Notice from the (former) Town Hall Building Committee Chair
On October 31, 2024, the Town was notified by the Connecticut Department of Housing that my position as Director of Special Projects, with primary responsibility for managing the Town Hall renovation project, was in violation of a Federal regulation regarding conflict of interest. The DOH was acting in its role as administrator of a $1.5 million Community Development Block Grant, which is funded by the Federal Department of Housing and Urban Development (HUD). Its reasoning was that I was First Selectman at the time of application for the grant, and therefore could not receive any financial benefit from it, even as a town employee paid with town funds, on the grounds that I might have arranged the grant in order to put money in my own pocket.
The grant has not been finalized yet, and the DOH threatened to withdraw funding so long as I was working for pay in any capacity related to the project. The Department of Economic Development, which has awarded $1.181 million from the Community Investment Fund, held up on finalizing those grants pending, among other matters, the resolution of the issue. The project was therefore effectively suspended until either I was removed from my position or the DOH decision was reversed.
The Federal regulation (CFR 24 570.611) allows HUD to grant exceptions in limited cases, under specific conditions. These include that the exception provide a “cost benefit or…expertise to the program that would not otherwise be available,” and that “hardship will result to the recipient…when weighed against the public interest served by avoiding the prohibited conflict.”
The Town hired an attorney who argued that my involvement in the project from the beginning gave me a unique expertise that would be expensive to replace, especially since I am getting paid $45/hour, much less than what managers of similar projects generally charge. Taken together, this gave the public an interest that outweighed the conflict. Our attorney also noted that the regulation only applies after a contract is signed for the grant (which it has not been), and that the restriction expires one year after the official leaves office, which in my case was November 21, 2023, so it should not even apply now.
In addition, we provided information indicating that DOH had previously determined that so long as I was not paid from their grant, the arrangement was valid. We also pointed out that I had had numerous meetings and emails with DOH both during my time as First Selectman and in the year since I took the position, so they had been fully aware of my change in roles. Making this decision now, when the project is at a critical juncture and a leadership change would have maximum impact, was not only capricious, but would also likely result in the extra costs that delays and confusion can cause.
In considering the case, HUD indicated that it would defer to DOH. On December 20, that agency ruled that an exception would not be granted; it did not address the one-year question. DOH did not explain either of these outcomes, but it does not have to. There may be a way to seek due process, but that would cost time and money that we do not have. As a result, I made the very difficult decision to resign from my job. I am also resigning from the Building Committee because in the absence of any coherent explanation for this outcome, I cannot assure the Town that my continued presence in any capacity will not cause problems as the project proceeds. The Committee held an emergency meeting on December 23, at which I notified them of these events and of my decision. They are in the process of formulating an approach to hiring a replacement. In the meantime, Dana Barrow has agreed to assume my duties.
With this issue resolved, the grants—which now total nearly $3.5 million—can be finalized and reimbursement begin. The architect has nearly finished the building plans, the grant consultants are working on the project manual, our lawyers are finalizing the contracts, and we are on target for going out to bid early next year. The renovation will transform the Town Hall into a modern, useful, accessible space, while maintaining its essential historic features. Working on it to this point has been mostly a labor of love, so leaving it is heartbreaking, especially insofar as it calls my integrity into question. But the Building Committee comprises people with excellent skills, and Dana is not only a fire marshal and building official, but also ran the firehouse construction project, so he has plenty of experience in these matters.
It’s been a pleasure to serve the Town in one capacity or another for the last 40 years. It’s been one of the best things I’ve done with my life. But I am confident that the Town Hall renovation is in good hands. When it is finished, we will have a building we can be proud of, and at very little local expense. While grant funding has its downsides—the current situation being a case in point—in the end, I am sure it will prove worthwhile.
Please feel free to ask me questions or send me your thoughts at gxgre@sbcglobal.net.