The Nov. 4 editorial "The Growth Gorilla" was off the mark in its discussion of the Montgomery County Council growth policy and decision to kill the "Pay and Go" program.

The editorial implied that without eased congestion standards buildings cannot be built to accommodate new employment. This is untrue. Plans have been approved for 134,000 additional jobs, enough to accommodate more than a decade of growth without new approvals. Commercial development moratoriums exist in only five of the county's 27 policy areas, leaving almost 80 percent where more development can be approved.

Moreover, even in the 22 policy areas not in moratorium, development that affects congested intersections can be approved, under current policy. Developers can proceed by making improvements to accommodate any traffic that their proposed development would generate.

The Post criticized the council's rejection of the growth package, but the somewhat reasonably balanced approach initially proposed by the county planning board became more unbalanced and political as it went through the approval process. What came before the council for final approval would have degraded congestion standards in exchange for a very limited increase in revenue.

The Post also asserted that the approval process was flawed because it assumed that all projects approved in prior years would be built. But the council addressed this shortcoming in 1989 by placing a 12-year limit on the length of approvals.

The council majority recognized the growth policy package as a bad trade permitting much more additional congestion than could be mitigated with the limited additional funds to be raised from developers.

JOHN G. VINER

Rockville

DANIEL L. WILHELM

Silver Spring

The writers cochair the transportation committee of the Montgomery County Civic Federation.