Although it is an annual ritual for visitors here to complain about the high cost of going to the Kentucky Derby, most people don't really mind it. Journalists who write impassioned essays on the subject aren't paying their own way, and are preparing their bosses for the expense accounts they are about to submit. Many of the other people who pay the sky-high prices are here for corporate entertaining, which is all a big write-off anyway.

But over the past year, complaints about Churchill Downs' greed have arisen from a different and surprising source: from the local folks who are the Derby's biggest boosters.

In the Louisville Courier-Journal's page-one coverage of the 1985 Derby, columnist Billy Reed cited the low attendance and said, "There already were indications that the public thinks Churchill Downs and new president Thomas Meeker are guilty of price-gouging . . . If Meeker is smart, he may want to consider dropping prices next year. Or perhaps going back into the practice of law. In five years, at this pace, the Derby will be just another horse race in early May."

An editorial in the Lexington Herald echoed this sentiment: "No one should begrudge Churchill's right to make a buck . . . But you don't make that buck by stepping all over the little people who have kept you in business through good times and bad."

Two years ago, Churchill Downs' board of directors tabbed Meeker, then the track's general counsel, to be its new president. The ex-Marine knew that his mission was to increase profits, and he didn't pussyfoot. He promptly doubled prices across the board.

Infield admission was raised to $20, clubhouse admission to $30 -- and that outlay entitled a patron only to be part of a great crush of humanity, not to have a spot where he could see a race. Actually, those prices could be considered a bargain, compared to the $50,000 some corporations paid for tents (accommodating up to 150 people) where nobody could see the race track. For traditionalists who would like to see the race, a 16-seat table in the clubhouse dining room costs $5,000 for two days. A good six-seat box in the mezzanine goes for $1,020.

To the critics who call this price-gouging, Meeker answers that Churchill Downs had a desperate need for capital improvements when he took over the presidency. He embarked on a five-year, $25 million master plan to make the necessary changes, and the only place to get the money was the Derby.

"We hadn't raised prices for 10 years," Meeker said, "and there was plenty of elasticity. There was no drop in demand for fixed seating. I have no misgivings whatsover."

It's nice that the tobacco, oil and liquor company executives who populate the Downs on Derby Day haven't felt a pinch from the higher prices, but other people clearly did last year.

Even though Meeker argued that the $20 infield admission was reasonable and comparable to what kids would pay at a rock concert, attendance last year plunged to 108,573 -- the lowest figure since 1970. Saturday's crowd could be less than 100,000.

Churchill Downs officials may not be terribly concerned about the lower attendance, because the higher prices more than offset the lost admissions, and because people who can't afford a $20 ticket aren't going to be betting much anyway. But even if the high prices make economic sense, they have subtly altered the atmosphere that surrounds America's most famous horse race.

The Derby has become an American institution not because it is so much more important than any other race, but because it is an experience, a spectacle that has broad popular appeal -- to children who try to see the race while perched on daddy's shoulders; to college students who make the infield the site of the world's largest beer blast; to the celebrities in "millionaires' row." It is as an appropriate a symbol of American democracy as Royal Ascot is of British elitism.

But after fostering the Derby's growth as a popular spectacle, Churchill Downs now has little desire to cater to the riffraff -- unless they can spend enough to justify their presence.

Money appears to be the management's total preoccupation, whether it takes the form of big-time commercialism or small-time ripoffs. The track program advises patrons that Buick is the "Official Car" of the Kentucky Derby and Old Kentucky Tavern the bourbon of the "Official Mint Julep."

In addition to these distinctions, Churchill Downs may be the only track in America where fans must pay more than the cover price for the Daily Racing Form. The $2 newspaper here costs $2.25, "tax included."

The spirit of unfettered greed at Churchill is so pervasive that officials of the Breeders' Cup were worried about it when they were considering holding their event here in 1987.

"We don't want a November rip-off like the May rip-off," one official said. For other reasons the Breeders' Cup will be held elsewhere, but the track is doing nicely with only one bonanza a year. Churchill Downs Inc. this week announced sharply higher earnings for its last fiscal year. In the view of management, nothing else counts.