The idea of removing counterintelligence and counterterrorism responsibilities from the FBI and placing them with a new domestic intelligence agency is a case of the ill-informed recommending the ill-advised ["Bush Aides Consider Domestic Spy Agency," front page, Nov. 16].

Despite its recent missteps, the FBI historically has been quite effective when it has focused on specific criminal or national security threats -- e.g., the Ku Klux Klan, organized crime and the KGB. It is precisely this capability to gather intelligence that has prompted congressional oversight and review, which frequently has stifled initiative and risk-taking.

As a young FBI agent in New York, I saw John J. Kearney, now a retired FBI supervisor, indicted for directing wiretap and mail-search operations in the hunt for Weather Underground bombing suspects. I concluded that absent specific, written authorization, FBI agents should not conduct any investigation that could be perceived as targeting a group in the United States based on its nationality, religion or ideology. There would be no "gray" areas.

I am especially intrigued that MI5 should be a model for a new domestic intelligence agency. During my 24 years with the FBI, I dealt with MI5 representatives; they always expressed a desire that MI5 have arrest powers similar to those of the FBI. They were frequently frustrated by having to coordinate investigations with the Special Branch of New Scotland Yard. I question whether an agency modeled on MI5 would prove feasible in the United States.

The real issue is what type of FBI is desired: a politically correct, risk-averse organization or an aggressive, proactive agency.

JEREMIAH W. DOYLE JR.

Amherst, N.Y.