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Advisory opinion regarding the application of the post-employment provisions to an employee of the Louisiana Office of Broadband Development and Connectivity ("ConnectLA") |
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Mr. Tyler's employment terminated with Louisiana Office of Broadband Development and Connectivity ("ConnectLA") on February 27, 2026. Mr. Tyler served as Deputy Director of ConnectLA, but he was not an agency head; that position was held by Executive Director Veneeth Iyengar.
While employed as Deputy Director of ConnectLA, Mr. Tyler served in a programmatic and operational role, in which he oversaw compliance frameworks, federal reporting, and program design relating to Louisiana's Broadband Equity, Access, and Deployment ("BEAD") Program. Subgrantees to the BEAD Program were not selected in a discretionary manner by either Mr. Tyler or any other ConnectLA employee. Rather, subgrantees were awarded funds according to CostQuest's GrantLight platform, which used an algorithm to analyze cost-per-location criteria applied uniformly for all applicants.
Mr. Tyler now owns a consulting firm called C207 LLC, for which the scope of work includes: (1) mapping and managing relationships with municipalities, police juries, and parish governments across the client's deployment footprint; (2) facilitating pre-construction engagement with local officials to set mutual expectations and support permitting coordination; (3) managing a proactive communications program during the construction phase to ensure over-communication with local governments and communities; and (4) stewarding post-construction relationships between the client and the local governments in its service area.
Mr. Tyler has been approached by Swyft Fiber, a Louisiana BEAD subgrantee, in solicitation of his services through C207 LLC. The proposed scope of work does not involve advocating before ConnectLA, the National Telecommunications and Information Administration, or any state or federal broadband oversight body on behalf of Swyft Fiber. It also does not involve seeking additional funding, modifications to Swyft's subgrant award, or any adjustment to compliance measurements. All work by C207 LLC would be directed at the local government and community layer of Swyft's deployment operations.
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La. R.S. 42:1121B(1) provides no
former public employee shall, for a period of two years following the
termination of his public employment, assist another person, for compensation,
in a transaction, or in an appearance in connection with a transaction in which
such former public employee participated at any time during his public
employment and involving the governmental entity by which he was formerly
employed, or for a period of two years following termination of his public
employment, render, any service which such former public employee had rendered
to the agency during the term of his public employment on a contractual basis,
regardless of the parties to the contract, to, for, or on behalf of the agency
with which he was formerly employed.
Ethics Board Docket No. 2025-796: R.S. 42:1121B(1) does not prohibit
the former reserve deputy from rendering on a contractual basis, within two
years of his termination of service, new services to the Marshal's Office that
he has not previously rendered to, for, or on behalf of the Marshal's Office.
Ethics Board Docket No. 2017-614: R.S. 42:1121B does not prohibit a
former Local Government Assistant with the Office of Community Development from
assisting, within two years of termination of her public service, an
engineering consultant firm with new grant applications that she did not
participate in while a public servant.
Ethics Board Docket No. 2016-271: R.S. 42:1121B
does not prohibit a former Licensing Specialist with the Louisiana Department
of Education, which role included inspection of daycare facilities for compliance,
from owning and operating a daycare center, even though it would be licensed by
and supervised by the Department of Education.
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Adopt proposed advisory opinion.
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| Assigned Attorney: |
Kelsey Simmons |
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