The Post's April 10 editorial, "What Counts With Mrs. Simmons," was totally off the mark. The Post misled its readership, which has a right to know in fact "What Counts With Mrs. Simmons."

With respect to school closings, my consistent position, reduced to its simplest terms, is as follows: I believe we must work vigorously to retain our inventory of school facilities.

My stewardship calls not only for viable, effective and efficient education for our existing school enrollment, but also for planning and providing for the educational facilities of future enrollments. Since major demographic studies are predicting another significant rise in school-age population in the 1980s, it is imperative that we maintain our stock.

Unlike Montgomery County and Northern Virginia, the District has a critical absence of open space. Land is at a premium, and vested interests are vying for a number of our school sites. Readers need only recall how perilously close the school system was to losing historic Sumner School at 17th and M streets NW. Even though Sumner was still within our inventory, a wrecking ball was at the site and the city-ordered demolition was stopped only after the board secured a temporary restraining order. Need I say more?

I think the machanism is already in place for dealing with our underutilized buildings while retaining them in our inventory at little or no cost. The procedures are detailed in our board rules as 'joint occupancy procedures." Here are some examples of shared space in underutilized buildings.

* The Bilingual/Multicultural High School, funded by the Department of Labor, at Reed School in Ward 1.

* A-Salon, Ltd. Art Gallery & Studio, at Jackson School in Ward 3.

* The D.C. Teachers Federal Credit Union and the Associates for Renewal in Education, both at Edmonds School in Ward 6.

It is precisely because of these kinds of uses that these school facilities can be maintained for possible future re-use by the school system without significant economic drain.

Another model of shared facilities is the now 7-year-old Six Small School Complex located in Ward 3. While admittedly this is a more costly approach, economic feasibility is not the overriding issue with the administration. Furthermore, it has been embraced and supported by me and others on the board because of its validated educational soundness. The question is why this model has not been replicated. This was the context of my comment about the right of people "being evaluated based on whether they fill out a long or short form on April 15th"--which was so blatantly distorted in The Post's editorial.

A somewhat similar model was developed even earlier in the '60s. It was the Tri-School Complex involving Amidon, Bowen and Syphax Schools. I find it disappointing that this administration recommended that Syphax be closed and the building removed from the inventory. The decisive factors cited for its closing are the very ones appropriate for reviving an updated Tri-School Complex. These kinds of possible groupings have yet to be addressed by the administration with respect to Syphax or any of the other schools recommended for closing.

I articulated my concern that this kind of exploration had not occurred and that the data supplied in the administration's report was insufficient, inaccurate, inadequate and evidenced even misapplication of the administration's stated criteria. I was not alone in making this observation. When the board met on April 10 (the day of The Post's editorial attack) to deal with the administration's recommendation, we were confronted with the addition of two more schools to the list of recommended closings, bringing the total now to 14.

The action taken by the board that day was a resounding 10-to-1 vote to delay any initial steps in the school-closing process until more accurate data could be secured. The administration also was directed to disseminate information on the availability of space in public school buildings to local businesses, agencies, non-profit associations and community organizations.

The administration complied in the following manner: a general advertisement appeared in the Business/Real Estate section of The Post April 18 and 19--with an April 22 deadline for responses. Even with this exceedingly limited time, 90 individuals and groups responded affirmatively. Who knows what the response would have been if an aggressive, appropriate marketing approach had been initiated in a timely manner by the administration, rather than relying upon a small display ad and an unimaginative, general information bulletin mailed to D.C. government agencies, education associations and other nonprofit groups?

Sufficient interest was shown, however, to confirm my thesis that this is a reasonable and untapped source for sound and appropriate use that can be mutually beneficial. I submit this is a more reasonable, mature and success-oriented approach to school under-utilization than the automatic reliance on school wipeouts. There may well be some schools that are best closed. Nine such instances already have occurred.

Good conscience does not permit action in the absence of such data and creative exploration. This is "what counts with Mrs. Simmons."