Alan S. Blinder {op-ed, Aug. 18} expresses the frustration so many people feel about the increasingly high costs of environmental protection. But his solution of selling the right to pollute as if it were a commodity suffers from the same basic problems as our current regulatory system.

It is not society that glibly decides (to use Blinder's hypothetical example) "that only 10 million tons of the unsightly pollutant 'glop' would be emitted into the atmosphere each year." Deciding on an acceptable amount of pollution is what the Environmental Protection Agency now does. History shows conclusively how technically difficult and contentious standard-setting is.

Moreover, marketable emissions permits of the sort Blinder proposes would, like current regulations, have to be established for many hundreds of pollutants. These increasingly are not merely "unsightly" but are invisible toxic chemicals released into our air, water and land. They pose diverse, uncertain, often delayed, and possibly negative health effects. It would be no easier to set acceptable amounts of pollution to be marketed than it is to satisfy all the conflicting interests slugging it out in today's regulatory arena.

The number of pages of federal environmental regulations jumped 20 percent last year, and national environmental spending increased 10 percent. The total is nearly 2 percent of our GNP. This argues for using a far more practical, cost-effective, proven and environmentally sound approach to cutting pollution costs than what Blinder proposes: pollution prevention. Pollution prevention cuts pollution and improves environmental protection instead of merely redistributing pollution through the selling of permits.

The most substantial reductions in pollution have resulted from occasional preventive measures, not typical control regulations. Examples: switching to lead-free gasoline cut atmospheric lead levels, and banning DDT and PCBs cut the blood levels of those substances in Americans.

Numerous analyses from the National Academy of Sciences, the Office of Technology Assessment, EPA and the public-interest group INFORM support the case for pollution prevention. These studies are reinforced by hundreds of concrete industrial examples of economic savings and technical feasibility.

Large amounts of pollutants can be prevented at their source of generation by safely changing industrial processes, materials, operations and products. OTA recently estimated that up to 50 percent of all environmental pollutants and hazardous wastes could be cut within the next few years through waste reduction. Industry would increase its profits and competitiveness this way. Example: 3M has cut its generation of hazardous waste by 50 percent in the past 10 years and saved over $300 million. Dow Chemical has a "Waste Reduction Always Pays" program that is generating substantial profit for the company.

Nearly everyone seems to believe that creating pollution is technologically inevitable. That simply is not the case. Generating environmental wastes has its historical roots in the low cost of discharging them into the environment. Even now much of the full, long-term costs to society of generating pollutants are not paid by the polluter. Society picks up the bill eventually, although Superfund cleanup liabilities and increasingly high costs from court settlements are changing this situation. But a bigger problem is the reluctance of production people to take a new look at why they generate so much environmental waste and an absence of technical information and support organizations to help them pursue alternatives.

Many European countries are far ahead of the United States when it comes to pollution prevention or clean technologies. Tiny nations such as Denmark and Austria spend more money to help industry reduce waste generation than does the United States. Out of a budget of several billion dollars, EPA asked for $400,000 for its waste reduction efforts. A few states have successful waste reduction programs. A Ventura County, Calif., program cut the off-site shipment of hazardous waste by 70 percent after two years by providing in-plant technical assistance and information.

A number of bills have recently been introduced in the Senate and House to establish a major federal waste reduction program based on the premise that pollution prevention is technologically feasible but requires stimulation through a national information base, in-plant technical assistance by state programs and creation of a federal Office of Waste Reduction.

A 10-year-old federal energy conservation program based on providing in-plant technical assistance has been enormously successful; industry has saved about $5 for every dollar the government spent. All indications are that pollution prevention might return $50 to industry for every dollar the government spent, meaning that through increased corporate profits and taxes the federal program might pay for itself in as little as one year.

The writers have worked on several studies of pollution prevention and hazardous waste at the Congressional Office of Technology Assessment.