Michael Kinsley's column "High-Fructose Baloney" {op-ed, May 31} contained some baloney on sugar, as well. Mr. Kinsley referred to a consumer cost of the U.S. sugar program of "more than $3 billion a year" -- a nonsense figure if there ever was one.

Back in the summer of 1985, the so-called "world price" of raw sugar averaged less than three cents per pound for two months, an all-time low in real terms. During the 1980s, monthly average prices ranged as high as 41 cents; prices in 1990 have averaged about 15 cents. The wizards who calculated the $3 billion cost figure used the sub-three cent figure and assumed that unlimited quantities of this sugar could be purchased from the world market without changing the price.

Clearly this is nonsense. In the absence of a U.S. sugar industry, U.S. consumers would be purchasing about 7 million tons of sugar from the thinly traded world residual market for sugar -- by far the most volatile commodity market in the world. This would represent about a 50-percent increase in buying from that market, and the price would certainly go through the roof. During a period in 1975 when there was no U.S. sugar program, the "world price" cleared 60 cents per pound.

At a conference on sugar policy at the Department of State last month, Andrew Schmitz, chairman of the Department of Agricultural Economics at the University of California, Berkeley, debunked the $3 billion estimate and provided a calculation of the annual societal cost of the U.S. sugar program that he had done in 1987 -- $203 million. Prof. Schmitz also provided in his study a host of reasons, including the resurgence of the world price, indicating that even this estimate is probably high.

I would also like to pass along to Mr. Kinsley some U.S. Department of Agriculture statistics on relative retail prices for sugar that suggest the program is costing U.S. consumers nothing at all. USDA reports that, on the basis of a survey performed in November 1989, the U.S. average retail price that month was 40 cents per pound, well below the average of the developed countries and lower than virtually all of the other sugar-importing countries surveyed.

In the United States, not even baloney is cheaper. LUTHER A. MARKWART Chairman, American Sugar Alliance Washington