THE PRESIDENT'S proposal for dismantling the Department of Energy is a textbook illustration of why government reorganizations are so often a waste of time: its political prospects are dim, it creates a bureaucratic nightmare out of a mere tangle, the tangible and intangible costs of the transition are likely to exceed what the reorganization would save and it will not improve policy-making by a hair.

The administration gives two principal reasons for its proposal. It redeems one of Mr. Reagan's most explicit campaign pledges, which capitalized on the widely held, erroneous belief that eliminating government agencies (without eliminating their functions) saves money. There is also the administration's conviction that a separate Department of Energy, simply by existing, creates an energy policy. In its words, DOE "symbolizes and probably encourages extensive government intervention in the energy sector." This is a confusion of form with function. DOE's counterproductive interventions were and are the result of policies--notably oil and gas price controls--that bear no relation to whether one, two or 10 agencies are devoted to energy.

Bureaucratically, the proposal is almost funny. It would transfer nearly all of DOE intact to the Commerce Department. A few duties would be parceled out to other agencies, many to the agencies from which they were collected when DOE was created just five years ago. The Federal Energy Regulatory Commission, which was once the independent Federal Power Commission, would again become independent, the only difference being that it would keep its new name. The new Department of Commerce would have three deputy secretaries, two associate deputy secretaries and three undersecretaries: more very high-level positions than exist in any other Cabinet agency, or for that matter, in the present departments of Energy and Commerce combined.

The final irony is that while additional high-level positions are created, nothing is abolished. A great many energy programs are being eliminated, and others--including those involving foreign commitments and statutory requirements--ignored, but this is the result of policy decisions and budget cuts. The administration's projected savings of $1 billion depends largely on personnel cuts that are independent of a reorganization. In fact, the Congressional Budget Office and battle-scarred reorganizers of the Kennedy, Johnson and Nixon administrations have all testified that the costs--confusion, delay, declining morale--will probably exceed whatever real savings might be achieved.

The point the administration is really trying to make with its plan is that the country doesn't need an energy policy because energy is but one component of the general economy, like any other. Just what the nation's energy policy should be is a subject overlooked in all this. There are better ways to approach it than through a reorganization whose only concrete result will be to provide raw material for the next president's reorganizers.