RICHMOND, JAN. 18 -- A commission studying the gaps in quality between Virginia's rich and poor schools has offered a cure that legislators say could cost $500 million annually and force Gov. L. Douglas Wilder to choose either raising taxes or raiding the wealthy school districts of Northern Virginia.

The Commission on Educational Opportunity for all Virginians, appointed by Wilder last year, finished its work Thursday night by supporting a catalogue of costly new initiatives and endorsing a redistribution of state aid that probably would mean less money for most Northern Virginia localities.

The commission's recommendations -- including smaller class sizes for kindergarten through third grade, free textbooks for all students and a general improvement of the state curriculum -- come at the same time that some of the state's poorest school districts are considering a lawsuit challenging Virginia's wide disparities in funding and instructional quality.

Similar lawsuits have led to expensive court-ordered changes in school funding in Kentucky, Texas and numerous other states.

Under a worst-case scenario studied by the commission, the new methods for distributing state aid could cost Fairfax County more than $32 million a year. Most commission members said they thought such sweeping take-from-the-rich schemes could be avoided, and Wilder recently said he opposed "any attempts to shift massive funds from well-off to less-affluent school systems."

If that's the case, legislators predicted, the only solution would be to spend more money -- increasing the size of Virginia's education pie, rather than simply reslicing it. But this would almost certainly force a tax increase that Wilder, who has been promoting himself nationally as a fiscal conservative, wants to avoid.

"The administration is in a box on this," said Del. Ford C. Quillen (D-Scott), who served on the commission. "The only way we can address disparity is with a tax increase of some type."

Wilder said he wanted the report released now so that legislators would have time to study it before next year's General Assembly session, when disparity is likely to be the paramount debate.

One example of Virginia's disparity is seen in per-student spending. Poquson County, not far from Williamsburg in the southeast, spends less than any other district, with $3,300 per student. By contrast, Alexandria adds substantially to its state aid with local dollars to lead the state with $8,000 per student.

Education Secretary James W. Dyke Jr. said speculation about the costs of ending disparity "is rather premature," and won't be addressed until next year's session of the General Assembly.

But Northern Virginia educational leaders are already steeling for a fight. "We'll be working with our legislators to turn this around," said Fairfax County School Board Chairman Kohann H. Whitney, who estimated that the report's recommendations would "cost tens of millions of dollars for Northern Virginia."

Virginia's complicated funding formula is already weighted to give help to poorer localities. The wealthiest jurisdictions, such as Fairfax City and Arlington County, must raise locally up to 80 percent of the money required to meet the state's educational standards. By contrast, poorer, mostly rural school districts pay a minimum of 20 percent, with the rest of the money coming from state aid.

The commission recommends revising the formula so that wealthier localities would be expected to pick up an even larger share, 85 or 90 percent, of total education spending. Also, the commission wants to reduce the amount of state sales tax money that is returned to wealthier localities.

Quillen, who represents a poor district in rural Southwest Virginia, said, "It's morally wrong for one segment of society to have opportunities that aren't there for others."