I would like to thank letter writer Ryan Whitney [“Conflicts of interest, constantly ignored,” Recorder, April 1] for allowing me to give real world examples of how the commonwealth’s Conflict of Interest law works.  Prior to our March 26 deliberations, several members of the Greenfield Community Preservation Committee (CPC) contacted the State Ethics Commission about any possible conflict of interest questions that might arise as we approached our discussions.  As a result, I can say with great confidence that the March 26 CPC meeting followed the state requirements.

The letter, however, gives me the opportunity to explain how these rules work in relation to specific situations and that is always helpful. Since the letter writer concentrated upon my own situation, I will endeavor to specifically address those issues.

Mr. Whitney notes the letters of support submitted by Housing Greenfield to the CPC  were signed by me. At the time of the writing of those letters, Housing Greenfield had not fully developed its present 3-person coordinating committee. As I was the official coordinator of our monthly meetings of 15-20 active members, I was asked by these members to write letters of support to the CPC expressing the group’s sentiments regarding several projects. The letters were on Housing Greenfield stationery and were signed by me as coordinator of the organization, not by myself as an individual. This was the appearance of a conflict of interest, but as I was representing an organization did not demonstrate a true conflict, as was verified by the Ethics Commission. In the future, another member of the coordinating committee would sign such letters to obviate even the appearance of conflict.

I am a commissioner of the Greenfield Housing Authority (GHA) and a member of the board of Greenfeld Housing Associates Inc. (GHAI).  GHAI is a private not-for-profit organization that is affiliated with the GHA but has a separate board. That board has some GHA members on it but votes independently and on a different agenda than the GHA.  (This is also true of Rural Development Inc., RDI, that is discussed below.)  Although not required by state ethics law, I determined that I would not vote or be involved in the discussion of the projects submitted to the CPC by the GHA and GHAI to avoid the appearance of conflict.  For the record, based upon community comments and other members’ analyses of the projects, the CPC voted to fund the GHA project and not fund GHAI’s project. 

Mr. Whitney is correct that I was on the board of commissioners of the Franklin County Regional Housing and Redevelopment Authority (FCRHRA), the affiliate of Rural Development Inc .(RDI).  I left that position two years ago. Similar to GHAI, RDI has a board that is independent of but connected to FCRHRA. I was never on the RDI Board. There was no conflict of interest in either the Housing Greenfield letter of support or my participation in the discussion of that project at the March 26 CPC meeting because I do not have any interest in the project other than one as an involved citizen. I, therefore, was part of the discussion and the vote.

Ethics questions like these require separating out real from perceived conflicts. That is often difficult. When we have doubts, members of the CPC and other city boards are encouraged to contact the lawyers of the State Ethics Commission to ensure that we are approaching the issue at hand correctly. And we do so.

I appreciate the opportunity to both discuss the complicated nature of these concerns and how they manifest themselves in real life discussions on the committee level.

Susan Worgaftik is chair of the Greenfield Community Preservation Committee.