THE TITLE REFERS TO THE FEDERAL BUREAU OF PRISONS DIRECTOR'S COMPLAINT THAT HIS EFFORTS TO BUILD BETTER PRISONS ARE COMING UNDER ATTACK FROM THOSE WHOSE DEMANDS FOR CORRECTIONAL REFORM HAVE BEEN LOUDEST. THE DIRECTOR NOTES THAT HIS CRITICS BASE THEIR CLAIM THAT CORRECTIONAL INSTITUTIONS ARE INHERENTLY EVIL ON THE ADMITTED INADEQUACIES OF PRISONS BUILT LONG AGO. IT IS SUGGESTED, HOWEVER, THAT THE OBSERVATION THAT PRISONS ARE INHERENTLY EVIL IS VALID FOR THE 103 NEWEST PRISONS IN THE UNITED STATES. THREE SPECIFIC CRITICISMS OF THE FEDERAL BUREAU OF PRISONS ARE RAISED: (1) THE FEDERAL PRISON SYSTEM IS OUT OF STEP WITH 'CREATIVE FEDERALISM' -- THE IDEA THAT THE CENTRAL GOVERNMENT SHOULD ENABLE WHILE THE STATES AND LOCAL COMMUNITIES OPERATE; (2) THE BUREAU HAS NO GRASP OF THE CONCEPT OF TOTAL SYSTEMS PLANNING; AND (3) BY ITS VERY NAME, THE BUREAU IS LIMITED TO THE BUILDING AND OPERATION OF PRISONS, ITS SUCCESS OR FAILURE TIED DIRECTLY TO THE PERPETUATION OF INSTITUTIONAL SOLUTIONS TO THE CRIME PROBLEM. A BRIEF REVIEW OF PENAL HISTORY INDICATES THAT, IN THE TWO CENTURIES SINCE THE FIRST PENITENTIARY, ONE TREATMENT CONCEPT AFTER ANOTHER HAS BEEN ABSORBED INTO THE PENAL SYSTEM IN A CONTINUOUS, FUTILE EFFORT TO OVERCOME THE INHERENT WEAKNESSES OF CONFINEMENT. FACTORS THAT MAY ACCOUNT FOR THE FAILURE OF INSTITUTIONALIZATION -- THE WORKINGS OF PRISON SUBCULTURES, THE TENDENCY OF PRISON LIFE TO DESTROY THE QUALITIES THAT HELP PEOPLE SURVIVE ON THE OUTSIDE -- ARE NOTED. EVIDENCE THAT THE UNITED STATES' CRIME PROBLEM COULD BE BETTER ADDRESSED THROUGH GUN CONTROL AND REDUCTION OF UNEMPLOYMENT AND UNDEREMPLOYMENT THAN THROUGH THE CONSTRUCTION OF MORE PRISONS IS CITED. (LKM)