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State College of Agriculture

At Cornell Aniversitp
Dthaca, N. V.

Librarp
AMERICAN
HORTICULTURE

and

QUARANTINE
O7

A BRIEF COMPILATION OF
ARGUMENTS AND FACTS

Including

1. Statement of the Tariff and Legislation Committee
of the S. A. F. and O. H. presented at the Quarantine Con-
ference in Washington, May 15, 1922.

2. “The Case of Quarantine 37,” as published in
THE FLORISTS’ EXCHANGE of April 29, 1922.

3. The Question of Plant Quarantine as Viewed in
Great Britain, being the address made by Mr. William G.
Lobjoit, Controller of Horticulture, British Ministry of
Agriculture, at the Washington Conference, May 15, 1922.
In troduction

Quarantine 37, an outgrowth of the Act of Aug. 20, 1912, went inte
effect on July 1, 1919. Imposed ostensibly to protect this country against the
introduction of new, injurious insects, its regulations have, as a matter of fact,
been directed mainly and almost exclusively against the importation of the plant
materials of “ornamental horticulture.’ Under the increasing burden of its
severe, sweeping, discriminatory and often unreasonable restrictions, there has
gradually risen during the past three years a mighty wave of resentment and
protest on the part of those whose legitimate activities have been hampered or
interfered with. These include both individuals, who are no longer able to secure
the plants they want and need for developing their gardens and conducting scien-
tific work, and commercial institutions that find it impossible to secure or handle
commodities that they previously handled and for which there is still an active
demand. In other words, both individual initiative and business progress have
been checked and, in some cases, suffocated.

And yet the actual reasons for these results and the way they have come about
are even now clearly understood by only a small proportion of those whose inter-
ests they threaten. Thousands of amateurs, plantsmen, growers and commercial
horticulturists know merely that they can no longer secure the plants they want
or need—or can get them only at prohibitive prices—without realizing why and
without appreciating the still larger dangers to which a continuation of present
conditions, an acceptance of existing policies and principles, an acquiescence to
the vast interpretative and legislative authority assumed by the Federal Horti-
cultural Board, may give rise.

The F. H. B. has repeatedly referred in its defense of Quarantine 37 and
its other rulings to “propaganda” against it, and to a wide misunderstanding of
its aims and methods. Actually, there has been a more extensive and more defi-
nitely organized propaganda for the Quarantine than against it; and certainly
the existing misunderstandings are in the minds of those who support the ruling
and refuse to attribute anything but misdirected and selfish motives to the great
mass of citizens who are opposing it—for the latter have at heart the future
welfare of American horticulture as a whole, knowing how much this can and
should mean to the nation and its progress.

The purpose of this pamphlet is to centralize horticultural trade opinion
upon the basic facts to the end that there shall be given adequate, reasonable pro-
tection against new, dangerous plant pests through a system of inspection and
certification of imported plants, without the present day total exclusion of
plants save such few exceptions as the F. H. B. sees fit to admit.

May 15, 1922, marked the culmination of the first stage of the campaign
against Quarantine 37. Secretary of Agriculture Wallace did preside at the
conference and threw it wide open for “full and free discussion.” As a result,
the facts were given wide publicity and brought to the personal attention of a
Cabinet officer; the F. H. B. acknowledged that some of its actions may have
been open to question; the legal status of Quarantine 37 was definitely ques-
tioned and a conference arranged to consider it; and other conferences were
planned at which specific recommendations involving modifications could be
discussed. So the situation stands at present.
Statement by the Tariff and Legislative Com-
mittee of the Society of American Florists
and Ornamental Horticulturists

THs committee speaks for the Society of American Florists and Orna-

mental Horticulturists—the national organization of florists with
which are affiliated more than twenty State and district horticultural or-
ganizations, having a combined membership of upward of 10,000, and in-
cluding practically all of the leading firms and horticulturists in the
United States. We approach the Board in a spirit of cooperation, we offer
you only constructive guidance; we seek only the best interests of our
members consistent with the present and future interests of this country.

As to the purpose and scope of this Conference, what subjects would
be considered here—we were informed by this Board and by Secretary
Wallace that Quarantine 37 would be thrown open for a full and free
discussion for the future guidance of the Department, so we prepared
to cooperate on that basis. If the Board has new proposals to advance
we ask for sufficient time to consider them—thus avoiding snap judg-
ment on important matters.

While offering constructive advice with regard to Qu. 37 and advis-
ing changes in the Board’s present policy, we credit the Board with the
best intentions and ask that we be credited with a genuine desire to
cooperate with the Board in carrying out its legitimate functions. We
consider the Federal Horticultural Board a necessary and useful body—
providing it adheres to its proper legal function: that of advising the
Secretary of Agriculture how to combat existing pests and plant diseases
and prevent the introduction of new or dangerous ones. We believe in
Government control of imports and in thorough inspection and certifica-
tion of imported plant products when necessary; but we protest vigor-
ously against Qu. 37 as administered, and which operates as a blanket,
economic embargo.

It is unfortunate that this Board is named “The Federal Horticul-
tural Board” for its functions are entomological rather than horticul-
tural. It is wrong that the U. 8. Customs classification of “Nursery Stock”
is used by the Board, for by including such classes of plant material as
orchids, palms, forcing bulbs, and plants imported exclusively by florists
in the term “Nursery Stock,” confusion is created in quite different in-
terests. Qu. 37 excludes a far larger volume and variety of necessary
plant material from florists than from nurserymen. We urge that the
consideration of “Florists’ Stock,” imported by florists, and “Nursery
Stock” imported by nurserymen, be kept quite separate at this Conference
as far as practicable. In this statement we refer only to florists’ stock im-
ported by florists.

Horticulture does not recognize boundaries; plants grow naturally in
localities where climatic and other conditions are most favorable, so
the best varieties growing in every civilized country today were imported
from some other country. Our hot Summers, combined with our cold Win-
ters, make it necessary for this country to import more raw materials
and plant products than any other, and the prosperity of our citizens
creates a larger demand for the best varieties of plant life than any other
country enjoys. And as the florist industry in this country owes its

3
enormous expansion largely to the diversified variety of plants and
flowers it is able to offer the buying public, it is obvious that any restric-
tions on imports, especially on raw materials or plant products that can-
not be commercially produced here, must be disastrous not only to hor-
ticultural trade interests, but ultimately to the United States.

To see why we need Government control of imports we must go back
to the year 1912, just before the “Plant Quarantine Act” was passed by
Congress; large shipments of plant products as well as nursery stock
were ariving from foreign countries under no Federal control; some States
had adequate inspection laws, properly enforced, other States had inade-
quate laws and lax enforcement; some States had no inspection law; so
the Department said that in view of that lack of uniformity in statute
and enforcement and the occasional absence of any inspection, and con-
sidering the common interest, the Department ought to be given author-
ity to see that importations from districts harboring a pest new to
this country or not generally distributed here, were given proper inspec-
tion by Federal officers.

What the Law Says a Quarantine Should Do

That was the whole plea at that time; for inspection. The trade
organizations recognized the necessity for such a law—the florists are
_continually fighting insect pests and plant diseases, it is part of their
business, and they wanted all the help the Department could give in com-
bating the existing pests and, of course, keeping out others, so the law
was passed by Congress and gave the Secretary, through the Board, wide
powers. Then the quarantine orders began to come until we now have
fifty-four of them. This law did not give the Board power to legislate,
to prohibit imports because they happened to be horticultural imports, to
build a Chinese wall around the United States in a horticultural sense
with a few small openings; in fact it limited the issuance of quarantine
orders in these four important ways:

1. The quarantine must be to prevent the introduction into
the United States of insect pests and plant diseases,

*. Which are new to or not heretofore widely prevalent or
distributed within or throughout the United States.

3. The order can only prohibit importation from a country
or locality where “such diseases or insect infestation exists,” and

4. The country or locality, and the class of plant products to
be excluded, must be specified in the order.

If Belgium has, say, a dangerous disease which is new to or not
widely prevalent here affecting Araucarias, this law gives power to
exclude Araucarias from Belgium if that is the only way to exclude the
disease; it clearly does not give the Department or the Board the power
or right to exclude nearly all plant products from every country or lo-
cality on the earth, on suspicion, as Qu. 37 does.

We have outlined the original plan for inspection and certification
as required by the Department and endorsed by the trade organizations:
now let us come back to the present and see how far the Board has
wandered from the original plan. I quote the words of the chairman
of the Board, as printed in the florist trade papers:

“As to returning to the old practically free entry of foreign
plants, a test over a seven year period was given to the possi-
bility of safeguarding such plant importations by inspection and
disinfection, and this test indicated the absolute inadequacy and

4
failure of this method of excluding new pests and forced the con-
clusion on this Department, and on the plant experts of all of our
states that the only safeguard for the future was the exclusion
of all plant stock not absolutely essential to the agricultural, hor-
ticultural and forestry needs of the United States.”

In other words the chairman says that having tried to do what the
law authorizes, and having failed, the Board decides to do something
else; something entirely without and beyond the limits of the legal
authority conferred by Congress. We florists cannot agree with, or sub-
scribe to any proposition that it is necessary or effective to exclude im-
portant classes of plants and plant products because of the alleged in-
adequacy of inspection. If the Board’s inspectors cannot do the work ef-
fectively, or lack equipment, then the Department can get other inspectors
and provide the necessary equipment.

When the Board undertakes to say what plant materials this country
needs, and what it ought to be permitted to have, it wanders off into the
field of economics and assumes powers it does not have and should not
have; it has no present authority in law to decide such matters. The
function of the Board is only to advise, and that on scientific matters re-
quiring expert knowledge of pests and plant diseases; as such it is prop-
erly limited in its personnel to expert advisers on entomology and plant |
pathology. When it comes to deciding what plants and plant products
the country requires, the florists and nurserymen can furnish expert
knowledge on that subject which the Board does not claim to possess.
It was not intended for this Board to decide such matters, for such ex-
perts are prone to consider plants as hosts and carriers of diseases and
be critical and unsympathetic toward practical horticulture.

The Effect of Quarantine 37 on Plant Imports

Now let us look for a moment at the effect of the present policy of
the Board as embodied in Qu. 37—and the full results are not yet visible.
Belgium, that shipped approximately 32,000 packages of plants and plant
products annually prior to Qu. 37 (1934 tons in 1918) now ships less
than 50 packages (3 tons in 1920). One little district in Holland (Bos-
koop) that formerly shipped 35,000 cases annually, now ships less than
300; our entire imports of plants and plant products, excluding bulbs,
from Holland in 1920 were less than 3 per cent of our 1916 imports. (The
Holland-America Line carried in 1916, 81,686 cases of bulbs and 39,145
cases of nursery stock as against 14,036 cases of bulbs and 808 cases of .
nursery stock in 1920. Total 120,000 odd for 1916 and 14,000 odd for
1920.) France and Japan that formerly shipped hundreds of varieties
of ornamentals, now ships none except under special permits. Out of the
thousands of varieties and classes of plant products formerly imported,
we can now freely import but seven, of which five are bulbs, and these
can only be imported under permit. Of the estimated 950,000 Azalea
indica formerly annually imported from Belgium, only an occasional
plant is now to be seen at our national flower shows. Where are our
Bay trees, our Araucarias? Where are our new orchids and hundreds
of other exotics to come from? And yet the Board’s chairman says that
Qu. 37 is not an embargo and points to the stock being allowed entry
under special permits—which is equivalent to limiting the waters of the
Potomac to what will come through a 12in. pipe and pointing to.the
great volume of water that comes through the pipe. These conditions
result in serious injury to American trade, the elimination of the ability
of that trade to supply garden and flower lovers and American citizens
in general with the plants they want at prices they can afford to pay,

5
and this means practically the suffocation of horticultural development

and progress.

And we are told that these restrictions and embargoes are necessary
to protect the country from insect pests and plant diseases. — The same
argument could be used by medical enthusiasts to stop immigration to
our shores to protect the country from human ills and diseases, but
people would sicken and die just the same. Or the police department
might shut out all immigration for fear that a criminal might occasion-
ally come, but we would have crime just the same. Recently there was
found on our Eastern coasts a species of pileworm that on ‘Western
coasts has caused millions of dollars’ worth of damage by attacking piles
and other underwater structures; it came presumably with the barnacles
on ships and, following the Board’s reasoning, it would be necessary to
exclude all ships for fear they might bring the pile pest. We contend
that exclusion of inspected plant materials does not exclude pests, and
does not reduce the annual damage done by pests to our crops and for-
ests. If the Board follows its present policy of excluding plant ma-
terials to its logical conclusion and excludes all merchandise and, indeed,
all ships because of the suspicion that they might bring pests, it would
not, in our opinion, reduce the sum total of damage by pests by any de-
gree visible. The gypsy moth was introduced into this country by a
naturalist or entomologist at Harvard University, but the exclusion of
all naturalists and entomologists in future from this country would not
reduce the annual damage done by the gypsy moth. You cannot change
the course of Nature by restrictions on business or exclusion of merchan-
dise. Your purpose is laudable and right, but your method is dead
wrong—the remedy is infinitely worse than the disease.

We are told that many of the pests that now plague us came in on
shipments of plant products, but we contend that was before we had our
present system of Federal and State inspection and before the exporting
nations had theirs. We admit there are pests on all plant products,
on home grown as well as on foreign grown, on our incoming shipments
of greenhouse products as well as on our outgoing shipments of wheat
and other cereals, but so long as these pests are not new or dangerous
we should expect only the same degree of reasonable freedom from other
nation’s products as they expect of ours. Of florists’ imports, fully 98
per cent come from inspected establishments and 95 per cent go direct into
greenhouses, so the risk of importing new or dangerous pests with such
shipments is practically nil.

Some Unwarranted Discriminations

But if the Board considers such drastic remedies necessary, why not
apply them to similar products not used by florists? Why discriminate
against florists? Why exclude nearly all varieties of flowering bulbs
without also excluding onions and all other bulbs not used by florists?
Qu. 37 places no restrictions whatsoever on the importation of field, vege-
table, or flower seeds, so why regulate and restrict the importation of
palm seeds used by florists without also regulating the importation of
all other seeds, representing 98 per cent of total seed imports? Why ex-
clude a few valuable orchid plants when the same ship brings in 40,000
bunches of bananas collected in the same forest? And why exclude
even on special permits, living plants which require a little soil to protect
the roots while allowing shiploads of soil or earth, arrivin hip’
ballast, to be dumped on our shores? : ener

The florist trade is heartily in accord with this
out the purpose for which it was created, but when t

6

Board in carrying
he Board gets into
economic or tariff fields no two florists think alike, for no two are affected
alike, and some florists, and nurserymen too, undoubtedly are benefited
by the exclusion of plant products which compete with what they pro-
duce. As in all trades, there are selfish men in ours; a florist who
grows only one variety of Narcissus is benefited by the exclusion of all
other varieties of Narcissus and, indeed, of all other bulbs, while a florist
who grows only Geraniums or bedding plants is benefited by the exclu-
sion of all plant products—but does such exclusion benefit the United
States or even the majority of florists? Naturally, a handler of, say, terra
cotta, is benefited by the exclusion of brick and lumber, but would such
exclusion benefit the United States or the building industry? Every
bit of comment that is favorable to Qu. 37 we have heard or read from
trade members treats only of the economic protection it gives them
from competition; not one commends it for the protection it was designed
to give from pests. This seems conclusive to us that Qu. 37 is considered
an economic measure; we contend that economic protection is not in-
cluded in the functions of this Board, that it is purely a tariff proposi-
tion.

Hundreds of varieties excluded by Qu. 37 are not being commercially
produced in this country, while the cost of production of other hundreds
will prevent their quantity sale when produced. Home production should
be encouraged and protected in every legitimate way, but by the tariff, not
by this Board. The tariff bill now before the Senate provides duties
more than double those now in effect, which will give home production
all the protection it needs, especially when it is considered that prices
in Europe are approximately three times what they were prior to Qu-
37, and it will be many years before an adequate supply of necessities is
again available. Summarizing our deductions, we submit to the Depart-
ment of Agriculture these

Recommendations

1. We recommend that Qu. 37 be withdrawn; it is indefen-
sible even as an economic measure. This will end the iniquitous
system of “special permits,” which is unfair, un-American and dis-
criminatory, since the Board not only decides which variety may
be imported and in what quantity, but by which firms or indi-
viduals. We submit that no firm should be permitted to import
the same stock that another firm is not permitted to import—
we need not comment on the abuses that can grow up under such
a system. If there are any varieties of plants in Qu. 37 which
carry a real risk of introducing a “dangerous pest new to or not
widely prevalent” in this country, the danger can be met ef-
fectively by specific quarantines, as the law intended.

2. We further recommend the establishment at entry ports,
especially at New York, to begin with, of an inspection station
where all imports of plants and plant products (excluding bulbs
and seeds) will get adequate inspection. The cost of this station
and its maintenance will represent but a small fraction of what
Qu. 37 costs the country in loss of customs duties on excluded
products each season.

3. We recommend that the Board make accessible, to persons
legitimately interested, information with regard to the special
permits that have been issued since Qu. 37 was promulgated,
stating the class or variety of plant products, the quantity, the
name of the importer and the country of origin. Secrecy in such
matters invites charges of discrimination and favoritism in the
issuance of special permits.

‘
4. Should the Board contemplate quarantining additional
items after withdrawing Qu. 37, it is urged that the notice of
hearing state precisely (not vaguely) which variety or varie-
ties it is proposed to quarantine, and from which country or
locality, so that the trade may have a chance to present its view
in accordance with the intent of the law.

‘There is no doubt that with a little good will and cooperation on the
part of the Board these recommendations can be made the basis for
regulations covering the importation of plant products that will give
adequate protection against the introduction of new or dangerous plant
pests, without prohibiting the importation of necessary plant materials,
This country cannot give a guarantee of absolute freedom of pests for
our outgoing shipments and we should not demand it on our incoming
shipments.

The florists want a tariff high enough to discourage importation of
all but the new and expensive varieties of Gladioli, Freesias, Ficus,
Hydrangeas, Dwarf Roses, and all other classes of plant products that
can be commercially produced in this country, but we cannot ask this
Board to cooperate with us on tariff matters even though this committee
is also the Tariff Committee, so our recommendations on economic pro-
tection have gone to Congress, as we feel that it is not the function of
this Board to decide such matters.

In this statement we refer only to greenhouse products or plant
materials used by florists, carefully refraining from referring to “Nur-
sery Stock” (as the term is understood in trade circles), as we leave
recommendations on that subject entirely to the nurserymen.

Respectfully submitted.

James McHurcuison, Chairman,
J. D. EIsEte,

F. R. Pierson,

A. L. Minter,

Lronarp Vacenan,

Henry F. Micyet,

Wo. F. Gupe.

 

The Case of Quarantine 37

About two weeks before the Washington Conference, ther ; i i
THE FLORISTS EXCHANGE probably the most complete, orderi> ane fee
discussion of the quarantine situation in its larger aspects that had appeared u
to that time. In its opening paragraphs the statement asked several eitinent
questions such as, What is this, conference actually called for? What i it
pected to accomplish? Upon what basis and with what hope of os an
will the S. A. FP. and other interested organizations participate? And a
who will actually preside? Tee eee anes

For these questions, THE EXcHANGE had no answer 7 4 i
“serious as we believe the present predicament of sentria RoEneoe . ge
we have little faith or hope of any definite, constructive results fr he Maw de
conference—uwnless Secretary Wallace or some mediator full ed an ae
appointed by him and not connected with any bureau or b
ment of Agriculture is to preside. Here, then, is our first a
mendation.” , E

Thereupon the statement continued, verbatim,

8

as follows:
HY do we regard the situation as serious?

Because we believe that an administrative body in the United States
Government, duly created by law to serve a definite, necessary, laudable
purpose, and to protect the horticultural and agricultural interests of
the country has unwisely and unwarrantably assumed powers that it was
never intended to wield; and through its arbitrary extension and exer-
cise of those powers has taken to itself prerogatives to which, accord-
ing to our interpretation of the law, it is not legally entitled.

As we grant the wisdom of protecting this country from new, injuri-
ous plant pests, recognize the value of thorough inspection and certifica-
tion of importations of plants, and all other articles upon or in connec-
tion with which such pests might enter, and recognize also the necessity
of quarantining specific localities or countries and particular types or
classes of plants, temporarily or permanently, according to the nature
and severity of any epidemic or other emergency—so we concede that the
F. H. B. has attempted sincerely, honestly and industriously to accom-
plish the desired results. Its integrity and good intentions, and the
ability of its individual members in their respective lines, we do not
question.

BUT .

1. We submit: That in its attempt to prevent the possible introduc-
tion of plant pests it has effected the prohibition of many important
kinds of plants needed for the normal, desirable progress and develop-
ment of American horticulture, to the extent that it has seriously in-
terfered with legitimate trade activities and denied the natural right of
American citizens to buy goods where they will, and bring them into this
country under moderate restrictions, so long as such goods cannot be
shown to be inimical to the welfare of the country.

We assert that the mere possibility that any plant might harbor
a dangerous insect or plant disease is not sufficient reason to bar out the
great bulk of foreign plants, nor justification for the avowed purpose
of the F. H. B. to “as rapidly as possible make this country independent
of foreign supplies, with the object of ultimately reaching a condition
where entry of foreign plants will be limited to new plants, and such
plants as are not capable of production in the United States.”

The Board says, truly, that no plant is actually prohibited by the
quarantine regulations—and in evidence of the leniency of its rulings
points to records of several million bulbs, plants, Rose bushes, etc., listed
under “excluded stock” and yet admitted under special permit. But it
says nothing as to the number of permits refused, or the grounds for the
refusals; it does not state that the number of plants brought in is smaller
than that for which permits have been issued because,a#n.some cases, the
permits have been forthcoming only after it was too late to have the
commodities shipped, or because in other cases, even the foreign supplies
of the desired articles are insufficient; nor does it explain why, although
six classes of bulbs are freely admitted (without soil, etc.) more than 50
other kinds—not a whit more dangerous or likely to be infested—may be
imported only by permit obtainable upon presentation of proof suffi-
cient to convince the F. H. B. that those particular shipments are es-
sential to the maintenance of adequate supplies of such stock in this
country; it does not explain why a budded Rose bush Gin. high is any
more dangerous than a Rose or Apple stock 2ft. high—but it admits
the one and excludes the other—at least it has not thus far made any
explanation for these inconsistencies that is, in our opinion, horticul-
turally or entomologically acceptable.

9
Knowledge of Nation’s Plant Needs Is Incomplete

2° We submit: That in assuming to determine what kinds of plants
and how many of them are needed for horticultural development, the
F. H. B. is exceeding both its authority and the limits of its knowledge—
or that of any individual or group of individuals. The Board has recently
distributed to the trade ponderous questionnaires calling for detailed
figures as to the available stocks of some thousands of varieties of Roses,
Iris and Peonies for the seasons of 1922-1926, inclusive, and of Orchids
and Gladioli for the current year! Is this not a tacit admission that it
has heretofore been without definite information as to how many of these
relatively common plants are in this country and how many may be said
to be needed? And yet for more than two years it has been rendering
decisions upon just this point. Would not the logical procedure have
been to have secured complete information on every possible subject before
discriminating between species and varieties of plants on a basis of hor-
ticultural needs?

3. We submit: That whereas the original purpose of the plant quar-
antine law was to provide for inspection so that, presumably, plants in-
spected and found clean would be permitted to enter freely (infected
specimens or shipments being subject to return, destruction or treat-
ment as might be deemed necessary), and that whereas the F. H. B. was
created to supervise and administer this service, it now admits that it
has failed in its attempt to do so and advocates wholesale exclusion as the
last hope. Why is this failure not an indication either of inefficiency on the
part of the employees of the Board or, perhaps, of the failure of the
Government to provide sufficient funds, rather than a proof that all
plants are too dangerous to be admitted and that ultimate total exclusion,
so far as this is possible, is the only safeguard?

Granting, for the sake of argument, that the importation of every
living plant and bulb should, and could, be stopped -for, say, ten years,
what assurance can the F. H. B. give that even that would provide ab-
solute immunity against the introduction of “any tree, plant, or fruit dis-
ease or of any injurious insect, new to or not, theretofore widely prevalent
or distributed within and throughout the United States?” Would our
growers and orchardists find it any less necessary to spray? Would there
not remain the danger of introducing the same exotic pests by means of
soil ballast, packing materials, raw fruits. grains and other commodities
making up our commercial importations and, for that matter, through
human beings themselves, the ships on which they travel, and every fac-
tor in the intercourse between nations? AJl of these things, by the way.
the Board has, by law, the power to intercept, quarantine and exclude—
but heretofore it has not seen fit to subject them to anything like the
requirements enforced against plant products.

European Countries Not Closed to American Plants

4, We submit: That in maintaining that inspection i i
systems are ineffective, the F. H. B. Se a position Tat pead ie
phytopathological and other authorities of European countries which.
lying closer together and having been occupied and cultivated for a much
longer time are, presumably, in greater danger of infestation by new
pests. To support its claims for “liberality of entry” as regards plants
the F. H. B. has stated, without qualification, that “Holland, France Ger.
many, Austria and Switzerland prohibit the entry of all ‘living plants

from America and other countries—Belgium, It i
Russia—are closed in lesser degree.” ee eee ee

10
As to this, let us quote from communications received from dif-
ferent officials in some of those countries, as follows:

“Mr. Marlatt says Qu. 37 is justified, European countries having long ago
prohibited American plant products by restrictions. This is not true. All plants
may be freely imported in Europe; but they must be accompanied by a Phyl-
loxera attest, certifying that no vines were grown in the nursery where the
oe came from.”—President of the Chambre Syndicale des Horticulteurs

elges.

Switzerland: “As the United States did not adhere to the International
Phylloxera convention, a preliminary authorization is necessary. This is deliv-
ered by our division on receipt of an application indicating the nature, the
quantity, from where the plants come and the name of the consignee and also
the customs bureau through which entry will be made. The shipment must be
accompanied by a declaration from a competent authority attesting that no vine
is found in the soil in which the plants were grown nor near them, and that the
shipment contains no vine or stalk thereof.”

Holland: “Importation of all woody plants from the United States is pro-
hibited by the San José Seale Act established in 1898 when that insect was
spreading rapidly in the United States and when Holland did not possess a phyto-
pathological service to protect its horticulture. : .

“But circumstances now are quite different. The scale does not threaten to
the same degree, and the service is able to give such protection as is necessary.
Therefore we intend to change the San José Scale Act in order that woody plants
from America may be imported under conditions of inspection and certification.”

British Isles: “All living plants with persistent woody stem, and parts
thereof * * * come under regulations, but will be admitted if certified by com-
petent officials of the phytopathological service of the exporting country as
healthy and free from certain scheduled pests [8 diseases and 17 insects listed]
* * * The right is retained to authorize the landing of plants contrary to the
above provisions.”

Germany: ‘There are no special importation laws against the United States.
The law applies against all countries in which the Colorado beetle, the Phyl-;
loxera and the San José Seale exist. The importation of Potatoes and all varie-
ties of vine is prohibited. Dicotyledonous woody plants and parts thereof, with
the exception of fruits, are also excluded. Gymnosperms and monocotyledonous
woody plants, also all other species, plants and parts thereof are subject to
examination by agents before importation as to the presence of phylloxera and
San José Seale. They are permitted entry after certification of absence of said
pests. All fresh fruits, plants of which can be cultivated in German fields, and
so-called southern plants, also rootless underground parts of plants, such as
onions, bulbs, ete., are subject to treatment the same as gymnosperms, ete.,
above.” ‘

Are these few statements not sufficient to flatly contradict the asser-
tion of the F. H. B.—and, naturally, to raise the question of the accuracy
of other of its generalities? Here again the Board may be within the
letter of the truth to the extent that there may be laws on the European
statute books designed to keep out American plants passed when this was
a necessary precaution. But who will deny the inertia of law-making
bodies when it comes to the rescinding of laws after their need has passed,
and after their enforcement has been discontinued as unnecessary?

In brief, then, most European countries admit plants from this coun-
try upon presentation of a certificate of freedom from certain pests is-
sued by our own F. H. B. Are we so superior that we cannot bring our-
selves to reciprocate; or are we so helpless and susceptible that we are

afraid to?
F. H. B. Is Attempting to Control Business, Not Pests

5. We submit: That in specifying what plants are needed by the trade
and horticultural interests, and in what amounts they may be imported,
and by what individuals and firms—irrespective of the likelihood of those

11
i ; ing i d (which obviously cannot be determined
particular plants being infested ( he non ot entry oe a

til they are presented for inspection el 1 try 01
ete rH. B. is exercising a control of business, not of injurious

organisms; and that such control is outside its legitimate jurisdiction.

If it be essential to the existence of any branch of the horticultural
re a America that foreign competition in certain plants be checked
then this is a matter to be remedied by tariff means through Con-
gressional action, not by an administrative body under a camouflage—in-
tentional or otherwise—of protection against pests. That Qu. 37 has
been and is being interpreted and is acting, in just such an economic, pro-
tective way is made clear by the introductory paragraphs on a ballot sent
out by the American Association of Nurserymen to ascertain the opinion
of its members as to whether the quarantine should be lifted or continued.
The statement says in part: “It may be recalled that before Qu. 37 went
into effect, foreign growers from France, Germany, Holland and other
countries, each Spring sent over enormous quantities of ornamental
products, trees, Roses, etc., which were sold through department stores
at auction, usually at prices that were far below cost of production of
similar American grown products. On the other hand, there are many
nurserymen who import these foreign grown products, and whose busi-
ness has been injured by the elimination of these foreign grown products.

“Tt is for the membership to'decide whether or not the majority fa-
yor the lifting of Qu. 37 and wish to let this foreign grown stock
again come in this country, or whether it would be better to let the quar-
antine stand and keep foreign ornamental stock out, and supply the
American market with American grown Roses, ornamentals, etc., as well
as keep new European diseases and insects out of our country.” '

Without reference to the general tone of those paragraphs and
whether or not they reflect the actual facts as to foreign vs. home grown
stocks, to what a minor extent do they involve the question of plant pests!

To illustrate the European trade attitude, there may be recalled a
letter from the president of a large French horticultural organization
to the French Ministry of Foreign Affairs in which it was urged that the
United States Government be advised that the European countries are
not “willing to be placed in a position of economic inferiority” by such
means and methods as the F. H. B. is employing.

Far Reaching Effects of Closed Door Policy

6. We submit: That in view of the serious damage to the horticul-
tural industries of foreign countries already effected by Qu. 37, and the
still greater injury that may be expected to result if its administration
is continued along the present, or even more stringent lines, there is a
distinct probability of the development of a retaliatory attitude, first on
the part of foreign trade interests and ultimately, perhaps, on the part
of their governments. Such an attitude would, doubtless, result in the
closing of many important markets for our grains, fruits and other agri-
cultural products. Whether this exclusion were effected by quarantine
regulations—based on arguments provided by the F. H. B. itself—or
whether it took the form of tariff or other economic measures, is imma-
terial. The important fact is that such a discord and spirit of retaliation
in international trade relationships—unfortunate at any time—would
be deplorable at the present stage of world chaos and insecurity.

The F. H. B. has frequently disavowed any intention of influencing,
controlling or hampering trade; it protests that it is working for the
good of horticulture. Again, let us accept its statement freely and em-

12
phasize the fact that therein our aims and interests are identical. But is -
it not possible that, notwithstanding all its foresight, sincerity, and com-
mendable desire to effect much needed improvement over early conditions
in respect to plant importation, it has brought about results that it did
not foresee and set in motion forces of which it had no conception?

The energetic boy in the cartoon who, watching a mosquito alight
on his sleeping father’s nose, picks up a hammer and smites with all his
strength, is impelled, no doubt, by the laudable desire to do a good, sure
job. Certainly, he destroys the insect. But can we approve such heroic
measures as a general thing?

A tourniquet may prove a life saver if applied promptly to a bleed-
ing artery—but why let it result in the loss of a finger, arm or leg, sim-
ply because it was drawn too tightly or left on too long?

A Federal Horticultural Board which, as Secretary Wallace has
pointed out, might better be called a “Plant Quarantine Board,” since
its object is the prevention of the introduction of pests of all kinds of
plants—agricultural as well as horticultural—is a necessity in these days
when the isolation of any one country is both impossible and undesirable;
it can do a great and valuable work; in its work it should make pro-
vision for the cooperation and assistance of practical growers; and it
can and should similarly extend the hand of cooperation to them; it
should exercise the right of inspection and certification of plant impor-
tations at all main ports of entry; it should impose specific quarantines
when and for as long as a particular and obvious danger exists; it should
work in close harmony with corresponding boards of recognized standing
in other countries, with a view to effecting reciprocal arrangements as to
inspection, certification, etc. Finally, it should be provided with adequate
funds, so that it may afford to the agriculture and horticulture of its
country reasonable protection, without suffocating them with regulations
and restrictions or destroying the initiative of either educational, indi-

-vidual or commercial interests.

Here is the platform of Tur Frorists Excuance. We submit it to
the American people and to Secretary Henry C. Wallace and appeal to
him—not to the F. H. B.—for full and just consideration. m

'

Plant Quarantines in Great Britain and America

The formal and comprehensive presentations made at the May 15 confer-
ence were those of the S. A. F. Tariff and Legislation Committee, by Mr. McHut-
chison; the Committee on Horticultural Quarantine (in ‘behalf of amateur and
scientific interests) by Mr. J. Horace McFarland; Belgium, by Mr. Charles
Pynaert, president of the Chambre Syndicate des Horticulteurs Belge; Holland,
by Messrs. E. van Slogteren and van Poeteren; and Great Britain, by Mr. William
G. Lobjoit, Controller of Horticulture of the Ministry of Agriculture.

The larger part of the latter’s address follows, only that part having been
omitted that merely reviews the history of plant quarantine legislation in this
country as it was observed and interpreted in England. The fact that Mr. Lob-
joit’s office and responsibilities correspond almost exactly with those of Dr. Mar-
latt, chairman of the F. H. B., and that he is giving England adequate protection
without imposing any of the excessive and destructive restrictions that have
been put in force in this country, renders his careful, restrained but highly
significant statement all the more interesting and important. In a general way
it also reflects the attitude of the other European countries, especially insofar
as they are of one mind regarding the desirability of increased international
trade in all directions in horticultural products—always with thorough, well
organized mutual protection through systems of inspection and certification of
all shipments of plants.

13
E rymen to comply with the American quarantine regula-
Da es Tie request of ite needed authorities—the English nur-
series were inspected throughout the Summer and after Oct. 1 and health
certificates, in the form prescribed by the American regulations, issued
to the effect that plants therefrom were found, or believed by the inspector
to be free from injurious plant diseases and dangerous insect pests.

What English Health Certificates Mean

A little reflection will be sufficient to show that many minor pests
ure bound to be present on plants in nurseries, and if all these were
taken into consideration no certificates could ever be issued. Prior to
1921 in most instances the American authorities did not require or ask
for an inspection of the plants at the time of packing, except in the case
of stock shipped during the growing season, a point of some importance.
The English health certificate has in the past been given to show that the
nurseries in which the plants were grown were free from injurious plant
diseases and dangerous insect pests (i. e., all British pests of any im-
portance, and also all those scheduled under the Destructive Insects and
Pests Order of 1910, e.g., Gypsy and Brown Tail Moths). It did not imply
that the plants had been inspected and found to be free from all insect
and fungus pests.

It never has been clear to English pathological experts why the
Americans did not insist on inspection also at the time of packing prior
to 1921, and of the issue of a certificate of another character; possibly
they may have deemed it unnecessary seeing that the plants were to pass
a critical test at the quarantine station in America. Letters from the
Department at Washington would indicate that in 1918 they had lost
faith in the value of the health certificates because of the number of in-
tercepted pests (in the case of England amounting to 62 pests in 154
infested shipments.) Fortunately the American system is excellent in
publishing quarterly letters, setting out details of these intercepted pests,
and it is thus possible to visualize exactly the kind of pest in question.

It would appear, then, that while the Federal Horticultural Board
haye under Quarantine 37 been asking for nursery inspection and a
health certificate of a certain kind, they have been expecting to receive
plants entirely free from all insects and fungi—a quite different matter.
The mere fact that many insects and fungi mentioned in the foregoing
lists have been intercepted is no indication that the health certificate
system has broken down—except in one or two isolated cases—or that
the system is of no value. It does indicate, however, that the terms of
the health certificate are a matter for consideration between the issuing
countries and the Federal Horticultural Board.

An examination of this list shows that three distinct classes of
pest have been intercepted. The first-class, and by far the largest, com-
prises pests cosmopolitan in distribution and abundant in the U. s. A—
in most cases more abundant there than in Britain. The second class
comprises a very few species resident in Britain, but not known to occur
in the U. 8. A., or at most only occurring in restricted areas. The third
comprises species which are distributed by shipping and have no direct
connection with the trade in live plants. Their presence in plant con-
signments must be regarded as purely accidental, as equally likely to oc-
cur on all merchandise and so without bearing on the present discussion.

Intercepted English Pests Mostly Unimportant

Of these three classes,

obviously th imp i
species resident in Britain y vac most important is Class 2—

and non-existent or very restricted in the
14
U. S. A. When, however, the list is examined, it will be found that
three, comprising one beneficial species (Philonthus politus), and one
pest (Hepialus lupulinus) must have come in with the soil. Another
(Apion ulicis) is neutral and feeds only on a weed. Another (Apetela
auricoma) is certainly an error, as the insect is on the verge of extinc-
tion in Britain. Still another (Z¥mphytus cinctus) is a Rose feeder of no
importance and in any case easily amenable to control, while moreover, its
presence in future shipments can easily be avoided.

So far as the introduction of new and dangerous pests into the U. S.
A. is concerned, the interceptions must be regarded as something of a
triumph for the British Service.

In a letter dated March 4, 1919, Mr. Houston [then Secretary of
Argiculture] admitted that, as regards Europe, England stands in a some-
what exceptional position and would be regarded as less dangerous to the
United States than other countries, were it not that England is such a
very large distributor of plants grown abroad. The development of the
British Pathological Service would render it quite feasible to guard
against the re-export of alien plants from England and there are, there-
fore, clear grounds for discrimination by the United States in favor of
English home-grown produce.

The English Pathological Service Today

Whatever grounds for suspicion the Federal Horticultural Board
may have had in connection with plants from England, the risks have
very much decreased owing to the improvement which has been made in
the pathological service of England during recent years.

The various elements of this service work together in complete co-
operation. They have recently carried out a Plant Disease Survey of the
entire country, and are continually engaged in cooperative measures for
reducing the damage done by plant pests. Under the general direction
of the Ministry, there is in existence a staff consisting of about 40 trained
entomologists and mycologists engaged in fighting plant pests and in-
sects, while there are also 37 inspectors, specially trained in their subject
whose business it is to enforce the various legal measures now found
necessary for preventing the spread of pests within the country. It
can, therefore, fairly be claimed, not only that the English Phytopatho-
logical Service is in a satisfactory condition, but also that, both in its
organization and in its personnel, it is in advance of that of most other
countries in the world.

There should, therefore, be no grounds whatever for complaint on
the part of the U. S. A., to the end that regulations, though scientifically
safe, cannot be carried out owing to the lack of sufficient scientific and
trained staff.

English Plant Import Regulations

Under the Destructive Insects and Pests Order of 1921 the free entry
of plants into England and Wales is allowed provided they are accom-
panied by a health certificate, issued after official inspection in the coun-
try of origin, to the effect that the plants are free from certain scheduled
serious diseases, and healthy as regards pests in general. Provided the
inspection is properly performed by experts in the exporting country, and
the certificates conscientiously given, there is little fear of danger from
the health of the plants, but the risks can be still further reduced if a
second inspection takes place at the ports of the receiving country, and
this double system of inspection is now in operation. The order has not
been in operation sufficiently long to enable a precise estimate to be made
of the risks involved, but it is clear from the season’s working that the

15
been effective in raising the standard of health of

the imported plants without seriously interfering with normal trade.

This method of safeguarding the plant industry has been adopted by

most European countries without involving undue interference with trade

conditions. . :

It can be fairly said that the proper perspective of the pathological
problem as compared with the cultural problem has been accepted by
Britain, and proper provision made to secure that the health of the
plants raised, not only for planting in the country, but for export to
other countries, may be regarded as reasonably safe. Realizing all that
is being done in England to control diseases and to raise clean nursery
stocks, and the measures taken to prevent, the export of anything but
the best, and the fact that the Department of America have admitted
that the States have little fear of English pests, it would appear that
the risk involved in admitting a number of categories of British plants
is extremely small if not non-existent.

In 1918 the U. 8. A. Department admitted this, but stated that Eng.
land had taken no steps to keep out pests from plants imported from
other countries and that such plants on reshipment to America might be
a serious factor, and so England must be grouped in with others. Such
trade may or may not have been in operation prior to 1918, but the po-
sition is entirely altered now, since by the passing of the D. I. P. Order
in 1921 effective measures have been adopted by Britain for keeping out
all plants other than those certified to be healthy, and inspection of im-
ported plants by the English service would indicate that the measures
are effective. Moreover, plants could not be shipped from England to
the U. S. A. in the absence of a health certificate, and it is not the inten-
tion of the English Pathological Service to issue certificates for any
plants other than those which have been actually grown in the country.

On these grounds the Federal Horticultural Board can rest assured
the English Service is very alive to the seriousness of the introduction
of pests from abroad and is safeguarding the home industry quite as en-
ergetically as America though under a different policy. If there was
an attempt in the near future to establish such a trade the States would
be helped by England either in stopping it or in seeing that it was only
carried on under conditions involving no risk. The law of self-interest
surely would be the driving force in this instance. Fears, then, as to
evil consequences on the transshipment from England of plants grown
in other countries need not for one moment be entertained.

safeguards taken have

Mutual Risks from Imported Pests

It is evident that any country which has a considerable plant in-
dustry cannot continue to receive imports of plants from other countries
without due consideration of the risks involved through the possible in-
troduction of insect pests and plant diseases which, if able to establish
themselves may cause great disaster to the plant industry.

In recent years the importance of the pathological side of plant in-
dustry has become increasingly evident, and most countries have in fact
considered this matter, and have been forced by dire experience to con-
sider and to devise measures for dealing with it. The whole problem
has been threshed out both by America and by England, and to some
extent it has been reduced in each country to definite issues In this
connection it may be well to set out the various pests in England which
the Americans may view with alarm, and also the particular American
pests with which the English pathologists are concerned having regard
to the particular categories of plants imported by each See .

16
What the United States Fears in England

The flowering plants which England can send into America are gen-
erally free from dangerous or serious pests, and as it is only the roots
from which the soil has been removed which are transmitted, the danger
is therefore reduced to almost a negligible quantity. The bulbs probably
fall into a different group of their own; but it is quite true that in
England there are three bulb pests of importance, namely, the Narcissus
fly, the small Narcissus fly, and the eel worm. It is quite probable that
American entomologists have been viewing with alarm the possible in-
troduction of these pests into the United States. The pests, however, are
by no means confined to Europe, but are present also in America, so that
their possible introduction cannot weigh as heavily as the introduction
of a pest at present non-resident in America. The other class of plants
which is exported to America in fairly large quantities is Manetti
stocks, and in the state in which they are exported, the stocks are appar-
ently only subject to two pests, namely, a sawfly (Emphytus cinctus) of
which the larve burrow into any dead wood to pupate, and crown gall,
which produces growths on the roots. These diseases cause no real dam-
age in this country. Both diseases are easily recognizable, and arrange-
ments have been made whereby reliable health certificates can be issued.

American pathologists must give the fullest consideration to such a
serious disease as the silver leaf of Plum (Stereum purpureum). This
is a really deadly disease which not only reduces the crop, but ultimately
kills the trees. It is a serious pest of a nature sufficiently deadly, in
the absence of control measures, completely to destroy the whole Plum
growing industry. The fungus is known, however, to exist in Canada
from Nova Scotia to Vancouver, while Hester and Whetzel in their “Man-
ual of Fruit Diseases” state that it is known in the United States on
Apples. The Ministry of Agriculture of England would support any rea-
sonable measures taken by the Federal Horticultural Board to prevent
the further spread of this disease.

It is true that in the southern part of Britain Rhododendrons are
attacked by the Rhododendron bug (Leptobrysa [Stephanitis] rhododen-
dri, Horv.) But this would appear to be an American pest which was
‘introduced from that country into Europe. The position with regard to
orchids perhaps is somewhat different. These are hothouse plants and
subject to attack by the insects commonly found existing under such con-
ditions. These insects are quite common the whole world over, and there
would appear to be no single special pest of orchids in this country which
is not already resident in the glasshouses of the States; so that the risk
involved by orchid introduction has been exaggerated.

It is clear, from the letter of Mr. Houston that the American Gov-
ernment attaches great importance to the further possible introduction of
plants carrying the brown tail and the gypsy moth. The risk of introduction
on British grown plants is negligible for the gypsy moth has become ex-
tinct, and repeated attempts at reintroduction by misguided entomolo-
gists have been completely unsuccessful. The brown tail moth maintains
a precarious existence on the southern and southeastern coasts of England
where it feeds chiefly upon Sea Buckthorn. It seldom, if ever, penetrates
more than a mile from the coast, and the Ministry has no record of its
discovery in any nursery.

What England Fears from America

When the insect pests and plant diseases of America are considered
by English pathologists in relation to the class of produce which America
sends Britain, the position is a particularly gloomy one, and it can con-

17
fidently be claimed that ag feed at least as much to fear from

rica as America has from England. .

a eae eee the most deadly disease of the ie seg
throughout the world—attacks also Apples, while its rapid sip in
New Zealand on Hawthorn hedges, the chief hedge plant of Britain, shows
how difficult or even impossible it would be to control it in England were
: aa pests are so many it is difficult to make a selection,
but as an instance the Apple maggot is most difficult to control and
would be a most undesirable addition to English pests. As a typical
fungus Apple blotch (Phyllosticta solitaria) attacks both the fruit and
twigs and might well come over in the former. It might prove a very
serious pest in Britain. The San Jose scale has been found on Apples
landed from America. Four cases of Colorado beetle are known to have
occurred. :

Onion seed is known to carry Onion smut, and there is every reason
to suppose that the isolated outbreaks of this destructive disease in
Britain have been due to American seed. The Clover seed chalcid ( Brucho-
phagus funebris) is unknown in Britain and its introduction might
prove a serious menace to the English seed industry. ;

This list might be continued ad nauseam, but the above will be suf:
ficient to show why English farmers and fruit growers fear American
produce and that their fear is fully justified on scientific grounds. It
may even be admitted that English scientists are not satisfied that the
present safeguards against the introduction of these pests in force in
England are sufficiently stringent. It is impossible to predict as to
whether the combined influence of the farming, fruit-growing, and scien-
tific interests will force the Government to adopt a more restrictive policy
in regard to foreign pests.

International Trade Benefits Outweigh Dangers

At present the view is that the pathological problem is not peculiar
to the United States, but is common to all civilized countries, and is in
fact one of the products of civilization. With the progress of cvilization
international trade was established, and has now become an essential fea-
ture of the industry of the world. In the course of this international
trade plants have been moved about the world from one country to an-
other, and though damage has been caused in some instances in the pro-
cess the balance of evidence is heavily in favor of the beneficial effects.
It is certain that both Britain and America have gained much through im-
ported plants. Surely it cannot be viewing matters in the right perspec-
tive to suggest that the whole course of trade which has been brought
into operation in a natural way should be entirely stopped by imposing
unnatural barriers. By such means progress would be delayed and in-
dustries suffer. :

The continuance of trade between Britain and America and America
and Britain should be the primary object to be kept in view, for each
country is able, by virtue of the different climates, to specialize in differ-
ent classes of produce. It would appear a far wiser policy to take a
broad view of the whole matter, and one not narrowed down merely toa
consideration of pathological problems; and to devise suitable ways and
means for protecting against pests without imposing regulations which
would tend to stop legitimate international trade. If the health certificate
policy has not been as effective as was expected it may be that while the
policy is right the system in operation can be improved upon: if so, it
should be possible for the Federal Horticultural Board to point out ex-
actly the kind of health certificates which are required with imported

18
plants, and the inspection conditions to be observed. If this be done an
assurance could be given on behalf of England that the inspections would
be strictly carried out and the certificates granted in a careful and con-
scientious manner. Furthermore, if the Federal Horticultural Board is
not able to accept the statements as to the improvement of the British
Pathological Service in recent years, England would welcome a delega-
tion from America to investigate the Service first-hand and to work out
a system for the certification of plants.

Complete Pathological Safety Unattainable

While it is true that the most important factor in carrying pests
from one country to another is the trade in living plants, yet this trade
is by no means the only factor. Many kinds of insects and also fungus
spores are able to persist for periods, long or short as the case may be,
away from their host plants and they are thus able to take advantage of
any means of transport which may exist. Plant quarantine, therefore, is
a means of reducing risks, not of eliminating them.

Since it is manifestly impossible to eliminate all risks, the problem
resolves itself into one of weighing the risk of the introduction of foreign
pests against the loss in trade due to quarantine measures of various de-
grees of stringency. :

Pathologists and entomologists in England have for the last ten years
looked with growing fear at the risks involved by the importation of
American produce. They would prefer an absolute prohibition of the
import of all American plants and temperate fruit. They have, how-

- ever, been deterred by the certainty that such a prohibition, which, it
is logical to suppose would become operative on both sides of the ocean,
would involve a serious reduction in trade, and that the premium the
country would have to pay for additional security would be too great.

General Prohibition Sought, but Undesirable

Now, however, that America has declared herself to be aiming at the
prohibition of all plant imports (in ordinary trade at all events) the
above argument loses its force, and pathologists are again asking them-
selves why England should continue to run risks without receiving any
compensation by way of trade.

This argument, at all events as regards fruit, is a disappering one,
but in any case it is countered by a totally different consideration, viz.,
there are other countries from which can be obtained the categories of
plants now imported from the U. 8. A., and these countries have no pro-
hibition on English exports. It is clearly preferable then, since risks
must anyhow be taken, to deal with a country open to English trade
rather than with one which will not risk English produce.

British Attitude Not One of Reprisal.

There is no question of reprisals in this argument. A reprisal is
the carrying out of something, in itself purposeless and undesirable, in
order to compel another party to make a concession. Here we ask no con-
cession and our action will stand on its own merits as desirable. We
merely assert our rights to deal with our risks in the manner most advan-
tageous to our country. It is, in fact, purely a business transaction in
pathology.

Additional copies of this pamphlet can be obtained from the A. T. DeLa Mare
Co., 448 W. 37th Street, New York. Price on application.
19
erican horticulture and quaratine 37