Clarence Pendleton, chairman of the U.S. Civil Rights Commission, has a knack for saying things about black people that would get him labeled a racist were he white. But he is a black man who has dared to say: "Black leaders have led blacks into a political Jonestown" and "Affirmative action is divisive, unpopular and immoral." Only last week, he said many "supporters of civil rights" and "media-designated black leaders" are "racists."

Why does he say these things, many people ask? Is he a "lackey" for the Reagan administration as some charge? Or does he really believe the things he says?

As much as I'd like to dismiss him, I can't. Like the proverbial bad penny, he keeps turning up. He is part of a sharp new rightward turn in American policy and politics that can't be ignored and has even engulfed some blacks. As this administration's chief racial symbol, he uses outrageous and inflammatory statements to oppose black leadership, dislikes the use of quotas to correct imbalances that result from discrimination and, in line with administration civil rights policy, speaks out against favorable treatment for minority groups.

Since William Junius Wilson wrote his conservative book, "The Declining Significance of Race," certain right-of-center blacks have proposed the philosophy that the problems of the underclass result more from lack of education and training than from racism. I don't think these intertwined problems can be easily separated. But that controversial philosophy still does not override this truth -- despite problems that result from shifts in the economy, the majority of blacks have traditionally concentrated on bringing a liberal, antiracist position to public policy.

But what is truly unbelievable about Pendleton is not that he thinks this traditional role is now archaic, but that he goes dangerously further and suggests that blacks are imagining problems, almost conspiratorially trying to blemish America by saying that conditions are worse than they are.

How can he say that when, according to his administration's Census Bureau, blacks are being disproportionately hurt by the dramatic changes taking place as a result of the shifting economy, by deindustrialization, budget cuts and the reinterpretation of civil rights that has resulted in weaker enforcement?

On just one score, budget cuts, James Turner, a professor at Cornell University, said that "more than 50 percent of minority students will be affected if Reagan budget cuts for higher education go into effect. At least half of blacks critically depend on financial aid. We may see a real closing of opportunity for blacks to go to college."

So black leaders aren't just blowing smoke in the wind when they criticize student loan cutoffs or point out that unemployment, which is more than twice as high among black adults, has hit hardest those industries and cities where blacks are concentrated. They know these problems are shaking the bedrock of America's black communities.

Now it's significant that though Pendleton heads a fact-finding agency that once had a reputation for careful research, he does not support his assaults with studies that support his positions. He doesn't show longitudinal evidence that white corporations are hiring larger numbers of blacks on a voluntary basis or clear studies that school integration has expanded despite weaker enforcement. He does not call up such data because they do not exist.

So I'm led to conclude that Pendleton is not engaging in honest debate but is using taxpayers' money to make an ideological assault on civil rights, one that goes hand-in-glove with William Bradford Reynolds' legal assault. Pendleton hammers away at black leaders, and they go on the defensive, and the exercise looses a smoke screen that hides the true impact of his boss' policies.

But I think much of Pendleton's act is aimed at whites, and his power may be that of a kind of political Stepin Fetchit. He may be the front-runner with the psychologically liberating news that the majority population need not feel obligated to pursue justice. He seems determined to lift that responsibility from their shoulders, happily performing this administration chore to advance his own career in some conservative circles.

But the truth of the matter is that while Pendleton may be the incarnation of black America's worst fears -- a loose-tongued, ambitious man who is insulated and isolated from the daily reality of black America, he could be used by blacks if viewed properly. He could be seen as a barometer of the New Right's most frightening attitudes. In that way, some good could come from this bad penny after all.