David Miller, California Tree Fruit Agreement.

MR. MILLER: Yes. I'm David Miller, the International Program Director for the California Tree Fruit Agreement. That would be the marketing body for the peach, plum and nectarine growers of California under various federal marketing owners and state marketing owners for the plum marketing Board.

On behalf of the nearly 2,500 growers, I would say there's several important issues we'd like to address in this next round regarding trade. But since we're small horticultural producers, we'd like a shorter round this year in agreement with what the Administration says. We'd also like to talk about the technical issues which tend to be our only avenue of resolution when we come into quarantine problems.

Because while the last round did, indeed, address several issues regarding SPS issues, it seems there are still many countries that are of a single mind about using quarantine barriers as a great means of protecting the growers of a more competitive marketplace.

Therefore, should we enter into the discussion of the SPS issue, it certainly would be in our interests that we do everything we can to avoid getting into this dialogue and backsliding from what we already gained in the last round.

So, when we see that these countries take these stands, we should certainly, at least, set up new standards that they must justify their position, should they choose to take this insidious form of protection. At the very least, we have to give them the scientific issue that they have to address the level of threat that comes to their country.

It's very unfair that a country post a barrier for a particular insect or any specific life form, be it a fungus, insect or a bacterial or viral disease, without having first hand assessed the populations of such entities already present in their country or production areas. It would be preferred that their own scientific papers have also been reviewed internationally by their scientific peers, hence unfettered by unqualified peer or political oversight.

Then we get to Pest Risk Assessment a part of SPS. These mechanisms worldwide are far too variable. If we could standardize this process, it would allow government agencies and commodity groups the ability to prepare the information ahead and the receiving country to abide by a standard of what must first be evaluated. These commodity-specific assessments ought to assess the areas of production and not just a country at large.

Absolutely, a sovereign nation's quarantine security is critical, but we need to set new standards for what constitutes a secure level of treatment. Certainly, "zero tolerance" is not tolerable. Especially given that some of the countries with this policy are also intolerant of pesticide residues.

For example, right now, we have a situation in Taiwan. They're increasing their quarantine conditions, but they're not allowing us to use the pesticides that we've allowed to use under EPA standards and hence they're keeping us out with a double standard. We have to avoid SPS security that will result in "scorched earth" policies of methyl bromide fumigation or all out exclusion.

At the very least, given the advanced techniques of the day, a system should be allowed that allows the suppliers to implement a "Systematic" process, by which each level of the production of a commodity can minimize the potential introduction of an unwanted pest.

A systems approach should be allowed that is quantifiable and provides a level of security commensurate with the threat. Furthermore, such systems may tend to be safer and possibly even more environmentally sound and looking more towards the future.

As I mentioned, SPS is a problem, but we have other issues. Unfettered access should also include the elimination of discretionary import permitting practices. We also need to recognize that the dispute resolution process, though a very forward approach in this issue, needs to have some teeth put into that process.

Probably, on the horizon what we see, with SPS barriers, is this new variant called food safety. Now, I guess, the quarantine agencies see there's a problem with their approaches so far, but as we see new lists of acceptable chemicals, additives and pesticides coming into the mix of what can be allowed into a country, we find a whole new opportunity for more barriers and we need to protect against that.