Priscilla Labovitz's article "No Green Card, No Green Light for Discrimination" {Close to Home, Oct. 21} was wrong in trying to cast efforts to curb illegal immigration in terms of discrimination.

She asserted, for example, that motor vehicle bureaus have no right to deny licenses to illegal aliens. Such bureaus have neither the obligation nor expertise to question aliens as to their immigration status, she said.

However, who is granted a driver's license is of great interest to the Immigration and Naturalization Service, and we think to the states as well. The INS has seen more that one instance of aliens -- and citizens -- with criminal histories seeking drivers' licenses or other documents with which to build new identities. The easier the requisites to obtain those documents, the easier it is to assume a new identity. Within the last month, for example, a license-issuing unit in a suburb of New Orleans was closed down after an investigation showed just such corruption on the part of issuing officials.

Recent drafts of proposed motor vehicle licensing regulations in Maryland would accept documents as varied and specious as foreign baptismal certificate and affidavits from relatives in other countries as to the applicant's identity. To undertake such a course will make Maryland a magnet for fraud and criminal activity. It will also draw undocumented aliens anxious to procure a license -- and not for the purpose of driving.

When Congress amended the immigration laws in 1986 to provide for sanctions against employers who knowingly hire unauthorized aliens, it also included a provision requiring two documents to prove the right to work: one identity document and one eligibility document.

Typically, the documents used are a driver's license (for identity), and a Social Security card (for eligibility). Liberalizing the licensing process would provide illegal aliens with half that equation. Then they need only buy a counterfeit Social Security card -- available for as little as $50 -- to complete the equation.

Labovitz also discussed the registration policies of certain local universities toward undocumented aliens. She maintained that the INS provides regulatory procedures solely for aliens who enter the United States on foreign student visas and that our regulations are silent about undocumented aliens with no visas. Ergo, she concluded, these institutions of higher learning have no obligation to the government regarding illegal aliens.

To accept that notion is to conclude that INS may regulate a school that accepts legal alien student but not ones who overstay or otherwise violate their visas and thus become illegal. Using that logic, it would be in a school's interest to only accept illegal aliens.

Labovitz also made passing reference to the Supreme Court decision affirming the right to public education for children of illegal aliens. Yes, the court found a substantial societal interest in avoiding an illiterate and uneducated underclass, but it was hardly addressing admissions requirements of institutions of secondary education. To my knowledge, our populace -- citizen or alien -- has no inherent right to a college education.

Further, many public universities rely upon taxpayer subsidies to underwrite the cost of student educations paid for at resident rates. The admission of undocumented aliens, therefore, also becomes a financial issue -- will they be charged the out-of-state tuition rate (in which case they must be regulated under INS rules) or the lower resident fees? Taxpayers might be concerned with that answer.

Finally, Labovitz depicted would-be students and driver's license applicants as "merely waiting for their names to be reached on years-long waiting lists." But while "merely" waiting, these aliens are "merely" here illegally. To be permitted to remain in the United States while awaiting one's visa defeats the concept of an orderly system of lawful immigration. There is nothing shameful about such a system -- it embodies the fundamental notion of "first come, first served."

True, many visa quotas are oversubscribed, and undoubtedly long waits can impose hardships. But short of open borders, no immigration scheme, no matter how generous, will satisfy the number of applicants for admission. Why should those who would cheat the system gain unfair advantage at the expense of others who wait patiently and lawfully in their own countries?

To assert that "the Immigration Service has the franchise" on regulating immigration is the equivalent of asserting that a drug-free America is the responsibility of the Drug Enforcement Administration. Our communities, public institutions and states must share in a commitment to a humane, generous, but legal system of immigration into the United States. -- Walter D. Cadman is a district director of the Immigration and Naturalization Service.