BAY COUNTRY ESTATES HOMEOWNERS ASSOCIATION, INC. 6343 Meadowland Drive P. O. Box 444 Dunkirk, MD 20754-9535 Tracy's Landing, MD 20779-0444 Home: 301-855-7009 Work: 202-606-2554 BOARD OF DIRECTORS President Ivan (John) Petric Vice-President Stephen E. Coleman Members Jeffrey D. Ludwig Susan M. Reed Treasurer Dale C. Williams Secretary Howard J. Klayman July 20, 1998 Mr. Daniel P. Gahagan Executive Secretary, Public Service Commission of Maryland 6 Saint Paul Street, 16th Floor Baltimore, MD 21202-6806 SUBJECT: Case # 8772, Investigation and Hearing on Expanded Calling Areas for Southern Maryland, et.al. Dear Mr. Gahagan: Enclosed for filing is the original and sixteen (16) copies of Testimony in the above referenced proceeding, along with a disk version of the filing formatted in WordPerfect 5.1, entitled "July8772.wpd". If you have any questions regarding this filing, please do not hesitate to contact me. Your cooperation in this matter is appreciated. Thank you. Sincerely, Ivan (John) Petric President Enclosures cc: Parties of Record BEFORE THE MARYLAND PUBLIC SERVICE COMMISSION Order No. 73658 In the Matter of the Commission's * Investigation Into Expansion of * Case No. 8772 Local Calling Area Boundaries * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * TESTIMONY OPPOSING BELL ATLANTIC'S AND PSC'S STAFF JOINT PROPOSAL FROM IVAN (JOHN) PETRIC CHARLENE L. COHEN, RONALD A. ISAACSON ALFONSO DIAZ DEL CASTILLO, JAMES H. CRAWFORD, WAYNE DERNONCOURT, DAVID F. HALE, JANET L. HALL, RICHARD D. LAWRENCE, et.al. FOR CONSUMERS AND COMMUNITIES IN SOUTHERN MARYLAND AND SURROUNDING COUNTIES IN ANNE ARUNDEL, CALVERT, CHARLES, PRINCE GEORGES, SAINT MARY'S, MONTGOMERY, ETC. July 20, 1998 TESTIMONY OF PETITIONERS Petitioners Ivan (John) Petric, Charlene L. Cohen, Ronald A. Isaacson, Alfonso Diaz Del Castillo, James H. Crawford, Wayne Dernoncourt, David F. Hale, Janet L. Hall, Richard D. Lawrence, et.al., hereby submit their initial comments in the above captioned case. I. INTRODUCTION As discussed in greater detail below, the Petitioners submit that the record evidence in this proceeding overwhelmingly supports the granting of each of the three pending Petitions requesting certain specified expanded local calling areas for their communities in the counties stated herein. Not only does the overwhelming testimony presented in this docket clearly establish that true Communities of Interest today exist between the requesting communities as represented by the Petitioners and the territories they would reach through the requested expanded calling areas, but also that in so approving the Commission could significantly aide customers in preserving the numbering resource (since by expanding local calling areas the Commission in turn could follow in the footsteps of such jurisdictions as Colorado and correspondingly consolidate rate centers. Such consolidation in turn is a well-recognized vehicle for greatly slowing the attrition of available numbers without the need for further overlays and/or geographic splits). Furthermore, the record does not support application of the "traditional" "Community of Interest" test -- which has relied on certain observable calling patterns by at least 50% of the affected populace -- as developed in the pre-Internet, pre- Telecommunication Act of 1996 ("the Act"). The record also does not justify adopting the hasty, last-minute FX "compromise" that Staff and Bell Atlantic unilaterally seek to have this Commission impose on the Petitioners, which would leave the Petitioners, and all like affected customers (principally end users), hostage to extortionate FX rates for another year and half, at a minimum, and in certain cases perhaps significantly longer should the "traditional" Community of Interest test advocated by Bell Atlantic and the PSC's Staff are not thereafter satisfied. There is no credible cost data underwriting this last minute proposal on the record, nor is there any credible data other than mere assertion and implicit assumption as to a revenue impact other than a de minimis one, if any, that would result. Finally, based on the record evidence, the Commission must reject assertions (1) that the Petitioners' traffic, which would become local under the pending petitions should remain captive to toll competition; or alternately, (2) that in the near term conditions should remain unchanged since they will be remedied by competitive market forces. As stated above, the record in this docket is overwhelming, that the legitimate local Communities of Interest do in fact exist (thereby obviating the legitimacy for maintaining such consumer traffic captive to long distance providers). The record also clearly demonstrates that no effective competition exists in the affected markets today nor, absent some drastic change in direction of events, is such competition likely to develop in the near term. II. THE RECORD EVIDENCE OVERWHELMINGLY DEMONSTRATES THAT COMMUNITIES OF INTEREST, AS APPROPRIATELY DEFINED, TODAY EXIST WITH RESPECT TO THE PETITIONING COMMUNITIES There has been no response to the evidence introduced, both through Mr. Petric and Mr. Isaacson's prefiled testimony, nor in the overwhelming record evidence introduced through letter submissions and live public hearing testimony presented by the citizens and their elected representatives of the affected communities, that telephony usage has been artificially suppressed by toll rate treatment, as well as by the availability of e-mail over the Internet, and bypassing of long distance carriers. Unlike the Office of People's Counsel (OPC) suggestion, that application of the traditional Community of Interest test was both optional (not mandatory) and ripe for revision, both Bell Atlantic and the PSC's Staff simply invoked the old formula without any comment whatsoever as to the continuing basis for its validity in the post-Internet, post-Act world. Their comments suggest that simply by sufficient repetition of the old Community of Interest test mantra, the Commission will overlook the fact that the undisputed record evidence demonstrates that this formula today is no longer valid, producing at least in the current docket predetermined and self-fulfilling results. Placed in today's perspective, the traditional Community of Interest test essentially is a protectionist vehicle. Prior to the advent of local exchange competition (first introduced in New York City in July 1993), the Community of Interest test was generally accepted as appropriate. There is no significant evidence on this record as to the derivation of the 50% rule, or as to its continuing legitimacy. Moreover, even under traditional conditions, it significantly understated the usage that otherwise would result, since the extraordinary costs associated with toll versus local calling has been an admittedly artificially suppressed usage and continues to be so. Bell Atlantic's witness, Mr. Gilbert, explicitly admitted as much, for he has acknowledged that once a local calling area is expanded "traffic typically increases tremendously." Furthermore, and most critically, anyone can send a written e-mail today anywhere in the world for the price of a local phone call. The Community of Interest test as initially advocated by Bell Atlantic and Staff, however, absolutely fails to take into account communications that otherwise would have been made via the preferred mode of voice telephony, which instead have been shifted onto e-mail (or alternately, simply abandoned). Yet witness after witness spoke eloquently to just such developments. For example, Mrs. Charlene L. Cohen of Gaithersburg, Maryland State President of the National Association of Retired Federal Employees, testified in part that: "As an alternative to using Bell Atlantic, I use E-mail extensively and also my cellular phone. I can make free calls every evening after 9:00 p.m. and on weekends to most of the State of Maryland, Northern Virginia, and parts of Delaware and West Virginia. I only make tolls calls during the day when I cannot reach the other party by E-mail." Mrs. Cohen further went on to note that, "There is no excuse for making up-county customers pay toll charges for calls to Northern Virginia and Prince George's County that the down-county customers do not have to pay. We are all part of the Washington Metropolitan area. Many customers who live in the up-county area [of Montgomery County] work either in Northern Virginia, Prince George's County or the District, and vice-versa;" furthermore, "the Gaithersburg area has more home-based businesses than anywhere else in the country. Are they being excluded? None of us, commercial or residential, are interested in changing our phone numbers." Similarly, a Rockville resident testified that his move to Montgomery County made him feel that he would lose touch with his ethnic heritage because he could not afford to communicate with his friends in Northern Virginia. In short, the Community of Interest test as traditionally applied no longer is valid because it (1) severely understates community relationships, even in its traditional form, because it does not and cannot take account for traffic which is otherwise artificially suppressed by high toll rates; and, (2) in today's new world of Internet and E-mail and of wireless cellular alternatives, the traditional test fails to account for traffic that otherwise would be sent via wireline means through the Public Switched Network, but which instead is being sent via alternate mediums to escape the artificial penalties imposed by the traditional local calling areas here in question. Further, as discussed in Part II below, that test also fails to account in any manner for the rapid decline in transport costs, which make expansion of local calling areas, even where less than the arbitrary and artificial "50%" touchstone is present, economically reasonable, with de minimis implications for the network. In short, the record evidence overwhelming favors the granting of the pending Petitions, without resort to the FX subterfuge addressed in the following section. We would respectfully submit that, based on the overwhelming record evidence, the OPC's Mr. Buckalew got it right when he concluded that, "The areas of concern are Northern Montgomery County, Dunkirk and the surrounding communities to Washington, and Kent Island to Annapolis. The data suggests that there is a strong community of interest between Poolesville, Gaithersburg and Damascus and Washington, and North Beach and Washington. The call volumes from these Northern Montgomery County locations to Washington are significant. The call volumes from Dunkirk and the surrounding areas to Washington also suggests that they have a community of interest with Washington. The FX demand between North Beach and Washington suggests that a majority of the customers would be willing to pay for the added cost of increasing the service areas. " III. THE LAST-MINUTE FX COMPROMISE JOINTLY SUBMITTED BY BELL ATLANTIC AND STAFF WITHOUT PRIOR CONSULTATION WITH PETITIONERS HAS NO CREDIBLE RECORD JUSTIFICATION On the one hand, as captive customers to Bell Atlantic in the truest sense of the word, the Petitioners welcome ANY positive movement. On the other hand, we vigorously object to what can only fairly be described as a paternalistic, unilateral attempt to co-opt these proceedings on terms that, while favorable to Bell Atlantic, ignore the very real concerns and needs of the consumer Petitioners. More importantly, this last minute surprise proposal absolutely fails to grapple with the lengthy series of legitimate, substantive issues and concerns originally raised in the testimony of Petitioners and certain interveners, including Teleport, OPC, and endorsed repeatedly and widely by those testifying at this Commission's subsequent statewide hearings. In fact, there is absolutely no record evidence that can credibly support adoption of this force majeure proposal under traditional standards of evidence in the administrative arena. Neither Bell Atlantic nor Staff have provided ANY evidence as to the current transportation and/or switching capacity, if that, that would need to be deployed to facilitate implementation of the FX proposal. In particular, Bell Atlantic has not submitted any evidence as to what alleged additional transport costs might be involved, if any, or as to what the current state of transport capacity is in the affected areas. Yet, as the record testimony demonstrates, in today's fiber-based world, transport costs for telephony rapidly are approaching the level of de minimis. Further, there has been no supporting data submitted as to whether any additional switching capacity currently exists in Bell Atlantic's affected tandem and local switches, and what costs, if any would in truth be incurred to handle the incremental additional burden imposed by expanded FX usage. (Further, there has been absolutely no evidence on the record as to the impacts generally acknowledged to be negative in nature as to engineering design and system reliability, particularly with respect to proper and timely handling of significantly increased 9-1-1 traffic over FX lines, that compromising these proceedings through expanded FX deployment/usage, rather than through simply expanded calling areas, would entail.) No specific evidence as to the underlying costs have been addressed; moreover, the alleged revenue at risk has not been broken down based on underlying costs (and the Petitioners would assert that in this post-Act environment, the only appropriate measure of costs should be a form of FORWARD LOOKING COSTS, i.e., a form of Long Run Incremental Costs ("LRIC") analysis. With respect to the revenue at risk figure articulated by Bell Atlantic, of slightly more than 1.5 million dollars, there has been no credible evidence articulating, never mind supporting, what underlying assumptions have been made as to how many users would request the service, and as to how that number would change over any given period of time. Moreover, there has been no articulation as to any specific cost breakdown, including how much overhead has been assigned; whether historic and/or embedded costs are being used, what level of profit, or rate of return, is being assumed that Bell Atlantic is entitled to on this given offering; nor on whether that level of usage, if realized, when added to the pre-existing numbers under the old infirm "community of interest" test, in and of itself, would drive usage over the requisite four calls per month by at least fifty percent of the dialing populace. Further, no evidence has been presented as to the size of such alleged foregone revenue versus Bell Atlantic-Maryland's overall revenue picture and most importantly, the impact not on gross revenues but rather on net revenues. Given that Bell Atlantic and Staff were the proponents of this last minute proposal, it is incumbent upon them and particularly on Bell Atlantic, the entity best positioned to present probative evidence on this issue to demonstrate that the true net revenue impact is anything more than a rounding error compared to Bell Atlantic's overall net revenue picture in Maryland (even assuming arguendo that Bell Atlantic's foregone revenue from these services would otherwise be static, a highly unlikely presumption given the explosion of E-mail traffic, which effectively transforms captive toll customers into local correspondents). In addition, while Bell Atlantic at the June 15 hearing before this Commission raised the bogey that additional FX usage could compromise the numbering resource, as Mr. Petric addressed in his previously-received testimony, no such issue presents itself with respect to grant of the Petitions for expanding the local calling areas. In fact, by expanding the local calling areas, this Commission in turn should be able to aggressively pursue the potential for rate center consolidation (as for example, the Colorado Commission recently has mandated in the 303 LATA in its Docket No. 97M-548T, Decision No. C98-439, adopted April 29, 1998). Whereas under the prevailing arcane, antiquated rate center system that exists today in virtually every jurisdiction, one or more 10,000 number block NXX code(s) must be assigned to each carrier serving each rate center, a consolidation of rate centers assuming at least some are, or will be, subject to the arrival of local exchange carrier competitors by definition will result in fewer NXXs being required and hence conservation of the numbering resource. By contrast, Bell Atlantic's FX proposal potentially can result incrementally increased pressure on the numbering resource in the more heavily-used, i.e., urban and/or suburban, rate centers that the FX proposal would open up. Accordingly, Petitioners' proposal, even from a numbering standpoint, is preferable to the FX Jerry-rig belatedly offered up by Bell Atlantic. Finally, there has been no response to Mr. Petric's prefiled testimony as to the fact that citizens of Northern Virginia metro have had comparable FX service from Bell Atlantic since 1988 for $.50 a month, rather than the $2.00 proposed here. Incredibly, up until the beginning of this year, consumers were forced to pay $15.25/month for FX service, which rate in turn had been approved as justified by this Commission. More recently, as reflected in the pre-filed testimony of among others, the Bell Atlantic witness, the reduction earlier this year to $14.50 was emphasized as a major reduction, still cost justified. Yet, as this proceeding has moved forward, suddenly and inexplicably, Staff and Bell Atlantic now proclaim that a reduction to $2.00/month a seven-fold decrease is justified and justifiable. Which begs the question: for if $2 is justified, then clearly the exorbitant rates of $15.25 and $14.50 must have had an extraordinary, artificial depressing impact on usage (which in turn simply compromises any argument as the validity of the Community of Interest test as Staff and Bell Atlantic would rotely apply it here!). So one must ask, which is it? $15.25? $14.50? $2.00? Fifty cents? Or more immediately, why are the communities represented by Petitioners being held captive, to pay artificially inflated rates, when Bell Atlantic's other residential customers receive comparable service at LOCAL rates. Moreover, we must challenge the good faith in which the proposal has been propounded for it only calls for the reduction to the $2.00 level A YEAR AND A HALF FROM NOW in two communities, and then in other communities only if the fatally-flawed Community of Interest test has been satisfied. This really is tantamount to bait and switch: for by definition, adoption ensures (1) that Bell Atlantic is secure in receiving excessive revenues (i.e., at a rate level at a minimum at least seven fold higher than would otherwise be justifiable, even under Bell Atlantic and Staff's suspect formula) at the expense of captive consumers for the next year and a half, and (2) any subsequent relief ratepayers would be entitled to in exchanges other than Poolesville and North Beach is to be judged by the traditional Community of Interest test which in turn is based on artificially deflated usage given the extraordinary suppressive impact of the continued applicable $14.50/month fee. Quite frankly, it is this kind of tortured logic which the incumbent has used at virtually every step of the way along the road to competition since 1994. What we are seeing here is the same tired old formula toss us consumers a bone; submit inflated, unsupported gross revenue impact figures; and raise the veiled spectre of untoward impacts on the rest of the state's telephone ratepayers, thereby attempting to set consumer against consumer. We would respectfully submit that such tactics must not and cannot be abided by this honorable Commission. IV. THE TRAFFIC IN QUESTION MUST NOT REMAIN CAPTIVE TO TOLL RATES (I.E., LONG DISTANCE) TREATMENT, NOR WILL COMPETITIVE MARKET FORCES CURE THE PENALTY RATES TO WHICH PETITIONERSHAVE BEEN SUBJECTED TOO ANY TIME IN THE FORESEEABLE NEAR TERM Petitioners strongly disagree with the assertion by AT&T that the wireline traffic in issue should remain subject to long distance, i.e., toll treatment. Further, the suggestion that the present situation will be remedied through the competitive workings of the marketplace on the face of it begs reality. In particular, AT&T has asserted in its testimony that local calling areas as currently defined are satisfactory, but that access charges need to be reduced. As Mr. Petric discussed in his rebuttal testimony, the suggestion of AT&T can be discounted as simply one more volley in that Company's continuing attempt nationwide to have access charges reduced. While the Petitioners do not necessarily disagree with AT&T as to whether the level of access charges to which Maryland consumers are subjected continue at excessive levels, nevertheless the Petitioners would submit that that issue is besides the point, as is the question as to whether long distance rates on a relative basis have been reduced rather dramatically. The true issue is whether a sufficient community of interest (as properly defined, given the realities of today, not those artificial ones embedded in the traditional test) between the affected areas addressed by the Petitions that seek fairness and equity, and to take away the mandate that the residents thereof no longer be artificially held captive to usage-based toll charges or to inflated FX costs. The central issue simply is whether these local exchange customers should be entitled to treatment, through a redefinition of their local calling areas after more than 20 years, which places them on a like footing with the rest of their fellow Maryland citizens. The fact that expanding such calling areas in turn would deprive AT&T, MCI, and others, of the ability to continue to collect long distance charges for calls that otherwise should be deemed local in nature is besides the point. In fact, the true remedy for AT&T, MCI, SPRINT and others, lies not on the side of continuing to impose an unwarranted and unsupportable situation pertaining to the long distance traffic definition, but rather to compete aggressively for the affected customers' local service (as announced in the acquisitions of Teleport and of TCI would allow it to do not just on a resale, but far more importantly, on a facilities-basis). Perhaps most telling in this regard is that Mr. Hirsch, the witness for Teleport (the competitive local exchange carrier that AT&T is in the process of acquiring) has presented extensive testimony implicitly suggesting that local calling areas be expanded to include all intraLATA calls (at least in the context of reciprocal compensation paid carrier-to-carrier for terminating each other's local calls). Mr. Hirsch's prefiled testimony would therefore appear to significantly undercut AT&T's stance and indicate that competition in the local marketplace, as well as the captive customers represented by the Petitioners would best be served by an expansion of the local calling areas and not a retention of the current situation. In Tennessee, the legislature passed a law to have county-wide toll-free calling (see attachment). Yet, this law was challenged by AT&T, MCI, SPRINT, and other long distance carriers. So no matter what the outcome, the long-distance carriers want long distance to remain no matter what happens. At the same time, it is highly unlikely contrary to the suggestions of Mr. Tomasello and of Bell Atlantic that the salutary effects of local exchange competition any time in the near future will take care of the calling areas. As noted in Mr. Petric's rebuttal testimony, the study recently released by Atlantic-ACM demonstrates that Bell Atlantic-MD retains 99.45% of all local phone lines in Maryland. Moreover, during calendar 1997, Bell Atlantic-Maryland added 126,999 new local phone lines, while ALL of its competitors collectively added a combined total of only 18,022 customer lines. Clearly, therefore, as Mr. Hirsch suggested, extraordinary barriers remain to the realization of a competitive marketplace in Maryland. Petitioners and their communities will likely have a Beckett-esque experience of "Waiting for Godot" if their hopes for broad-based relief is left to the vagaries of competition developing in their communities any time in the immediate future. CONCLUSION For the foregoing reasons, Petitioners respectfully submit that this honorable Commission (1) grant each of the three pending Petitions to expand specified local calling areas in their entireties; and (2) reject the FX Joint Proposal as submitted by Bell Atlantic and Staff. Respectfully submitted, Ivan (John) Petric, President Bay Country Estates Homeowners Association 301-855-7009 (Home); 410-257-0398 BayCountry@Yahoo.com Charlene Cohen, President National Association of Retired Federal Employees Maryland Federation Chapter 16920 Baederwood Lane Rockville, MD 20855-2013 301-977-9091 clcohen1@juno.com Ronald A. Isaacson 12481 Walnut Cove Circle Germantown, MD 20874-1586 301-353-9153; 301-972-0142 (Fax) isaacson@x-press.net Alfonso Diaz Del Castillo 8710 King George Court Pomfret, MD 20675 301-934-5656; 301-934-2111 (Fax) fiestair@erols.com Mr. James H. Crawford P.O. Box 236 Bryantown, MD 20617 301-870-2036 jhc@us2000.org Wayne Dernoncourt SVC Board Representative Bannister Neighborhood Association 1209 Bannister Circle Waldorf, MD 20602-1502 301-843-7503 WayneD@cpcug.org David F. Hale 1785 Mt. Harmony Road Owings, MD 20736 301-855-3415 HaleDave@Erols.com Janet L. Hall 2395 Parkers Creek Road Port Republic, MD 20676 410-586-3065 overhall@chesapeake.net Richard D. Lawrence 4131 Birch Drive Huntington, MD 20639 410-535-1703; 301-855-9094; 202-682-7711 (Fax) rich1@olg.com CERTIFICATE OF SERVICE I certify that a copy of the foregoing document(s) in Case No. 8772 was/were sent by regular mail, unless otherwise indicated below, this day to each of the following: Daniel P. Gahagan, Esq. Executive Secretary Public Service Commission 6 St. Paul Street, 16th Flr. Baltimore, MD 21202-6806 410-767-8067, 410-333-6495 (Fax) Parties: Janice M. Flynn, Esq. Sarah R. Lazarus, Esq. Office of Staff Counsel Public Service Commission 6 St. Paul Street, 17th Flr. Baltimore, MD 21202-6806 410-767-8120, 410-333-6086 (Fax) Michael J. Travieso, Esq. Theresa V. Czarski, Esq. Maryland Office of People's Counsel 6 St. Paul Street, Ste. 2102 Baltimore, MD 21202-1631 410-767-8150, 410-333-3616 (Fax) Mr. Ivan (John) Petric, President Bay Country Estates Homeowners Association, Inc. 6343 Meadowland Drive Dunkirk, MD 20754-9535-1 301-855-7009 (Home); 202-606-2554 (Work) 202-606-1163 (Fax) Robert D. Lynd, Esq. Bell Atlantic-Maryland, Inc. Constellation Place 1 E. Pratt Street, 8 East Baltimore, MD 21202 410-393-7477, 410-393-7547 (Fax) Matthew W. Nayden, Esq. Stephanie A. Baldanzi, Esq. Ober, Kaler, Grimes & Shriver AT&T Communications of Maryland, Inc. 120 E. Baltimore Street Baltimore, MD 21202-1843 410-685-1120; 410-547-0699 (Fax) 202-408-8400; 202-408-0640 (Fax) Mark Keffer, Esq. AT&T Communications of Maryland, Inc. 3033 Chain Bridge Rd., Room 3-D Oakton, VA 22185 703-691-6047; 703-691-6093 (Fax) Cathy Thurston, Esq. Sprint Communications Co. 1850 M Street, NW, Ste. 1110 Washington, D.C. 20036 202-828-7425, 202-828-7403 (Fax) Allen M. Freifeld, Esq. MCI Telecommunications Corp. 1133 N.W. 19th Street Washington, D.C. 20036 202-736-6104; 202-736-6876 (Fax) Michael A. McRae, Esq. Senior Regulatory Counsel Teleport Communications Group, Inc. Regulatory & External Affairs 2 Lafayette Centre, Ste. 400 1133 NW 21st Street Washington, D.C. 20036 202-739-0032; 202-739-0044 (Fax) Lisa M. O'Mara, Esq. J. Edward Davis & Associates 409 Washington Ave., Ste. 909 Towson, MD 21204 410-494-9000; 410-823-6839 (Fax) (for Cable TV Assn. of Maryland, Delaware, and D.C.) Russell M. Blau, Esq. Robin F. Cohn, Esq. Russell M. Blau, Esq. Swidler & Berlin, Chartered 3000 K Street, NW, Ste. 300 Washington, D.C. 20007-5116 202-424-7500, 202-424-7645 (Fax) (for RCN Telecom Services of Maryland, Inc.) Mr. Ronald A. Isaacson 12481 Walnut Cove Circle Germantown, MD 20874-1586 301-353-9153; 301-972-0142 (Fax) Interested Persons: Honorable Paul S. Sarbanes U.S. Senate 2nd & C Sts., NE, SH309 Washington, D.C. 20510 202-224-4524; 202-224-1651 (Fax) Honorable Barbara A. Mikulski U.S. Senate 2nd & C Sts., NE, SH709 Washington, D.C. 20510 202-224-4654; 202-224-8858 (Fax) Honorable Wayne T. Gilchrest U.S. House of Representatives 332 Cannon House Building Washington, D.C. 20515-2001 202-225-5311; 202-225-0254 (Fax) Honorable Steny H. Hoyer U.S. House of Representatives 1705 Longworth House Building Washington, D.C. 20515-2005 202-225-4131; 202-225-4300 (Fax) Honorable Robert Ehrlich, Jr. U.S. House of Representatives 315 Cannon House Building Washington, D.C. 20515-2001 202-225-3061; 202-225-3094 (Fax) Honorable Albert R. Wynn U.S. House of Representatives 407 Cannon House Building Washington, D.C. 20515-2004 202-225-8699; 202-225-8714 (Fax) Honorable Thomas V. Mike Miller Maryland State House, #107 Annapolis, MD 21401-1991 301-858-3700; 301-858-3910 (Fax) 1-800-492-7122 Ext. 3700 Honorable Leo Green 212 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3631; 301-858-3174 (Fax) 1-800-492-7122 Ext. 3631 Honorable Leonard H. Teitelbaum 205 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3151; 301-858-2409 (Fax) 1-800-492-7122 Ext. 3151 Honorable Patrick J. Hogan 316 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3686; 301-858-3617 (Fax) Honorable Jennie M. Forehand 214 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3134; 301-858-3850 (Fax) Honorable Van T. Mitchell Chairman, Southern Maryland Delegation 216 Lowe House Office Bldg. Annapolis, MD 21401 301-858-3247; 301-858-3252 (Fax) Honorable George W. Owings III 217 Lowe House Office Bldg. Annapolis, MD 21401-1991 301-858-3231; 301-858-3252 (Fax) Honorable Raymond Beck 225 Lowe House Office Bldg. Annapolis, MD 21401-1991 301-858-3037; 301-858-3850 (Fax) Honorable Adrienne A. Mandel 220 Lowe House Office Bldg. Annapolis, MD 21401-1991 (301) 858-3045; (301) 858-2411 (Fax) Honorable Cheryl C. Kagan 224 Lowe House Office Bldg. Annapolis, MD 21401-1991 (301) 858-3046; (301) 858-2411 (Fax) Honorable Virginia P. Clagett 212 Lowe House Office Bldg. Annapolis, MD 21401-1991 (301) 858-3211; (410) 867-1493 (Fax) Honorable Murray D. Levy President, Charles County Board of Commissioners 200 Baltimore St. La Plata, MD 20646 301-870-3000; 301-645-0560 (Fax) Honorable Bert L. Rice Chairman, Anne Arundel County Council 44 Calvert St. Annapolis, MD 21404 301-970-8250, Ext 1401; 410-222-1755 (Fax) Honorable Ronald F. Russell Chairman, Prince George's County Council 14741 Governor Oden Bowie Dr. Upper Marlboro, MD 20772 301-952-3695; 301-952-4862 (Fax) Honorable Hagner Mister President, Calvert County Board of Commissioners 175 Main St. Prince Frederick, MD 20678 301-855-1243; 410-535-5594 (Fax) Honorable Barbara R. Thompson President, St. Mary's County Board of Commissioners 23115 Leonard Hall Dr. Leonardtown, MD 20650 301-475-4461; 301-475-4935 (Fax) Honorable Isiah Leggett President, Montgomery County Council 110 Maryland Ave. Rockville, MD 20850 301-217-7900; 301-217-7940 (Fax) Honorable Douglas M. Duncan Montgomery County Executive 101 Monroe St. Rockville, MD 20850 301-217-2500; 301-217-2517 (Fax) Honorable Louis L. Goldstein Comptroller of the Treasury P.O. Box 466 Annapolis, MD 21404-0466 1-800-552-3941; 410-974-3808 (Fax) Ms. Virginia Avers Calvert Chamber of Commerce 226 Marrimac Court Prince Frederick, MD 20678 301-855-1930; 410-257-3140 (Fax) Mr. Bobby Sturgell 9915 Old Solomon's Island Road Owings, MD 20736 410-257-2992 Mr. Woody Traylor MCI Metro 2250 Lakeside Boulevard Richardson, TX 75082 Sheryl A. Butler, Esq. Office of Judge Advocate General Department of the Army 901 N. Stuart Street, Ste. 713 Arlington, VA 22203-1837 703-696-1642; 703-696-2960 (Fax) Robert S. Fleishman, Esq. James P. Bennett, Esq. Baltimore Gas & Electric Company P.O. Box 1475 Baltimore, MD 21203 410-234-5607; 410-234-5690 (Fax) J. Manning Lee, Esq. Teresa Marrero, Esq. Teleport Communications Group, Inc. Two Teleport Drive, Ste. 300 Staten Island, NY 10311 718-983-2671; 718-370-4891 (Fax) Mr. Eldon B. Erickson Ms. Patricia G. Erickson 11026 Webster Drive Lusby, MD 20657 301-326-2053 Jeffrey Blumenfeld, Esq. Christy C. Kunin, Esq. Blumenfeld & Cohen 1615 M Street, NW, Ste. 700 Washington, DC 20036 202-955-6300, 202-955-6460 (Fax) Ms. Charlene L. Cohen, President National Association of Retired Federal Employees Maryland Federation Chapter 16920 Baederwood Lane Rockville, MD 20855-2013 301-977-9091 Mr. Alfonso Diaz Del Castillo 8710 King George Court Pomfret, MD 20675 301-934-5656; 301-934-2111 (Fax) Ms. Lucille Parkerson 11323 Shannon Court LaPlata, MD 20646 301-753-1985; 301-836-8151 (Fax) Ms. Eileen M. Curley 12150 Laramie Lane Lusby, MD 20657 410-326-0630 Mr. David W. Cole Ms. Dawn A. Cole 37412 E. Lakeland Drive Mechanicsville, MD 20659 301-884-5339 Mr. Horace Y. Edwards Ms. Dolly K. Edwards 4986 Sentinel Drive, #201 Bethesda, MD 20816-3518 301-229-4875 Mr. Nicholas G. Andrews Ms. Dana R. Andrews 4619 Langdrum Lane Chevy Chase, MD 20815 301-652-2497 Mr. Richard D. Lawrence 4131 Birch Drive Huntington, MD 20639 410-535-1703; 301-855-9094; 202-682-7711 (Fax) Mr. L. T. Pimental 1517 Widows Mite Road Edgewater, MD 21037-2144 410-956-3238 (Home); 301-261-4545 (Work) 410-956-4700 (Fax) Mr. Joseph P. O'Kane 2300 Apricot Arbor Place Odenton, MD 21113 410-551-2530; 301-688-0255 (Fax) Mr. John P. Winner 10800 Potomac Street Glendale, MD 20769 301-805-1261 Ms. Catherine Roche 23112 Pineywood Circle California, MD 20619 301-862-3998-H; 855-1903; 410-535-4509 (Fax) Ms. Valerie A. Watson 1040 Walnut Avenue North Beach, MD 20754 410-741-5954 Ms. Michelle Harner 1317 Butternut Street Box 333 Shadyside, MD 20764 410-867-4673 Mr. Peter Perry, President South County Coalition, Inc. P.O. Box 154 Davidsonville, MD 21035 301-261-7527 Mr. William B. Glascock, II P.O. Box 382 315 Strathmore Lane Solomons, MD 20688 410-326-4357 (Home); 410-326-1052 (Work) Mr. Modesto S. Rivera 806 Solomons Island Road Prince Frederick, MD 20678 410-535-4242 Ms. Leah L. Horak 2150 Stinett Road Huntington, MD 20639 410-535-5764 (Home); 410-741-6025 (Work) Mr. James S.D. Ray 6085 Tapir Place Waldorf, MD 20603 301-638-3422 Mr. Larry E. Johnson 2755 Mill Hill Road Waldorf, MD 20603 301-638-3035 Mr. Howard M. Clements 5202 Grenock Drive Lothian, MD 20711-2803 301-627-6387 Ms. Kathryn R. Clagett 2590 Davidsonville Rd. Gambrills, MD 21054 301-261-3342; 410-721-2715 Rev. Brian C. Mentzer, Pastor Riverdale Baptist Church 1177 Largo Road Upper Marlboro, MD 20774 301-249-7000; 301-249-1063 Mr. Dennis Y. Howard 1705 Wickham Way Crofton, MD 21114 410-721-8739; 301-249-1063 (Fax) Mr. James H. Crawford P.O. Box 236 Bryantown, MD 20617 301-870-2036 Ms. Karen Egloff 2950 Holand Cliffs Road Huntingtown, MD 20639 301-855-7476 Ms. Janet L. Hall 2395 Parkers Creek Road Port Republic, MD 20676 410-586-3065 Mr. David F. Hale 1785 Mt. Harmony Road Owings, MD 20736 301-855-3415 Diane Kincaid, President United Way of Calvert Couty 530 Main Street Prince Frederick, MD 20678-0560 Wayne Dernoncourt SVC Board Representative Bannister Neighborhood Association 1209 Bannister Circle Waldorf, MD 20602-1502 301-843-7503 WayneD@cpcug.org Mr. Sherman W. Benton 3501 29th Place Temple Hills, MD 20748 301-702-2872 Mr. Ronnie W. Pitcock, Jr. 627 Maple Lane, #3 Eau Claire, WI 54703 1-888-947-2638 Ms. Lisa Fine Montgomery Journal 1 Research Court Rockville, MD 20850 301-670-1400; 301-670-1421 (Fax) (Date) Ivan Petric