EXHIBIT V.-Southern pine costs, years 1937 and 1944-Group I (large) mills1

1 Not available for group II (small) mills, and group III (concentration plants). Source: Southern Pine Association, New Orleans, La.

EXHIBIT VI.-Production and consumption of lumber in the Southern States and percentages of production sold intrastate and consumption derived intrastate, 1936 and 1938

EXHIBIT VI.—Production and consumption of lumber in the Southern States and percentages of production sold intrastate and consumption derived intrastate, 1936 and 1938-Continued

Source: U. S. Forest Service, Lumber Distribution and Consumption for 1936 and 1938, Forest Research Project Report No. 1, and Miscellaneous Publication No. 413, respectively.

EXHIBIT 18

STATEMENT OF H. A. THOMAS, JR., MANAGER OF THE AGRICULTURAL PRODUCERS LABOR COMMITTEE, LOS ANGELES, CALIF.

I. REPRESENTATION

Agricultural Producers Labor Committee represents the producers of 98 percent of the oranges, grapefruit, and lemons grown in the States of California and Arizona; it is also associated with Avocado Growers Association, a grower cooperative association, made up of 95 percent of the producers of avocados in California, and the Western Growers Association, made up of the grower-shippers of a large percentage of the carlot shipments of vegetables from California and Arizona.

My statement will pertain primarily to the relation of the citrus growers to the exemption in the Fair Labor Standards Act.

There are approximately 28,000 citrus growers in California and Arizona and these growers cultivate, on an average, 12 acres of citrus fruit. They are directly interested in and vitally affected by the exemption in the Fair Labor Standards Act and the regulation of the Administrator defining "area of production" in that the packing houses are in most instances operated by associations of growers, and in all instances the costs of handling, washing, grading, and packing are paid by the growers.

There are in California and Arizona 275 citrus packing houses. Of these, 235 citrus packing houses, packing approximately 85 percent of the oranges and grapefruit and 94 percent of the lemons grown in California and Arizona, are nonprofit cooperative associations organized and controlled by the citrus growers. Such. cooperative citrus packing houses act as the agent of the members in picking, washing, grading, and packing their citrus fruit, and as trustee of the growers in receiving and distributing the funds received from the sale of the fruit. They handle only the fruit of their members. As such cooperative packing houses act as agents for and pack the fruit for the account of the members, all packing costs are borne directly by the grower-members. Forty citrus packing houses, packing approximately 15 percent of the oranges and grapefruit and 6 percent of the lemons grown in California and Arizona, are independently owned. Such packing houses either pack exclusively the fruit which they grow, or pack fruit for growers under contract whereby the fruit is packed for the account of the grower. In the latter case the fruit is packed and sold and the packing charges plus a reasonable fixed charge are deducted from the sales price and the balance is passed on to the grower. In such a case the grower directly bears the increased cost of packing the fruit. In some instances a buyer may acquire fruit directly from the grower for cash, but in such instances the buyer deducts the packing and handling costs from the purchase price, so that any increase in packing charges is directly paid by the grower.

There are approximately 330,000 acres of land in California used in the production of oranges, grapefruit, and lemons. The annual total value of the citrus crop produced amounts to approximately $300,000,000, and there are employed in the citrus packing houses in normal times approximately 20,000 workers, consisting largely of the growers, their children, other members of their families, and their neighbors. Labor relations in these packing houses is one of being a good neighbor, rather than one of strict industrial conflict such as is sometimes found in industrial centers.

II. THE 3 (F) AGRICULTURAL EXEMPTION

Under section 3 (f) the activities of the growers in the growing, production, and harvesting of citrus fruit are exempt from the minimum wage and maximum hours provision of the act.

There are different seasons for each variety of citrus fruit. The navel season in central California begins in November and lasts through January; the navel season in southern California begins in December and lasts through May. The Valencia season in central California begins in April and lasts through June; the Valencia season in southern California begins in May and lasts through October; and navel season in Arizona and the desert is during the early winter months; lemons are harvested at different times during the year, but the peak of the harvest takes place during the winter season in most of the districts.

III. THE 7 (B) (3) EXEMPTION

Some of the houses have only one variety and operate only a few months; other houses have more than one variety and operate for longer periods; most of the houses have both varieties of oranges and some of them have lemons and grapefruit; in all cases a survey supplied to the Administrator shows that 50 percent or more of the volume handled by the individual house was received and handled during a 14-workweek period, so that their operations were seasonal, and the Administrator found the citrus industry in California to be a seasonal industry in accordance with 7 (b) (3). These establishments are entitled to that exemption.

IV. THE 7 (C) EXEMPTION

Citrus fruits are a perishable and seasonal fresh fruit, and such establishments are entitled to the 7 (c) exemption for the packing of such fruit. They do no canning or processing. Under this section they are entitled to an additional 14-workweek exemption from the maximum hours division of the act.

These establishments need the 7 (b) (3) and 7 (c) exemptions, as their operations are seasonal, affected by weather conditions, pests, maturity rates, and other factors beyond the control of the farmers. Consequently they are unable to regulate their hours of work so as to prevent abnormal costs arising from overtime where they are forced to operate the establishments more than 40 hours per week. They have endeavored at all times to maintain a level of operation satisfactory to the employee, and to avoid long or unusual hours; however, the conditions over which they have no control make such operations necessary at various times during their operating period, and they would be unduly penalized if it was necessary for them to pay overtime during such period. Their operations cannot be standardized, as can be those of an industrial establishment.

These establishments pay the highest wage for agricultural labor of any operators in the United States; consequently they would be the most heavily penalized if they were required to pay overtime during their seasonal operation.

V. THE 13 (A) (10) EXEMPTION

Citrus is produced in commercial quantities in 13 counties in California and 3 counties in Arizona, and these counties have always been recognized by the Federal Department of Agriculture and the various State departments in the areas of production. These counties are: Butte, Glenn, Fresno, Kern, Tulare, Imperial, Los Angeles, Orange, Riverside, San Bernardino, San Diego, Santa Barbara, and Ventura, in California; and Maricopa, Yavapai, and Yuma Counties, in Arizona.

These areas may be defined geographically in California by the central California area (parts of Fresno, Kern, and Tulare Counties), Sacramento Valley (northern California-parts of Butte and Glenn Counties), desert area (Imperial County and eastern portion Riverside County), Ventura-Santa Barbara area (Ventura and Santa Barbara Counties), Whittier-Orange County area (part of Los Angeles and Orange Counties), foothill area (Los Angeles and part of San Bernardino Counties), San Fernando Valley (Los Angeles County), Redlands and Highlands (San Bernardino County), Riverside area (Riverside County), Corona district (Riverside County), San Diego area (San Diego County), and in Arizona by the Yuma-Mesa (Yuma County), and Salt River Valley (Maricopa and Yavapai Counties).

Over 60 percent of the California-Arizona citrus and vegetable packing houses are located in towns of a population more than 2,500. They happen to be so located for a variety of reasons, none of which gives them any competitive advantage over the other citrus or vegetable packing houses, or causes them to operate in any other or different manner, or puts them outside the zone of agricultural economic influences.

For example, there are located in the San Fernando Valley, in California. seven cooperative citrus packing houses. Five of these are located within the corporate limits of the city of Los Angeles. These five citrus packing houses are located within the corporate limits of the city of Los Angeles, not to obtain any economic advantage or so they can operate in a manner different from the other citrus packing houses, but because all of the groves of their members are located within the corporate limits of the city of Los Angeles and the packing