Regarding Sidney Holt's Oct. 23 letter, "Rules for unsubsidized whaling": Holt's statement that "Japan, more than any other nation, has opposed conservation measures and efforts toward sustainability far more often than any others" is simply false. Further, as an ardent advocate for the protection -- not conservation -- of all whales, he is ill-qualified to specify rules for resuming commercial whaling.

His suggested rules are the same as we've heard at the International Whaling Commission from antiwhaling countries during 15 years of failed negotiations: It is a tactic of making management rules unnecessarily duplicative and expensive to make it impossible for whaling to be viable.

Holt's assessment that Mark Brazil's Oct. 15 article, "Let them eat whales," is "well-argued" is wrong. Brazil's article contains numerous errors including that antiwhaling attitudes are "global." In fact, antiwhaling attitudes occur mainly in developed Western nations. Brazil has also wrongly extrapolated the results of contaminant testing of a few small, toothed whales to all whales. This is grossly misleading. Meat from baleen whales -- particularly baleen whales from the Antarctic -- generally has very low levels or no contaminants.

Brazil also refers to "the mountain of surplus whale meat in huge cold-storage facilities." He is repeating Greenpeace, but again this is simply untrue. In March of this year there were 2,368 tons of whale meat in storage, compared to 160,000 tons of pork and over 60,000 tons of beef.

There is a flaw in the logic of Brazil's argument that whaling should be allowed only if it is not subsidized. Despite years of multilateral negotiations to eliminate agricultural and fisheries subsidies, food production systems worldwide remain subsidized. Why should whaling for food be differently conditioned?

dan goodman