In his Sept. 17 op-ed piece, "Ireland's Famine Wasn't Genocide," Yale economics professor Timothy W. Guinnane says, "With the potato crop ruined, Ireland simply did not have enough food to feed her people."

According to economist Cormac O' Grada, more than 26 million bushels of grain were exported from Ireland to England in 1845, a "famine" year. Even greater exports are documented in the Spring 1997 issue of History Ireland by Christine Kinealy of the University of Liverpool. Her research shows that nearly 4,000 vessels carrying food left Ireland for ports in England during "Black '47" while 400,000 Irish men, women and children died of starvation.

Shipping records indicate that 9,992 Irish calves were exported to England during 1847, a 33 percent increase from the previous year. At the same time, more than 4,000 horses and ponies were exported. In fact, the export of all livestock from Ireland to England increased during the famine except for pigs. However, the export of ham and bacon did increase. Other exports from Ireland during the "famine" included peas, beans, onions, rabbits, salmon, oysters, herring, lard, honey and even potatoes.

Dr. Kinealy's research also shows that 1,336,220 gallons of grain-derived alcohol were exported from Ireland to England during the first nine months of 1847. In addition, a phenomenal 822,681 gallons of butter left starving Ireland for tables in England during the same period. If the figures for the other three months were comparable, more than 1 million gallons of butter were exported during the worst year of mass starvation in Ireland.

The food was shipped from ports in some of the worst famine-stricken areas of Ireland, and British regiments guarded the ports and graineries to guarantee British merchants and absentee landlords their "free-market" profits.

Mr. Guinnane says that "the contrast with the Holocaust is instructive" and points out that the British did not act like Nazis who "devoted considerable resources to hunting down and murdering the Jews." Instead, he says that "the British government's indifference to the famine helped cause thousands of needless deaths."

Richard L. Rubenstein, in his book, "The Age of Triage: Fear and Hope in an Overcrowded World," says, "a government is as responsible for a genocidal policy when its officials accept mass death as the necessary cost of implementing their policies as when they pursue genocide as an end in itself." JAMES MULLIN President Irish Famine Curriculum Committee and Education Fund, Inc. Moorestown, N.J.

Timothy Guinnane's question, "But does the {British} government's inadequate response to the famine constitute genocide?" is answered in the affirmative by the following undisputed facts:

In 1846 Prime Minister Robert Peel succeeded in repealing the Corn Laws, eliminating protective tariffs on grain imports to the United Kingdom, thereby reducing the cost of grain and bread. The compelling reason for the repeal was the crop failure in Ireland. Peel also established the Relief Commission to coordinate relief measures in Ireland.

Lord John Russell replaced Peel as prime minister in mid-1846. Russell immediately abolished Peel's Relief Commission. Under Russell's administration, all food depots except on the western seaboard were closed, public works were suspended, and local relief committees were forbidden to sell or distribute food at less than prevailing prices -- which were inflated because of scarcity and speculation.

The chief architect of these policies was Charles Trevelyan, assistant secretary of the treasury and director of government relief, who was knighted in 1848 "for his services to Ireland." The motivation for these policies was attested to by none other than Trevelyan, who stated: "The great evil with which we have to contend is not the physical evil of the famine, but the moral evil of the selfish, perverse and turbulent character of the {Irish} people."

In mid-1847, Parliament amended the Poor Law with the "Gregory Clause." The effect of this clause was to forbid public relief to any household head who held more than a quarter-acre of land and refused to relinquish possession of the land to the landlord. The choice was either become landless or starve, and many Irish chose the latter. Those who chose eviction were at the tender mercies of the Russell administration, whose policies are described above.

During the famine period, the wheat and other grain crops were unaffected and were reported to be "bountiful." However, the Irish could not take advantage of those crops. The agricultural structure of the times required landlords to pay "rates" to Britain, which were due and payable even if the tenant farmer could not pay rent. Russell and Trevelyan never permitted an abatement on "rates," with the result that wheat and other grains were exported to pay "rates" while millions of Irish starved. (The estimated deaths from the famine are between 1.1 and 1.5 million.)

Finally, Mr. Guinnane's disingenuous observation that "by 1847 Ireland was a large net importer of food" misleads the reader. He fails to point out that throughout the famine period, Ireland exported 100,000 pounds sterling of food monthly, and almost throughout the period Ireland remained a net exporter of food.

Russell and Trevelyan's laissez-faire economics cannot forgive or excuse the results of their policies in Ireland any more than Pol Pot's political ideology can protect him from the ravages he visited on his people, which -- as I recall -- are being referred to as genocide. Similarly, the forced deportation of the Armenians by the Turks during World War I, resulting in untold deaths and suffering, is known as genocide -- and I would not quarrel with that. DENNIS F. NEE Washington

Timothy Guinnane's statements are surprisingly misleading. The disastrous potato famine of 150 years ago should and could have been avoided. During that famine, wealthy Irish Catholic landowners of the South continued to sell their abundant crops, their beef and their lamb to French, German and Low-Country markets rather than feed their own impoverished and starving tenant farmers. Aggravating the farmers' reliance on the blighted potato was the number of young in each Catholic family. In the following four years, potatoes continued to be planted and new babies born, while in the Protestant North -- with its same reliance on the staple potato -- crisis was eased by the region's industry and a landowner population caring for its poor.

Certainly the predominantly English Parliament also was at fault. Unfortunately, they were not made aware of the Irish famine until it had reached disastrous proportions and then behaved with far too typical indifference to a problem so non-English in much the same way they had behaved with our own American colonies some 70 years earlier. IRVING O'SHEA ROBINSON Baltimore

The Oxford English Dictionary defines genocide as the {attempted} deliberate and systematic extermination of an ethnic or national group. The Catholic Irish were an ethnic or national group.

During the famine, the British government deliberately and systematically adopted reckless and wanton policies of official neglect that exacerbated the famine's savagery and substantially increased its cruel death count. Can inactivity be criminal to the point of homicide? I submit that it can and was in the circumstances of the Great Famine.

As force majeure masters of Ireland, the British had an affirmative duty grounded in justice to provide relief. They had the means and the ability to deliver such relief. They intentionally failed to do their duty because of their hostility to Irish Catholics -- who then starved to death by the hundreds of thousands as their rich and well-fed British rulers complacently waited and watched. British inertia in such circumstances was callous, contemptible -- and maliciously criminal to the point of second-degree murder. D. J. REARDON Leavenworth, Kan.