Dear Chairman Bragg and Secretary Koehnke:

Food Marketing Institute (FMI) files this comment in opposition to the imposition of any remedy in the above-referenced investigation. The proposed remedies include an increase in the tariff on lamb meat or a quota limiting the amount of lamb meat imported. These measures are not in the interest of consumers because they will reduce availability and/or raise the price of lamb meat. This, in turn, will result in a decline in demand for lamb meat, thereby injuring not only consumers and retailers, but also the lamb industry itself.

FMI particularly disagrees with Petitioner’s assertion that retailers would or could absorb price increases resulting from higher tariffs. In this regard we support the testimony of Mr. Marty Gardner, Director, Meat Merchandising at Wegman’s Food Markets, at the February 25, 1999 remedy hearing in this proceeding.

The retail price of any product is directly related to its costs. The assumption that the retail sector could or would absorb the costs of any tariffs requested by the petitioners is simply unfounded and inaccurate. Food retailing is a highly competitive industry and our members do all they can to hold down costs and prices. Margins and profits are so tight that there is no room to "absorb" these unnecessary cost increases.

FMI is a nonprofit association conducting programs in research, education, industry relations and public affairs on behalf of its 1,500 members including their subsidiaries — food retailers and wholesalers and 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 $220 billion — more than half of all grocery store sales in the United States. FMI’s retail membership is composed of large multi-store chains, small regional firms and independent supermarkets. Its international membership includes 200 members from 60 countries.

If you have any questions concerning our position or about this filing, please contact me.

Respectfully submitted,