Maryland Politics Watch: February 2010

Sunday, February 28, 2010

Madaleno's Letter to Northrop Grumman

Following is the letter from Senator Rich Madaleno (D-18) to Northrop Grumman that was referenced in an article yesterday by the Post. In the letter, Madaleno asks the company to not move to Virginia based on its recent steps backward on protections for LGBTs.

County Council to Hold Town Hall Meeting in Kensington

Following is the press release from the County Council.

Saturday, February 27, 2010

Rushern Baker on the Spot, Part Six

Prince George’s County Executive candidate Rushern Baker has taken tens of thousands of dollars from a GOP candidate for U.S. Senate who is a birther, even more money from an obscure entity operated by his campaign Treasurer and at least three-quarters of a million dollars from one apartment building owner. All of the above is legal. But what about his slate account?

Friday, February 26, 2010

Blair Lee Protests Barve Response to Power Outages

Gazette columnist Blair Lee, one of MoCo's most ardent defenders, is crying foul on House Majority Leader Kumar Barve's call for an examination of disproportionate power outages in MoCo during the recent blizzards. In his letter to the Public Service Commission (PSC), Barve noted that Pepco suffered 78,000 outages in MoCo against just 7,700 in Prince George's County and asked the PSC to find out why. That rubbed Lee the wrong way, and he sent the following email to Barve.

Stud of the Statehouse

We have never seen their like before. They are legion, the faceless fans who swarm into this blog looking for information on the object of their desire. And what is that object? He is the answer to their dreams, owner of their lonely hearts and the undisputed Stud of the Statehouse:

Sharon Dooley Announces Campaign Kickoff

Council District 2 candidate Sharon Dooley has announced a campaign kickoff event on Facebook. We reprint the notice below. Also, the Gazette profiled Dooley on Wednesday.

Rushern Baker on the Spot, Part Five

Powerful people usually have powerful enemies. Southern Management Corporation (SMC) boss David Hillman and Prince George’s County Executive Jack Johnson proved that axiom true with a bitter feud that eventually benefited Rushern Baker in a VERY big way.

Thursday, February 25, 2010

Berliner Hiring Campaign Staff

One of our spies intercepted the following message from a Google group.

---------- Forwarded message ----------
From: HMILLS3 [email withheld]
Date: Wed, Feb 24, 2010 at 12:12 AM
Subject: [jobsthatareLEFT] Campaign Staff & Interns needed for Local Montgomery Count MD race
To: JobsthatareLEFT

Paid and unpaid positions available on local District County Council race in Montgomery County, MD. Field Director, Canvass Organizers needed. Contact Heather Mills, Campaign Manager, at [email withheld] for more information.

Heather Mills is, of course, Council Member Roger Berliner's campaign manager.

In our overview of the District 1 race, we concluded that Roger Berliner was the favorite but challenger Ilaya Hopkins had a chance. The fact that Berliner is hiring people while Hopkins is just getting started is a useful reminder of exactly why Berliner is favored. First, he is the incumbent. Second, he has lots of money. Third, this will be the third time he has run in District 1, so he knows the local players better than almost any challenger would. And fourth, he is anything but complacent.

Lenett Weighs in on the Post's War vs. MCEA

Senator Mike Lenett (D-19) sent the following email to his constituents regarding the Washington Post’s war on MCEA Monday.

What It Takes: Montgomery County Planning Board Chairs from Hanson to Hanson

By Marc Korman.

Montgomery County Planning Board Chair Royce Hanson is not seeking reappointment and the Council has begun advertising the vacancy. Before looking forward, it might be helpful to look backwards at some Planning Board Chairs.

Barve Calls for Examination of MoCo Power Outages

House Majority Leader Kumar Barve (D-17) has called on the Public Service Commission (PSC) to examine why Montgomery County suffered disproportionate power outages during the recent blizzards. Barve cited the experience of his 83-year-old mother, who had to be evacuated to Virginia, and noted the much lower rates of outage in neighboring jurisdictions. We reprint Barve's press release and his letter to the PSC below.

County Contractors Ask for Relief from Living Wage Law

At least three Montgomery County janitorial contractors are asking the county to waive its living wage law so that they can reduce employee wages. Otherwise, they are predicting that county budget cuts could put 150 janitors out of work.

Our proposal is simple. We propose reducing the cost to the County for our services so that jobs will be saved and the level of cleaning maintained for the good of the County, County employees and County facilities.

The savings would be achieved by reducing the wage paid to our employees and our company’s margin and overhead. This would reduce our billing rate from $17.25 to $14.15, saving an average of $31,000.00 per month (based on 10,000 hours worked per month) for our company alone. Similar cost reductions for the other contractor, if they were to adopt the same plan, would push the savings to about $550,000.00 annually.

We have polled our employees and they are overwhelmingly in favor of the proposal we are making. A copy of the employee agreement and waiver is attached.

The county’s living wage law was the product of a long struggle waged between 1999 and 2002, with Council Members Phil Andrews and Blair Ewing along with labor in support and parts of the business and non-profit communities opposed. The living wage is currently set at $12.95 per hour, but the law has a big loophole: it does not apply to non-profits. Since the law does not contain a provision allowing the Executive Branch to waive its requirements by itself, we believe action by the County Council will be necessary to suspend or otherwise modify it.

On its face, the contractors’ proposal creates some questions. If the workers’ wages will be cut, are the company executives willing to cut their own compensation by an equal amount? How can the county be sure that any wage concessions will not just go to the companies’ bottom line rather than solely back to the county in savings? Can the companies’ characterization of their workers’ views be trusted? (Your author knows through long experience that workers who lack union representation can be easy to scare when times are tough.) Most importantly, under what circumstances – if any - should the county be willing to relax labor protections that were won with great effort?

In their letter, the contractors claim that Director of Procurement David Dise “was in favor of the plan and was willing to take it up the chain of command for consideration.” Dise is one of the Executive Branch’s most respected managers, but this is not a done deal. We hear that the Executive has not yet established a hard and fast position on this issue. The administration has been reaching out to County Council Members for at least a week, but no consensus has emerged. We do not expect the county’s labor movement to support the proposal, especially since they had to fight for four years to get living wage passed. So anything could happen.

Do we really need yet another budget-related item to fight about?

Rushern Baker on the Spot, Part Four

Meet David H. Hillman. He’s a 67-year-old, self-made white billionaire. He once lived in Bethesda, but now lives in an 11,809-square-foot, $6.3 million mansion in McLean. He is one of the biggest apartment building owners in the Washington metro area. He has given thousands of dollars to Republican politicians including George W. Bush, John McCain, George Allen, Michael Steele, Mitt Romney and Rick Santorum in addition to thousands more to the Republican National Committee. And a year from now, he could be the second-most powerful man in Prince George’s County without even living there.

Why? Because after spending over three-quarters of a million dollars, he may finally get Rushern Baker elected County Executive.

Staff has serious concerns about whether SMC’s practices violated the FCRA. From our investigation, it appears that SMC, upon a renter’s termination of a lease with an outstanding debt, automatically reported an I-9 rating within approximately 30 days (and sometimes fewer) of the renter’s move-out date. In many instances, it appears that SMC failed to determine that the debt was uncollectible – the accounting basis for charging it off – before using the I-9 rating, even though less derogatory ratings indicating that the debt was overdue but not yet uncollectible were available and may have been more accurate. The I-9 rating is the most adverse rating available, and its presence on a credit report can contribute to a creditor’s decision to deny credit to a consumer.

However, the agency decided to close its investigation because SMC only engaged in these practices for “a very short period of time.”

4. David Hillman and Suzanne Hillman vs. Internal Revenue Service, 2001
In an epic battle that had to happen, David Hillman – one of the Washington area’s most powerful real estate owners – once squared off against one of the country’s most powerful federal agencies, the IRS.

In 1997, the IRS sent written notice to Hillman and his wife that they owed “$294,556.00 in federal income taxes for taxable year 1993 and $309,696.00 in federal income taxes for taxable year 1994.” The issue was the Hillmans’ treatment of management expenses charged by SMC to a number of their real estate partnerships characterized by the IRS as “passthrough entities.” The Hillmans deducted fees charged by SMC to the passthrough entities from their income and the IRS objected, taking them to federal Tax Court. The Tax Court initially found in favor of the Hillmans, but the IRS appealed the case to the U.S. Court of Appeals, 4th Circuit. The Appeals Court found that the Hillmans could not legally deduct the fees and decided in favor of the IRS. The case established a precedent for the real estate industry and is still cited by the IRS in its advice memoranda.

5. Lawsuits Involving Renters
Maryland courts have recorded so many lawsuits involving SMC that they may be literally uncountable. The Maryland Judiciary Case Search website reports that “Southern Management” has been a party in more than 500 lawsuits in Prince George’s County.

And the site reports that “Southern Management” has been a party in more than 500 lawsuits in Montgomery County.

The majority of these lawsuits are probably claims for unpaid rent or damaged property. That does not necessarily reflect badly on SMC as evictions and rent claims are an unfortunate part of the apartment rental business. But is SMC’s staggering volume of litigation truly necessary?

So what does David Hillman and SMC have to do with Rushern Baker? Plenty, because Hillman is BY FAR Baker’s biggest financial supporter. We’ll get into that tomorrow.

Wednesday, February 24, 2010

Nancy Navarro: "Jobs, Jobs, Jobs"

Council Member Nancy Navarro's newest newsletter starts with an obligatory photo featuring Leisure World residents - a natural given the retirement community's big role in her district - but is really all about the economy. For heaven's sake, it mentions the word "job" twenty-two times! Navarro talks about "jobs and investment for East County residents," attracting bio-tech jobs to the Route 29 corridor, more transit options to help residents get to (you guessed it) jobs, bringing jobs to Burtonsville, protecting libraries since residents use them to find (say it with me) jobs, expanding *job* opportunities for disabled residents, and so on. If you didn't get the message, the words, "Jobs, Jobs, Jobs" appear in bright red letters right in the middle of the newsletter. Sheesh, folks, it's quite a job to keep up with all these mentions of jobs!

But we believe that Navarro, who will be the only candidate who has gone to the voters for three straight years(!) by the end of this cycle, has a point. In 2006, debate over the pace of development was a big part of the county elections. 2010 looks like it could be very different.

Sierra Club to Score Gaithersburg West

In a recent email to Council Members, the Sierra Club states that it will score candidates' positions on Gaithersburg West in determining its endorsement. We reprint the email below.

-----Original Message-----
From: David Hauck
Sent: Wednesday, February 17, 2010 10:40 AM
To: Floreen's Office, Councilmember; Knapp's Office, Councilmember; Leventhal's Office, Councilmember; Andrews' Office, Councilmember; Elrich's Office, Councilmember; Trachtenberg's Office, Councilmember; Navarro's Office, Councilmember; Berliner's Office, Councilmember; Ervin's Office, Councilmember
Subject: Sierra Club adds Gaithersburg West to its voting scorecard

Dear Council members:

The Montgomery County Group of the Sierra Club is developing a scorecard of Council votes over the last four years. This scorecard will be an important element as we decide on our endorsements for Council in the 2010 elections.

The scorecard is unfinished but we want to alert you to one issue that will weigh heavily on our endorsements. This issue, the Life Sciences Center within the Gaithersburg West master plan, will come to you for decisions within the next few months.

The Countys development pattern and the associated transportation investments are the most environmentally consequential decisions that officials make. If balanced urban growth around our Metro stations reflects our hopes for a more sustainable future, then sprawl-inducing, car-demanding, unbalanced growth on our suburban fringes embodies the worst of our fears. The damage is compounded when the plan allows sprawl development at urban densities, proposes an uncertain and inadequate transit system to serve the development, and calls the result smart growth. Worst of all is creating de novo a large, dense center far from any Metro station, at the request of an ambitious land owner.

As we have said many times, our issue is not with a Life Sciences Center as such. There are proposals on the table to enhance the Life Sciences Center(s) without creating such havoc with sustainability.

We will watch closely the outcome of Council decisions on this plan. We expect the Council to agree on a plan that, to paraphrase the late Council member Betty Ann Krahnke, represents not a compromise but a solution, that promotes prosperity and sustainability.

Sincerely,

David Hauck

Chair
Sierra Club, Montgomery County Group

Our Take:

In the past, the ICC was the number one issue for MoCo environmentalists. But the Sierra Club's opposition to the project was largely washed out by the Washington Post's support for it and when their endorsements clashed, they at least partially neutralized each other. So both ICC supporters (like Nancy Floreen and George Leventhal) and ICC opponents (like Phil Andrews and Marc Elrich) - all of whom were strong candidates in other respects - got elected. Now that the ICC is headed for completion, the Sierra Club and the Post will have to move on to other criteria for endorsements.

If the Sierra Club is serious about shrinking and/or altering Gaithersburg West, one possible result is that a decision on the project's master plan could be put off until after the election. The issue could also affect the at-large County Council race. The District Council Member who represents Gaithersburg is Phil Andrews, who opposes the significant increase in density contained in the plan and would like to spread jobs to other parts of the county. If both Andrews and the Sierra Club wind up basing their support for at-large candidates on their positions on Gaithersburg West, that will make this issue a weighty one in the election.

Lessons from a South American Bus Rapid Transit System

(Or, What I Did on my Winter Vacation)
By Council Member George Leventhal.

Councilmember George Leventhal enters a bi-articulated express bus in Curitiba.

Curitiba, a city of 1.8 million people, is the capital of the state of Paraná in Brazil. In late December, I visited Curitiba at my own expense and was briefed on its Bus Rapid Transit (BRT) system, one of the world’s first and most highly-regarded. Because Montgomery County is studying BRT as an option for its residents, I wanted to find out how it is working in other communities. I found many positive aspects and some less positive.

This video demonstrates a biarticulated bus navigating a tight turn.

Within the stations, bus stops are identified with a clear map similar to the Metro route map. A tourist like myself can easily navigate most of the city by following the bus route on a map. Unfortunately, because the buses are used on multiple routes and because the bus network covers so much territory, complete routes are not shown inside every bus.

A single fare of R$2.20 Brazilian Reals (U.S. $1.22) enables a rider to take a single bus as far as it travels, even from Curitiba’s furthest suburbs into the city center. Fare revenue accounts for 100 percent of Curitiba’s operating budget. (Its capital budget – the cost of building the system – came from international investment including the World Bank and French Development Agency.)

Property values adjacent to the bus line have shown consistent increases when new express routes are constructed, increasing tax revenues to local governments. Buses utilize 20% Biodiesel to minimize emissions of carbon and other pollutants.

Less Positive Aspects of the System

My son Daniel Leventhal rides the bus.

Because the current system dates to 1974, the 29 primary bus terminals that facilitate transfers between collector and primary bus routes are aging. The two I visited were not especially attractive, and abundantly covered with graffiti.

Ms. Dos Santos told me that “the rich do not use the system much.” Those who have access to the comfort and privacy of their automobiles opt out of using the BRT system. In general, I did not find the BRT experience comparable to fixed-rail systems in terms of comfort. Curitiba does not have a Metro rail system, although there are plans to construct a rail line in time for the 2014 World Cup.

Lessons for Montgomery County, Maryland

Taken from inside an express bus, this photo shows the division of the BRT lanes from automobile lanes.

According to Ms. Dos Santos, the rate of automobile ownership in Curitiba is 22%, while transit usage is 40% and the balance of commuters travel by motorcycle or motor scooter, or walk. This helps to explain why ridership of the BRT system is so high and why farebox revenues cover operating costs.

By contrast, in Montgomery County, 66% of workers drive to work alone while only 14.9% commute by rail or bus, according to the 2008 American Community Survey.

Another important difference is the price of gasoline, which is substantially more expensive in Brazil (R$2.49 Brazilian Reals per liter, or approximately U.S. $5.20 per gallon, while I was there) than in the U.S., making automobile travel substantially less affordable for working Brazilians.

The critical question is whether increased frequency, speed and convenience would persuade enough Montgomery County residents to ride the bus to make the system financially sustainable. Even in Curitiba, where per capita income was R$17,977 Brazilian Reals (U.S. $10,005) in 2006, upscale people do not ride the bus – and there are far more upscale people in Montgomery County, where per capita income is U.S. $35,684.

The county’s current Ride-On bus system generates only approximately 15% of its revenue from fares, with the remainder subsidized from general tax revenues. The current budget crisis has highlighted the Ride-On system’s significant expense to taxpayers, although the County Council has so far resisted cuts in Ride-On service proposed by the County Executive. How much more can we afford to expand the bus system even if the current 85% subsidy from all taxpayers decreased to a subsidy of 80%, 75% or lower?

Also relevant is that the county’s bus storage and maintenance facility is at its absolute limit of available space, and a new storage and maintenance facility proposed for Clarksburg has been delayed because of concerns over runoff into Ten Mile Creek, so there is currently no place to store additional buses in the county.

An express bus departs from tube stations.

Curitiba has a long history of transit service, dating back to horse-drawn trolleys in 1887. Planning for 20 primary express bus routes began in 1966 and the system opened in 1974. For more than 35 years, primary roads have been designed to accommodate the BRT system. Municipalities in the Curitiba region served by URBS delegate management of the transit system to URBS, whose board members are appointed by the Mayor of Curitiba.

In Montgomery County, however, major roads would need to be redesigned to accomodate bus rapid transit. The state of Maryland’s recent reconstruction of Route 29 represented a critical missed opportunity to develop express bus lanes in the middle.

Our county’s primary roads (Route 29, New Hampshire Avenue, Georgia Avenue, Connecticut Avenue, Routes 28 & 198, Veirs Mill Road, University Boulevard, Wisconsin Avenue/Rockville Pike, and I-270) are owned, designed and maintained by the State Highway Administration. Close coordination between the county, the state and possibly the Washington Metropolitan Area Transit Authority (WMATA) would be necessary to accomplish the BRT vision. Ridership will be a very important criterion for winning federal funding – and ridership is the key question regarding whether the system can succeed here.

Accommodating through automobile traffic on primary roads will be another key issue. Because the buses travel on a dedicated route, automobiles may not cross primary streets at every intersection. In Montgomery County, this will affect many neighborhood streets whose residents are accustomed to being able to cross major streets or make left and right turns to exit their neighborhoods – all of which could be restricted with rapid bus routes down the center of major streets.

My visit to Curitiba was a great experience and there is no question that I would love to see similar technology employed in Montgomery County. In the near term, I will advocate for BRT on Veirs Mill Road, which along with University Boulevard has just received a federal grant for bus transit improvements, and Georgia Avenue. I am also optimistic about prospects for BRT on the Inter County Connector and the proposal for BRT on Rockville Pike contained in the White Flint Sector Plan, now pending before the County Council.

On the other hand, my visit to Curitiba did not persuade me that BRT compares favorably to fixed-rail systems as an effective inducement for riders to leave their automobiles at home. I will continue to advocate strongly for light rail on the Purple Line and, while I understand that cost factors may ultimately persuade Governor O’Malley to select BRT for the Corridor Cities Transitway, my preference remains light rail for that system as well.

George Leventhal is an at-large member of the Montgomery County Council. He serves on the Transportation, Infrastructure, Energy and Environment Committee.

Gansler Opinion on Same-Sex Marriage

Many media outlets are reporting on Attorney General Doug Gansler's opinion that same-sex marriages originating in other states can be recognized in Maryland. Those who wish to see the opinion itself can find it here. We reproduce the concluding language below.

Ilaya Hopkins Announces Campaign Kickoff (Updated)

Ilaya Hopkins, who announced her exploratory committee for the Council District 1 seat currently occupied by Roger Berliner last month, is now formally launching her campaign. We reproduce her kickoff announcement below.

Update: Hopkins's website is up and running.

Rushern Baker on the Spot, Part Three (Updated)

Meet Bradford L. Seamon. He is the President, CEO and founder of B.L. Seamon Corporation, a minority business enterprise (MBE) government contractor based in Greenbelt with offices in Atlanta and Bedminster, New Jersey. He is also very, very close to Rushern Baker.

It’s been almost 18 years since Bradford Seamon rounded the corner on his block heading towards his house only to discover the “repo man” sitting in his front yard, waiting to take his car.

As a young entrepreneur in his late twenties, he was able to pay everyone on his payroll - everyone except for himself. He took another look at his yard and kept driving.

“That’s one of the risks that you take as an entrepreneur,” Seamon said. “It’s all about being an individual and being willing to take risks. The more risks, the higher the reward.”

Seamon founded his company in 1989 and has had great success working as a contractor for the federal government and private companies, including the U.S. Food and Drug Administration, the National Cancer Institute and the Department of Labor. His firm was named as one of the area’s top 100 MBEs in November. According to the company’s website, “BLS orchestrates meetings and events, designs communication materials and Web sites, and executes program services using advanced technology, expert staff, and unparalleled client service standards. We have built our reputation by providing top-notch service and designing seamless support that allow us to work in unison with our clients and their partners.”

Minority contracting is the mother’s milk of Prince George’s County politics. The county government is saturated with minority contractors who win public consulting, vending and construction contracts and then use part of their profits to contribute to the politicians in power. All of this creates a “pay-to-play” culture that exceeds anything that has ever been seen in Montgomery County. WSSC has been nearly paralyzed for years by the relentless focus of its Prince George’s County commissioners on minority contracting requirements. Many minority contractors spray their campaign contributions liberally across the county’s political establishment and beyond. But Bradford Seamon is different. He has contributed to only four political accounts: Barack Obama ($4,550), DNC Services Corporation ($1,250), State’s Attorney Glenn Ivey ($1,250) and Rushern Baker.

B.L. Seamon Corporation has made three loans to Baker: $693 on 10/18/99, $1,192 on 11/10/99 and $1,426.69 on 8/1/02. This is the period during which Baker, who served as a Delegate from 1995 through 2003, was preparing for and running in his first race for County Executive. Seamon, his company and his wife also made 21 different contributions to Baker worth $10,613.63 from 2000 through 2008. Many of these contributions reflect Seamon’s closeness to Baker: forgiveness of interest on loans, sale of office furniture, food for a fundraising event and even a $100 generator rental. There’s nothing unusual here. Loyal political supporters often make these kinds of contributions to their candidates.

What is unusual is the behavior of a company called MStream Inc. Founded on 4/23/02 by Seamon and his wife, the company’s purpose according to its Articles of Incorporation was, “to engage in investment management and other business ventures as the officers of the corporation may decide.” The company’s business address matched the Seamons’ home address in Upper Marlboro.

On 8/2/02, less than four months after its creation, MStream made a $100,000 loan to Baker. On 8/8/06, right before Baker’s second County Executive primary loss to Jack Johnson, MStream made another $65,000 loan to Baker. On 5/8/07, MStream made a final $1,000 loan to Baker. MStream forfeited its Maryland corporate registration on 10/5/07 for “failure to file property return for 2006.”

We cannot find any record of an MStream Inc. based in Upper Marlboro undertaking any actual business activities in Maryland or anywhere else. Furthermore, Baker was the only candidate recipient in Maryland of any contributions from MStream. The Baker campaign has repaid all of MStream’s loans, but we can find no record of any interest paid to the firm.

What was MStream’s scope of business? How did it get hold of $100,000 to loan to Baker after less than four months of existence? If MStream’s money came from Seamon, why would he not loan it under his own name? Did it come from somewhere else? Will we ever know the answers?

The traditional excuse used by candidates for transactions like these is that they cannot know everything about all of their donors. That is often true, but the excuse would fail in this case for two reasons.

1. All candidates know exactly where five- and six-digit loan checks come from.

2. Bradford Seamon has been Rushern Baker’s campaign Treasurer since 1992.

The story of Seamon, Baker and MStream’s money may never be known because it has never been investigated and perhaps never will be. But as generous as Seamon has been, he is not Baker’s biggest benefactor. We will reveal that person’s identity tomorrow.

Update: All contribution and loan data may be verified at the State Board of Elections campaign finance website.

Josh Kurtz on Political Pulse on Ch. 16 TV‏

Josh Kurtz, Senior Editor for Roll Call Newspaper, columnist for the CenterMaryland blog (www.centermaryland.org) and former Gazette reporter in Annapolis will be on the "Political Pulse" TV Show on:

Thurs (Feb 25th) at 9 p.m.
Fri-Sun (Feb 26th-28th) at 6 p.m. and
Tues (March 2nd) at 9:30 p.m.

Federal, Maryland and County political races and issues will be discussed.

Political Pulse is on Channel 16 TV in Montgomery County.

Tuesday, February 23, 2010

Rushern Republican is a Birther

Let's be fair: Prince George's County Executive candidate Rushern Baker may not have much control over his GOP contributor Eric Wargotz, but this tidbit is too wild to ignore. Courtesy of blogger Mike Stark and the Examiner, here is video of Wargotz saying that he does not believe Barack Obama was born in the United States. Those remarks come in the first two minutes of the video.

Lenett Sends out New Mailer

District 19 Senator Mike Lenett has sent out a new full-color 9 x 17 mailer to his constituents touting his priorities and asking for their input. Given the unpredictable politics in the district, every mailer must be evaluated from an electoral perspective. We reproduce it below.

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