MEMORANDUM OF JUSTIFICATION CONCERNING THE AERIAL ERADICATION OF COCA AND OPIUM POPPY IN COLOMBIA

The Andean Counterdrug Initiative section of the Foreign Operations, Export Financing, and Related Programs Appropriations Act, Division E, Consolidated Appropriations Resolution, 2003, (P.L. 108-7) (“FOAA”) lays out conditions under which assistance using funds appropriated under the FOAA may be made available for the procurement of chemicals for use in aerial eradication of illicit crops. In particular, the FOAA provides:

That not more than 20 percent of the funds appropriated by this Act that are used for the procurement of chemicals for aerial coca and poppy fumigation programs may be made available for such programs unless the Secretary of State, after consultation with the Administrator of the Environmental Protection Agency (EPA), certifies to the Committees on Appropriations that (1) the herbicide mixture is being used in accordance with EPA label requirements for comparable use in the United States and any additional controls recommended by EPA for this program, and with the Colombian Environmental Management Plan for aerial fumigation; (2) the herbicide mixture, in the manner it is being used, does not pose unreasonable risks of adverse effects to humans or the environment; (3) complaints of harm to health or licit crops caused by such fumigation are evaluated and fair compensation is being paid for meritorious claims; and such funds may not be made available for such purposes unless programs are being implemented by the United States Agency for International Development, the Government of Colombia, or other organizations, in consultation with local communities, to provide alternative sources of income in areas where security permits for small-acreage growers whose illicit crops are targeted for fumigation.

This memorandum lays out the justification for the Secretary of State’s Determination that the conditions in The Andean Counterdrug Initiative section have been met as required.

On April 9, 2003, the Secretary of State wrote U.S. Environmental Protection Agency (EPA) Administrator Whitman to request written consultation concerning the U.S.-supported Colombia eradication program. This letter is included as Attachment 1. Specifically, EPA was asked to advise the Department of State about whether the herbicide mixture is being used in accordance with EPA label requirements for comparable use in the United States and any additional controls recommended by EPA for this program; and about the risks of adverse effects to humans or the environment from the herbicide mixture, in the manner it is being used.

In 2002, EPA provided the Department of State a thorough technical review of the Department of State’s glyphosate use in the Government of Colombia’s coca spray program. The Department of State and EPA determined that EPA should use the EPA’s 2002 analysis as a foundation for the 2003 consultation. The Department’s working level consultations with EPA preceded the Secretary’s letter and continued into June. The Department met with EPA to brief EPA on changes in the eradication program since the 2002 EPA Analysis and to discuss opium poppy eradication, which Congress did not ask EPA to address in 2002. The Secretary’s April 9 letter provided EPA with a written document -- “Department of State Updated Report on Chemicals used in the Colombian Aerial Eradication Program” -- that provided further information on the issues discussed in the briefing. This document is included as Attachment 2.

On June 9, EPA Assistant Administrator Stephen Johnson responded to the Secretary of State on behalf of EPA Administrator Whitman with the results of EPA’s consultation review. That letter, and the attached document “Office of Pesticide Programs Details of the 2003 Consultation for the Department of State Use of Pesticide for Coca and Poppy Eradication Program in Colombia” (“EPA 2003 Analysis”) are included as Attachment 3.

1.(A) The herbicide mixture is being used in accordance with EPA label requirements for comparable use in the United States

EPA does not draft the label requirements for pesticide use in the United States, although it reviews and approves recommendations for use that are written by pesticide manufacturers. The aerial spray mixtures currently used in the U.S.-supported program of aerial eradication of both coca and opium poppy in Colombia contain three components: water, an EPA-registered formulation of the herbicide glyphosate, and a surfactant (Cosmo-Flux 411F).

The commercial glyphosate formulation used in the spray mixture is registered with EPA for sale in the United States for non-agricultural use. Although EPA does not regulate the use of adjuvant products not labeled as pesticides, EPA’s Office of Pesticide Programs reviewed the complete chemical constituents of Cosmo-Flux 411F, at the request of the Department of State, in 2001. This allowed the Department of State to better assess safety concerns related to the use of this product in the spray program. EPA determined in September 2001 that all of the ingredients of Cosmo-Flux 411F are exempt under 40 CFR 180.1001 from the requirement of tolerances when included in pesticides applied to food, feeds, and livestock.

During 2003 consultations with EPA, the Department of State reported to EPA the breakdown of the spray mixtures used for spraying coca and opium poppy and the application rates used in each operation (Attachment 2, p. 5). EPA responded that “EPA has determined that application rates for both coca and opium poppy eradication in Colombia are within the parameters listed on U.S. labels” (Attachment 3, Executive Summary). This determination meets the criteria for the Secretary to certify that the herbicide mixture is being used in accordance with EPA label requirements for comparable use in the United States.

1.(B) The herbicide mixture is being used in accordance with any additional controls recommended by the EPA for this program

The Government of Colombia and the Department of State have implemented several changes in the program to address issues raised by the 2002 EPA analysis. For reference, the 2002 EPA analysis, entitled: “Office of Pesticide Programs Details of the Consultation for Department of State: Use of Pesticide for Coca Eradication Program in Colombia” (“2002 EPA Analysis”) is enclosed as Attachment 4. The 2002 EPA recommendations and the Department of State responses are outlined below.

EPA recommendation to change glyphosate product used by the program:

The EPA made one direct recommendation to the Department of State related to spray program controls in the 2002 EPA Analysis. EPA recommended (Attachment 4,

p. 12) that “...due to the acute eye irritation caused by the concentrated glyphosate formulated product and the lack of acute toxicity data on the tank mixture, the Agency recommends that DoS consider using an alternative glyphosate product (with lower potential for acute toxicity) in future coca and/or poppy aerial eradication programs.” The Department of State believes that this recommendation was meant as a precaution for those persons filling spray tanks on the airplane who risked splashing the full-strength glyphosate into the eyes or onto the skin. The Department of State does not believe that the recommendation was intended to indicate any potential risk to persons exposed to the spray mixture as actually applied by the spray aircraft.

At the time that the EPA made this recommendation, there were no suitable replacement glyphosate formulations registered for sale and use in Colombia that offered lower potential for acute eye irritation. The Department of State worked with the program’s glyphosate supplier to identify and to register for sale and use in Colombia a formulation of glyphosate with reduced potential for eye irritation. As soon as that product could be registered for sale and use in Colombia, the Department of State began to purchase it for use in the spray program beginning in September 2002, and it is the formulation used today.

Like the previous formulation, the new formulation is also registered with the EPA for sale in the United States for non-agricultural use. It also contains 41 percent glyphosate salt and 59 percent inert ingredients. Like the previous formulation, the formulation now used is made from a base material (glyphosate technical) that is produced by a manufacturing plant in the United States. The glyphosate formulation now used is mixed with water and surfactant in the same proportions as the previous formulation to form the coca spray mixture.

The difference between the old and new formulations is that the current full strength product has an overall category III toxicological rating (“mildly toxic”) on the scale used by the EPA, whereas the previously used glyphosate formulation was rated category I (“highly toxic”) in its full, undiluted strength. The toxicity reduction is due to a change in the surfactant used in the glyphosate formulation. Of course, these ratings refer to the toxicological profile of the glyphosate formulations in their point of sale, undiluted form, and not the spray mixture (water, glyphosate formulation, and surfactant) that exits the spray aircraft.

EPA’s 2003 analysis offered the following assessment of the implications of the spray program’s switch to the new herbicide formulation for spraying of coca and opium poppy in Colombia: “As for human health concerns, EPA concludes there are no risks of concern from dietary, mixer/loader/applicator or field workers, or bystanders (including children). The concerns for mixer/loader eye irritation discussed in the Agency’s 2002 findings have been mitigated by switching to the lower toxicity product” (Attachment 3, Executive Summary, p. ii).

EPA advice regarding tracking reported health complaints:

EPA’s 2002 analysis (Attachment 4, p. 32) also stated that: “(p)rospective tracking of reports of health complaints, documenting times of exposure and onset of symptoms, are recommended during future spray operations to evaluate any potential health effects and ameliorate or prevent their occurrence.” The Department of State has increased its efforts to track reported health complaints and to investigate any possible connection between verified spraying of illicit crops and damages purported in any such complaints.

The spray program tracks human health complaints in several ways. The first is to initiate an immediate investigation, often including clinical evaluation of the patient(s), upon notice to the U.S. Embassy of a problem. The Embassy’s Narcotics Affairs Section (NAS) learns about cases through letters directed to the Embassy or Government of Colombia (GOC) entities, from local counternarcotics base commanders, from the members of the media, and from non-governmental organizations. To investigate complaints of toxic exposure allegedly caused by spraying, NAS retains the services of two of Colombia's leading toxicologists, including the director of Colombia’s national poison control center, the Uribe Cualla Centro de Asesoramiento Toxicológico.

Since submission to Congress of the FY 2002 “Report on Issues Related to the Eradication of Illicit Coca in Colombia,” four such complaints have been reported to the U.S. Embassy. Details of these complaints and of follow-up medical evaluations are included below.

In September 2002, the Embassy received a complaint of multiple cases of poisoning from spraying of coca in Puerto Asís (Putumayo Department). A visit to the hospital and interviews with doctors there by a Colombian toxicologist under contract to the State Department revealed no cases of poisoning or illness attributable to spray chemicals. The toxicologist learned of two hospitalized children who could have been the source of the complaint, and he reviewed their cases. One of those children was suffering from poisoning by an organophosphate insecticide. The other child was suffering from asthma. An English language version of the toxicologist’s report from this investigation is enclosed as Attachment 2, Tab B.

In February 2003, a news report in the Bogotá daily “El Tiempo” attributed the spread of tuberculosis and cases of harelip and cleft palate in newborns to aerial spraying of coca in Tibú (Norte de Santander department). A toxicological review (Attachment 5) showed cleft palate and harelip to be genetically inherited defects that have never been reported in humans as a result of exposure to any chemical substance. Tuberculosis is an infectious disease passed from person to person, and is also unrelated to any potential exposure to spray chemicals.

During a March 2003 visit to Pasto, Nariño, Embassy Public Affairs personnel were told that the local hospital had cases of children suffering health problems from spraying. A NAS officer followed up on this case and spoke with a hospital doctor who explained that there were no sick children in the hospital, but that he was tracking a number of children with birth defects whose mothers allegedly were exposed to spray chemicals. The doctor offered to let an Embassy-contracted Colombian toxicologist review the case files. A NAS letter to file regarding this case is enclosed as Attachment 6.

On July 2, 2003, a news broadcast on Caracol TV reported the death of a coca leaf harvester allegedly exposed to spray chemicals. The man had been hospitalized in San Pablo, Bolivar department. Investigation revealed that the man suffered a serious infectious disease that went undiagnosed until it was too late. Officials in San Pablo eventually transferred the man to a better-equipped hospital in Bucaramanga, Santander department, where he later died. An autopsy confirmed that the man had died from pneumonia and meningial infection. A screen for chemicals in his lung tissue was negative. The toxicologist’s report from this investigation is enclosed as Attachment 7.

The Government of Colombia and the U.S. Embassy Bogotá have also taken a proactive approach to investigating human health concerns manifest in areas where the spraying takes place. Both governments have collaborated to create a robust Medical Civic Action Program (Medcap) to search out cases of harm to health allegedly caused by the spraying. These public health interventions are timed to take place in areas where coca eradication has recently taken place. U.S. Embassy-contracted Colombian toxicologists talk to patients as well as to local medical personnel, looking for spray-related cases. As outlined in the chart below, a total of 4,779 patients made themselves available for Medcap medical personnel, had their medical conditions assessed, and received complimentary health care. Although Medcap personnel have encountered cases that were claimed to be spray-related, their reviews of these cases have determined that, in each case, the conditions were caused by events unrelated to aerial eradication. Through Medcap and other medical investigations, the U.S. Embassy has still not yet found a single instance of spray-related harm to human health. (Note: This is an ongoing program and several Medcaps are planned for upcoming months).

Place and Date	Patients Assessed
Cartagena del Chairá (Caquetá) May 11, 2002	250
Solano (Caquetá) August 7, 2002	120
Santa Ana (Putumayo) September 21, 2002	260
Puerto Asís (Putumayo) November 9, 2002	250
San Vicente del Caguán (Caquetá) February 1, 2003	149
Morelia (Caquetá) July 20, 2003	250
Florencia (Caquetá) September 18-21, 2003	3,500

Additionally, NAS is collaborating with the Colombian National Institute of Health (INS) on a program to identify health effects of herbicides and pesticides, including glyphosate, in populations located in coca growing regions across Colombia. A NAS-contracted toxicologist helped INS prepare and conduct training for physicians and environmental health personnel who serve the populations of these areas.

The training consists of a weeklong workshop that covers toxicology, classification of pesticides, prevention, diagnosis and recognition of pesticide poisoning, clinical management, epidemiological considerations and procedures for the study of an outbreak, glyphosate toxicological facts, and a risk assessment of aerial application of glyphosate for people and the environment. Two such workshops have been completed:

Place and Date

Attendees

Pasto (Nariño)

September 1-5, 2003

32 physicians

31 technicians

Puerto Asís (Putumayo)

October 20 to 24, 2003

28 physicians

26 technicians

Another workshop was held in Neiva, Huila from December 1-5, 2003, for public health personnel in the Huila and Tolima opium poppy growing regions. Some 60 physicians and 55 environmental health technicians were expected to attend. Four more workshops are scheduled for the first quarter of 2004 in Meta-Guaviare, Arauca, North Antioquia, and Santander/South of Bolivar.

The EPA 2003 Analysis reported that “the Government of Colombia and the U.S. Embassy Bogota have adhered to the EPA advice on tracking and investigating health complaints” (Attachment 3, p. 30). The EPA 2003 Analysis also made new health tracking recommendations: “(EPA) requests that Department of State improve its definition of glyphosate poisoning, provide further documentation of its investigations and how they are conducted, and standardize data collection” (Attachment 3, Executive Summary, p. ii).

The Department and the Government of Colombia are currently implementing the 2003 EPA recommendations. NAS Bogota and the Government of Colombia’s (GOC’s) National Institute of Health have developed and distributed standardized data collection worksheets and a definition of glyphosate poisoning in the workshops referenced above.

EPA comment regarding spray drift:

Although not addressed to the Department of State as a recommendation, EPA also noted in its consultation with the Department of State some concern regarding spray drift and the potential for non-targeted, desirable vegetation to suffer from the spraying of nearby coca (or opium poppy). Informed of EPA and Congressional concern, the Department of State and the Government of Colombia have incorporated several measures into the spray program to assist with evaluation and control of spray drift.

The first of these steps was to reinforce the environmental safety component of spray pilot training. A NAS Environmental Advisor and aviation experts from the Department of State’s Air Wing designed a curriculum for pilots on the potential negative impact that spraying may have on the environment and techniques to minimize potential collateral damage to legal crops and the environment.

Pilots received this briefing in December 2002 and again in June 2003. All pilots, both fixed wing spray pilots and rotary wing escort helicopter pilots, will receive these briefings, which will be conducted semi-annually (a third session is on track for December 2003). Briefings emphasize the unique aspects of the Colombian operational theatre, and will solicit feedback from pilots on techniques to maximize application effectiveness and avoid damage to non-target vegetation. An outline of this briefing is included as Attachment 2, Tab C.

Search and rescue helicopter crews that accompany each spray flight have also been directed to monitor drift patterns from above. They now assist in ensuring that spray does not drift beyond target crops and notify the spray aircraft flight lead when conditions might merit canceling a spray flight. A copy of the directive from the Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (INL) Office of Aviation to the eradication contractor that formalizes these new spray regulations is included as Attachment 2, Tab D.

EPA noted in 2003 that “(t)he Agency believes that the potential for spray drift phytotoxicity is still a factor for both coca and poppy spraying. EPA recognizes that the Department of State is employing Best Management Practices to minimize drift and encourages them to continue these efforts.” (Attachment 3, Executive Summary, p. ii).

The Department will continue drift control efforts as EPA recommends. Based on responses to EPA’s 2002 and 2003 recommendations on herbicide use, human health tracking, and spray drift, the Department of State believes that the herbicide mixture is being used in accordance with any additional controls recommended by the EPA for this program.

1.(C) The herbicide mixture is being used in accordance with the Colombian Environmental Management Plan for aerial fumigation

The GOC’s Environmental Management Plan for aerial eradication (EMP) was drafted and implemented by the Ministry of the Environment (MINAMB) in 2001. The EMP was designed to be a living document, and it was modified by several MINAMB resolutions at the end of the previous administration. As written, the EMP was impossible to execute and lacked clear lines of responsibility for the GOC line agencies that were required to carry out aspects of the EMP.

In 2003, the GOC recognized that further refinement was necessary to achieve greater efficiencies, and formed an inter-institutional technical committee to revise the EMP. This committee, which first met on May 8, 2003, was composed of representatives from the Ministry of the Environment (MINAMB), the National Directorate for Dangerous Drugs (DNE), the Antinarcotics Police (DIRAN), the Ministry of Health, the Ministry of Agriculture (ICA), MINAMB's laboratory (IDEAM), and the U.S. Embassy Bogota Narcotics Affairs Section (NAS).

The revisions recommended by the committee were briefed to Colombian environmental groups following formal publication. After a fifteen-day period, during which no adverse comments were received, the revisions were incorporated into the EMP by MINAMB Resolution 1054 on September 30, 2003. An English language version of the revised EMP is enclosed as Attachment 8.

The most significant change in the EMP is the inclusion of multiple agencies in the monitoring process. Under the EMP as modified, environmental monitoring is an inter-agency process, with clear roles and responsibilities for each party. INL technical and equipment assistance provided to a wide range of EMP participants has given these agencies an ability to actively participate in monitoring of the spray program and to carry out the roles required of them. With Department of State-donated laboratory equipment, the GOC Institute of Geography will conduct soil sampling and the Ministry of Health will conduct water sampling to determine the persistence of glyphosate in sprayed areas. Similarly, with assistance from the Department of State, the GOC’s Ministry of Health is training health care providers in areas where spraying takes place to recognize different forms of chemical poisoning. Once trained, they will be able to differentiate between glyphosate-derived illness and the other forms of chemical poisoning that commonly afflict people who process raw materials into finished drugs in their homes. NAS has allocated $3 million from the eradication budget for environmental improvements ranging from physical upgrades at bases to the provision of training and equipment to GOC line agencies for EMP purposes.

INL Principal Deputy Assistant Secretary Paul Simons visited Bogota during November 5-7 to meet with NAS Bogota and participating GOC EMP agencies to discuss their roles under the new EMP. All of these agencies were appreciative of the Department of State’s assistance that is now allowing them a seat at the table under a functioning EMP. In addition to providing assistance to Colombia’s EMP agencies, NAS Bogota has hired four personnel to strengthen oversight of the eradication program and related initiatives to ensure continued compliance with environmental guidelines, including the EMP. The added positions include a U.S. contractor Environmental Advisor, a Colombian Environmental Advisor, and a Colombian lawyer to assist with complaint investigations and adjudication, and a Colombian toxicologist.

Due to the limited time between the approval of the modifications to the EMP (September 30) and the submission of this report, INL has been unable to fully comply with one provision. This provision (Attachment 8, specification No. 4), calls for sewage and industrial wastewater treatment facilities to be installed at all aerial eradication forward operating locations (FOL’s). NAS Bogota has designed and ordered the necessary equipment, but there will be some lag time pending delivery and installation. This is inevitable, as spraying moves into new areas and new FOL’s are developed. Although this aspect of the EMP has not been completed, we believe that in progress implementation of the program complies with both the spirit and the letter of the EMP sufficiently so that the Secretary’s certification is appropriate at this time.

Attachment 9 is a letter dated November 5 from the Government of Colombia’s Vice Minister of Environment certifying that the spray program is being carried out in compliance with the Government of Colombia’s Environmental Management Plan. The Government of Colombia’s Environmental Ministry has over-arching responsibility for supervision of the Environmental Management Plan.

2. The herbicide mixture, in the manner it is being used, does not pose unreasonable risks or adverse effects to humans or the environment

The Secretary of State certified last year that the herbicide mixture, in the manner it is being used, does not pose unreasonable risks or adverse effects to humans or the environment. Since the 2002 certification, the Department has responded to EPA recommendations (per the above) with adjustments that have strengthened spray program controls and ensure increased protection against adverse effects to humans and the environment.

After consultations with the Department of State in 2003, EPA offered the following assessment of human health concerns related to the spraying of coca and opium poppy in Colombia: “As for human health concerns, EPA concludes there are no risks of concern from dietary, mixer/loader/applicator or field workers, or bystanders (including children). The concerns for mixer/loader eye irritation discussed in the Agency’s 2002 findings have been mitigated by switching to the lower toxicity product” (Attachment 3, Executive Summary, p. ii).

EPA also concluded that the eradication program lowered its potential risks to wildlife and takes appropriate measures to minimize off target drift: “EPA concludes that the switch to a lower toxicity product will pose less risk of acute poisoning to wildlife. The Agency believes that the potential for spray drift phytotoxicity is still a factor for both coca and poppy spraying. EPA recognizes that the Department of State is employing Best Management Practices to minimize drift and encourages them to continue these efforts.” (Attachment 3, Executive Summary, p. ii).

The Department of State believes that improvements over the last year have decreased the likelihood of adverse impacts of eradication program on humans and the environment and that the herbicide mixture, in the manner it is being used, does not pose unreasonable risks or adverse effects to humans or the environment.

3.(A) Complaints of harm to health or licit crops caused by such fumigation are evaluated and fair compensation is being paid for meritorious claims

On October 4, 2001, the GOC formally instituted a new process to compensate growers for legal crops sprayed in error. Since that date, the Government of Colombia’s National Directorate of Dangerous Drugs (DNE), the Government of Colombia agency responsible for complaint investigations, has received 4,329 complaints. Five of these complaints have been found to be valid and a total of 52 million pesos ($18,400 dollars) in compensation has been paid for damages to legal crops.

63 percent of these complaints (2,740) have been investigated and denied as not being valid cases. Of this group, 44 percent (1,200 complaints) were verified in the field and the crop in question was found to be coca or to be interspersed with coca and thus ineligible for compensation. 52 percent (1,425) of the rejected complaints were denied because there was no spraying in the area during the time frame of the complaint (the complainant is given the benefit of the doubt with a calendar day on either side of the day cited in his/her complaint). Three percent (89) of the rejected complaints were denied because they were filed more than two months after the alleged spraying. The remaining one percent (26) of the cases was closed because the request for additional information from the complainant was not returned within 60 days (the time allotted for any request for more information in a Colombian judicial process).

Although almost two thirds of the filed complaints have been closed, 37 percent (1,584) are being processed and verified. Complaints resolution is a rolling process; on-site investigations continue and compensation is being paid to cases with merit.

Field verification is extremely dangerous and resource intensive and this is a slow-moving process. Because of the risks involved for the Embassy personnel, agronomists, lawyers, DNE representatives, CNP officials, and ombudsman’s representatives that accompany site visits, the primacy of security will dictate the pace of investigations in the future. Although logistical considerations (security concerns, personnel availability, and helicopter resources) are part of the reason that complaints cannot be resolved in the field more quickly, the greatest logjam in this system is the number of false complaints that overwhelm the ability of field investigators to close more cases.

False complaints – cases in which growers complained that their legitimate crops were sprayed, but investigators who reached the fields in question found them to be coca or legitimate crops interspersed with coca – waste resources that otherwise might be used in the service of the farmers who really deserve compensation. Of the 1,200 complaints investigated in the field, only five have been deemed credible. In other words, less than half of one percent of the cases that have been visited by complaint verification teams to date have merited compensation. Nevertheless, Embassy Bogota has taken steps to make sure that the complaint resolution is swifter and continues to pursue field verifications when security, weather, and logistical considerations permit.

The Colombian Ministry of Justice is in the process of refining the claims procedures to further streamline the process. These will include a warning that a complainant found to have coca growing in fields that he claims were legal crops will be subject to prosecution under violation of a Colombian law prohibiting false claims. Presumably, this will deter the overwhelming number of false claims that have flooded the system, making investigation of and restitution for genuine claims very difficult.

3.(B) Such funds may not be made available for such purposes unless programs are being implemented by the USAID, the GOC, or other organizations in consultation with local communities, to provide alternative sources of income in areas where security permits for small-acreage growers whose illicit crops are targeted for spraying

Thus far in calendar year 2003, the Colombian aerial eradication program has sprayed coca in the departments of Putumayo, Nariño, Guaviare, Meta, Bolivar, Cauca, Norte de Santander, Vichada, Antioquia, Vaupes, Cordoba, and Arauca and opium poppy in the departments of Cauca, Huila, Tolima, Nariño, Cesar, and La Guajira. In each of these areas, USAID, the GOC, and/or other organizations are implementing alternative development programs to provide legal income generating opportunities to illicit crop growers who agree to accept benefits after eradicating their crops of coca or opium poppy.

For the purposes of this report, the Department of State interprets the term “area” as a Colombian department. This is consistent with the way that the Colombian spray program records and reports spray activity. It is also the most appropriate definition because Department of State and USAID experience has shown that while alternative development programs should be (and are) coordinated with spraying, these two components should not always be implemented in every location.

Alternative development is not appropriate in many locations where illicit crops are grown. Coca and opium poppy are often grown in remote, difficult to reach areas with limited infrastructure to support legal crops that have less value and higher transport costs than illegal merchandise. Dispersing development activities to remote areas raises costs while reducing impact. Furthermore, many drug-producing regions have nutrient-poor and fragile tropical soils, inappropriate for large-scale farming activity and unsuitable for increased human habitation. As reflected in the language of Public Law 108-7, guerilla and paramilitary groups operate in many illicit crop-growing zones and make alternative development inadvisable in these locations. These narcoterrorist groups reap immense profit from the illegal trade and pose grave security risks for development personnel and slow down the implementation progress.

Despite these obstacles to alternative development in Colombia, USAID and the GOC are implementing a robust alternative development program in coca and opium producing areas. Now in the fourth year of Plan Colombia alternative development coordination with the GOC and the third year of project implementation, USAID’s alternative development (AD) program has supported a total of 24,549 hectares of licit crops and completed 260 infrastructure projects in coca and poppy growing areas through March 31, 2003. These efforts have benefited a total of 22,829 families. These achievements in each category have surpassed program goals. Equally important, USAID has strengthened a total of 30 NGOs, cooperatives, and national institutions so that alternative development and community building activities will be more sustainable.

The alternative development projects being carried out by USAID and GOC organizations in each area where the spray program eradicates illicit crops are described below.

Antioquia

A $9.1 million project through the Pan-American Development Foundation (PADF) for short-term production activities for immediate income and employment needs; longer term crops such as natural rubber and cacao to provide sustainability; and complementary productive infrastructure. Also operating in south of Bolivar Department.

A $8.5 million project through Land O’Lakes (LOL) to promote sustainable dairy production, processing and marketing involving small farmers. Also operating in Nariño.

Aid to Artisans (ATA) is carrying out a $4.3 million project to strengthen local capacity for production and marketing of crafts. Also operating in Atlantico, Boyaca, Caldas, Cauca, Cesar, Codoba, Huila, Magdalena, Narino, Quindio, Santander, Sucre, and Tolima.

The $20 million Colombia Agribusiness Partnership Program (CAPP), implemented by Associates in Rural Development (ARD) is promoting private sector agricultural production. In Antioquia, the program supports small farmers in producing fruit for processing into pulp and African palm. Also operates in Atlantico, Bolivar, Caldas, Casanare, Cauca, Cesar, Cordoba, Guajira, Huila, Magdalena, Narino, Quindio, Risaralda, Santander, Sucre, Tolima, and Valle del Cauca.

The $12 million Colombia Enterprise Development (CED) project to support small and medium enterprise development in secondary cities. Also operating in Atlantico, Caldas, Quindio, Risaralda, Santander, Valle del Cauca, and Tolima.

The $22.7 million Colombia Forestry Development Project (CFDP) to support: forest policy changes and improved production, processing and marketing of forest and wood products to increase incomes. Will also operate in Choco, Magdalena, and Narino.

The Colombian Government’s Investment Fund for Peace (FIP), a $32.2 million investment, is generating employment through infrastructures, licit crop production (coffee rehabilitation, agro forestry), skills training, and education/nutrition aid to poor families.

Arauca

The $2.4 million effort under the GOC’s FIP generates employment through infrastructure and road improvements, equipment and infrastructure for local government and community organizations, and education/nutrition assistance to poor families.

Bolivar

PADF is supporting short cycle production activities to address immediate income and employment requirements; longer term crops such as natural rubber and cacao to provide sustainability; and complementary productive infrastructure.

CAPP is also promoting private sector involvement with farmers to produce cacao, African palm, and yucca (cassava).

The GOC’s FIP is also active in Bolivar providing

$12.8 million for employment generation activities through infrastructure and road improvement projects, licit crop production (rubber, reforestation, corn, beans), equipment and infrastructure for local governments and community organizations, skills training, forest guardian families program, and education/nutrition assistance to poor families.

Caqueta

Chemonics -- Colombia Alternative Development (CAD) project is investing $4.5 million and fostering short-term crop production for food security and longer-term income generation through rubber production.

The Amazon Conservation Team is assisting Colombian indigenous communities in food security, health and local governance/land management (total investment $1.8 million). Activities under this program are also being carried out in the Departments of Putumayo and Vaupes.

The GOC’s FIP is supporting employment generation activities through infrastructure and road improvement projects, licit crop production (coffee rehabilitation, sugarcane, rubber planters, livestock), equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families with resources amounting to $2.0 million.

Cauca

Chemonics-CAD activities, totaling $3.9 million, to improve forest management/production, processing and marketing chains as well as supporting small scale irrigation for the production and marketing of short-season, high-value crops.

ACDI/VOCA is also promoting specialty coffee production, processing and marketing in Cauca’s illicit crop growing areas.

The CAPP project is supporting private sector investments in hot peppers, jute, and cacao.

Aid to Artisans project is enhancing local capacity for production and marketing of crafts as licit income generating alternatives.

The GOC’s FIP is supporting employment generation activities through infrastructure and road improvement projects, licit crop production (coffee rehabilitation, fruit trees, forestry, yucca, vegetables, and livestock), equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families with resources totaling $8.6 million.

Cesar

Aid to Artisans project is carrying out activities to strengthen the production and marketing of crafts.

The ARD/CAPP program is supporting private sector investments with small farmers producing crops such as cacao, fruits and African palm.

The GOC’s FIP is supporting employment generation activities through infrastructure and road improvement projects, licit crop production (cacao, coffee rehabilitation, forestry), equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families totaling $3.8 million.

Cordoba

Aid to Artisans project is supporting the strengthening of local capacity to produce and market crafts by artisans in the Department.

ARD/CAPP program is supporting private sector activities in cacao and passion fruit production.

The GOC’s FIP is providing $8.6 million for employment generation activities involving road improvement projects, and education/nutrition assistance to poor families.

La Guajira

The CAPP is supporting private sector activities in crops such as passion fruit and cacao.

The GOC’s FIP is providing $0.7 million to support employment generation through infrastructure activities, equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families.

Guaviare

The GOC’s FIP is providing $0.8 million to support employment generation activities through road improvement projects. A FIP road improvement program involving Guaviare and Meta is providing $3.4 million for the two departments.

Huila

Chemonics - CAD project is supporting a $0.6 million activity to promote production and marketing of passion fruit.

ACDI/VOCA is promoting specialty coffee production, processing and marketing in poppy growing areas.

ARD/CAPP is supporting cacao and fruits production.

The Aid to Artisans project is promoting production and marketing of crafts.

The GOC’s FIP is supporting employment generation activities through road improvement projects, equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families with $7.5 million in GOC resources.

Meta

The GOC’s FIP is supporting employment generation activities through infrastructure and road improvement projects, equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families totaling $3.6 million. In addition, a road improvement program involving Guaviare and Meta is providing $3.4 million to the two departments.

The ARD/CAPP program is promoting private sector investments with small farmers to produce African palm.

Nariño

ACDI/VOCA is promoting specialty coffee production, processing and marketing in illicit crop growing areas of Narino.

The United Nations Office on Drugs and Crime (UNODC) is implementing a $1.2 million activity to encourage annual crops, agro forestry, and dual purpose livestock production. An agro-forestry management activity totaling $1.8 million is scheduled to begin in December.

Land O’Lakes is promoting sustainable small farm dairy production, processing and marketing.

ARD/CAPP program is supporting small farmer, private sector projects in cacao and African palm production.

Aid to Artisans project is carrying out activities to promote the production and marketing of crafts in Narino.

The $22.7 million Chemonics Colombia Forestry Development Project will be supporting forest policy changes and carry out activities for the improved production, processing and marketing of forest and wood products in Narino as well as in Antioquia, Choco and Magdalena.

The GOC’s FIP is supporting employment generation activities through infrastructure and road improvement projects, support for licit crop production (coffee rehabilitation, fruit trees, corn, beans), equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families with resources totaling $8.2 million.

Norte de Santander

A Chemonics-CAD $6.4 million activity in cooperation with FIP is promoting cacao and African palm production, processing and marketing.

The GOC’s FIP is supporting employment generation activities through road improvement projects, licit crop production (rubber, cacao, plantains), equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families totaling $6.0 million.

Putumayo

Chemonics-CAD project is providing $44.7 million in Putumayo for: short and medium-term crop production with farmers and indigenous groups, hearts of palm production, processing and marketing; rubber production, processing and marketing; forest management and value added processing and utilization of forest and wood products; infrastructure projects, including bridge construction and road improvements, schools, and health facilities. As part of the development of production and marketing chains, support is being provided for the private sector involvement in processing plants and marketing for cassava chips, black pepper and plantain; tropical flowers and foliage, vanilla production, as well as for medicinal plants and essential oils.

The U.S. Army Corp of Engineers’ $6.7 million rural infrastructure project is carrying out road, sewage and water treatment activities that are generating employment.

The Amazon Conservation Team’s $1.8 million project is supporting Colombian indigenous communities in food security, health and local governance/land management.

The GOC’s FIP also supports employment generation activities through infrastructure and road improvement projects, the forest guardian families program, equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families totaling $8.5 million.

Tolima

Chemonics-CAD project is supporting a $1.1 million activity to increase annual crop production for food security and to increase income and employment generation in the longer term through forestry, livestock and cold climate fruit production.

ACDI/VOCA is promoting specialty coffee production, processing and marketing in illicit crop growing areas of Tolima.

The $12.0 million Colombia Enterprise Development project implemented by CARANA Corporation will be supporting small and medium enterprise development in Colombia’s secondary cities including those in Tolima.

Aid to Artisans project is carrying out activities to promote the production and marketing of crafts in the Department.

ARD/CAPP is supporting private sector projects in fruits and cacao production.

The GOC’s FIP is supporting the forest guardian families program, equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families with resources totaling $10.2 million.

Vaupes

The Amazon Conservation Team’s project is supporting traditional healers and helping to strengthen indigenous community organizations that are also involved in managing indigenous lands.

Vichada

The GOC’s FIP is providing $200,000 in employment generation activities through infrastructure projects, equipment and infrastructure for local governments and community organizations, and education/nutrition assistance to poor families.