MR. WHEELING: Good morning. My name is Craig Wheeling and I'm the CEO of Brooks Tropicals. We're the largest domestic producer of tropical fruits. Our company grows tropical fruit like avocados, limes, papayas and mangos. Our main problem is harmful pest introduction. It has been mentioned a couple of times previously, but I just want to go into that in a little more detail.

In terms of trade, you can't export what you can not grow because you don't have a spray for a hitchhiking pest. All of the fruit we grow is vulnerable to pest introductions like fruit fly. Furthermore, effective sprays either may not exist or may not be approved for use by APA. A good example is bacterial citrus canker for which there is no spray cure or seed weevil where the cure is to burn your tree.

Our firm supports improved trade. Indeed, we are somewhat unique in that a good portion of our company's business revolves around marketing fruit from Latin America and the Caribbean. But Florida is currently suffering a rash of domestic infestations. In the 1990s we've had two infestations of citrus canker, one of which as has been mentioned before will cost over 170 million to eradicate. Canker is currently one mile north of our commercial lime growing area. In the next month we will spend $300,000 on chlorine and other wash systems to combat this with no commensurate revenue.

Oriental fruit fly found in May 1999. Mediterranean fruit fly, a very bad insect, found in 1990, found in May 1997, found in April 1998. Citrus leaf mite found in May 1993 -- a horrible problem when we tried to replant limes after Hurricane Andrew. Brown citrus aphid found November 1995. Citrus psyllid found June 1998. Citrus longhorn beetle found April 1999. Killer bee found in Jacksonville, May 1999. Mexican weevil, a serious pest, got established in the 1990s. Tomato yellow leaf curl virus found 1997. Asian wooly hackberry aphid found 1998. Small hive beetle, May, 1998. Asian elm aphid 1998. I'll stop, but there are more.

Some of these are very bad pests like medfly and canker which can destroy whole industries. This list does not add confidence to me or our growers that our borders are being adequately protected. Where are these pests coming from? At the same time of the pest introductions in Florida, trade and travel have increased. From the USDA website it says that the sheer volume of trade means about 70 percent of the trucks sail through the Nogales, Mexico entry gates without anyone from any agency inspecting any cargo at all.

The systems approach has been used to justify and liberalize fruit importation rules into the U.S. This is a statistical predictive model known as quantitative risk assessment. But we believe that there are problems with the use of this model. Indeed, Dr. Jan Nyrop from Cornell University analyzed the risk assessment model used in the Mexican avocado entry and he concluded that the Monte Carlo simulation was not needed and only provided analytical objectivity, the data upon which parameters of the model were estimated either were non-existent or not adequately documented.

Mexico has been allowed to ship avocadoes into 19 northern U.S. states for two seasons using the systems approach. Prior to this allowance a major area of concern of the model was that it would be impossible to restrict distribution of the fruit to these 19 states. In the first season USDA agents at Wal-Mart violated the Planned Protection Act by receiving Mexican fruit outside of the designated 19 states. Six states outside of the legal area are believed to have received illegal fruit during the first season. In the second season five other distributors shipped Mexican fruit outside the 19-state area, one shipment of which went to Florida where a scaled insect which found, which in Florida is an actionable pest.

Using a systems approach based on inaccurate inputs is equivalent to designing computer software under the old adage garbage in, garbage out. A further problem in trade negotiation is pesticide regulation. Currently we do not have a level playing field. A specific instance, Mexico is allowed to export avocadoes to the U.S. with parathion residue. Parathion is a very bad pesticide. It's acutely toxic and it may pose chronic effects including nerve and muscular degeneration, depression, memory loss and disorientation. It is associated with bird kills since the 1950s and 52 accidental fatalities in the U.S. from 1965 to 1980. Most domestic uses of parathion were cancelled in 1991, however, Mexico is allowed to export avocadoes to the U.S. with a residue of parathion on the fruit.

In summary, as trade has exploded, pest infestations have become a huge problem, especially to subtropical farmers. U.S. producers are severely restricted on what pesticides they can use, and the new group of U.S. pesticides tend to be very expensive. We have a very tough time fighting new pests, some of which will destroy our farms if they become established.

We believe that successful trade discussions must address these two problems. Thank you for taking the time to hear us.

(Applause.)