British Columbia Tory MP Kerry-Lynne Findlay wrote to Public Works Minister Rona Ambrose last year encouraging her to get her department to enter into talks to renew its lease on a building owned by a constituent.
Findlay was the parliamentary secretary to the minister of justice at the time she wrote the letter. She has since been promoted to associate minister of national defence, where she is responsible for military procurement.
She signed her letter as both the member of Parliament for Delta-Richmond East and as parliamentary secretary.
Findlay also included a handwritten message to Ambrose at the bottom of the letter.
"I endorse this request and thank you for your consideration. K.F."
The Canadian Press obtained the letter and other correspondence under the Access to Information Act.
Terence Scheltema, a spokesman for Findlay, said the ethics commissioner was notified Friday after The Canadian Press raised the matter.
"At the time, Ms. Findlay was writing as a member of Parliament. The use of Parliamentary Secretary in the signature block was an administrative error that has since been rectified," Scheltema wrote in an email.
"Minister Findlay has proactively disclosed this to the ethics commissioner."
Ethics commissioner Mary Dawson's office confirmed the matter was brought to its attention on Friday.
"Generally speaking, we can't comment on individual cases," spokeswoman Sherry Perreault said.
"What I can do is confirm that Ms. Findlay did contact the office and that we're following up."
Section 9 of the Conflict of Interest Act prohibits ministers and parliamentary secretaries from using their positions to try to sway decisions when doing so would improperly advance another person's private interests.
A somewhat similar situation earlier this year got Finance Minister Jim Flaherty in trouble with Dawson.
She said it was "improper" of Flaherty to have written a letter to the federal broadcast regulator in support of a local company's bid for a radio licence. Dawson ordered him not to do it again without first getting permission from her office.
The ethics commissioner also issued compliance orders to two other parliamentary secretaries, Conservative MPs Eve Adams and Colin Carrie, for their letters to the CRTC in support of applications by two radio stations for broadcasting licenses.
Dawson also made it clear in those compliance orders that "writing such a letter would be improper regardless of whether or not you explicitly identified yourself as a parliamentary secretary."
The Flaherty episode prompted the Prime Minister's Office to order all cabinet ministers to review their files. In doing so, Conservative MP John Duncan found a letter he wrote to a tax court judge on behalf of a constituent and promptly resigned his post as aboriginal affairs minister.
In Findlay's case, she wrote to Ambrose last June about one of her constituents, Mike Salvatore, whose company leases a building to the federal government.
Citizenship and Immigration Canada uses the building in Vegreville, Alta., as a case-processing centre.
But the lease is set to expire in 2014 and Salvatore wanted to negotiate a new, long-term lease with Public Works, Findlay explained to Ambrose. He also wanted to do some work on the building.
"To obtain the financing necessary for the improvements, Mr. Salvatore is respectfully requesting that a longer lease be negotiated and that these negotiations begin soon," Findlay wrote.
She also copied Salvatore and Citizenship and Immigration Minister Jason Kenney on the letter.
Ambrose replied about two weeks later. In the address part of the letter, she identified Findlay as both an MP and a parliamentary secretary
"Please be assured that your constituent's request will be given every consideration," Ambrose wrote.
Amber Irwin, a spokeswoman for Ambrose, said the minister had nothing to do with the lease decision.
"We have confirmed the letter from Minister Ambrose to Minister Findlay was a standard high-level response letter confirming receipt," Irwin wrote in an email.
"The minister did not in any way influence the decision on the lease extension; it was handled by department officials."
Public Works followed up with Salvatore at least twice, the documents show. A senior official wrote to him in mid-August to let him know Citizenship and Immigration was still figuring out if it would renew the lease. That letter references another recent conversation between Salvatore and department officials.
Public Works confirmed the lease has been extended to 2019.
"PWGSC exercised the five-year option to extend the current lease and is finalizing the increase of the rent in accordance with the terms of the option and consistent with the Consumer Price Index," spokesman Sebastien Bois wrote in an email.
Elections Canada records show Salvatore made two donations to Findlay's local riding association shortly after the letter was sent to Ambrose: $115.92 on July 12, 2012, and $500 on Sept. 6, 2012.
Salvatore did not reply to an email or a message left on his cellphone.
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