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2019-323
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Last modified
7/12/2021 10:14:45 AM
Creation date
4/16/2019 3:07:09 PM
Metadata
2019-323
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2019-323
Requesting Party
CSRS, Inc.
Decision Date
4/12/2019
Law
La. R.S. 42:1121
Caption
Advisory Opinion whereby the Code of Governmental Ethics would not prohibit CSRS, Inc. from responding as a prime contractor to the Louisiana Land Trust's Request for Qualification Statements for Phase III Engineering Design and Related Service for the Resettlement of Isle de Jean Charles (Phase III) while also subcontracting with the Office of Community Development Disaster Recovery Unit to provide grant management services since neither CSRS or the former employee participated in any aspect of Phase III.
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In August 2017, CSRS requested and received an opinion from the Ethics Board BD # 2017-887 <br /> that CSRS was able to respond as prime contractor to the OCD-DRU's Request for Proposals for <br /> Community Master Planning and Program Development for the Isle de Jean Charles ("Phase II") <br /> while it also sought to act as a subcontractor to the State's Request for Proposals for Disaster <br /> Grant Management Services for recovery efforts other than the Resettlement of Isle de Jean <br /> Charles. Phase II is complete. <br /> The Road Home Corporation dba the Louisiana Land Trust (LLT) is a nonprofit corporation <br /> created to take title to properties purchased by the Road Home Homeowner Assistance Program, <br /> among other purposes. It is chartered under La. R.S. 40:600.61 et. seq., and through the <br /> operation of Section 600.65 for the purposes of the Code of Governmental Ethics. <br /> In January 2018, OCD entered into a Cooperative Endeavor Agreement with the Louisiana Land <br /> Trust ("LLT") to provide a range of services including the implementation of activities related to <br /> Phase III, including all procurement for required professional services. On January 16, 2019, <br /> LLT issued the RFQ for Phase III of the Isle de Jean Charles project. The RFQ was open to the <br /> general public to bid, and CSRS did not participate in any way developing or drafting the RFP. <br /> PAE provided input to LLT in preparing the RFQ and a principal of PAE served in an advisory <br /> capacity to LLT's panel which evaluated the RFQ responses. CSRS did not provide input in the <br /> preparation of the RFQ and no one at CSRS served in an advisory capacity to LLT's evaluation <br /> panel. CSRS has submitted a proposal and would like to serve as Contractor on Phase III of the <br /> Isle de Jean Charles project. <br /> Initially, CSRS's qualifications statement proposed to utilize Stacy Bonnaffans the project to be <br /> responsible for CDBG-NDR compliance but subsequently decided that Stacy Bonnaffans would <br /> not participate in or be involved in any way in CSRS's delivery of services with respect to Phase <br /> III. <br /> Ms. Bonnaffans did not participate in any discussion or review of any aspect of Isle de Jean <br /> Charles Phase III or its funding through NDR during her tenure as staff of OCD. However, the <br /> discussion or review of Requests for Qualifications or Requests for Proposals were ever <br /> involved, nor any interaction with Louisiana Land Trust. <br />
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