The chairman of the Montgomery County Republican Party has asked the county Ethics Commission to investigate whether County Council member David L. Scull used county stationery, envelopes and postage to send a "political" mailing to Democratic Party officials in violation of county law.

Scull, vacationing in Maine, was unavailable for comment, but his staff assistant, Ken McIntyre, called the request "groundless" and said the mailing was "public money put to a good use."

At issue is a July 22 letter on County Council stationery that was sent by Scull to 350 Democratic Party leaders and precinct officials. The letter covered a range of issues, from next year's council election to recent legislation sponsored by Scull to curb the county's housing boom.

Scull opened the letter with a request for "your views" on "some new initiatives" and closed with a plea to buy season tickets to help bring a National League baseball team to Washington.

The letter included enclosures -- summaries of the housing legislation and a prepared statement on teacher salaries -- and praised party leaders for organizing several coffees attended by council members.

GOP chairman Fredric J. Mashin charged in a letter to the Ethics Commission that inclusion of references to "precinct officials" and the (Democratic) central committee "clearly establishes" that the underlying purpose of the letter was "political."

"We object to the use of county government material, time and money for political purposes . . . , and at the very least," he wrote, "we believe that Mr. Scull should reimburse the taxpayers . . . . "

McIntyre said the mailings, which began in July, are designed to counter a campaign by developers who have taken out full-page ads in local newspapers to protest the housing legislation, he said.

More than 500 community leaders have been sent similar letters, at a cost of about $300, and county GOP leaders also will get missives as soon as the party releases its mailing list, which has been requested, McIntyre said.

"I don't see how you can classify that political; it's really a matter of keeping your constituents informed," said Jay S. Bernstein, chairman of the county Democratic Party.

Council members receive $1,100 a year for postage but are prohibited by county law and the county charter from using public money for private purposes, said council staff director Art Spengler.

Russell I. Brown, chairman of the county's Ethics Commission, said yesterday that he had not seen Mashin's letter or Scull's letter and declined to comment.