Following the directives of its new chairman, the Federal Trade Commission has launched a stepped-up campaign to intervene in other government agency proceedings and comment on the effectiveness of dozens of pending federal rules.

In this spirit, the staff filed a 14-page legal memorandum yesterday with the Federal Communications Commission in support of the FCC's plan to grant radio and television licenses through a lottery instead of the lengthy and costly hearing process.

The filing--the first made before any government agency since James C. Miller III assumed the agency's chairmanship three months ago and approved by the commission--represents a shift in the FTC's policy.

Although the agency has in the past made similar filings before the Interstate Commerce Commission, the Civil Aeronautics Board, the Federal Reserve Board and the Department of Energy, it has filed few comments before the FCC.

In fact, a little more than two years ago, the FTC commissioners strongly discouraged its staff from preparing comments on telecommunications and broadcasting issues before the FCC on the grounds that the subject was too far afield from the agency's basic expertise of antitrust and consumer protection issues.

Nonetheless, FTC officials now say the FCC filing yesterday will be the first of many before a host of government agencies. Miller, a strong deregulation advocate, has promised greater scrutiny of other agency proceedings to make sure rules are cost-effective and ensure competition.

The prospect of such future filings was one reason why yesterday's filing was strongly criticized by FTC Commissioner Michael Pertschuk.

"The staff enters into areas where we do not know enough about the issues to discuss them fully and adequately," Pertschuk said in two-page separate statement.

Specifically, the staff applauded the FCC's proposal of a lottery, saying it is "probably preferable from a competitive and consumer welfare perspective to other methods presently available to the FCC." The staff said a lottery is better than a comparative hearing in which the qualifications of competing applicants for television licenses are scrutinized to determine which would provide the best public service. Its reason: Lotteries allow the FCC to license new outlets more quickly.

Pertschuk, however, denounced that idea, saying, "pure dumb luck is justified as a better way to allocate licenses than a rational decision making process, simply because it works faster."

Inititally, Pertschuk voted along with his three fellow commissioners to permit the staff to release the report--even though he didn't agree with the staff position. But yesterday, after he released his separate statement, he changed his vote to make it clear he did not agree with the the staff's action or with the comments.

Also filing at the FCC yesterday was American Telephone & Telegraph Co. in response to a complaint filed against the Bell System by Fujitsu America, Inc.

Fujitsu has complained that AT&T violated the law when it rejected Fujitsu's bid to build AT&T's proposed fiber-optic system in the Northeast between Washington and Boston.

Although Fujitsu claimed its bid was the lowest, AT&T selected its own subsidiary, Western Electric, to build the new lightwave technology that promises a revolution in telecommunications systems.

AT&T defended its choice of Western Electric yesterday, saying it "took into account concerns about the national security and defense, trade reciprocity, balance of trade and the possiblity that lightwave technology might be dominated by a foreign supplier."