I am writing in response to the article "Re-Regulation Has Cable Firms Rewriting Rates" {Business, July 12}.

The article states that in anticipation of congressional proposals to restore rate regulation in the cable television industry, many cable systems around the country have offered or are considering offering an optional, reduced-price "basic" service tier to subscribers, consisting primarily of over-the-air broadcast stations. It also quotes some observers as saying that the new tier offering is designed to evade the impact of future rate regulation.

As the president of the Montgomery County Maryland system, which was mentioned specifically in the article, I wish to stress several points that are critical to understanding this issue:

First, Cable TV Montgomery has for some time been discussing this subject with county officials in the usual, cooperative and open dialogue. A basic service tier has not yet been offered to subscribers in Montgomery County. We will continue to delay any further action regarding this tier until the federal regulatory situation has been resolved.

Second, the "re-tiering" that may cable operators have offered or are considering would be mandated by the legislation making its way through Congress, in part because the creation of multiple tiers offers consumers more choices. In re-tiering now, cable operators are anticipating and being responsive to this congressiona mandate as well as responding to subscriber interest in having basic and possible other new service options.

Third, re-tiering would not result in an increase in rates to any cable consumer. The overall package of broadcast signals plus so-called satellite channels (such as CNN and ESPN) would, in Montgomery County, cost the same as it does now. The only change is that there would be two tier options instead of one: a full service option at the current price and a lower-price tier consisting essentially of the broadcast channels.

Fourth, the reduced price of a basic service tier must ultimately reflect its actual cost in order to avoid the need to subsidize it in the form of higher rates to other subscriber. We do not believe that subscribers would knowingly agree to pay such a subsidy or that the marketplace permits imposing such a subsidy.

Finally, re-tiering does not undercut congressional efforts to regulate basic cable rates. The legislative proposals before Congress provide for the Federal Communications Commission to regulate the rates to be charged for the basic tier of service. If the FCC determines that rates being charged for the basic tiers now being established in some areas are not cost-justified, it would be free to roll them back. JOHN R. EDDY Montgomery