The Maryland-National Park and Planning Commission is hardly a "shadow government" {front page, June 14}. It is well recognized as a legitimate, state-chartered, bi-county agency consisting of the Montgomery and Prince George's County planning boards, planning staff, park department staff and their bi-county offices. The commission's authority is granted under Article 28 of the Annotated Code of Maryland, commonly referred to as the "Regional District Act."

The Montgomery County Planning Board is accountable to the county council and the county executive. Two members of the Montgomery County Planning Board are appointed by the county executive and three by the county council; each member must be confirmed by the other body, and can be removed by the appointing body. In Prince George's, board members are appointed by the executive and confirmed by the council.

The planning boards advise the county governments on comprehensive land-use planning, including acquisition and development of park land. They have been delegated the regulatory authority to approve or disapprove preliminary plans of subdivisions, but are governed by the zoning ordinance and the subdivision regulations (which are approved by the county council) in addition to their own rules of procedure. They are also covered by the state's administrative rules of procedure, and they adhere to strict rules of notification of adjacent property owners, homeowners and civic associations and other interested parties, regarding subdivision or similar activities in their neighborhoods.

More careful attention should be paid to defining accurately the concept of "shadow governments." This would enable the public to judge for itself between those organizations, public or private, that have a legitimate purpose and those that serve only their own ends or a very limited constituency.

PATRICIA V. PLUNKETT

Community Relations Manager

Montgomery County Planning Board

Silver Spring