Douglass Cater has had a long and varied career, but I had not previously appreciated his gift for fiction. It helps, of course, to create a villain to engage his readers' interest.

Cater's favorite, in one "op-ed" piece after another, is Education Secretary William J. Bennett, whom he characterized {op-ed, Oct. 7} as higher education's "chief scold" and a "spiteful" fellow. But even a villain needs a pet for comic relief, and in his latest piece Cater thoughtfully supplies Bennett with a parrot, namely me, depicted as "sardonic" and sarcastic. It would have been well, however, if Cater had actually addressed the issues that Bennett and I have been raising.

The specific event that touched off Cater's latest salvo was a recent oversight hearing by the House subcommittee on postsecondary education on the important issue of rising college costs. Part of the congressional agenda was to review a research paper ("Estimating the Cost of a Bachelor's Degree: An Institutional Cost Analysis") by Dr. Duc-Le To of my staff.

This pioneering study has clearly stated methodological limitations and data constraints, to be sure, but it isn't on scholarly grounds that Cater and his colleagues in private higher education are so agitated by it. What they cannot abide is the possibility that the true cost of a bachelor's degree in a private college -- and it's the cost to the institution we are referring to, not the price charged the tuition-paying consumer -- may actually exceed that of a similar degree from a public institution.

This tentative finding contradicts a cherished private-sector belief that if you wipe away all the uneven subsidies that so distort the college marketplace, the "true cost" of higher education is approximately the same on private and public campuses. Maybe that is so; maybe it isn't. Dr. To's study suggests that in the average case it isn't. But Cater -- and the National Association of Independent Colleges and Universities before him -- prefers to obscure that possibility by attacking the motives and behavior of those who did the study. In this vein, he states that Dr. To's study was a sort of decoy, constructed by the big bad Education Department to divert attention from evil Bill Bennett's true agenda.

What that agenda is Cater never actually says, though he murmurs darkly of a "national curriculum." Mainly he seems to resent Bennett's having the nerve to suggest that American higher education is "underaccountable and underproductive."

By and large, of course, it is. It's also the envy of the world, a swell source of upward mobility and a source of many good things. No one I know denies that American higher education has a lot going for it. But underaccountable and underproductive -- darned right. I didn't have to come to the Education Department to find that out. It was perfectly clear to me from a decade of work in the field. Apparently, however, one isn't supposed to suggest that this particular emperor's haberdashery leaves anything to be desired.

Two exchanges at the oversight hearing especially galled Cater. In the first of these I suggested -- only as a hypothesis, mind you -- that one reason for the staggeringly high (and costly) default rate on federally guaranteed student loans may be that some students arrive on campus and find that they aren't getting value for money; and accordingly they may feel less obliged to repay those who advanced them tuition money.

An "awesome indictment," Cater terms this, with "no research data to sustain it." Well, as it happens there is some pertinent research, a new study by UCLA professor Wellford Wilms. He found -- this should not come as a surprise -- that college dropouts have a far higher loan default rate than those who complete their studies. And there are many such dropouts. Why? Wilms speculates that they "either didn't have what it took or the program was not what they had hoped for. They became discouraged and don't pay back what they owe." If this is so, one may fairly ask whether our universities don't bear some of the onus for having admitted (and in many cases recruited) them.

The second observation that griped Cater was more personal: when my 12th-grade daughter and I toured colleges this past summer, attempting to see which ones she might want to apply to, I found virtually all the campuses deserted; those costly physical plants unused; those well-stocked libraries without anyone reading; and most of the faculty nowhere to be seen. Might not the nation's higher education industry, I asked the subcommittee, consider seeking productivity gains by making fuller use of existing resources. Is the 32- (or sometimes 28-) week academic year so sacred?

Cater retorts that college presidents of his acquaintance work "eight-day weeks" to "schedule summer programs as well as to lease campus facilities to others." Perhaps they do. My daughter and I encountered the odd tennis workshop, even a pantomime course. But renting out the place is scarcely the point: converting the core higher education enterprise to a more productive and efficient operation is what I had in mind.

Can greater yield be eked out of the available resources? Is there no smidgen of waste anywhere on campus? Cater has generously offered to throw open the books of Washington College for an informal inspection by the Education Department. My colleague Bruce Carnes has already written to take him up on this offer.

The writer is assistant secretary of education for research and improvement.