Linda Stuntz, coordinator of the Bush administration's long-running attempt to develop a comprehensive national energy policy, was joking when she said the other day that "the best we can hope to do is make everyone equally unhappy."

But if that were the goal, the administration would appear to be on the verge of success. The package of energy policy elements that will be submitted to President Bush this month has distressed members of Congress, conservation and enviromental groups and large segments of the energy industry.

Some of the critics are unhappy about one or more of the 59 "options" that Stuntz and White House policy aide Olin Webington are shepherding through Cabinet review before sending them to Bush. Others are unhappy about the process by which the National Energy Strategy is being developed. Some are distressed by both the process and the specifics.

It also touched off a fight between the Energy Department and the Office of Management and Budget over an attempt by OMB to put fiscal policy ahead of energy policy by forcing federal power agencies to raise electricity rates and ending subsidies for rural electrification.

The nuclear power industry, the trade association that represents investor-owned utilities, the American Public Power Association, Greenpeace, the National Rural Electric Cooperative Association, the American Automobile Association and several members of Congress all have expressed unhappiness over some aspect of the energy plan.

In separate news conferences scheduled today, for example, environmental groups, state officials, Ralph Nader's Public Citizen organization and consumer groups plan to object to what they believe to be the overall thrust of the policy: favoring the development of energy-producing facilities such as oil wells and nuclear power plants while doing too little to promote conservation and the use of renewable fuels.

But none of these groups has actually seen the administration's National Energy Strategy, because no such document exists. Deputy Undersecretary of Energy Stuntz and Energy Secretary James D. Watkins are scheduled to meet with Bush Dec. 18 to present to him the options that survive Cabinet scrutiny.

The options -- Energy Department officials don't call them proposals -- include some that are certain to be controversial if endorsed by the president: revision of the Public Utility Holding Company Act to promote competition in the electric utility industry; increased use of nuclear power; imposition of some new energy taxes; creation of a private corporation to assume responsibility for the nation's mountains of nuclear waste; deregulation of interstate natural gas pipeline rates; and oil drilling in the Arctic National Wildlife Refuge.

Critics have complained that the options range from rewriting fundamental federal energy laws to vague statements about environmental policy, and from large-scale comprehensive proposals to micro-management changes in regulations, without any overall statement of philosophy or objectives. In effect, the "options" are a list of solutions without a statement of the problem or the objective. The background analysis papers supporting each of the options have not been made public.

An analysis distributed by the nuclear power industry labeled the options "wishful thinking, theoretical scenarios based on unproven and untested concepts and hypothetical contributions." The utility trade group Edison Electric Institute, noting that the options include "fundamental changes to the structure and operation of the electric utility industry," said it is "not prudent for DOE to proceed . . . without allowing for a thorough public review of the background studies."

"On a lot of these things, they haven't laid out what they would accomplish," said Christopher Flavin, energy analyst at the Worldwatch Institute, who will preside at one of today's news conferences. "A lot of the options are extremely broad; others very specific. There's no overriding statement of philosophy or purpose."

"I can understand some of the frustration," Stuntz said. "People keep expecting to see a draft National Energy Strategy to comment on. That's not what we have been doing."

Watkins said in July 1989 that he would develop an "action plan" for meeting the nation's projected energy needs. But Stuntz said that "if we did this as just a DOE policy, we don't have all the policy levers" to implement it.

It is up to the president, she said, to decide his policy on energy security, the environment and economic competitiveness. Once he does that, the energy policy options -- some of which will be listed as "consensus items" approved by the Cabinet -- will be the "building blocks" for implementing the policy.

"Then you'll be able to say, okay, this set of options will increase our dependence on imported oil by X percent, or cut greenhouse gases by Y percent," she said. In theory, the background papers will explain the political, environmental and economic impact of each policy choice.

The biggest political uproar has centered on OMB's proposal to require public power agencies such as the Tennessee Valley Authority to raise their hydroelectric rates to market levels and accelerate repayment of their federal loans.

Legislators from the Tennessee Valley and the Pacific Northwest reacted with fury. The entire Tennessee congressional delegation, joined by legislators from Alabama and Mississippi, said the proposal was inflationary and probably illegal.

Sen. Mark O. Hatfield (R-Ore.) called it "a proposal for social and economic disaster in the Pacific Northwest." Rep. Al Swift (D-Wash.) told the newsletter Public Power Weekly that "it is a shortsighted, stupid, monomania idea in the mind of some troll at OMB who once a year wanders out from under the bridge and tries to chew on Senator Hatfield's leg."

"The public power stuff isn't ours," Stuntz said. "That's OMB's baby."