To put it bluntly, Bill Cowher is coaching like a guy who plans to go on sabbatical next year.

That’s what the rumors say and that’s what the results say, notably Sunday’s game in Oakland, where the Steelers outgained the Raiders 360-98, but managed to lose 20-13 because Ben Roethlisberger threw four interceptions, two returned for touchdowns.

Blame Cowher?

Sure. The buck stops at him, and the Super Bowl champions are 2-5, three games behind Baltimore in the AFC North almost halfway through the season. His main mistake this week: starting the star-crossed Roethlisberger a week after his second concussion in four months.

“I haven’t got a whole lot to say,” Cowher said after the game. “Four interceptions, two returned for touchdowns, you can’t overcome that.”

What he should have said was one word before the game: “Batch.”

As in Charlie Batch, who has proven in limited action that he’s perfectly capable of winning against a team like Oakland, which actually looked like it had a legitimate shot at going 0-16 until it beat equally hapless Arizona last week.

The Steelers certainly aren’t the NFL’s only underachievers. Seattle, the team they beat in the Super Bowl, is just 4-3.

Yes, the Seahawks have been hurt offensively by injuries to Shaun Alexander and Matt Hasselbeck and the offseason defection of Steve Hutchinson. But a Super Bowl defense shouldn’t allow 499 yards to anyone, as Seattle did in the 35-28 loss in Kansas City.

Carolina, one of the preseason favorites in the NFC, is just 4-4. It can’t run the ball – under 100 yards a game. And it’s supposed shutdown defense got no pass rush Sunday night against Tony Romo, a quarterback making his first NFL start, and allowed the Cowboys to rush for 156 yards.

And Philadelphia has lost three straight since it beat Dallas in the T.O. return game on Oct. 8. In Sunday’s 13-6 home loss to Jacksonville, the Eagles allowed the Jaguars to run for 209 yards even though the wind at Lincoln Financial Field made passing of any kind difficult – and should have allowed Philadelphia to stack the front.

But the Steelers are Exhibit A because they are the champions. Yes, champions also fall the season after they win, but Pittsburgh is a historically sound franchise and a collapse was largely unforeseen.

Maybe it’s just in the stars.

It started with Roethlisberger’s motorcycle accident in June. He was lucky to survive, especially lucky to be ready for training camp the next month.

But what was overshadowed by his luck in escaping with facial injuries and a broken jaw was that he also had a concussion, the kind of trauma that doesn’t stand up well in the brutal world of the NFL. Then came an appendicitis attack on the eve of the season, then another concussion a week ago in a 41-38 overtime loss in Atlanta.

Why did he start Sunday? Cowher said after Roethlisberger practiced last week that he was very impressed. But some folks who talked with the Steelers QB last week came away with the impression he wasn’t as sharp as normal.

There are other factors in Pittsburgh’s fall, of course.

They clearly missed the retired Jerome Bettis on Sunday. The best example on his on-field absence came with just under three minutes left in the game when, trailing by a touchdown, they had a first down at the Oakland 1-yard line.

In past years, that would have been an automatic: Bettis into the line, touchdown!

Now it was Willie Parker, who used to come out when they reached the goal line, just as the Giants lift Tiki Barber and insert Brandon Jacobs, who has solved all the short-yardage problems they used to have.

Parker went into the line for no gain. So the Steelers tried Najeh Davenport, the ex-Packer they picked up in hopes he had overcome his various injuries. Davenport lost 4 yards.

The Steelers lined up at the 5. Whoops, false start. Third-and-10. Two incomplete passes and there went the last best chance, one that Bettis probably would have converted on first down.

It’s not all Roethlisberger, of course. It’s also the struggling offensive line, one of the best in the game the last few years. The right side has been soft. Tackle Max Starks is having a bad year and right guard Kendall Simmons, a former first-round draft pick, was benched and replaced by Chris Kemoeatu, a fifth-round pick in 2005 who was inactive for 15 games last season.

Overall, it’s simply a wacky season throughout the NFL.

The Raiders’ win marked the third straight week that a team won without scoring an offensive touchdown. Tampa Bay beat Philadelphia on Ronde Barber’s two interception returns on Oct. 22, and two weeks ago was Chicago’s come-from-behind win over Arizona in which the Bears scored on two fumble returns and a punt return.

But the strangest development still is the Steelers’ decline, especially because they seemed to find their form following a 45-7 thumping of the Chiefs two weeks ago. Then came an overtime loss in Atlanta and Sunday’s debacle.

“Two wins for the year – that’s not the way you imagined the Super Bowl champs would start the year off,” said Hines Ward, the team’s best offensive player and locker room leader. “When you turn the ball over as much as we did, it’s hard to beat anybody.”

AP-ES-10-30-06 1638EST