A $3.7 million public housing project scheduled for construction in Montgomery County has been dealt a nearly fatal blow by federal officials who have put the proposed development on indefinite hold.

The move marks the second time in less than three months that a low-income housing project in the county has been blocked by Department of Housing and Urban Development (HUD) action after residents in the proposed area complained to the federal agency.

An option to buy the land for the 39-unit project, scheduled to be built on Mateney Road in the Germantown area, expired this week after the local Housing Opportunities Commission (HOC) was unable to guarantee the developer that federal funds would be available for construction.

Money for the Mateney Road project was in its last stages of commitment, with local housing officials expecting a final federal signature on the contract any day, when HUD recalled all files on the project from its local office and halted processing of the plans. A HUD spokeswoman acknowledged that the records had been withdrawn for study after residents in the area complained about the project and questioned its cost, but added that the case is being reviewed and no decision has been made. Local housing officials said, however, that the last time a file was called back to HUD's central office, the project eventually was dropped.

That was in November and involved the 48-unit Broadmore project planned for the Colesville area. Like the Mateney Road plan, which has been opposed by residents in the area, the Broadmore project was hotly contested by neighbors. HUD officials never officially refused to sign the Broadmore contract, but commission member Harold L. Kramer said that community opposition, coupled with the recall of files and other problems, eventually led to HOC abandonment of the project.

In addition to the citizen opposition and its apparently growing clout within the federal agency, the supply of money from HUD is drying up, said county housing officials. Prospects for building any subsidized housing in the county looked even bleaker this week when a partial draft of Ronald Reagan's latest round of budget cuts showed that no new money would be committed for subsidized housing programs in fiscal 1983. The budget calls for expenditures of $3.8 billion nationwide, and only on those programs already committed.

The most recent HUD move adds to an already troubled past year for the Housing Opportunities Commission that culminated in a review by the county's state legislative delegations of 15 bills calling for a major overhaul of the HOC's operating procedures. In particular, the bills, which are still under consideration, call for more public comment and hearings on HOC projects and some type of budget review of the independent housing agency at either the state or the local level.

The County Council also is considering incorporating a number of the tenets of the bills in its countywide housing policy. Last week, when representatives from the agency and the council met in Annapolis with several county members of the House of Delegates, the three groups seemed to be reaching for conciliation. During the session, Del. Joel Chasnoff, author of the bulk of the bills, uncharacteristically congratulated the agency for its more open policy and responsiveness to community questions in recent weeks.

It is expected that if the County Council can come up with procedural checks satisfactory to the delegation's housing committee, the state bills will be withdrawn from consideration.

Among the council proposals would be regulations requiring the agency to hold public hearings on all subsidized housing projects. Low-rate mortgages funded by the agency would not be subject to this requirement, however. Another proposal calls for a map review process requiring the county executive to list according to preference areas where public housing should be built in the county.

Commission representatives, who had vehemently opposed restrictions in earlier meetings, agreed to the bulk of these changes.

"We've been so tied up in the procedural issues that we haven't been able to debate the big issues . . . (like) whether the county should even build housing for low-income people," said Commissioner Cathy Bernard in an interview after the meeting. "Everyone says the whole problem has been with procedures and not philosophy. Now, we'll see if this is all true when they don't have the procedures to knock around anymore.