Our sometimes distinguished colleague, Andrew Beyer, who writes of racing in this newspaper, is moaning again.

He has departed from his annual gripe about the bleakness at poor Bowie, and also from his other rite of spring--his loud grumbling at tax time against the IRS, which wants a Draconian share of hard-earned, blood-soaked winnings of lucky bettors at the track.

In his latest lament, put in writing the other day, Beyer took a swipe at all of the 3-year-olds in America. Not a steed among them is of great account, he growled, and the Kentucky Derby only three weeks away.

No exceptional talent in the crop, said Beyer, yearning for the good old days of Secretariat and Forego, Affirmed, Seattle Slew and Spectacular Bid. Andy, with glee, quotes one racing personality--in evident agreement with him, of course--saying that a certain English trainer could take the fifth-best horse in his stable and win the Derby.

The trouble with racing in America right now, Beyer wrote, is that the dratted furriners, mostly Arabs, have been buying up prime American bloodstock and campaigning and breeding it in Europe.

The Arabs and Robert Sangster, a very rich Briton, have been bidding up prices to levels Americans can't afford, Beyer says. For example, in the 1981 sales, a total of 13 yearlings were bid up to more than $1 million each and only two of them stayed in this country. How's that for proof of something?

Of course, it isn't proof of anything. What should be noted is that a slew of the finest American thoroughbreds never got to the auction ring. Important American breeders kept their horses in the barn in 1981, and have been doing so since.

To drop a few proud American names who wouldn't expose their stock to Arab bidders, there are Paul Mellon, John Galbreath, Louis Wolfson, the Whitney Greentree Stable, Fred Hooper, the Elmendorf and Tartan Farms and T.M. Evans. The Arabs never had a shot at their prize yearlings. So, it is not to worry so much. The nation is safe.

And as for all those million-dollar buys by the Arabs, and how grievous it is for the American racing picture, there is a strong suspicion that Beyer may be confusing price with value.

John Finney, president of the Fasig-Tipton Sales, an eminent authority on the yearling auctions, recalls that his firm sold four recent Kentucky Derby winners, Genuine Risk, Seattle Slew, Bold Forbes and Foolish Pleasure, to different buyers.

His records show that Genuine Risk went for $32,000, Seattle Slew for $17,500, Bold Forbes for $16,500, and Foolish Pleasure for under $20,000. "You could have bought all four of those Derby winners for less than $85,000," Finney said. The race has not always gone to the rich.

The incursion of the Arabs at the yearling sales began in 1973, Finney says, so it seems that the sheiks have been spending all that big money for the wrong horses. Britain's latest pride and favorite for the Epsom Derby, the American-bred Dunbeath, was no million-dollar baby. Fasig-Tipton knocked him down for $100,000.

It is true that the Derby field at this time is tentatively undistinguished, with Roving Boy and Hostage eliminated by injuries, and the speedball Copelan denigrated as a mere sprinter. Pax in Bello, another that has promise, the other day foundered into a fourth-place finish in a mere Florida allowance race for state-breds.

But Current Hope, the Flamingo winner, is showing distance qualities and has important Little Current breeding, and the Santa Anita Derby winner, Marfa, appears far better than an empty barn.

April is no time to judge the caliber of the 3-year-old crop, and Beyer should know that. At this point last year, you couldn't locate the horse of the year with a search warrant. He wasn't even a Derby contender, had finished fourth in an allowance race at Hialeah, and had won only one of his two starts. But Conquistador Cielo ran away with the Belmont, and commanded a record price of $36.4 million when syndicated.

It is only the middle of April, Andy. Hold your fire.