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 May 27, 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. 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 text, entitled "May8772.txt". 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 * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * May 27, 1998 REBUTTAL TESTIMONY OF IVAN PETRIC FOR CONSUMERS AND COMMUNITIES IN SOUTHERN MARYLAND AND SURROUNDING COUNTIES IN ANNE ARUNDEL, CALVERT, PRINCE GEORGE'S, CHARLES, SAINT MARY'S, MONTGOMERY, ET.AL. I. REBUTTAL Q Please state your name for the record. A. My name is Ivan Petric. Q. Are you the same Ivan Petric who previously submitted testimony in this proceeding on April 15, 1998? A Yes, I am. Q. What is the purpose of your testimony today? A. I wish to reply to certain arguments and/or assertions that are contained in the testimony of witnesses for Staff, Bell Atlantic, and AT&T. Q. Could you please summarize your reply testimony. A. Certainly. First, and most importantly, I vigorously disagree with the assertion by Staff and Bell Atlantic that the traditional, pre-Internet, pre-Competition, "Community of Interest" test should continue to be applied under the circumstances present in this proceeding. Second, I also disagree with AT&T's assertion that the present local calling areas should be retained while access fees are lowered. Third, I also strongly disagree with the assertion that a "market" driven remedy today is a practical approach given the circumstances. And fourth, I believe it is critical to point out that the assertions as to additional costs, lost revenue, etc., on the part of the incumbent are essentially just that: unproven assertions. These statements are strongly reminiscent of parallel claims that have been made by this incumbent, Bell Atlantic-Maryland (BA-MD) , and like situated incumbent local exchange carriers ("ILECs") in response to every pro-competitive and/or, more importantly, every pro-consumer initiative that has been presented that I can think of right back to the days of the Carter phone decision at the Federal Communications Commission (FCC). Q. Why do you believe that the Community of Interest test is an inappropriate test? A. The Community of Interest test is essentially a protectionist vehicle when viewed from today's perspective. The Commission needs to ensure that the expansion of local calling areas is performed in a more consistent and fair basis statewide by eliminating the current method of calculating percentages of local calls to neighboring communities to determine if the local calling area is adequate and meets basic needs Prior to the advent of local exchange competition (which, bear in mind, nationally it is still slightly less than five years old, since its first introduction in New York City in mid-1993), the Community of Interest test was I believe generally accepted. There is no evidence on this record as to where the derivation of the "50%" rule came from, or as to its continuing legitimacy. Moreover, even under traditional conditions, it significantly understated the usage that otherwise would result, since the extraordinary costs that are associated with a toll versus a local call are admittedly an artificially suppressed usage and continues to be so, especially when it is controlled by a monopoly to bring in higher revenues. Ironically, the witness for Bell Atlantic explicitly admits as much, for he acknowledges on page 18 of his testimony that once a local calling area is expanded "traffic typically increases tremendously" (while Bell Atlantic implies that this is because such usage now is less expensive and hence more folks take advantage of it, he totally misses the other critical implication that absent a significant community of interest there would be no driver leading to such dramatic traffic increases!) Not only that, but an informal survey of the surrounding states, indicates that Maryland phone rates for consumers are among the highest in the nation. However, in today's world what this Commission CAN take administrative notice of is that national carriers are increasingly offering telephony over IP at rapidly declining prices. So, for example, ICG (a national CLEC headquartered in Denver) has announced that it will be offering long distance telephony over its IP network in 238 markets by the end of the year at, I believe, 5.9 cents a minute (compare that with the current standard rates of, for example, the Big Three, AT&T, MCI, and Sprint). Similarly, Qwest (also based in Denver, and building a 16,000 mile national all fiber optic high capacity long distance network, much of which is already in operation) has announced telephony over IP rates of, I believe, 7.5 cents per minute. In Washington State, four LECs have proposed to change their measured rates. United proposed to decrease its measured rate 2 cents per minute, from 8 cents per minute to 6 cents per minute. Scio proposed to increase its rate 4.1 cents per minute, from 3.9 cents per minute to 8 cents per minute. Monroe proposed to increase its measured rate 3 cents per minute, from 5 cents per minute to 8 cents per minute. GTE proposed to combine its 2 measured rates into one combined rate. The present rate in Zone 1 was 7.5 cents per minute for the initial minute and 3 cents per minute for subsequent minutes. In Zone 2, the present rate was 12 cents per minute for the initial minute and 6 cents per minute for subsequent minutes. GTE proposed no change in its Zone 1 initial minute rate of 7.5 cents per minute. The company proposed to increase the present Zone 1 per minute rate by 1 cent per minute to a level of 4 cents per minute, and eliminate the distinction between Zone 1 and Zone 2. The measured rate would be charged at the Zone 1 rate. All of the measured rates proposed by eight companies were consistent with measured rates that were being charged by the other LECs and Commission guidelines. Furthermore, and most critically, anyone can send a written e-mail today ANYWHERE IN THE WORLD for the price of a local phone call, without incurring any long distance charges. What we can draw from this action are two indisputable facts: first, the traditional Community of Interest test has no way of taking into account the number and volume of communications which today are being by-passed from the incumbent and going to mobile phones, competitors not registered as telephony carriers, sent by e-mail, in lieu of voice, within communities of interest, given the dramatic differential in costs. Yet, without such valid documented information, the traditional, arcane touchstones of the Community of Interest test cannot in any way be validated or accepted as a valid test. Second, the rapid decline in long distance rates from carriers such as ICG and Qwest, and others, effectively validates the point that I made in my opening comments that the price of transport in this day of fiber optic networking has been reduced dramatically, to the point where for most carriers such costs incrementally are apparently de minimis. Accordingly, in sum, the Community of Interest test first, severely understates community relationships, even in its traditional form, because it does not and cannot take into account the amount of traffic which has otherwise been artificially suppressed by high toll rates or mileage/monthly charges. Second, in today's new world of internet and e-mail, the Community of Interest test totally fails to account for traffic that is being sent via that medium in order to escape the artificial penalties that are imposed by the traditional local calling areas here in question. Third, that test also fails to account in any manner whatsoever for the rapid decline of transport costs, which make the expansion of local calling areas even more important, versus the arbitrary and artificially selected "50%" touchstone that is present, and economically reasonable. At the same time, I would ask this Commission whether the public interest is served by a mechanism which fosters the rapid growth and establishment of extended communities of interest, rather than, as in the olden days, of waiting until such a community of interest had emerged despite the odds of artificially inflated communications costs to and after-the-fact, and recognize the evolution of that condition. The witness for the People's Counsel seems to clearly recognize that this Commission is NOT bound by the traditional tests; that it has the flexibility in determining what serves the public interest; and implicitly demonstrates a distinct discomfort given the shortcomings of that test. This was demonstrated in the Chief Hearing Examiners ruling against BA-MD when it tried to suppress the testimony of the witness for the Teleport Communications Group, Inc., (TCG). In essence, the Commission should also establish a statewide policy that would allow consumers to call essential services within their communities without incurring local long-distance charges, in addition to creating improved calling areas which BA-MD does not want to do voluntarily. I made several suggestions in my previous testimony. This is no different that the current calling pattern that exists in some of the FX calling areas that are currently applied by BA-MD. Consider the Upper Marlboro exchange (855). Not only does it encompass at least 36 "towns", but also 2-3 counties, including the Washington Metro area, and Northern Virginia as well (an average 40-60 miles), except that it does not go directly into Annapolis, which is the county seat, 20 miles away, but in a round about way it goes there when it reaches other Bowie metro numbers (261). Q. Why do you disagree with AT&T's assertion that local calling areas as currently defined are satisfactory, but that access charges need to be reduced? A. I would submit that AT&T's comments can be discounted as simply one more shot in their continuing crusade nationwide to have access charges reduced. While I do not fault them for that, I would note that should local calling areas be expanded, those calls that they would carry within the suggested expanded areas which today are for example intraLATA toll calls would have to be converted to local calls, thereby depriving AT&T of being able to continue to collect long distance charges in such instances. I would simply suggest that, should the public interest be served, and the requested local calling areas are expanded, that AT&T's best strategy instead of attempting (in what would seem a figurative "silent conspiracy" with Bell Atlantic to each preserve their own chunk of what is essentially a captive market) would be to compete aggressively for such affected customers' local services. Perhaps the most telling testimony is that of the TCG witness for the competitive local exchange carrier (CLEC) that AT&T is in the process of acquiring, that has presented a forceful testimony suggesting that the local calling area be EXPANDED to include all intraLATA calls, at least for the purposes of reciprocal compensation. This would seem to directly undercut the AT&T suggestion and would indicate that competition in the local marketplace, as well as of consumers like myself and the members of my homeowners association, would best be served by an expansion of the local calling areas, and NOT a retention of the current situation as dictated by BA-MD. Q. Do you agree with TCG's testimony? A. I will not pretend to be an expert in matters such as that of reciprocal compensation, etc. However, I can say this. First, according to the recent study that was released by Atlantic-ACM, Bell Atlantic-Maryland retains 99.45% of the local phone lines in this state. Moreover, the same report indicates that in 1997 Bell Atlantic-Maryland added 126,999 new local phone lines in Maryland, while ALL of its competitors collectively had added a combined total of only 18,022 customer lines. Clearly, therefore, as the TCG witness has suggested, extraordinary barriers remain to the realization of a competitive marketplace in this state to the extent that the TCG suggestion would lead towards the competition which this Commission and the Telecommunications Act of 1996 promised consumers like myself, including lower rates, I can only applaud it.. Moreover, it is my understanding that there is in fact one jurisdiction New York where local and intraLATA toll calls are combined for purposes of reciprocal compensation, and such has been the case for more than two years. And from what I have read and been told by acquaintances that are knowledgeable in the telecommunications field, the New York Public Service Commission has issued a report that is strongly favorable to the Section 271 application of Bell Atlantic-New York (BA-NY) which, if granted, would allow BA-NY entry into the long distance market. So, in view of the above jurisdiction where a competitive marketplace apparently has most successfully flourished, local and intraLATA toll calls are combined. I would hope that this Commission would take administrative notice of the New York proceeding. In short, while TCG's comments are not necessarily a remedy, I believe they do dramatically point out some of the shortcomings sighted in the approaches that were advocated by AT&T, as well as BA, and the Staff. Q. Why do you disagree with BA's suggestion that a market driven approach might be appropriate? A. I believe that my comments, immediately above, particularly as documented in the Atlantic-ACM report, and as discussed in the TCG testimony, dramatically underline why BA's suggestion for one approach that might be one that is "market driven" is nothing but a blatant red herring, which should be treated as such. Q. Why do you believe that assertions as to the additional costs of Bell Atlantic should be treated as unproven, and disregarded? A. First, I would point to my earlier comments about the apparent dramatic drop in transport costs, as validated by the extraordinary, rapid decline in per minute use of charges for IP-based and long distance telephony rates by companies such as ICG, Qwest, and others. Second, I would note that all cost data that is being supplied by Bell Atlantic-Maryland, which in-and-of itself makes it suspect there must be a full and open opportunity to test all such data, which should then be put under a critical INDEPENDENT eye, preferably by the Office of People's Counsel, and perhaps a mutually agreed upon outside consultant to review the costs which should be underwritten by this regulated monopolistic organization for there is nothing truer than whosoever has monopoly control over the information, they can effectively ensure that such information will be presented in a manner that is most favorable to its own position. Unfortunately, it is also a truism that small consumer groups, like my own homeowners' association, do not and will never have the resources to aggressively pursue the kind of discovery and analysis that is desperately essential to drilling down through the layers of information of a corporate behemoth like Bell Atlantic, which has numerous sub-organizations under its direct control. Therefore, we accordingly must look to the servants of the public interest, like this good Commission (as well as the Office of People's Counsel) to assist us against such extraordinary odds. Q. On their face, do you believe that the cost assertions of witness for Staff and of Bell Atlantic should be discounted? A. Absolutely. First, if you will note, and most critical is the fact that the Staff witness, Steve Molnar, speaks almost exclusively in terms of alleged lost revenue to BA, and NOT in terms of underlying costs. Yet, it was my understanding in this post-Telecom Act, pro-competitive environment, that absolute revenues are NOT the touchstone. No longer is a guaranteed revenue stream supposed to be the touchstone or "sine qua" none of the public interest. Much like the Federal Line charges (an outright windfall profit) and BA-MD's direct mileage charges on the consumers bills are one such source of documentation. I'll quote Mr. James Crawford, an interested party in this case, "I've had this line charge for more than 20 years, that's more than $24,000. I've more than paid for the "line" to be run to my house. Multiply that amount times (x) the number of consumers who've paid this amount, and you can definitely say that "Bell Atlantic has more than collected its fair share of reasonable profits from consumers." Rather, I would strongly suggest that the real issue should be what actual COSTS are being incurred, and further suggest that such costs be assessed on a forward-looking basis so that they are reasonable, i.e., utilizing some form of long run incremental costs (LRIC), such as total service long run incremental costs that are reasonable and prudent. Second, this Commission can take administrative note of the fact that since 1988 the FX metro rate for northern Virginia has been fifty cents a month, rather than the more than $15 charged to consumers like myself here in Maryland, or none at all charged in Tennessee. Yet, I am unaware of any economic hardships that are being experienced by Bell Atlantic and/or its ratepayers in Virginia over the last decade, and there is no evidence in this or any other record that would support such an assertion. Accordingly, absent detailed, forward-looking cost-based proof that BA in Maryland has costs (including a reasonable profit which, of course, is part of an LRIC analysis) that are more than 30 times that of its sister company immediately across the river, I would urge this Commission to presumptively determine that the current extraordinary FX costs, that are being applied here in Maryland, are so high as to artificially suppress the greater FX usage that otherwise would result. The end result is that suppression of such FX usage further undermines the Community of Interest test arguments that are supported by Staff and BA. Third, I would note that BA-MD also relies on the fact that its expanded calling area service is only marginally used. Again, this may well simply be a self-fulfilling prophecy given the high cost of the service, its price may artificially be suppressing usage by consumers that otherwise be taking advantage of improved telephone calling in their areas. In fact, BA's announcement of its new SoundDeal service coming soon here to Maryland would seem as much a belated attempt to continue to hold consumers like myself essentially captive albeit at a lesser level of revenue, than a market-driven response. Fourth, at page 18 of his testimony, the Bell Atlantic witness focuses first and foremost on BA's lost revenue opportunity. References to costs are general in nature, not specific, are asserted without specificity, and in fact, at page 12, BA admits that it "is not able to complete its analysis of the costs associated with making these changes." Interestingly enough, this reference occurs immediately after its description of the alleged "lost revenue" that it will incur (the specific testimony cited here by way of example was in relationship to the Poolesville/North Beach local calling areas, but the like approach is pervasive throughout all areas discussed). Clearly critical to BA's approach is the alleged "lost revenue" opportunity which presumes that BA is entitled to a set revenue quotient, and which from day one Staff has attempted to address versus at looking at how much already BA-MD is already overcharging in high rates compared to other states in our geographical area, including charging per minute toll charges rounded up, versus per six second increments. I respectfully suggest that such a continued approach is diametrically opposed to the move towards a competitive marketplace, which in turn by definition requires a recognition of a forward-looking cost analysis. Application of such an action will surely result in the rapid debunking of the strategy put forth by BA. BA states flatly at page 18 that the increase in traffic occasioned by an expansion of local calling areas "places additional demands on BA's switching and trunking facilities." BA has failed, however, to quantify such additional demands, particularly from a monetary perspective. This Commission is well aware, I am certain, that with the rapid deployment of extensive fiber optic networks by BA, its sister RBOCs, other ILECs, as well as CLECs and IXCs, the amount of CAPACITY that is now available has jumped tremendously. So it is indeed questionable as to how marginal the trunking COSTS would be that BA in fact face in the foreseeable future with these technological advancements. Moreover, with the advent of ADSL and HDSL technology, the amount of capacity that is now available even over traditional copper loops has been increased a thousandfold. Further, switching effectively has become a commodity moreover, switches are modular, and can be sized to accommodate incremental traffic increases. Before any protective plan is adopted due to BA's alleged revenues, BA should be required to prove clearly and convincingly that its switching architecture has been engineered to maximize efficiency and reduce to the absolute minimum any additional costs that it may sustain (whereas in fact, there has been no showing to date whatsoever as to whether BA has any additional available switching capacity in any and all affected tandem and end offices with respect to the potential expanded local calling areas!). Q. Are there any other benefits that you would see from having expanded local calling areas that the other commenters have not touched upon? A. Yes. In addition to statements previously made, it is my understanding that our state, like so many others, is repeatedly facing the issue of the rapid depletion of numbers (NXX codes) due to extraordinary increases in telephony by virtue of faxes, internet, and second or third voice lines to the homes (some even say that the teenage children of baby boomers are the driving force behind this last factor!) It is my understanding, and suggestion, that expanding the local calling areas will more than likely readily allow you to combine Rate Centers (as a number of other states are currently are considering, i.e., New York and Colorado), and that with larger Rate Centers, the drain on numbers will be significantly eased. The Commission should ORDER, that Bell Atlantic's current rate groups be consolidated to lowest number of rate groups for ease of monitoring and reasonableness. This action would also be in the best interests of the Commission, thus enabling it to monitor Bell Atlantic's earnings and, should the over earnings continue, the Commission will be able to investigate this matter with the assistance of the Office of the People's Counsel, outside independent auditors, and order such further reductions and improvements as necessary. In this way the urgently needed expansion of our local calling areas under consideration in this docket, and lower rates, will likely have beneficial effects for numbering resources, and also be a benefit to the State, and the economy. Q. Would you please summarize your testimony? A. Yes. The Community of Interest test that has been espoused by Bell Atlantic and staff is an antiquated way of looking at things, which effectively will result in the preservation of the Company's existing monopoly revenues. Moreover, a focus on revenue, rather than on forward-looking costs, also is an artificial and anti-competitive, anti-consumer construct. Since its decision in April 1994 in the original MFS-Intelenet case, this Commission has been a national leader in bringing competition, and in some cases, improved calling areas to our communities. Whereas, I would urge the Commission to seriously consider the comments of myself and of Mr. Ronald Isaacson, as well as those of the Office of People's Counsel and TCG, and continue to extend the pro-competitive and pro-consumer tradition. I want to thank the Commission in advance for your continuing dedication and sensitivity to the legitimate concerns of consumers like myself and the fellow members of our homeowners association, and the surrounding communities in Anne Arundel, Calvert, Charles, Prince Georges, Saint Mary's, Howard, and Montgomery Counties . Q. Do you have any other testimony to add at this time? A Not at this time. Thank you, Ivan (John) Petric, President Bay Country Estates Homeowners Association, et.al. 6343 Meadowland Drive Dunkirk, MD 20754-9535 202-606-2554 (Work); 202-606-1163 (Fax) 301-855-7009 (Home); 410-257-0398 E-mail: BayCountry@Yahoo.com; IPetric@opm.gov 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 Keefer, 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) Prince Jenkins, Esq. 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) J. Edward Davis, Esq. 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. Swidler & Berlin, Chartered 3000 K Street, N.W., 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 418 Cannon House Building Washington, D.C. 20515-2001 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) Honorable Leo Green 212 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3631; 301-858-3174 (Fax) Honorable Leonard H. Teitelbaum 205 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3151; 301-858-2409 (Fax) Honorable Patrick J. Hogan 316 James Senate Office Bldg. Annapolis, MD 21401-1991 301-858-3686; 301-858-3617 (Fax) 1-800-492-7122 Ext. 3686 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 Jennie M. Fo 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 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) Virginia Avers Acting Executive Director Calvert Chamber of Commerce 226 Marrimac Court Prince Frederick, MD 20678 301-855-1930; 410-257-3140 (Fax) 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) 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 Mr. Nicholas G. Andrews Ms. Dana R. Andrews 4619 Langdrum Lane Chevy Chase, MD 20815 301-652-2497 Mr. Eldon B. Erickson Ms. Patricia G. Erickson 11026 Webster Drive Lusby, MD 20657 301-326-2053 Mr. Richard D. Lawrence 4131 Birch Drive Huntington, MD 20639 410-535-1703; 202-682-7711 (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-W; 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. Dennis Y. Howard 1705 Wickham Way Crofton, MD 21114 410-721-8739; 301-249-1063 (Fax) 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 Mr. L. T. Pimental 1517 Widows Mite Road Edgewater, MD 21037-2144 410-956-3238 (Home); 301-261-4545 (Work) 410-956-4700 (Fax) 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. Sherman W. Benton 3501 29th Place Temple Hills, MD 20748 301-702-2872 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 Mr. James H. Crawford P.O. Box 236 Bryantown, MD 20617 301-870-2036 Mr. Peter Perry, President South County Coalition, Inc. P.O. Box 154 Davidsonville, MD 21035 301-261-7527 Mr. Ronnie W. Pitcock, Jr. 38 Lark Bunting Lane Littleton, CO 80127 1-888-947-2638 (Date) Ivan Petric On behalf of the Bay Country Estates Homeowners Association, Inc. And Surrounding Communities, et.al. P.O. Box 444 Tracy's Landing, MD 20779-0444 (Residence Address) 6343 Meadowland Drive Dunkirk, MD 20754-9535-1 301-855-7009 (Home) 410-257-0398 " 202-606-2554 (Work) 202-606-1163 (Fax)