An internal memo from an official in Gov. George Allen's Department of Environmental Quality proposed several ways to try to discredit a legislative report that savaged the governor's environmental record, such as threatening a libel suit or a congressional inquiry.

The memo, dated Dec. 20 and written by Michael McKenna, the department's director of external affairs, also suggests that the agency file a Freedom of Information Act request for any correspondence between the legislative panel and the media. McKenna said the request should be filed "under our names, so they know we're the ones coming after them."

The report, issued last month by the Joint Legislative Audit and Review Commission, accused the Republican governor's administration of coddling industrial polluters and neglecting to enforce water-quality laws. It noted that under Allen, water-pollution fines collected by the state declined from $327,000 in 1992 to $4,000 last year.

McKenna, using football jargon to describe a political play to "get us out from under" the report, states in the memo that the department should "immediately engage in some play-action to freeze the linebackers."

As word of the memo spread across Capitol Square today, lawmakers in both parties called it a cynical political attack on a nonpartisan examination of the governor's environmental record. Allen's aides and Department of Environmental Quality officials, meanwhile, tried to distance themselves from McKenna's paper, with one environmental official calling it a "rogue memo" that was never implemented or taken seriously.

Some critics said the memo was an indication that Allen's administration is more interested in discrediting the report than in addressing the concerns it raised.

Sen. Joseph V. Gartlan Jr., a Fairfax Democrat who is on the bipartisan legislative panel that issued the report, called McKenna's memo "dreadful." He said it "reflects that these people recognize they were seriously wounded by the report, and they are now going to mount what is essentially a PR campaign and a scheme of legal threats to cow {the joint commission} out of its independent stature."

Philip A. Leone, who has been with the legislative panel since its inception in 1974 and has been its director for a decade, said the memo is "a rotten way to do business. We try to handle everything in a professional way. That's the first time I've ever encountered an agency trying to devise a strategy like that for countering a report."

McKenna did not return telephone calls today. Allen spokeswoman Julie Overy, one of three people to whom McKenna sent the memo, said the governor had nothing to do with it and did not endorse any strategy it outlined.

"This should not be viewed as anything more than one guy at DEQ who has an idea, puts it in writing, happens to know me personally, {and} sends it to me," Overy said. "There is a rather irreverent tone to his memo, and certainly anything we would do would not reflect that tone. . . . It has not gone beyond the pile on my desk. This does not make it an official view, certainly not the policy position of this office, not the policy of the administration, or even of the agency. This is Mike McKenna's opinion."

She added that the memo is "only damaging {if it were} . . . something we were pursuing. None of those things on there have happened to any degree."

In his memo, McKenna suggested that the Allen administration try to show a political link between the legislative panel and the federal Environmental Protection Agency, which has been highly critical of Virginia's recent enforcement of pollution laws.

In particular, the federal agency has accused Allen of not seeking enough fines against the Smithfield Co., the East Coast's largest pork processor and one of Virginia's biggest polluters. Smithfield, which has been cited repeatedly for dumping hog waste into a Chesapeake Bay tributary, last year was the largest contributor to Allen's effort to elect GOP legislators, giving $125,000.

McKenna's memo suggests filing a Freedom of Information Act request with the EPA to obtain correspondence between it and "all our friends (including JLARC)" to find out whether the legislative panel is "in the loop" with the EPA.

Besides Overy, the memo was addressed to Environmental Quality Director Thomas L. Hopkins and Deputy Director T. March Bell.

"This is not the type of memo that Director Hopkins or I like to receive," Bell said. "We're going to remind {McKenna} and make sure all of our people write professional memos that have realistic responses that we can actually use. We don't use these types of responses at DEQ."

Word of the memo comes as Allen's administration is trying to put a positive spin on its environmental efforts before the November elections for governor, lieutenant governor and all 100 seats in the House of Delegates. In recent weeks, Allen's aides have repeatedly said that the drop in pollution fines is an indication that industries are working with the state to improve air and water quality.

In his State of the Commonwealth address Wednesday night, Allen -- who under state law cannot succeed himself as governor, but who wants to help elect Republican Attorney General James S. Gilmore III to the office -- proudly noted his proposal to spend $11 million to help clean up the Chesapeake.

Del. Vincent F. Callahan Jr. (R-Fairfax) said that while he can understand some of the Allen administration's frustration in defending its environmental record, McKenna's memo was "reprehensible."

Callahan, a member of the joint legislative panel since 1974, said it "has been nonpartisan and above reproach. There is no political motivation there . . . and for bureaucrats to try to undermine this integrity, it's not the Virginia way."