I would like to take this opportunity to clarify my answers to two of the questions on your
Committee's questionnaire for Presidential nominees. Accordingly, I am providing the
following information:

Question 25. Explain how you will resolve any potential conflict of interest that may be disclosed by your responses to this form and the attachments thereto. Attach a statement of the appropriate agency ethics official explaining the applicable laws or regulations, any potential conflicts, and the action required to resolve such conflicts.

Answer: I will abide by the advice of the Designated Agency Ethics Official. Please see the enclosed statement dated July 29, 1997, from the Department of Energy's Designated Agency Ethics Official.

Question 26. Explain how you will resolve any potential conflicts of interest that may arise in the future if you are confirmed for the position for which you have been nominated.

Answer: I will consult with the Designated Agency Ethics Official of the

Department of Energy and follow his advice to avoid any real or perceived conflicts of interest.

If you or your staff require anything further concerning this matter, please contact me at
(202) 586-9500.

This memorandum is intended to serve as a statement from the
designated agency ethics official for this Department, as
required by the Statement for Completion by Presidential Nominees
that you are submitting to the United States Senate Committee on
Energy and Natural Resources in connection with your nomination
to the position of Assistant Secretary for Congressional and
Intergovernmental Affairs. I have reviewed your Executive Branch
Public Financial Disclosure Report (Standard Form 278) dated July
21, 1997, and have certified that the information contained
therein discloses no conflict of interest under applicable laws
and regulations.

Section 208, title 18, United States Code, prohibits a Federal
officer or employee from participating personally and
substantially, as a Government employee, in any particular matter
in which, to his knowledge, he has, or his spouse, minor child,
general partner, organization in which he is serving as officer,
director, trustee, general partner, or employee, or any person or
organization with whom he is negotiating or has any arrangement
concerning prospective employment has, a financial interest.
Your spouse is employed at the law firm of O'Neill, Athy & Casey.
You have agreed to recuse yourself from participation, as a
Government employee, in any matter that would have a direct and
predictable effect upon the financial interests of O'Neill, Athy
& Casey or any other entity in which you have a financial
interest within the meaning of section 208.

Further, the Standards of Ethical Conduct for Employees of the
Executive Branch prohibit you from participating in a particular
matter in which a client of your spouse is a party, if the
circumstances would cause a reasonable person with knowledge of
the relevant facts to question your impartiality in the matter (5
C.F.R. S 2635.502(a)). However, I have determined that a
reasonable person with knowledge of the relevant facts would not
question your impartiality in such a matter, unless your spouse's
firm represents the client in the particular matter.
Accordingly, you have further agreed to recuse yourself from
participation as a Government employee in any matter in which the
firm is a party or represents a party.

In addition, you have received a copy of the United States Senate Committee on Energy and Natural Resources Recusal Policy," dated May 6, 1993. You have agreed to adhere to the Committee's recusal policy upon appointment to the position of Assistant Secretary for Congressional and Intergovernmental Affairs.

You should also be aware that Executive Order 12674, as modified by Executive Order 12731, prohibits employees appointed by the President to positions in the executive branch from receiving outside earned income during the term of the Presidential appointment. Further, title V of the Ethics in Government Act of 1978 (Pub. L. No. 95-521, as amended by Pub. L. No. 101-194) contains restrictions on the outside activities of certain Government employees including those appointed by the President. Specifically, section 502 of the Ethics in Government Act provides that such an employee may not permit his name to be used by any entity which provides professional services involving a fiduciary relationship, whether or not compensation is received for such activity.

Finally, as required by Executive Order 12834, you have agreed to sign a Senior Appointee Pledge upon your appointment. The pledge describes certain post-employment restrictions that will be applicable to you when you terminate your Government service. Please let me know if I can be of further assistance.

Кания.

Ralph D. Goldenb

This memorandum is intended to serve as a statement from the
designated agency ethics official for this Department, as
required by the Statement for Completion by Presidential Nominees
that you are submitting to the United States Senate Committee on
Energy and Natural Resources in connection with your nomination
to the position of Assistant Secretary for Congressional and
Intergovernmental Affairs. I have reviewed your Executive Branch
Public Financial Disclosure Report (Standard Form 278) dated July
21, 1997, and have certified that the information contained
therein discloses no conflict of interest under applicable laws
and regulations.

Section 208, title 18, United States Code, prohibits a Federal
officer or employee from participating personally and
substantially, as a Government employee, in any particular matter
in which, to his knowledge, he has, or his spouse, minor child,
general partner, organization in which he is serving as officer,
director, trustee, general partner, or employee, or any person or
organization with whom he is negotiating or has any arrangement
concerning prospective employment has, a financial interest.
Your spouse is employed at the law firm of O'Neill, Athy & Casey.
You have agreed to recuse yourself from participation, as a
Government employee, in any matter that would have a direct and
predictable effect upon the financial interests of O'Neill, Athy
& Casey or any other entity in which you have a financial
interest within the meaning of section 208.

Further, the Standards of Ethical Conduct for Employees of the
Executive Branch prohibit you from participating in a particular
matter in which a client of your spouse is a party, if the
circumstances would cause a reasonable person with knowledge of
the relevant facts to question your impartiality in the matter (5
C.F.R. S 2635.502(a)). However, I have determined that a
reasonable person with knowledge of the relevant facts would not
question your impartiality in such a matter, unless your spouse's
firm represents the client in the particular matter.
Accordingly, you have further agreed to recuse yourself from
participation as a Government employee in any matter in which the
firm is a party or represents a party.

In addition, you have received a copy of the United States Senate Committee on Energy and Natural Resources Recusal Policy," dated May 6, 1993. You have agreed to adhere to the Committee's recusal policy upon appointment to the position of Assistant Secretary for Congressional and Intergovernmental Affairs.

You should also be aware that Executive Order 12674, as modified by Executive Order 12731, prohibits employees appointed by the President to positions in the executive branch from receiving outside earned income during the term of the Presidential appointment. Further, title V of the Ethics in Government Act of 1978 (Pub. L. No. 95-521, as amended by Pub. L. No. 101-194) contains restrictions on the outside activities of certain Government employees including those appointed by the President. Specifically, section 502 of the Ethics in Government Act provides that such an employee may not permit his name to be used by any entity which provides professional services involving a fiduciary relationship, whether or not compensation is received for such activity.

Finally, as required by Executive Order 12834, you have agreed to sign a Senior Appointee Pledge upon your appointment. The pledge describes certain post-employment restrictions that will be applicable to you when you terminate your Government service. Please let me know if I can be of further assistance.

Кания.

denberg

Ralph D. Goldenb

be

45-882 98-7