The Rivlin Commission's recommendations on police staffing and operations in the District have stirred city-wide controversy. Two members of the commission, James J. Fyfe and Patrick V. Murphy, have addressed the subject on this page -- on Nov. 27 and Dec. 24. Retired police officer Richard L. Vavrick replied on Dec. 10, and Chief of Police Isaac Fulwood Jr. replies today.

Theop-ed article of Nov. 27 by Rivlin Commission members James J. Fyfe and Patrick V. Murphy, "D.C. Police: Trim the Fat," set off a city-wide debate on the size and operation of the Metropolitan Police Department.

My initial reaction was that the article was so full of misinformation, discrepancies and conjecture that it did not deserve a reply. However, I have now decided to issue a formal response.

As the chief of police, I have always appreciated constructive critiques and substantive suggestions. But this article exceeded all bounds of constructive comment. Also, I was appalled that neither I nor my executive-management staff was afforded an opportunity at the conclusion of the Rivlin Commission study to clarify many of the writers' suppositions, though we had been assured that the department would be given this opportunity.

I cannot comprehend the need to distort fact on such a volatile and emotionally charged issue as proposing a reduction in public safety. Saying that "the D.C. police department is the most bloated and inefficient big-city police department in the United States'' without introducing any operational performance standards or criteria on efficiency and effectiveness, (for instance, arrest rates, case closure rates or crime-index levels) is a serious aberration.

In reviewing our performance against other police departments, the MPD has consistently stayed 2 to 3 percentage points above or below the national average in maintaining a respectable case-closure rate for all Part I offenses: homicide, aggravated assault, rape, larceny, robbery, auto theft, burglary and arson. Additionally, among the FBI's list of 27 major cities across the country, the District ranks 11th; this ranking includes homicides.

To hypothesize that the department is grossly overstaffed with eight officers per 1,000 citizens and to say "that about 800 officers have been quietly hired since last spring,'' is to invite the question: Where have these gentlemen been? They imply we were surreptitiously hiring new police officers. But everyone in this city heard the department's recruitment call for more police. To suggest this was done ''quietly'' is pure fiction. Further, the number of officers we hired since last spring is 1,046, not 800. I would hope that this error was attributed to sloppy research rather than to a feeble attempt to sensationalize.

Any adroit researcher knows that the natural demographic variations (differences in geography, topography and other socioeconomic factors) between cities make it virtually impossible to make valid comparisons on police levels city to city. The article suggests that other cities, with lower police-to-population ratios, were completely satisfied with their police staffing levels and doing just fine in managing incidences of crime, drugs and violence.

The fact is, every city mentioned has been clamoring for more police and in most instances is now hiring more officers. Practically every major urban city is suffering record levels of homicides: New York, Los Angeles, Detroit, Atlanta. Although the comparison is unscientific, past trends have shown that when crime increases, so do police staffing levels; as crime decreases, the level of police diminishes. This correlation has been known and used for some time.

Further, to set forth the idea that D.C. police get more help from other agencies than any other American police department is totally misleading. Capitol Police, Executive Protective Service, National Zoological Park Police etc. have specific jurisdictions that they patrol. The article would have the reader believe that if police assistance was needed at American University, students or faculty might have the option of dialing 911 and receiving an answer from the National Zoological police. No such chance. The MPD is the only law enforcement agency in the District answering citizens' 911 calls.

On the matter of police overtime expenses, Mr. Fyfe and Mr. Murphy wrote that this city, unlike any other major city, has no night court system. I am perplexed that they criticized this department as though we have authority over the court system and are responsible for this inefficient policy.

The U.S. Justice Department, more specifically the U.S. Attorney's Office, has direct control over this prosecutorial arm of the District's criminal justice system and unilaterally made the decision to stop night papering. Countless times I have publicly stated: All segments of the local and federal government must work cooperatively to attack the local crime problem. In the article, negative references were made to the fact that a detective earned in excess of $100,000. This is true. But persons earning a salary of this level represent less than 1/2 of 1 percent of police personnel. Many of the cases investigated were of the most difficult and complex types to close. A substantial number were for drug-related murder. It should be noted that this occurred during a period of reduced resources. I am very proud to serve with this group of men and women, who are willing to make the necessary sacrifices and willing to commit themselves to the high level of dedication required to bring these cases to a conclusion through arrest.

I felt the overall overtime analysis was completely unfair. Clearly, there were three factors that drove the Metropolitan Police Department's use of programmatic overtime during the last several years: an inadequate level of personnel resources trying to meet an increasing demand for police service, unscheduled special events and court decisions related to the Fair Labor Standards Act.

BothFyfe and Murphy were aware that I had already taken steps to reduce the use of overtime prior to initiation of the Rivlin Commission and had discontinued the use of programmatic overtime last Oct. 1. Yet, this was never directly mentioned or even alluded to in the article. It was very confusing to see the flawed logic used to arrive at the workload and staffing levels conclusions. The numbers the writers used (appropriate staffing formulas, calls for service, response time etc.) are frequently debated within the law enforcement community as to whether they are appropriate and effective measures for judging a police department's service delivery quality. The wide variances in the way those terms are defined from agency to agency make direct comparisons very unscientific. For example, often a low level of calls for service can mean that police are responsive and effective in reducing repeat calls for service to the same location.

Undoubtedly, the overall Rivlin Commission report has some merit. However, Fyfe and Murphy wrote an article that purports to summarize thorough research when it is, in fact, a cursory review of MPD operations that does not identify any areas of deficiency that we haven't previously recognized or taken action to correct.

From the acquisition of state-of-the-art computers in scout cars and information processing systems to increased civilianization, we are attempting to make broad strides as part of our blueprint for the 1990s. But fiscal austerity, brought on by a declining economy and city-imposed hiring freezes, has not allowed us to put into effect every element of this plan. Community Empowerment Policing (CEP) is the department's new philosophy and style of policing. It is evidence of my firm commitment to achieving better information exchange between the officers on the street and the citizens of this city. CEP is designed to bring improved organizational performance and greater accountability. Fundamentally, it will put more officers on foot beats to become an integral part of the community.

All officials and officers of the First and Seventh Police Districts have been trained as part of our pilot project. CEP has also been integrated into our recruit-training curriculum. CEP's other features include identifying and facilitating neighborhood problem-solving, comprehensive crime analysis, developing prevention programs for delinquents and at-risk youth and directing public and private resources at the causes of crime to ameliorate the egregious human conditions that pervade many District neighborhoods.

I traverse this city daily, frequently talking to residents of those neighborhoods most afflicted by crime and violence. Most residents simply feel safer with a police officer walking a beat. Since becoming chief in 1989, I have assigned 74 percent of the total force to the Patrol Operations Bureau, which makes assignments in the seven police districts. The majority of citizens in this city understand this fact.

Recent department realignments have placed all investigative functions (Narcotics, Intelligence, Criminal Investigation and Morals Division) into one bureau: Investigative Services. In supporting the Patrol Operations Bureau, it provides a direct-line function that now involves 85 percent of the force. Incidentally, the Rivlin Commission applauded this organizational adjustment.

Itotally agree with those scholars who firmly believe that cities should not have to expend scarce fiscal resources to maintain large numbers of police to arrest and incarcerate. More of this funding should go to eliminating the human blight and alienation that exists in inner-city neighborhoods in every urban center in America. But Fyfe and Murphy present a contrary thesis that is immersed in law enforcement hyperbole.

I believe that this problem of violence and crime is a crisis of values and conscience in our community. The best long-term approach is a comprehensive well-structured offensive that focuses on young people and includes measurable quality programming in education, prevention, drug treatment on demand, economic empowerment and law enforcement. This human agenda must be supported with activities to strengthen families, more caring teachers, committed clergy and a contributing business and academic community.

My 26 years experience as a police officer and official, including command of two police districts, tells me that unfortunately the only short-term response that can counter the on-street violence and offer neighborhoods relief from crime and drugs is aggressive law enforcement. Perhaps Fyfe and Murphy do not realize what is happening in inner-city America. Cities and states have indeed made police the institution of first response rather than of last resort in addressing this crisis.

It is an unfortunate manifestation, and I hope it is one that will somehow change in the distant future. But to advocate scaling back police personnel as the answer to this city's crime situation demonstrates a detachment from reality and a lack of perspicacity for the human dynamics of the problem.

Some time ago, I remember reading some of the work of Danish philosopher Soren Kierkegaard, where he noted that life is lived forward but only understood backward. I say to Jim Fyfe and Pat Murphy: This city over the past several years has found far too many ways to go backward. We've had to endure a high dropout rate, a high infant mortality rate, exorbitant levels of homelessness, the highest arrest and incarceration rate in the world except South Africa and the nation's highest homicide rates.

Today, we are on the brink of entering a new era of stability with immense optimism. To consider this out-of-step notion to cut police personnel would only point us in the direction that the District of Columbia, at this point in history, does not want to go.