money by completing the site preparation. b. If the construction project would have required prevailing wage rates, project costs would have increased. 64. Pollino Excavating's equipment was rented by the township for the purpose of the maintenance garage site preparation. a. No vote of the board was taken to award the work to Pollino Excavating. b. Gradizzi participated in the discussions to utilize Pollino. c. Gradizzi operated Pollino's excavator during the demolition and site preparation. 65. Pollino Excavating submitted invoices for work performed in relation to the site preparation and was compensated as follows by Fox Township: Gradizzi abstained from the vote to approve payment of the bills which included the Pollino Excavating invoices for the site preparation. Gradizzi signed check #593 issued from the Landfill account, dated 10/01/03, in the amount of $9,072.00, payable to Pollino Excavating. Gradizzi, 04 -033 Page 17 a. The $8,295 total of invoices 695 and 696 were included as part of the payment. 66. Gradizzi was paid as a township employee for operating Pollino's excavator during the demolition and site preparation for the Maintenance Garage. 67. Pollino invoiced the township for 107.5 hours for the use of the excavator during the site preparation for the maintenance garage. a. Gradizzi was the only one who operated the excavator during the site preparation for the maintenance garage. b. The township pay rate for an equipment operator in 2003 was $16.02 per hour. 68. Gradizzi was paid $1,722.15 as a township employee during the site preparation for the maintenance garage, which included operating the excavator rented from Pollino Excavating. a. The hourly rate of $16.02 multiplied times 107.5 hours = $1722.15. The following findings relate to the allegation that Gradizzi participated in actions of the board to award a contract to a company that subcontracted with a business with which he is associated. 69. At the June 16, 2003, meeting, the board of supervisors approved the purchase of the Fox Township Senior Center from St. Boniface Parish for the amount of $60,000.00. a. The vote approving the purchase was unanimous with all three supervisors, including Gradizzi, present. b. The purpose of the purchase was to utilize the building as a township Senior Center. 70. On February 25, 2004, the board of supervisors bid out the Senior Center project. "Separate sealed BIDS to the Fox Township Supervisors for construction of a new Senior Center, including approximately 6,300 square foot facility, concrete foundation, walls and floors, general construction, site work, HVAC, plumbing and electrical work to be located at 365 Main Street, Kersey, PA, 15846, Elk County. The owner will receive bids at the Fox Township Municipal Building, located at 11 Irishtown Road, Kersey, PA 15846 until 2:00 p.m. local standard time on the 19 day of March 2004, publicly opened and read aloud at 4:00 p.m. during Fox Township Supervisor's meeting that same day. The work to be performed under one (1) contract. Bidders may submit proposals for the following: Contract No. 1 - General Construction" a. The advertisement was placed with publishers of the Courier- Express /Tri- County Sunday /Jeffersonian Democrat. 71. The bids were opened and awarded at the special meeting of the board of supervisors held on March 19, 2004. Gradizzi, 04 -033 Page 18 *The bid from Mazza Sheet Metal was for the HVAC only, and was therefore rejected. 72. The bid from Micale Construction, dated March 19, 2004, included a list of sub- contractors that would be used on the project. a. Pollino Excavating was named as the subcontractor who would perform the site work/excavating. 73. Micale Construction, located in Fox Township, subcontracts excavating work to Pollino Construction. a. b. Micale Construction Services, Inc. $ 856,000.00 Alternate #1 (paving) $37,420.00 Alternate #2 (food service equipment) $26,674.00 Alternate #3 (sidewalk ice melt) $6,485.00 J C Orr & Son, Inc. $1,025,598.00 Alternate #1 $41,089.00 Alternate #2 $28,173.00 Alternate #3 $ 6,940.00 Hallstrom Construction, Inc. $ 990,700.00 Alternate #1 $39,000.00 Alternate #2 $24,000.00 Alternate #3 $ 5,000.00 Mazza Sheet Metal, Inc. $ 125,250.00* Alternate #1 $ - - -- Alternate #2 $ - - -- Alternate #3 $ 8,970.00 Between January 2002 and May 2005, Pollino Excavating performed excavating services for Micale and was paid $376,297.00. During this period, work for Micale represented 45% of all Pollino work. 74. Gradizzi participated in the vote to award the contract to Micale Construction. a. The vote was unanimous, 3/0. 75. Micale Construction invoiced and was paid $976,909.50 by Fox Township as follows for work on the Senior Center. 76. Gradizzi signed two of the checks issued to Micale Construction for work performed on the Senior Center Project, including check #0646 in the amount of $107,364.00; and check # 0745 in the amount of $43,059.90. 77. Pollino received payments totaling $8,360.00 from Micale for work performed on the Senior Center. 78. Gradizzi operated Pollino equipment and received the prevailing wages rate for the hours he worked for Pollino Excavating on the Senior Center Project. a. Gradizzi was classified as an Operator — Class I. 79. Gradizzi's wages from Pollino for operating equipment on the Senior Center Project resulted in additional compensation of $740.41. a. Gradizzi received $740.41 more at prevailing wage rate than he would have received at his normal wage. 1. 127 hrs. @ $22.22/hr = $2,821.94 - $2,081.53 = $740.41. Gradizzi, 04 -033 Page 19 b. Gradizzi's regular rate of pay for Pollino was $16.39/hr. at the time the Senior Project work was performed. The following findings relate to Gradizzi's participation in awarding a prevailing wage contract to build a park concession stand to a business that employed his son. 80. In or around August 2001 the board of supervisors decided to award contracts for the construction of a park concession stand. a. The concession stand was included in the plans to develop the community park, and was one of the goals for 2001. b. The concession stand project was to be built following the prevailing wage guidelines. 81. At the September 10, 2001 board of supervisors meeting, a motion was made to advertise for bids for the concession stand for the new park, and fencing for the new fields and perimeter at the new park. a. The bids were to be opened at a special meeting on September 26, 2001. b. Gradizzi seconded the motion. c. The project was subject to prevailing wage requirements. 82. The following bids were received by the township in response to the advertisement of the Concession Stand Project. Kersey Builders $126,000.00 Excavating 8,000.00 Concrete 20, 000.00 Plumbing 8,500.00 Heating 9,500.00 Electric 8,000.00 Building Material 33,000.00 Labor Costs 39,000.00 Ruffner Enterprises $ 29,781.45 Concrete & Masonry (includes setting doorframes, etc.) Micale Construction Excavation, footers, floors, masonry, doors, overhead doors, stairs, floor hear, shutters, under floor plumbing (material & labor) $ 57, 000.00 Carpentry, electrical, plumbing and finish work $ 44,194.00 (materials) $ 50,000.00 (labor) Shirey Masonry Footer, floor, first floor, sidewalks, foundation $ 17,365.80 (material & labor) 83. At the September 26, 2001, meeting, Gradizzi made the motion and participated in the vote to award the concrete portion of the bid to Ruffner Enterprises, Inc., at the bid price of $29,781.45 for concrete and masonry; and the balance of the project to Kersey Builders at the bid price of $65,000.00. a. The motion was unanimously approved. Gradizzi, 04 -033 Page 20 84. At the time that Gradizzi participated in the award of the bid, his son, Robert Gradizzi, was employed by Kersey Builders. 85. Robert Gradizzi's employment with Kersey Builders began in or around the first week of August 2001, approximately one month prior to Randall Gradizzi's vote to award the contract to Kersey Builders. a. Ron Luchini hired Robert Gradizzi based on his observance of Robert Gradizzi's capabilities and work habits while they were both volunteering during the construction of the township park during the summer of 2001. b. Randall Gradizzi did not solicit employment for Robert Gradizzi with Kersey Builders. c. Robert Gradizzi continued to work for Kersey Builders through the late spring of 2002. 86. Weekly Payroll Certification forms submitted by Kersey Builders documented Robert Gradizzi as having worked 366.25 hours on the Concession Stand Project, earning $8,218.65 (366.25 hours @ $22.44 per hour) between 11/15/01 — 04/18/02. 87. Gradizzi participated in votes to approve payment of the bills which included the invoices submitted by Kersey Builders for the work performed on the concession stand. MEETING CHECK DATE # 12/05/01 378 01/07/02 386 02/06/02 394 03/06/02 409 04/03/02 413 04/03/02 415 05/01/02 430 08/07/02 464 Check No. Date AMOUNT $3,714.41 19, 338.30 7,591.70 14,134.22 9,000.00 11,447.99 13, 373.38 2,407.20 GRADIZZI'S ACTION Seconded — 3/0 Seconded — 3/0 Vote - 3/0 Seconded — 3/0 Seconded — 3/0 Seconded — 3/0 Vote - 3/0 Vote - 3/0 88. Gradizzi was one of three signatures on two of the checks issued to Kersey Builders from the Fox Township Supervisor's Landfill Host Fee Account, for work performed on the Concession Stand. Amount Signatures 378 12/05/2001 $ 3,714.41 M -JZ -RG 386 01/07/2002 $19,338.30 M -JZ -RG he following findings relate to Gradizzi participating in actions of the Fox Township Sewer Authority related to his employer, Pollino Excavating. 89. Gradizzi has served on the Fox Township Sewer Authority Board of Directors since January 4, 2000. a. Gradizzi was appointed by the board of supervisors to fill an unexpired term on the authority board which ended 12/31/02. b. At the January 6, 2003 reorganization meeting of the board of supervisors Gradizzi was reappointed to a five year term ending 12/31/07. Gradizzi, 04 -033 Page 21 90. Sewer authority board members are not compensated. a. The board consists of seven members appointed by the board of supervisors. 91. In or around June 2001, requests for bids were sent to six area excavating companies by Authority Clerk Juli Schlimm seeking quotes to serve as contractors. The requests for bids were sent to: Pollino Excavating Vollmer Brothers Excavating Dobson Excavating, Kronewetter Excavating Perry Casper Excavating David Badeau Excavating 92. The request for bids detailed in part the following: The Fox Township Sewer Authority seeks the submission of written bids from contractors /excavators willing to assist the authority from time to time in performing, as independent contractors, emergency repair work and /or normal repair or maintenance work to portions of the authority- operated community sewage collection system. Each bid submitted must detail the proposed hourly charge for contractor's services furnished for (1) labor and (2) equipment. Additionally, each bid must include proof of contractor's liability insurance (minimum coverage of $1,000,000) and workman's compensation insurance, such proofs either in the form of Certificates of Insurance or copies of Declaration Sheets evidencing such coverages in force through at least 12/31/00." 93. Raymond Pollino submitted a proposal to the Fox Township Sewer Authority on behalf Pollino Excavating, which detailed the following quote: Equipment $45.00 /hr. Labor $25.00 /hr. a. The proposal was undated. b. The proposal was signed by Raymond Pollino. c. A Certificate of Insurance accompanied the Proposal. 94. Pollino Excavating was the only contractor that submitted a bid in response to the request for bids. 95. At the July 11, 2000 authority board meeting, the board voted to award a contract to Pollino Excavating to provide excavating services to the authority on an as- needed basis. a. Gradizzi abstained on the vote to award the contract to Pollino Excavating. 96. Pollino Excavating was notified that it had been awarded the contracting work for the Fox Township Sewer Authority by letter dated 07/18/00. a. Receipt of the executed form was noted in the August 8, 2000, authority board meeting minutes. 97. Between November 2000 and August 2002, three checks totaling $2,774 were issued to Pollino Excavating from the authority revenue fund. Gradizzi, 04 -033 Page 22 98. Gradizzi was present at the authority board meetings and participated in the approval of the payments to Pollino Excavating. 99. Gradizzi did not sign any of the Fox Township Sewer Authority checks payable to Pollino Excavating. 100. Pollino Excavating has not performed any other work for the sewer authority since August 2002. 101. On February 22, 2002, the Fox Township Sewer Authority advertised for bids for the purchase of a used one ton truck. a. The specifications for the truck were prepared by Jerry Zimmerman, in his capacity as a member and chairman of the sewer authority. b. The basic use of the truck was to be for hauling sludge from the sewer plant to the landfill. c. Bids, due on 3/13/02 at 3:30 p.m., were opened on the same date at 6:00 p.m. 102. The specifications for the truck were listed as follows: Used one (1) ton with dump body and plow; 1995 -1998; 4x4, 8 cyl. Diesel motor with a turbo; 5 speed manual transmission; duel fuel tanks; under 50,000 miles; air conditioning; ten foot (10') aluminum or stainless steel dump body; Pintel hitch; eight foot (8') snow plow power angle; three (3) passenger bench seat; AM -FM stereo cassette clock; heavy duty front suspension package; manual locking hubs; power door locks /windows; interval wipers; roof clearance lights." 103. Pollino Excavating submitted the following quote for the used truck, at the price of $22,000.00. "1995 Ford f -350, 4x4, power stroke diesel motor, 5 speed manual transmission, duel fuel tanks, air conditioning, 10 ft. aluminum dump body; pintel hitch, 3 passenger bench seat, an -fm stereo, cassette, clock, power door locks /windows, interval wipers, roof clearance lights, heavy duty front suspension, manual locking hubs, 8 ft western power angle plow, 47,800 miles." a. Pollino's bid was the only one received by the authority in response to the advertisement. b. Pollino's truck was for sale prior to the advertisement by the township. 104. The Pollino bid was nearly identical to the authority specifications. 105. Gradizzi participated in the vote to approve the purchase of the truck from Pollino Excavating at the March 13, 2002, authority board meeting. a. The vote was 4/0/1. 1. Only five board members were present. b. Rudy Pollino abstained on the vote. 1. Rudy Pollino is the brother of Raymond Pollino. 106. Authority revenue fund check #3936, dated 03/25/02, was issued to Pollino Excavating in the amount of $22,000.00. Gradizzi, 04 -033 Page 23 a. The check was signed by authority board members Jerry Zimmerman and Carole Harshbarger. III. DISCUSSION: At all times relevant to this matter, the Respondent, Randall Gradizzi, (Gradizzi), has been a public official subject to the provisions of the Public Official and Employee Ethics Law, Act 9 of 1989, Pamphlet Law 26, 65 P.S. § 401, et seq., as codified by the Public Official and Employee Ethics Act, Act 93 of 1998, Chapter 11, 65 Pa.C.S. § 1101 et seq., which Acts are referred to herein as the "Ethics Act." The allegations are that Gradizzi, as a Fox Township Supervisor, violated Sections 1103(a) (conflict) and 1103(f) (contracting) of the Ethics Act: when he participated in actions and discussions of the Board of Supervisors resulting in private pecuniary benefits for himself, immediate family members or businesses with which he is associated, including but not limited to, the hiring of his sister as Recreation Park Director, and his brother as a full -time employee with the Road Department; when he participated in decisions of the Board of Supervisors to enter into contracts with Pollino Excavating, a business with which he is associated, when the contracts were in excess of $500 and entered into without an open and public process; when he approved payments to his employer, Pollino Excavating, in 2001 and 2002; when he participated in actions of the Board of Supervisors to approve a contract for the Senior Center to Micale Construction when Pollino Excavating was a subcontractor for Micale; and when, as a member of the Fox Township Sewer Authority, he participated in decisions to enter into contracts with Pollino Excavating in excess of $500 without an open and public process. Pursuant to Section 1103(a) of the Ethics Act quoted above, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest. The term "conflict of interest" is defined under Act 93 of 1998 as follows: 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. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official /public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official /public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1103(f) of the Ethics Act imposes certain restrictions as to contracting. Section 1103(f) of Act 9 of 1989 provides: Gradizzi, 04 -033 Page 24 Section 1103. Restricted activities (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 public 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 commenced within 90 days of the making of the contract or subcontract. 65 Pa. C. S. § 1103(f). Section 1103(f) of the Ethics Act provides in part that no public official /public employee or spouse or child or business with which he or the spouse or child is associated may enter into a contract with his governmental body valued at five hundred dollars or more or any subcontract valued at five hundred dollars or more with any person who has been awarded a contract with the governmental body with which the public official /public employee is associated unless the contract is awarded through an open and public process including prior public notice and subsequent public disclosure. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are reproduced above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. 1. The change of Gradizzi's work status from "emergency only" to "as- needed." Gradizzi has served on the three - member Board of Supervisors of Fox Township (Township) since January of 2000 and on the Board of Fox Township Sewer Authority (Authority) from January 2000 through June 2005. Gradizzi has also worked as the Township Assistant Roadmaster since June 2004. The Fox Township Board of Auditors annually meets to set the compensation for Supervisors working as Township employees. For the years 2000 through 2002, the auditors approved hourly wages for Gradizzi for work in emergency situations only. For the calendar years 2003 through 2005, Gradizzi's work status was changed to an as- needed basis. The action was taken by the Township Secretary, Kathleen Mosier, without any direction from Gradizzi or the other two Township Supervisors to make the change in Gradizzi's work status. Mosier did not advise the auditors of the change she made. Mosier changed Gradizzi's status because she believed Gradizzi would be operating equipment on Township projects. However, the Board of Supervisors never approved such a change and the auditors likewise did not notice or authorize the change in Gradizzi's work status. The auditors believed that Gradizzi would continue to work in emergency situations only. 2. The hiring of Gradizzi's sister, Debra Agosti, as Township Recreation Facilities Director. Gradizzi, 04 -033 Page 25 Around 2000, the Township began to develop a new park on property that was donated to the Township for such use. The plan entailed a community park with baseball, soccer and football fields, as well as rest rooms, a concession stand, a walking /bicycle track and parking. The Township received a $100,000 grant from DCNR for the development of the park. Gradizzi was proactive as to the development of the new park. In October of 2001, during a budget meeting, a discussion ensued regarding the creation of a recreational position with an estimated salary of $25,250. Gradizzi participated in the discussions at that meeting. In March of 2002, Gradizzi participated in the action of the Board of Supervisors to advertise in the Daily Press newspaper for a Recreational Facilities Director. One of the applicants for the position of Recreation Director was Debra Agosti, the sister of Gradizzi, who has served on the Township Recreation Board from September 2000 to the present. Although six resumes were received for the Recreation Director position, the Township Board of Supervisors did not interview any of the candidates. At a Board of Supervisors' Meeting in May of 2000, the Chairman announced that Debra Agosti had been hired as the Township Recreational Facilities Director. Although no vote was taken by the Board to approve Agosti's hiring, the announcement was preceded by an executive session at which all three supervisors, including Gradizzi, were present. Gradizzi participated in that executive session but did not advocate for the hiring of his sister. Agosti was initially hired on a part -time basis at $10 an hour with time and a half for all work over 40 hours. In October 2002, the Board announced that Agosti's status changed to full -time as Recreational Facilities Director with an annual salary of $21,840 plus benefits. No formal vote was taken to approve the change in Agosti's status but Gradizzi was present in the executive session when the action was taken. In January 2005, when Agosti's salary as Recreation Director was raised to $25,000, Gradizzi abstained on that vote. Gradizzi participated in the reorganizational meetings in January of 2003, 2004 and 2005 when the Board approved the payrolls for each respective year that encompassed all Township employees, including his sister. Gradizzi co- signed 53 payroll checks issued to Debra Agosti between May of 2002 and 2005. 3. The hiring of Gradizzi's brother, Joseph Gradizzi, to the Township road crew. In February 2003, Township Supervisor Zimmerman offered Gradizzi's brother, Joseph Gradizzi (Joseph) employment without any Board action to approve the hiring. Zimmerman knew that Joseph could operate equipment, drive trucks, weld, and repair trucks and equipment. Zimmerman, during an executive session in October 2003, asked the other Supervisors if he (Zimmerman) could hire Joseph as a full -time employee. Gradizzi participated at the executive session and told Zimmerman that he did not want his brother hired on the road crew. No vote was taken by the Board of Supervisors to approve the hiring of Joseph. Joseph was then hired. Gradizzi co- signed 33 payroll checks issued to his brother, Joseph, between February 2003 and June 2005. 4. Contracting between the Township and Pollino Excavating, a business with which Gradizzi is associated. Pollino Excavating has employed Gradizzi in a private capacity as an equipment operator for 12 years. Pollino Excavating is owned and operated by Raymond Pollino. Since Pollino owns various heavy equipment, the Township began renting such equipment from Pollino Excavating in 2001. In December 2001, Supervisor Zimmerman authorized the Township Road Department to begin a road widening project known as the Boone Mountain Road and Four Points Road Project (Project). When Zimmerman became Roadmaster in 2001, he changed the operations of the Road Department whereby he made decisions on management and the projects to be performed by the Road Department. Zimmerman talked to Gradizzi and Keller about paying Gradizzi as a Township employee to operate the Pollino Excavating equipment on Gradizzi, 04 -033 Page 26 the Township road projects. Zimmerman wanted to take such action because of a specific concern about Gradizzi, as an employee of Pollino Excavating, operating its equipment on Township jobs. In December 2001, Zimmerman had discussions with Pollino about leasing equipment. Zimmerman advised Pollino that he wanted to lease the equipment without an operator and use Gradizzi as a Township employee to operate such equipment. Pollino agreed to Zimmerman's rental proposal because the project was set up to be done during winter months when Pollino generally only had sporadic work. Zimmerman advised the Township secretary that Gradizzi would be working for the Township to operate equipment that would be rented by the Township from Pollino Excavating to work on Township road projects. Pollino Excavating leased equipment to the Township and submitted invoices between November 2001 and September 2002. Parenthetically, beginning in the Fall of 2002, Zimmerman changed his practice and began soliciting telephone quotes for equipment rentals for Township road projects. In the Fall of 2004, the Township publicly advertised for equipment rental prices for the Project. Two bids were received, one of which was from Pollino Excavating. In October 2004, the Board of Supervisors awarded the contract to Pollino Excavating with Gradizzi abstaining on the vote. The minutes of that meeting reflect a statement by Gradizzi that he was abstaining because his employer was one of the bidders. While operating Pollino equipment on the Township road projects, Gradizzi received compensation as a Township employee. However, in July 2004, Gradizzi ceased operating Pollino Excavating equipment in order to avoid any conflict of interest. Gradizzi participated in approving payments to Pollino Excavating in 2001 and 2002 totaling $35,853. Subsequently, Gradizzi began abstaining on votes after receiving information from the Solicitor that he should abstain on Pollino matters. Gradizzi co- signed six checks totaling $51,969 in authorized payments to Pollino. 5. The award of a Township contract to Pollino Excavating to construct a Township maintenance building. At the beginning of 2004, the Board of Supervisors decided to build a maintenance garage. The project was advertised in the Daily Press and Courier Express newspapers. The Township received two bids for the maintenance garage project from Hallstrom Construction and Micale Construction, the latter being the low bidder. A contract was awarded to Micale Construction in May 2004 on a 3 -0 vote with Gradizzi participating. Since the excavation and site preparation were not part of the bid specifications as a means to reduce costs, Gradizzi proposed a plan to demolish the existing structure by using an excavator. Pollino Excavating equipment was rented by the Township to do the site preparation for the maintenance garage. Such action was taken without any vote by the Board. Gradizzi participated in the decision to utilize Pollino. Gradizzi operated Pollino's Excavating equipment during the demolition and site preparation process. Although Gradizzi abstained on the vote to approve bills that included those from Pollino Excavating, he co- signed one check that was payable to Pollino Excavating equipment. In addition, Gradizzi was paid as a Township employee for operating Pollino's Excavating equipment during the site preparation for the project. Gradizzi received payment of $1,722.15 as a Township employee during the maintenance garage site preparation in operating the excavator rented from Pollino. 6. The award of a Township contract to a company that subcontracted with a business with which Gradizzi is associated. In June 2003, the Board of Supervisors approved the purchase of a Fox Township Senior Center from St. Bonafice Parish. Once the purchase was effectuated, it was necessary to construct a new Senior Center. In March, the Board voted to solicit bids for the Senior Center project. Gradizzi, 04 -033 Page 27 Subsequently, the bids were opened at a special meeting of the Board of Supervisors. Four different contractors were selected to perform various services on the Project. One of the contractors, Micale Construction, in its bid for the project, submitted a list of subcontractors that included Pollino Excavating. Micale Construction, as a matter of course, subcontracts excavating work to Pollino Construction. The contract to Micale Construction was approved by the Board in a 3 -0 vote with Gradizzi participating. Micale Construction performed services under the contract and submitted invoices to the Township. Gradizzi participated in the approval of payments to Micale Construction and co- signed two of the checks made in payment. Pollino Excavating, in turn, received payments from Micale for work performed on the Senior Center. Gradizzi operated Pollino equipment for the Project and received the prevailing wages for the hours he worked for Pollino Excavating. Gradizzi's wages from Pollino for operating the equipment on the Senior Citizen project totaled $740.41. 7. Township contract to build a park concession stand with a business that employed Gradizzi's son. In August 2001, the Board of Supervisors decided to bid a contract for the construction of a recreation park concession stand. In the following month, the Board of Supervisors passed a motion to advertise for bids for the concession stand and fencing for the fields. Bids were submitted by the following companies: Kersey Builders, Ruffner Enterprises, Micale Construction, and Shirey Masonry. In a September 2001 meeting, Gradizzi made a motion and participated in the vote to award the recreation park concession contract to two companies: Ruffner Enterprises for the concrete work and Kersey Builders to do the rest of the project. Gradizzi's motion passed by a unanimous vote. At the time the Township Board awarded the bid for the recreation park concession stand, Gradizzi's son, Robert Gradizzi (Robert), was employed by Kersey Builders. Although Robert's employment with Kersey Builders began about one month prior to the vote to award the Township contract, Gradizzi did not solicit such employment for his son with Kersey Builders. Robert worked 366.25 hours on the concession stand project as an employee of Kersey Builders. Kersey Builders submitted invoices and received checks from the Township. Gradizzi participated in the votes to approve the payment of bills that included invoices from Kersey Builders. Gradizzi also co- signed two of the Township checks and payments to Kersey Builders. 8. Participation by Gradizzi as a Township Sewer Authority Member as to matters involving Pollino Excavating. In June 2001, requests for bids were sent by the Township Authority Clerk to six area excavating companies for the performance of emergency repair or maintenance work on the Township Authority sewer system. Out of the six contractors who were contacted, only Pollino submitted a bid. Pollino presented a quote separating the equipment and labor costs for services. In July of 2000, the Authority Board voted to award the contract to Pollino Excavating to provide such services to the Township Authority on an as- needed basis. Gradizzi abstained on the vote to award the contract to Pollino Excavating. Although Gradizzi did not sign any Township Sewer Authority checks in payment to Pollino Excavating, he was present at Authority Board meetings and participated in the approval of payments to Pollino Excavating. In February 2002, the Township Authority advertised for bids for the purchase of a used one -ton truck. Pollino Excavating submitted a quote for the used truck, which was the only bid received by the Township Authority in response to its advertisement. Gradizzi participated in the vote to approve the purchase of the truck from Pollino Excavating. The motion passed on a 4 -0 -1 vote with Rudy Pollino, the brother of Raymond Pollino, Gradizzi, 04 -033 Page 28 abstaining. Gradizzi did not co -sign the check in payment to Pollino Excavating for the used truck. Having summarized the above relevant facts, we must now determine whether the actions of Gradizzi violated Sections 1103(a) and 1103(f) of Act 9 of 1989. The parties have entered into a Consent Agreement and Stipulation of Findings. The parties propose to resolve the case as follows: "3. The Investigative Division will recommend the following in relation to the above allegations: a. That no violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when Gradizzi participated in actions and executive session discussions of the board of supervisors resulting in his sister being hired to the position of Park Director; b. That no violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when Gradizzi participated in actions and discussions of the board of supervisors resulting in his brother being hired for a full -time position with the Road Department; c. That no violation of Sections 1103(a) and 1103(f) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §§ 1103(a) and 1103(f) occurred when Gradizzi participated in decisions of the board of supervisors to enter into contracts with Pollino Excavating for road widening projects which were in excess of $500 and entered into without an open and public process; d. That an unintentional violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when Gradizzi voted to approve payments and sign [sic] checks issued to Pollino Excavating. e. That an unintentional violation of Section 1103(f) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(f) occurred when Gradizzi participated in actions of the board of supervisors to approve a contract for the Senior Center to Micale Construction at a time when a business with which he is associated was subcontracting with Micale; f. That no violation of Sections 1103(a) or 1103(f) of the Public Official and Employee Ethics Law, 65 Pa.C.S. § §1103(a) or 1103(f) occurred when as a member of the Fox Township Sewer Authority, Gradizzi participated in decisions of the authority board of directors to enter into contracts with his employer, Pollino Excavating in excess of $500 without an open and public process. That a violation of Section 1103(a) and 1103(f) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) and 1103(f) occurred when Gradizzi participated in discussions of the board of supervisors leading to a contract in excess of $500 being awarded to Pollino Excavating for site preparation of the maintenance garage. h. That an unintentional violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when, as a member of the authority, Gradizzi voted to purchase a vehicle from his employer. g. Gradizzi, 04 -033 Page 29 Consent Agreement, ¶3. We shall apply the provisions of the Ethics Act to the eight separate scenarios in the order that they appear in the Fact Findings. Regarding the first allegation concerning Gradizzi's change in his work status with the Township from an emergency to an as- needed basis, it appears that the Investigative Division has chosen to exercise its prosecutorial discretion to non pros this as well as some of the other allegations, as for example, the Township concession stand contract. The second allegation concerns Gradizzi's involvement in the hiring of his sister Debra Agosti to the position of Township Recreation Facilities Director. The Board of Supervisors was in executive session when the decision was made to hire Gradizzi's sister. However, there is no factual information as to what actions Gradizzi took. Gradizzi was present at the October 2002 budget meeting when his sister's position became full - time with an annual salary plus benefits. At that executive session, there is no delineation as to the extent or nature of Gradizzi's participation. From the record in this case, the only definitive action by Gradizzi is that he signed some payroll checks issued to his sister for her work as Recreation Director. However, such appears to be routine, uncontested payroll expenditures. See, Krushinski, Order 168. Accordingly, Gradizzi did not violate Section 1103(a) of the Ethics Act as to the hiring of his sister as Township Recreation Facilities Director because there is no factual basis to establish a use of authority of office. Dixon, Order 1297. We will now consider the third allegation involving the hiring of Gradizzi's brother, Joseph, to a position on the Township road crew. As to whether there were any uses of authority of office on the part of Gradizzi, we have statements on his part that he did not want Zimmerman to hire his brother as a Township employee. Obviously, this use of authority of office was not to obtain any financial gain for his brother. As to Gradizzi's participation in the executive session when it was determined that his brother would be hired to a full -time position with the Township, he opposed the hiring. Lastly, we have Gradizzi's general participation in the approval process to pay routine payroll bills. Accordingly, Gradizzi did not violate Section 1103(a) of the Ethics Act as to the hiring of his brother, Joseph, a Township employee, because there is no factual basis to establish a use of authority of office. Dixon, supra. The next allegation for consideration concerns Gradizzi participating in the Township's contracting process with Pollino Excavating, a business with which Gradizzi is associated, without an open and public process. As to this allegation, we shall first consider Section 1103(f) of the Ethics Act as to contracting and then Section 1103(a) as to conflict. Under Section 1103(f) of the Ethics Act, the Boone Mountain Road widening project was not put out for bids by the Township. Supervisor Zimmerman authorized the rental of equipment from Pollino Excavating and then used Gradizzi as a Township employee to operate that equipment during the road widening project. In that Gradizzi is an employee of Pollino Excavating, it is a business with which he is associated. Beginning in the Fall of 2002, the contracts were solicited by telephone or through written quotes by Zimmerman. The contracts from the Fall of 2002 were in excess of $500 and were awarded through an open and public process as required by Section 1103(f) of the Ethics Act. Accordingly, Gradizzi did not violate Section 1103(f) of the Ethics Act when Pollino Excavating, a business with which Gradizzi is associated, entered into contracts with the Township which were in excess of $500 and were awarded through an open and public process. It appears that the contracting in 2001 was subject to a non pros by the Investigative Division. As to Section 1103(a) of the Ethics Act, it was the decision of Supervisor Zimmerman to undertake the road widening project and to utilize Pollino Excavating for the rental of equipment to be used on the project. It was also the decision of Supervisor Gradizzi, 04 -033 Page 30 Zimmerman to utilize Gradizzi as a Township employee to work on the road widening project using the equipment rented from Pollino Excavating. As to such actions, there were no uses of authority of office on the part of Gradizzi. Hence, Gradizzi did not violate Section 1103(a) of the Ethics Act as to the award of contracts to Pollino Excavating in that such actions were done by Supervisor Zimmerman alone without any use of authority of office by Gradizzi. However, Gradizzi voted on at least six occasions to approve payments to Pollino Excavating and co- signed at least six checks authorizing payments to Pollino Excavating. Accordingly, Gradizzi unintentionally violated Section 1103(a) when he participated in the approval of invoices from Pollino Excavating and co- signed checks in payment to Pollino Excavating, a business with which Gradizzi is associated. Stevenson, Order 1335. The next allegation concerns Gradizzi's actions as to the award of a contract to Pollino Excavating for the excavation work in preparation of the construction of a Township maintenance building. As to Section 1103(f) of the Ethics Act, the construction of the new maintenance garage for the Township was put out for bids but the excavation of site preparation was not part of the bid specifications. In an effort to reduce costs, the Board of the Supervisors made a determination that the excavation and site preparation would be done in -house whereby the Township would rent equipment and its employees would perform the work. The equipment was rented from Pollino Excavating without any action by the Board or advertisement for bids. Accordingly, Gradizzi violated Section 1103(f) of the Ethics Act when Pollino Excavating, the business with which he is associated, entered into a contract to rent equipment for the excavation and site preparation of a Township maintenance garage project when the contract was $500 or more and awarded without an open and public process. Andzulis, Order 1081. As to Section 1103(a) of the Ethics Act, the findings reflect that Gradizzi participated in the decision to utilize Pollino. The findings do not delineate the nature or extent of Gradizzi's involvement. Although Gradizzi abstained from the vote to approve payments of bills that included invoices from Pollino Excavating, he co- signed at least one check in payment to Pollino Excavating. As noted above, in that Gradizzi is an employee of Pollino Excavating, it is a business with which he is associated. Accordingly, Gradizzi violated Section 1103(a) of the Ethics Act when he participated in the decision to use Pollino Excavating and co- signed a check in payment to Pollino Excavating, a business with which he is associated, as to a Township project to build a maintenance garage. Stevenson, supra. The following allegation concerns Gradizzi's involvement as to the award of a Township contract regarding a senior citizen's center to a company that subcontracted with Pollino Construction. The record reflects that as to this Township project for the senior center, there was an open and public bid process as to the award of contracts for different aspects of the Project. One of the successful bidders was Micale Construction Services, Inc. Micale is a business with which Gradizzi is not associated. Micale then awarded a subcontract to Pollino Excavating to perform the site work/excavating. Based upon these facts, Gradizzi did not violate Section 1103(f) of the Ethics Act as to the award of a Township contract to Micale Construction Services that awarded a subcontract to Pollino Excavating, a business with which Gradizzi is associated, in that the contract was awarded through an open and public process and the subcontractor, but not the contractor, was a business with which Gradizzi is associated. Although the parties propose an unintentional violation of Section 1103(f), we believe, based upon our analysis above, that a result of no violation of Section 1103(f) is appropriate. Since our result is more favorable to Gradizzi, there is no legal issue in our modifying this particular aspect of the Consent Agreement. As to Section 1103(a) of the Ethics Act, it appears that the Investigative Division in the exercise of prosecutorial discretion has elected to non pros this allegation. The last allegation before us concerns actions by Gradizzi as a Sewer Authority Board member relating to Pollino Excavating, a business with which he is associated. The Gradizzi, 04 -033 Page 31 Township Authority Board advertised for bids for work that would involve emergency repairs, normal repairs and maintenance of the municipal sewer system. Pollino Excavating was the only contractor that submitted a bid in response to the advertisement by the Township. Pollino obviously obtained the contract. Gradizzi participated at Authority Board meetings in approving payments to Pollino Excavating, but did not co -sign any Authority checks. In another instance, the Township Authority Board advertised for bids for the purchase of a used truck. Once again, Pollino Excavating was the only business that submitted a bid. Gradizzi participated in the vote to approve the purchase of the truck from Pollino Excavating. Gradizzi did not violate Section 1103(f) of the Ethics Act as to the award of the contract to Pollino Excavating for the repair /maintenance work on the Authority sewer system in that the contract was awarded through an open and public process. Turning to Section 1103(a) of the Ethics Act, as to the maintenance /repair contract work for the Authority sewage system, Gradizzi abstained on the vote to award that contract. Accordingly, Gradizzi did not violate Section 1103(a) of the Ethics Act as to the award of a contract to Pollino Excavating, a business with which he was associated, as to a Township Authority to do repairs /maintenance work on the Township sewage system in that there was no use of authority of office by Gradizzi. Regarding the purchase of the used truck, the record reflects that Gradizzi participated in the vote to purchase the truck. Such was a use of authority of office. Juliante, Order 809. Even though Rudy Pollino, the brother of Raymond Pollino, who owned Pollino Excavating, abstained as a Board member, Gradizzi participated in the vote. Accordingly, Gradizzi unintentionally violated Section 1103(a) of the Ethics Act when he voted to purchase a used truck from Pollino Excavating, a business with which he was associated. Smith, Order 1147. We determine that the Consent Agreement submitted by the parties sets forth the proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. We would also note that if this case were in a different procedural posture, our analysis might yield different results as to certain allegations. However, this case is in the posture of a Consent Agreement and it is our view that overall, the resolution is fair and appropriate. In this regard, we believe the Board Chair is an individual who took charge of the Township with Gradizzi and the other supervisor passively following the lead of the Chair. Gradizzi's problems to a large extent arose because of this method of operation in the Township. We will take no further action in this case which is closed. IV. CONCLUSIONS OF LAW: 1. Randall Gradizzi, a Fox Township Supervisor and Sewer Authority Member, Elk County, is a public official subject to the provisions of Act 9 of 1989 as codified by Act 93 of 1998. 2. Gradizzi did not violate Section 1103(a) of the Ethics Act as to the hiring of his sister as Township Recreation Facilities Director in that there is no factual basis to establish a use of authority of office. 3. Gradizzi did not violate Section 1103(a) of the Ethics Act as to the hiring of his brother Joseph as a Township employee, in that there is no factual basis to establish a use of authority of office. 4. Gradizzi did not violate Section 1103(f) of the Ethics Act when Pollino Excavating, a business with which Gradizzi is associated, entered into contracts with the Gradizzi, 04 -033 Page 32 Township which were in excess of $500 in that the contracts were awarded through an open and public process from the Fall of 2002. 5. Gradizzi did not violate Section 1103(a) as to the award of contracts by the Board Chairman to Pollino Excavating, a business with which Gradizzi is associated, in that there was no use of authority of office by Gradizzi. 6. Gradizzi unintentionally violated Section 1103(a) when he participated in the approval of invoices from Pollino Excavating and co- signed checks in payment to Pollino Excavating, a business with which Gradizzi is associated. 7 Gradizzi violated Section 1103(f) of the Ethics Act when Pollino Excavating, the business with which he is associated, entered into a contract to rent equipment for the excavation and site preparation of a Township maintenance garage project when the contract was $500 or more and awarded without an open and public process. 8. Gradizzi violated Section 1103(a) of the Ethics Act when he participated in the discussion to use Pollino Excavating, and as to the bill approval process by co- signing a check in payment to Pollino Excavating, a business with which he is associated, as to a Township project to build a maintenance garage. 9. Gradizzi did not violate Section 1103(f) of the Ethics Act as to the award of a Township contract to Micale Construction Services that awarded a subcontract to Pollino Excavating, a business with which Gradizzi is associated, in that the contract was awarded through an open and public process and the subcontractor, but not the contractor, was a business with which Gradizzi is associated. 10. Gradizzi did not violate Section 1103(f) of the Ethics Act as to the award of the contract to Pollino Excavating for the repair /maintenance work on the Authority sewer system in that the contract was awarded through an open and public process. 11. Gradizzi did not violate Section 1103(a) of the Ethics Act when he participated in the approval of payments to Pollino Excavating, a business with which he was associated, as to a Township Authority contract for Pollino Excavating to do repairs /maintenance work on the Township sewage system in that Gradizzi abstained on the award of the contract. 12. Gradizzi unintentionally violated Section 1103(a) of the Ethics Act when he voted to purchase a used truck from Pollino Excavating, a business with which he was associated. In Re: Randall Gradizzi ORDER NO. 1379 File Docket: 04 -033 Date Decided: 9/12/05 Date Mailed: 9/21/05 1 Randall Gradizzi ( "Gradizzi "), a public official in his capacity as a Fox Township Supervisor and Sewer Authority Member, Elk County, did not violate Section 1103(a) of the Ethics Act as to the hiring of his sister as Township Recreation Facilities Director in that there is no factual basis to establish a use of authority of office. 2. Gradizzi did not violate Section 1103(a) of the Ethics Act as to the hiring of his brother Joseph as a Township employee, in that there is no factual basis to establish a use of authority of office. 3. Gradizzi did not violate Section 1103(f) of the Ethics Act when Pollino Excavating, a business with which Gradizzi is associated, entered into contracts with the Township which were in excess of $500 in that the contracts were awarded through an open and public process from the Fall of 2002. 4. Gradizzi did not violate Section 1103(a) as to the award of contracts by the Board Chairman to Pollino Excavating, a business with which Gradizzi is associated, in that there was no use of authority of office by Gradizzi. 5. Gradizzi violated Section 1103(f) of the Ethics Act when Pollino Excavating, the business with which he is associated, entered into a contract to rent equipment for the excavation and site preparation of a Township maintenance garage project when the contract was $500 or more and awarded without an open and public process. 6. Gradizzi unintentionally violated Section 1103(a) when he participated in the approval of invoices from Pollino Excavating and co- signed checks in payment to Pollino Excavating, a business with which Gradizzi is associated. 7 Gradizzi violated Section 1103(a) of the Ethics Act when he participated in the discussion to use Pollino Excavating, and as to the bill approval process by co- signing a check in payment to Pollino Excavating, a business with which he is associated, as to a Township project to build a maintenance garage. 8. Gradizzi did not violate Section 1103(f) of the Ethics Act as to the award of a Township contract to Micale Construction Services that awarded a subcontract to Pollino Excavating, a business with which Gradizzi is associated, in that the contract was awarded through an open and public process and the subcontractor, but not the contractor, was a business with which Gradizzi is associated. 9. Gradizzi did not violate Section 1103(f) of the Ethics Act as to the award of the contract to Pollino Excavating for the repair /maintenance work on the Authority sewer system in that the contract was awarded through an open and public process. 10. Gradizzi did not violate Section 1103(a) of the Ethics Act when he participated in the approval of payments to Pollino Excavating, a business with which he was associated, as to a Township Authority contract for Pollino Excavating to do Gradizzi, 04 -033 Page 34 repairs /maintenance work on the Township sewage system in that Gradizzi abstained on the award of the contract. 11. Gradizzi unintentionally violated Section 1103(a) of the Ethics Act when he voted to purchase a used truck from Pollino Excavating, a business with which he was associated. BY THE COMMISSION, Louis W. Fryman, Chair