1.                  Neutral election administrator.  As before, we believe that this referendum should meet the standards embodied in the Labor Management Reporting and Disclosure Act (“LMRDA”), the recommendations of the Department of Labor, the practices of the American Arbitration Association, and others.  In order to do this, we ask that a true professional and neutral election administrator be appointed to conduct all aspects of the process, including supervision of the printing and mailing of ballots.  The American Arbitration Association is the preeminent administrator in this field, and one that everyone in this Brotherhood can have confidence in.  As we described to you and to the Court last year, we do not believe that Delancey is acceptable as the election administrator in this matter.  While Delancey has conducted ratification votes in the past, it is not a professional election administrator.  Moreover, as a major vendor for the Grand Lodge, it is all too possible that Delancey will be seen to be biased toward the position of the Grand Lodge officers who favor ratification of the merger.  In addition, Delancey has a disturbing record of breaches of election neutrality.

2.                  Count by Local Lodge.  We again believe that the votes must be counted by Local Lodge.  Segregating and counting ballots by lodge offers a quick check to observers on the reliability and honesty of the election process.  An abnormally high turnout from certain local lodges, or a lopsided vote either for or against the merger could be an important indication of potential vote fraud.

3.                  Right to be heard by the Members.  Opponents of the proposed merger, including the Pennsylvania Federation, intend to send one or more mailings to the membership (or portion thereof) of the union, sharing our views on this important subject.  If we can voluntarily agree on this issue, the Pennsylvania Federation is ready to pay the cost of the mailing(s).  I am requesting that Grand Lodge either (1) provide us with mailing labels of the membership, or (2) commit to send out our communications, at our expense, as requested.  We would like to have at least one of the mailings in the mail no later than seven (7) days prior to the time the ballots go to the mail.  In addition, we ask that one page of the print version of the BMWE Journal be assigned to us for the purpose of communicating any opposition to the merger, so that members will have a chance to read all views on this issue.  Similarly, we ask that one page of the Grand Lodge website be assigned to us for the purpose of communicating our views.  We note that the Brotherhood of Locomotive Engineers provided such access to opponents of their merger in 2001.

            As stated before, we believe that under these circumstances, such access is mandated by LMRDA.  We also note that the resolution passed by the delegates at the Grand Lodge Convention call on you to enable the membership to cast “an informed vote.”  You cannot have an informed vote if the members hear only one side of the story.  Thank you for your attention to this letter.  We look forward to hearing from you on this subject as soon as possible.