FILM RATING--FROM <i> A</i> TO <i> X</i>

In an open letter to Jack Valenti, president of the Motion Picture Assn. of America, film columnist Jack Mathews complained that the X rating, which had just been given to Alan Parker’s “Angel Heart,� was tantamount to censorship and suggested that the X be changed to A (adults only) to remove the stigma from non-pornographic movies (“Movie Rating System Needs to Clean Up Its Act,� Feb. 18). Following is Valenti’s response, addressed to Mathews.

I don’t find that (changing X to A ) is an unattractive suggestion. Indeed, in the almost 19 years of the MPAA ratings’ life, that counsel has been offered many times. In order for me to tell why that seemingly simple revision will not achieve your goal, would you be forgiving of a very brief recall of history?

The ratings system was born not in response to my or any other’s zeal to put a boundary on the film maker’s reach. Ratings were invented because the Supreme Court (in 1968) judged it to be legitimate and legal for communities and states to construct their own film classification systems. I counted it wiser for the film industry to preempt the field by putting in place its own design than to have it imposed by a thousand localities, with boards populated by folks whose yeast rose too easily. . . .

Ah, but the enigma was how to fashion a system that would (1) keep the screen free so that a film’s creator could tell his or her story without intrusions, (2) serve parents’ needs in a workable and uncomplicated way, and (3) meet court challenges and survive.

The answer that we designed achieved all those objectives. The sticky one was the court. The ratings system has been challenged, and in each case the court has supported our design. Why? Because what the rating program adduced persuaded judges that (1) it was non-discriminatory, (2) it was voluntary; that is, no one would be forced to submit a film for ratings if they chose not to.

The sensitive nerve edge of an unforced system is the ability of any producer to resist submission of his film for rating, and the right to self-apply the most severe rating.

For example, a film maker says, “I will self-apply the rating.� Whatever he self-applies has to be the same “most severe� rating that the rating board can apply, even though the rating board never sees the non-complying producer’s film.

If we chose to “separate� so-called “critically acclaimed� films from those we find coarse and meretricious . . . we would be denying those who didn’t submit their films the right of “due process� by branding their films as “pornographic� or “obscene.� These are legal words and have no residence in a rating-board judgment.

Why, then, you have asked, would you not put a different label on the most severe rating category, say, A or AO (adults only) or NFC (not for children) or whatever? The X , you point out, has been so despoiled it has become a pariah.

Answer: Because a rating takes on the patina of the films that inhabit the category. In a New York minute, newspapers, exhibitors, parents, just plain moviegoers would know what the new label meant to them. . . .

No matter what name or initial or description you give the most severe rating, it is still going to be populated by “Debbie Does Denver� and “The Iowa Buzzsaw and Wheat Combine Murders,� and other gems. That may be unsuitable to reasonable people, but it is real.

What you might have dwelt on a little more is the simple fact that producers don’t have to cut one millimeter of their films. If they do, it is because they believe it is in their economic interests to do so. . . . Finally, the X means, simply, a film that in the ratings board’s judgment parents will not want children to see. Why should a director object to having his “adult� film seen only by adults?

The Supreme Court has ruled that there is a difference between restrictions on children and those on adults. The ratings board doesn’t make the laws. It most strenuously tries to live within them.

Ah, Mr. Mathews, too often in this unruly world the choice is between the undesirable and the intolerable. If not this, what? I do not believe the rating system would have survived for almost 19 years unless it was providing the public with some kind of visible benefit.

The endurance of the rating system has a nice shine to it. It has kept intruders, in the government and without, from soiling the freedom that every film maker in this land possesses. That is not an ignoble laurel.

JACK VALENTI

Washington