In his Dec. 5 letter, Douglas Johnson of the National Right to Life Committee seriously misrepresented the acceptance and incidence of abortion in less developed countries. Because family planning services are inadequate and contraceptives sometimes fail, there are an estimated 28 million abortions annually in less developed countries. In Brazil alone, an estimated 3 million abortions occur every year. Doctors at maternity hospitals in some poor countries report that more than 1,000 cases of abortion require medical treatment every month.

These numbers refute Mr. Johnson's claim that people of poor countries reject abortion. In fact, the administration's "Mexico City" population policy, created partly under pressure from Mr. Johnson's organization, is more restrictive than abortion laws governing 1.6 billion people in 65 countries eligible for U.S. population assistance.

Mr. Johnson is also wrong when he states that all family planning agencies have accepted the administration policy barring support of overseas organizations involved in abortion that use their own funds for this service. About 16 out of 37 U.S.-based organizations have signed the policy. Almost all of them did so with great reluctance and misgivings about their ability to comply. The International Planned Parenthood Federation no longer receives U.S. funds because it would not agree to the Mexico City policy.

If he were genuinely seeking to reduce the incidence of abortion, Mr. Johnson would be supporting the Planned Parenthood Federation of America's family planning work overseas and not urging its loss of funding.

J. JOSEPH SPEIDEL President, Population Crisis Committee Washington