The Organizational Sentencing Guidelines announced by the Justice Department appear to be an important improvement over the version of the guidelines endorsed by the department earlier this year {news story, Oct. 16}. While there are few significant changes from the earlier DOJ recommendation, the elimination of the provision for fines equal to twice the gain or loss resulting from the crime removes a feature of the prior proposal that could sometimes lead to arbitrary results.

It therefore appears that the intercession by the White House on March 16, requesting additional time in which to evaluate the corporate sentencing issue and consider divergent views, has resulted in a useful change while maintaining an appropriately tough sentencing posture. The department's previous position had been formulated and publicly announced by the department's Criminal Division. Acting upon the attorney general's personal authorization to speak for the department, the Criminal Division submitted a detailed statement of position to the Sentencing Commission on Feb. 12, arguing for the adoption of particular sentencing guidelines. Upon request of the Criminal Division, spurred by its concern that the commission might issue only recommendations rather than binding guidelines, I reaffirmed the department's announced position in a letter of Feb. 26.

Contrary to the suggestion of some misguided critics, it is no cause for embarrassment that the White House intervention led the department to reconsider its position. The further deliberation that resulted has improved the recommended guidelines in a manner fully consistent with effective law enforcement. DONALD B. AYER Washington The writer is a former deputy attorney general.