Merrill Cook may get into a race in 1994 after all, the leader of the Independent Party of Utah said Friday.

Cook said he's "seriously considering" running in the 2nd Congressional District as an Independent. He said he's "absolutely not" going to rejoin the Republican Party - a party he left in 1988 to challenge then-GOP Gov. Norm Bangerter.If Cook enters the congressional race, it would be bad news for Rep. Karen Shepherd, D-Utah, the current officeholder. Shepherd needs all the independent votes she can get this year. She's facing, once again, a challenge by Republican Enid Greene Waldholtz. Republican Carol Nixon also plans to run in the 2nd District.

Waldholtz ran against Shepherd in 1992, losing a close, tough campaign. Placing Cook in the mix of a three-way race can't be good news for Democrats or Republicans, but it would especially cloud Democrats' hopes.

Cook ran as an independent in the gubernatorial races of 1988 and 1992. Democrats believe - although Republican Party leaders strongly disagree - that Cook cost Democrat Ted Wilson the 1988 race. GOP Gov. Norm Bangerter ran a good race that year, coming from far behind to nip Wilson in the final election. Bangerter won 40 percent of the vote to Wilson's 38 percent. Cook finished a distant third with 21 percent of the vote. At one time, Wilson led Bangerter in the polls by 35 percentage points.

In 1992, Cook did much better. He clearly hurt Democrat Stewart Hanson and made a strong showing. GOP Gov. Mike Leavitt won the race, getting 42 percent of the vote. Cook got 34 percent of the vote, and Hanson finished third with just 23 percent of the vote.

Cook says the 1992 gubernatorial results give him heart in a 2nd District race this year. He says he's analyzed the results and they tell him that he ran neck-and-neck with Leavitt in the 2nd District and beat Hanson in the district.

The 2nd District takes in the east half of Salt Lake City, the east side of unincorporated Salt Lake County and all the other cities in the county except West Valley City. West Valley City, the western half of Salt Lake City and the west side of the valley are in the 3rd Congressional District.

"I would never go back to the Republican Party, especially to face another (GOP) candidate in the party convention who is supported by so many legislators," Cook said, referring to Waldholtz's party support.

"Now, an Independent Party candidacy in the 2nd District; that's what I'm considering. My interests lie in Congress and congressional reform," Cook said.Cook's Independent Party is now circulating citizen petitions that - if certified, placed on the 1994 ballot and approved by voters - would limit the terms of federal, state and county officeholders and require a run-off election between the top two vote-getters in any race in Utah where one candidate didn't get more than 50 percent of the vote in a general election.

For example, if Cook's initiative had been law in 1992, Cook would have faced Leavitt in a gubernatorial run-off election because Leavitt didn't get more than 50 percent of the vote in the regular November election.

A congressional candidacy by Cook in 1994 would give him a platform to push his congressional reforms and his citizen initiative.

With a record of harming Democratic candidates in his three-way races, Cook's entry into Shepherd's race would pose real problems for the freshman Democrat. Polling by Dan Jones & Associates shows the 2nd District is slightly Republican. But it has been held by Democrats the last eight years - six years by former Rep. Wayne Owens and the last two by Shepherd.

But Shepherd has been under an organized attack by state and national Republican Party leaders for a year now, and a new Deseret News/KSL poll shows that her job approval rating has dropped below 50 percent in her district - a danger zone for any politician in Utah but especially precarious for a Democrat in this Republican state.

Cook is a millionaire who has spent freely from personal funds in his previous campaigns. He spent more than $600,000 of his own money in his 1992 race. While federal law restricts campaign fund raising in many areas, a candidate for federal office can spend as much of his own money as he wants. Thus, Cook can fund his own race this year, if he so wishes, and keep pace with Shepherd's and Waldholtz's spending or actually spend more.

Cook says he'll decide whether to enter the 2nd District race as an Independent by the end of January. The candidate filing deadline is March 15.