In 1986, broadcasters provided $115 million worth of free air time for American Red Cross public service announcements, about one-fifth of it during prime time.

There is nothing unusual about this. The Red Cross is one of thousands of national and local service agencies that receive free air time on almost every network and station in the country.

Public service announcements are but one manifestation of broadcasters' operation in the public interest. In the 1986 congressional elections, for example, hundreds of radio and television stations organized and broadcast debates by candidates for public office. And every day their programming presents a wide and balanced variety of viewpoints on vital public issues in news and commentary, in telephone call-in and panel shows and in documentaries.

Broadcast stations are businesses like The Washington Post, but both forms of media are also important vehicles of contemporary journalism, fulfilling responsibilities to the public as well as to their investors. It is as nonsensical for Tom Shales to write {Style, Nov. 17} that "insatiable greed" drives broadcasters as it would be for him to so characterize Post Co. Chairman Katharine Graham. Shales is also dead wrong in his assertion that broadcasters "are drunk on the martini of deregulation and they want more, more." In fact, broadcasters are not pushing for more deregulation.

Along with Shales, Ralph Nader and David Danner {op-ed, Nov. 23} assert that broadcast journalists can't be trusted to serve the public interest without government review of their performance. They want Congress to reinstate the recently voided fairness doctrine so government bureaucrats can second-guess broadcasters' coverage of controversial issues.

The doctrine required broadcasters to do what they do anyway -- to afford reasonable opportunity for the discussion of contrasting viewpoints on controversial public issues. And it provided for review and adjudication of citizen complaints by the Federal Communications Commission.

Nader and Danner assert that the government should police broadcasters' fairness because they use airwaves, which are owned by the public. That view is not relevant to the current debate over codification of the doctrine. It ignores the central point: broadcasters are already required by law to provide programming that responds to community issues, a requirement they accept and fulfill along with the additional journalistic responsibility of fairness. It also ignores the fact that, unlike most other users of the spectrum, broadcasters provide their service free to the public.

The Federal Communications Commission abolished the fairness doctrine after years of study that led it to conclude that the doctrine was both unconstitutional and counterproductive. The commission found that, in fact, the doctrine "chilled" speech by driving some local broadcasters to avoid controversy because they could not afford to defend lengthy administrative reviews of their day-to-day journalistic decisions. Although the doctrine has been repealed, that chilling effect has not yet dissipated because Congress seems determined to reinstate its provisions any day now.

Shales asserts that the doctrine has not had a chilling effect based on his conversations with three network executives. That is about as logical as asking Sears Roebuck about the retailing climate in a town where it doesn't have a store. The operations of networks, which serve a national audience, are as different from those of local broadcasters as night and day.

The Founding Fathers guaranteed free speech despite their distaste for the strident popular press of the time. They saw government oversight of content as inimical to democracy. They decided to rely on diversity, instead of oversight. Their judgment was sound.

Edward O. Fritts

The writer is president and chief executive officer of the National Association of Broadcasters.