Your Jan. 7 editorial "Stacked for Incumbents" noted that House members raise far more money than they need to win reelection. Based on reports to the Federal Election Commission, the 391 House incumbents who were returned to office in November have $80 million in their collective war chests for the 1992 campaigns.

While this is unfair, I don't share your solution of limiting campaign spending, which you based on the erroneous assumption that all campaign funds are spent for election-related purposes.

In actuality, the FEC allows two distinct uses of contributed campaign funds. First, funds can be used for election-related expenditures. But surplus funds also can go "to defray any ordinary and necessary expenses incurred in connection with {a candidate's} duties as a holder of federal office."

What are these "ordinary and necessary" expenses? Just about anything under a long list of FEC advisory opinions. How much is spent this way? Nobody really knows, but it's generally thought to be a considerable amount.

As an advocate for the widest possible disclosure of political contributions, I believe the FEC fails to provide a meaningful overview of how campaign funds are raised and spent.

For example, Sen. Jesse Helms (R-N.C.) spent $17 million and Sen. John Kerry (D-Mass.) spent more than $6 million on their 1990 reelection campaigns. But a significant amount of this money went for direct-mail solicitations to donors outside their jurisdictions, who obviously could not vote for the senators.

Another example: 63 House incumbents spent $15.8 million (an average of $250,800 apiece), even though they had no general-election opponent. FEC's statistics fail to show who had to spend money to survive a primary election, which in some states is the only election that matters.

Still one more example: Incumbent lawmakers with large cash reserves and prospects for easy reelection are being tapped for contributions by other candidates, who have tough elections. The FEC double-counts this money, in effect, creating a pool of political funds that exists solely for statistical purposes.

To resolve these infirmities, the FEC should reform its financial-disclosure forms and statistical data base to account for: (1) election-related expenses, (2) overhead and fund-raising costs and (3) political expenditures not directly attributable to an election, including official duty expenses.

Separate campaign accounts and statistical record-keeping also should be maintained for primary and general elections -- not a difficult task, because federal law already treats primary and general elections as separate events for the purposes of its individual and PAC contribution limits.

In addition, Congress should enact legislation so that candidates could not establish general-election accounts earlier than 180 days prior to an election. Transfer of funds or assets from a primary-election account into a general-election account would be prohibited -- only money raised for a general election could be used to pay general-election expenses. After an election, general-election accounts would be closed.

These reforms would permit incumbents to carry over funds from one election cycle to another, but for use only in primary elections. In the general elections, these reforms would put challengers and incumbents on a more equal footing. Gone would be the multimillion-dollar head start incumbents now so unfairly enjoy. -- Edward Zuckerman The writer is editor and publisher of the newsletter PACs & Lobbies