NEW LIMITS ON eligibility for guaranteed

loans for college students were published by the Education Department last Friday. Unless Congress objects, they will become effective Oct. 1. By the normal standards of government, the department's proposal is remarkably straightforward --a set of tables laying out what families of different sizes and incomes must spend on their children's education from their own funds before those children become eligible for bargain-rate loans. Hidden in the tables, however, are many judgments about how access to education should be distributed in the society.

Families earning less than $30,000 a year should be pleased--they will continue to be fully eligible for the $2,500 loans. In addition, some will also be eligible for other grants and aid provided to lower income families. A middle-level bureaucrat, however, whose 4.8 percent October pay raise moves him across the magic $30,000 line, won't be so pleased. If his child is attending a middle or lower cost public institution he may suddenly lose all or part of his loan eligibility. On the other hand, a $60,000-a-year family with a comfortable savings cushion and a child at Harvard could be delighted to find that it continues to be eligible precisely because Harvard is so expensive.

The abrupt cut in aid at $30,000 is an obvious unfairness that ought to be fixed. Beyond that the questions get tougher. It is simply not possible to deal evenhandedly on a mass production basis with a range of educational institutions varying enormously in standards, amenities and price, and with a student population ranging from the most gifted and hard-working to feckless avoiders of both classes and loan repayments. No simple formula can do justice to the variety of individual circumstance.

Even some of the broader choices are tricky. In determining need, for example, what weight should be given to a family's available assets? To ignore this factor, as does the department's formula, is to reward people who save. This has merit, but it also means less money is available for people who couldn't save because their past incomes were low or who failed--who didn't?--to foresee the astronomical rise in education costs and interest rates.

In the past, it was possible to slide over many of these difficulties by layering on new programs and living with a certain amount of sloppiness. Now the fat is gone. It will not be easy to filter out the effect of this one change from all the other pressures causing families and educational institutions to tighten their belts. But it will be essential to see if these new rules work out fairly over time.