Plot owners at Aspin Hill Pet Cemetery, the country's second largest pet burial ground, are fighting plans of a development group to build medical offices on three of the cemetery's 7.7 acres. The owners contend that the beauty of the place would be marred by the construction, and are opposing the required zoning change.

"I know we're just the little guys in this matter," said Noel Bob O'Dell, who purchased plots at the Silver Spring cemetery for his dog, himself and his half-brother. "Aspin Hill has the most tranquil and beautiful atmosphere, and I'm afraid this development might change all of that."

Plot owners at the 65-year-old cemetery on Georgia Avenue, where more than 50,000 animals -- and 30 pet owners -- are buried, have sent a petition opposing the development to county zoning officials. It was signed by 47 persons.

The developers, the Northgate Professional Park Partnership, which is managed by E. Brooke Lee III, plan to build on land now occupied by several buildings, but said they would not disturb the graves. The cemetery is surrounded by commercial strips and neighborhoods of single-family houses.

Lee said the medical facilities would be built no closer than 15 feet from the burial ground.

The four-member partnership has had a contract for a year to buy the entire 7.7-acre cemetery from Silver Spring veterinarian Edgar Ruebush and his wife June.

The developers said they hope to set up a maintenance fund for the graves and donate the cemetery to a nonprofit group, but were turned down by their first choice, the Montgomery County humane society.

Lee said his company is working on a legally binding agreement that would fulfill existing contracts by granting plot owners access to the grave sites. However, no new burial contracts will be accepted, he said.

Sale of the cemetery is contingent on rezoning that would allow construction of a strip of office town houses at the southwest corner of Aspen Hill Road and Georgia Avenue.

While the planning board has given preliminary approval to the change, plot owners contend that they were not given adequate notice of the hearings.

One of 23 pet cemeteries in the United States, Aspin Hill is the final resting place for cats, birds, horses and dogs, including seven dogs that belonged to the late FBI director J. Edgar Hoover. Burial fees range from $297.50 to $551.

Founded in 1921 by the late Richard C. Birney and his wife, Aspin Hill is modeled after "Le Cimetiere des Petits Chiens" (the Cemetery of the Little Dogs) established just outside Paris in the mid- "Aspin Hill has the most tranquil atmosphere . . . . " -- Noel Bob O'Dell 18th century. The cemetery here was sold to the Ruebushes 25 years ago.

The final decision on the rezoning rests with the County Council, which is waiting for a recommendation from a hearing examiner.

Meanwhile, Northwest Washington resident O'Dell still plans to be buried at Aspin Hill, next to the cremated remains of his half-brother, Edward Hulburt Rich, who died last January. A plot is also reserved for his 13-year-old collie, Punkin.

"My brother and I love Punkin so much that we decided we would be buried there together," said O'Dell, 50, a security supervisor at the Paralyzed Veterans of America office in Washington.

When the time comes, O'Dell said, he will bury his pet beneath a granite marker with the inscription, "He was our child. Together in life, together in death."