The Honorable Donald Evans
Secretary of Commerce
U.S. Department of Commerce
14th Street and Constitution Avenue, N.W.
Washington, D.C. 20230
Attention: Central Records Unit, Room 1870

Re:      Spring Table Grapes from Chile and Mexico; Inv. Nos. A-201-829 and A-337-805

Dear Secretary Evans:

We understand that the Department of Commerce is currently examining an antidumping duty petition that was filed on March 30, 2001 by a small group of U.S. grape growers, primarily from Coachella, California. The petition was filed against the grape exporting industries in both Chile and Mexico. We are writing to you because many members of the Food Marketing Institute (FMI) believe that they and the American consumers that they serve will be injured if this case moves forward.

FMI is a non-profit association that conducts programs in research, education, industry relations and public affairs on behalf of its 1,500 members and their subsidiaries. Our membership includes food retailers and wholesalers, as well as their customers, in the United States and around the world. FMI’s domestic member companies operate approximately 21,000 retail food stores with a combined annual sales volume of $300 billion, which accounts for more than three-quarters of all grocery sales in the United States. FMI’s retail membership is composed of large multi-store chains, small regional firms, and independent supermarkets.

Many FMI members believe that the presence of Chilean and Mexican grapes in the U.S. marketplace has not harmed U.S. interests but, instead, has created a win-win situation for both U.S. businesses and U.S. consumers. Given the U.S. climate, domestic producers simply cannot supply grapes for U.S. supermarket shelves year-round. Chilean grapes, which are primarily sold in the U.S marketplace during the winter months, when domestic grapes are not available, allow U.S. supermarkets to keep consumers supplied with this delicious, reasonably priced, nutritious source of food on a year-round basis. The steady supply of fresh, high quality Chilean grapes in the U.S. market place has also played an important part in keeping grape prices stable for our member companies and for American consumers.

Many FMI members believe that if Chilean and Mexican grapes are effectively removed from the U.S. marketplace by the application of future dumping duties, U.S. consumers will pay a heavy price. The imposition of duties would also likely harm the ongoing Chile-U.S. Free Trade Agreement negotiations, and the long-term U.S. trade development goals in the region as well.

Accordingly, FMI member companies respectfully request that your agency examine this case and the facts presented above carefully, and with an eye toward ensuring that the broadest scope of U.S. interests are served in this matter.

Sincerely,

George Green
Vice President
General Counsel