I would like to set the record straight on just a few of the many misstatements in Thomas Thompson's complaint about imposing anti-dumping duties on imports of Chinese manhole covers {op-ed, Dec. 25}.

First, Mr. Thompson suggests that dumped Chinese imports don't compete with domestically produced manhole covers in the Northwest. That's untrue. My foundry produces manhole covers in Washington and has been hurt by dumped and subsidized foreign castings.

Second, the coalition of foundries to which Mr. Thompson refers is not "primarily eastern." The Municipal Castings Fair Trade Council has members in 15 states including California, Texas, Nebraska, Minnesota and Wisconsin as well as my foundry.

Third, while Mr. Thompson complains about the Commerce Department's methodology for calculating anti-dumping duties and suggests that China may have a comparative advantage in labor costs, he ignores that the United States has a comparative advantage in most other aspects of the production of construction castings, including raw materials, mechanization, energy and transportation. In fact, one of the most misleading statements by Mr. Thompson concerns the costs of foundry-grade sand -- a product he suggests can be found cheaply in the desert but that in reality is specialized and costly.

Finally, Mr. Thompson attempts to scare the reader by suggesting that a recent $1 million purchase of American equipment by the Chinese was suspended "in retaliation for Commerce's antics." Enforcing the U.S. anti-dumping law is the Commerce Department's responsibility; it is not an antic. More important, China has much more to lose by retaliatory tactics, because the United States suffers an $8 billion trade deficit with China.

RAYMOND L. DAVIS President, Inland Foundry Co. Inc. Mead, Wash.