volume II | INTERNATIONAL COURT OF JUSTICE

Document Number

17566

Parent Document Number

17564

Document File

17566.pdf

INTERNATIONAL COURT OF JUSTICE
____________________________________________

CASE CONCERNING
AERIAL HERBICIDE SPRAYING

(ECUADOR v. COLOMBIA)

REJOINDER OF THE

REPUBLIC OF COLOMBIA

VOLUME II

ANNEXES 1 - 19

1 FEBRUARY 2012 LIST OFANNEXES

VOLUME II

SCIENTIFICAND TECHNICALEXPERT REPORTS

Annex 1 Dr A.J. Hewitt, Ph.D., Response to Report “Spray Drift Modeling
of Conditions of Application for Coca Crops in Colombia by D.K.
Giles, Jan. 2011”, Nov. 2011 .....................................1

Annex 2 Dr A.J. Hewitt, Ph.D., Aerial Spray Drift Modeling of Plan
Colombia Applications,Nov .21................................33

Annex 3 Dr K.R. Solomon, Ph.D., Expert Report of Keith R. Solomon on

Behalf of Colombia, Nov. 2011. ..................................41

Annex 4 Dr S. Dobson, OBE Ph.D.,▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
to Volume II of Ecuador’s Reply (2011), Dec. 2011....................79

Annex 5 A. Tait, International Mapping Associates, Statistical Summary of
Data for Spray Events Within the Relevant Area Along the Border
between Colombia and Ecuador, Dec. 2011. .......................105

Annex 6 Dr B.M. Evans, Ph.D., Expert Report by Dr. Barry M. Evans ,
Dec. 2011.. .................................................127

Annex 7 Colombian Expert on Environmental Law, Mr José Vicente Zapata,

Critique of the Report Prepared by Ms Claudia Rojas Quiñonez
dated January 2011 on ‘The Aerial Spray Program and Violations
of Colombia’s Domestic Laws Regarding The Environment And The
Rights Of Indigenous Peoples’, Nov. 2011. ........................219

OTHER EXPERT REPORTS

Annex 8 Expert Report of Dr G. Marcella, Ph.D. on behalf of the DynCorp
Defendants in Arias/Quinteros v. DynCorp (D.D.C.), Jan. 2011. ........283

Annex 9 Expert Report of Dr J.M. DiTomaso, Ph.D. prepared for the Dyncorp

Defendants in Arias/Quinteros v. Dyncorp (D.D.C.), Jan. 2011. ........329

iiiAnnex 10 Expert Report of Dr K.R. Solomon, Ph.D. on Behalf of the
Defendants in Arias/Quinteros v. Dyncorp, Jan. 2011.................377

Annex 11 Expert Report of Dr A. Atalay, Ph.D., CPSS, prepared for the

Defendants in Arias/Quinteros v. Dyncorp (D.D.C.), Jan. 2011. ........415

Annex 12 Expert Report of Dr J.P. Giesy, Ph.D. on Behalf of the Defendants in
Arias/Quinteros v. Dyncorp, Jan. 2011. ...........................433

Annex 13 Expert Report of Dr R.D. Smalligan, M.D., M.P.H., prepared for the
Defendants in Arias/Quinteros v. Dyncorp (D.D.C.), Jan. 2011. .......465

Annex 14 Expert Report of Dr R.C. Ploetz, Ph.D. on Behalf of the Defendants
in Arias/Quinteros v. Dyncorp, Jan. 2011. .........................503

Annex 15 Expert Report of Dr R.I. Krieger, Ph.D. prepared for the Defendants

in Arias/Quinteros v. Dyncorp (D.D.C.), Jan. 2011...................545

Annex 16 Expert Report of Dr G.M. Williams, M.D. on Behalf of the
Defendants in Arias/Quinteros v. Dyncorp, Jan. 2011.................571

COLOMBIAN OFFICIALDOCUMENTS

Annex 17 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
by theAnti-Narcotics Directorate of the Colombian National Police

(DIRAN),Results of the Breaking Point and Historical Management
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. .............583

Annex 18 Anti-Narcotics Directorate of the Colombian National Police

(DIRAN), Eradication of Illicit Crops Division, Analysis of Certain
Spraying Operational Aspects, Oct. 2011: .........................587

I. Analysis of time records
II. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
III. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
IV. Spraying data and witness statements confronted

Annex 19 ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
(IDEAM), Climate Characterization of the Nariño and Putumayo
Border Zone with Ecuador, Dec. 2011. ..........................693

iv Annex 1

DR A.J. HEWIT, PH.D., ESPONSE TREPORT “SPRAYDRIFTM ODELING OF
CONDITIONS OAPPLICATION FOCOCAC ROPS ICOLOMBIA BYD.K. GILE,

JAN. 2011”, OVEMBER 2011

12 Annex 1

Response toCrops in Colombia” by D.K. GilesConditions of Application for Coca

Andrew Hewitt, Ph.D.

Table of Contents
Page

This report contains 30 pages
Title Page .....................................................................................................................1
1

Table of Contents...............................................................................................................2

▯▯▯▯▯▯▯ .....................................................................................................................3

▯▯▯▯▯▯▯▯▯▯▯▯ .....................................................................................................................3

AGDISP ....................................................................................................................5

Canopy ....................................................................................................................5

Evaporation Rate................................................................................................................7

Application Rate ................................................................................................................7

Atmospheric Stability........................................................................................................9

Wind Speed ....................................................................................................................9

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.....................................................................10

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯........................................................................................................10

Additional Factors that Exacerbate Drift.........................................................................12

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.......................................................................................12

▯▯▯▯▯▯▯▯▯▯▯ ..................................................................................................................13

Appendix 1 Curriculum vitae for Dr Andrew Hewitt....................................................15

3Annex 1

Summary

1. This report provides a response to a repor t prepared by D.K. Giles titled “Spray
Drift Modeling of Conditions of Application for Coca Crops in Colombia”, as well as

reports cited in the Giles report.

2. The Giles report ignores the most important variable in the present scenario which
is closer to forest spraying than to sp ray applications over low cr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯–
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
These vegetation ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ring media for airborne
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯de minimis levels within a few ▯▯▯▯▯▯▯▯meters of
the applications. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯to ▯▯▯▯▯▯▯that represent de minimis
drift, i.e. <0.7 g/ha at a distance of 800 m from spraying 10 swaths with width of 50 m
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ from the sprayed area.
▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, which means that most of the time, any spray drift
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Introduction

3. This report has been prepared by Dr Andrew Hewitt, who directs spray drift
research and modeling programs at the Centre for Pesticide Application and Safety at the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ealand
and Canada. Dr Hewitt has over 2 decades of experience in spray drift management,
research, modeling, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, New
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯roject
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯TM▯▯▯▯▯▯▯▯▯▯▯▯▯ (www.agdrift.com).
He is one of the developers of the AgDRIFT ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯initial technical advisor to EPA on an extensive drift
re▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯As a Science Fellow, he advises the
▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ spray drift
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ers
on spray application technology and drift management, he serves as Chair for

international society committees relating to spray drift. His curriculum vitae ▯▯▯▯▯▯▯▯▯▯▯▯
in Appendix 1.

4. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ involving the

movement of droplets of pesticide at the time of spray application to an off-target site. It

4 Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯at levels of concern for affecting people, animals,
wildlife and other sensitive organisms.

5. Extensive res▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

are well-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of meteo▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

6. The present report addresses off-targe t ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ aerial
applications of glyphosate to coca crops in Co lombia in response to a report prepared by
D. K. Giles, “Spray Drift Modeling of C onditions of Application for Coca Crops in

Colombia”. The report has been prepared based on ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
applications r▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ served as a member of a science
advisory team for the Inter-▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯atomisation as it relates to the potential

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯PECIG. The
research findings were presented in peer-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Solomon, and E.J.P. Marshall, 2009, Spray Drop let Size, Drift Po▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Nontarget Organisms from Aerially Applied Glyphosate for Coca Control in Colombia,
▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯-929). This paper

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯t modeling of
spray dispersion for generic scenarios applicable to aerial applications in Colombia. Giles
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7. ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ Giles presents several factors which can
increase spray drift potential above safe levels. These factors were stated to be as follows:

x Higher aircraft flight speeds than pres cribed in the Colombian Environmental

Management Plan (EMP);
x Greater aircraft heights than prescribed in the EMP;
x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯et al (2009));
x Stable atmospheric conditions from night spraying, and

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

T▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯
AGDISP version 8.25 spray transport/ deposition model.

8. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯etected at distances downwind of the release.
However, for spray drift of pesticides a nd herbicides, the deposition rates downwind of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

5Annex 1

of interest. For glyphosate, the level of concern is 1368 g/ha for amphibians and 36-1958
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯et al (2009): “Hewitt,
A.J., Solomon, K.R. and Marshall, E.J.P. ( 2009). Spray droplet size, drift potential, and

▯▯▯▯▯▯ ▯▯▯ ▯▯▯-target organisms from aerially-applied glyphosate for coca control in
▯▯▯▯▯▯▯▯▯ J. Toxicology and Env. Health, Part A, 72, 921-929”▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the PECIG
program which is the Program for the Eradication of Illicit Crops by Aerial Spraying with

Glyphosate.

AGDISP

9. AGDISP is a widely accepted model for spray drift modeling at near-field
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯performs

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-predict spray drift relative to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-prediction level
of approximately 4 x field data by 800 m downwind. This over-prediction was described
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯: “Bird,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯GDISP aerial
spray algorithms in the AgDRIFT model, Environmental Toxicology and Chemistry
21(3), pp. 672-81”. Hence AGDISP predictions ar e considered to be environmentally-
conservative at far-▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

10. AGDISP is the engine for several other spray drift models, the most notable of
which is AgDRIFT TM▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-operative research and development

between the US Environmental Protection Agency (“EPA”▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Forest Service (“FS”▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯“SDTF”). Hewitt was one of the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ TM ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tion is presented
▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯

Development of the AgDRIFT Model for Aerial Application from Helicopters and
Fixed-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯pp. 3-6. If the same
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ TM , the model predictions will be the same.
TM
However, the presence o▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ allows end-
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, with AgDRIFTTM
libraries providing ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

Canopy

11. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
airborne droplets, thereby preventing their off-target movement as drift. The report
▯▯▯▯▯▯▯s that droplet size was probably in the order of 128 μm, based ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯

6 Annex 1

mixes. Interestingly, t▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

type, p▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
foliage involve droplets with average diam eter somewhere between 50 and 150 μm
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯droplet sizes. 1

12. Giles ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ in the initial
sensitivity analyses sections of his report ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯30 to 65 meters, with an approximate average
height in the order of 32.5 m based on th e Hansman and Mena Re port (ER Annex 1, p.
10), where it is stated that “T▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-Colombia

border region is in the range of 30 to 35 metres. Emergent trees may2extend even higher,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

13. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯that the initial spray release ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, there
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
strips of ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

clearings and taller trees/ ve getation▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
across the entire area between the spray applications and sensitive areas downwind
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ a ▯▯▯▯▯▯of approximately 30% of the average tree height, i.e., 10 m. Once

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯n the
▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 3

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ both sides,
any airborne spray drift will be intercepted by canopy downwind of the spray release.

14. Similarly, assessments by Giles of the eff ect of aircraft height on spray drift have
ignored the significant canopy downwind of the spray applications whic▯▯ ▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

15. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ vegetation for intercepting spray drift with
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. 4

1
See Matthews, G.A. (2000) Pesticide Application Methods ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
pages. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2The Balslev article is contained in an Annex for t▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
3See ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(2008) First direct landscape-sca▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-172; A.-L. C. McWilliam, J. M. Roberts, O. M. R.
Cabral, M. V. B. R. Leitao, A. C. L. de Costa, G. T. Maitelli and C.A. G. P. Zamparoni (1993) Leaf area
index and above-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯terra firme ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Ecology 7, 310-317.
4See ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, H.A. (2001) The Entrapment of Particles
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Atmospheric Environment.; ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7Annex 1

Evaporation Rate

16. On page 7 of his report, Giles ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯n large droplets and
that this increases spray drift is an over-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
rate, proportion of non-vo latile materials in the spray (b asically most components other
▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ If a droplet does

experience complete loss of all of its vol atile components by evaporation prior to
deposition, its final size will depend on the proportion of th e contents which were non-
▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯
atmosphere to tiny (de minimis▯▯▯▯▯▯▯▯▯▯▯The Giles report presents a sensitivity analysis

for evaporation rate effects on drift potentia l (page 26). However, the implication that
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
rate might be closer to that of water (84 μ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ et
al ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯et al (2009) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
TM
for glyphosate in the spray material library in AgDRIFT . The spray material libraries
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Laboratory Practice Standards (“GLPS”▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and Scientific Advisory Panel review by EPA, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯
prediction of pesticide drift as in this assessment.

Application Rate

17. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ applied in PECIG is higher than assessed
in the Hewitt et al (2009) paper. On page 25 of his re port, a table is presented showing

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
higher rates between 20 and 28 L/ ha. Application rates for sprays applied by aircraft can
be described by the total a pplicati▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
mix, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

application r▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯~680
L/min total flow rate for a swath width of ~▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯~93 m/s
for the OV-10▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and▯▯▯▯▯▯▯▯▯▯▯. DNRQ 97088; www.agdrift.com/PDF_FILES/drift%20filtration.PDF

8 Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
AGDIS▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

18. In this example, the spray ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, of which approximately one
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

or no difference in drift from applicatio▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in PECIG. Hence the Hewitt et al
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯PECIG
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

9Annex 1

Atmospheric Stability

19. Page 27 and pages 42-44 of the Giles report consider atmospheric stability classes
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯et al (2009). However,
there is no ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
stable air existing at the same time ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯
presence o▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯ ▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

20. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
– ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e morning low or
decreased by less than 3▯C ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
applications when inversions exist. They may also ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
wind speed above 2 ▯▯▯h.

21. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

are only of concern if their height is similar to that of the spray release height, in other
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯The normal daily cycle of heating and cooling
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(e.g. before 5 to 6 a.m.) and again in the evening. Based on ▯▯▯▯ ▯▯▯▯▯▯▯▯ personal
experience of aerial spraying of bananas in the tropics (Costa Rica and the Philippines),

by 7 a.m., the wind will have typically in creased above 3 ▯m/h to provide mixing and
▯▯▯▯▯▯▯e atmospheric conditions appropriate for safe spraying. The 3 ▯▯▯h wind speed
▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

the wind speed is very low.

22. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯ore
concentrated rather than dispersed. However, if this drift is to be carried downwind, then

Wind Speed

23. ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯
atmosphere is stable and to select a high wind speed for modeling spray drift potential

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Near-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
to increase, with the Giles report showing a relationship that is close to linear. However,

10 Annex 1

when more appr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-range modeling, the
relationship between wind speed and deposition of drifting particles is not the same.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
stability clas▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯far-field
distances.

Illustrative Example Application Scenarios

24. On pages 30-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

several applications: a) spraying near low vegetation with strong wind, and b) spraying at
increased height and speed with strong wind. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the order of 5-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
downwind. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯re below the le vels of concern for sensitive areas, the
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ filters ▯▯▯▯▯▯▯▯
airborne drift rapidly after its releas e. ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
spraying by the US Forest Service and its co- operators. Trees are very effective filters of

droplets of diameter 100-1▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
winds is not appli▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯

impaction. In scenario b), which involves sprayi ng at increased height with strong wind,
any displacement of the spray swath by the wind will see the applied herbicide droplets
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-target drift beyond a few tens of meters.

Multiple Spray Lines

25. On pages 34-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Giles from his analyses were in this secti on of the report, the present assessment re-
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a
32.5 m tall ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
height of 10 m, with a single 18 m swath as in the Giles assessment. However, for more

representative assessment of ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, the swath width was set to 50 m with
50 m separation distance between swaths – i .e. the model ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
data from each swath by 50 m as in the Gile s report)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
as in the Giles report (i.e. 59.54 m air craft ▯▯▯▯▯▯▯▯▯▯▯38.51 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ wind

speed, 23.65 L/ha ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯). It is important to note that, contrary to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
same spray event is not repeated in the spray data from the Department of State (there

11Annex 1

26. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

27. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯new ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯5 of the Giles report ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

No. Dep. Dep. Dep. Dep. Dep. Dep. Dep. Dep.
spray 800m 800 m ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯
lines Giles New Giles New Giles New Giles New
1 18 0.08 5 0.03 2 0.01 1 0.006
10 130 0.67 42 0.26 16 0.12 8 0.057

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯from 100 to 1000 m
downwind of spray release, in 100 m increments.

12 Annex 1

28. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯with 10 spray lines are also very low – i.e. 0.18 g/ha at 800
m falling to 0.005 g/ha ▯▯▯▯▯▯▯▯▯downwind for a single swath assessment. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯0.16 and 0.02 g/ha. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

are so low that they can be considered as de minimis drift.

Additional Factors that Exacerbate Drift

29. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯et
al ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ PECIG – sent from Colombia to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-42

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and there
▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯-▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Colombia’s Spray Drift Studies

30. Pages 44-46 of the Giles ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Colombian application sce▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

13Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
an overly simplified analysis of spray drif t potential, ignoring canopy interception and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ve papers
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
assessed) and laboratory analysis for depos ition rates. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
speeds of two of the aircraft that have bee▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the Colombian National Police, 3 aircraft have

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

The T-65 aircraft, with speeds of 193-▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
droplet size >219 μm▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯late 2007.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Droplet size at
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

The AT 802 aircraft with an average speed of 203 ▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯>▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the Program.

31. It has been asserted by ▯▯▯▯▯▯▯▯with respect to higher aircraft speeds ▯▯▯▯▯▯▯▯▯▯▯

violations of the speed limit have a dramatic impact on spray drift.” However, aircraft
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a parameter in
the EMP. According to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯

Hansman and Mena, as follows: “If the spray aircraft airspeed is too high, the droplets
from the spray noz▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯ere can be lower deposition at far-field distances. This was corroborated by the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, in all of which deposition was
insignificant.

Conclusions

32. The Giles report presents some interesting scenarios for ▯▯▯▯▯ing the sensitivity of
spray drift to a range of variables associated with the application of sprays by aircraft.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯resent in

Colombia which will act as an efficient filter of any airborne droplets that do not deposit
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-10 spray droplet size in PECIG of
~128 μm is optimal for interception by foliage of which there is plenty in this forested
and vegetated area of Colombia. When the canopy is appropriately entered into the

14 Annex 1

15Annex 1

Appendix 1

Curriculum Vitae for Andrew Hewitt

16 Annex 1

NAME: Andrew Hewitt

ADDRESS: ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

EDUCATION:

1988-1991 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯with air-
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1986-1987 Cranfield University, U.K. M.Sc. Bio-▯▯▯▯▯▯▯▯▯▯▯ (crop protection, space
spraying, forest protection and remote sensing).

1982-1985 University of Sheffield, U.K. B.Sc. Hons. Nat. Environmental Science (plant
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

WORK EXPERIENCE:

2004-present Director, Centre for Pesticide Application and Safety, University of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
transport, deposition, environmental fate, optimization and efficacy for

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
facilities for spray research. Field and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nd Canada),
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Advisor on PECIG aerial narcotics eradication program (to US State Dept. and
government of Colombia).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
research and collaboration in science.

Head of Delegation to International Standards Organisation on ag. standards.

ASABE, Chair of technical committees of several international societies,
organizer of several internation▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

17Annex 1

government).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1993-2004 Emplo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-ordinated and facilitated SDTF
activities, data analysis and report preparation. Official representative of SDTF
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯etings (e.g. Spray Drift Conference
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
tech▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-ordinated SDTF interaction with
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ning sessions for AgDRIFT spray
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
herbicide drift and lift-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for drift
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

invited presentations on spray application technology/ drift minimization/ spray
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ng the National Coalition on Drift Minimization
(NCODM); ILASS; ASAE, ASTM; AAPSE; NAAA; BCPC; National Spray
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-time
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

drift control ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
standard test methods. EU grant to develop single international database on
spray drift.

1991-1993 Research Specialist, New Mexico State University - projects assessing droplet

size spectr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
U.S., U.K. and Canada. Preparation of grant proposals and final reports for
EPA, PWG, SDTF, chemical companies and others; active research as
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1991 Res▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
spraying research for Schering Agrochemicals Ltd.

1990 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
armyworm control in Kenya with ODA NRI, FAO of the United Nations &

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯- ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

18 Annex 1

1989 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Trypanosomiasis Control Project spraying operations.

1988 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯teorological data.

1988-1991 Research Assistant with International Pesticide Appln. Research Center at
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
controlled droplet sizes, for the ODA NRI Armyworm Project and the Aerosol

Tech▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
The Aerosol Society. Also attendance at agric▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
chemical companies on application projects.

1987-1988 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯h spray applications to bananas,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

OTHER: Associate Editor, TRANSACTIONS of the American Society of Agricultural and
Biological Engineers, Member of Editorial Board, Atomization and Sprays,
and Journal of ASTM International. Joint ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Biological Sprays Committee. Former member, ILASS-Americas Board of
Directors. Chair and organizer of three International Conferences on Pesticide
Application for Spray Drift ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
committee on development of droplet size classification standards. Former
Head of Delegation for the U.S. at ISO meetings on spray drift and application
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

for the program. Member of USDA Forest Service committee for modeling.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
conference proceedings. Member, OECD drift committee.

SKILLS: ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
SDTF AgDRIFT model. Excellent Spanish, French & German. Certified in
Good Laboratory Practice Standards. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

laser particle size analyzers. Operation of meteorological stations. Active
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
developments.

19Annex 1

SELECTED PUBLICATIONS:

Hewitt, A.J. (2010) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Hewitt, A.J. (2010) Tracer and Collector Systems for Field Deposition Research. Aspects of

Applied Biology 99, International Advances in Pesticide Application, 283-289.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Fritz, B.K., Hoffmann, W▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
J.W., Hewitt, A. (2010) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯7, 1-14. JAI102775

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
within a Riparian Management Area. Forests and People, SAF National Convention▯▯▯▯▯▯▯▯▯▯▯▯▯▯
New Mexico, USA.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Conference, San Francisco, California.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Science Society of America, Denver, Colorado.

Fritz, B., Hoffmann, W.C., Birchfield, N., Ellen▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Hewitt, A.J. (2010) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and Aerial Application Systems. Proc. ASTM 31st Symposium on Pesticide Formulations and
Delivery Systems: Innovative Green Chemistries for the 21st Century, San Antonio, Texas, USA.

Hewitt, A. J. (2010) Invited Talk – ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ASTM 31st
Symposium on Pesticide Formulations and Delivery Systems: Innovative Green Chemistries for
the 21st Century, San Antonio, Texas, USA.

Hoffmann, W.C., Fritz, B. and Hewitt, A.J. (2010) Development and Testing of an Aerial
Application Standardized Spray System. Proc. ASTM 31st Symposium on Pesticide Formulations
and Delivery Systems: Innovative Green Chemistries for the 21st Century, San Antonio, Texas.

Hoffmann, W.C., Fritz, B., Hewitt, A.J. and Bagley, W. (2010) Effects of Air Speed and L▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ASTM 31st
Symposium on Pesticide Formulations and Delivery Systems: Innovative Green Chemistries for
the 21st Century, San Antonio, Texas, USA.

Thistle, H.W., Ice, G.G., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Applied Spray to a Stream within a Vegetative Barrier. TRANS of the ASABE 52(5), 1481-90.

20 Annex 1

Connell, R.J., Hewitt, A.J., Wolf, T. and Miller, P.C.H. (2009) WTDISP – Adapting a Lagrangian
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ World IMACS/ MODSIM Congress,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Spray Drift G▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Proc. International Conference on Liquid Atomisation and Spray Systems, Vail, Colorado.

Hewitt, A.J., Solomon, K.R. and Marshall, E.J.P. (2009). Spray droplet size, drift potential, and
▯▯▯▯▯▯▯▯▯▯▯▯-target organisms from aerially-applied glyphosate for coca control in Colombia. J.

Toxicology and Env. Health, Part A, 72, 921-929.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. Conf. American Society for
Testing and Materials, Miami, Florida.

Hoffmann, W.C., Hewitt, A.J., Ross, J.B., Bagley, W.E., Martin, D.E., Fritz, B.K. (2008) Spray
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-based systems. Journal of ASTM
International. 5(6): Paper ID JAI101233

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Aspects of
Applied Biology 84, 73-82.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
variables–I. The Environmentalist 28 (1), 25-30.

Hewitt, A.J. (2008) Droplet size spectra classification categories in aerial application scenarios.

Crop Protection 27 (9), 1284-88.

Hewitt, A.J. (2008) Spray Drift Minimisation Technologies in Forestry. Proc. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

th
Hewitt, A.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Annual Pesticide
Stewardship Conference, Asheville, NC, USA.

Hewitt, A.J. (2008) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯-Specific Models for Label Compliance. ▯▯▯▯▯▯ Annual Pesticide Stewardship
Conference, Asheville, NC, USA.

Hewitt, A.J. (2008th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Sprayers. ▯▯▯▯▯▯ Annual Pesticide Stewardship Conference, Asheville, NC, USA.

Hoffmann, W.C., Hewitt, A.J., Ross, J.B., Bagley, W.E., Martin, D.E. and Fritz, B.K. (2008)

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Three Laser-Based Systems in a
High-Speed Wind ▯▯▯▯▯▯. J. ASTM International 5 (6).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Functional Plant Biology 35 (10), 988 - 996

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, N. and Hewitt, A.J. (2006) Development of a Test Plan to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASABE Annual Meeting,

Portland, Oregon, USA.

21Annex 1

Thistle, H., Reardon, R., ▯▯▯▯▯▯▯M., Richardson, B., Cormier, G., Davies, D., Cameron, S.,
Hewitt, A., LeClerc, M. and Karipot, A. (2005) Variability in Spray Application and Utilization
of a Time Varying Model. Annual Review of Agricultural Engineering, 4(1), 187-96.

Hoffmann, W.C. and Hewitt, A.J. (2005) Comparison of Three Imaging Systems for Water-
Sensitive Papers. Applied Engineering in Agriculture 21, 961-964

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
www.oecd.org/dataoecd/48/44/37237952.pdf

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯(2005) Rotary
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Transactions of the American Society of Agricultural

Engineers. 48(3), 917-921.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯H.W., Reardon, R., Cormier, G., ▯▯▯▯▯▯▯▯▯▯P., Davies, D., Cameron, S.,
Dorr, G., Hewitt, A.J., Brown, J., LeClerc, M. and Karipot, A. (2005) Aerial Application

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Symposi▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
F▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, Journal of the American Society of Testing and Materials
International. 2 (4).

Hewitt, A.J., Wolf, T., Woods, N., Ganzelmeier, H., Miller, P.C.H., and Van de Zande, J. (2004)
An International Database/ Model on Pesticide Drift. Aspects of Applied Biology 71,
International Advances in Pesticide Application.

Hewitt, A.J., Woods, N., Ross, J. and Hornby, J. (2004) Comparisons of Droplet Sizing
th
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ILASS Americas, 14
Annual Conference on Liquid Atomization and Spray Systems, Washington, D.C.

Hewitt, A.J. (2004) Spray Drift Management, Proc. International Symposium on Adjuvants for

Agrochemicals, Cape Town, South Africa.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. International
Conference on Pesticide Application and Drift Management, Kona, HI.

Hewitt, A.J. (2004), Atomization Models Proc. International Conference on Pesticide
Application and Drift Management, Kona, HI.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. International Conference on

Pesticide Application and Drift Management, Kona, HI.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Spray Research, Proc. ASTM Conference on Application and Formulation Systems, Washington,

D.C.

Hewitt, A.J. International Activities in Spray Drift Management (2004) Conference of the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Hoffmann, W.C. and Hewitt, A.J. (2004) Comparison of Droplet Imaging Systems for Water
Sensitive Cards. Aspects of Applied Biology 71, International Advances in Pesticide Application.

22 Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE paper No. AA03-006, ASAE/ NAAA Technical Session, Reno, NV.

Hewitt, A.J. Hoffmann, W.C., Barber, J.A.S., Brown, J.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE paper No. AA03-006, ASAE/ NAAA
Technical Session, Reno, NV.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Drift Ana▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE paper No. AA03-007, ASAE/ NAAA Technical Session, Reno,
NV.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Aspects. Proc. Third Latin American Symposium on Agricultural Adjuvants, Sao Paolo, Brazil.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯24 Symposium on Pesticide Formulations and Application Systems: The
Continued Evolution of Agrochemical Formulations and Delivery Systems, Tampa, FL.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Evaporation Corrections For Aerial Spray Drift Modeling. I: Theoretical Considerations.
Atomization and Sprays Vol. 13, 243-50.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Control. Proc. 69 Annual Meeting American Mosquito Control Association, Minneapolis, MN.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯omizer Droplet Size
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ICLASS-2003, Italy.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
in Determining Droplet Size Spectra for Forest Spraying. Proc. ILASS-Americas, Monterey, CA.

Hewitt, A.J. (2003) Drift Minimization in Forest Vegetation Management. Forest Vegetation
Management Symposium, Redding, CA.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Dorr, A. He▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯24 Symposium on Pesticide Formulations and
Application Systems: The Continued Evolution of Agrochemical Formulations and Delivery
Systems, Tampa, FL.

Thistle, H., Reardon, R., Dorr, G., LeClerc, M., Karipot, A., Brown, J., Cameron, S., Davies, D.,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Atmospheres: Field Trial Data. ASAE paper 031091, ASAE Convention, Las Vegas, NV.

23Annex 1

Hewitt, A.J. (2002) The Practical Use of AgDRIFT® and Other Drift Exposure Models for
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-19.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯M.E. and Thistle, H.E. (2001) The Development of the AgDRIFT Model for
Aerial Application from Helicopters and Fixed-Wing Aircraft, Australian Journal of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-6.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Residue
Analytical Methods Handbook for Agrochemicals, Volume I John Wiley and Sons, Inc.,
Chichester, UK.

Hewitt, A.J., Dexter, R.E. (2002) Aerial Applications of Herbicides Using Low Drift Nozzles and
▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. NAAA/ ASAE Conference, Reno, NV.

Hewitt, A.J. (2002) Factors Affecting Spray Drift. Encyclopedia of Agriculture, Food and
Biological Engineering▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Devel▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Environmental Toxicology and Chemistry. 21(3), 648-58.

Sprays vol. 12, 267-281.

Hewitt, A.J. (2002) Atomization Characteristic▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc.
American Mosquito Control Association Annual Conference, Denver, CO.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Atomizers Proc. Amer. Mosquito Control Assoc. Annual Conference, Denver, CO.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Spray Performance. Paper presented at ASAE Annual Meetings, Chicago, IL.

Hewitt, A.J., Jany, W., Dorr, G. and N. Woods (2002) Droplet Size Spectra from Rotary
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ILASS-Americas, Madison, WI.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯hysical
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ILASS-Europe 2002, Zarazoga, Spain.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Atomizers. Spray Efficacy Research Group Conference, Niagara Falls, Canada.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ILASS-Europe 2002, Zarazoga, Spain.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Parasitica vol. 57 (1-2-
3), 33-38. ISSN 0031 – 1812.

24 Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
NAAA/ ASAE Paper No. AA01-004. Las Vegas, NV.

Hewitt, A.J. (2001) Response to EPA’s Draft PR Notice ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
NAAA/ ASAE Paper No. AA01-007. Las Vegas, NV.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

NAAA/ ASAE Paper No. AA01-001. Las Vegas, NV.

Hewitt, A.J., Miller, P.C.H., Dexter, R.W. and Bagley, W.E. (2001) Invited presentation, The
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯International Symposium on Adjuvants for Agrochemicals, Amsterdam,
Netherlands.

Hewitt, A.J. (2001) Invited presentation, The Practical Use of AgDRIFT® and Other Drift

Exposure Models for Aerial, Ground and Orchard Spray Applications, Conference on Pesticide
Drift, Canberra, Australia, February 11, 2001.

Hew▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Invited presentation, The Development of the

AgDRIFT Model for Aerial Application from Helicopters and Fixed-Wing Aircraft, Conference
on Pesticide Drift, Canberra, Australia, February 11, 2001.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Physical Property Variables, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
effects by means of new methods” 2 International in-depth symposium OpdenKamp R&N, The
Hague, Netherlands.

st
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-
Royal Research Station of Gorsem “Crop Protection Efficiency in Fruit Growing and Its Impact
on Environment and Legislation”, Sint-Trinden, Belgium.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Phytoparasitica, Developments in International
Harmonization of Pesticide Drift Management, Vol. 29, no. 2.

Hewitt, A.J., Maber, J. and Praat, J.P. (2001) Drift Management Using Modeling and GIS
Systems, World Congress of Computers in Agriculture and Natural Resources▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Brazil.

Maber, J., Dewar, P., Praat, J.P. and Hewitt, A.J. (2001) Real Time Spray Drift Prediction, Proc.
IT Symposium, New Zealand.

Miller, P.C.H., Hewitt, A. J. and Bagley, W.E. (2001) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and Drift Potential Pesticide Formulations and Applications Systems: Twenty First Volume,
ASTM STP, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯n, PA.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯(2001) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Pesticide Formulations and Applications Systems: Twenty
First Volume, ASTM STP, American Society for Testing and Materials, West ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

25Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Evaporation Corrections For Aerial Spray Drift Modeling, Proc. ILASS-Americas 2001,
Dearborn, Michigan.

Hewitt, A.J., Miller, P.C.H. and Bagley, W.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Sacaramento, CA.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯American

Mosquito Control Association Annual Meeting, Dallas, TX.

Hewitt, A.J. (2000) Spray Drift Modeling, Management and Labeling in the U.S. Aspects of
Applied Biology Vol. 57, pp. 11-20.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Crop
Protection Vol. 19, pp. 623 – 627.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE Paper,

NAAA/ ASAE Technical Session, Reno, Nevada.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Potential, ASAE Paper No. A00-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯for Nozzle Emission
Spectra in Drift Mitigation, ASAE paper no. 001049, Milwaukee, WI.

from PMS Optical Array Probe. Eighth International Conference on Liquid Atomization and
Spray Systems, Pasadena, CA. Peer-reviewed 8-page paper.

preliminary analytical model, ASAE Paper No. 001112, Milwaukee, WI.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
characteristics. Eighth International Conference on Liquid Atomization and Spray Systems,
Pasadena, CA, pp. 349-53. Peer-reviewed 8-page paper.

Hewitt, A.J▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Proc. 53 New Zealand Plant Protection Society Conference, Christchurch, New Zealand.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Field
Applications, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Hewitt, A.J. (2000) Invited presentation, AgDRIFT®: Applied Modeling Tool for Aerial

Spraying. Proc. Annual Gypsy Moth Review, Norfolk, VA.

Hewitt, A.J. (2000) Invited presentation, Spray Application and Drift Management, CPDA North
American Adjuvant Conference, Washington, D.C.

Hewitt, A.J. (2000) Invited presentation, Spray Drift Modelling, Labelling and Management in
the U.S. Association of Applied Biologists Conference on Pesticide Application, Guildford, UK.

26 Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
California Agricultural Aviation Association Annual Conference, Ontario, CA.

Hewitt, A.J. (1999) Invited presentation, “International Spray D▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
International Plant Protection Congress, Jerusalem.

rd
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯3 North
American Conference on Adjuvants and Inerts, CPDA, Alexandria, VA.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯United Nations

International Development Organization International Conference on Pesticide Chemistry,
Nantong, China.

Hewitt, A.J., Valcore, D.L. and Barry, T. (1999) Analyses of E▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
th
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯20 Symposium on
Pesticide Formulations and Application Systems, American Society for Testing and Materials,
New Orleans.

Hewitt, A.J. and Valcore, D.L. (1999) Drift Management: Why Reading and Following the Label
is Worthwhile, ASAE paper presented at NAAA/ ASAE session, Reno, NV.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE

paper, NAAA/ ASAE technical session, Reno, NV.

Hewitt, A.J., Valcore, D.L. and Barry, T. (1999) The effect of droplet size and other variables on
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE paper No. 991010, Toronto, Canada.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ILASS-Americas, Indianapolis, IN.

Hewitt, A.J. and Valcore, D.L. (1998) Nozzle Selection and Use for Effective Spray Application
and Drift Minimization. ASAE Paper presented at Joint NAAA/ ASAE Technical Session, Las
Vegas, NV.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Fifth International Symposium on Adjuvants for Agrochemicals, August 17-21, Memphis, TN.

Hewitt, A.J. (1998) Spray Drift Management in the U.S. Invited Presentation, Association of
Applied Biologists Symposium on Spray Drift, Silsoe, U.K.

Hewitt, A.J., Stern, A.J., Bagley, W.E. and Dexter, R. (1999), The Formation of A New ASTM
th
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯19 Symposium on Pesticide
Formulations and Applications Systems: Global Pest Control Formulations for the Next
Millennium, ASTM STP 1373, R. S. Tann, J. D. Nalewaja, and A. Viets, Eds., American Society
for Testing and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯American Society for Testing and Materials
E35.22 Annual Symposium on Pesticide Formulation and Application Systems, Norfolk, VA.

27Annex 1

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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ILASS-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Hewitt, A.J. (1998) Nozzles/ Droplets Effects on Drift. Proc. North American Conference on
Pesticide Spray Drift Management, Portland, ME.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE

Paper presented at NAAA/ ASAE Symposium, Las Vegas, NV.

Hewitt, A. J. (1997) The Importance of Droplet ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Atomization &
Sprays Vol. 7 (3), pp. 235-244.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Scenarios With the AgDRIFT Model. ASAE Paper No. 971073, Minneapolis, MN.

Hewitt, A.J▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ILASS-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (peer

reviewed extended abstract).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯id Properties on Spray Performance. Proc.
Chem Show▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Hewitt, A.J. (1997) The International (BCPC) Spray Classificatio▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Potential Factor. Proc. Br. Crop Prot. Conf. Vol. 5A-I, pp. 371-380 (peer reviewed extended
abstract).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(1997) Statistical Comparison of PMS and Malvern Using Glass Beads Under Static Conditions.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, 21 (peer reviewed
extended abstract).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ation
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯PROC ILASS-Americas 96, San Francisco, CA (peer
reviewed extended abstract).

Hewitt, A. J., Valcore, D. L. and Bryant, J. E. (1996) Nozzle and Application Parameter Effects
on Droplet Size and Use of Spray Classification Schemes. ASAE Paper AA96-003.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Proc. ILASS-95, Detroit, MI (peer reviewed extended abstract).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Spect▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASAE Paper No. 95-

1299, ASAE, St. Joseph, MI 49085.

28 Annex 1

Hewitt, A.J. (1994) ILASS Inter-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. ICLASS-94, Rouen, France (peer reviewed
extended abstract).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Atomization Droplet Size Spectra Using Laser Diffraction Particle Size Analyzers in Wind

▯▯▯▯▯▯▯▯▯Proc ILASS-94, Seattle, WA.

B, 815-830. also in Proc. Symp. Entomol. Socs. of Canada & Ontario ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Entomol. Societies of Canada & Ontario (1993 Symposium, Sault Ste. Marie).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Other Variables Affect "Fines". ASAE Paper 93002.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Maize Canopies for the Control of Spodoptera exempta Larvae. Crop Protection Vol. 12(1), pp.
59-62.

Apodaca, M.A., Sanderson, R., Hewitt, A.J., Ort▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

(1993) Statistical Comparison of Droplet Size Spectra. Proc. 6th. ILASS Conf. Liquid Atomization
& Spraying Systems, Worcester, MA, pp. 73-78.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-assisted atomizers. Journal of Aerosol

Science Vol. 24 (2), pp. 155-162.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Drop Size & Drift Potential of Aerial Sprays. Proc.Ent.Soc.Amer. Albuquerque, NM.

Hewitt, A.J▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Pesticide Science Vol. 37, pp. 209-211.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Ross, J.B. (1993)
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Additives on Droplet Size & Drift Potential of Aerial Sprays. Proc. BCPC Conf., UK.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ss,J.B. & Hewitt,A.J.(1993)"Broom
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Snakeweed Research, NM Agric. Exp. Station.

29Annex 1

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

& Drift Potential. ASAE Paper 931103.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Crop Protection Vol. 11 (3), pp. 221-224.

Sanders▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ASTM E35 Symposium, Miami.

Hewitt▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Mistblowers. Air-Assisted Spraying In Crop Protection, BCPC Monograph Vol. 46, pp. 271.

Hewitt, A.J. & Matthews, G.A. (1991) Some Aspects of Rotary Atomizer Performance.
Proc.ILASS Sprays And Aerosols, pp. 200-206 (peer reviewed extended abstract).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-Assisted Rotary Atomizers for Pesticide Application Ph.D.
Thesis, Imperial College, London University, 260 pp.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Ross, J.B., Hewitt, A.J. & Bartee, S.M. (1991) Comparison of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯ASAE Paper AA91-▯▯▯.

Hewitt, A.J.& Senior,D.A.(1989) Development of Air-Assisted Controlled Droplet Atomizers for
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Proc. IUPAC Int. Con. Pest. Chem., Hamburg

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

SELECTED REPORTS TO EPA:

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
in Chemigation. SDTF Report No. A93-007, MRID No.43845501

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Particle Size An▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-001, EPA MRID No. 43485603

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Trial Conditions. SDTF Report No. A92-005, MRID No.43657601

Hewitt, A.J. (1995) Spray Dri▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-002, MRID No. 43757801

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯s: 1993 Field Trial Conditions. SDTF Report No. A93-008, MRID No. 43757802

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-001, MRID No. 43766501

Hewitt, A.J. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Ingredients. SDTF Report No. A92-004, MRID No.43766502

30 Annex 1

Hewitt, A.J. (1995) String Collectors for Assessing Spray Drift, SDTF Report No. T95-003,

MRID No. 43766503

Hewitt, A.J. (1996) Atomization Droplet Size Spectra for Airblast Sprayers. SDTF Report No.
A95-009, MRID No. 43953001

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Physical Property Parameter Characterization. SDTF Report No. A92-003, MRID No. 44100901

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

A95-010, MRID No. 44310401.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Atomization: ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-003, MRID No. 44747401.

Hewitt, A.J. (1999) Error Bars, Precision and Bias of Data for SDTF Aerial Field and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-002, MRID No. 44696901.

Hewitt, A.J. (1999) Collection Efficiency of Spray Drift Samplers. SDTF Report No. T98-006,
MRID No.44641001.

Hewitt, A.J. (1999) Nozzle and Spray Classification. SDTF Report No. R97-003, MRID No.
44640801.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯8-005,

MRID No. 44640901.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Report T99-006.

▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3132 Annex 2

DR A.J. EWITT, H.D., ERIALSPRAYD RIFM ODELING OP LAN
C OLOMBIAAPPLICATIO, NOVEMBER2011

3334 Annex 2

Aerial Spray Drift Modeling of Plan Colombia Applications
by Andrew J. Hewitt

Executive Summary

1. This is a▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ report presenting the modeling of spray drift from specific
aerial applications of relevance to the Plan Colombia coca eradication operations. This modeling
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(8.25) at the time of this mode ling in late October 2011. AGDISP is a model developed by the
US Forest Service, NASA and US Army for predicting the di spersion, collection and deposition
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯modeling applications in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
spray research, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯roach are provided in the
following report:

Andrew J. Hewitt (2011). Response to Report “Spray Drift Modeling of Conditions of
Application for Coca Crops in Colombia” by D.K. Giles.

Model Inputs

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ this report. The following

parameters are not shown in the tables:

Canopy: The approximate average canopy height in forested areas ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 20 m.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
clea▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯
between the spray applications and the border ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ i.e., 10 m.

▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ important for
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Amazonian rain forest, the canopy was set
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯See ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-scale
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Ecology Letters 11, 163-172; A.-L. C. McWilliam, J. M. Roberts, O. M. R. Cabral, M. V. B. R.
Leitao, A. C. L. de Costa, G. T. Maitelli and C.A. G. P. Zamparoni (1993) Leaf area index and
above-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯terra firme ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Ecology 7, 310-317.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, whereas
▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯

35Annex 2

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
worse-case than typical.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Andrew J. Hewitt, Keith R. Solomon, and E.J. P. Marshall (2009) Spra y Droplet Size, Drift
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Organisms from Aerially Applied Glyphosate for Coca Control
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-929.

Swath Width ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

line.

Meteorology: ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the reasonable worst-case scenario from D.K.
Giles’ expert report of relatively high wind speed of 5.14 m/s (for higher transport off the target
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯of 70% ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯of 35°C (for increased evaporation
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯According to the following
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-case for evaporation:

Climate Characterization of the Nariño ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ IDEAM
(Government of Colombia) 2011. Carrera 10 No. 20 – ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

Atmospheric Stability ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
events.

Evaporation Rate was entered based on library data from the AgDRIFT model for a very similar
▯▯▯▯▯▯▯▯▯▯▯▯▯9% glyphosate, i.e. 36.7 μm²/°C/sec.

4. Once the model was ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-target deposition (drift) rates to be
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯
complete, the Deposition Assessment toolbox was opened and the deposition rates at the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the spray line
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

5. An example of the model screen (for line 143) is shown below:

36 Annex 2

Results

6. The model ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the following table which is sorted by deposition rate
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯(high to low).

37Annex 2

Spray Line Ht. Application Application Rate Line Swath Border Deposition
Line ID/SEG Speed (mph) Length Aircraft Distance
Date (m) Rate Unit (m) (ft) (m) (g/ha)

gallons/acre
143 10-Oct-0249 200.100 2.4 110.95 85 OV-10 570 2.71

3143 13-Sep-01060.12666.470087.23000336 gallons/minute 114.385 50 T-65 947 1.66

671 22-Sep-01391.2525.3000031 0 gallons/acre 6.966 50 T-65 585 1.66

gallons/acre
1058 9-Sep-01222.63 151 2.299999952 186.803 50 T-65 479 1.59
gallons/minute
3667 13-Sep-01041.18540.619986.81999969 40.78 50 T-65 922 1.52

2010 15-dec-01112.76155.97 77.66 gallons/minute 72.85 50 T-65 571 1.46

1956 15-dec-01113.83162.83 81.8 gallons/minute 223.19 50 T-65 674 1.45

gallons/hectare 85 OV-10 1.22
4250 23-Nov-0550.68 211.70 6.700 112.696 277
4250 50.68 211.7 6.700 112.7 OV-10 277
23-Nov-05 gallons/hectare 85 1.22

399 10-Oct-0243 219.9 2.6 gallons/acre 232.8 85 OV-10 501 1.2

3519 08-Jan-01722.11660.6000061 7 gallons/hectare 269.942 50 T-65 964 1.17

gallons/acre
135 7-Oct-0243 212.800 2.600 244.12 85 OV-10 891 1.15
401 48 224.8 2.3 gallons/acre 64.5 85OV-10 541 1.1
10-Oct-02

3522 08-Jan-01706.14677.1999.900000095 gallons/hectare 317.531 50 T-65 904 0.9404

391 6-Sep-02 50.4 242.90 2.700 gallons/acre 74.439 85 OV-10 807 0.7641

528 45 136.1 0 gallons/acre 6.1 50T-65 480
22-Sep-02 0.75
132 40.71 207.10 0.000 gallons/acre 145.673 85 OV-10 153 0.706
8-Oct-02

358 26-Sep-0261 142.200 2.600 gallons/acre 6.363 50 T-65 393 0.7004

4188 23-Nov-0543.97 224.60 5.900 gallons/hectare 143.455 85 OV-10 683 0.6921

gallons/acre
716 8-Sep-0250 220.400 2.500 662.37 85 OV-10 1696 0.6537
gallons/acre
1254 22-Sep-02 58 153.200 Mean 21,75 l/ha 13.63 50 T-65 86 0.6379

596 22-Sep-0256 150.300 2.4 gallons/acre 201.67 50 T-65 169 0.633

4257 14-Jan-07 49 188.400 5.900 gallons/hectare 64.048 85 AT802 932 0.6199

319 53.39 174 2.800 98.542 AT802 71
24-Feb-03 gallons/acre 85 0.584
54 51.46 166.6 2.600 246.25 AT802 12
5-Feb-03 gallons/acre 85 0.5753

1977 13-Mar-01 47.75 224.040 216.540 gallons/minute 377.26 85 OV-10 979 0.56

2119 23-Jan-00 51.330 209.450 192.8300018 gallons/minute 159.305 85 OV-10 1153 0.551

4399 24-Dec-04 24 161.900 2.500 gallons/acre 341.92 50 T-65 439
0.506
gallons/hectare
135 2-apr-01438.28 151 1.6 7.147 85AT802 209 0.4349

562 22-Sep-02 43 143.3 0 gallons/acre 6.4 50T-65 547 0.41

1785 13-Mar-01 37.41 211.690 5.700 gallons/minute 137.09 85 OV-10 728 0.386

4041 33.63 201.5 7.5 gallons/hectare 90.1 OV-10 710 0.3662
22-Nov-05 85
13-Oct-05 46 gallons/hectare
1238 204.500 6.300 109.577 85 OV-10 2539 0.36

3899 19-Dec-06 42.33 180.900 6.900 gallons/hectare 48.475 50 T-65 430 0.3158

155 3-Oct-02 35.61 205.400 3 gallons/acre 584.5 85 OV-10 704 0.314

gallons/hectare
6857 24-Dec-0687 172 5.900000095 292.409 50 T-65 1145 0.3
2212 42.760 209.720 206.4299927 278.391 85 OV-10 1225 0.281
23-Jan-00 gallons/minute

4358 23-Nov-0530.13 224.60 6.200 gallons/hectare155.83 85 OV-10 638 0.261

13872 15-Mar-01 507.81771.39999391.600000024 gallons/hectare 78.473 85 AT802 704 0.2586

38 Annex 2

697 41.00 156.500 2.6 196.08 T-65 52
22-Sep-02 gallons/acre 50 0.2317

2647 18-Jan-01 63 171 81.8 gallons/minut0e.00450 T-65 1130 0.2

2835 14-Sep-00 54 151.9 62.4 gallons/minute296.250T-65 4560 0.192

gallons/hectare
13841 15-Mar-0595.62 158 1.600000024 226.773 85 AT802 464 0.1907
1711 79 156 0 gallons/minut0e.00650 2750 0.167
05-Jan-01 T-65

550 13-May-03 52 173.200 2.400 gallons/acre 7.755 85AT802 2270 0.1439

101 14-May-0237 197.1 2.5 gallons/acre 123.6 85 OV-10 970 0.14

gallons/acre
123 22-Sep-0238 155.600 2.5 230.54 50 T-65 123 0.1376
03-Oct-02 40 gallons/acre
51 202.200 2.700 36.163 85 OV-10 2406 0.111

914 8-Sep-02 48 174.5 0 gallons/a58.0e T-65 2498 0.11

400 10-Oct-02 42 223 2.6 gallons/acre220.55V-10825 0.11

2771 70 165.1 0 gallons/minute 0 50 3131 0.106
04-Jan-01 T-65
50 T-65
1979 Jan-01 78 163.3 0 gallons/minue.002 1500 0.1

3293 31-Sep-0066 185.8 91g.3allons/minute201.6 50 T-65 3890 0.099

4264 24-Dec-04 33 157.400 2.200 gallons/acre 148.078 50 T-65 340 0.0833

85 OV-10
66 14-May-0240 208.3 2.8 gallons/acre 173.4 1430 0.08
730 63 178.3 2.5 gallons/acre 8 50T-65 4910
10-Jul-03 0.076

1253 22-Sep-0229 156.700 2.6 gallons/acre 254.05 50 T-65 117 0.0673

1651 2-Feb-0730.28160.300 7.000 gallons/hectare 64.639 85 AT802 552 0.066

291 49 168.1 2.5 gallons/acre458.650T-65 5100
14-Jul-03 0.0645
286 46 171.2 0 gallons/acre 15.4 50 T-65 4952
9 July 2003 0.0599

862 2-Feb-07 23.32 166.6 6.5 gallons/hectare 141.71 85 AT802 407 0.055

No record 07-Jan-02 25 No record Mean 21,75 l/ha No record 265.76 50 T-65 198 0.0529

50 T-65
2721 26-Sep-0054 194.2 0 gallons/minute 153 1817 0.05
694 40 166.6 2.5 gallons/acre 402 50T-65 4574
23-May-03 0.0395

928 20-Jan-0335 167.000 2.600 gallons/acre138.85385AT8025200 0.0372

240 20-Feb-0232 208.900 2.5 gallons/acre500.34785OV-10 5160 0.0339

50 T-65
3527 Jan-01 30 186.3 10.7 gallons/minue.001 955 0.033
2994 152.4 0 gallons/acre 16.0 50
8-Sep-02 36 T-65 1760 0.015

2721 26-Sep-00 54 194.2 0 gallons/minute153 50 T-65 2062 0.01

2552 18-Jan-01 62 174.2 75.1 gallons/minute0.00150 T-65 1850 0.01

2748 53 177.3 0 gallons/minut1e491.950T-65 1960
26-Sep-00 0.01
2057 64 152.9 95.2 gallons/minute252.850T-65 2086
14-Sep-00 0.001

39Annex 2

40 Annex 3

DR K.R. SOLOMON, PH.D., XPERTREPORT OFKEITHR.

S OLOMON ONBEHALF OFC OLOMBI, NOVEMBER 2011

4142 Annex 3

B EFORE THE NTERNATIONAL COURT OF JUSTICE

CASE CONCERNING

AERIAL HERBICIDE SPRAYING

(ECUADOR v. COLOMBIA)

E XPERT REPORT OF K EITHR S OLOMON ON B EHALF OF COLOMBIA

1 Executiv Seummary

1. Overall, Ecuador’s Reply is based on a lack of understanding of the basic
principles of toxicology and risk assessment, misinterpretation of data, erroneous use

and interpretation of data and selective citations of the literature. These include, but are
not limited to:

a. Toxicologically, there is no difference between the formulations of glyphosate

used in the spray program. As sprayed in Colombia, formulations present de
minimis risk to humans and non-target animals.

b. There is confusion between the toxicity of the concentrated product and the
diluted spray. Based on tests with the spray mixture as used on coca, the risks

to humans and animals are de minimis.
c. The adjuvant, Cosmo-Flux 411F is of low toxicity to animals and does not

enhance the toxicity of the spray mixture to animals. Efficacy in plants may be
enhanced to a small degree but not the 4-fold claimed.

d. Impurities and other products in the formulations of glyphosate used in the spray
program are not of toxicological significance.

e. The modeling of spray drift used by Ecuador was flawed as it did not consider the
presence of trees and interception of the spray drift. Refined modeling of spray-

drift that incorporated all of the worst case assumptions but also included

Page 1 of 35

43Annex 3

interception by trees shows only very small amounts of spray-drift at distances

close to the spray swath and that, in most cases no deposition occurred in
Ecuador or, if drift occurred at all, amounts were extremely small and

toxicologically insignificant.
f. Contrary to claims by Ecuador, there is a robust data set with which to assess

the risks of the spray in non-target species. When this rich data set of
information on toxicology and fate in the environment is combined with the

refined estimates of spray drift, there is no environmental or human health risk in
Ecuador.

2. Overall, Ecuador’s Reply provides no proof that the spray used for control of

coca in Colombia drifted into Ecuador in toxicologically significant quantities or that any

harm occurred. Moreover, all of the scientific information shows that the spray does not
cause the harmful effects attributed to it by Ecuador.

2 Expe crtedentials – Keith R Solomon

3. I am an Emeritus Professor in the School of Environmental Sciences at the

University of Guelph, where I have served as a member of the faculty for over thirty
years. I have a BSc degree in Chemistry and Zoology (Hons) from Rhodes University

(1967), MSc degrees in Zoology and Entomology from Rhodes University (1971) and
the University of Illinois (1973) respectively, and a PhD in Entomology from the

University of Illinois (1973). I have more than 40 years of experience in research and
teaching in pesticide science and toxicology and have contributed to more than 400

scientific publications and reports (more than 250 in the peer-reviewed literature) in the
fields of pesticides, environmental toxicology, and risk assessment. I am a member of

the Society of Environmental Toxicology and Chemistry, the American Chemistry
Society (Agrochemistry), and the American Association for the Advancement of

Science. I am the recipient of the 1993 Society for Environmental Toxicology and
Chemistry-ABC Laboratories award for Environmental Education, was elected as a

Fellow of the Academy of Toxicological Sciences in December 1999, and am a recipient
of the 2002 American Chemical Society International Award for Research in

Agrochemicals. In 2006, I was awarded the SETAC Europe Environmental Education
Award and the Society for Environmental Toxicology and Chemistry Founders Award. I

have served on and provided expertise on pesticides via advisory panels to the US
EPA, the Institute of Life Sciences, the Pest Management Regulatory Agency in

Canada, and various panels in Europe, and the United Nations Environmental

Page 2 of 35

44 Annex 3

Programme. I was also appointed to the Board of Review for Siloxane D5 by the
government of Canada. A book of which I am a co-author, Pesticides and the

Environment, has been translated into Spanish and Portuguese and is distributed
worldwide. In addition, I have been asked for advice, written reports, and testified at

permitting hearings related to the use of glyphosate in forests and rights of way in
Canada.

4. My research into the use and effects of glyphosate herbicides in the
environment has resulted in a number of relevant publications, “Giesy JP, Dobson S,

Solomon KR. 2000. Ecotoxicological risk assessment for Roundup® herbicide.
Reviews in Environmental Contamination and Toxicology 167:35-120”, “Solomon KR,

Thompson DG. 2003. Ecological risk assessment for aquatic organisms from over-

water uses of glyphosate. Journal of Toxicology and Environmental Health B, 6:211-
246”, Solomon KR, Anadón A, Carrasquilla G, Cerdeira A, Marshall J, Sanin L-H. 2007.

Coca and poppy eradication in Colombia: Environmental and human health assessment
of aerially applied glyphosate. Reviews of Environmental Contamination and

Toxicology 190:43-125”, ”Solomon KR, Marshall EJP, Carrasquilla G. 2009. Human

health and environmental risks from the use of glyphosate formulations to control the
production of coca in Colombia: Overview and conclusions. Journal of Toxicology and

Environmental Health A 72:914-920, et seq.” A complete listing of my publications and a
more complete listing of my expert credentials are available in my curriculum vitae

(Exhibit A).

5. In 2003, I was contacted by the Inter-American Drug Abuse Control

Commission (CICAD) section of the Organization of American States (OAS) to serve as
the lead investigator on an independent Scientific Assessment Team (SAT) for what

became a series of studies investigating the potential environmental and human health
impacts of the glyphosate spray mixture used in the Program for the Eradication of Illicit

Crops by Aerial Spraying with Glyphosate (PECIG) . The SAT operated independently

of the US and Colombian governments, and other governments, none of which had
input or editorial control of the reports of the SAT. The studies of the SAT were divided

into two phases, Phase-I and II. Phase-I included a review of the literature on
glyphosate and an epidemiological study conducted in Colombia and was published as

a report to CICAD/OAS in 2005 and in the scientific literature in 2007. The Phase-II

studies were completed in 2007-2008 and published in the scientific literature in 2009.

Page 3 of 35

45Annex 3

6. From the beginning of the process, it was recognized that the SAT would need

to visit Colombia to observe firsthand how the coca fields were identified, how the
herbicide was applied, and the locations and habitats where the spraying occurred. The

first site visit took place in February 2004 with several members of the SAT and
subsequent visits in Jun. 2004, Aug. 2004, Feb. 2005, Jun. 2005, Jul. 2005, Jun. 2006,

Oct. 2006, Dec. 2006, Feb. 2007, May 2007, Jul. 2007, and Oct. 2007. These site visits
included the areas of Putumayo, Tumaco, and Nariño and one visit included a flight

along the border with Ecuador in the area where coca was being grown and sprayed.

Spray operations were observed in detail during these visits. Members of the SAT were
given complete freedom to observe all operations related to the spray program and

were allowed to photograph all operations except those related to the gathering of
intelligence about guerilla groups. We were allowed to travel with the spray operators

and with the team that evaluated efficacy and off-target effects, but for safety reasons,
we were accompanied by the Colombia National Police and their elite unit, the

“Junglas,” where appropriate. During these visits, we personally collected samples of
the glyphosate formulation as well as the adjuvant, Cosmo-Flux, for the purposes of

testing. These visits also provided us with the opportunity to meet regularly with
contractors to CICAD who were working in Colombia in the studies related to Phase-I

and -II, as well as to visit several Government and other agencies in Colombia where
additional data for the assessment could be obtained.

7. In this particular case, I have been asked by the Government of Colombia to
provide expert testimony the in the case before the International Court of Justice. I was

provided with complete copies of the Reply of Ecuador (Vol. I-V) which I reviewed in
preparation of this report.

3 Comments on Ecuador’s allegations in Chapter 2,
section I of the Reply

8. Sectionuador ’s Reply (Ecuador 2011, 2.17- 2.21) makes a number of

errors in interpretation of toxicity data that clearly show that Ecuador does not
understand the basic principles of the toxicology or the use of pesticides. The following

sections highlight these errors and show that the hazards of the mixture as sprayed
during the aerial applications in Colombia are de minimis. Given the greatly reduced

Page 4 of 35

46 Annex 3

exposures that would be found a short distance away from the spray swath, the hazards
1
of the mixture to the environment of Ecuador, if any, would be negligible.

9. The formulations of glyphosate used for the spraying of coca in Colombia were

the following: Fuete-SL® , Roundup SL® (which are equivalent – as is Roundup
Export® – since these alternate brand names are identical in ingredient formula

composition (EPA Registration No. 524-308)), and Gly-41® (equivalent to Roundup-

Ultra® (EPA Registration No. 524-475)) (EPA 2011). Because Fuete-SL and Roundup
SL are equivalent, only two sprays were used (Romero Herrera 2002, EPA 2011).

From the dates of sampling, all toxicity tests for the assessments by the SAT were
conducted on the product in use at that time, Gly-41 (see also comments in Ecuador’s

Reply (Ecuador 2011, at para. 4.45). All of these products contain the same technical

active ingredient (glyphosate isopropylamine (IPA) salt) in similar concentrations a
surfactant, POEA, consisting of ethoxylated tallow-amines, and water. The amounts of

POEA in the formulations ranged from approximately 15% to 11%, the latter for Gly-41.

The smaller concentration of POEA in Gly-41 allowed classification in a less restrictive
category (IV) (Romero Herrera 2002). However, as discussed below, the spray

solutions of all these formulations have equivalent de minimis toxicity.

10. In addition another adjuvant, Cosmo-Flux® 411F, and water were added to the

mixture prior to spraying (Weller 2011, Figure 10, p. 10). The addition of water to the

spray mixture changes the exposure-concentrations and effectively reduces the hazard
of the components.

3.1 Confusion between thetoxicity of the concentrated commercial

product and the diluted spray mixture.

11. InEcuador ’s Reply (Ecuador 2011, at para. 2.19), there is confusion between

the statements of hazard as appear on the label of the formulated product and the
toxicity of the spray mixture. Statements such as “Harmful if swallowed” on the label of

the product refer to the undiluted concentrated material in the container and are

1Hereinafter, “environment” is taken to include the natural environment consisting of plants and wildlife as
well as humans.
2
The reason for this lack of a specific product name was to protect the local representatives of the
manufacturer (personal communication to K Solomon from the manufacturer, 2005). It was only after the
publication of the 2009 studies in the Journal of Toxicology and Environmental Health A, Vol. 72 that the
identity of the product was confirmed as Gly-41. The product is referred to as Gly-41 in this report.

Page 5 of 35

47Annex 3

intended for the information of those who handle the undiluted product. These
instructions are intended for the mixers and loaders and are not relevant to bystanders

who would be exposed to the diluted product as sprayed. These comments also are
relevant to the discussion of the pictograms discussed in the response (Ecuador 2011,

Figures 2.1 & 2.2, 2.41). By analogy, pure alcohol is “dangerous if swallowed” but,
when diluted with a mixer or in wine, it is an enjoyable beverage.

12. None of the glyphosate-products used in the spray programs for coca and
poppy in Colombia present a hazard to humans as sprayed. This is shown in the

results of toxicity tests carried out on the mixture as sprayed in Colombia. This mixture
consisted of the formulated product, Cosmo-Flux® 411F, and water in the proportion as

loaded into the spray-aircraft. These tests on toxicity were carried out under Good

Laboratory Practices, using standard protocols with appropriate Quality Assurance and
Quality Control. Also included in the testing were confirmatory analyses of the content

of glyphosate in the mixture to ensure that the values were consistent with the
Environmental Management Plan of the spray program. These data are summarized in

Table 1 and it should be noted that all of these mixtures fall in toxicity category III. This

is similar to shampoo, vinegar, and a number of other household products.

Table 1. Summary of the mammalian toxicity data for the spray mixtures as used for control of
coca in Colombia

Product
Product Fuete-SL RoundupSL Gly-41

Code name Spray Alpha Spray Bravo Spray Charlie
Toxicity test Results

Concentration of 16.3% (Springborn 16.33% (Springborn 16.53% (Springborn
glyphosate a.e. as 2002b) 2003a) 2003b)
measured

Acute oral toxicity in LD50 >5000 mg/kg LD50 >5000 mg/kg LD50 >5000 mg/kg
rats (Springborn 2002e) (Springborn 2002g) (Springborn 2003c)

Acute nose-only LC50 >3.27 mg/L LC50 > 2.60 mg/L (Springborn 2003h)
toxicity in rats (Springborn 2002f) (Springborn 2003i)

Acute dermal LD50 >5000 mg/kg LD50 >5000 mg/kg LD50 >5000 mg/kg
toxicity in rats (Springborn 2002c) (Springborn 2002d) (Springborn 2003g)

Primary skin irritant Primary Irritation Primary Irritation Primary Irritation
in rabbits Index = 0.5; slight Index = 0.83; slight Index = 0.25; slight
irritant (Springborn irritant (Springborn irritant. (Springborn
2002k) 2002a) 2003e)

Dermal All scores = 0; not a All scores = 0; not a All scores = 0; not a

Page 6 of 35

48 Annex 3

Product

Product Fuete-SL RoundupSL Gly-41
sensitization in dermal sensitizer dermal sensitizer dermal sensitizer

guinea-pigs (Springborn 2002l) (Springborn 2002j) (Springborn 2003f)
Primary eye Mild eye irritant with Mild eye irritant withModerate eye

irritation in rabbits recovery by 7 d recovery by 7 d irritant with
(Springborn 2002i) (Springborn 2002h) recovery by 7 d
(Springborn 2003d)

Most severe toxicity III (EPA) III III
category. Based on
irritation of the 2B (UN) 2B (UN) 2B (UN)
eyes a.
a
EPA = U.S. Environmental Protection Agency Classification. UN = United Nations
Global Harmonized System for classification (UN 2005).

3.2 Toxicito yPfOEA

13. In the same manner as the above, Ecuador’s Reply (Ecuador 2011, at para.
2.45) confuses the toxicity of pure POEA with that of the mixture as used for spraying.

The complete lack of significant oral, dermal, and inhalation toxicity of the spray mixture
(Table 1) demonstrates that the exposures from the diluted spray are below the

threshold of toxicity.

14. POEA consists of ethoxylated tallow-amines and is made from the natural

product, tallow (animal fat). As a result, POEA consists of a mixture of products with
differing chain of the fatty-acid “tail”, i.e. the “blend” referred to in Ecuador’s Reply

(Ecuador 2011, at para. 2.48). This is characteristic of POEA and tallow itself. Tallow is

animal fat and, despite being a blend, is not toxic to humans. Slight differences in
chain-length have little impact on toxicological properties and the potency of the mixture

is considered in the toxicity tests discussed above so the implication that the product is
a blend is not relevant.

3.3 Composition and toxici ty of Cosmo-Flux 411F

15. Ecuador’s Reply (Ecuador 2011, at para. 2.49) also discusses Cosmo-Flux
411F and claims that the ingredients are in some way “secret”. This is not the case.

Despite Ecuador’s assertion, the ingredients were listed (Solomon et al. 2007b) as “a
mixture of linear and aryl polyethoxylates, (17% w/v) and isoparaffins (83% v/v)”. This

is also clearly stated on the label of the product (Cosmoagro 2004) so it is not “secret”.

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49Annex 3

16. Ecuador’s Reply (Ecuador 2011, at para. 2.55) also notes that Cosmo-Flux
411F enhances the toxicity of Gly-41. However, this does not apply to mammals (see

discussion of this in Section 3.1 above), amphibians, and plants. The toxicity of a
mixture of Gly-41 and Cosmo-Flux to mammals was reviewed in the 2005 assessment

where “It was also concluded that the addition of the adjuvant Cosmo-Flux® to the
glyphosate did not change its toxicological properties to mammals.” (Solomon et al.

2007b) The same conclusion can be drawn for mixtures of Roundup-Ultra and

Roundup-Export on the basis of the above data on toxicity to mammals (Table 1).

17. Although Cosmo-Flux 411F is added to many agricultural pesticides to increase
their efficacy, the increase in toxicity to coca is not as great as is claimed in Ecuador’s

Reply (Weller 2011, p. 15, see section 7 below). Cosmo-Flux 411F, in and of itself, was

shown to not be highly toxic to juvenile fish (Piaractus brachypomus) where an LC50 of
>4,000 mg/L was reported (Rondon-Barragan et al. 2007). Based on these

observations, it appears that Cosmo-Flux 411F does not significantly enhance the
toxicity of formulations of glyphosate to plants or to fish that are, in fact, found in

Colombia. The toxicity of the spray mixtures the tadpoles of Xenopus laevis was

smaller (LC50 = 1300 μg/L) (Wildlife International 2006) than that of regular Roundup
(Vision®), which was 800 μg a.e./L in the same species (Edginton et al. 2004).

3.4 Othep rotentially toxic ingredients

3.4.1 Dioxins

18. There are several other inaccuracies that relate to the presence of “other toxic

ingredients” in the spray mixture. Perhaps the most egregious of these errors is the
claim that the spray mixture contained dioxin. Dioxins are a class of halogenated

contaminants formed during the manufacture of chlorophenols. There are no halogens
in glyphosate or in the formulants added to the formulated product. This is likely an

error on the part of a non-technical person who misread the word “dioxane” for “dioxin”.

3.4.2 Dioxane

19. It is correct that small amounts of 1,4-dioxane have been found in formulations
of glyphosate, however, the relevance of these must be assessed against the

concentrations present – once again it is a case of “the dose makes the poison”.
Concentrations of 1,4-dioxane in formulations of glyphosate were reported to be less

than 0.03% (Dykstra 1991). The estimated cancer risk for the group with the greatest
exposure (Mixer-Loaders-Applicators) was 7.04 x 10 , while the risk of dietary

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50 Annex 3

exposures is “non-existent” (Dykstra 1991). Because exposures of bystanders to
sprays for control of coca are infrequent, the risk from 1,4-dioxane is less than Mixer-

Loaders-Applicators and is likely similar to the dietary risks – de minimis and not of
concern.

3.4.3 Formaldehyde

20. Formaldehyde is listed by the FAO as one of the two relevant impurities of
concern in the technical active ingredient, glyphosate (FAO 2001). The limits on

content are 1.3 g/kg of glyphosate (a.e.) and the hazard from this impurity was not
determined by the WHO/FAO Joint Meeting on Pesticide Specifications to be

toxicologically significant. This is a specification prepared for the FAO and all

formulations conforming to the specification, including those sold in Ecuador, would
contain formaldehyde. This is not a toxicological issue.

3.4.4 CosmoIN-d

21. Mention is made of the use of COSMO IN-d in the spray mixture Ecuador’s
Reply (Ecuador 2011, at para. 2.61). The toxicity of this material is referenced as being

classified in Category I because of the potential for severe irritation of the eyes. This
material is an adjuvant for the enhancement of penetration and reduction of foaming in

the pump of the sprayer. It contains alcohol ethoxylates (16.3%) and polyoxyethylealkyl

ethers (10.85%) (Cosmoagro 2011). As for the other additives discussed above,
potential for irritation of the eyes would be reduced by dilution in the spray mixture and it

would present a small hazard. In my several visits to Colombia to observe spray
operations (2004-2007), I never observed the use of this product.

3.5 Conclusions

22. In conclusion, the material in Chapter 2, section I of Ecuador’s Reply does not
make use of the appropriate data, shows a clear lack of understanding of the use of

agrochemicals, a lack of understanding of toxicology and the concentration-response,
and offers no analytical data to justify Ecuador’s claims. Contrary to these claims, the

mixtures as sprayed in Colombian territory do not present a hazard to humans in that

country. Given the greatly reduced or non-existent exposures in Ecuador, the spray
mixture presents no hazard to humans and the environment in Ecuador.

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4 Comments on Ecuador’s arguments in Chapter 4,

section II, sub-section A of the Reply

4.1 The areas sprayed

23. ThestatementinEcuador ’s Reply (Ecuador 2011, at para. 4.36) that “Colombia
sprayed vast quantities of chemical herbicides….” prior to March 2005 is incorrect.

From the data in the Phase-I report (Solomon et al. 2007b) total area sprayed
represented only 0.0000057 percent of the total land area of Colombia, hardly a vast

area, even if all of this had been located close to the border. In addition, the use of
glyphosate represented only 15% of the total use of glyphosate in Colombia – the

balance was used in agriculture. As glyphosate is widely used in agriculture, it is likely
that large amounts also were used in Ecuador at that time and continue to this day.

4.2 Studies conducted by the SAT
24. Ecuador’s Reply (Ecuador 2011, at para. 4.37) attempts to minimize the

relevance and/or the thoroughness of the Phase-I study conducted by the SAT. This
study is very useful in the context of the assessment of impact. The Phase-I study was

the product of a team of experts (SAT) and, at the express direction of the CICAD
division of OAS, was a risk assessment – that is an assessment of the potential impact

of the spray program on humans and the environment in Colombia.

25. That the Phase-I and the Phase-II studies and risk assessment did not include

Ecuador does not mean the results cannot be applied to assess risks in Ecuador. The
conclusion of the risk assessment for humans in Colombia was that the risk of adverse

effects was negligible, even from a direct overspray (Solomon et al. 2007b). By
extension, the risks in Ecuador would have been zero because there is no potential for

exposure in Ecuador. Refined modeling of spray drift that takes into consideration the
presence of trees and other vegetation as well as the contribution of adjacent spray

swaths shows that exposures will be very small close to the swath and essentially zero
at greater distances (1 km) (Hewitt 2011). It should be noted that the refined modeling

conducted by Hewitt used the same worst-case assumptions for all parameters as in
Ecuador’s Reply (Ecuador 2011, Annex 2) with the exception of the consideration of the

effect of trees on the interception of the spray.

4.3 Toxicity studies on the spray mixtures used in Colombia

26. Ecuador’s Reply (Ecuador 2011, at para. 4.38) is again incorrect in its
discussion of the lack of toxicity testing of the spray mixtures. As discussed in section

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3.1 above, the toxicity of all of the formulations used for spraying coca and poppy in

Colombia was tested. All formulations were tested by US-based Springborn

Laboratories, using GLP and QA/QC and, in addition, tests of the Gly-41-based spray
mixture were conducted in a Colombian Laboratory, Immunopharmos Ltda.

Laboratorios in Cota, Cundinamarca, Colombia. As with the testing done by
Springborn, all results demonstrated negligible toxicity via the oral, dermal, and

inhalation routes and the reversible and mild irritation of the eyes placed all the spray
mixtures in category IV.

4.4 Lack of studies of spray drift, toxicity to amphibians, and human

reproduction

27. It is correct that the Phase-I study (Solomon et al. 2007b) identified a need to
assess spray drift, however, that was not in response to allegations of spray drift into

Ecuador; these were not known to the SAT at the time of the Phase-I assessment.
Furthermore, the studies on spray-drift were directed specifically to the need to assess

exposures for organisms in the environment, not humans who were at negligible risk,
even from a direct overspray. It is correct that no tests with the spray-mixture had been

conducted on amphibians prior to the Phase-I study (Ecuador 2011, 4.39) but other
formulations had been tested and, at that time, amphibians were thought to be more

sensitive than other aquatic organisms.

28. Thestatementin Ecuador’s Reply (Ecuador 2011, at para. 4.39) that

amphibians “…are particularly sensitive to herbicides” is incorrect. Data on sensitivity of
tadpoles to pesticides shows that they are much more sensitive to insecticides and

some fungicides than to herbicides (Brain and Solomon 2009). In fact, for aquatic
organisms in general, endosulfan presented the greatest hazard (Solomon et al. 2007a)

with a hazard ratio 20,000-times greater than glyphosate. Endosulfan is banned in

Colombia but is used in Ecuador where eight formulations are registered for sale
(Agrocalidad 2011).

29. Contrary to what is alleged by Ecuador in its Reply (Ecuador 2011, at para.

4.39), the spray’s impact on human health has been adequately studied, including with

respect to reproductive health. It is clearly stated in the report from Phase-I, that
glyphosate is not a reproductive toxicant in laboratory animals except at large doses

that are not relevant to exposures in humans (Solomon et al. 2007b). That there were
equivocal epidemiological studies on the effects of glyphosate in humans was

acknowledged in the Phase-I report (Solomon et al. 2007a) and this was the reason

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why the study on time-to-pregnancy (TTP) was conducted in Colombia. The

conclusions of this study – that there was no association between eradication spraying

and TTP – were included in the report of Phase-I but were only published in detail in
2009 (Sanin et al. 2009). From this it appears that, at best, Ecuador did not read the

report of the Phase-I study very thoroughly.

4.5 Field measurements of drift

30. Ecuador’s Reply (Ecuador 2011, paras. 4.41-4.42) discusses one of the

proposed studies on spray drift. This was one of a number of proposals considered in
Phase-II but was not undertaken. This was because of the difficulty in finding a suitable

site for the study where multiple sprays could be undertaken, as well as the logistical
difficulty of collection and measurement of small droplets under different atmospheric

conditions. The SAT determined instead that the most reliable method for measuring
spray drift was through a wind tunnel analysis of spray droplet size and the use of

AGDISP modeling of drift scenarios.

31. Inparagraph4.43of Ecuador’s Reply, there are two errors with respect to the

spray-drift study. It was carried out in 2006-2007, not in 2009 and was paid for by the
CICAD division of OAS, not by the “Governments of Colombia and the United States”.

All of the members of the SAT worked under contract to OAS-CICAD. All payments
made to me and the other SAT members for work conducted on the Phase I and Phase

II investigations were made by OAS-CICAD. That OAS-CICAD had received funding for

these studies from other sources (including the United States and the United Kingdom)
is of no consequence. It is my understanding that it is normal practice for divisions of

the OAS to obtain outside funding from member states and other interested countries
on many of its projects.

4.6 Effects on amphibians

32. Ecuador’s Reply (Ecuador 2011, at para. 4.46) states that the rate of
application used in the studies on amphibians was unrealistic. This is incorrect. In the

work on frogs (Bernal et al. 2009b), a range of concentrations was chosen and the
LC50 and LC1 calculated. From this realistic field study, the LC50s were all greater

than the application rate of 3.69 kg a.e/ha. These studies were direct sprays on adults
with no interception by foliage. Interception of droplets by foliage would further reduce

exposures by between 50 and 95% (Linders et al. 2000) and provide the margin of
safety from a direct overspray. Given the lack of toxicologically significant exposures,

effects on amphibians in Ecuador would be negligible (see additional discussion of this

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in section 6 below). Other adjuvants were tested by the SAT (Marshall et al. 2009) as

part of a series of parallel studies. Because of time factors, the SAT studied other
formulations of glyphosate and other adjuvants before the data from the toxicity tests on

amphibians from Colombia were available. Because the spray mixture being used was
later shown to present low risk to amphibians under realistic conditions (Bernal et al.

2009b), there was no need to recommend consideration of other formulations, even
though some of these had similar efficacy to the current spray mixture (Gly-41 plus

Cosmo-Flux).

33. Further, Ecuador’s Reply is behind the times with respect to the sensitivity of

amphibians. The statement that “….Amphibians may serve as indicators of more
extensive environmental change because they are sensitive to environmental

contamination and live in both aquatic and terrestrial environments” (Reply of Ecuador,
Vol. II, Annex 4), is based on an incorrect conclusion that amphibians are inherently

very sensitive to chemicals. They are, in fact, less sensitive than some other aquatic
species (Kerby et al. 2009). As has been pointed out (Brain and Solomon 2009),

amphibians are sensitive to changes in habitat and to diseases (Cheng et al. 2011).

This is not as a result of exposures to glyphosate but to other activities of humans.

4.7 Conclusions

34. Inconclusion,thematerial in Chapter 4, section II A of Ecuador’s Reply shows
a lack of understanding of the scientific experiments and the manner in which scientific

studies are undertaken. Even though a specific Environmental Impact Assessment for

the eradication program was not conducted by the SAT or OAS/CICAD, the data
contained within the reports of the Phase-I and –II studies of the SAT do provide the

appropriate information to make conclusions on the risks of the spray program to
humans and the environment. Contrary to their claims, the mixtures as sprayed on

coca do not present a hazard to humans and amphibians in Colombia and, because of
insignificant or non-existent exposures in Ecuador, present no hazard there.

5 Comments on Ecuador’s arguments in Chapter 4,
section III of the Reply

35. In Ecuador’s Reply there are several general statements about pesticides
(Ecuador 2011, paras. 4.78-4.85) that do not apply to the uses of formulations of

glyphosate for control of coca.

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5.1 Off-label use of pesticides

36. Labels of pesticides are meant to provide instructions for correct use as well as

protect the manufacturer from claims of lack of efficacy or adverse effects from users
who do not follow the directions on the label. While it is true that labels on pesticides

are used to convey information about use and safety of the product, a deviation from the
directions on the label does not necessarily mean that harm will result; this depends on

how the pesticide is used. The statement in para. 4.78 of Ecuador’s Reply: “Since
pesticides, if not used properly, can cause serious harm to human health and the

environment” should read “…properly, may cause….”. Depending on how they are
used, certain products may or may not cause harm. In fact, in the quote from the

Decree No. 1843 of the Colombian Government (4.83) states “Use products according
to the instructions on the labels or with the technical assistance of the company”. This

specifically allows off-label use if approved by technical experts, in this case, from the
company. The spirit of this statement is that, with appropriate technical advice, off-label

uses are allowed. There was excellent technical and scientific advice provided on the
spray program by scientists from the U.S. Department of Agriculture and the U.S.

Environmental Protection Agency in many phases of the program which ensured the
safe application of the formulations of glyphosate used in the eradication program. In

addition, the spray program followed detailed directions for the conditions and manner
of application (Government of Colombia 2001, 2003) that are more specific and detailed

than a simple label.

37. All of the discussion of the off-label use of various formulations of glyphosate

(Roundup SL (Ecuador 2011, paras. 4.86-4.91) and Gly-41(Ecuador 2011, paras. 4.92-
4.95) is moot as the spraying was done with appropriate technical advice and guidance

and the assessment of risks from these products demonstrated that they were being
safely used (Phase-I and –II studies by the SAT).

6 Comments on Dr. Charles Menzie’s response (Annex 6
of Ecuador’s Reply, Vol. II)

38. The report by Menzie and Booth (2011) focuses on three areas: a hazard
assessment, a discussion of uncertainties, and the managing of uncertainty. There are

a number of unsupported assumptions in this report and, while there is much discussion
of uncertainty, other than hand-waving, there is no attempt to quantify this uncertainty.

One major point in this report is the bias in the way that uncertainty is applied. By
statistical definition, uncertainty is around a mean or average value. Some values are

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greater than the mean and others less than the mean. For this reason, scientists
usually express mean or average values with a notation of the uncertainty such as a

95% confidence interval. For example, 9.5 ± 1.0 says to the reader that the average
value was 9.5 and the in the data set, 95% of the values were between 8.5 and 10.5.

Thus, the velocity of the wind is not always at the maximum and the direction of the
wind is not always towards the border. In fact, because of geographical and

topographical factors, the average value for wind direction may not always be zero. For

example, in the border area Departments of Nariño and Putumayo between Colombia
and Ecuador, the predominant direction (11 months a year) of the wind is from South to

North i.e., from Ecuador towards Colombia (IDEAM 2011). In addition, these areas are
in the Doldrums and the wind speed is generally small; in the range of 1-2 m/sec (4-8

km/h).

39. In addition, the authors assume that all of the uncertainties are additive, for

example, the implied co-occurrence of high winds and thermal inversions is highly
unlikely (Hewitt 2011). There is no attempt to address the probability of these

occurrences; it is merely assumed that all factors are extreme and that they all co-occur

in a way that maximizes the risk. Clearly, this is illogical and against the laws of
probability. The following sections address several points in this report in the same

order as they were raised by Menzie and Booth.

6.1 Validation of the hazard assessment by new modeling of drift

40. The arguments brought forward by Menzie and Booth in this section of their

report are heavily reliant on the revised modeling data provided in the Reply of Ecuador
(Ecuador 2011). The modeling conducted in the Phase-II study (Hewitt et al. 2009),

was a worst-case analysis based on standard operational conditions. Maximum speed
of cross-wind (9.3 km/h) was assumed; flight speeds for the aircraft were 333 km/h for

OV-10, 274 km/h for AT-802, and 226 km/h for ATT-65; temperature was assumed to

be 35°C; but type of trees and density of foliage typical for the region were not included
in the model. All of these factors contribute to an overestimation of drift and result in

worst-case values for drift. When the model was run using multiple swaths and the
actual types of trees and foliage, drift values were smaller than had been estimated

before (Hewitt 2011). The speeds used in the spray-drift tests are a reasonable worst-
case that represent the 90 centile of speeds claimed in Menzie and Booth (2011, p. 4).

In addition, the claim of nighttime spraying is wrong and is based on the incorrect

interpretation of the offset time set in the Del Norte navigation systems which was either
Zulu time (GMT) or +5, instead of -5 (Story 2011). Spraying at night was never

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observed by the SAT in its many field visits and makes no sense for safety reasons

alone.

41. This small estimate of the drift of spray agrees with actual field observations in

Colombia in the areas sprayed for the control of coca. In verification exercises
conducted in Colombia (as discussed in Solomon et al. 2007a, Table 3), the amount of

area affected by visible damage to plants caused by off-target deposition ranged from

0.25 to 0.48%. If spray drift was as severe as is claimed and was affecting areas 10 km
from the border (Ecuador 2011, Menzie and Booth 2011), then damage from off-target

deposition in Colombia would be much greater than has been measured. In addition,
the weekly monitoring of surface waters for 24 weeks in sprayed and non-sprayed

regions of Colombia (as discussed in Solomon et al. 2007a, Table 9) showed no
detections of glyphosate associated with the spraying of coca. These measurements

provide further evidence that spray drift is de minimis. Further, Ecuador’s Reply
(Ecuador 2011) does not report measurements of glyphosate in samples of soils or

water from the border region so they have presumably not been able to detect the
presence of glyphosate in environmental media. Ecuador’s claims of widespread and

pervasive drift of glyphosate into its territory are inconsistent with the evidence of very

little drift and no pervasive contamination in Colombia, and are mere speculation.

6.2 Uncertaintiea sssociated with health and environmental effects

42. This section of the report by Menzie and Booth (2011, p. 6 et seq), refers to a

number of factors that may introduce uncertainties into the assessment of risk. These
are discussed in the following paragraphs.

43. Meteorology is important when spraying pesticides and adherence to

procedures is important. Local meteorological conditions were considered during the

application of sprays. Members of the SAT were present at a number of spray
operations and made the following observations:

a. The spray operation was preceded by a reconnaissance of the area by a spray-

pilot. If conditions (cloud, rain, etc.), were inappropriate the operation was

postponed to later in the day or to the following day.
b. If spraying could not be initiated early enough in the afternoon, the operation was

postponed to the following day. This was for two reasons; to ensure the safety of
pilots and to avoid the possibility of stronger winds associated with localized

thunder storms in the late afternoon.

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58 Annex 3

c. Before initiating spraying, the lead spray-plane released oil smoke (known as
“beeper”) and the movement of the cloud of smoke was used to judge suitability

of local wind conditions for spraying.

44. Thus, local meteorological conditions were considered on a case-by-case

basis. In addition, and contrary to Menzie and Booth (2011, p. 6 and Section 2.1, pp. 9-
10), spraying was not conducted at night (see discussion above in section 6.1 of this

report). These allegations are thus incorrect.

45. Composition of the spray mixture did change over the period of spraying

(Roundup SL to Gly 41), but this did not influence the hazard from the spray solution
(Table 1). There is no basis for this argument (Menzie and Booth 2011, p. 7 and in

Section 2.2, pp. 11-13) and this allegation is not based on appropriate scientific data.
The allegation related to the use of other surfactants is discussed in Sections 3.1 and

3.2 above. Also, as stated above (Section 3.3), the composition of Cosmo-Flux F411 is

known and was considered in the toxicity tests conducted on the spray mixture. The
allegation that the change in the spray mixtures affected risks is not supported by the

toxicity tests conducted on all of the spray mixtures that were used in the spray
operations (Table 1 above).

46. The vulnerability of the populations in the border area is alleged to make
the people more susceptible to the effects of glyphosate (Menzie and Booth 2011, p. 7

and Section 2.3, pp. 13-15) but this is pure speculation. There is no evidence to
suggest that the individuals in the border area are made more sensitive by the

conditions under which they live. In addition, for an interaction to occur, exposures to

the spray would have to be at a dose close to that which would cause a response.
Even the exposures expected from a direct overspray provide a margin of safety that

would be protective (Solomon et al. 2007b) of just such a scenario. The de minimis
exposures resulting from spray-drift would be so small and infrequent that these

interactions would not occur. In addition, epidemiology studies conducted by the SAT in
Colombia showed no link between time-to-pregnancy and aerial spraying (Sanin et al.

2009) or frequency of micronucleus in white blood cells and self-reported proximity to

the spray or entry into the sprayed fields (Bolognesi et al. 2009). This further confirmed
the lack of health effects in populations in the immediate vicinity of the areas sprayed in

Colombia. As no exposures occurred in Ecuador, claims of health effects in populations
near the border cannot be caused by spraying in Colombia. Furthermore, new studies

conducted in Ecuador concluded that “the study population did not present significant

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59Annex 3

chromosomal and DNA alterations” (Paz-y-Miño et al. 2011). Again, these allegations
of harm to humans are incorrect and are not supported by studies conducted on the

exposed populations in Colombia or Ecuador.

47. The Ecology of Ecuador is different from that of the temperate regions of the

world (Menzie and Booth 2011, p. 7 and Section 2.4, pp. 15-18) but Menzie and Booth
do not provide examples of how this may have caused the SAT to “to neglect to

consider important exposure pathways”. If anything, exposures would be less and for
shorter periods than experienced in temperate regions. The greater humidity and

temperature results in more rapid dissipation of most chemicals, including pesticides
(Racke et al. 1997), which reduces exposures and the concomitant risks. Once again,

these allegations are incorrect and are inconsistent with scientific knowledge about the

behavior of pesticides in the tropics.

48. Menzie and Booth also discuss the life history of frogs in Ecuador and seem to

misunderstand the nature of the choice of the frogs tested in the studies conducted by
the SAT. The frogs selected for testing under laboratory (Bernal et al. 2009a) and field

conditions (Bernal et al. 2009b) in the tadpole stage were chosen specifically because
their juvenile stages are found in water, a likely exposure pathway for the spray mixture.

Another reason for the choice of these species was that they are typically found in
lowland areas where coca is grown (<1000 m above sea level). Most of the diversity of

species of frogs in Colombia and Ecuador are found at greater altitude in the Andes.

This is the case for the members of the Strabomantidae (Menzie and Booth 2011, p. 20)
which are montane frogs (Arteaga-Navarro and Guayasamin 2011) and would not be

found close to areas where coca is grown. Frogs with other reproductive strategies that
do not make use of surface waters could not be tested in this manner as aqueous

exposure would be unrealistic. However, the responses of terrestrial stages of frogs to
the spray mixture were studied as well (Bernal et al. 2009b), although it is unclear

whether Menzie and Booth actually read this part of the paper. The species used in the

testing of terrestrial stages included some that have different reproductive strategies
such as the Dendrobatids (Menzie and Booth 2011, p. 18). The species tested was

Dendrobates truncatus, along with seven others representing different habitats. These
frogs were exposed by direct contact with the skin but under realistic conditions and

showed a range of sensitivity (Bernal et al. 2009b). D. truncatus was the least sensitive

with no effects at the greatest concentration tested, i.e., 14 kg a.e./ha. The lack of
sensitivity of terrestrial stages of frogs is consistent with the results of other studies

conducted in the U.S.A. and Canada (Dinehart et al. 2009, Edge et al. 2011). It is

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correct that some of these species are almost strictly arboreal but, as pointed out
((Lynch and Arroyo 2009) and (Hewitt 2011)), the dense foliage of the canopy of the

forest is protective of these organisms. Last, but by no means least, all of the
discussion of the sensitivity of frogs in Ecuador is moot as the exposures are essentially

negligible (Hewitt 2011) and the risks de minimis.

49. In their report Menzie and Booth (2011, p. 7) allege that the use of sensitivity

of species to spray mixtures by the SAT was inappropriate as species from Ecuador
were not tested. This is speculation as Menzie and Booth do not provide toxicity data

from species of plants or animals from Ecuador. In fact there is evidence that there are
no significant differences between species from the tropics and other regions in terms of

sensitivity to pesticides and other chemicals. No significant differences were found in

HC5 values derived from Species Sensitivity Distributions of tropical and temperate
species to several pesticides (Maltby et al. 2005) as long as the species were from the

same taxon (fish vs. fish). If anything, cold-water species (of fish) appear to be
somewhat more sensitive than tropical species (Dyer et al. 1997) probably because of

differences in metabolism and detoxification at lower temperatures (Daam and Van den

Brink 2010). When the SAT completed Phase-I of the risk assessment, it identified a
lack of toxicity data from amphibians in Colombia as a data-need (Solomon et al.

2007b). The hypothesis that the sensitivity of frogs to glyphosate was not different
between Colombia and other locations was tested with laboratory data on tadpoles of

eight species of frogs from Colombia (Bernal et al. 2009a). This hypothesis could not
be falsified as was illustrated in distribution of data in Figure 1 of Bernal et al. (2009a).

The theory that Ecuadorian species of amphibians would be consistently more (or less)

sensitive than those from Colombia is even less plausible when one considers the
similarity of climate and the closer relationship between species in these two countries

as compared to Colombia and Europe or the U.S.A. In addition, as pointed out for
amphibians (Lynch and Arroyo 2009), the same species are found on either side of the

border in Nariño, in western Putumayo, and adjacent areas of Cauca and Caquetá
where the exposures are alleged to occur. These allegations of greater sensitivity of

species of frogs and other organisms from Ecuador are not supported by the studies

conducted by the SAT or other scientists.

50. With regard to plants, Menzie and Booth (2011, p. 24) are correct that the

Phase-II studies of the SAT utilized data on the susceptibility of crop plants only. These
data were obtained from the ECOTOX database (USEPA 2001) because these are

studies conducted using standardized protocols for the purposes of registration. Since

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that time, more recent data for wild plants from a presentation by Olszyk et al. (2009) at

a meeting of the Society for Environmental Toxicology and Chemistry have been added
to the data set. A commonly used measure of effect on plants is the EC25 based on

growth, yield, or size (Suter et al. 2007). These data were characterized by the use of

Species Sensitivity Distributions (SSDs) using procedures as before (Hewitt et al. 2009)
and are presented in Table 2 and Figure 1 below.

Table 2. Regression coefficients and intercepts for the toxicity data distributions for exposures of
terrestrial plants to glyphosate (Roundup®)

th
Herbicide n r² y = ax + b 5 centile inter-
a b cepts (kg a.e./ha)

Glyphosate (Roundup crop plants) 21 0.89 2.63 1.91 0.045

Glyphosate (Roundup wild plants) 13 0.95 2.32 3.02 0.0(Springborn
2003a)10

51. Cropplants
are less sensitive to

glyphosate than wild
th
plants with a 5
centile of 0.045

compared to 0.01 kg
a.e./ha. When

compared to the

refined data on drift
(Hewitt 2011)

deposition at 100

and 800 m were less
than the 5 thcentile of

the distribution of

EC50 values for wild Figure 1. Distributions of EC25s for glyphosate in terrestrial plants
plants Figure 1. and refined estimates of drift from a 10-swath aerial application. The
yellow square is the HC5 as reported by (Boutin et al. 2004).
Deposition at 800 m
also was less than the HC5 (equivalent to the 5 centile) of plants as tested by Boutin et

al. (2004). These data show that allegations of harm to plants in Ecuador by Menzie

and Booth (2011, p. 24) are without basis.

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62 Annex 3

52. With regard to the discussion of the effect of Cosmo-Flux on toxicity of Gly-41
to plants, see the discussion in Section 3.3 above. With regard to the suggestion that

the toxicity of glyphosate to all plants is increased by a factor of four-fold (Menzie and
Booth 2011, p. 25), this would only be the case if the sensitivity was determined by

penetration only. Menzie and Booth (Menzie and Booth) present no evidence to show
that this is the case and apparently rely on the Weller report (Weller 2011) where these

data were misinterpreted (see section 7.4 below).

53. Menzie and Booth (2011, p. 8 and Section 2.6, pp. 25-26) suggest that there is

uncertainty in the measurements of exposure close to the border with Ecuador.
Because of logistical issues, it was not possible for the SAT to measure exposures in

these regions. Thus, the SAT relied on modeling of drift to estimate worst-case

exposures. Ecuador has also relied on the same type of models and has not presented
any measured values of exposures in Ecuador. In addition (as discussed in the section

on drift (Hewitt 2011)), the modeling conducted by Ecuador did not consider interception
of spray droplets by trees and foliage and their estimates of drift are much greater than

is realistic for the environment where coca is sprayed. Thus, the modeled exposures

used by Ecuador are, in fact, more uncertain than those used in the risk assessments of
the SAT and the comment is incorrect.

54. Menzie and Booth (2011, p. 8 and Section 2.7, pp. 26-31) allege that Colombia

dismissed reports of adverse effects and imply that this is contrary to accepted

environmental regulatory practice. Firstly, this is incorrect – reports of adverse effects
are not used in regulatory practice, they are used in risk assessment. However, not all

data from these reports is appropriate for this purpose. The SAT did consider the
anecdotal testimony of individuals who alleged harm from the aerial eradication

operations in Colombia, where exposures, if any, would be greater than in Ecuador.
Individual members of the SAT with medical expertise assessed the nature of the

information provided in these anecdotal reports and concluded that it was not usable in

a risk assessment. The major reasons for this conclusion were that the anecdotal
reports were not collected in a consistent manner, often did not have necessary

information such as medical records or measurements of alleged exposures, and could
not be analyzed in any scientific way (epidemiologically) because of the absence of a

control group. How this can be characterized as “strong testimonial evidence” (Menzie

and Booth 2011, p. 27) is not clear, an anecdote is an anecdote and, for all we know,
could also be a fairy-tale. For this reason, the SAT designed and carried out two

epidemiological studies of the spraying operations, with inclusion of appropriate

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63Annex 3

reference and/or control groups and a standardized approach. The findings from these

epidemiological studies are included in the studies of the SAT published in the peer-

reviewed literature and do not suggest a link between exposure to the spray and
significant adverse effects. As Ecuador has offered no alternative way to analyze these

anecdotal reports in a scientific manner, there is no substance to their allegations. In
Section 2.7, Menzie and Booth (2011) launch into an extensive study of the evidence

used to assign causality; however, they fail to acknowledge that these criteria were
developed for the analysis of properly conducted epidemiological studies and

experiments (Hill 1965). The anecdotal evidence that they cite is poor evidence of
causality and the lack of significant toxicity of the spray mixture in guideline tests (Table

1) shows, once again, that this is all pure speculation on the part of Ecuador.

55. Menzie and Booth (2011, p. 8) allege that extreme adverse events may not

be anticipated by modeling, which is correct. Nevertheless, the environmentally
refined modeling conducted (Hewitt 2011) does consider extremes of operational

conditions as well as local conditions. However, Menzie and Booth raise this
uncertainty as if it applied across all events. By definition, extreme adverse events are

rare and the probability of their occurrence is small. When using these in a risk

assessment context, one must consider the extent and frequency of the potential
adverse effects, which Ecuador has failed to do. However, if one considers the extent

of adverse effects, say from a greater than expected drift event, one must consider the
relatively small area that would be affected and the very small increased exposures that

may result from spraying at a greater altitude (Hewitt 2011).

56. The report of Menzie and Booth (2011, Section 2.8, pp. 31-32) provides some

discussion of extreme events, but no discussion of probability of these. It appears that
they wish to rely only on hypothetical possibilities when they have a wealth of data from

which to derive conclusions. This is neither science nor deductive reasoning and is no
more scientific than Chicken Little crying that the sky is falling.

6.3 Managing Uncertainty for Risk-Based Decision Making

57. In the section on managing uncertainty for risk-based decision making, Menzie
and Booth (2011, Section 3, pp. 33-41), argue that, in the face of uncertainty, large

safety factors are necessary for making decisions that are protective. They further
argue that there is great uncertainty due to lack of knowledge. However, their own

evidence is also lacking in knowledge and is flawed. The modeling on which their

estimates of exposure were based was unrealistic as it failed to consider the presence

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64 Annex 3

of trees that would act to intercept drift and their estimates of exposures are thus highly

exaggerated. They claim that the toxicity of the spray mixture(s) is unknown, whereas it
is well documented. They claim that the uncertainty factors are not used, when they

were. The reference dose (RfD) used as a comparison for exposures of humans was
derived by the U.S. EPA by the use of uncertainty factors. Menzie and Booth also imply

that the database for glyphosate is “poor” (Menzie and Booth 2011, p. 35), whereas it is
very robust for both human and ecological endpoints. This is illustrated in the wealth of

data in published assessments from regulators ((World Health Organization
International Program on Chemical Safety 1994, USEPA 1993, et seq.), (Williams et al.

2000, Giesy et al. 2000, Solomon and Thompson 2003)), and the work of the SAT. The
discussion of uncertainty factors for ecological receptors is not relevant. The exposures

calculated from the refined modeling of drift all include large margins of safety, i.e., they
are all thousands of fold less that exposures of concern (Hewitt 2011).

7 Comments on the expert report prepared by Dr. Stephen
C. Weller (Annex 3 to Ecuador’s Reply, Vol. II)

58. Dr. Weller’s report (Weller 2011) contains a number of errors and
misinterpretations of information that bias the conclusions. The following sections

highlight these errors and show how they have prejudiced the conclusions.

7.1 Rates ofpplication

59. The comparison of the rate of application of glyphosate for control of coca (3.67

kg a.e./ha) in Colombia to its use in agriculture (1.5 kg a.e./ha) in the US (Weller 2011,
p. 10) is inappropriate. A better comparison is to the rate of application in forestry

where it is used to control herbaceous species similar to coca plants. In forestry,
maximum label rates range from 2.14 to 11.2 kg a.e./ha (Thompson 2011). In this

context, the rates used for the control of coca are not unusual, especially when one
considers resistance of the waxy leaves to penetration of hydrophilic substances such

as glyphosate.

7.2 Sprad yriftstimates

60. The estimates of spray drift used in the report (Weller 2011, p. 12) are based

on older studies and only focus on the maxima. The loss to downwind drift from boom
application (ground-based) is small. Based on analysis of >100 spray drift trials, the
th
90 centile drift value for ground sprayers is 2.7% of the rate applied (Rautmann et al.
2001), far less than the 14 to 78% from older studies. Similarly, aerial application of

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65Annex 3

glyphosate (1.07 to 2.14 kg a.e./ha) by helicopter for conifer release showed

insignificant deposition from drift at distances of 30 to 60 m from the edge of the spray

block (Thompson et al. 2004).

7.3 Tolerance of plants to glyphosate

61. That crop plants may be more tolerant to glyphosate (Weller 2011, p. 14) is
correct. The 5 centile for wild plants (Table 2) was 10 g a.e./ha. However this ignores

the fact that small concentrations of glyphosate can be stimulatory to plant growth.

Rates of 1.8 to 36 g a.e./ha were stimulatory in three species of plants from Brazil
(Velini et al. 2008) and in crop plants (barley) treated at rates up to 63 g a.e./ha

(Cedergreen 2008). Thus, to extrapolate to very small rates and assume that damage
will occur in all plants is incorrect. The observation of stimulation of growth shows that

there is a threshold below which adverse effects will not occur, even in the most
sensitive organisms, plants.

7.4 Enhancement of toxicity by Cosmo-Flux 411

62. The allegation (Weller 2011, p. 15) that Cosmo-Flux 411F enhances the
efficacy of formulated glyphosate products is incorrect. The source of this information

was claimed to be a paper by Collins and Helling (2002), in which several mixtures of
adjuvants were tested; “Ultimately, two glyphosate-surfactant systems (COC/OSI-U [a

mixture of crop-oil concentrate, Agri-Dex® and organosilicone, Silwet L-77®] and

CAT/ANA [cationic surfactant/anionic surfactant, Optima®]) were found that increased
glyphosate phytotoxicity fourfold:…” (emphasis added). Cosmo-Flux 411F was not

tested by Collins and Helling (2002) and the increase in efficacy referred to was in
reference to a glyphosate formulation without surfactants (Rodeo®), not Gly-41 or its

equivalent. In addition, studies of the efficacy of mixtures of Gly-41 and several
adjuvants carried out in Colombia (Marshall et al. 2009, Table 3) showed little

enhancement of efficacy for the mixture of Gly-41 and Cosmo-Flux in coca. To
extrapolate from an advertisement from Cosmoagro that states that “Its effectiveness is

four (4) times greater than conventional spraying oils due to synergism between the
paraffinic oil and the stereospecific surfactant”, demonstrates gullibility in the extreme.

Glyphosate is not specifically mentioned in this claim and there is no evidence that

paraffinic oils are synergistic (using the classical definition for pesticide synergists) or
that the surfactant is stereospecific with regards to the vast range of products of very

different molecular structure that it is claimed to enhance. In short, there is no support
for the claim that Cosmo-Flux 411F enhances the efficacy of formulated glyphosate to a

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66 Annex 3

significant degree. The extensive discussion of the enhancement of toxicity of

glyphosate in the section on page 16 (Weller 2011) is moot as this enhanced toxicity

does not occur.

7.5 Sprad yrift

63. The discussion on spray drift (Weller 2011, pp. 17-21) is addressed in the
expert report prepared by Dr Hewitt in response to Dr Giles’ report (Hewitt 2011).

However, combining the sensitivity data (Table 2) and from Boutin et al. (2004), and

combining this, in turn, with the exposures at various distances from the spray area from
the refined analysis of drift (Hewitt 2011), shows a de minimis risk to plants at distances

greater than approximately 100 m from the sprayed area (see section 6.2 and Figure 1,
above).

7.6 Factors that enhance injury to plants

7.6.1 Humidity

64. That greater humidity may enhance the penetration of glyphosate through the

cuticles of leaves (Weller 2011, p. 21) is correct, but the extent to which this enhances
the penetration of glyphosate is not stated. Measurements of uptake of glyphosate

through cuticle have shown that rate of penetration is increased by a factor of about 8 at
100% humidity as compared to 70% humidity (Schönherr 2002, Jordan 1977), but these

observations were based on the use of pure glyphosate in the absence of surfactants.

Addition of an ethoxylated fatty amine (Ethomeen T25) at a rate of 4 g/L did not
enhance penetration but the interaction of this with humidity was not tested (Schönherr

2002). To what extent humidity enhances the efficacy of the spray mixture used in
Colombia is uncertain.

7.6.2 Concentration of herbicide in the spray droplets

65. Greater humidity will also influence the rate of evaporative loss water from
spray droplets; however, the humidity at the normal times of spraying in the Nariño and

Putumayo regions of Colombia is high (IDEAM 2011), a factor that is considered in the
modeling of spray drift (Hewitt et al. 2009, Hewitt 2011). Studies on the effect of volume

of spray on efficacy were conducted in the field in New Mexico (Banks and Schroeder
2002) presumably at low humidity (this was not reported in the paper) or in the

greenhouse (Yerkes and Weller 1996) (where the humidity was again not reported).

Thus the effect of humidity on size of droplet and runoff from treated leaves is not
known. In contradiction to these suggestions, others have shown that coarse (large)

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67Annex 3

droplets enhance the uptake of glyphosate by plants (Feng et al. 2003), so the
suggestion by Weller (2011, p. 22) that small droplet size will increase efficacy is not

necessarily correct.

66. This discussion of humidity as it relates to droplets of spray is, in any case,

confounded. High humidity would reduce loss of water from the droplets and increase
the effective volume of the spray, and may reduce efficacy. However, large droplets

reduce the extent of spray drift. Weller attempts to argue for effects of high humidity in
one case and low humidity in the other when they are mutually exclusive and cannot be

additive.

67. Also relevant is that, even if there is complete evaporation of all of volatile

components of a droplet by prior to deposition, its final size will depend on the
proportion of the contents which were non-volatile (Hewitt 2011). Such small droplets

would be dispersed and diluted in the atmosphere to tiny (de minimis) amounts that are

not toxicologically relevant.

7.6.3 Secondary effects of glyphosate-based herbicides

68. Weller (2011, p. 22) states that glyphosate may affect the nutrition of plants and

that this may in some way enhance toxicity. However, the sum of all the actions of
glyphosate on the target system (the shikimic acid pathway) and other processes are

included in the response of the plant in the bioassays and are quantified in the EC25.
Thus this is not an additional effect and has no impact on the sensitivity of the plant

beyond what is measured in the test.

69. Although glyphosate can penetrate plants and then be extruded from the roots

and possibly affect microorganisms in the soil, these effects have only been reported in
experiments where normal application rates are used (Kremer et al. 2005, Kremer and

Means 2009) and are only relevant to direct deposition on a sprayed plant (coca), not to

exposures via drift. This may be an issue in fields sprayed directly with formulations of
glyphosate but there are no data to suggest that this occurs in plants exposed to much

smaller amounts such as those that result from spray drift. The allegation that
“Glyphosate is a potent mico (sic)-herbicide with toxicity to earthworms, myorrirhizae

(sic) and many microbes …” (Weller 2011, p. 23) is attributed to Kremer and Means
(2009) but there are no descriptions of potency in this paper and earthworms are not

even mentioned. Glyphosate is not a mycoherbicide; these are bioherbicides based on

fungi that are pathogenic in plants. These allegations are not supported in the literature.

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68 Annex 3

70. Although it is alleged that glyphosate may increase susceptibility of plants to

diseases (Weller 2011, p. 23), this is at rates of field application and, most likely, due to
the infection of the dying plant by pathogens. In a review of the topic, Camberato et al

(2011) concluded that “Overall, the claims that glyphosate is having a widespread effect
on plant health are largely unsubstantiated. To date, there is limited scientific research

data that suggest that plant diseases have increased in GM crops due to the use of
glyphosate.” To add to this, glyphosate has been shown to protect plants from some

diseases (Feng et al. 2008). There is no basis for the claim that small amounts of
glyphosate predispose plants to infection from disease.

8 Comments on other points raised in Ecuador’s Reply

8.1 Measurement of residues of glyphosate in Ecuador

71. InEcuador ’s Reply (Ecuador 2011, paras. 3.29-3.31) it is stated that it is
pointless to test for glyphosate in water and soil because it easily dissipates and is

carried away by river currents. This statement is only partially correct. In a flowing
river, any residue of glyphosate would dissipate rapidly to the point of being

undetectable. Sampling would have to be done on a regular basis or shortly after the
spray event. In Phase-I of the SAT studies, samples of water were taken weekly for 24

weeks from creeks and rivers in five locations in Colombia. Glyphosate was detected
twice but only in regions where it was being used for agricultural purposes. However,

dissipation in pools would be slower, and these environments have been used to
measure exposures after aerial spraying in forests (Thompson et al. 2004).

72. As is discussed above, glyphosate adsorbs strongly to soil and, by this

process, is rendered biologically unavailable. However, adsorbed glyphosate can be
displaced from the soil by the use of strong acids and then analyzed. This is the basis

for the analytical method for glyphosate in soils.

8.2 Number of formulations used in Ecuador

73. Thefollowing formulations of glyphosate were used for the spraying of coca in

Colombia:

a. Fuete-SL®, Roundup SL ® (equivalent to Roundup-Export® (EPA Registration

No. 524-308)),
b. Gly-41® (equivalent to Roundup-Ultra® (EPA Registration No. 524-475))

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Alpha. Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.4. 48
p.

Springborn. 2002g. An acute oral toxicity study in rats with Spray--Bravo. Spencerville,
Ohio, USA: Springborn Laboratories Inc. Report. 3596.9. 22 p.

Springborn. 2002h. A primary eye irritation study in rabbits with Spray-Bravo.
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.12. 27 p.

Springborn. 2002i. A primary eye irritation study in rabbits with Spray-Alpha.
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.5. 25 p.

Springborn. 2002j. A dermal sensitization study in guinea-pigs with Spray-Bravo.

Modified Buheler design. Spencerville, Ohio, USA: Springborn Laboratories Inc.
Report. 3596.14. 43 p.

Springborn. 2002k. An primary skin irritant study in rabbits with Spray-Alpha.
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.20. 23 p.

Springborn. 2002l. A dermal sensitization study in guinea-pigs with Spray-Alpha.
Modified Buheler design. Spencerville, Ohio, USA: Springborn Laboratories Inc.
Report. 3596.7. 41 p.

Springborn. 2003a. Purity analysis for glyphosate of Spray-Bravo (active ingredient).
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.8. 30 p.

Springborn. 2003b. Purity analysis for glyphosate of Spray-Charlie (active ingredient).
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.18. 30 p.

Springborn. 2003c. An acute oral toxicity study in rats with Spray--Charlie. Spencerville,
Ohio, USA: Springborn Laboratories Inc. Report. 3596.16. 29 p.

Springborn. 2003d. A primary eye irritation study in rabbits with Spray-Charlie.
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.19. 24 p.

Springborn. 2003e. An primary skin irritant study in rabbits with Spray-Charlie.

Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.20. 23 p.

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75Annex 3

Springborn. 2003f. A dermal sensitization study in guinea-pigs with Spray-Charlie.
Modified Buheler design. Spencerville, Ohio, USA: Springborn Laboratories Inc.
Report. 3596.21. 40 p.

Springborn. 2003g. An acute dermal toxicity study in rats with Spray-Charlie.
Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.17. 29 p.

Springborn. 2003h. An acute nose-only inhalation toxicity study in rats with Spray-
Charlie. Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.18.

52 p.

Springborn. 2003i. An acute nose-only inhalation toxicity study in rats with Spray-
Bravo. Spencerville, Ohio, USA: Springborn Laboratories Inc. Report. 3596.11.
50 p.

Story JB. 2011. Letter to Ambasador Sonia Pereira re. the setting of times in the Del
Norte navigation systems of the spray aircraft. Bogota, Colombia: Embassy of
the United States, NAS. 2 p.

Suter GW, II, Barnthouse LW, Bartell SM, Cormier SM, Mackay D, Mackay N, Norton

SB. 2007. Ecological Risk Assessment. Boca Raton, FL: CRC Press/Taylor and
Francis. 634 p.

Thompson D. 2011. Ecological Impacts of Major Forest-Use Pesticides. In: Sánchez-
Bayo F, Van den Brink PJ, Mann RM, editors. Ecological Impacts of Toxic
Chemicals. Oak Park, IL, USA: Bentham E-Books. p 88-110.

Thompson DG, Wojtaszek BF, Staznik B, Chartrand DT, Stephenson GR. 2004.
Chemical and biomonitoring to assess potential acute effects of Vision herbicide

on native amphibian larvae in forest wetlands. Environ Toxicol Chem 23:843-
849.

UN. 2005. Globally Harmonized System of Classification and Labelling of Chemicals
(GHS). New York and Geneva United Nations. Report. ST/SG/AC.10/30/Rev.1.
244 p. http://www.unece.org/trans/danger/publi/ghs/ghs_rev01/01files_e.html

USEPA. 1993. Reregistration Eligibility Decision (RED) Glyphosate. Washington, DC,

USA: United States Environmental Protection Agency. Report. EPA 738-R-93-
014. 291 p.

United States Environmental Protection Agency, Office of Pesticide Programs,
Environmental Fate and Effects Division, United States EPA, Washington, D.C.
2001. Environmental Effects Database (EEDB). ECOTOX Database System.
USEPA website http://www.epa.gov/ecotox/, Accessed, November 2009.

Velini ED, Alves E, Godoy MC, Meschede DK, Souza RT, Duke SO. 2008. Glyphosate

applied at low doses can stimulate plant growth. Pest Manag Sci 64:489-496.

Weller SC. 2011. Case Concerning Aerial Herbicide Ecuador v Colombia, Glyphosate-
Based Herbicides and Potential for Damage to Non-Target Plants Under

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76 Annex 3

Conditions of Application in Colombia. Annex 3. West Lafayette, IN, USA:
Purdue University. Report. number not provided. 55 p.

Wildlife International. 2006. Glyphosate-Cosmo-Flux® - Coca Mix: A 96-Hour Static-
Renewal Acute Toxicity Test with the African Clawed-Frog Tadpole (Xenopus
laevis). Final Report. Easton, MD, USA: Wildlife International. Report. 628A-101.
42 p.

Williams GM, Kroes R, Munro IC. 2000. Safety evaluation and risk assessment of the

herbicide Roundup® and its active ingredient, glyphosate, for humans. Reg
Toxicol Pharmacol 31:117-165.

World Health Organization International Program on Chemical Safety. 1994.
Glyphosate. Geneva. 161 p.

Yerkes CN, Weller SC. 1996. Diluent volume influences susceptibility of field bindweed
(Convolvulus arvensis) biotypes to glyphosate. Weed Technol 10:565-569.

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7778 Annex 4

D R S. OBSON, OBE P H.D., ESPONSE TS CIENTIFIPAPERS IN
ANNEXES TOV OLUMEII OFE CUADORS REPLY(2011), ECEMBER 2011

7980 Annex 4

81Annex 4

82 Annex 4

83Annex 4

84 Annex 4

85Annex 4

86 Annex 4

87Annex 4

88 Annex 4

89Annex 4

90 Annex 4

91Annex 4

92 Annex 4

93Annex 4

94 Annex 4

95Annex 4

96 Annex 4

97Annex 4

98 Annex 4

99Annex 4

100 Annex 4

101Annex 4

102 Annex 4

103Annex 4

104 Annex 5

A. TAI, NTERNATIONAM APPINGASSOCIATE, TATISTICSUMMARY
OFD ATA FOSPRAYEVENTSW ITHIN THRELEVANTAREAALONG THE

BORDER BETWEEC OLOMBIA ANECUADOR, ECEMBER 2011

105106 Annex 5

Statistical Summary of Data for Spray Events Within the Relevant Area

Along the Border between Colombia and Ecuador

Alex Tait
International Mapping Associates, Inc.

107Annex 5

1. Introduction

1.1 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Colombian
Government’s anti-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Program for the Eradication of
Illicit Crops by Aerial Spraying with Glyphosate (PECIG). Planes flying for this
▯▯▯▯▯▯▯▯▯▯▯▯▯on-board ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1.2 The spray event data analyzed in this report come from the electronic datasets that
were ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯as part of their Reply in these proceedings.
The datasets were compiled by the U.S. Department of State from the ▯▯▯▯▯▯▯▯▯▯

the on-board electronic data recorders and were then provided by the Department
of State ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1.3 The data consists primarily of a set of geographic information system (GIS) files
1
in standard shapefile format. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
each ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯s (also referred to as a

spray lines) are not completely consistent year to year. The U.S. Department of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
changed and in other cases there was a change in the variable itself.

2. Spray Events in the Relevant Area

2.1 International Mapping processed the entire set of spray event shapefiles that were
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tate ▯▯▯▯▯▯▯▯▯▯▯▯▯▯

to the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ded files for the years 2000 to 2009 and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. All data were placed in ESRI’s ArcGIS
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯
associated with each spray line. The analysis of all the spray event records

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
border) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. These and other aspects of the
Department of State ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

2.2 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯of which
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
relevant area”). The reasons why Colombia defined this area for analysis are
2
described in detail in the text of the Rejoinder.

1The shapefile format is a standard developed by ESRI for ArcView and ArcGIS software and is

2▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Colombia Rejoinder, Vol. I, Chap. 2.

108 Annex 5

2.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
1:100,000, 1:50,000 and 1:25,000 printed maps and digital mapping data provided
by the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (IGAC) of the Government of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯treaty ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and Colombia, the border between the two States is defined simply as “the river”
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e is the necessity for a single-
line border in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

the Colombia-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯rse
of the border displayed on ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯
border derived from its own 1:50,000 and 1:25,000 series topographical maps, 3

there are ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯
in this analysis.

2.4 Table 1 provides ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯lines by year for the relevant area

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. There were no spray events in the relevant area
for the years 2008 and 2009. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
for the period of 2000 to 2007 was 4,128.

3. Evaluation of Department of State Spray Event Data

3.1 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (those
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.2 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯n 2002, and 35
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯II, Annex 1, Hansman and Mena, p. 7.

109Annex 5

triplicates in 2001 or 2006 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. ▯▯▯▯▯▯▯▯▯
show▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯The 32
▯▯▯▯▯▯▯▯▯▯▯ines within the relevant area in 2002 were removed from the data for

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
were 7 lines in 2001 that had no geography in the GIS. They were present as
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯her or not they are in the
relevant area of wit▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.4 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯of

the spray event records. Most pertinent to this ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

110 Annex 5

111Annex 5

3.5 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the ▯▯▯▯▯▯▯▯▯▯▯▯ble for the year 2001 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of State dataset ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
be that in the transfer of data from the plane’s recording device to the compiled
GIS files delivered by the Department of State, there was a decimal point error in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯sensical lengths of less
than one meter were created for the affected spray lines. In order to correct this
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Table 2
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

example records ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.6 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
accorded with the hypothesiz▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯original ▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4. Speed

4.1 We analyzed the spray lines within the relevant area by speed for defined ranges:

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
spray lines within the relevant area for each year and for the defined ranges of
speed is shown in Table 3.

4.2 As noted above ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

112 Annex 5

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
statistics r▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
within the relevant area.

4.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

levels were tallied as well as events between those two speeds.

4.4 The top ten fastest speeds recorded for spray events in each year from 2000 to
2007 are shown in Table 4 along ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
line length.

4.5 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
with ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
closest to the border. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and a heads-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
closest to the Colombia-▯▯▯▯▯▯▯▯▯▯▯der for each year with spray events over 333

▯▯▯▯▯was identified. More than one spray line was selected when several were
▯▯▯▯▯ the same distance away from the border.

4.6 The two extreme spray lines for each year, i.e., the highest speed within the
relevant area from Table 4 and the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
determined above, were given to Dr. Andrew Hewitt drift modeling. These

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯5.

113Annex 5

114 Annex 5

5. Height Above Ground

5.1 Data for the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
events within the relevant area. We were informed that the on-plane devices
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
therefore at the beginning of each spray line. To determine the height above

5.2 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
each spray event, the SRTM digital elevation model was placed in ArcGIS
software. The starting point for each of the spray events was derived from the
event lines ▯▯▯▯▯▯▯ class in the original Department of State dataset to create a

points ▯▯▯▯▯▯▯▯▯▯▯▯▯.

5.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯sing the “Add Surface Information” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
“linear” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tion at
4
each of the start points. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
di▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

5.4 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
recorded in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯oth years were discarded
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
5
Reply. However, when ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4ESRI ArcGIS Online Help Library, last accessed 8 December 2011,

5▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯6.

115Annex 5

5.5 For the complete set of records obtained from the Department of State, the split
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯hts was from 0 meters to 200 meters. The

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
reasonable heights▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯they ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 6

5.6 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
relevant area in 2001 and 2004 become clear.

5.7 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in 2001 in the relevant area
appeared to be in feet, not meters. Table 6 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, it
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

all data lines.

6
▯▯▯▯▯▯▯▯▯eply, Vol. II, Annex 1, Hansman and Mena, Annex 1, p. 7

116 Annex 5

5.8 Table 7 shows a similar eval▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the spray lines from 2004, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ing meters, from highest to lowest.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and lines

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
feet, and then begin for meters. The ranges for height above gr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
splitting the spray events at the line shown in the table, are from 24.01 to 138.28
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

117Annex 5

5.9 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
with▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯shown in Table 8. ▯▯▯▯▯▯▯

of spray events with heights above and below 50 meters and 77 meters were
tallied as well as events between those two heights. The height of 50 meters was
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Government of Colombia’s Environmental Management Plan and the additional
range of 50 to 77 meters represents a normal height for avoiding obstacles.

5.10 There were 3,550 spray events below 50 meters, 578 events 50 meters or above,
and 51 events above 77 meters. The 51 events above 77 meters represent 1.2% of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯events within the relevant area. The spray events above
77 meters had speeds ranging from 134 to 172 mph.

118 Annex 5

5.11 Similarly, the top ten ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ recorded for spray events within

the relevant area in each year from 2000 to 2007 are shown in Table 9 along with
each event’s speed and spray line length.

5.12 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the closest to the border for each year. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯I’s

ArcGIS software, and a heads-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ over
77 meters that was closest to the Colombia-▯▯▯▯▯▯▯▯▯▯▯▯▯▯ was identified for
each year. More than one spray line was selected when several were ▯▯▯▯▯ the
same distance away from the border.

5.13 The two extreme spray lines for each year, i.e., the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
level within the relevant area from Table 9 and the line closest to the border of
those over 77 meters as determined above, were given to Dr. Andrew Hewitt for
drift modeling▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Table 10.

119Annex 5

120 Annex 5

6. Application Rate

6.1 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
within defined ranges by applicatio▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
is shown in Table 11. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯rea as was done for the others years) and spray rate for 2004 was
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
recorded in gallons per acre and those recorded in gallons per hectare for 2004.
7
As was done ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Chap. 2, para. 2.141.

121Annex 5

6.2 As noted above, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
964 spray events were discarded ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

area.

6.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
based on a threshold of 23.65 liters/hectare. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
within the relevant area, 1,522 were below the threshold of 23.65 liters/hectare

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
liters/hectare, 552 or 60.5% were only above it by a ma▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
relevant area was 28.39 liters/hectare, exceeding the 23.65 liters/hectare threshold
by 20.04%.

6.4 In analyzing the spray events for application rate, we noticed that for the year
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(application rate) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ve been recorded.

Table 12 shows the spray lines above and below the apparent split between
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

6.5 By wa▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

122 Annex 5

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯gallons per acre.

6.6 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
spray rate. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
converted from gallons per acre to gallons per hectare.

6.7 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
records for application rate. The overall average for the years 2002-2003 and
2005-2007 is 22.67 liters/hectare.

6.8 The top ten spray events by highest application rate in each of the relevant years
(2002, 2003, 2005, 2006, and 2007) are shown in Table 13 along with each

event’s ▯▯▯▯▯ for speed and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯level. For those spray events
with the same application rate, they are ▯▯▯▯▯▯▯ sorted by distance to the border.

123Annex 5

6.9 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
with an application rate over 23.65 liters/hectare to determine which of these was
the closest to the border for each year. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
ArcGIS software, and a heads-▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(over 23.65 liters/hectare) that was closest to the Colombia-▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for

each year was identified. More than one spray line was selected when several
were ▯▯▯▯▯ the same distance away from the border.

6.10 The two extreme spray lines for each year, i.e., the highest application rate within
the relevant area from Table 13 and the line closest to the border of those over
23.65 liters/hectare as determined above, were given to Dr. Andrew Hewitt for

drift modeling. The selected spray events along with ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
shown in Table 14. In some cases where the highest application rate is exactly the
same, or very nearly so, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
border has been chosen.

124 Annex 5

7. Statement of Qualifications

7.1 International Mapping has performed geographical analysis and mapping for
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯to which International Mapping has
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯s:

▯ Pulp Mills on the River Uruguay: Argentina v. Uruguay (▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯ Territorial and Maritime Dispute between Nicaragua and Honduras in the

Caribbean Sea: Nicaragua v. Honduras (▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯,

▯ Application of the International Convention on the Elimination of All Forms
of Racial Discrimination: Georgia v. Russian Federation (▯▯▯▯▯for Georgia),

and

▯ Land and Maritime Boundary between Cameroon and Nigeria: Cameroon v.
Nigeria: Equatorial Guinea intervening (▯▯▯▯▯for Nigeria).

7.2 In addition, International Mapping recently ▯▯▯▯ed for the Government of
Bangladesh at the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in the Dispute
concerning delimitation of the maritime boundary between Bangladesh and
Myanmar in the Bay of Bengal in 2011 and for the Interim Government of ▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯Abyei Arbitration at the P▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
in 2009.

7.3 The analyses contained in this report were performed based on standard
geographical and statistical methods. All geographical analysis and data

125Annex 5

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Dated: 19 December 2011

Alex Tait

Vice President
International Mapping Associates, Inc.
Ellicott City, Maryland, USA

126 Annex 6

D RB.M. EVANS, PH.D., XPERTREPORT BYD R. ARRYM. E VAN, PH.D.,
D ECEMBER 2011

127Annex 6

128 Annex 6

EXPERT REPORT BY
BARRY M. EVANS, Ph.D.

Prepared for the Government of Colombia

Before The International Court Of Justice
CASE CONCERNING

AERIAL HERBICIDE SPRAYING (ECUADOR v. COLOMBIA)

1. Summary of Completed Analyses and Opinions

1.1 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a service contract with the Colombian

Ministry of Foreign Affairs. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ contract, v▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ spraying

▯▯▯▯▯▯▯▯▯▯place between the years 2000-2003, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Crops by Aerial Spraying with Glyphosate (hereafter, PECIG), ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. These

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

geographic locations visible on a series of sate▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ these

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ as follows:

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Site 2: Cofan Area▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Site 3: San Francisco I and II Area, September 2002 to October 2002

Site 4: Salinas Area, December 2000 to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯

129Annex 6

Based on my r▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ images (as described in detail below),

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-orbiting systems between the years 2000 and 2003 for the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1.2 While significant changes in vegetation cover and condition may be observed in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯– some of

which changes coincide very closely with locations and times associated with PECIG spraying

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ according to available spray data – there are no similar

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ or in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

1.3 While significant changes in vegetation cover and condition may be observed in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯2 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯-Bermejo Ecological Reserve – some of which

changes coincide very closely with locations and times associated with PECIG spraying that to▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ according to available spray

data – there are no similar changes ref▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯-Bermejo Ecological Reserve.

1.4 While significant changes in vegetation cover and condition may be observed in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ – some of which changes coincide

very closely with locations and times associated with PECIG spraying that to▯▯▯▯▯▯▯▯▯▯▯▯

Colombia ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ according to available spray data – there are no

similar changes ref▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Those

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯eved to be entirely

130 Annex 6

1.5 While significant changes in vegetation cover and condition may be observed in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and early 2001 near Salinas – some of which changes

coincide very closely with locations and times associated with PECIG spraying that to▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯that time period according to available spray data – there are no similar

changes ref▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e in the vicinity of Salinas. Those relatively minor

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2. Knowledge of the Dispute and Related Factors

2.1 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯aerial spraying of an

herbicide ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯glyphosate ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ as part of the government-sponsored PECIG program. This spraying was

performed for the p▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯these areas ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

time period. In an application ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯ice, bas▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯as alleged that damage has ▯▯▯▯▯▯▯▯▯▯▯ within

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ inhabitants and the environment ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

chemical herbicides.

2.2 Prior ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯blic of Colombia in the above case, I

▯▯▯▯ed as an expert in the “Arias vs. DynCorp▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. In this case, I provided similar satellite image analysis services

related to assessing aerial herbicide spraying. However, in the Arias vs. Dyncorp case, services

were only provided for a small area encompassing the Mestanza farm ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

described in Sections 3.13 ▯▯▯▯▯▯▯▯▯▯37 of the present report.

131Annex 6

2.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a service contract with the Colombian

expert scientific and technical advice in the field of satellite data/i▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

PECIG ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯place between the years 2000-2003. These analyses were primarily

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯f ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

series of sate▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ These areas were selected based

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯o have

witnessed alleged damage related to the herbicide spraying lived, the proximity of these

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and the availability of satellite images for

the relevant periods covering ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (and these

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)

Site 2: Cofan Area (▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)

Site 3: San Francisco I & II Area (September 2002 to October 2002)

Site 4: Salinas Area (December 2000 to ▯▯▯▯▯▯▯▯▯▯▯▯▯)

132 Annex 6

2.4 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

were provided to me by other parties associated with Colombia’s defense in the above-

The following satellite images were provided by International Mapping in a
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯© GIS (Geographic Information
System) software:

x Color infrared rendition of Landsat image dated December 11, 2000

x Color infrared rendition of SP▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x Color infrared rendition of Landsat image dated September 12, 2002

x Color infrared rendition of SPOT image dated September 22, 2002

x Color infrared rendition of SPOT image dated October 7, 2002

x Color infrared rendition of Landsat image dated October 14, 2002

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x NDVI rendition of Landsat image dated December 11, 2000

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x NDVI rendition of Landsat image dated September 12, 2002

x NDVI rendition of SPOT image dated September 22, 2002

x NDVI rendition of SPOT image dated October 7, 2002

x NDVI rendition of Landsat image dated October 14, 2002

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the date and location of aerial
spray lines ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-
Bermejo Ecological Reserve

2. A copy of testimony provided by Mr. Victor Mestanza to Engineer Roger
Mera, Ministry of the Environment on October 14, 2002 (ANNEX 237 to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)

133Annex 6

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯-Bermejo Ec▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (Witnesses 26,
27, 29 and 31) (ANNEXES 210, 211, 213 and 215 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
dated April 28, 2009).

4. Copies of witness declarations provided ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯9 (Witnesses 11, 12, 13, 14, 18 and
19) (ANNEXES 199, 200, 201, 202, 204 and 205 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
dated April 28, 2009).

5. Copies of witness declarations provi▯▯▯▯▯▯▯▯▯▯▯▯wn residents of Salinas
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯9 (Witnesses 1, 2, 3, 4, 5, 6 and 7) (ANNEXES 189,
190, 191, 192, 193, 194 and 195 to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2009).

6. A copy of the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Conditions of Application for Coca Crops in Colombia” by D.K. Giles”,
prepared by Andrew Hewitt, Ph.D.

7. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Modeling of Plan Colombia
Applications”, prepared by Andrew J. Hewitt, Ph.D.

8. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯by Keith R. Solomon.

In addition, t▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ from t▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ are referenced in

the report:

x Lillesand, T.M. and R.W. Kiefer, 2000. Remote sensing and image interpretation.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. The
interpretation of spectral vegetation indexes, IEEE Transactions on Geoscience
and Remote Sensing, 33, 481-486).

3. Discussion of Opinions Related to Vegetative Changes near the Border in 2000 - 03

A. Initial Background Work

3.1 My initial activity ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, following receipt of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (▯▯▯▯▯▯▯▯▯▯▯▯

134 Annex 6

retained by the Government of Colombia) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯be of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Mapping, it was learned that digital map records in the form of GIS (digital map) files were

available which indicate the date and times of each specific spray event carried ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

PECIG ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

as to date and other rel▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Copies of these files were provid▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

this same time, International Mapping also provided me with a copy of a GIS file that showed

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.2 International Mapping, as part of its activities on behalf of the Government of Colombia,

aerial spray events. In ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

images from ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ specific

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯getation and other

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯l review of these images to identify specific

135Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-effects) in both the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ aerial coca eradication operations at several

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯dor-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and as to which the records of spray flights indicated that there had been spraying in the

imm▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ specific reported spray events since

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯h images was a critical part of

▯▯▯▯▯▯▯▯▯▯▯▯▯

3.3 In relation to the western sector of the border, covering the province of Narino in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nd

cover. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nalysis as described

earlier was not available. However, given the above limitations and considerations, we were able

to identify and obtain for review, the following satellite images that revealed specific locations of

interest in the relevant periods identified:

1. December 11, 2000 (Landsat)

2. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3. September 12, 2002 (Landsat)

136 Annex 6

4. September 22, 2002 (SPOT)

5. October 7, 2002 (SPOT)

6. October 14, 2002 (Landsat)

7. ▯▯▯▯▯▯▯ 19, 2003 (SPOT)

8. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.4 The identified satellites (Landsat and SPOT) collect high-▯▯▯▯▯▯▯▯▯▯▯imagery in a

standardized ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

exam▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯non-military, commercial satellites that have been develo▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ positioned in fixed

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯i.e., they are positioned at fixed

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-determined flight paths). Data

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

reflected and emitted energy fro▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in specific portions of the electromagnetic

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-infrared, and far-infrared portions. When viewed as

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.5 Not all commercial satellites are similar in terms of the data they collect and the spatial

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-co▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ decades. The Landsat 7 system

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ has a sensor

that collects digital data in the visible and near-infrared portions of the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

137Annex 6

1
from 6 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ . The SPOT satellites

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in 1986) also have similar “m▯▯▯▯-spectral” sensors

that collect data in separate channels. The SPOT 4 satellite ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

this report) has a sensor that ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-infrared data at a spatial ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

meters▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in the visible and near- infrared channels, when compared with

Landsat 7 data, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯SPOT satellite images.

3.6 International Mapping also searched other ▯▯▯▯▯ and available satellite so▯▯▯▯▯▯▯▯▯▯▯▯▯

and Digital Globe) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

date range for the specific areas that encompass the geographic locations of interest.

3.7 Copies of the digital image data for the specific dates identified above were obtained and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯described in this

report. The viewing of vari▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ is typically done by displaying

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ representing different portions of the electromagnetic (color)

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯i.e., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

that transmitted data are presented on a color television. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and g▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯(i.e., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ a photograph

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-held or aircraft-borne camera▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯d of image that one typically

sees on web-based ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (see www.google.com/earth/).

3.8 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ng data from the near-infrared channel of each

___________________

1▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

138 Annex 6

satellite ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-tinted image was created that highlighted

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯been

recognized as a standardized approach for vegetation mapping and analysis (Lillesand and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Therefore, as vegetative cover decreases in a

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

green” tones in the image. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Mapping staff created ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

manner in which these images were to be processed ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

correctly.

3.9 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for some of the site analyses, additional

processing was done by International Mapping to create “normalized difference vegetation

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and “near infrared▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

generally repre▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and tropical rainforests (▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ “non-vegetated”

3.10 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯NDVI images were created

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ge processing software, which are two of the

139Annex 6

most widely-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

1 to + 1 as described ab▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-1 to 0 were

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

200). In viewing these images on-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-200 are separated in discrete color

ranges in order to highlight certain degrees of vegetation/non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Section 3.31).

B. Analysis of Relevant Images

3.11 The images described above were each reviewed ▯▯▯▯▯▯▯▯▯▯▯▯▯me to determine what they

revealed▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯iated with each of

▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.12 Analyses for each of these sites are provided below. A more site-specific analysis is

provided for the Mestanza site (Site 1▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯) since ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯smaller in terms

of geographic area than the other sites, and the precise location in which it is alleged by Mr.

Victor Mesta▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Less “site-

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯witnesses live in these cases. Therefore, it was necessary to extend the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nces and farmed areas to which those

witnesses ▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

140 Annex 6

Site 1: Mestanza Farm (Puerto Mestanza)

3.13 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯this is a plot of land

apparent▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

▯▯▯▯▯▯▯▯ depicts ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e the approximate location of this site (shown by the red

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vintage image provided

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Google Earth (see http://www.google.com/earth/).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.14 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

review of the areas allegedly sprayed with herbicide near the Mestanza farm. In Memorial

141Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ place in November of 2000, Ja▯▯▯▯▯▯▯▯▯

2002, September of 2002, and October of 2002.

3.15 Based on the limited dates of the satellite images available, it was determined that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for the alleged spraying in November of ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ of 2002.

More specifically, as to November 2000, an analysis of the spray line data revealed that no aerial

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯y to the west,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ The next closest set of spray lines were over

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

the vicinity of the Mestanza farm in November ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.16 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ terms of their dates

were Landsat ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

however, were far too removed ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2002 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, given the large gap in time, short-term ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯to aerial

▯▯▯▯▯▯▯▯▯▯

3.17 However, for the PECIG ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and October 2002, there were the potentiall▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2003.

3.18 As indicated earlier, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

events that t▯▯▯ place as part of PECIG▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯st ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

142 Annex 6

relevant period in the fall of 2002. As I reviewed the September and October 2002 images and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯te, the “spray

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ . ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-by-step manner is

described below.

3.19 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. More specifically, for those spray lines

shown in Fi▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

these application dates▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in Colombian territory of the

early September herbicide applications on the Septembe▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯se PECIG ▯▯▯▯▯▯▯

effects of the spraying in Colombia, most of the effects from the early September spraying

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯arm -- prior to any impacts of the Fall 2002 PECIG spraying

operations.

2
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

143Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for aerial applications
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.20 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ with

respect to vegetat▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

as well as in Colombian territory across the border river. These observations, as well as

comments on the appearance of vegetation types and conditions on color infrared images, are

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯example areas denoted by “A” ▯▯▯▯▯▯▯▯▯▯▯). Areas with lower-lying “grassy”

144 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯d plants ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-grains

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

vegetative cover (i.e., leaf cover) typicallyap▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯example areas

labeled “B” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ example areaslabeled “C” ▯▯▯▯▯▯▯▯▯▯▯). In contrast, areas

devoid of leaf cover appear in v▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green (indicating

exposed soil), with lighter areas typically being relatively drier, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

relatively wetter and/or having more “non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

example areas labeled “D” in ▯▯▯▯▯▯▯▯). Areas that appear somewhat between “B” and

bare soil (see example areas labeled “E” ▯▯▯▯▯▯▯▯▯▯▯).

2. Based on my observations, it appears that a significantly larger percentage of the

Colombia side of the border ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯had been cleared

of forest ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the examples labeled ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and was in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ s▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

green ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Some areas similar to those labeled “B” and “E” in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯coca fields ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

there is mostly bar▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯not appear on a satellite

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ier vegetative growth for many months or mor▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

example areas labeled ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Finally, the areas which from their color on the

image appear to be bare ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯recent removal of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯/clearing, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

145Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯latter

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ be ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

appear ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green” in tone).

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯he Mestanza

prope▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ing types and density of

vegetation. However, the image does not reveal any ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

as those seen in Colombia. The different colors on the Mestanza property ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯time of the image (September 2002)

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯t▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (Landsat) satellite image with annotations.

146 Annex 6

3.21 Using the same September 12, 2002 image, one can see the area where fish ponds are

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Mestan▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ with the letters “X” and “Y”,

two small areas which appear to be devoid of vegetation at the time this satellite image was

of bare land (or land with very little vegetation). On the basis solely of my analysis of the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯firm ▯▯▯▯▯▯▯▯▯▯▯ as to why these patches of land

were bare, as ▯▯▯▯▯▯▯▯-green coloring might indicate recent planting/harvesting activities or

might be areas that the Mestanzas had ▯▯▯▯▯▯▯▯▯▯▯▯ for other reasons. However, given the date of

September 4-8), the distance of these spray lines from ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

have an eff▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

these areas were devoid of vegetation for ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the aerial spraying. This

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ring this

area show that these areas remained bare in several different years. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

also confirmed by the findings of Hewitt in his report “Aerial Spray Drift Modeling of Plan

Colombia Applications”, for the spray line of September 8, 2002, in Colombian territory, closest

practically zero), as a res▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

147Annex 6

3.22 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

SPOT ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ same spray lines created by the planes

that flew eradication missions in Colombia ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Mestanza farm in

early September 2002 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

September 2002 in the region shown)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in Colombia of the September

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯lines in Colombian territory. In this image, many of these areas appear to have

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

soil and loss of leaf cover as compared to 10 days prior (see example areas labeled as “A”). In

general, there appears to be far ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯eath the sprayed areas, indicating a ▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

148 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ area not sprayed

(below) and a sprayed area immediately above it.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯b. September 22, 2002 (SPOT) image (with September spray lines)

149Annex 6

3.23 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in the close-▯▯▯▯▯ the Mestanza farm

(corresponding to the close-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ shown in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯i.e.,

areas “X” and “Y,” the same area of the fis▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

river (“W”)) as well as other color variations on the Mestanza farm corresponding to different

crops or plant types, which have not changed in any significant degree from the September 12

image.

▯▯▯▯▯▯ 5c. Sept. 22, 2002 (SPOT) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.24 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯rimposed lines onto the October 7, 2002 SPOT image

indicating those spray events ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in October of 2002 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

image (specifically, October 3 and 7)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

150 Annex 6

3.25 As of the date of this image, the effects of the September PECIG spraying operations

within Colombia ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the image. Indeed, there is apparent a clear demarcation within

Colombian territory ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯line between areas in which spraying had ta▯en

the arrows labeled as “B” in F▯▯▯▯▯ 6a). This difference is highlighted by the r▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

of vegetative growth below this line (as indicated by the reddish colors) and areas with little

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green” patches of bare soil above

the line).

3.26 In examining the areas previo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-

lying vegetation (see example areas labeled as “C” ▯▯▯▯▯▯▯▯▯▯▯▯) and taller, woody vegetation

(see example areas labeled as “D” ▯▯▯▯▯▯▯▯▯▯▯▯) immediately adjacent to ▯▯▯▯▯▯▯▯▯▯▯sprayed

areas. In these cases, the strong reddish responses indicate relatively ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

cover that shows no ill effects from nearby spraying activities.

3.27 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ close-▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

any similar changes in the vegetative cover as described above. One can again see the same area

“V” of fish ponds, the same area “W” of homes along the river, and the same patches of bare

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. No significant vegetative changes are visible in any of those

areas. Moreover, none of the vegetated areas on the Mestanza farm appear to have experienced

any changes in vegetative vigor and/or leaf cover similar to those noticeable on the Colombian

side of the river.

151Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ge.

▯▯▯▯▯▯▯▯b. October 7, 2002 (SPOT) (with early October spray lines).

152 Annex 6

▯▯▯▯▯▯▯▯c. October 7, 2002 (SPOT) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.28 ▯▯▯▯▯▯▯▯▯▯▯▯▯b and 7c are all ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e on

October 14, 2002. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯lines in yellow to indicate spray

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in Colombia in October 2002 after the date of the previo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7, 2002) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ closeness in time of the images, one

w▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯effects on Colombia’s side of the border of the

spraying prior to October 7, 2002 on the October 14, 2002 image. However, some effects are

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ October 2002 spray lines shown ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

That is, there appears to be less vegetative cover than that shown a ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

fewer ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green” tones (indicating exposed

soil). There are still areas exhibiting some foliage (see example areas labeled as “A” ▯▯▯▯▯▯▯▯▯▯

7a▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

is typically not evident ▯▯▯▯▯ some ▯▯▯▯▯▯▯▯▯▯▯ spraying. However, mo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green tones indicative of

153Annex 6

defoliated areas with exposed soil (see example areas labeled as “B” ▯▯▯▯▯▯▯▯▯▯▯▯) as seen in

areas to the north affected by the Septembe▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

the effects in Colombia ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green tones) and little re-

vegetation ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

intervening month.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

154 Annex 6

▯▯▯▯▯▯▯▯b. October 14, 2002 (Landsat) Image (with later October spray lines)

3.29 An even more revealing contrast may be seen by comparing the same October 14, 2002

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯b) with the earlier September ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯), which

▯▯▯▯▯▯▯▯▯▯▯▯▯ore most of the effects of the spraying later that month became visible. To

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ayed them both

again on the following page. As is evident from these images, there appears to be no change at

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ing this same time period.

155Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

156 Annex 6

▯▯▯▯▯▯▯▯c. October 14, 2002 (Landsat) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.30 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

river (“W”), the same areas “X” and “X”. No significant changes in the vegetative cover ▯▯▯▯▯▯▯

these areas, or anywhere else on the Mestanza farm, is visible▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Victor Mestanza has claimed that there was “clear evidence of the death of woodlands, orito and

th th
▯▯▯▯▯▯▯▯▯▯ after aerial spray events on “Monday 7 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ of October of this year”

(i.e., October of 2002) (see page 2 of Annex 237 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯). However, none of the

images, as described above, show any evidence of defoliation or decline in vegetation health.

Additionally, none of the September or October images reveal any area near the Mestanza farm

(or elsewhere) where “drifting” herbicide hasdestroyed trees, crops or any other vegetation

157Annex 6

between the site of the spraying and the Mestanza farm. If any damage from drifting herbicide

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, appearing as a change

in colo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

October 2002 satellite ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a-c and 7a-c) reveals ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯when compared to the earlier September 2002 images. ▯▯▯▯▯▯▯▯▯ of change

in vegetation condition is consistent with the findings of Hewitt in his report “Aerial Spray Drift

Modeling of Pl▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-case

scenario” drift modeling, “Deposition rates generally decreased with greater distance from spray

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯dred meters from

release by the aircraft”. Indeed, Hewitt’s findings in the aforementioned report show that for the

spray lines of October 7 and 12, 2002 (which were closest to the border river in the vicinity of

the Mestanza farm), the lines were at a distance of 891 and 570 meters, respectively, from the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e insignificant (i.e.,

1.15 g/ha and 2.71 g/ha, respectively).

3.31 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ver

three months after the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯is part

of the world, vegetation grows v▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-grow within a three-month period. In this image, the

areas sprayed in Colombia in both September and October 2002 appear to show a range of

responses to the defoliant ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

158 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. In some areas on the Colombian side, the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯“A” ▯▯▯▯▯▯▯▯▯▯▯▯) as

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯- planted coca, weeds

labeled as “B”). In contrast, other areas appear still to be devoid of vegetation to varying degrees

(see example areas labeled as “C”). These latter areas may have experienced more devastating

defoliati▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯all September and October spray lines).

159Annex 6

▯▯▯▯▯▯▯▯▯. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.32 ▯▯▯▯▯▯▯▯▯▯ador side of the river, the close-▯▯ image shown in ▯▯▯▯▯▯▯▯▯ (which

corresponds to the close-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ again reveals no evidence

of ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯de spraying in Colombia on the Mestanza farm. One change

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-planted crop on that

plot of land which was bare in 2002. Otherwise, I do not see any significant changes on the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

160 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.33 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯fferent view of the same October 14, 2002 Landsat satellite image as

shown earlier ▯▯▯▯▯▯▯▯▯▯▯▯▯▯- 7c, which depicts a larger geographic region (i.e., it appears to be

from a “higher-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the ▯▯▯thern

extent of the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

place in Colombia. This view provides an even better perspective of the considerable contrast

between the areas corresponding to the location of the spraying in Colombia, which exhibit ▯▯▯▯▯

of vegetation, above the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

farmers do clear the land and pl▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ a major role

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

161Annex 6

▯▯▯▯▯▯▯▯▯ Enlarged “regional” view of October 14, 2002 Landsat image

3.34 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

these i▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯generally ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

tend to be water or “non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Mestanza property, and lighter oranges and yellows tend to be “vegetation-free” areas as might

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ areas defoliated by aerial spraying.

3.35 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ NDVI image of the same portion of the September 12, 2002 Landsat

image ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯NDVI image that corresponds to the portion of

162 Annex 6

the September 22, 2002 SPOT image ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-5b▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

correspond to the SPOT and Landsat images from October 7, 2002 and October 14, 2002, shown

▯▯▯▯▯▯▯▯▯▯▯▯▯-6b and 7a-7b, respectively. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

place in the period ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.36 It is to be noted that the annotations shown on these images are the same as those shown

on their corresponding color infrared images. The slight difference in the “brightness” of the

colors between the NDVI images derived from the Landsat images and those derived from the

SPOT images is ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯type has “visible” and “near infrared”

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯fferent

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.37 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

on the Colombian side of the border ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

defoliated areas in these images correspond closely with these same areas ill▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

September-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯erty.

3.38 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯pert opinion is that while changing levels of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-2003 in the immediate area of

– ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯– the September and October 2002 PECIG spraying

operations, there are no similar changes in vegetation ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

river in the area of the Mestanza farm.

163Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯ 11. NDVI image for September 22, 2002

164 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

165Annex 6

Site 2: Cofán Area

3.39 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-Bermejo Ecological Reserve▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ to the west of

the Mestanza site, a less site-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a. However, a similar

events completed in Colombia as part of PECIG via the analysis of satellite images. That is, the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-Bermejo Ecological Reserve. In this case,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯SPOT images) were not available ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (i.e., the images from the

SPOT satellite did not extend that far west). ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the September 12 (Landsat), October 7 (SPOT), and

October 14 (Landsat) images ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

analysis▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. The late September 2002

time frame was ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯that was closest to the

▯▯▯▯▯-Bermejo Ecological Reserve ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.40 Prior to doing the analysis for this site, it was first necessary to define a more specific

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯cinity

▯▯▯▯▯▯▯▯▯▯▯▯-Bermejo Ecological Reserve.

3.41 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (i.e., Witness 26 in

Annex 210 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, Witness 27 in Annex 211, Witness 29 in Annex 213, and

Witness 31 in Annex 215)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-Bermejo Ecological

166 Annex 6

events a▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. T▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯was not provided in the Annexes mentioned above,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ provided to me.

3.42 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯-Ber▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Reserve itself. Sho▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ of the October 7, 2002 SPOT

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯llow are the spray lines

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the three primary satellite images ▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯More specifically, these spray lines ▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ and September of 2002 (there was no aerial

spraying in this area after September in 2002). The labeled ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

river that defines ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ the northern

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

The remainder of the spray lines shown to the north and east are ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

167Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.43 Based on the above information, the area ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ was the geographic limit of the Reserve ▯▯▯▯▯▯▯▯▯to the

east an▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-to-east to

▯▯▯▯▯▯▯▯▯ (this small river can be seen more clearly on the image in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

later)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯witnesses identified above testified that

they resided within the Reserve. ▯▯▯▯▯▯▯▯▯y area is pre▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nities

near the river that defines the Colombia-▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

168 Annex 6

resided▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, as described above,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯es▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯

identified ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

(approximately 16,000 hectares), as well as by the fact that no aerial spray lines were recorded to

the west of those identified ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. This

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.44 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

annotations, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯For context, the geographic area

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯From

these color infrared images, it can be seen thatmany plots of land north of the border in

Colombia are devoid of vegetation as indicated by the characteristic ▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯14.

169Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

170 Annex 6

3.45 Upon reviewing the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

15 and 16, respectively, it was noticed that those areas of Colombia that were sprayed prior to

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ shown

▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯at were sprayed after

September 12. The approximate locations of these gr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (highlighted in green)

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in the areas sprayed prior to September 12, as

contrasted with these same areas in the October 7 image ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, from

October 7, more evidence of defoliation is present on the Colombian side in areas in which

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯September 12 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the spraying after September 12 was ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
September 12, 2002 Landsat image.

171Annex 6

3.46 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯s of the October 14, 2002 Landsat

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯18 and 19, respectively.

From these images, one can see that vegetation conditions in Colombia between October 7 and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯03, many of the areas appearing

as “vegetation-free” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e of vegetative

cover similar to the conditions exhibited in September of 2002. (▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

172 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.47 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯close-▯▯” review was made

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ries of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯described earlier to see if there were any changes in vegetation (i.e., from a

vegetated to a non-vegetated condition) similar to those seen in Col▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

review, no evidence of similar vegetation changes within the entire area of approximately 16,000

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ of one small area located close to the river that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a. That small area was located in the vicinity of spray lines which

had been sprayed in Colombia on September 22, 2002. The general location of this area is

173Annex 6

indicated by the “A” in ▯▯▯▯▯▯ 17. Hewitt’s findings in his report “Aerial Spray Drift Modeling

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ which were close to zero:

Row 22: line of 22 September 2002, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
meters, Deposition: 0.633 g/ha

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
meters, Deposition: 0.137 g/ha
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
meters, Deposition: 0.0673 g/ha
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

meters, Deposition: 0.637 g/ha

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.48 An enlarged view of the area descr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 20 which shows

conditions as seen on the September 12, 2002 Landsat image as well as indicating the location of

the spray lines in late September 2002▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯interest is ▯▯▯▯▯▯▯▯▯▯

one-half hectare area, again indicated by the annotation “A”. On this image, the area can be seen

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-lying vegetative cover; whereas in the October 7,

2002 image ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯des o▯▯▯▯▯▯-gray

indicating a change in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯This change, however, is

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯it ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯bright red▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

healthy vegetation. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ still relatively

these spray lines within Colombia.

174 Annex 6

▯▯▯▯▯▯▯▯▯▯ October 7, 2002 SPOT image.

175Annex 6

3.49 Area “A” is similar in appearance to three other areas ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯that can

be seen nearby as indicated by annotation “B” ▯▯▯▯▯▯▯▯▯▯▯▯. As evident ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, these

latter areas were “vegetation-free” on or before September 12, 2002▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2002▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. ▯▯▯▯▯▯▯▯22 and 23 show

close-▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, as depicted on the October 14,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. As can be seen in

▯▯▯▯▯▯▯▯▯, the conditions described for site “A” for October 7 are still evident on October 14,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, however, this area appears to have developed vegetative cover

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.50 Another example ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in

Colombia ▯▯▯▯▯▯▯▯▯▯▯▯▯d by the white circle in F▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. From the drastic change in

vegetative conditions noticeable on the Colombian side from September 12, 2002 to October 7,

2002, one can see how the intensive aerial spraying has essentially obliterated the vegetation

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ are

indicative of healthy vegetation, and the area remains ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nged from September 12,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.51 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

176 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

177Annex 6

Site 3: San Francisco I & II Area

3.52 I was provided with a GIS map showing ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Francisco I and San Francisco II. I▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ to me, six (6) witnesses living

aerial spraying activities in Colo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

provided descriptions of the approximate locations of their homes and/or farms with respect to

the border with Colombia. Witness #12 described having a 35-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ers

from the border (Annex 200); Witness #13 described having a 52-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯s from the border (Annex 201); Witness #14 described having a 55-hectare farm less

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯om the border (Annex 202); and Witness #18 described wor▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (Annex 204). ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

sister of Witness #12, and apparently lives at the same location.

3.53 Based on the above information▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for this site

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯centered on San

Francisco I and II (shown as green ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (which is

approximately 5,046 hectares in size) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

River, which serves as the border betwee▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in this region. In creating this

area, an attempt was made so far as possible ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ located

close to San Francisco I and II ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

178 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.54 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

images that were available ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

12, 2002 (Landsat), October 7, 2002 (SPOT), and October 14, 2002 (Landsat). In this case, the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

there other SPOT, Landsat or other satellite images available for these or similar dates in time.

179Annex 6

3.55 Given the dates of the satellite images available for this area, the aerial spray dates

considered for the analysis performed werethose events that ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Colo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ September 12, 2002 and October 14, 2002. This was done

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯lag time between spray events and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ effects that might be

▯▯▯▯▯▯▯▯▯ spraying activities on or ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

noticeable by the date of the October 14 image.

3.56 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ representing aerial spray

applications that o▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

September 11 and October 13, 2002 (i.e., one day before the first and last dates of the satellite

images). Within this interval, spr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

being September 11 and October 13, respectively. These lines are generally within a few

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. Those lines shown in

3.57 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯a from September

12 to October 14, 2002. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated areas based on the presence/▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green

3.58 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯d earlier (Annexes 199, 200, 201, 202, 204 and 205),

180 Annex 6

in rather rapid and dramatic damages to crops and plants ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

and II. Example▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

that, all the plants drie▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

incredible, never before had we seen all the plants die at the same time. All of them

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯204)

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

river, there were two planes and two helicopters. Shortly after they sprayed, all the plants

died.” (Witness 19, Annex 205)

3.59 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ above allegations as to the effects of the spraying were

Francisco I and II shortly after nearby aerialspraying operations in Colombia were completed.

So fo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ one w▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

see an extensive portion of the landscape visible on the satellite images change from bright,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-green (indicative of

181Annex 6

defoliation and plant loss). As described below, a satellite image analysis of this type was

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.60 In the first phase of this analysis, the color infrared satellite images from September 12 to

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-half

from both a vegetated to non-vegetated ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯s from reddish

▯▯▯▯▯▯▯▯▯▯▯▯-green ▯▯▯▯), as well as from a non-vegetated to a vegetated condition (as indicated

by a reverse shift in ▯▯▯▯▯▯▯▯▯▯▯▯having completing ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

chang▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.61 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2002, respectively. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

that were ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e applications completed in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

September of 2002. Note also that the SPOT image available for October 7 did not extend far

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. This, however, did not affect the analysis in this case since

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯re primarily based on the vegetation differences evident between September 12

and October 14.

182 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

183Annex 6

▯▯▯▯re 27▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ image.

3.62 ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ns have changed from vegetated to non-

represent parcels ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

“parcels” had changed from vegetated to non-vegetated, and 30 had changed from non-vegetated

to vegetated. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯that the dramatic changes alleged

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯nts in the area (see Section 3.58) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

vegeta▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯area, a

184 Annex 6

▯▯▯▯▯▯▯▯▯▯al ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯scribed in Sections 3.9 and 3-10

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

▯▯▯▯▯▯▯▯▯. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated,
▯▯▯▯▯▯▯▯▯▯▯-vegetated to vegetated). Image shown is Landsat from October 14, 2002.

3.63 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯images ▯▯▯▯▯▯▯▯▯▯▯▯ed to range from -1 to +1, with ▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated

▯▯▯▯▯▯▯▯ (see Sections 3.9 and 3.10)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ depict NDVI images derived from the

September 12, 2002 and October 14, 2002 Landsat images, respectively. (Note: the middle

detailed below).

185Annex 6

▯▯▯▯▯▯▯▯▯. NDVI image derived from September 12, 2002 Landsat.

▯▯▯▯▯▯▯▯0. NDVI image derived from October 14, 2002 Landsat.

186 Annex 6

3.64 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

two NDVI images were simplified to create two new “vegetation” maps that only show

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯- type 1 (i.e., non-vegetated areas remain non-vegetated), 2) no change -

type 2 (i.e., vegetated areas remain vegetated), 3) change from vegetated to non-vegetated, and

4) change from non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ember 12 and October 14.

3.65 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

a▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ shows the “difference” map that was derived by comparing

the va▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-dated map to those in the earlier-dated map. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

of “1” (indicating vegetation) are shown in green, and non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯own in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, areas that remained vegetated from September 12, 2002 to October 14,

2002 are shown in light green; non-vegetated areas that did not change from one date to the next

are shown in brown; areas that changed from non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

areas that changed from vegetated to non-vegetated are shown in yellow. (Note that “brown

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ and “▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ along the northern edge of the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

187Annex 6

▯▯▯▯▯▯▯▯▯. Vegetation map for September 12, 2002 (from Landsat)

▯▯▯▯▯e 32. Vegetation map from October 14, 2002 (from Landsat)

188 Annex 6

▯▯▯▯▯▯▯▯▯. Vegetation changes between September 12 and October 14 of 2002.

3.66 F▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

(and 10.8% non-vegetated) on Octob▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, it was determined that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

September12 to October ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ changed from non-

vegetated to vegetated.

189Annex 6

3.67 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-month interval between September

12, 2002 and October 14, 2002. However, this was also a period when extensive aerial herbicide

earlier.

3.68 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

plant growth, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Section 3.58), then a significant change in vegetation condition (i.e., a shift from “vegetated” to

“non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

dates. Moreover, as described earlier in the analysis performed for the Mestanza farm (Site 1),

vegetated to non-vegetated ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

3.69 In his report “Aerial Spray Drift Modeling of Plan Colombia”, Hewitt also modeled the

p▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯lly zero: 0.01 g/ha and 0.01

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

190 Annex 6

river▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯3 g/ha and 0.1 g/ha, respectively (i.e., nearly zero). In 2002,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

z▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯observed on the images in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Site 4: Salinas Area

3.70 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯geographic

area ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ was defined on the basis of witness statements regarding the locations

of their homes/farms within this area and the extent of available satellite images. ▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ alternative locations for this

▯▯▯▯▯▯▯▯▯▯▯referred to as Salinas I and II] are described in the text and i▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

activities in Colombia that were completed at the end of 2000 and the beginning of 2001, the two

area was limited to the western edge of the SPOT image since it did not extend as far to the west

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯aerial spray activities that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

191Annex 6

3.71 In the witness statements for the seven ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯s as residing in

Salinas, six gave descriptions of where they lived or farmed. All six said that they had lived or

farmed “near” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Annex 190; Witness 3, Annex 191; Witness 5, Annex 193; Witness 6, Annex 194; and Witness

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ are the two alternative

locations of Salinas (shown in green), as well as spray lines (shown in yellow) representing aerial

herbicide applications in Colombia between ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

17, 2001. In this instance, spray events in the relevant region within ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

spray activities completed between the two image dates.

192 Annex 6

▯▯▯▯▯▯▯▯▯. Salinas ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.72 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯enlarged portions of the satellite images for December 11,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. As can be seen

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯fairly dramatic changes in vegetation on the Colombian side of the border, as

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

identified as “A” ▯▯▯▯▯▯▯▯▯▯▯▯) are apparent, and these very closely correspond to the locations in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

193Annex 6

▯▯▯▯▯▯▯▯▯. December 11, 2000 (Landsat) image.

▯▯▯▯▯▯▯▯▯. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

194 Annex 6

3.73 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ (San Francisco I and II), an image analysis was

between the times of the two image dates. Specifically, the satellite images were analyzed to

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated areas based on the presence/absence of

reddi▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯or infrared images. ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

analysis. As ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

changed from vegetated to non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

17, 2001; whereas white dots depict parcels where conditions changed from non-vegetated to

vegetated.

3.74 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tivation activities. In fact, some of the larger “non-

vegetated” areas (see examples labeled “B” in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

“shifting” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-tropical regions where the need exists

and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ed areas on color infrared

images, on which large masses of brown-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

very ▯▯▯▯▯▯▯▯▯-green. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in 2002 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯]). Of the 37 parcels

identified, 23 changed from vegetated to non-vegetated, whilst the remaining 14 shifted from

non-vegetated to vegetated ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

additional analyses ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

195Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯
vegetated to non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated to vegetated).

3.75 Similar to the exercise performed for the San Francisco site, NDVI images derived from

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

vegetation maps for those two time periods. Th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and 39,

respectively. Also▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ prepared for the San ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯2001. F▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯d 39, it was determined that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated) on December 11, 2000; and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

di▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, it was de▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

changed from vegetated to non-vegetated between the two dates▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯3.4% of the area

had changed from non-vegetated to vegetated.

196 Annex 6

▯▯▯▯▯▯▯▯▯. Vegetation map derived from December 11, 2000 Landsat image.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

197Annex 6

3.76 In the witness statements described earlier (see Section 3.71▯▯▯▯▯▯▯▯▯▯ claims were made

by residents of Salinas ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯zapote, were the first ones to be affected. These tall trees were the first

198 Annex 6

died.” (Witness 1, Annex 189)

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯”

(Witness 2, Annex 190)

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)

everything.” (Witness4, Annex 192)

3.77 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

herbicide applications on the Colombian side of the river▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e evident based

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯above. Based on these analyses▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯on is

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ between the two dates

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯more or less ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-vegetated,

and vice versa), and there was also no evidence of damage to vegetati▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

“areas of change” described above ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

199Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3.78 In his report “Aerial Spray Drift Modeling of Plan Colombia Applications”, Hewitt also

modeled the relevant spray lines. In 2000, two lines were identified at distances of 3,890 meters

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ meters

0.106 g/ha and 0.167 g/ha, respectively (again, close to zero). In 2002, there were two lines at

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tory, which is

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4. Discussion Regarding the Heights of Trees Near Aerial Spray Sites in Colombia

4.1 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯s sprayed

as part of PECIG ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ across bordering rivers into areas of ▯▯▯▯▯▯▯▯

immediately downwind of PECIG ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯This is so ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ that meteorological conditions in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-to-north direction (i.e.,

200 Annex 6

relevant. As indicated by Hewitt in his report (“Response to Report “Spray Drift Modeling of

Conditions of Application for Coca Crops in Colombia” by D.K. Giles”), forested areas serve as

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tial effects of aerial

spraying. As also indicated by Hewitt in the same report, the drift modeling performed by D.K.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

spray sites in Colombia and areas ac▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

4.2 As described below, relatively high-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯dsat and SPOT

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

described below.

Site 1: Puerto Mestanza

4.3 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯n of high-▯▯▯▯▯▯▯▯▯▯▯satellite images available via Google Earth

(dated October 26, 2006) that were close in date to when aerial herbicide applications in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯), I estimated the heights of the trees and other vegetation

across the river from ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in Colombia. (Note: high-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

October 26, 2006). I did this ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

interpretation. That is, I ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

201Annex 6

meters. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ at

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ in the image▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

relationsh▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ cast a 2-meter shadow, then a tree

casting a 16-meter ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

meters high]). ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e same image.

4.4 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯my observation▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯n ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

areas represent different patches of vegetation on the landscape that are composed of vegetation

that vary in plant density and height. The labeling scheme is as follows:

1: Areas of dense trees with heig▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯– 30 meters.

2: Areas of dense trees with heig▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯– 15 meters.

3: Areas of less dense trees with heig▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯– 15 meters.

4: Areas with dense mix of trees ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2 – 30 meters.

5: Areas with mix of scattere▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯those that have low-lying vegetation or have been cleared for

▯▯▯▯▯▯▯▯▯▯▯, or wher▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ are the spray lines for aerial herbicide applications that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in ▯▯▯▯▯▯▯▯▯.

202 Annex 6

4.5 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯having trees

and plants of considerable height that were located between the locations in Colombia that

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ across the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯ 41. Vegetation map derived from October 26, 2006 satellite image.

203Annex 6

▯▯▯▯▯▯▯▯▯. Aerial spray lines (shown in yellow) for the year 2002.

Sites 3 and 4: San Franciso I and II, and Salinas I and II

4.6 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Similar to the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ for Site 1 above, an analysis of satellite images provided via Google Earth

was performed to characterize the relative heights of vegetation in the areas between both San

Francisco I and II and Salinas I and II, and areas across the river in Colombia where aerial

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ However, d▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

these two ▯▯▯▯▯▯▯▯▯▯s ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

204 Annex 6

vegetation map was prepared in this instance. More specifically, a more generalized vegetation

map was prepar▯▯▯▯▯▯▯▯▯information gleaned from the Google Earth images in combination with

information derived from the NDVI map created from the September 12, 2002 Landsat image (a

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4.7 As described earlier in Sections 3.9 and 3.10, NDVI ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

low-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯is, the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ patches of taller vegetation

(i.e., trees and similar plants generally ranging in height from meters to tens of meters) in the

vicinity of San Francisco (I and II) and Salinas (I and II). This was essentially done via the

following steps:

1) A ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

higher-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯from 2006 and 2007 available via Google Earth.

2) Areas corresponding to the “sample areas” identified above were located on the September 12,

2002 Landsat image.

3) The range of NDVI ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4) Based on the above information, patches of taller vegetation were identified and mapped

across the entire image.

4.8 Shown in ▯▯▯▯▯▯▯▯▯ is the vegetation map ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯enerally ranging in height from meters

to tens of meters is represented by the green patches. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

in red, and spray lines corresponding to aerial herbicide applications completed in 2000, 2001

205Annex 6

and 2002 are shown in bl▯▯▯▯Also shown in ▯▯▯▯▯▯s ▯▯▯▯▯▯▯▯▯▯▯▯▯ are enlargements of the

vegetation maps for the two sites with their corresponding portions of the September 12, 2002

Landsat image.

▯▯▯▯▯▯▯▯▯. Map ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ and aerial spray
l▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

206 Annex 6

▯▯▯▯▯▯▯▯▯. September 12, 2002 image of San Francisco I and II area.

▯▯▯▯▯▯▯45. Map of “taller” vegeta▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

207Annex 6

▯▯▯▯▯▯▯46. September 12, 2002 image of Salinas I and II area.

▯▯▯▯▯▯▯47. Map of “taller” vegeta▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

208 Annex 6

209Annex 6

ADDENDUM

Background and Relevant Experience

My name is Dr. Barry M. Evans. I ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ of over 30 years▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

directly on GIS (geographic information systems) and environmental projects for both

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

of aerial photographic and/or satellite images. I have also performed environmental mapping,

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯gency

and others for state government agencies and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯revolved ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

the analysis of aerial photography and satellite images, and, at one point, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

cle▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

many of the my more recent projects ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯otography and/or

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

mapping/analysis. Most recently in 2010, I was a principal investigator in a project completed for

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

210 Annex 6

From the mid-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e data for identifying the location of medicinal plants in

the mid 2000’s, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯-ba▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

environmental non-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the Amazon region ▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Control from Penn State

University in 1978, and a Ph.D. in Soil Science from Penn State in 2002.

A c▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

to 1979.

211Annex 6

BARRY M. EVANS

EDUCATION

Pre-Engineering. Vincennes University, 1970-71.
B.S., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

M.E.P.C., ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Ph.D., Soil Science. The Pennsylvania State University, 2002.

CAREER SUMMARY

2002-Present Senior Researcher, Penn State Institutes of Energy and the Environment

Dr. Evans is a ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Energy and the
Environment (PSIEE). At PSIEE, he is primarily responsible for obtaining and managing applied

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ors. In this role, he has
managed ▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯-million dollar open-end contract to provide environmental /▯▯▯▯▯▯▯▯▯▯▯▯
services to the Pennsylvania Department of Environmental Protection (PaDEP), as well as other state
agencies. Of late, he has been primarily involved in developing specialized software applications to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ment needs. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯MapShed, AVStreams, PRedICT, AVNPSTool and
SWAP-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
water protectio▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ mitigation strategies at the watershed level. Dr. Evans has
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯In addition to h▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ has also provided technical expertise to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Mexican
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯er Technology; the Scottish Environmental Protection Agency; the Swedish
Meteo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯the Environment Agency (of England and Wales), the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and to local and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1995-2002 Senior Research Assistant, Environmental Resources Research
Institute, Penn State University

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ governmental and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯-million dollar contract to provide GIS services to the
Pennsylvania DEP and other state agencies.

1988-1995 President, Geo Decisions, Inc., State College, PA

Responsible for corporate management as well as obtaining and managing GIS and environmental
pr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-recognized firm specializing in geo-spatial technologies.

1984-1988 Research Assistant, Environmental Resources Research Institute,
Penn State University

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

GIS and remote sensing technology.

212 Annex 6

1981-1984 Manager of Environmental Mapping Section, Resource Technology

Corporation, State College, PA

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
landscape analysis.

1980-1981 Owner/Manager, Remote Sensing Consultants, State College, PA

Obtained and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1978-1980 Consultant, Development Sciences, Inc., Sagamore, MA

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
inventories.

1976-1978 Project Manager, Trident Engineering, Warrenton, VA

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-site contractor at the U.S. EPA’s Environmental Photographic Interpretation Center.
Projects completed invo▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

5. PROFESSIONAL MEMBERSHIPS

Soil and Water Conservation Society
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
International Water Association

RECENT CONSULTANCIES

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
CH2M-Hill, Inc.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
National Water Commission, State of Israel
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Inc.

Environment Agency of England and Wales
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
BION Environmental Technologies, Inc.
Zedx, Inc.

213Annex 6

OTHER

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Board of Directors, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

SELECTED PUBLICATIONS AND REPORTS

Program or Policy, pp. 285-297. In ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
from the 14th ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
States: Phase 1. Report to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Energy and the Environment, 157 pp.

Boston, T., B. Evans and C. Stang, 2010. Review of Agri-Environmental BMP Effectiveness. Report to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e Environment, 66 pp.

Strobl, R.O., B.M. Evans, F. Somma, E. Garcia-Gorriz, A. Stips and J.M. Zaldivar, 2008. Feasibility
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Evans, B.M▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
th
of the GIS-▯▯▯▯▯▯▯▯▯rient Management Model CANWET in Ontario. In: Proc. 58 Natl. Conf. Canadian
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214 Annex 6

GIS-Based Modeling Approach, 2004. In: Pahl-Wostl, C., Schmidt, S. and ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
International Congress: "Complexity and Integrated Reso▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and Software Soc.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Sheeder, S.A. and B.M. Evans, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-
888.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 2004. Developing Statistical Models to Establish the

Gracz▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯). Elsevier Science,
Amsterdam, pp. 353-358.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
within a Watershed. Proc. 7 International Conf. On ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Ireland, Vol. 2 of 4, pp. 10.7 – 10.12.

Evans, B.M., D.W. Lehning, K.J. Corradini, G.W. Petersen, E. Nizeyimana, J.M. Hamlett, P.D.
Robillard, and R.L. Day, 2002. A Comprehensive GIS-Based Modeling Approach for Predicting
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯J. Spatial Hydrology, Vol. 2, No. 2.,
(www.spatialhydrology.com ).

Evans, B.M., D.W. Lehning, K.J. Corradini, and M.C. Anderson, 2002. Description of GIS-Based
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ State University, 23 pp.

Chang, H., B.M. Evans, and D. Easterling, 2001. The Effects of Climate Change on Stream Flow and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-986.

Hamlett, J.M., B.M. Evans, C.G. Knight, J.J. Carmichael, T.N. Hristov, D. Dimitrov, V.D. Ioncheva, I.I.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯-stream models. ASAE Microfiche No. 01-2123. ASAE, St. Joseph, MI.

Ghebremichael, L.T., J.M. Hamlett, and B.M. Evans, 2001. Incorporating a pesticide component into the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-2129. ASAE, St. Joseph, MI.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ersity, 73 pp.

215Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Garcia, L.E. Johnson, J.D. Jorgeson, V. Krysanova, G. Leavesley, D.R. Maidment, E.J. Nelson, F.L.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Reston, VA, 120 pp.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯elopment of a GIS for Managing
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Evans, B.M., 1998. Development of an Historic State-Wide Defoliation Database in Pennsylvania. In:
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Vista, FL, pp. 309-313 (Vol. II).

Evans, B.M. and E. Nizeyimana, 1998. GIS-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯oc. 3 rd
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Evans, B.M., 1998. GIS-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. In:
Proc. Watershed Mgmt: Moving from Theory to Implementation, Denver, CO, pp. 841-848.

Petersen, G.W., E. Nizeyimana, and B.M. Evans, 1998. Applications of Geographic Information Systems
in Soil Degradation Assessments. In: B.A. Stewart (ed) Methodologies for Assessing Soil Degradation,
Advances in Soil Science, CRC Press, Boca Raton, FL.

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Environ. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Univ.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Nizeyimana, E., B.M. Evans, M.C. Anderson, G.W. Petersen, D.R. DeWalle, W.E. Sharpe, J.M. Hamlett,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Watersheds.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯and K. Klein, 1996. Development of a Phytohabitat Index for
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426, ISHS.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯GIS-Based Spatial
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ No. ER9605, 43pp.

Myers, W.L., B.M. Evans and M.C. Anderson, 1996. Spatial (In)consistency of Watershed Delineations
Among Agencies and Scales in Pennsylvania. In: Proc. 2 Intl. Symp. Spatia▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Nat. Res. and Environ. Sciences, Colo. State Univ., Fort Collins, CO.

216 Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯l. 25, pp. 346-354.

Hamlett, J.M., G.W. Petersen, B.M. Evans, L.A. Deichert, S.R. Messier, M.C. Anderson, and G.M.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

in Pennsylvania. Environ. Res. Res. Inst., Penn. State ▯▯▯▯▯▯▯▯▯▯▯▯ER9502.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-06, 76 pp.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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Sasows▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
815-824.

Evans, B.M. and W.L. Myers, 1990. A GIS-Based Appr▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-245.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Vegetation and Landscape E▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of Holarctic Ecology.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of a Geographic Information System. In: Proc. Symp. on Nonpoin▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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System. In: Proc. Symp. on Floodplain and Stormwater Management, Penn State University Office of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯, NYC.

Myers, W.L▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Digital Pattern Recognition in Preparation of Thematic Maps. ISPRS J. Photogrammetric Engineering
and Remote Sensing, 44: 85-96.

Evans, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

217Annex 6

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ Disposal Sites.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

Evans, B.M. 1983. Using Aerial Photography to Detect Vegetation Damage in a Large-▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Monitoring Program. Proceedings, Ninth Bie▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Science, Orlando, FL.

Evans, B.M. 1982. Aerial Photographic Analysis of Septic System Performance. Photogrammetric
Engineering and Remote Sensing, 48(11).

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Arbor, MI.

218 Annex 7

C OLOMBIANEXPERT ONENVIRONMENTALLAW, MRJOSÉ VICENTEZAPAT,

CRITIQUE OF TREPORTPREPARED BM SC LAUDIR OJAQ UIÑONEZ DATED
JANUARY2011ON “THE AERIASPRAYPROGRAM ANDVIOLATIONS

OFC OLOMBI’SDOMESTICLAWSR EGARDINTHE ENVIRONMENTAND
THE RIGHTSOF NDIGENOUSPEOPLE”, NOVEMBER2011

219220 Annex 8

EXPERT REPORT OFD RG. M ARCELLA, H.D.ON BEHALF OF THE
DYN CORP DEFENDANTS IA RIA/QUINTEROS . YNC ORP(D.D.C.),

17 ANUARY 2011

(United States District Court for the District of Columbia,
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Cases consolidated for Case Management and Discovery)

283284 Annex 8

Case 1:07-cv-01042-Filed 08/19/11 Page 1 of 51

EXHIBIT 10

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 2 of 51

EXPERT REPORT BY DR. GABRIEL MARCELLA
ON BEHALF OF THE DYNCORP DEFENDANTS IN

ARIAS/QUINTEROS v. DYNCORP (D.D.C.)

I. Expert Credentials and Required Disclosures

A. General Professional Credentials.

My name is Dr. Gabriel Marcella. I teach the “Americas” course at the United States

Army War College (USAWC), where I served from 1981 until 2008 as a professor of Third

World Studies and the Director of the Americas Regional Studies in the Department of National

Security and Strategy. I am a recognized authority on United States policy and strategy in Latin

America and have been working in this field for over 45 years, dating back to my studies as a

Fulbright Scholar in Quito, Ecuador in 1964-65. I have instructed military and civilian officers

of the United States and foreign countries (including Colombia and Ecuador) on international

security issues in Latin America, including the threats posed by narcoterrorism. I have also

served as a consultant on these matters to the U.S. Department of Defense, United States

Southern Command, U.S. Department of State, and National Defense University.

My publications include over 100 articles, book chapters, monographs, edited volumes

and commentaries on Latin America and the United States’ vital security interests in the region.

I have written extensively about “Plan Colombia,” the United States’ security interests in

Colombia, and the threats posed by the narcoterrorist organizations. My publications on these

topics include: “Colombia’s Three Wars: U.S. Strategy at the Crossroads,” Carlisle, PA:

Strategic Studies Institute (SSI), March 5, 1999; “Plan Colombia: The Strategic and Operational

Imperatives,” Carlisle, PA: SSI and North-South Center, April 2001; “Plan Colombia: Some

Differing Perspectives,” Carlisle, PA: SSI, June 2001; “The U.S. Engagement with Colombia:

Legitimate State Authority and Human Rights,” Miami: University of Miami, North-South

285Annex 8

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Center, March 2002; “The United States and Colombia: The Journey from Ambiguity to

Strategic Clarity,” Carlisle, PA: SSI, May 2003; “American Grand Strategy for Latin America

in the Age of Resentment,” Carlisle, PA: SSI, September 2007; “War Without Borders: The

Colombia-Ecuador Crisis of 2008,” Carlisle, PA: SSI, December 2008; and “Democratic

Governance and the Rule of Law: Lessons Learned From Colombia,” Carlisle, PA: SSI,

December 2009. With respect to Ecuador, I also have co-authored a book and authored a report

for the Strategic Studies Institute about its war with Peru in the 1990s: Security Cooperation in

the Western Hemisphere: Resolving the Ecuador-Peru Conflict, Miami: University of Miami,

North-South Center Press, May 1999; “War and Peace in the Amazon: Strategic Implications for

the United States and Latin America of the 1995 Ecuador-Peru War,” Carlisle, PA: SSI,

November 24, 1995.

Prior to joining the USAWC, I served from 1974 to 1981 as a Foreign Affairs Analyst at

the Strategic Studies Institute of the USAWC. From 1987 to 1989, I took leave from USAWC to

serve as the International Affairs Advisor to the Commander-in-Chief at the United States

Southern Command in Panama. In 1997, I took a research sabbatical at the Bureau of Western

Hemisphere Affairs of the U.S. Department of State. During my service in government I have

consulted with officials responsible for formulating and implementing U.S. policy for Colombia.

I received a B.A. in Latin American Studies from St. Joseph’s University in Philadelphia

in 1964. I received an M.A. in History from Syracuse University in 1967, a Ph.D. in Latin

American History from the University of Notre Dame in 1971, and a diploma from the Inter-

American Defense College in Washington, D.C. in 1981. I was a member of the Bipartisan

Commission on Central America, the Atlantic Council Study Group on Central America and the

286 Annex 8

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Caribbean, the Atlantic Council Study Group on International Terrorism, and the Inter-American

Dialogue. I have also lectured extensivelyin the United States, Canada, and Latin America.

A copy of my current CV and list of publications is attached hereto as Exhibit A.

B. Compensation and Prior Expert Witness Experience

I am being compensated at a rate of $250 per hour for my work in this matter. I have not

previously served as a testifying expert in other litigation.

C. Materials Considered

I have cited in this report a number of the authorities that I have considered in forming

the opinions set forth. A full list of the sources is attached as Exhibit B.

II. Summary of Opinions

International terrorism poses one of the greatest threats to the security of the United

States and the international community. The ability of international terrorist organizations to

threaten U.S. and international interests is heavily dependent upon those terrorist organizations’

securing the necessary financial resources to fund operations. Accordingly, the United States has

a vital security interest in pursuing every available avenue to deprive foreign terrorist

organizations of financing.

Narcotics trafficking is a key source of financing for international terrorist organizations.

The link between terrorism and narcotics trafficking is evident in many regions of the world,

including Afghanistan, Africa, Asia, Europe, Mexico, Central and South America. The threat to

U.S. security from narcotics funding of terrorist groups is very real. For example, the opium

market in Afghanistan is a major source of funding for the Taliban and Al Qaeda. Moreover,

1
For purposes of this report, “narcotics trafficking” refers to the entire chain in the supply of cocaine and heroin into
end-user countries, from the growing of the illicit coca and poppy crops, to the processing of the narcotic drugs, and
to the packaging and smuggling of those drugs into the United States and other countries.

287Annex 8

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other transnational criminal organizations funded by narcotics also pose threats to the United

States. In 2009, Mexican drug cartels were present in at least 230 American cities, up from 50

2
cities in 2006. The cross-cutting nature of the threat of narcotics and its linkage to terrorism and

crime is underscored by numerous policy statements from both government and non-government

organizations and academic writings.

In Colombia three foreign terrorist organizations, the Revolutionary Armed Forces of

Colombia (FARC), the Army of National Liberation (ELN), and the United Self-Defense Forces

of Colombia (AUC), have relied heavily on narcotics trafficking to finance violent terrorist

attacks against the government, institutions, and people of Colombia, as well as against U.S.

citizens and property located within that country. These terrorist groups also have fostered

violence and corruption in South and Central America, Mexico, and the Caribbean. Since 2000,

as the various components of Plan Colombia have taken hold and the revenues from drug

trafficking have declined, the FARC and the ELN have been substantially weakened, and the

AUC formally disbanded. While the FARC, the ELN, and remnants of the AUC continue to

pose a significant security threat to the United States, their ability to conduct terrorist operations

against Colombia and U.S. interests has been greatly diminished.

The aerial coca and poppy eradication operations of Plan Colombia have played an

important role in weakening the three groups. According to the latest United Nations (UN)

statistics: “Coca cultivation in Colombia decreased by 58% between 2000 and 2009, mainly due

to large-scale eradication,” and poppy cultivation was virtually eliminated between 2000 and

2Lanny A. Breuer, Statement Before Subcommittee on Human Rights and the Law Committee on the Judiciary,
U.S. Senate, “Drug Enforcement and the Rule of Law: Mexico and Colombia,” May 18, 2010, p. 4.

3United Nations Office on Drugs and Crime (UNODC), World Drug Report 2010, New York, NY: United Nations,
2010, p. 65.

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4
2009. This sharp reduction has led to a corresponding decline in revenues for the FARC and

ELN. The Colombian government has estimated that FARC income from narcotics trafficking

fell by greater than 30% during the period 2003-2007 (or by about $200 million), and the 5

continued decline in coca cultivation between 2007 and 2009 suggests that FARC revenues from

6
narco-trafficking has continued to drop. Moreover, the coca growers’ responses to aerial

eradication (e.g., relocating, planting smaller plots, earlier harvesting of low yield coca) have

increased the costs to the FARC and weakened its hold on the populations in coca growing areas.

Plan Colombia’s aerial eradication operations have accordingly played a key role in the battle

against international terrorism and are vital to U.S. national security interests.

III. The Link Between Narcotics Trafficking and Terrorism Poses a Grave Threat to
United States’ Security Interests and the Security Interests of the Broader

International Community.

As former Attorney General John Ashcroft explained in the months following the

September 11 attacks: “Terrorism and drugs go together like rats and the bubonic plague – they

7
thrive in the same conditions, support each other, and feed off of each other.” Terrorist groups

engage in drug trafficking not only as a major source of funding but also as a weapon in their

4Ibid., Table 14, p. 138.
5
See Juan Manuel Santos, República de Colombia, Ministerio de Defensa Nacional, Tendencias y resultados 2007,
January 24, 2008, p. 12
(http://colombiaemb.org/docs/Plan%20Colombia%20Documents/Main%20Results/…
_SP.pdf). See also: International Crisis Group (ICG), “Colombia: Making Military Progress Pay Off,”

Bogotá/Brussels, April 28, 2008, p. 8, n. 65; Peter De Shazo, Johanna Mendelson Forman, Phillip McLean,
“Countering Threats to Security and Stability in a Failing State: Lessons from Colombia,” Washington, DC: Center
for Strategic & International Studies, September 2009, p. 56, which cites ICG, “Ending Colombia’s FARC Conflict:
Dealing the Right Cards,” March 26, 2009, p. 12.
6
Of course, these reductions in narcotics production also serve a vital U.S. interest in reducing the flow of illegal
narcotics into this country. It is my understanding that the importance of the aerial eradication operations to
counter-narcotics efforts within the Colombia is being addressed by another expert, and I do not address this issue in
my report.

7Attorney General John Ashcroft, “Prepared Remarks of Attorney General John Ashcroft: DEA/Drug Enforcement
Rollout,” March 19, 2002

(http://www.justice.gov/archive/ag/speeches/2002/031902newsconferencedea…).

289Annex 8

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war against the United States. Thus, for example, the Hezbollah issued a fatwa (an Islamic legal

pronouncement) on the distribution of drugs in the mid-1980s that proclaimed: “We are making

these drugs for Satan – America and the Jews. If we cannot kill them with guns, so we will kill

them with drugs.” 8

The close link between narcotics and the financing of terrorism is well established by the

international community, and is frequently addressed in academic research, the work of think

9
tanks, and government statements and publications. According to the United Nations Office on

Drugs and Crime (UNODC), drug trafficking is a global enterprise that generates approximately

$394 billion per year, providing a revenue stream for terrorists and other international criminal

organizations that dwarfs the proceeds of any other form of organized criminal activity. 10

Eighteen of the 44 organizations designated by the United States as Foreign Terrorist

Organizations have been linked to the international drug trade, including the FARC, the ELN,

11
and the AUC. Likewise, 24 of the 55 organizations on the United States Attorney General’s

FY 2009 Consolidated Priority Organization Target list – a unified list of the most significant

8
Rex A. Hudson, et al., “A Global Overview of Narcotics Funded Terrorist and Other Extremist Groups,” Library
of Congress: Federal Research Division, May 2002, p. 10.
9
Anthony P. Placido, Assistant Administrator for Intelligence, U.S. DEA, Statement Before the Subcommittee on
National Security and Foreign Affairs Committee on Oversight and Government Reform, U.S. House of
Representatives, “Transnational Drug Enterprises (Part II): Threats to Global Stability and U.S. Policy Responses,”
March 3, 2010; Joint Report of the U.S. Senate Committee on the Judiciary Subcommittee on Terrorism,

Technology, and Homeland Security, “Three Years After September 11: Keeping America Safe,” March 2005, pp.
60-63; Rex A. Hudson, et al., “A Global Overview of Narcotics-Funded Terrorist and Other Extremist Groups,”
May 2002; Rand Beers and Francis Taylor, Joint Testimony Before the U.S. Senate Committee on the Judiciary
Subcommittee on Technology, Terrorism and Government Information, “Narco-Terror: The Worldwide Connection
Between Drugs and Terror,” March 13, 2002. See also: Paul Rexton Kan, Drugs and Contemporary Warfare,
Washington, DC: Potomac Books, 2009; Vanda Felbab-Brown, Shooting Up: Counterinsurgency and the War on

Drugs, Washington, DC: Brookings, 2009; Juan Carlos Garzón, Mafia & Co.: The Criminal Networks in Mexico,
Brazil, and Colombia, Washington, DC: Woodrow Wilson Center for International Scholars, 2010. An excellent
study of the sociological and psychological dimensions of the problem is Francisco Thoumi, Illegal Drugs,
Economy, and Society in the Andes, Washington, DC: Woodrow Wilson Press, 2004. Sayaka Fukumi painstakingly
analyzes the policy dimensions in Cocaine Trafficking in Latin America: EU and US Policy Responses, Burlington,

Vermont: Ashgate, 2008.
10Placido, “Transnational Drug Enterprises (Part II),” p. 1.

11Ibid., p. 3.

290 Annex 8

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international drug and money laundering targets around the world that affect the supply of illegal

drugs in the United States – have been linked to terrorist organizations. As reported in a March

2005 Report of the Subcommittee on Terrorism, Technology, and Homeland Security of the

Senate Judiciary Committee:

Narcoterrorism is a world-wide problem. In South America, the

State Department has officially designated the National Liberation
Army (ELN), the Revolutionary Armed Forces of Colombia
(FARC), and the United Self-Defense Groups of Colombia (AUC)

as terrorist organizations. Hezbollah and the Islamic Resistance
Movement (known as Hamas) operate in the tri-border area of
Paraguay, Argentina, and Brazil. The Kurdish Workers Party
(PKK) operates among violent separatist Kurds in Turkey. The

United Wa State Army is the largest heroin- and
methamphetamine-producing organization in Southeast Asia. The
Abu Sayyaf Group engages in kidnapping, drug-smuggling,

extortion, and other profitable criminal activity in support of i13
goal of establishing a separate Islamic state in the Philippines.

This same report noted that “Osama bin Laden and his organization finance many of their

terrorist activities through the drug trade.”4

More recently, the U.S. Department of State, in its 2010 International Narcotics Strategy

Report, stated:

The United States and many other countries are particularly
concerned by evidence of links between international terrorist

groups and the drug trade. Some of these linkages – such as the
longstanding ties between drug trafficking, terrorist and insurgent
groups in Colombia and Afghanistan – are well documented and

directly endanger the stability of these governments and, in the
case of Afghanistan, the lives of U.S. service members. … More
globally, there is evidence that individuals belonging to or

12Ibid., p. 4.
13
Joint Report of the U.S. Senate Committee on the Judiciary Subcommittee on Terrorism, Technology, and
Homeland Security, “Three Years After September 11: Keeping America Safe,” March 2005, p. 63.
14Ibid., p. 61.

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sympathetic to international terrorist groups have turned to the
drug trade as a revenue source. 15

In July 2010, General Douglas Fraser, of the United States Southern Command, explained:

Illicit trafficking feeds an income stream to drug cartels and
subversive movements. The revenues in the hands of criminals

and narco-terrorists have weakened state structures throughout the
region, subverted the rule of law and ripped apart the fabric of
social order. To address this challenge, U.S. Northern

Command… and USSOUTHCOM, in support of other interagency 16
partners, are collaborating in countering illicit trafficking…

The United States is not alone in recognizing the grave security risks posed by the link

between drug trafficking and international terrorism. There has long been a broad consensus that

narcoterrorism poses a major threat to the international community and that it requires a

coordinated, international response. The UN, for example, has repeatedly warned about this

threat over the past dozen years:

• In 1998, the UN General Assembly Special Session on drugs expressed
“deep concern about links between illicit drug production, trafficking and

involvem17t of terrorist groups, criminals and transnational organized
crime.”

• Shortly following the September 11 attacks, the UN Security Council

passed Resolution 1373 which, in part, “notes with concern the close
connection between international terrorism and transnational organized
crime [and] illicit drugs …” and “… emphasizes the need to enhance

coordination of efforts on national, subregional, regional, and international
levels in order to strengthen a global response to this serious challenge and
threat to international security.” 18

15U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs, 2010 International

Narcotics Control Strategy Report, Volume I: Drug and Chemical Control, Policy and Program Developments,
Washington, DC, March 2010, p. 17.
16Douglas Fraser, Commander-in-Chief, “The United States Southern Command Strategy for 2010,” Miami: United

States Southern Command, July 2010, p. 6. USSOUTHCOM has the responsibility to provide military support to
Colombia’s counternarcotics effort.
17UNODC, World Drug Report 2010, p. 37 (quoting the United Nations General Assembly Special Session on the
World Drug Problem, New York, NY, June 8-10, 1998).

18UN Security Council Resolution 1373, September 28, 2001.

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• In October 2004, Antonio Maria Costa, Executive Director of UNODC
issued the following warning on the nexus between drugs, crime and

terrorism: “Drug trafficking has always meant untold suffering and death
for addicts. Today, drug trafficking is also the source of a different and

very urgent problem: the financing of terrorism. The revenue generated
by organized crime offers terrorist groups a steady flow of funding,
making the effort to eliminate drug trafficking and to reduce drug abuse
19
critical strategies in the global fight against terrorism.”

• In December 2009, UN Secretary General Ban Ki Moon proclaimed:
“…drug trafficking has emerged as a leading threat to international peace

and security” and “is evolving into an ever graver threat that is affecting
all regions of the world” and “I call on Member States to work with each
other and to support the UN in this crucially important endeavor.” 20

• In February 2010, the President of the UN Security Council issued a
statement on behalf of the Council, noting “…with concern the increasing

link, in some cases, between drug trafficking and the financing of
terrorism, including through the use of proceeds derived from illicit
cultivation, production of and trafficking in narcotic drugs…” and

“…encourages States to strengthen international, regional and sub-
regional cooperation to counter drug trafficking, transnational organized
crime, terrorism and corruption….” 21

The major regional international organizations likewise have expressed their concern

over the narcoterrorism threat. The Organization of American States (OAS), in its Declaration of

Montevideo in January 2004, affirmed that “the threat of terrorism is exacerbated by the

22
connections between terrorism and illicit drug trafficking.” The European Union (EU) warns

that: “Drug trafficking networks have many links, especially with terrorist networks, making it

19UN Press Release, “UN Warns About Nexus Between Drugs, Crime and Terrorism,” SOC/CP/311, October 1,

2004 (http://www.un.org/News/Press/docs/2004/soccp311.doc.htm).
20UN Secretary General, “Remarks to Security Council Meeting on Drug Trafficking as a Threat to International
Peace and Security,” New York, NY, December 8, 2009, pp. 1-3

(http://www.idpc.net/sites/default/files/alerts/SG_SC_Drug_Trafficking.p…).
21UN Security Council, “Statement by the President of the Security Council,” S/PRST/2010/4, February 24, 2010,
pp. 1-2.

22 OAS, Inter-American Committee Against Terrorism, “Declaration of Montevideo,” OEA/Ser.L/X.2.4,
CICTE/DEC. 1/04 rev.3, February 4, 2004, p. 2.

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ever more important for us to stop drugs being brought into Europe,” and the EU issued a joint

declaration with the Association of South East Asian Nations (ASEAN), acknowledging “that

terrorism, including its links with trans-national organized crime, such as money laundering,

arms-trafficking and the production of and trafficking in illicit drugs … forms part of a complex

set of new security challenges, which have to be addressed urgently in all aspects and in all fora,

including the ASEAN Regional Forum.” 24 And a recent African Union report stated: “Drugs

have political, social and economic impacts on Member States and are linked to money

laundering, organized crime and terrorism; a coordinated multifaceted response is required.” 25

IV. Colombia: Epicenter of the International Narcoterrorism Threat.

Along with Afghanistan, Colombia has been at the epicenter of the connection between

drug trafficking and terrorism. In September 2002, President George W. Bush stated:

In Colombia, we recognize the link between terrorist and extremist

groups that challenge the security of the state and drug trafficking
activities that help finance the operations of such groups. We are
working to help Colombia defend its democratic institutions and

defeat illegal armed groups of both the left and right by extending
effective sovereignty over the entire national territory and provide
26
basic security to the Colombian people.

In 2004, Sandro Calvani of the UNODC, explained: “The two major determinants of the poor

human security situation in Colombia are the production and trafficking of illicit drugs and the

23
Council of the European Union, Political and Security Committee, “Statement on strengthening international
security,” 16751/2/08 REV 2 (en), Brussels, December 8, 2008, p. 5
(http://www.eu2008.fr/webdav/site/PFUE/shared/import/1211_Conseil_europe…
g%20international%20security_EN.pdf).
24
Association of South East Asian Nations and European Union, “Joint Declaration on Cooperation to Combat
Terrorism,” 14thASEAN-EU Ministerial Meeting, January 27-28, 2003, paragraph 4
(http://archive.asean.org/14030.htm; last visited November 30, 2010).

25African Union, 4 Session of the African Union Conference of Ministers for Drug Control and Crime Prevention,
Report of Experts’ Meeting, “Turning the Tide of Drugs and Crime in Africa – From Policy to Action,"
CAMDCCP/EXP/Report (IV), Addis Ababa, September 28-October 2 2010, p. 7

(http://www.uneca.org/coda/Documents/AU_Drugs_Crime_Experts%20Report_Oct…).
26George W. Bush, The National Security Strategy of the United States of America, September 20, 2002, pp. 9-10.

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internal conflict sustained by the Colombian ‘outlaw’ armed groups. Both scenarios are

intimately linked to the global threats caused by narcotrafficking and terrorism.” As Juan J.

Quintana, Counselor for the Colombian Embassy, explained in testimony to the United States

Congress, “the European governments have consistently expressed support for the Colombian

state in its fight against terrorism and drugs trafficking, and on several occasions they have

underlined the need for the international community to contribute to Colombian efforts aimed at

defeating those who are waging a war against our democratic institutions.” 28

As noted above, the U.S. Department of State has designated three groups in Colombia as

Foreign Terrorist Organizations, i.e., as terrorist organizations that threaten the security of U.S.

nationals or the national security of the United States: (1) the FARC; (2) the ELN; and (3) the

AUC. Each depended in a major way upon narcotics trafficking to finance operations. Although

Plan Colombia has significantly weakened the FARC and the ELN and led to the official

disbanding of the AUC (in 2006), the FARC, the ELN, and remnants of the AUC continue to

pose a significant threat to Colombia, the United States, and the international community.

A. History of Narco-Terrorism in Colombia Leading Up to Plan Colombia

The FARC and the ELN originate from La Violencia, a combination of partisan conflict

and rural banditry that occurred from 1948 to 1964 and cost some 200,000 lives. The FARC and

the ELN shared the goal of establishing a communist state. The Colombian military had

seriously weakened the FARC and the ELN by the 1980s. However, the eruption of the cocaine

economy in that decade resuscitated them. As the ELN and the FARC parlayed drug money into

27Sandro Calvani, UNODC Representative in Colombia, “Summary Statement: UNODC Briefing on Foreign Aid to
Colombia and the European Role in the Fight Against Narco-terrorism,” Committee on International Relations, U.S.
House of Representatives, October 14, 2004, p. 1.
28
Juan J. Quintana, Counselor, Embassy of Colombia, Prepared Statement before the Committee on International
Relations, U.S. House of Representatives, Hearing on Aid to Colombia: The European Role in the Fight Against
Narco-terrorism, “European Assistance to Colombia,” November 18, 2004, p. 1.

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greater control over large regions of the country, the growing insecurity gave rise to the

paramilitary AUC, which brutally competed for territory, population control, and the illegal drug

economy.

Narcotrafficking totally transformed Colombia. State and society came under assault.

Narcotraffickers assassinated Justice Minister Rodrigo Lara Bonilla in April 1984, triggering the

resignation of some 100 judges. The attack on the Palace of Justice on November 6, 1985 by the

small M-19 guerrilla group, with the financial aid of narco-trafficker Pablo Escobar, is akin to

29
the United States’ September 11, 2001. Eleven Supreme Court justices were killed. Later, the

assassination of three presidential candidates and of Judge Miryam Rocío Veléz in 1992 showed

that the narco-traffickers had become a mortal threat to the institutions of government. 30

By the early 1990s, four groups were making war against the state, each other and the

Colombian people. These were: (1) internationally organized drug trafficking groups (estimated

to number 162 drug cartels within Colombia); (2) the FARC, with 17,000 to 20,000 members;

(3) the ELN, with perhaps 5000 members; and (4) the AUC, which would reach over 30,000

members.

With the assistance of the United States, the Colombian government in the 1990s

defeated the leadership of the largest drug cartels, particularly the Medellín and Cali cartels.

Nonetheless, the FARC, the ELN, and the AUC seized even greater control over drug trafficking

29
Ana Carrigan, The Palace of Justice: A Colombian Tragedy, New York, NY: Four Walls Eight Windows, 1993;
Rex A. Hudson, “Colombia’s Palace of Justice Tragedy Revisited: A Critique of the Conspiracy Theory,” Terrorism
and Violence, Vol. 7, No. 2, Summer 1995, pp. 93-142. The narco-traffickers intended to have the legal records
about their illicit activities destroyed in the attack. Much like the 9/11 attack, Colombians are considering erecting a
monument to memorialize the tragedy. See “Preliminary Report of the Commission of Truth for the Holocaust in
the Palace of Justice of Bogotá of November 6 and 7, 1985,” November 15, 2006
(http://www.verdadpalacio.org.co/Assets/DOCs/informe_prelimiar.pdf).
30
For an analysis of the impact of violence on state institutions and the search for a solution, see Rafael Pardo
Rueda, De Primera Mano, Colombia 1986-1994: Entre Conflictos y Esperanzas, Bogotá: Norma, 1996. For the
thesis of war against society, see Daniel Pécaut, Guerra Contra La Sociedad, Bogotá: Planeta, 2001. See also

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and a larger share of the financial proceeds. The narcoterrorist activities of the FARC, ELN, and

AUC were facilitated by Colombia’s difficult geography of mountains and jungle regions.

Moreover, the state infrastructure of judicial system, public security, schools, markets, roads, and

communications was nearly absent in major portions of the national territory. Indeed, the state

has not exercised control over an estimated 40 percent of the national territory, precisely the

areas where illegal drugs are cultivated and where the FARC, ELN, and the AUC have been

active, filling the void with de facto and brutal administrative systems. 31

By 1997, the FARC was defeating the Colombian Army in battalion-sized battles. This

was the first time that a modern Latin American army was beaten by irregular formations. In

Washington, D.C., there were ominous warnings about the entry of the FARC into Bogotá and

the possibility of a narco-state emerging. The threat posed by drug-financed Colombian foreign

terrorist organizations to U.S. and international security shortly after Plan Colombia was

instituted was clearly stated by then-DEA Administrator Asa Hutchison in testimony before the

U.S. Senate Caucus on International Narcotics Control on September 17, 2002:

The DEA continues to develop overwhelming evidence about the
connection between the Revolutionary Armed Forces of Colombia
(FARC), other terrorist groups in the Andean region, and the drug

trade. . . . The FARC and ELN have routinely kidnapped U.S.
citizens and attacked U.S. economic interests in Colombia.
According to the 2001 U.S. State Department Annual Report on

Global Patterns of Terrorism, 55 percent of all the terrorist acts in
the world reportedly were committed in Colombia by the FARC or

Rafael Pardo Rueda,La Historia de las Guerras, Bogotá: Vergara, 2004, especially pp. 390-652. In addition, see
Eduardo Pizarro Leóngomez, Una Democracia Asediada, Bogotá: Norma, 2004.
31This was especially true of the northwestern areas of Urabá and Chocó as well as those of eastern and
southeastern Colombia, including the lightly populated departments of Arauca, Guaviare, Meta, Guainía, Caquetá,
Vaupés, Vichada, and Putumayo, parts of which are in the Amazon Basin, where permanent habitation is difficult
and the state is only minimally present. See Gabriel Marcella, “The United States and Colombia: The Journey From

Ambiguity to Strategic Clarity,” Carlisle, PA: SSI, May 2003, p. 17
(http://www.strategicstudiesinstitute.army.mil/pdffiles/PUB10.pdf).

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ELN. The report also claims that almost 85 percent of the terrorist 32
attacks (219 attacks) against U.S. interests occurred in Colombia.

B. The Revolutionary Armed Forces of Colombia

The FARC is the oldest, largest, and most capable insurgency in Latin America. Tactics

run the gamut: terrorism, extortion, intimidation, bribery, kidnapping, use of anti-personnel

mines, explosive gas cylinders, assassination, and exploiting narcotics. The FARC’s traditional

power base has been in southern Colombia, including areas in Putumayo and Nariño (the two

Colombian departments that share a border with Ecuador), as well as in northwestern Colombia.

The FARC has also had a significant presence in northern Ecuador for rest, recreation, procuring

33
weapons, processing drugs, laundering money, and obtaining precursor chemicals. In some

parts of Ecuador’s northern border, the FARC exercises significant control over the local

34 35
population. In 2002 FARC had roughly 17,000 fighters under its command.

32
Asa Hutchinson, Administrator, U.S. DEA, Statement Before the U.S. Senate Caucus on International Narcotics
Control, September 17, 2002, p. 2. (http://www.justice.gov/dea/pubs/cngrtest/ct091702.html).
33
See Douglas Farah and Glenn Simpson, “Ecuador at Risk: Drugs, Thugs, Guerrillas and the Citizens Revolution,”
International Assessment and Strategy Center, January 24, 2010. Unfortunately, these problems in northern Ecuador
persist to the present time. See Philip Alston, “Statement by Professor Philip Alston, UN Special Rapporteur on
extrajudicial executions, Mission to Ecuador: 5-15 July 2010,” Quito, July 15, 2010, p. 2. Alston states: “Illegal

armed groups enter Ecuador to obtain food, goods and health services; to traffic drugs and weapons; to conduct
combat training; and to escape the conflict in Colombia.”
34
On March 1, 2008 Colombian forces killed FARC commander Raúl Reyes inside Ecuador at Angostura. In
response, the Ecuadorian government established the Comisión de Transparencia y Verdad Angostura, a bi-partisan
commission of prominent citizens to prepare a report. The report confirmed the extensive presence of the FARC in
Ecuador. The report states: “There is a situation on the border where Ecuadorean peasants and Indians have been

‘displaced’ by the Farc (sic) to facilitate narco-trafficking and operations by irregular groups. Marcial Campaña is a
Colombian who used violence to expel [Ecuadorian] peasants near the San Miguel River. There he built a house to
lodge more than 60 persons. This place was turned into storage of precursors, drugs, and weapons. As well as a
meeting place for Farc members and traffickers from various nationalities….near the junction of the Putumayo and
San Miguel rivers were laboratories for processing drugs, fixed and mobile camps, arms caches and fuel. Along the

border there were 4thillegandentry points. The [Ecuadorian] province of Sucumbths is utilized as a center of
operations by the 48 and 32 front of the Farc. In Carchi and Esmeraldas, the 29 front exercises influence.”
“Informe Comisión de Transparencia y Verdad Angostura,” Quito, December 10, 2009, Section 3.2
(http://www.ecuadorenvivo.com/images/pdf/INFORME-ANGOSTURA.pdf). For additional detail about the attack
at Angostura, see Gabriel Marcella, “War Without Borders: The Colombia-Ecuador Crisis of 2008,” Carlisle, PA:

SSI, December 2008 (http://www.strategicstudiesinstitute.army.mil/pdffiles/PUB891.pdf).
35Admiral James Stavridis, “U.S. Southern Command Posture Statement,” Miami, FL: United States Southern

Command, 2008, p. 15.

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The FARC has established links with terrorist groups throughout Latin America under the

umbrella of the Bolivarian Continental Coordinator (CCB), which was founded by the FARC in

2003. 36 The FARC has also worked with individuals associated with the Irish Republican

37 38
Army and the Basque Terrorist Group Euskadi ta Askatasuna (ETA).

The FARC is responsible for numerous terrorist attacks on U.S. citizens. In January

1994, the FARC kidnapped two American missionaries, Stephen Everett Welsh and Timothy

Van Dick. Their bodies were found a year and a half later. In March 1999, the FARC executed

three U.S. Indian rights activists on Venezuelan territory after kidnapping them in Colombia.

According to journalist Ana Arana: “The three Americans were abducted on February 25 as they

left the reservation of the indigenous U'wa tribe in northeast Colombia, where they had attended

a religious ceremony.” 39 In May 2003, the Colombian government extradited to the United

36The CCB was founded by the FARC to reverse its international isolation. The group held its second congress in

Quito, Ecuador, on February 24-27, 2008 to “confront the imperialist aggression against our peoples…and to
demand the immediate departure of foreign military bases from our territories….” The allusion to foreign military
bases meant the U.S. Forward Operating Location at Manta Air Base, which, under a 10 year agreement with
Ecuador, supported by U.S. counter-narcotics reconnaissance flights targeting the cocaine traffic. Through mid-
2009, the reconnaissance helped in the seizure of 1,700 metric tons of cocaine, with an estimated street value of 35.1

billion dollars. Nine foreign delegations attended the Quito conclave, including terrorists from Spain and Peru. For
details, see: Comisión de Transparencia y Verdad Angostura, “Informe Comisión de Transparencia y Verdad
Angostura,” Quito, December 10, 2009, pp. 31-40 (http://www.ecuadorenvivo.com/images/pdf/INFORME-
ANGOSTURA.pdf). With respect to the FARC in Ecuador, see also pages 31-32 below.

37As reported following a U.S. congressional investigation: “The IRA has had well-established links with the
FARC narco-terrorists in Colombia since at least 1998…. It appears they have been training in the FARC safe haven
in explosives management, including mortar and possibly car-bomb urban terrorist techniques, and possibly using

the rural jungles of the safe haven as a location to test and improve the IRA’s own terrorist weapons and
techniques.” Committee on International Relations, U.S. House of Representatives, “Summary of Investigation of
IRA Links to FARC Narco-Terrorists in Colombia,” April 24, 2002, p. 1. Gerry Adams, the Sinn Fein leader in
Ireland, denied that these individuals represented the IRA.

38In November 2009, Spanish prosecutor Vicente González stated in his investigation about links between the
FARC and the ETA: “From the investigation procedures it has been revealed that the collaboration between both
organizations, which was suspected for several years, has been proven by demonstrating contacts and collaboration.

That collaboration is centered both in terms of contacts among heads of both organizations and as much as in the
providing of short courses on the use of explosives.” “The FARC-ETA Connection,” Semana, February 16, 2009
(http://www.semana.com/noticias-print-edition/the-farceta-connection/120…). Semana states that
collaboration started in 1993.

39 The workers were Ingrid Washinowatok, Lahe’na’e Gay, and Terence Freitas. Washinowatok headed the
Rockefeller funded American Indian philanthropic group Fund for Four Directions. See: Ana Arana, “Murder in
Colombia,” Salon.com, December 14, 1999 (http://www.salon.com/news/feature/1999/12/14/colombia). Colombian

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States Nelson Vargas Rueda, one of the six FARC members suspected of committing the

40
murders. On February 13, 2003 the FARC captured three American citizens and a fourth was

executed by the FARC after their plane crashed. The three spent nearly 5 ½ years in captivity

before being rescued, along with former Colombian presidential candidate Ingrid Betancourt and

others, by the Colombian army on July 2, 2008. 41 According to a Congressional Research

Service (CRS) report, by February 2004 the FARC and the ELN had kidnapped more than 100

42
Americans, 13 of whom had been killed.

Perhaps the most brutal example of FARC terrorism occurred in the town of Bojayá on

May 2, 2002, where innocent civilians had taken refuge in a Catholic church. The FARC, in

violation of international norms barring military operations near places of worship, launched a

bomb containing 40 pounds of dynamite. The bomb struck the church, killing 119 (including 40

children) and injuring 98. 43 The UN condemned the attack as a violation of international law.

authorities charged FARC commander Germán Suárez Briceño, brother of FARC military commander Jorge Suárez
Briceño (AKA Mono Jojoy), who was killed in September 2010 by Colombian troops for the murder. Both were
wanted by American authorities for drug trafficking and murder. The FARC outraged world opinion by refusing to
turn over the killers to authorities. U.S. Department of State, Office of the Coordinator for Counterterrorism,
Patterns of Global Terrorism: 1999, Latin America Overview, April 2000
(http://www.state.gov/www/global/terrorism/1999report/1999index.html). The FARC also killed Awa Indians,

located in the Nariño department, near the Ecuadorian border. See Rick Kearns, “FARC Massacre of indigenous in
Columbia (sic), more deaths and displacement,” Indian Country Today, March 13, 2009
(http://www.indiancountrytoday.com/global/latin/41204617.html?corder=rev…). Kearns reports: “In the first
week of February… FARC rebels massacred up to 27 Awa people in the southern Nariño province, including
women and young children (from ages 3 to 6), bringing the total number of murdered Native people to 50 since the

national march in the fall.”
40Audrey Kurth Cronin, Huda Aden, Adam Frost, and Benjamin Jones, “Foreign Terrorist Organizations,”

Washington, DC: Congressional Research Service (CRS), February 6, 2004, p. 91.
41Their ordeal is described in Marc Gonsalves, Tom Howes, Keith Stansell, Out of Captivity: Surviving 1,967 Days
in the Colombian Jungle, New York, NY: Harper Collins, 2009.

42Cronin, et al., “Foreign Terrorist Organizations,” p. 90.

43For more information, see: Colombian Office of the UN High Commissioner for Human Rights,Informe de la
Oficina del Alto Comisionado de las Naciones Unidas para los Derechos Humanos Sobre la Misión de Observación
en el Medio Atrato, Bogotá, May 20, 2002. See also: Scott Wilson, “No Sanctuary from War,” Washington Post,

May 8, 2002 (http://www.globalexchange.org/countries/americas/colombia/26.html.pf). For the lasting
psychological effects among the people of Bojayá, see “Una cicatriz en lo profundo del Atrato,” Semana, September
18, 2010 (http://www.semana.com/noticias-nacion/cicatriz-profundo-del-atrato/1447…). With respect to the
massacres of Awa Indians in the Nariño department, see also: Pilar Lozano, “Matanza de 27 indígenas en el sur de

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On February 7, 2003, the FARC attacked the Club El Nogal in Bogotá using a car bomb

of 200 kilograms of explosives, killing 32 persons and wounding 160. A FARC e-mail recently

revealed by President Juan Manuel Santos on October 16, 2010, details the FARC’s planning of

the El Nogal bombing: “…lately the possibility has emerged to explode it in the presence of 150

44
industrialists and diplomats who meet there weekly.” The UN Security Council approved

Resolution 1465, which called the attack an “act of terrorism” that threatened “peace and

45
security.” The Permanent Council of the OAS affirmed in Resolution 837: “… its profound

repudiation of the despicable terrorist attack carried out by the FARC on February 7, 2003, in

Bogotá and to pledge its cooperation in pursuing, capturing, prosecuting, punishing, and, when

appropriate, expediting the extradition of the perpetrators, organizers, and sponsors of this

46
act….”

47
The FARC began financing its terrorist operations with drug money in the 1980s. The

FARC’s role in narcotics trafficking began with “revolutionary” taxes on farmers who were

growing coca and “protection” fees imposed on drug traffickers for the security of their landing

48
strips, crops, and processing facilities. Revenues from these operations accelerated

dramatically in the 1980s and the heroin boom of the early 1990s. In 1998 the FARC’s narcotics

Colombia,” El País (Madrid), February 14, 2009
(http://www.elpais.com/articulo/internacional/Matanza/27/indigenas/sur/C…
es).
44
“Correos del ‘Mono Jojoy’ revelan cómo se planearon atentados contra El Nogal y la Universidad Militar,”
October 16, 2010 (http://wsp.presidencia.gov.co/prensa/2010/octubre/paginas/20101016_02.a…).
45
UN Security Council Resolution 1465 (2003), February 13, 2003, p. 1 (http://daccess-dds-
ny.un.org/doc/UNDOC/GEN/N03/247/96/PDF/N0324796.pdf?OpenElement).
46
OAS Permanent Council Resolution 837 (1354/03), Condemnation of Terrorist Acts in Colombia, February 12,
2003 (http://www.oas.org/consejo/resolutions/res837.asp).
47
Alejandro Reyes, “Compra de tierras por narcotraficantes,” in Francisco Thoumi, et. al., Drogas ilícitas en
Colombia, Ministerio de Justicia, Dirección Nacional de Estupefacientes, Bogotá: Ariel Naciones Unidas-PNUD
1997, pp. 270-346.
48
John Rollins, Liana Sun Wyler, and Seth Rosen, “International Terrorism and Transnational Crime: Security
Threats, U.S. Policy, and Considerations for Congress,” Washington, DC: CRS, March 18, 2010, p. 17.

301Annex 8

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revenues received yet another boost when the government ceded FARC operational control over

42,000 square kilometers in the Caquetá region as a basis for peace negotiations. The FARC

quickly turned this territory into a drug depot and a safe haven for its narcotics trafficking

49
activities. Moreover, as the Medellín and Cali cartels ceased to be the main trafficking

organizations in the 1990s, the FARC expanded its drug trafficking activities. 50 By 2005, 65 of

the 110 FARC fronts were reported to be involved in the cultivation of coca and marketing of

51 52
cocaine. The CRS reported that 60% of the FARC’s revenue came from the drug economy.

A CRS report of February 2004 stated that the FARC might very well be “one of the richest, if

not the richest, insurgent group in the world.” 53 The FARC’s link to the cocaine market, and the

tremendous amount of money derived therefrom, is illustrated by the account of captured

Brazilian trafficker Luis Fernando da Costa:

The FARC are the richest and strongest guerrillas in the world.
Their leaders live like millionaire capitalists: beautiful women,
good food and liquor. . . In Colombia not a kilo of cocaine moves

without the permission of the FARC . . . For each kilo I sent they
paid me $3,000. . . . The drug business is pretty good for the
FARC; for each kilo that is ready to be shipped they charge $500,

for each flight . . . $15,000. . . . I paid the FARC $10 to $12 million
a month. Each flight carried between 700 kilos and a ton of coca

. . . Each pilot was paid $25,000 and the co-pilot $5,000 . . . and a
little bit was paid to the air controllers so that they would not cause
problems with the flights. . . . Part of the payment for the coca was

49
Rollins and Wyler, “International Terrorism and Transnational Crime: Security Threats, U.S. Policy, and
Considerations for Congress,” pp. 17-18.
50Ibid., p. 18.

51Ibid.
52
Ibid.; Cronin, et al., “Foreign Terrorist Organizations,” p. 92. See also: Gabriel Marcella, “Plan Colombia: The
Strategic and Operational Imperatives,” Carlisle, PA: SSI and North-South Center, April 2001, p. 4
(http://www.strategicstudiesinstitute.army.mil/pdffiles/PUB29.pdf).
53
Cronin, et al., “Foreign Terrorist Organizations,” p. 92.

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made to the FARC in 3,000 guns and three and a half million
54
rounds of ammunition, which came from Paraguay.

Further proof is an e-mail from FARC leader Edgar Tovar to Raúl Reyes, dated July 13, 2007,

which states: “Comrade, this coming Tuesday I have to deliver 700 kilos of crystal (refined

cocaine), but Saturday or Sunday I have to collect the money in Quito (Ecuador). It is $1.5

55
million.”

The U.S. government has aggressively pursued the FARC for its role in narcotics

trafficking. On March 18, 2002, Attorney General John Ashcroft and DEA Administrator Asa

Hutchinson announced the indictment of three members of the FARC’s 16 front for drugh

trafficking.56 On February 19, 2004, several leading members of the FARC and AUC were

designated by the Treasury Department as Significant Foreign Narcotics Traffickers pursuant to

57
the Kingpin Act. By January 2009, the Department of the Treasury’s Office of Foreign Assets

58
Control had designated 77 FARC members or associates as narcotics traffickers. A number of

them have been extradited to the United States and are currently incarcerated on drug charges.

54
“La confesión de Fernandinho,” Semana, April 30, 2001
(http://www.semana.com/wf_imprimirarticulo.aspx?IdArt=17243). For more details: Marcella, “The United States
and Colombia: The Journey from Ambiguity to Strategic Clarity,” pp. 12, 16, 19-21, 27, 37; Marcella, “Plan
Colombia: The Strategic and Operational Imperatives,” pp. 3-4.

55Douglas Farah, “What the FARC Papers Show Us about Latin American Terrorism,” Washington, DC: NEFA
Foundation, April 1, 2008, p. 13 (http://www.nefafoundation.org/miscellaneous/FeaturedDocs/nefafarc0408.p…).

56U.S. DEA Press Release, “Department of Justice Hands Down Indictments Against FARC Terrorists,” March 18,
2002 (http://www.justice.gov/dea/pubs/pressrel/pr031802.html).

57U.S. Department of the Treasury Press Release, “Treasury Takes Action Against FARC/AUC Narco-Terrorist
Leaders in Continued Effort to Halt Narcotics Trafficking,” February 19, 2004
(https://ustreas.gov/press/releases/js1181.htm). Marín was AKA Manuel Marulanda and Tirofijo. Briceño Suárez,

AKA Mono Jojoy, was the military leader of the FARC killed by Colombian troops in September 2010.
58U.S. Department of the Treasury Press Release, “Treasury Designates Additional FARC International

Commission Members,”January 14, 2009 ( https://ustreas.gov/press/releases/hp). From December 1997 to the
end of November 2010, over 1,100 Colombians had been extradited, most for drug trafficking, and a good number
being FARC members.

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C. The Army of National Liberation

The ELN, which in the 1990s fielded perhaps 5,000 fighters, is a junior partner to the

FARC in operational capability. Born also in the 1960s, the ELN’s political goals are similar to

those of the FARC: to establish a Marxist state. While they sometimes coordinate their

activities, they also clash at times over territory and influence.

Like the FARC, the ELN has directly attacked Colombian and U.S. interests in

Colombia. The ELN has extorted money from energy companies and blown up the Coveñas-

59
Limón pipeline, which brings petroleum to the Caribbean coast for export. Local offices and

franchises for U.S. companies, such as Drummond, Coca-Cola, Nestle, Halliburton and 3M are

reported to have received threatening letters. 60 In 1998, ELN activists bombed and ransacked a

Dole-owned subsidiary and attacked the Ocensa pipeline, which is jointly owned by a

61
consortium of American, British, French, Canadian, and Colombian companies. On March 5,

2003, a car bomb exploded in a shopping center in Cucutá, a northeastern Colombian city. The

bomb, attributed to the ELN by military and police sources, killed seven people and injured more

than 50. 62 As stated previously, between 1980 and February 2004, the FARC and ELN together

63
had kidnapped more than 100 Americans, 13 of whom had been killed.

While the ELN has publicly expressed disdain for illegal drugs and denied involvement

in the drug business, it is well-established that the ELN funds much of its operations through

59The FARC also attacks oil pipelines. For example, see: Thomson Financial, “Colombia’s main oil pipeline closed
after guerrilla attack,” Thomson Financial News, June 23, 2008
(http://www.forbes.com/feeds/afx/2008/06/23/afx5143758.html).

60John Otis, “Colombians Forced to pay rebels / Fighting extortion may come at deadly price for opponents,”
Houston Chronicle, October 28, 2001 (http://www.chron.com/CDA/archives/archive.mpl?id=2001_3344360).
61
Cronin, et al., “Foreign Terrorist Organizations,” p. 69.
62
Steven W. Casteel, Assistant Administrator for Intelligence, Statement Before the U.S. Senate Committee on the
Judiciary, “Narco-Terrorism: International Drug Trafficking and Terrorism- a Dangerous Mix,” May 20, 2003.
63
Cronin, et al., “Foreign Terrorist Organizations,” p. 90.

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64
narcotics trafficking. The ELN supplements its income derived from narcotics trafficking with

65
income derived from kidnapping and extortion.

D. The Colombian Self Defense Forces

Founded in 1997, the AUC was an umbrella organization of paramilitary groups. Prior to

demobilization, the AUC fought the FARC and ELN. The paramilitaries competed with the

FARC for territory and the narcotics market in various parts, including in the south, east, and

66
northwest. The AUC groups became notorious for their brutality and penetration of local and

regional politics. Their involvement in moving cocaine to the United States made them a major

threat. The Colombian National Police reported that during the first 10 months of 2000, the

AUC conducted 804 assassinations, 203 kidnappings, and 75 massacres with 507 victims. 67

In 2000, AUC leader Carlos Castaño claimed that 70 percent of the AUC’s operational

68
funding came from drug-related earnings. On February 19, 2004, 18 AUC members and three

front companies affiliated with the AUC, along with members of the FARC, were designated by

the Treasury Department as Significant Foreign Narcotics Traffickers pursuant to the Kingpin

64U.S. Department of State, 2009 Country Reports on Terrorism—Colombia, August 5, 2010; Rand Beers and
Francis Taylor, Joint Testimony Before the U.S. Senate Committee on the Judiciary Subcommittee on Technology,

Terrorism and Government Information, “Narco-Terror: The Worldwide Connection Between Drugs and Terror,”
March 13, 2002.
65
U.S. Department of State, 2009 Country Reports on Terrorism—Colombia; Stephanie Hanson, “FARC, ELN:
Colombia’s Left-Wing Guerrillas,” Council on Foreign Relations, August 19, 2009
(http://www.cfr.org/publication/9272/farc_eln.html).
66
U.S. Department of State, Office of the Coordinator for Counterterrorism, Patterns of Global Terrorism: 2000,
Appendix B: Background Information on Terrorist Groups, April 2001
(http://www.state.gov/s/ct/rls/crt/2000/2450.htm). For more information on the paramilitaries, see Mauricio
Romero, Paramilitares y autodefensas, 1982-2003, Bogotá: Instituto de Estudios Políticos y Relaciones
Internacionales and Editorial Planeta, 2003.

67U.S. Department of State, Office of the Coordinator for Counterterrorism, Patterns of Global Terrorism: 2000,
Appendix B: Background Information on Terrorist Groups.

68Ibid.; see also: Rand Beers and Francis Taylor, “Narco-Terror: The Worldwide Connection Between Drugs and
Terror.”

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Act. 69 In 2006, following peace talks with the Colombian government, the AUC formally

disbanded, and eventually, 31,671 paramilitaries demobilized and surrendered 18,051 weapons. 70

V. Plan Colombia and the Aerial Eradication Operations

By the mid 1990s, the magnitude of the Colombian crisis, the noxious effects of cocaine

(and heroin) on a growing number of people, and the stakes for security in the Andean region,

the Caribbean, and Central America, convinced officials in Colombia and the United States that

an ambitious and comprehensive plan was needed to sustain an effort by the Colombian

government to regain control over its country. 71 Thus was born Plan Colombia, an initiative

conceived by the administration of President Andrés Pastrana in Colombia (1998-2002), in close

collaboration with the United States. The U.S. Congress first approved support for Plan

Colombia on July 13, 2000 and has continued to do so as Plan Colombia has evolved.

The strategic theory of Plan Colombia linked economic development and security to

peace. The central premise was that drug money feeds the coffers of the FARC and ELN, whose

criminal activity gives rise to the AUC paramilitaries. If the money was taken away, the narco-

terrorists could not mount attacks, they would become less threatening, and the paramilitaries

would have less reason for being. Plan Colombia endeavored to strengthen the state, reenergize

69U.S. Department of the Treasury Press Release, “Treasury Takes Action Against FARC/AUC Narco-Terrorist

Leaders in Continued Effort to Halt Narcotics Trafficking,” February 19, 2004
(https://ustreas.gov/press/releases/js1181.htm).
70Colleen W. Cook and Clare Ribando Seelke, “Colombia: Issues for Congress,” Washington, DC: CRS,

September 12, 2008, p. 3; Colombian Embassy, Washington, DC, “Peace & Justice Law”
(http://colombiaemb.org/index.php?option=com_content&task=view&id=45&Ite; last visited December 10, 2010).
See also: Juan Forero, “New Colombia Law Grants Concessions to Paramilitaries,” The New York Times, June 23,
2005 (http://www.nytimes.com/2005/06/23/international/americas/23colombia.htm…).
71
Thomas R. Pickering, “Anatomy of Plan Colombia,” The American Interest Online, November-December 2009
(http://www.the-american-interest.com/article.cfm?piece=703).

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the economy, generate the conditions for peace, reduce the expansion of drug trafficking, and

72
strengthen civil society.

Within the framework of Plan Colombia, American military and other support to

Colombia was initially limited to counternarcotics operations, force protection, and to provide

humanitarian assistance when necessary. However,the September 11 attacks radically changed

73
the threat assessment for terrorism and gave new urgency to American support to Colombia. In

the fall of 2002, President George W. Bush signed Presidential Decision Directive 18, a new

Colombia policy that went beyond counter-narcotics support and focused more particularly on

counter-terrorism, in addition to economic assistance. 74 These policy changes were codified into

law in 2003, when Congress granted expanded authority for counter-terrorism missions in

Colombia “because it concluded that there is no useful distinction between a narco-trafficker and

75
his terrorist activity -- hence, the term ‘narco-terrorist.’” A State Department report to

Congress added: “The expanded authority, as envisioned by the Congress and implemented by

the Department of State, has provided useful operational flexibility when the distinctions

between counternarcotics and counterterrorism may not be clear cut, and recognizes and

72
For more analysis of Plan Colombia, see Marcella, “Plan Colombia: The Strategic and Operational Imperatives;”
Marcella, “Democratic Governance and the Rule of Law: Lessons Learned from Colombia,” Carlisle, PA: SSI,
December 2009, p. 11 (http://www.strategicstudiesinstitute.army.mil/pubs/display.cfm?PubID=955); Marcella, “The
U.S. Engagement with Colombia: Legitimate State Authority and Human Rights,” Miami: University of Miami,
North-South Center, March 2002. There were 10 elements to the plan: economic strategy, fiscal and financial steps,

peace, national defense, judicial and human rights, counternarcotics strategy, alternative development, social
participation, human development, and international strategy.
73These developments are explored in Marcella, “The United States and Colombia: The Journey From Ambiguity to

Strategic Clarity,” pp. 35-39 and 50-58; Marcella, “Plan Colombia: The Strategic and Operational Imperatives,” pp.
5-6.
74
See Secretary of State, “A Report to Congress on United States Policy Towards Colombia and Other Related
Issues,” Washington, DC: Department of State, February 3, 2003, p.
6 (http://www.state.gov/p/wha/rls/rpt/17140.htm).
75
“U.S. General Outlines Existing and Emerging Hemispheric Threats,”America.gov, March 25, 2004
(http://www.america.gov/st/washfile-english/2004/March/20040325145251ASr…).

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reaffirms the practicality of providing assistance to address both scourges simultaneously, since,

76
as occurs more often than not, they are essentially one and the same.”

The scope of Plan Colombia also expanded in 2002, with the election of President Alvaro

Uribe. The prior administration of Andrés Pastrana had pursued peace talks with the FARC. For

this purpose, between 1999 and 2002 the government ceded the FARC a demilitarized area. The

talks went nowhere, but they allowed the FARC to buy time, kidnap and assassinate local

populations, re-equip, and expand their narcotics operations. 77 President Alvaro Uribe

abandoned peace negotiations with the FARC, re-asserted government control over the ceded

territory, and pursued an aggressive strategy against the terrorists and traffickers. Via the

implementation of Plan Colombia and its sequel, the Democratic Security and Defense Policy,

the Colombian government undertook a dramatic expansion of its capabilities to consolidate

control over national territory in order to deny sanctuary to the terrorists, protect the population,

and to destroy the illegal drug trade. The military and police were expanded in size and

operational capabilities, and ministries were given more resources to provide the benefits of

governance. The results have been impressive: greater security, a much weakened FARC,

demobilization of over 30,000 paramilitaries, reduction in coca and heroin cultivation,

78
confidence in the government, reduced unemployment, and a dynamic economy.

One key component of Plan Colombia has been the aerial eradication campaign against

illicit coca and poppy. The aerial eradication campaign has had two key objectives. First, the

76U.S. Department of State, “Use of United States Assets in Colombia,” Report to Congress, 2004, p. 2. The report
added: “The managers [in Congress] are supportive of the Colombian government in its attempts to provide security

for the Colombian people and has provided the expansion of authorities in recognition that the narcotics industry is
linked to the terrorist groups, including the paramilitary organizations, in Colombia.”
77See, e.g., Ashley Turton 43.

78The impact of Uribe and the synchronization of US policy are explored in Marcella, “The United States and
Colombia: The Journey from Ambiguity to Strategic Clarity,” pp. 50-64.

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campaign directly attacks the supply of coca and poppy, thereby decreasing the available supply

of cocaine and heroin coming out of Colombia (and into the United States and other countries)

while concurrently decreasing the revenues to narcoterrorists. Second, as the aerial eradication

operations weakened the economic and security links between the farmers and the terrorists, the

government has regained control over large areas of the country that had beende facto ceded to

the terrorists.

The reaction of the FARC itself to these Plan Colombia initiatives is described in a press

release from the U.S. Department of Justice when a notorious FARC leader was extradited to the

United States for prosecution:

[R]ecognizing that the FARC could not survive without its cocaine

revenue, the indicted [FARC leaders] directed . . . members to
attack and disrupt coca eradication fumigation efforts, including
shooting down fumigation aircraft; [and] forcing local farmers to

participate in rallies against fumigation . . . . Recognizing that the
United States has contributed significantly to Colombian
fumigation efforts, the FARC leaders [late in 2001 and early 2002]
also ordered FARC members to kidnap and murder U.S. citizens in

order to dissuade the United States from its continued efforts to
fumigate . . . .9

The graphic below illustrates the evolution and success of the coca eradication program

from 2002 to 2009. 80 Throughout this period, the Colombian government, with U.S. assistance,

eradicated large areas of coca cultivation, in excess of 130,000 hectares a year, reaching a peak

of over 200,000 hectares a year in 2006, 2007, and 2008. During the early part of this period, the

eradication operations were almost exclusively conducted by aerial spraying because the FARC

79Erin Mulvey, U.S. DEA Press Release, “Leader of Colombian Narco-Terrorist Group Extradited to the United
States on Cocaine Importation Charges,” July 17, 2009
(http://www.justice.gov/dea/pubs/states/newsrel/2009/nyc071709.html).

80The graph comes from the Colombian Embassy, Washington, DC, “Plan Colombia: Institution Building & the
Fight Against Drug Trafficking”
(http://colombiaemb.org/index.php?option=com_content&task=view&id=989&It…; last visited December
10, 2010).

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and other narco-trafficking organizations still controlled most of the territories in which coca was

cultivated, making manual eradication too dangerous. Over time, as the effects of Plan

Colombia took hold, the government regained control over significant portions of the country

and manual eradication operations became a viable option in those areas. By the end of the

decade, manual eradication operations represented a substantial percentage of the total volume of

eradicated coca crops.

The eradication of illicit drug crops has helped open the door for a comprehensive

strategy that includes security and more effective and permanent governance in areas formerly

influenced or controlled by the FARC. Governance includes the permanent presence of the

police and military, improved access to justice, the construction of infrastructure, schools, and

medical facilities, the availability of markets and credit, and the development of alternative crops

for legitimate farmers. By September 2009, alternative development programs had benefited

more than 439,276 families in 18 (out of 32) departments in Colombia, including in Putumayo

and Nariño. Approximately 1,290 social and productive infrastructure projects were completed

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81
in the last seven years with communities that remain free of illicit crops. The expansion of the

capability of the public security forces (military and police) also has allowed the state to better

govern its citizens. Among the accomplishments is the impressive reform in the administration

of justice, whereby the judicial system, with the support of the Department of Justice and the

Agency for International Development, has been converted from the inquisitorial to the

accusatorial system. The results are remarkable in expediting cases and building confidence in

82
the judicial system. With security and the development of more effective and legitimate

institutions, the territorial space for terrorists has been reduced, their revenue flow has been

decreased, and their ability to attack institutions and officials has been diminished.

VI. Plan Colombia Has Successfully Weakened Foreign Terrorist Organizations in
Colombia and Improved United States National Security.

The aerial eradication operations of Plan Colombia have played a critical role in

weakening the FARC, ELN, and AUC. According to the latest UN statistics, “coca cultivation in

83
Colombia decreased by 58% between 2000 and 2009, mainly due to large-scale eradication”

and poppy cultivation in Colombia between 2000 and 2009 had been virtually eliminated. The

U.S. Department of State reported in 2010 that because of “…sustained aerial eradication and

increased manual eradication operations in 2008,” there was a “decline in pure cocaine

production potential of 39 percent from 485 metric tons in 2007 to 295 metric tons in 2008. The

UN reported an 18 percent drop in cultivation in 2008, down to 81,000 hectares, and a 28 percent

81
U.S. Department of State, 2010 International Narcotics Control Strategy Report, Volume I: Drug and Chemical
Control, Colombia section.
82The impact of the changes is discussed in more detail in Marcella, “Democratic Governance and the Rule of Law:

Lessons from Colombia,” pp. 28-33.
83UNODC, World Drug Report 2010, New York, NY: United Nations, 2010, p. 65.

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fall in cocaine production potential to 430 metric tons.” 84 As President Obama explained in his

2010 National Drug Control Strategy, one of the “lessons learned” from Plan Colombia is that

“[e]radication can be an effective deterrent to illicit cultivation.” 85 This sharp reduction in

narcotics crop cultivation has led to a correspondingly sharp decline in revenues for the FARC

86
and ELN. The Colombian government has estimated that FARC income from narcotics fell by

greater than 30% between 2003 and 2007, or by about $200 million, and the continued decline

in coca cultivation between 2007 and 2009 suggests that FARC revenues from narco-trafficking

continued to decline. Moreover, the coca growers’ responses to eradication (relocating,

dispersal, camouflage, smaller plots, pruning, and earlier harvesting) increased the costs to the

FARC and weakened the FARC’s hold on the populations. These responses also have depressed

the yield of coca plants. Between January 2007 and September 2009 the price per pure gram of

cocaine in the United States increased 75.4 percent, while the purity decreased 31.5 percent,

according to the DEA. 88

In its 2010 report, The Globalization of Crime: A Transnational Organized Crime Threat

Assessment, the UNODC strongly proclaimed the success of Plan Colombia in confronting the

threat of narcoterrorism, identifying Colombia as “the country which has made most progress

84
U.S. Department of State, 2010 International Narcotics Control Strategy Report, Volume I: Drug and Chemical
Control, Colombia section.
85
White House Office of National Drug Control Policy, National Drug Control Strategy, 2010, p. 84. Of course,
these reductions in narcotics production in Colombia also serve a vital U.S. interest in reducing the flow of illegal
narcotics from Colombia into this country. More than 31,000 Americans die each year from drug abuse, and an
estimated seven million people are addicted to controlled substances. See Placido, “Transnational Drug Enterprises
(Part II),” p. 1.

86ICG, “Colombia: Making Military Progress Pay Off,” Bogotá/Brussels, April 28, 2008, p. 8; De Shazo, et al.,
“Countering Threats to Security and Stability in Failing State: Lessons from Colombia,” p. 56; ICG, “Ending
Colombia’s FARC Conflict: Dealing the Right Cards,” p. 12.

87See footnote 5.

88Colombian Embassy, Washington, DC, “Plan Colombia: Institution Building & the Fight Against Drug
Trafficking” (http://colombiaemb.org/index.php?option=com_content&task=view&id=989&It…; last visited
December 10, 2010).

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over the last few years in curbing the threats to national and international security emerging from

drug production and trafficking” and announcing that “[t]he progress made in Colombia over the

last few years in reducing the threats emerging from the narco-business has been impressive.” 89

The UNODC gave much of the credit for these improvements to the sharp drop in coca

90
cultivation, which the UNODC explained was “mainly due to eradication.” The UNODC

included in its report the following chart, which demonstrates a clear temporal relationship

between the reduction of coca cultivation in Colombia and the size of the FARC and ELN:

In addition, UNODC found that this same temporal relationship between reducing illicit coca

cultivation and a reduction in terrorism had also occurred in Peru:

89UNODC, The Globalization of Crime: A Transnational Organized Crime Threat Assessment, Vienna: UNODC,
2010, pp. 228-29.
90
Ibid., p. 228.

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The US Government likewise has declared Plan Colombia a “dramatic success” as

clearly stated by President Barack Obama in his 2010 National Drug Strategy Report to

91
Congress. And, in a recent appearance before Congress, David T. Johnson, Assistant Secretary

of State for the Bureau of International Narcotics and Law Enforcement Affairs, testified that “as

a result of progress under Plan Colombia and its follow-on programs, more than 50,000

paramilitary members and guerilla combatants have demobilized, coca cultivation and cocaine

production potential have been significantly reduced … [and] public security has improved

enormously.” 92 Appearing before the same hearing, R. Gil Kerlikowske, the current United

States “Drug Czar,” testified that “the Revolutionary Armed Forces of Colombia (FARC) has

been significantly weakened through aerial and manual eradication, causing serious damage to

91
White House Office of National Drug Control Policy, National Drug Control Strategy, 2010. p. 84.
92David T. Johnson, Assistant Secretary of State, Bureau of International Narcotics and Law Enforcement Affairs,

Prepared Testimony Before the House Oversight and Government Reform Subcommittee on Domestic Policy,
“International Counternarcotics Policies: Do They Reduce Domestic Consumption or Advance Other Foreign
Policy Goals,” July 21, 2010, p. 2 (http://www.state.gov/p/inl/rls/rm/144982.htm).

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its financial viability, which had benefited from profits generated by its increased involvement in

93
narcotics trafficking.”

The success of the aerial eradication operations in depriving the narco-terrorists of

funding has been confirmed by the FARC itself. Among the computer files seized during the

Colombian military raid of the camp of FARC commander Raúl Reyes on March 1, 2008, was an

email in which Reyes bemoaned the impact of the spraying: “In the area of finances, we have

been unable to do a big deal, we have only done some small things, and the situation is difficult

94
because of the eradication and fumigation.” Other captured records reflect the FARC’s efforts

to stop the spraying operations by raising concerns about alleged environmental effects. In one

document, Raúl Reyes discussed a message from Ecuadorian Minister of National Security,

Gustavo Larrea, in which the Ecuadorian minister was believed to be seeking to foster relations

with the FARC in part by agreeing that Ecuador “will sue the state and government of Colombia

before the International Court for the damages the aerial spraying has caused.” 95 In another

document, a top FARC commander notes that: “The Bi-national Commission is being

strengthened, made up of members of the PCCC [Clandestine Communist Party of Colombia, the

civilian wing of the FARC] and Ecuadoran friends, so we can denounce the violations of

Ecuadoran sovereignty by [Colombian President] Uribe’s troops, and show the damaging effects

93
R. Gil Kerlikowske, Director of National Drug Policy, Prepared Testimony Before the House Committee on
Oversight and Government Reform Subcommittee on Domestic Policy, “International Counternarcotics Policies:
Do They Reduce Domestic Consumption or Advance Other Foreign Policy Goals,” July 21, 2010, p. 4
(http://www.whitehousedrugpolicy.gov/news/testimony10/07212010.pdf).
94
Letter from Edgar Tovar to Raúl Reyes, document obtained from FARC hard drive, March 1, 2008, Farah, “What
the FARC Papers Show Us about Latin American Terrorism,” p. 13.
95
Farah and Simpson, “Ecuador at Risk: Drugs, Thugs, Guerrillas and the Citizens Revolution,” p. 19.

315Annex 8

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96
of fumigation.” The FARC have also reportedly organized peasant demonstrations against the

97
spraying.

The loss of narcotics revenues has deeply affected the FARC’s military capability.

According to Colombian sources cited by the International Crisis Group (ICG), in 2002, the

FARC was present in 514 of 1,098 municipalities, while in 2009, “insurgent military actions

were registered in only 206 municipalities.” 98 Decreased revenues, battlefield losses and

desertions have forced the FARC to devote personnel and resources to defend senior officers, to

defend strategic corridors for the movement of cocaine, to hold valuable hostages, and to secure

geographic space in Cauca, Nariño, Chocó, Meta, Huila, Tolima and Guaviare that is critical for

their finances. Moreover, the loss of equipment and ammunition has diminished the FARC’s

arsenal. The military has also penetrated the FARC’s communications, making coordination

between fronts difficult, dangerous, and time-consuming. 99

A number of senior and mid-level terrorist commanders have died or been killed (some at

the hands of subordinates) and thousands of terrorist “soldiers” have deserted (reportedly 6,091

100
between 2008 and mid 2010). Because of the desertions, the average age of new recruits was

11.8 years in 2009, down from 12.9 years in 2008, according to the UN High Commissioner for

Human Rights. 101 The FARC’s offensive capability has been reduced by 70% in the same

period. 102 The Colombian Ministry of Defense lists the FARC’s critical losses: command and

96
Ibid., pp. 17-18.
97ICG, “Ending Colombia’s FARC Conflict: Dealing the Right Card,” p. 4.

98ICG, “Improving Security Policy in Colombia,” Latin American Briefing, Number 23, June 29, 2010, p. 2.

99The factors in the decline of the FARC, ELN, and AUC are explored in Fundación Seguridad y Democracia, “El
debilitamiento de los Grupos Irregulares en Colombia-2002-2208,” Bogotá, March 2, 2009.
100
ICG, “Improving Security Policy in Colombia,” p. 3.
101
Ibid., p. 5, footnote 35.
102
Fundación Seguridad y Democracia, “El debilitamiento de los Grupos Irregulares en Colombia-2002-2208,” p. 5.

316 Annex 8

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control, ability to communicate and coordinate among fronts, income and liquidity from the loss

103
of coca zones, logistical capabilities, combat capacity, morale, and manpower. In addition, the

FARC’s international support has eroded even more because of the atrocities they committed and

revelations of their involvement in narcotics trafficking.

The sharp setbacks for the FARC are mirrored by the declines of the two other

narcoterrorist organizations in Colombia. It is estimated that the ELN has been reduced to 2,000

members and is much less of a military threat. Analysts predict that because of its weakness the

group may eventually agree to put down its arms, like the AUC did with over 30,000 of the AUC

members undergoing demobilization, demilitarization, and reintegration.

The bottom line is that Colombia is a dramatically safer place than it was when Plan

Colombia began. From 2002 to 2009, kidnappings in Colombia were down by 83 percent, and

terrorist attacks decreased by 76 percent, while the area of coca cultivation was down from

163,000 hectares in 2000 to 77,870 in 2006, and 68,000 in 2009. 104 The expansion of the public

security forces has created safer conditions on the roads of the nation and greater citizen security.

In addition, the state has consolidated control over areas where the FARC held sway. The

government’s increased control over the country has facilitated fundamental reforms of the

judiciary and legal systems. Finally, the economy is dynamic, unemployment is reduced to

nearly 10 percent, investment is high, the stock market is performing well, and the Colombian

peso is rising impressively among international currencies. 105

103
Ministry of National Defense, Republic of Colombia, “The FARC at Their Worst Moment in History,” Bogotá,
2008, pp. 5-10 (http://web.presidencia.gov.co/english/publicaciones/farc_peor_momento.p…).
104
Marcella, “Democratic Governance and the Rule of Law: Lessons Learned from Colombia,” p. 21; Marcella,
“War Without Borders: The Colombia- Ecuador Crisis of 2008,” p. 16.
10Various indicators of success, including eradication, are analyzed in De Shazo, et al., “Countering Threats to

Security and Stability in a Failing State: Lessons from Colombia.”

317Annex 8

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▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

318 Annex 8

Case 1:07-cv-01DocumentFiled 0Page 41 of 51

EXHIBIT B

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 42 of 51

Exhibit B

Dr. Gabriel Marcella Materials Considered

Publications

1. African Union, 4 Session of the African Union Conference of Ministers for Drug

Control and Crime Prevention, Report of Experts’ Meeting, “Turning the Tide of Drugs
and Crime in Africa – From Policy to Action," CAMDCCP/EXP/Report (IV), Addis
Ababa, September 28-October 2 2010

(http://www.uneca.org/coda/Documents/AU_Drugs_Crime_Experts%20Report_Oct…
2010_%20English.pdf).

2. Philip Alston, “Statement by Professor Philip Alston, United Nations (UN) Special
Rapporteur on extrajudicial executions, Mission to Ecuador: 5-15 July 2010,” Quito, July
15, 2010.

3. Ana Arana, “Murder in Colombia,” Salon.com, December 14, 1999
(http://www.salon.com/news/feature/1999/12/14/colombia).

4. Gersón Ivan Arias, Natalia Herrera, and Carlos Andrés Prieto, “Mandos medios de las

FARC y su proceso de desmovilización en el conflicto colombiano: ¿Una apuesta para la
paz o para la guerra?” Bogotá: Fundación Ideas para la Paz, September 2010.

5. Attorney General John Ashcroft, “Prepared Remarks of Attorney General John Ashcroft:
DEA/Drug Enforcement Rollout,” March 19, 2002
(http://www.justice.gov/archive/ag/speeches/2002/031902newsconferencedea…

trollout.htm).

6. Association of South East Asian Nations and European Union (ASEAN-EU), “Joint
Declaration on Cooperation to Combat Terrorism,” 14 ASEAN-EU Ministerial Meeting,

January 27-28, 2003 (http://archive.asean.org/14030.htm; last visited November 30,
2010).

7. Rand Beers and Francis Taylor, Joint Testimony Before the U.S. Senate Committee on

the Judiciary Subcommittee on Technology, Terrorism and Government Information,
“Narco-Terror: The Worldwide Connection Between Drugs and Terror,”March 13, 2002.

8. Sebastian Brett, “‘You’ll Learn Not To Cry:’ Child Combatants in Colombia,” New
York, NY: Human Rights Watch, September 18, 2003
(http://www.hrw.org/reports/2003/colombia0903/).

9. Lanny A. Breuer, Statement Before Subcommittee on Human Rights and the Law
Committee on the Judiciary, U.S. Senate, “Drug Enforcement and the Rule of Law:
Mexico and Colombia,” May 18, 2010.

10. George W. Bush, The National Security Strategy of the United States of America,
September 20, 2002.

319Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 43 of 51

Exhibit B

11. Sandro Calvani, United Nations Office on Drugs and Crime (UNODC) Representative in
Colombia, “Summary Statement: UNODC Briefing on Foreign Aid to Colombia and the
European Role in the Fight Against Narco-terrorism,” Committee on International
Relations, U.S. House of Representatives, October 14, 2004.

12. Ana Carrigan, The Palace of Justice: A Colombian Tragedy, New York, NY: Four Walls
Eight Windows, 1993.

13. Steven W. Casteel, Assistant Administrator for Intelligence, Statement Before the U.S.
Senate Committee on the Judiciary, “Narco-Terrorism: International Drug Trafficking
and Terrorism- a Dangerous Mix,” May 20, 2003.

14. William J. Clinton, A National Security Strategy for a Global Age, White House:
December 2000.

15. Colombian Embassy, Washington, DC, “Peace & Justice Law”
(http://colombiaemb.org/index.php?option=com_content&task=view&id=45&Ite…;

last visited December 10, 2010).

16. Colombian Embassy, Washington, DC, “Plan Colombia: Institution Building & the Fight
Against Drug Trafficking”
(http://colombiaemb.org/index.php?option=com_content&task=view&id=989&It…

37; last visited December 10, 2010).

17. Colombian Office of the UN High Commissioner for Human Rights, Informe de la
Oficina del Alto Comisionado de las Naciones Unidas para los Derechos Humanos Sobre
la Misión de Observación en el Medio Atrato, Bogotá, May 20, 2002.

18. Comisión de Transparencia y Verdad Angostura, “Informe Comisión de Transparencia y

Verdad Angostura,” Quito, December 10, 2009
(http://www.ecuadorenvivo.com/images/pdf/INFORME-ANGOSTURA.pdf).

19. Committee on International Relations, U.S. House of Representatives, “Summary of
Investigation of IRA Links to FARC Narco-Terrorists in Colombia,” April 24, 2002.

20. Colleen W. Cook and Clare Ribando Seelke, “Colombia: Issues for Congress,”
Washington, DC: Congressional Research Service (CRS), September 12, 2008.

21. “Correo de ‘Jojoy’confirma que matanza de indígenas en 2009 fue obra de las FARC,”El
Universo, October 30, 2010 (http://www.eluniverso.com?imprimir.htm).

22. “Correos del ‘Mono Jojoy’ revelan cómo se planearon atentados contra El Nogal y la
Universidad Militar,” October 16, 2010
(http://wsp.presidencia.gov.co/prensa/2010/octubre/paginas/20101016_02.a…).

23. Council of the European Union, Political and Security Committee, “Statement on
strengthening international security,” 16751/2/08 REV 2 (en), Brussels, December 8,

2008

320 Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 44 of 51

Exhibit B

(http://www.eu2008.fr/webdav/site/PFUE/shared/import/1211_Conseil_europe…
ent%20on%20strengthening%20international%20security_EN.pdf).

24. Council on Foreign Relations, “Transnational Organized Crime as a Threat to Peace and
Security,” transcript, June 17, 2010

(http://www.cfr.org/publication/22580/transnational_organized_crime_as_a…
ace_and_security.html).

25. Audrey Kurth Cronin, Huda Aden, Adam Frost, and Benjamin Jones, “Foreign Terrorist
Organizations,” Washington, DC: CRS, February 6, 2004.

26. Peter De Shazo, Johanna Mendelson Forman, and Phillip McLean, “Countering Threats
to Security and Stability in a Failing State: Lessons from Colombia,” Washington, DC:
Center for Strategic and International Studies, September 2009.

27. Douglas Farah and Glenn Simpson, “Ecuador at Risk: Drugs, Thugs, Guerillas and the
Citizens Revolution,” International Assessment and Strategy Center, January 24, 2010.

28. Douglas Farah, “What the FARC Papers Show Us about Latin American Terrorism,”
Washington, DC: NEFA Foundation, April 1, 2008
(http://www.nefafoundation.org/miscellaneous/FeaturedDocs/nefafarc0408.p…).

29. “The FARC-ETA Connection,” Semana, February 16, 2009

(http://www.semana.com/noticias-print-edition/the-farceta-connection/120…).

30. Vanda Felbab-Brown, Shooting Up: Counterinsurgency and the War on Drugs,
Washington, DC: Brookings, 2009.

31. Jess T. Ford, Director International Affairs and Trade, Testimony Before the

Subcommittee on Domestic Policy, Committee on Oversight and Government Reform,
U.S. House of Representatives, “Drug Control: International Programs Face Significant
Challenges Reducing the Supply of Illegal Drugs but Support Broad U.S. Foreign Policy
Objectives,” United States Government Accountability Office, GAO-10-921T, July 21,
2010.

32. Juan Forero, “New Colombia Law Grants Concessions to Paramilitaries,” The New York
Times, June 23, 2005
(http://www.nytimes.com/2005/06/23/international/americas/23colombia.htm…).

33. Douglas Fraser, Commander-in-Chief, “The United States Southern Command Strategy

for 2010,” Miami: United States Southern Command, July 2010.

34. Sayaka Fukumi, Cocaine Trafficking in Latin America: EU and US Policy Responses,
Burlington, Vermont: Ashgate, 2008.

35. Fundación Seguridad y Democracia, “El debilitamiento de los Grupos Irregulares en
Colombia-2002-2208,” Bogotá, March 2, 2009.

321Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 45 of 51
Exhibit B

36. Juan Carlos Garzón, Mafia & Co.: The Criminal Networks in Mexico, Brazil, and
Colombia, Washington, DC: Woodrow Wilson Center for International Scholars, 2010.

37. Marc Gonsalves, Tom Howes, and Keith Stansell, Out of Captivity: Surviving 1,967 Days
in the Colombian Jungle, New York, NY: Harper Collins, 2009.

38. Stephanie Hanson, “FARC, ELN: Colombia’s Left-Wing Guerrillas,” Council on
Foreign Relations, August 19, 2009 (http://www.cfr.org/publication/9272/farc_eln.html).

39. Rex A. Hudson, “Colombia’s Palace of Justice Tragedy Revisited: A Critique of the
Conspiracy Theory,” Terrorism and Violence, Vol. 7, No. 2, Summer 1995.

40. Rex A. Hudson, et al., “A Global Overview of Narcotics Funded Terrorist and Other
Extremist Groups,” Library of Congress: Federal Research Division, May 2002.

41. Asa Hutchinson, Administrator, U.S. Drug Enforcement Administration, Statement
Before the U.S. Senate Caucus on International Narcotics Control, September 17, 2002
(http://www.justice.gov/dea/pubs/cngrtest/ct091702.html).

42. International Crisis Group (ICG), “Colombia: Making Military Progress Pay Off,”
Bogotá/Brussels, April 28, 2008.

43. ICG, “Ending Colombia’s FARC Conflict: Dealing the Right Cards,” March 26, 2009.

44. ICG, “Improving Security Policy in Colombia,” Latin American Briefing, Number 23,

June 29, 2010.

45. “International Global Terrorism: Its Links With Illicit Drugs as Illustrated by the IRA
and Other Groups in Colombia,” transcript of hearing before the Committee on
International Relations, U.S. House of Representatives, April 24, 2002.

46. David T. Johnson, Assistant Secretary of State, Bureau of International Narcotics and
Law Enforcement Affairs, Prepared Testimony Before the House Oversight and
Government Reform Subcommittee on Domestic Policy, “International Counternarcotics
Policies: Do They Reduce Domestic Consumption or Advance Other Foreign Policy
Goals?,” July 21, 2010 (http://www.state.gov/p/inl/rls/rm/144982.htm).

47. Joint Report of the U.S. Senate Committee on the Judiciary Subcommittee on Terrorism,
Technology, and Homeland Security, “Three Years After September 11: Keeping
America Safe,” March 2005.

48. Paul Rexton Kan, Drugs and Contemporary Warfare, Washington, DC: Potomac Books,

2009.

49. Rick Kearns, “FARC Massacre of indigenous in Columbia (sic), more deaths and
displacement,” Indian Country Today, March 13, 2009
(http://www.indiancountrytoday.com/global/latin/41204617.html?corder=rev…).

322 Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 46 of 51
Exhibit B

50. R. Gil Kerlikowske, Director of National Drug Policy, Prepared Testimony Before the
House Committee on Oversight and Government Reform Subcommittee on Domestic
Policy, “International Counternarcotics Policies: Do They Reduce Domestic
Consumption or Advance Other Foreign Policy Goals,” July 21, 2010
(http://www.whitehousedrugpolicy.gov/news/testimony10/07212010.pdf).

51. “La confesión de Fernandinho,” Semana, April 30, 2001
(http://www.semana.com/wf_imprimirarticulo.aspx?IdArt=17243).

52. Pilar Lozano, “Matanza de 27 indígenas en el sur de Colombia,” El País (Madrid),
February 14, 2009

(http://www.elpais.com/articulo/internacional/Matanza/27/indigenas/sur/C…
uint/20090214elpepiint_5/Tes).

53. Gabriel Marcella, “American Grand Strategy for Latin America in the Age of
Resentment,” Carlisle, PA: Strategic Studies Institute (SSI), September 2007

(http://www.strategicstudiesinstitute.army.mil/pdffiles/pub811.pdf).

54. Gabriel Marcella, “Colombia’s Three Wars: U.S. Strategy at the Crossroads,” SSI, March
5, 1999 (http://www.strategicstudiesinstitute.army.mil/pdffiles/pub34.pdf).

55. Gabriel Marcella, “Democratic Governance and the Rule of Law: Lessons Learned from
Colombia,” Carlisle, PA: SSI, December 2009

(http://www.strategicstudiesinstitute.army.mil/pubs/display.cfm?PubID=955).

56. Gabriel Marcella, “Plan Colombia: Some Differing Perspectives,” Carlisle, PA: SSI, June
2001 (http://www.strategicstudiesinstitute.army.mil/pdffiles/pub23.pdf).

57. Gabriel Marcella, “Plan Colombia: The Strategic and Operational Imperatives,” Carlisle,

PA: SSI and North-South Center, April 2001
(http://www.strategicstudiesinstitute.army.mil/pdffiles/PUB29.pdf).

58. Gabriel Marcella and Richard Downes, Security Cooperation in the Western Hemisphere:
Resolving the Ecuador-Peru Conflict, Miami: University of Miami, North-South Center

Press, May 1999.

59. Gabriel Marcella, “The United States and Colombia: The Journey From Ambiguity to
Strategic Clarity,” Carlisle, PA: SSI, May 2003
(http://www.strategicstudiesinstitute.army.mil/pdffiles/PUB10.pdf).

60. Gabriel Marcella, “The U.S. Engagement with Colombia: Legitimate State Authority and

Human Rights,” Miami: University of Miami, North-South Center, March 2002.

61. Gabriel Marcella, “War and Peace in the Amazon: Strategic Implications for the United
States and Latin America of the 1995 Ecuador-Peru War,” Carlisle, PA: SSI, November
24, 1995 (http://www.strategicstudiesinstitute.army.mil/pdffiles/00037.pdf).

323Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 47 of 51

Exhibit B

62. Gabriel Marcella, “War Without Borders: The Colombia-Ecuador Crisis of 2008,”
Carlisle, PA: SSI, December 2008
(http://www.strategicstudiesinstitute.army.mil/pdffiles/PUB891.pdf).

63. Gabriel García Márquez, News of a Kidnapping, New York, NY: Penguin Books, 1997.

64. Ministry of National Defense, Republic of Colombia, “The FARC at Their Worst
Moment in History,” Bogotá, 2008
(http://web.presidencia.gov.co/english/publicaciones/farc_peor_momento.p…).

65. Tyler K. Moore, “Winning the Psywar in Colombia,” Monterey, CA: Naval Postgraduate

School, July, 2001.

66. Erin Mulvey, U.S. Drug Enforcement Administration Press Release, “Leader of
Colombian Narco-Terrorist Group Extradited to the United States on Cocaine
Importation Charges,” July 17, 2009
(http://www.justice.gov/dea/pubs/states/newsrel/2009/nyc071709.html).

67. Barack Obama, National Security Strategy, May 2010.

68. Organization of American States (OAS), Inter-American Committee Against Terrorism,
“Declaration of Montevideo,” OEA/Ser.L/X.2.4, CICTE/DEC. 1/04 rev.3, February 4,
2004.

69. OAS, Inter-American Committee Against Terrorism, “Declaration on Strengthening
Border Controls and International Cooperation in the Fight Against Terrorism,”
OEA/Ser.L/X.2.9, CICTE/DEC.1/09, Washington, March 6, 2009.

70. OAS Permanent Council Resolution 837 (1354/03), Condemnation of Terrorist Acts in

Colombia, February 12, 2003 (http://www.oas.org/consejo/resolutions/res837.asp).

71. John Otis, “Colombians Forced to pay rebels / Fighting extortion may come at deadly
price for opponents,” Houston Chronicle, October 28, 2001
(http://www.chron.com/CDA/archives/archive.mpl?id=2001_3344360).

72. Daniel Pécaut, Guerra Contra La Sociedad, Bogotá: Planeta, 2001.

73. Thomas R. Pickering, “Anatomy of Plan Colombia,” The American Interest Online,
November-December 2009 (http://www.the-american-
interest.com/article.cfm?piece=703).

74. Eduardo Pizarro Leóngomez, Una Democracia Asediada, Bogotá: Norma, 2004.

75. Anthony P. Placido, Assistant Administrator for Intelligence, U.S. Drug Enforcement
Administration, Statement Before the Subcommittee on National Security and Foreign
Affairs Committee on Oversight and Government Reform, U.S. House of
Representatives, “Transnational Drug Enterprises (Part II): Threats to Global Stability

and U.S. Policy Responses,” March 3, 2010.

324 Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 48 of 51

Exhibit B

76. “Preliminary Report of the Commission of Truth for the Holocaust in the Palace of
Justice of Bogotá of November 6 and 7, 1985,” November 15, 2006
(http://www.verdadpalacio.org.co/Assets/DOCs/informe_prelimiar.pdf).

77. Luis Alberto Villamarín Pulido, El Cartel de las FARC, Bogotá: Ediciones El Faraón,

1996.

78. Juan J. Quintana, Counselor, Embassy of Colombia, Prepared Statement before the
Committee on International Relations, U.S. House of Representatives, Hearing on Aid to
Colombia: The European Role in the Fight Against Narco-terrorism, “European
Assistance to Colombia,” November 18, 2004.

79. Alejandro Reyes, “Compra de tierras por narcotraficantes,” in Francisco Thoumi,et. al.,
Drogas ilícitas en Colombia, Ministerio de Justicia, Dirección Nacional de
Estupefacientes, Bogotá: Ariel Naciones Unidas-PNUD, 1997.

80. John Rollins, Liana Sun Wyler, and Seth Rosen, “International Terrorism and

Transnational Crime: Security Threats, U.S. Policy, and Considerations for Congress,”
Washington, DC: CRS, March 18, 2010.

81. Mauricio Romero, Paramilitares y autodefensas, 1982-2003, Bogotá: Instituto de
Estudios Políticos y Relaciones Internacionales and Editorial Planeta, 2003.

82. Rafael Pardo Rueda, De Primera Mano, Colombia 1986-1994: Entre Conflictos y
Esperanzas, Bogotá: Norma, 1996.

83. Rafael Pardo Rueda, La Historia de las Guerras, Bogotá: Vergara, 2004.

84. Juan Manuel Santos, República de Colombia, Ministerio de Defensa Nacional,

Tendencias y resultados 2007, January 24, 2008
(http://colombiaemb.org/docs/Plan%20Colombia%20Documents/Main%20Results/…
encias_y_Resultados_2007_SP.pdf).

85. Secretary of State, “A Report to Congress on United States Policy Towards Colombia
and Other Related Issues,” Washington, DC: Department of State, February 3, 2003

(http://www.state.gov/p/wha/rls/rpt/17140.htm).

86. Admiral James Stavridis, “U.S. Southern Command Posture Statement,” Miami, FL:
United States Southern Command, 2008.

87. Thomson Financial, “Colombia’s main oil pipeline closed after guerrilla attack,”

Thomson Financial News, June 23, 2008
(http://www.forbes.com/feeds/afx/2008/06/23/afx5143758.html).

88. Francisco Thoumi, Illegal Drugs, Economy, and Society in the Andes, Washington, DC:
Woodrow Wilson Press, 2004.

325Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 49 of 51

Exhibit B

89. “Una cicatriz en lo profundo del Atrato,” Semana, September 18, 2010
(http://www.semana.com/noticias-nacion/cicatriz-profundo-del-atrato/1447…).

90. United Nations Office on Drugs and Crime (UNODC), Colombia: Coca Cultivation
Survey, 2006, Bogotá: UNODC, June 2007.

91. UNODC, The Globalization of Crime: A Transnational Organized Crime Threat
Assessment, Vienna: UNODC, 2010.

92. UNODC, World Drug Report 2010, New York, NY: United Nations, 2010.

93. UN Press Release, “UN Warns About Nexus Between Drugs, Crime and Terrorism,”

SOC/CP/311, October 1, 2004
(http://www.un.org/News/Press/docs/2004/soccp311.doc.htm).

94. UN Secretary General, “Remarks to Security Council Meeting on Drug Trafficking as a
Threat to International Peace and Security,” New York, NY, December 8, 2009
(http://www.idpc.net/sites/default/files/alerts/SG_SC_Drug_Trafficking.p…).

95. UN Security Council Resolution 1373, September 28, 2001.

96. UN Security Council Resolution 1465 (2003), February 13, 2003 (http://daccess-dds-
ny.un.org/doc/UNDOC/GEN/N03/247/96/PDF/N0324796.pdf?OpenElement).

97. UN Security Council, “Statement by the President of the Security Council,”

S/PRST/2010/4, February 24, 2010.

98. U.S. Department of Justice Press Release, “Dutch Woman and 17 Other Members of
FARC Terrorist Organization Indicted on Hostage-Taking and Weapons Charges,”
December 14, 2010 (http://miami.fbi.gov/dojpressrel/pressrel10/mm121410.htm).

99. U.S. Department of State, 2009 Country Reports on Terrorism—Colombia, August 5,
2010.

100. U.S. Department of State, Bureau for International Narcotics and Law Enforcement
Affairs, 2010 International Narcotics Control Strategy Report, Volume I: Drug and

Chemical Control, Policy and Program Developments, Washington, DC, March 2010.

101. U.S. Department of State, Office of the Coordinator for Counterterrorism, Patterns of
Global Terrorism: 1999, April 2000
(http://www.state.gov/www/global/terrorism/1999report/1999index.html).

102. U.S. Department of State, Office of the Coordinator for Counterterrorism, Patterns of

Global Terrorism: 2000, April 2001 (http://www.state.gov/s/ct/rls/crt/2000/2450.htm).

103. U.S. Department of State, “Use of United States Assets in Colombia,” Report to
Congress, 2004.

326 Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 50 of 51

Exhibit B

104. U.S. Department of the Treasury Press Release, “Treasury Designates Additional FARC
International Commission Members,” January 14, 2009
(https://ustreas.gov/press/releases/hp1353.htm).

105. U.S. Department of the Treasury Press Release, “Treasury Takes Action Against

FARC/AUC Narco-Terrorist Leaders in Continued Effort to Halt Narcotics Trafficking,”
February 19, 2004 (https://ustreas.gov/press/releases/js1181.htm).

106. U.S. Drug Enforcement Administration, “Drug Trafficking in the United States,”
(http://www.justice.gov/dea/concern/drug_trafficking.html; last visited December 14,
2010).

107. U.S. Drug Enforcement Administration Press Release, “Department of Justice Hands
Down Indictments Against FARC Terrorists,” March 18, 2002
(http://www.justice.gov/dea/pubs/pressrel/pr031802.html).

108. “U.S. General Outlines Existing and Emerging Hemispheric Threats,” America.gov,

March 25, 2004 (http://www.america.gov/st/washfile-
english/2004/March/20040325145251ASrelliM0.9962274.html).

109. U.S. Government Accountability Office, Report to the Honorable Joseph R. Biden, Jr.,
Chairman, Committee on Foreign Relations, U.S. Senate, “Plan Colombia: Drug

Reduction Goals Were Not Fully Met, but Security Has Improved; U.S. Agencies Need
More Detailed Plans for Reducing Assistance,” GAO-09-71, October 2008.

110. United States v. Garcia, Grand Jury Indictment, United States District Court for the
District of Columbia, December 14, 2010.

111. Connie Veillette, “Plan Colombia: A Progress Report,” Washington, DC: CRS, February

17, 2005.

112. William F. Wechsler, Deputy Assistant Secretary of Defense for Counternarcotics and
Global Threats, Testimony Before the Subcommittee on Domestic Policy Committee on
Oversight and Government Reform, U.S. House of Representatives, “International

Supply Reduction and Interdiction Programs,” July 21, 2010.

113. White House Office of National Drug Control Policy, National Drug Control Strategy,
2010.

114. Scott Wilson, “No Sanctuary from War,” Washington Post, May 8, 2002,

(http://www.globalexchange.org/countries/americas/colombia/26.html.pf).

Other Materials Considered

1. Declaration of Rand Beers, Assistant Secretaryof State for the Bureau of International
Narcotics and Law Enforcement Affairs Regarding Potential Impact of Arias Litigation

on United States National Security and Foreign Policy Interests, November 27, 2001, and
Supplemental Declaration of Rand Beers re same, August 8, 2002.

327Annex 8

Case 1:07-cv-01042-RWR -DAR Document 220-10 Filed 08/19/11 Page 51 of 51

Exhibit B

2. Declaration of Paul F. O’Sullivan, Jr., Deputy Director of the Office of Aviation,
Department of State, Bureau of International Narcotics Law Enforcement of Affairs,
Arias/Quinteros litigation, Nos. 01-1908 and 07-1042, May 27, 2010.

3. Declaration of Spray Plane Pilot John Doe, redacted version, Arias/Quinteros litigation,

Nos. 01-1908 and 07-1042, June 2, 2010.

328 Annex 9

EXPERT REPORT OF DR J.M. DT OMASO, PH.D.PREPARED FOR THEDYNCORP
DEFENDANTS INARIAS/QUINTEROS . YNCORP (D.D.C.),

20 ANUARY 2011

(United States District Court for the District of Columbia,

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Cases consolidated for Case Management and Discovery)

329330 Annex 9

Case 1:07-cv-01042-RWR Document 220Filed 08/19Page 1 of 64

EXHIBIT 3

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EXPERT REPORT OF JOSEPH M. DITOMASO

Prepared for the DynCorp Defendants in
Arias/Quinteros v. DynCorp (D.D.C.)

Table of Contents

BACKGROUND & CREDENTIALS.............................................................................................1

STATEMENT OF COMPENSATION ...........................................................................................2

PRIOR TESTIMONY......................................................................................................................2

SUMMARY OF EXPERT OPINIONS...........................................................................................3

GLYPHOSATE IS WIDELY USED AND WIDELY STUDIED..................................................4

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Use of glyphosate in sensitive environments...........................................................5

Use of glyphosate by everyday homeowners...........................................................6

THE MODE OF ACTION AND EFFECTS OF GLYPHOSATE AND ITS

SURFACTANTS.............................................................................................................................7

Glyphosate’s mode of action ...............................................................................................7

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

phytotoxic effects...................................................................................................10

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Delayed effects in plants........................................................................................11

Universal, dose-dependent effects in plants...........................................................11

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

331Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 3 of 64

PLAINTIFFS’ ALLEGED CROP DAMAGES ARE INCOMPATIBLE WITH THE

KNOWN PHYTOTOXIC EFFECTS OF GLYPHOSATE, AND THEREFORE
PLAINTIFFS’ALLEGED CROP DAMAGES WERE NOT CAUSED BY THE PLAN
COLOMBIA SPRAY MIXTURE.................................................................................................22

y Salmsily...........................................................................................................23

Family ..................................................................................................25

y CaFaroily.........................................................................................................26

y Balcaamrily.....................................................................................................27

y Alvarazily.......................................................................................................28

y▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

y MestaFamaily....................................................................................................30

THE EXPERT REPORT SUBMITTED BY DR. WOLFSON ON BEHALF OF THE TEST
PLAINTIFFS IS INCORRECT IN SEVERAL OF ITS FUNDAMENTAL ASSUMPTIONS....34

332 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 4 of 64

BACKGROUND & CREDENTIALS

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
am presently a Cooperative Extension Weed Specialist with the University of California, Davis
(UC Davis). I received my BS degree in 1978 in Wildlife and Fisheries Biology from UC Davis.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Arcata, California. I received my Ph.D. in Botany/Weed Science from UC Davis in 1986.

Among some of my recent accomplishments, in 2008, I was appointed by the Secretary of the
Interior of the United States to serve on the Invasive Species Advisory Committee, a committee
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Committee. I am President of the Western Society of Weed Science (elected in 2009), and I am
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Invasive Plant Science and Management (appointed to this position by
the Board of Directors of the Weed Science Society of America in 2007). In March 2011, I will

be named a Fellow of the Weed Science Society of America. This is the highest award the
society bestows on its membership and represents career accomplishments in the Weed Science
discipline.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
applied research and are responsible for statewide leadership in extending information to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
establish more effective, scientifically-based, and cost effect methods for the management of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
biology of the target and non-target plants, as well as the ecology of the ecosystem, to develop
environmentally safe, economical, and effective strategies for invasive plant management. My
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e.g., rangelands, wildlands,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

333Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 5 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
plants, describe the fate of herbicides in the environment, provide options for control of a variety
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Conyza spp.,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
vitae, attached to this report as Exhibit A▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

STATEMENT OF COMPENSATION

deposition and trial testimony.

PRIOR TESTIMONY

Date Nature of Testimony Case Information

2006 Deposition ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2007 – 2009 Deposition and Trial Adams, et al. v. United States of America, et al., No.
CIV 03-0049-E-BLW (D. Idaho)

▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

al., No. M74585 c/w M83877

334 Annex 9

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SUMMARY OF EXPERT OPINIONS

in Plan Colombia has damaged their crops, as evidenced by the photographs, videos, deposition
testimony, and other descriptions provided by the test plaintiffs in this litigation. My opinions
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
effects (toxic effects on plants).

Therefore, it is my opinion, to a reasonable degree of certainty, that the test plaintiffs’
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯

materials considered in reaching my opinions is attached to this report as Exhibit B.

335Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 7 of 64

GLYPHOSATE IS WIDELY USED AND WIDELY STUDIED

Glyphosate is a widely used herbicide. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯1▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
toxicological / environmental profile combined with its effectiveness in controlling a wide

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
at odds with the real world experience with glyphosate, most notably glyphosate’s major role in

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

herbicide) second with 1.7 million lbs). In terms of total acreage treated in California, glyphosate
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

336 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 8 of 64

y Use of glyphosate throughout modern agriculture. Glyphosate is by far the leading
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
example, controlled applications of glyphosate are a common treatment to eradicate
3
developing or established weeds in the tree rows or space between the rows.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
90% of the soybeans grown worldwide, and 100% of the soybean grown in Argentina.
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Powles 2008).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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y Use of glyphosate in sensitive environments.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

337Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 9 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Pueraria phaseoloides (a close relative of
▯▯▯▯▯▯▯ Cinchona pubescens, and Rubus glaucus (Gardener et al. 1999, Soria et al. 2002,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

y Use of glyphosate by everyday homeowners.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Glyphosate has been widely studied.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
perhaps more extensively than any other herbicide – over the last 30 or more years. 4 In addition
5
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ recent reviews by Williams (2000) and Giesy
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

338 Annex 9

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THE MODE OF ACTION AND EFFECTS OF GLYPHOSATE AND ITS

SURFACTANTS

Glyphosate’s mode of action. Glyphosate is the active ingredient in the Plan Colombia spray

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roots and leaves, storage organs, and other actively growing areas of the plant. At these
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growth.

synthesis of the aromatic amino acids phenylalanine, tyrosine, and tryp6ophane (Gresshoff 1979)
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Figure 1: Pathway for synthesis of aromatic amino acids and site of inhibition by glyphosate.

Glyphosate
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+ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Erythrose 4-P

Phenylalanine Prephenate Chorismate

Serine +
Indolglycerol

Many proteins Tyrosine Tryptophane
Phenolic acids
Lignin
Phytoalexins

In plants, stores of aromatic amino acids (e.g., phenylalanine, tyrosine, and tryptophane) are
critical to maintaining protein synthesis, a process which is necessary for the plant’s growth and
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6Convincing evidence that EPSP is the sole site of herbicide action can be inferred from the fact that

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synthase, tolerate applications of glyphosate (at reasonable/commercial levels).

339Annex 9

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plant leads to a shortage of free carbon that in necessary for the synthesis of many other
7
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ In essence, following a
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
aromatic amino acids, the target site for glyphosate is not present in any animal system.

Use of surfactants to enhance efficacy of glyphosate.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
contains several components (often characterized as “inactive” ingredients) in addition to

Surfactants generally.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
10
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ The most common type of

7▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2009).

8▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

9▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯
10
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

340 Annex 9

DGMXYDQWXVHGLQKHUELFLGHVSUD\VROXWLRQVLVDVXUIDFWDQWDFRPELQDWLRQRIWKHZRUGV
³VXUIDFHDFWLYHDJHQW´1XPHURXVVWXGLHVKDYHVKRZQWKDWVXUIDFWDQWVDUHQHFHVVDU\WR
DFKLHYHPD[LPDODFWLYLW\RIWKHKHUELFLGHDQGLQP\H[SHULHQFHDOOIROLDUDSSOLHG

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341Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 13 of 64

Surfactants in the Plan Colombia spray mixture do not exert independent
phytotoxic effects.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
glyphosate alone (Collins and Helling 2002). And, consistent with the properties of
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

wetting, retention, and penetration into the plant. They exert no phytotoxic effects
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Characteristic phytotoxic effects of glyphosate formulations. To a large extent, glyphosate’s
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
plaintiffs’ crop damage claims.

11
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

to Congress, 2002).

342 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 14 of 64

y Delayed effects in plants.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e.g▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

herbicide (Collins and Helling 2002; Solomon 2005).

y Universal, dose-dependent effects in plants. Given that the site of action (EPSP

12
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(http://wssa.net/Weeds/Tools/Herbicides/HerbicideMovies.htm ) for time-lapse photography of the effects
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

13▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
14
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Ready crops with a genetically modified resistance to glyphosate.

343Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 15 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
15
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Powles 2008), and not target site sensitivity or the rate of herbicide degradation in the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

15
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
hormesis in plants (i.e▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Cedergreen et al. 2007, 2009; Cedergreen 2008a, b; Velini et al. 2008).

16▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(which can depend on photosynthetic rates in the plant), or other morphological or physiological
differences among plant species.

344 Annex 9

345Annex 9

346 Annex 9

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347Annex 9

348 Annex 9

349Annex 9

350 Annex 9

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351Annex 9

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JO\SKRVDWHZHUHDSSOLHGWRFRFD)HUUHLUDHWDO

352 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 24 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
points. As a general proposition, ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

y Effects produced only after foliar application. Glyphosate is well recognized to have
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
preparation settings (Williams 2000). In these applications, glyphosate is applied to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

353Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 25 of 64

PLAINTIFFS’ ALLEGED CROP DAMAGES ARE INCOMPATIBLE WITH THE
KNOWN PHYTOTOXIC EFFECTS OF GLYPHOSATE, AND THEREFORE

PLAINTIFFS’ALLEGED CROP DAMAGES WERE NOT CAUSED BY THE PLAN
COLOMBIA SPRAY MIXTURE

In reviewing the crop damage allegations of the seven test-plaintiff families, it is clear that if
their allegations have any consistency whatsoever, 20they consistently fail to demonstrate the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the Plan Colombia spray mix.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
nearly all of the plaintiffs explain that the herbicide selectively targeted their crops in some
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
a non-selective herbicide that affects all vegetation.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯he drift zone. Therefore, if one credits the test plaintiffs’
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
originating from the intended spray zone (in Colombia) and – in the case of many of the test
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Plan Colombia aerial eradication missions (i.e., the “Verification Mission Reports”) indicates a
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
even then the effects allegedly observed in the test plaintiffs’ crops are not consistent with the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
associated with glyphosate are not apparent in any of the videos, photos or testimony. Indeed,

20
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
deposition testimony) and from one family member to another.

354 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 26 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
am not aware of any testing here that demonstrates that the test plaintiffs’ crops were exposed to

y Salasily

21
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ of the three Salas family shows that
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
alleged spray event (May 2001) the “little leaves” fell from some of his crops
(Dep. 43). This is not consistent with the activity of glyphosate, which does not
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2. Each member of the Salas family indicated that distinctive spots appeared on their
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
spotting described by the Salas family’s testimony. In my experience, symptoms
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
glyphosate.

21
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
testimony.

355Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 27 of 64

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Sanchez Dep. 82-83), and yet there is no mention of the typical growth
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4. Jorge Salas testified that none of the wild plants/grasses were affected by the

5. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
their depositions) provide some of the best evidence that their crop damages are
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯part of a

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

6. The Salas family also testified that the Plan Colombia herbicide adversely
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
six years▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
claims that the sprayings forced him to abandon certain (infertile) fields only to
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
by trees and other plants of a secondary forest (Dep. 47). If glyphosate prevented
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7. The Salas family’s testimony concerning when they observed spray planes does
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
near the Colombian border. In their deposition testimony, the family alleged
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

356 Annex 9

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357Annex 9

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358 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 30 of 64

4. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

5. The testimony of the Calero family made no mention of any effects in the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

6. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
destroyed all of his crops. However, the available spray/flight data show that no
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

that time.

y BalcaFzarily

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
border with Colombia – were devastated by the Plan Colombia aerial eradicat22n
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ In fact, the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
best evidence that glyphosate was not ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

example:

1. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Balcazar explaining how the Plan Colombia spraying has totally destroyed cacao

2. As another example, the video goes on to show Mr. Balcazar standing next to a
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

22▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
herbicide.

359Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 31 of 64

some dead branches, the same tree also contains far more green – apparently
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
in the video. Finally, the cacao shows none of the typical growth deformities
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
can be said of the lemon (3:45), lime (4:20), and mango trees (7:05) that Mr.
Balcazar selects as examples later in the video.

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
was affected following sprayings several months prior to the date of the video
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

vegetation in the distance.

4. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

In his deposition, Mr. Balcazar describes additional effects that are inconsistent with
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
described above. For example:

1. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
cacao “seed” or “bean” “got dried and fell down” (Dep. 64). Glyphosate is not
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(cacao), 67 (coffee)), in his descriptions he never mentions any new growth
deformation (e.g., witch’s broom appearance), which is characteristic of

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3. Mr. Balcazar testified that his rice was affected for three years following the spray
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
activity.

y AlvFraezily

360 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 32 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
crops (Dep. 49-50). Meanwhile, there is no mention of growth deformation,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯23▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
months and then die – and all that is left is weeds (Dep. 93). For one,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 24▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
healthy vegetation that clearly was not affected by an aerial/drift application of

glyphosate.

4. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

y QuevFeadoily

1. As is the case with all of the test plaintiffs, there is no mention of the primary
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

23
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
related to Plan Colombia spraying somewhere (Dep. 78).

24Ms. Alvarez also claims that for a period of six months following the April 2001 spray event nothing
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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for that matter.

2. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
crops with little or no activity on the wild vegetation.

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

that even today the corn grown on her property is “not really normal” (Dep. 66)
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯26▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
her life seen a Plan Colombia spray plane (Dep. 30-31).

y Mesta Fnzmaily

The video shot in November 2002 – i.e., one month after the October 7 thand 10 spray
27
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ – shows time and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

25
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

26▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

18).
27
In his deposition, Mr. Mestanza testified that the October 2002 spray events were so devastating to his
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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herbicide, if it reached the Mestanza property by a direct aerial application or by drift

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
glyphosate to be observed only in isolated plants (or portions of plants). Rather, wide
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

relatively dense vegetation to reach an example of a plantain plant that, according
to Mr. Mestanza, was damaged from the Plan Colombia sprayings. This segment
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
28
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ In fact,
it becomes increasingly evident that Mr. Mestanza’s plantains were not
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 29

2. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the plants are becoming dry. Again, these are not symptoms of glyphosate

28▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

well from Mr. Mestanza’s description of his crop damages, despite the fact that this is the most
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

29▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

30▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

363Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 35 of 64

4. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
beneficial effects in that crop species.

5. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

spray drift from the aerial eradication missions on the Colombian side of the river
had somehow devastated Mr. Mestanza’s property as he alleges, then this segment
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
effects originating on the Colombian side and extending across the river onto Mr.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

6. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
adjacent to the pool show any symptoms of glyphosate phytotoxicity.

8. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

364 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 36 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

9. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

10. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
panoramic shot across Mr. Mestanza’s property. This scene depicts animals

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of widespread devastation testified to by Mr. Mestanza and his family) indicative
of an aerial/drift application of glyphosate.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
glyphosate on his property seven years after the last alleged spray event. In the video
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯31▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

31▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
plants grow, their leaves fall off (Dep. 177). Mr. Mestanza also testified that two years after the October
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

365Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 37 of 64

THE EXPERT REPORT SUBMITTED BY DR. WOLFSON ON BEHALF OF THE TEST

PLAINTIFFS IS INCORRECT IN SEVERAL OF ITS FUNDAMENTAL ASSUMPTIONS

The addition of Cosmo-Flux to the Plan Colombia spray mixture.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
32
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯33▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the EPA-approved master label ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Product Description:▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

32
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

33▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Labeling Database, at ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

366 Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 38 of 64

OPTIONAL STATEMENT:▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯INSERT BRAND NAME▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯should be added▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

The concentration of Roundup in the Plan Colombia spray mixture. Dr. Wolfson’s opinion
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
label that “unless otherwise specified▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯is

otherwise specified▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

367Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 39 of 64

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
34
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

also wrong.

Dated: ____1-20-2011 ______ __________
DJiMo.phso

&51RWH'U'L7RPDVR
V&9([KLELW$IRXQGLQ&'2ULJLQDO$QQH[HV

34
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
NOT APPLY THIS PRODUCT USING AERIAL SPRAY EQUIPMENT EXCEPT UNDER
CONDITIONS AS SPECIFIED WITHIN THIS LABEL.” To the extent Dr. Wolfson believes that the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
applied. Applications made in Plan Colombia were within the specifications of the label, as noted above.

368 Annex 9

Case 1:07-cv-0104Document Filed 08Page 55 of 64

E(Materials Considered)

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 56 of 64

Publications

1) Avila, R., E. Bravo, J. Breilh, A. Campaña, C. Paz-y-Miño, L. Peñaherrera, and J.
Valencia. 2007. The Plan Colombia Aerial Spraying System and its Impact on the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
122:5341-536.

3) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Rubus
megalococcus and R. adenotrichos▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4) Carlisle, S.M. and J.T. Trevors. 1988. Glyphosate in the environment. Water, Air Soil
▯▯▯▯▯▯▯▯▯. 39:409–420.

5) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

6) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
438.

7) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

8) Cedergreen, N., C. Felby, J.R. Porter, and J.C. Streibig. 2009. Chemical stress can
increase crop yield. Field Crops Research. 1-4.

9) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

10) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Species by Glyphosate. Weed Technology. 16:851-859.

11) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

12) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
herbicide. Pest Management Science. 64: 319-325.

13) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

14) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

369Annex 9

Case 1:07-cv-01042-RWR -DAR Document 220-3 Filed 08/19/11 Page 57 of 64

15) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
4):225-235.

16) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

17) Ellis, J.M., J.L. Griffin, S.D. Linscombe, and E.P. Webster. 2003. Rice (Oryza sativa)
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Technology. 17:452-460.

18) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Hort. Soc. 109:40-42.

19) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Erythroxylum
caco and E. novogranatense) with glyphosate. Weed Science 45:551-556.

20) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Galapagos Islands. Pages 396-400 in A.C. Bishop, M. Boersma, and C.D. Barnes, editors.
Proceedings from the Twelfth Australian Weeds Conference, 17-19 September 1999.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

21) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

22) Gravena, R., R.V. Filho, P.L.C.A. Alves, P. Mazzafera, and A.R. Gravena. 2009. Low
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

425.

23) Gresshoff, P.M. 1979. Growth inhibition by glyphosate and reversal of its action by
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

24) Hance, R.J. 1976. Adsorption of glyphosate by soils. Pesticide Science 7:363-366.

25) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Technology 14:807-813.

26) Hewitt, A.J., K.R. Solomon, and E.J.P. Marshall. 2009. Spray Droplet Size, Drift
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
929.

370 Annex 9

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27) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(Chlidonias niger▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Waterbirds 17:160-167.

28) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and Environmental Health, Part A. 72:930-936.

29) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

30) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
economic costs associated with alien-invasive species in the United States. Ecological
Economics 52:273-288.

31) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

32) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

33) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
29:85-94.

34) Schabenberger, O., B.E. Tharp, J.J. Kells, and D. Penner. 1999. Statistical tests for
hormesis and effective dosages in herbicide dose response. Agron. J. 91:713-721.

35) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(Convolvulus arvensis). Weed Science 34:811-816.

36) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(OAS).

37) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Assessment of Aerially Applied Glyphosate. Rev. Environ. Contam. Toxicol. 190:43-
125.

371Annex 9

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38) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
20.

39) Soria, M.C., M.R. Gardener, and A. Tye. 2002. Eradication of potentially invasive plants
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in C.R. Veitch and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Turning the tide: the eradication of invasive species. IUCN, Gland,
Switzerland and Cambridge, UK.

40) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
soil. Weed Science 23:224-228.

41) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Degradation of Glyphosate in the Soil. Weed Science 23:229-234.

42) Tye, A., M.C. Soria, and M.R. Gardener. 2002. A strategy for Galapagos weeds. Pages
336-341 in▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Turning the tide: the eradication of
invasive species. IUCN, Gland, Switzerland and Cambridge, UK.

43) U.S. Department of State Report to Congress. 2002. Chemicals Used for the Aerial
Eradication of Illicit Coca in Colombia and Conditions of Application.

44) U.S. Environmental Protection Agency. 2001. Environmental Effects Database (EEDB).

45) ECOTOX Database System, U.S. Environmental Protection Agency, Office of Pesticide
Programs, Environmental Fate and Effects Division, Washington, DC. Accessed Oct 10,
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46) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Science. 64:489-496.

47) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

America.

48) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Toxicology and Pharmacology 31:117-165.

49) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

372 Annex 9

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Other Materials Considered

1) Joint Mission Verification thporth of Flithts th Colombia by USDS and Colombia
National Government: 10 -13 and 15 -19 Reports

2) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ )

4) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)

5) Relevant videos available at Weed Science Society of America website

(http://wssa.net/Weeds/Tools/Herbicides/Herbicide Movies.htm)

6) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ )

7) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
website (http://www.cdpr.ca.gov)

8) Test Plaintiff Depositions

9) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

a. A table with citations to claims of crop damages in certain evidentiary
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
declaration of Marco Campana, deposition testimony excerpts, Accion Ecologica
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

b. the following information for each test plaintiff (if applicable to the test plaintiff
and/or family):

i. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

ii. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

iii. excerpt from the Marco Campana declaration specific to each plaintiff

iv. all deposition testimony excerpts re alleged crop damages

v. other test plaintiff-specific information relating to their alleged crop

damages (e.g., testimonials, photographs and/or video, etc.)

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vi. excerpts of certain non-governmental organization and other third party
reports that mention the test plaintiffs or the areas in which they live with
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

vii. a map showing the approximate location of the test plaintiffs’ farm and

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
family members in their depositions

10) Expert report prepared by Plaintiffs’ expert, Dr. Michael A. Wolfson

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EXHIBIT C
(Table 1)

375Annex 9

376 Annex 10

EXPERT REPORT OF DR K.R. SOLOMON , H.D.ON BEHALF OF THE
DEFENDANTS INARIAS/QUINTEROS . YNCORP, 18 ANUARY 2011

(United States District Court for the District of Columbia,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Cases consolidated for Case Management and Discovery)

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EXHIBIT 13

Case 1:07-cv-01042-RWR -DAR Document 220-13 Filed 08/19/11 Page 2 of 80

EXPERT REPORT OF KEITH R. SOLOMON ON BEHALF OF
THE DEFENDANTS IN ARIAS/QUINTEROS V. DYNCORP

1 Credentials and Disclosures

1.1 ExperC tredentials

My name is Keith R. Solomon. I am an Emeritus Professor in the School of
Environmental Sciences at the University of Guelph, where I have served as a member
of the faculty for over thirty years. I have a BSc degree in Chemistry and Zoology
(Hons) from Rhodes University (1967), MSc degrees in Zoology and Entomology from
Rhodes University (1971) and the University of Illinois (1973) respectively, and a PhD in

Entomology from the University of Illinois (1973). I have more than 40 years of
experience in research and teaching in pesticide science and toxicology and have
contributed to more than 350 scientific publications and reports (more than 240 in the
peer-reviewed literature) in the fields of pesticides, environmental toxicology, and risk
assessment. I am a member of the Society of Environmental Toxicology and

Chemistry, the American Chemistry Society (Agrochemistry), and the American
Association for the Advancement of Science. I am the recipient of the 1993 Society for
Environmental Toxicology and Chemistry-ABC Laboratories award for Environmental
Education, was elected as a Fellow of the Academy of Toxicological Sciences in
December 1999, and am a recipient of the 2002 American Chemical Society

International Award for Research in Agrochemicals. In 2006, I was awarded the SETAC
Europe Environmental Education Award and the Society for Environmental Toxicology
and Chemistry Founders Award. I have served on and provided expertise on pesticides
via advisory panels to the US EPA, the Institute of Life Sciences, the Pest Management
Regulatory Agency in Canada, and various panels in Europe. A book of which I am a

co-author, Pesticides and the Environment, has been translated into Spanish and
Portuguese and is distributed worldwide. In addition, I have been asked for advice,
written reports, and testified at permitting hearings related to the use of glyphosate in
forests and rights of way in Canada.

Prior to 2003, my research into the use and effects of glyphosate herbicides in the
environment resulted in two publications, “Giesy JP, Dobson S, Solomon KR. 2000.
Ecotoxicological Risk Assessment for Roundup® Herbicide. Reviews in Environmental
Contamination and Toxicology 167:35-120” and “Solomon KR, Thompson DG. 2003.
Ecological Risk Assessment for Aquatic Organisms from Over-water Uses of

Glyphosate. Journal of Toxicology and Environmental Health B, 6:211-246.” A
complete listing of my publications over the last 10 years and a more complete
discussion of my expert credentials are set forth in my curriculum vitae, attached hereto
as Exhibit A.

In 2003, I was contacted by the Inter-American Drug Abuse Control Commission
(“CICAD”) section of the Organization of American States (“OAS”) to serve as the lead

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investigator on an independent Scientific Assessment Team (“SAT”) for what became a
series of studies investigating the potential environmental and human health impacts of
the herbicide spray mixture used in the Plan Colombia aerial eradication operations.

These studies, each of which were subsequently submitted to the OAS and published in
the scientific literature, are described and discussed in this expert report (Solomon et al.
2007b, Solomon et al. 2007a, Solomon et al. 2009, Solomon and Marshall 2009, Bernal
et al. 2009b, a, Brain and Solomon 2009, Bolognesi et al. 2009, Marshall et al. 2009,
Sanin et al. 2009). The complete titles of these cited works and of the other materials
cited through the body of this expert report are set out in the References section
immediately following the text of this report. Other materials which I reviewed are set
out in Exhibit B of this report.

1.2 Compensation and Prior Expert Work

I am being compensated for my work in this matter at a rate of $250 per hour. I have
not served as a testifying expert in any other litigation during the past 4 years.

1.3 Sources, Facts and Data Considered in Connection with my
Expert Report
The sources considered in connection with my expert report are the books, chapters,
reports, and papers cited herein and in the References section immediately following

the text of this report. Additional facts and data obtained during my work with the SAT
that I considered in rendering my opinions in this case are summarized in the text of this
report.

2 Summary of My Opinions

I am generally familiar with the allegations made by the Ecuadorian plaintiffs in this
litigation. Based upon the extensive analyses conducted from 2003-2009 by myself and
by CICAD expert teams that I supervised, as well as the broader scientific literature
regarding glyphosate, formulated glyphosate (Roundup®) and Cosmo-Flux®, it is my
opinion that there is no valid scientific basis upon which one could opine that Plan

Colombia aerial eradication operations could have caused the adverse human health
effects, animal deaths, and off-target crop damage that the plaintiffs allege.

3 CICAD’s Formation of an Independent Scientific
Advisory Team Under My Leadership to Investigate the

Alleged Environmental and Health Risks of Plan
Colombia’s Aerial Eradication Operations

In the summer of 2003, I was contacted by CICAD to participate in an independent
analysis of the Plan Colombia spraying operations. This initial telephone call was

followed by a meeting in OAS HQ in Washington DC on August 5, 2003. At this
meeting, I was interviewed by David Beale and other members of CICAD. I was told

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that I had been selected for the interview after an extensive search of the scientific
literature and that several other candidates had been considered for membership, as
well as the chair, of the Scientific Assessment Team (SAT). Following this interview
process, I was offered the position of chair of the SAT, which position I accepted.

My original charge from CICAD was as follows:

1. To serve as leader/coordinator of the SAT.

2. To prepare and submit to CICAD an Operational Plan that would guide the work of the
SAT. The operational plan would include a budget and cost estimates, milestones and
timelines, and methodologies required to execute a study of the potential risks of
environmental and health effects from the Plan Colombia spraying operations.

3. To identify, interview and select the individual members of the SAT, based on the needs
identified to properly undertake the risk assessment.

4. In collaboration with the other members of the SAT, to coordinate the formulation and

development of a scientific protocol to guide the Operational Plan for the requested risk
assessment.

5. To gather information and scientific literature available on aerial spraying of glyphosate
(including any glyphosate spray mixture used in the Colombia Program) from all possible
sources.

6. To establish a Permanent Technical Mobile Monitoring Group (PTG) in Colombia
capable of periodic random evaluations and on-site investigations of specific allegations
and controversies relating to the Plan Colombia spraying operations, as directed by the
SAT.

7. To be responsible for publicly presenting and defending the results and conclusions of
the Evaluation after the work has been completed. There were to be no public
comments from the SAT Coordinator or Team unless otherwise approved by CICAD.
Results would be presented to the international press, media and all other organizations

interested in the Evaluation. Presentations would be made in Colombia and the United
States and possibly in Europe.

8. To conduct at least four on-site visits to Colombia to areas that had been the subject of
the Aerial Spray Program.

9. To provide quarterly reports on the progress of the study to CICAD.

10. To provide the Final Report of the risk assessment by October 15 of 2004 to CICAD.
The report was to be prepared in English and Spanish in both hard copy and electronic
format.

Because of the political sensitivity of the allegations that had been made regarding the
Plan Colombia aerial eradication operations and to ensure both the fact and
appearance of independence, CICAD decided that all members of the SAT would have

to be from countries other than the United States and Colombia. The members of the

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team were selected based on CICAD’s initial search of the relevant scientific literature
and my own personal knowledge of specific individuals. The final team consisted of the
following five scientists:

Dr. Keith R Solomon, University of Guelph, Canada – Ecotoxicology and risk
assessment.

Dr. Arturo Anadón, Universidad Complutense de Madrid, Spain – Mammalian
toxicologist.

Dr. Antonio Luiz Cerdeira, EMBRAPA, Brazil – Technology of application of
herbicides and their fate in tropical regions.

Dr. Jon Marshall, Marshall Agroecology Limited, UK – Agroecologist and expert
on the use of pesticides in management of pests.

Dr. Luz-Helena Sanin, University of Toronto, Canada – Epidemiology and expert
on the effects of pesticides in humans.

The SAT operated independently of the US and Colombian governments (and of the

U.S. State Department contractor DynCorp). None of these entities had input or
editorial control of the reports of the SAT, except insofar as various reports published by
the governments of the Colombia and the United States were used as references,
where appropriate. No specific information was provided to the SAT by DynCorp except
in the course of visits to Colombia, when the SAT met with various DynCorp employees
engaged in the operations in Colombia and asked them technical questions about the
mechanics of the aerial eradication program.

4 The Scientific Advisory Team’s Work in Conducting the

2005 Risk Assessment of the Plan Colombia Herbicide
Spraying

The process used by the SAT to address the charge given by CICAD is illustrated in
(Figure 1) and is discussed in more detail below.

4.1 Review of existing scientific studies, government regulatory
assessments, verification reports, and damages claims

regarding the Plan Colombia herbicide spray mix
Glyphosate is one of the most widely-used herbicides in the world, and there were many
existing studies of its potential toxic effects, as well as risk assessments conducted for
the purposes of registration, including, e.g., the US EPA’s Reregistration Eligibility
Decision documents (USEPA 1993 et seq.). Most of these studies and assessments

were conducted in connection with the active ingredient and/or glyphosate formulations
available in the United States. The spray program in Colombia made use of a generic
formulation of glyphosate sold in Colombia. This formulation contains glyphosate (IPA)

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as the active herbicidal ingredient and a surfactant (ethoyxylated tallowamine or POEA)
to aid in penetration into the leaves of target plants. The proportion of the POEA in the
spray mixture is slightly less than the 15% (Edginton et al. 2004) found in commercial

formulations of Agropecuaria (ICA)). In
addition to this generic formulation, an adjuvant, Cosmo-Flux – which is frequently added to a
variety of other pesticides in Colombia as well – is mixed with the glyphosate to improve efficacy.
Cosmo-Flux is an agricultural adjuvant containing non-ionic surfactants (a spray mixture of linear and aryl
polyethoxylates – 17% w/v) and isoparaffins (83% v/v) (Cosmoagro 2004). glyphosate used in the US (discussions with the Instituto Colombiano
Scientific Permanent Technical
Assessment Team Mobile Monitoring
Review publications Group (PTG)
and reports on use of Choose PTG leader
adjuvantse and
Collect information on
Conduct site visit local issues and
questions
and hypothesestions
Design field studies
to collect local data Conduct field
sampling and
Assess data and analysis
incorporate into risk
assessment
Refine risk Conduct field
assessment sampling and
analysis
Incorporate new data
into risk assessment

As an initial step in its Complete risk
assessment, in addition to assessment
Figure 1. The process used by the SAT
reviewing the general
literature regarding
glyphosate and formulated glyphosate, the SAT reviewed the following sources of

information regarding the Plan Colombia herbicide spray mixture used in the aerial
eradication operations in Colombia.

4.1.1Mammalian toxicity studies of the Plan Colombia herbicide spray
mixture conducted for the U.S. and Colombian governments

Two series of mammalian toxicity tests had been conducted on the formulation of
glyphosate and Cosmo-Flux used for eradication of coca in Colombia. One set of
studies was conducted for the United States Department of State under good laboratory

practices (GLP) and using the quality control assurance as appropriate for regulatory
decision making (Springborn 2003b, c, e, f, d, g, a - Springborn studies ). The other set

of studies was conducted for the Colombian government, also in compliance with GLP
and according to US EPA guidelines (Immunopharmos 2002g, e, f, d, h, i, j, a, c, b -
Immunopharmos studies ). Both series of mammalian studies employed generally

accepted methodologies and are of the type relied upon by experts in the field in
assessing the toxicity of a test substance. The mammalian studies assessed acute oral
toxicity, acute inhalation toxicity, acute dermal toxicity, skin irritation, eye irritation, and

skin sensitization. Based on the review of the results of these studies, the SAT reached
the following conclusions:

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The acute oral and dermal LD50 value of the Plan Colombia herbicide spray
mixture was estimated to be greater than 5,000 mg/kg body weight in rats. In

other words, it was not possible to observe toxicity, even at the greatest dose
tested. The greatest dose tested (5,000 mg/kg) is equivalent to more than
350,000 mg in a 70 kg adult (3/4 of a pound in a 150 lb adult human).
Therefore, the Plan Colombia herbicide spray mixture was found to be

practically non-toxic by the oral and dermal route.

The acute inhalation LC50 value of the Plan Colombia herbicide spray
mixture was estimated to be greater than 2.60 mg/L in rats. In one study, rats
showed breathing abnormalities after exposures at 2.6 mg/L for 4 hours. In

two other studies, the spray mixture was shown to not be harmful at
exposures up to 20 mg/L for 4 hours. Based upon these LC50 values, which
show that the spray mixture is less toxic than common bathroom cleaners and
air fresheners (S C Johnson 2008, 2009a, b, c), the acute toxicity of the Plan
Colombia herbicide spray mixture is classified as “non-hazardous”.

The Plan Colombia herbicide spray mixture was found to be a slight and
moderate irritant to the skin and eyes of rabbits, respectively, with a
calculated Primary Irritation Index for the spray mixture of 0.25. The eye

irritation finding is similar to the irritation caused when shampoo gets into a
person’s eyes.

These studies demonstrated that the hazards to humans and other mammalian life via
application or bystander exposures to the Plan Colombia herbicide spray mixture were

limited to slight to moderate skin and eye irritation from direct exposures, which could
be resolved if the affected areas were rinsed with water shortly after exposure.
Moreover, by comparing the study results to similar studies from the literature and for
registration purposes conducted solely on formulated glyphosate (Roundup) (referenced

in Solomon et al. 2005), it was shown that the addition of the adjuvant Cosmo-Flux to
the glyphosate formulation used Colombia did not change its toxicological properties to
mammals.

4.1.2United States and other government regulatory analyses and
findings for glyphosate and for the Plan Colombia herbicide spray

mix
Extensive testing is required for pesticides to be registered for use in the United States
and most other countries (Stephenson and Solomon 2007). This testing comprises

detailed information on the product chemistry, toxicology to mammals, metabolism,
environmental chemistry, and toxic effects on aquatic and terrestrial animals and plants.
These tests must be carried out under Good Laboratory Practice (GLP) guidelines with
Quality Assurance (QA) and the full and complete reports must be submitted to
regulators for a detailed and critical review. In the United States, the Environmental

Protection Agency (“USEPA”) issues a Registration Eligibility Decision (RED) for
approved pesticides, which is updated at regular intervals or when changes in use of
the product are proposed.

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The USEPA has repeatedly approved glyphosate for use in the United States and has
concluded that glyphosate has low toxicity to humans and animals.(USEPA 1993, 1997,
1998b, 1999, 2000). Similar conclusions have been reached in other jurisdictions (NRA

1996, World Health Organization 1994).

The United States Department of State (“DOS”) has consulted with USEPA on the
safety of the specific herbicide spray mixture used in the Plan Colombia aerial
eradication operations. USEPA concluded that the application rate being used in the

aerial eradication operations was within the manufacturer’s label, that the spray mixture
was unlikely to cause adverse effects to humans or to terrestrial or aquatic animals, and

that there was no evidence of significant human health or environmental risks from the
spraying (USEPA 2004). The United States Department of Agriculture (“USDA”)

likewise has advised DOS that “it is USDA’s determination that the risks involved in
using glyphosate with commercially available adjuvants for narcotics eradication are
minimal” and that “no unreasonable risk to non-target plant or animal species have been

detected” from the aerial spraying in Colombia (USDA 2002).

4.1.3Plan Colombia aerial eradication verification missions conducted by

the U.S. and Colombian governments and findings of minimal off-
target impacts

Each year, on-site verification missions are conducted by a team of scientists and
specialists from the U.S. and Colombian governments to review the efficacy of the Plan

Colombia aerial eradication spray operations. Because not all spray sites can be
visited, a statistically derived sub-sample is selected from across the country and these

sites are visited from the air and sometimes on the ground. Photographs and visual
observations are used to assess the efficacy of the spraying operations in eradicating

coca and to look for evidence of off-target damage that would be indicative of drift or
other off-target deposition of
herbicide. The resulting 140000
120000 Total ha sprayed
data are summarized in Estimated range of off-target drift
reports that are provided to 100000
80000
the relevant governmental 60000
agencies in the United Ha sprayed
States and Colombia (see 20000

e.g., Helling 2003). 1000

800
Based upon the findings in 600
these verifications missions,
400
the SAT estimated that off- Ha off-target
target impacts from Plan 200
Colombia spraying were 0
1994 1996 1998 2000 2002 2004
minimal, constituting less
than one-half of one percent Year
Figure 2. Areas of coca sprayed and areas affected by off-target
of the total area sprayed
(see Figure 2). Moreover, deposition

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from the SAT’s direct observations as guests on verification missions, the SAT

concluded that damage caused by off-target deposition of the spray was generally
limited to small areas of vegetation at the start and at the end of the spray swath, within
meters of the targeted coca fields. This type of off-target deposition is indicative of too
early initiation of the spray or continuation of the spraying for too long a time rather than
drift of the herbicide spray.

4.1.4Allegations that Plan Colombia aerial eradication operations had
caused property damage and personal injuries
The SAT also reviewed allegations that had been made by individuals in Colombia

claiming damage as a result of the spraying operations. Pursuant to Colombian law, the
Colombian government has set up a claims process whereby individuals can seek
compensation for alleged damages to crops, animals, and humans from spraying
operations.

With respect to crop damage, the SAT was informed that when a complaint is lodged,
the spray data (date, time and location as recorded by the GPS systems on board the
spray planes) are reviewed, and if the date and location of the alleged damage were
consistent with the spray data (<100 m difference) and if an on-site team then confirmed
the damages to lawful crops, compensation was provided. Because the Plan Colombia

herbicide spray mixture would be expected to cause damage to lawful crops that might
be accidently sprayed, the SAT did not analyze these data.

The SAT did seek to analyze data submitted with respect to claims of alleged adverse
effects in humans (and animals) arising from the spraying operations, both as submitted
to the Colombian government and as reported in news-media or on websites of various

interest groups. In reviewing these claims, however, the SAT found that the reports of
these events were all anecdotal, that there was no documentation or measures of
exposure to spraying operations, and that, with the possible exception of minor short-
term skin- or eye-irritation, the allegations were inconsistent with the scientific research
and the documented toxicological profiles of glyphosate and the Plan Colombia

herbicide spray mix. Because it was not possible for the SAT to verify the accuracy of
these reports or to analyze them in a scientific manner, the SAT concluded that the
reports did not provide any scientific data that could be used in its assessment.

4.2 Visits to Colombia to understand the aerial eradication
program

From the beginning of the process, it was recognized that the SAT would need to visit
Colombia to observe firsthand how the coca fields were identified, how the herbicide
was applied, and the locations and habitats where the spraying occurred. The first site
visit took place in February 2004 with several members of the SAT. Spray operations in

the Popayan region, in southwestern Colombia, were observed in detail during this visit.
During this and subsequent visits (Jun. 2004, Aug. 2004, Feb. 2005, Jun. 2005, Jul.
2005, Jun. 2006, Oct. 2006, Dec. 2006, Feb. 2007, May 2007, Jul. 2007, Oct. 2007),
members of the SAT were given complete freedom to observe all operations related to
the spray program and were allowed to photograph all operations except those related

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to the gathering of intelligence about guerilla groups. We were allowed to travel with the

spray operators and with the team that evaluated efficacy and off-target effects, but for
safety reasons, we were accompanied by the Colombia National Police and their elite
unit, the “Junglas,” where appropriate. During these visits, we personally collected
samples of the glyphosate formulation as well as the adjuvant, Cosmo-Flux, for the
purposes of testing. These visits also provided us with the opportunity to meet with and

interview potential leaders of the PTG, as well as to visit several Government agencies
in Colombia where additional data for the assessment could be obtained.

4.3 Additional scientific studies of the Plan Colombia herbicide
spray mixture conducted by the CICAD Scientific Advisory

Team
To expand upon the existing scientific research regarding the Plan Colombia herbicide
spray mix, the SAT decided to conduct a number of additional studies, including wildlife
ecotoxicity tests to assess the potential ecological impacts of the spray mix, a Time-To-

Pregnancy (“TTP”) study to address potential questions regarding any impact of the
spray mixture on human reproductive health, and a series of surface water tests to
evaluate the persistence of the spray mixture in the environment. In all of these studies,
the SAT and the PTG were allowed free access to all relevant information and data
sources and conducted their work without hindrance or interference. Each of these

studies is discussed below.

4.3.1Wildlife ecotoxicity studies in aquatic algae, fish, aquatic
invertebrates, and honey bees
To complement the mammalian toxicity studies discussed in Section 4.1.1 above, the

SAT conducted a standard panel of ecotoxicity tests of the Plan Colombia herbicide
spray mixture using samples of the formulated glyphosate and Cosmo-Flux, collected
by the SAT on one of its site visits. These tests were conducted under good laboratory
practice (GLP) using standard procedures by a consulting company in Guelph, Ontario
(Stantec). The tests employed generally accepted methodologies and are of the type

relied upon by experts in the field in assessing the toxicity of a test substance.

The tests on multiple aquatic organisms (Stantec 2005d, e, c, a, b) demonstrated that
the toxicity of the Plan Colombia herbicide spray mixture was similar to that of other
formulated glyphosate products tested in the same species (Table 1). From these

studies, the SAT concluded that the addition of Cosmo-Flux did not enhance
aquatoxicity of the spray mixture and that the spray mixture did not pose a significant
risk to fish or other aquatic wildlife. This finding is consistent with other observations
that Cosmo-Flux is of low toxicity to fish with an acute LC50 of 4,418,000 μg/L (Rondon-
Barragan et al. 2007).

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Table 1. Toxicity values obtained from toxicity tests conducted on a spray
mixture of glyphosate and Cosmo-Flux
Test species Common name 96 h LC/EC50 in Reference
μg/L (as glyphosate

a.ea)
Selenastrum Algae, based on cell 2,278-5,727 (Stantec 2005e)
numbers, area under
the growth curve and
growth rate.
Daphnia magna Water flea, mortality. 4,240 (3,230-5,720) (Stantec 2005b)
Onchorynchus mykiss b
Rainbow trout, 1,847 (1,407-2,425) (Stantec 2005c)
mortality. b
Pimephales promelas Fathead minnow, 4,600 (1,805-11,700) (Stantec 2005a)
mortality.
aGreatest and smallest effect measures in the studyLC/EC50 and 95% Confidence Interval

A toxicity test was also conducted with honeybees (as surrogates for beneficial insects)
using the spray mixture of glyphosate and the surfactant Cosmo-Flux® 411F (Stantec

2005d). The results of this study showed that the spray mixture was not toxic via acute
contact exposure to honey bees (i.e., did not cause mortality or stress effects in bees
within 48-hours of treatment) at concentrations equal to or less than 63.9 μg a.e./bee.

These results are similar to those for glyphosate and formulations from the US EPA
ECOTOX data base (USEPA 2001) and show that the Plan Colombia herbicide spray
mixture is not hazardous to bees or, by extrapolation, to other beneficial insects.

4.3.2Time to Pregnancy study

The SAT decided to conduct an investigatory Time to Pregnancy (TTP) study because,
at the time the SAT was formulating its study objectives (2004-2005), there were studies
in the literature suggesting an association

between pesticide use on farms and
reproductive outcomes. The TTP study
was conducted to explore possible effects

on reproductive health from exposure to
the Plan Colombia herbicide spray

mixture by assessing any delays in
fecundity among women living in different
areas of the country with different

pesticide use patterns. The design was
analogous to a retrospective cohort study
of populations from different regions and

with different exposures to the Plan
Colombia spray mix. The study popu-

lation consisted of 600 women of
reproductive age in each of five different
regions (Figure 3): two regions where

Plan Colombia spraying took place
(Nariño and Putumayo), two regions Figure 3. Locations for the sampling for the TTP
where there was no Plan Colombia study

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spraying but where there were other uses of glyphosate (Boyacá and Valle del Cauca)
and one region in which no pesticides were used at all (Sierra Nevada). Possible
confounders or independent predictors of the reproductive variables were also

considered.

The TTP study failed to find any association between TTP and Plan Colombia aerial
eradication operations. In particular, the TTPs in the two regions in which Plan
Colombia spraying occurred (Nariño and Putumayo) were shorter than the TTP in Sierra
Nevada, where there was no spraying and no use of pesticides. The longest TTP was

found in Valle de Cauca, where much lower levels of glyphosate are sprayed on sugar
cane to accelerate maturation of the crop (Sanin et al. 2009).

4.3.3 Water sampling studies
In parallel to the TTP study, the SAT collected samples from surface waters and

adjacent sediment at each of the five study locations to test for the presence of
glyphosate and AMPA (a glyphosate metabolite). Water samples were taken at weekly
intervals for a period or 24 weeks, frozen and held at -17°C until shipped to Canada for
analysis using a glyphosate Method Detection Limit (MDL) of 25 μg/L (Thompson et al.
2004). Sediment samples were also taken (at monthly intervals) for analysis of potential
transport of glyphosate and/or AMPA from treated areas to surface water.

In all locations and on most occasions, residues of glyphosate and AMPA were not
detected (present at concentrations above the detection limit of 25 μg/L). There was no
detection of glyphosate above the MDL in either Putumayo or Nariño, the two tested
locations in Colombia where Plan Colombia aerial eradication operations were taking

place. On one occasion each in Valle del Cauca and Boyacá, minor glyphosate
concentrations of 30.1 and 25.5 μg/L, respectively, were found. No Plan Colombia
spraying for coca control was carried out in these locations, and the only use of
glyphosate was in agriculture. These data suggested that, at the watershed level, little
or no contamination of surface waters with glyphosate at significant concentrations has
resulted from the use of glyphosate in either agricultural or eradication spraying in

Colombia. Because no meaningful detections were identified in surface water samples
– and accordingly there was no occasion to analyze potential transport of glyphosate
from sediment to surface water – the sediment samples taken from areas adjacent to
the surface waters were not analyzed.

5 Conclusions Reached in the CICAD 2005 Risk

Assessment of the Plan Colombia Herbicide Spray mix
After completing its investigation of the Plan Colombia herbicide spray mixture and the
aerial eradication operations in Colombia, the SAT conducted a risk assessment to

determine whether the spraying operations posed a risk to human health or the
environment. The SAT’s risk assessment methodology and findings are set forth below.

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5.1 Basic principles of risk assessment

All toxicological risk assessment methods are similar (National Academy of Sciences
2008, USEPA 1992, 1998a), although they may vary somewhat based upon the
purpose of the analysis. A key variable is whether the assessment is being used for
prospective regulatory purposes or for a concurrent or retrospective analysis of specific

exposure situations. In the former case, the risk assessment is geared at setting a
regulatory exposure level that provides a margin of protection against all potential
hazards, while in the latter case, the risk assessor will be seeking to determine whether
measured or estimated exposures to a potentially hazardous substance are causing
unacceptable risks.

Risk assessments are normally conducted in a series of steps or tiers. As one
progresses through the tiers, the estimates of exposure and toxicity become more
realistic as uncertainty is reduced through the use of more or better quality data. Tiers
are normally designed such that the lower tiers in the risk assessment are more
conservative (i.e., provide greater margins of safety), while the higher tiers are more

realistic, with assumptions more closely approaching reality.

5.1.1Assessment of risk
In a lower tier risk assessment, the values for exposure and toxicity are compared by

simple division using a quotient, called a hazard quotient (HQ). The result is a ratio of
toxicity to exposure (margin of exposure) or of exposure to toxicity (level of concern), as
defined below:

Margin of Exposure (MOE) = Toxicity value/exposure value

Level of Concern (LOC) = Exposure value/toxicity value

If the MOE is greater than 1.0, i.e., the exposure value is less than the toxicity value,
then the conclusion is that the exposure would not give rise to any hazard to health. If
the margin of exposure is less than 1.0, i.e., the exposure value is greater than the

toxicity value, then the potential for hazard cannot be rebutted. It is important to note,
however, that because of the conservative assumptions used in setting toxicity and
exposure values for a lower tier risk assessment, an MOE less than 1.0 does not mean
that the exposure poses an actual hazard to health. Rather, this finding may trigger
higher tier risk assessments that include more realistic analyses of the probability of

exposure and the probability of toxicity to characterize the likelihood (risk) that harm will
occur (ECOFRAM 1999a, b, EUFRAM 2006, Solomon 2010). (For LOC, the variables
are reversed, so a value less than 1.0 indicates safety and a value greater than 1.0
requires further study or refinement of data).

5.1.2Toxicity values used in risk assessment

In human health risk assessment, the no-observed-adverse-effect level (NOEL) for the
most sensitive response (e.g., loss of weight, increased liver weight, etc.) in the most
sensitive mammalian test species is used as a point of departure (POD) for setting a

toxicity value, that is, the highest level of exposure at which there is no observation of

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the adverse response (e.g., loss of weight) in the most sensitive animal tested. For
risks from daily exposures over a lifetime, the POD is normally derived from the NOEL
from long-term studies in animals and an uncertainty factor of 100 is used to calculate

an acceptable daily intake (ADI) or reference dose (RfD). In other words, the ADI or
RfD is set at 100 times less than the NOEL. For short term exposures, such as in
applicators or people exposed infrequently during spraying, the POD may be derived
from acute toxicity studies with uncertainty factors smaller than 100.

In ecological risk assessment, a similar approach is used. In the case of glyphosate,
acute data are normally used because glyphosate and its surfactants are not persistent
in the environment and acute exposure is thus the most appropriate comparison to the
infrequent exposures that would occur with the use of glyphosate and its formulations in
the control of plants. As in human health risk assessment, the most sensitive response

in the most sensitive plant organism may be used as the POD. However, if more data
are available, distributional analysis may also be used to characterize an exposure that
is protective of a proportion, such as 95%, of plant species (CCME 2007).

5.2 Toxicity values for Plan Colombia herbicide spray mixture
In the 2005 CICAD risk assessment, both the NOEL and the RfD were used to assess

the health risks to humans of exposures to the Plan Colombia herbicide spray mix.
Based upon the findings in the mammalian studies of the Plan Colombia herbicide
discussed in section 4.1.1 above that the Plan Colombia spray mixture had the same
toxicity as formulations of glyphosate from the U.S, the SAT concluded that it was
appropriate to use the USEPA’s NOEL and RfD for glyphosate for purposes of the

assessment. The USEPA NOEL for glyphosate is 175 mg/kg/day based on maternal
toxicity in an assay of developmental toxicity in rabbits (Williams et al. 2000). The
USEPA RfD for glyphosate is 2 mg/kg/day (USEPA 1993), the same value used by the
World Health Organization (World Health Organization 1994).

Assessment of the environmental risks to aquatic organisms was based on toxicity data
from the literature and from studies conducted on the Plan Colombia herbicide spray
mixture (Solomon et al. 2005, Solomon et al. 2007b).

5.3 Calculation of potential exposure scenarios from the Plan
Colombia aerial eradication operations

5.3.1Estimates of potential human exposures
In calculating potential human exposures to herbicides and pesticides in the agricultural
setting, the standard methodology is to separate the analysis into two groups –

applicators and bystanders. The group that experiences the greatest probability of
exposure is the applicator group, which, in the case of the Plan Colombia aerial
eradication operations, includes the mixer-loaders, the spray-plane pilots, and
mechanics who work on and service the aircraft. The second group is made up of
bystanders who could potentially come into contact with the sprayed herbicide (1) via

direct deposition if they are within the spray swath, are directly exposed to spray drift, or

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are exposed to deposits of spray when they reenter treated fields, or (2) indirectly

through the consumption of food items that have been sprayed or drinking water that
has been impacted. The SAT’s charge focused on assessing risks to the bystander
group.

Bystanders were classified by the SAT into several classes, depending on their route of
exposure. Although the SAT understood that it would be unlikely for people to be
present in a coca field during a spraying operation, for purposes of the risk assessment,

the SAT estimated potential exposure to a person who was standing directly in the
spray swath and received a direct application of the spray solution to the body. The
most likely scenario was judged to be a partially clothed human with a cross-sectional

area of 0.25 m² exposed to the spray. Given that glyphosate penetrates poorly through
the skin with maximum penetration of about 2% (Williams et al. 2000), the body dose
under a reasonable worst-case exposure was estimated to be 0.04 mg/kg body weight. 1

This exposure estimate is greater than that which could occur from exposure to spray
drift, which would involve deposition rates lower than that directly within the spray
swath. Because the salt forms commonly used in glyphosate formulations have very

low vapor pressure, potential additional exposure to glyphosate via vapor is negligible.
(Giesy et al. 2000)

For other bystanders such as children exposed via reentry into a field or bystanders
exposed via, water, diet, and wild foods, exposure values from the literature
(summarized in Williams et al. 2000) were used to estimate exposures by multiplying

the literature values by the ratio of the application rate used in coca and that used in
agricultural settings assessed by Williams et al. (2000). This ratio was 4.982/1 = 4.982
and provided the acute values shown in Table 2. Acute values are most appropriate for

assessment of infrequent exposures to glyphosate such as would occur in the spray
program.

Table 2. Estimates of exposure of bystanders to glyphosate (IPA) during the
spraying of coca in Colombia
Scenario Exposure in mg/kg body weight
Adult Child

Maximum re-entry exposure estimated for an adult human 0.013 0.259
with a 10 hour day.
Drinking water 0.000179 0.00055
0.259 Diet 0.119
Wild foods 0.224 0.224

Total from diet and water 0.343 0.483

1
The figures reported herein are based upon the application rate for the Plan Colombia herbicide spray
mixture as used to eradicate coca. Note that exposures for humans are presented as glyphosate
isopropylamine salt (IPA), the active ingredient used in toxicity testing in mammals.

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5.3.2Estimates of potential terrestrial animal exposures
Animals present during the spray may be exposed on skin, hair, fur, or feathers.

Exposures via this route were not estimated as the presence of hair, fur or feathers, or
an impervious cuticle (insects) would reduce penetration into the body to levels far
below the estimated levels for humans in the bystander scenario above.

5.3.3Estimates of potential exposures in surface water
If over-sprayed during application, surface waters could contain measurable

concentrations of glyphosate for at least some period of time. Although the SAT did not
detect glyphosate in surface waters located close to the sprayed coca fields in its own
studies and was not aware of any other findings of detections following such spraying

operations, the SAT calculated worst-case concentration levels, as set forth in Table 3
below, based on water depth assumptions used by the US EPA (Urban and Cook 1986)
and the EU (Riley et al. 1991).

Table 3. Estimates of concentrations of glyphosate in surface water after a spaay
application for control of coca sprayed at 4.982 kg/ha (3.69 kg a.e./ha) and
assuming rapid mixing, no absorption to sediments, and no flow.
Scenario Concentration in μg
a.e. /L

Surface water, 2 m deep 185
Surface water, 0.3 m deep 1,229
Surface water, 0.15 m 2,473

aurface water, 0.15 m deep with 50% absorption to sediments 1,237
Note that the concentration is expressed as glyphosate acid to allow comparison to exposures used in environmental toxicity
testing. In both these exposures and in the toxicity testing Cosmo-Flux, proportional amounts are present and the exposure and
toxicity values are thus directly comparable and can be used to assess the hazard of the spray mixture as applied in Colombia.

5.4 Findings of the Risk Assessment

The 2005 risk assessment used Margins of Exposure for both the NOELs and the RfD
as a means of characterizing risk. Because potential bystander exposures to Plan
Colombia herbicide spray mixture would be acute rather than continuing over one’s
lifetime, the NOEL is the more appropriate measure for assessing potential human

health risk from the spraying operations and is itself conservative because the NOEL
was determined based upon a maternal toxicity rather than acute toxicity study. As set
forth below in Table 4, even combining the worst-case scenarios for all sources of

exposure in a single individual, the MOE based on the NOEL was significantly greater
than 1.0, demonstrating that bystander exposure to Plan Colombia herbicide spray
mixture did not present a risk to human health. Notably, even as compared to the RfD,
the worst case exposure scenario MOE exceeded 1.0. In other words, even if one were

to assume that a bystander experienced a worst-case aggregate exposure to Plan
Colombia herbicide spray mixture every day over their entire lifetime, that individual
would not be exposed to any significant health risk. Because the MOEs were all in

excess of 1.0, there was no need to move to higher tier risk assessments.

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Table 4 Summary of reasonable worst-case estimated exposures of humans to
the Plan Colombia herbicide spray mixture resulting from its use in the

eradication of coca in Colombia and margins of exposure
Source of exposure Exposure value in Margin of exposure

mg/kg compared to the most
sensitive NOELa(175
mg/kg)
Direct overspray 0.04 4,918

Re676try 0.26
In28l2ti6n 0.01

Diet and water 0.75 234
Worst case total exposure from all 1.05 167
sources

Source of exposure Exposure value in Margin of exposure for
mg/kg the US EPA RfD (2
mg/kg/day) a
Direct overspray 0.04 56

Reen7t.y7 0.26
Inhal3ti3n 0.01

Diet and water 0.75 2.7
Worst case total exposure from all 1.05 1.9
sources

a Based on NOEL and RfD from USEPA Registration Eligibility Decision (USEPA 1993).

For the environment, risks from the use of the Plan Colombia herbicide spray mixture to
terrestrial mammals and birds were likewise judged to be negligible. From the worst-

case estimated exposure values for surface waters (Figure 4), it was concluded that
moderate risks might exist for certain aquatic organisms in shallow surface waters (i.e.,
less than 30 cm = 1 foot deep) that are directly over-sprayed during the eradication

program. Aquatic stages of amphibians were the organisms at greatest risk.

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99 Estimated concentration in
surface water (cm deep)
MDL surface
water 200 30 15

90
Fathead
minnow

70 Water flea

Green alga
50

Percent rank
Rainbow Formulated LC50s amphibians
trout Formulated LC50s arthropods
Formulated LC50s fish
10
Glyphosate technical LC50s

Glyphosate plus Cosmo-Flux -animals
Glyphosate plus Cosmo-Flux -algae
1

10 1 102 10 3 104 105 106 107 108

Concentration (μg/LglyphosateAE)

Figure 4. Cumulative frequency distribution of toxicity values for glyphosate
technical, formulated glyphosate (Roundup) in all aquatic organisms and in fish

and the toxicity values in four aquatic species for glyphosate and Cosmo-Flux
spray mixture as used in Colombia.

5.5 Presentation of 2005 risk assessment findings

On behalf of the SAT, I presented the results of the risk assessment to officials from the
Government of Colombia in Bogota on April 15, 2005, to CICAD/OAS and to

representatives of the United States Congress in Washington, D.C. on April 19, 2005, to

the public in Bogota on April 22, 2005, and to the OAS Assembly on April 26, 2005 in
Santo Domingo. The Santo Domingo presentation was made to representatives from

all OAS member-countries (including Ecuador) and included an opportunity for
question-and-answer. I also presented the results of the risk assessment at scientific

meetings and at universities, such as the Pan-Pacific Meeting in Hawaii on December

16, 2005; Queen’s University on April 5, 2006; Baylor University on April 27, 2006; the
Ontario Pesticides Advisory Committee on November 19, 2006; and the University of

Costa Rica on December 15, 2006.

5.6 Publication of the 2005 risk assessment

As had been agreed with CICAD/OAS, the risk assessment report (Solomon et al. 2005)

was formatted for publication in the scientific literature. The report was submitted to
Reviews of Environmental Contamination and Toxicology and accepted for publication

in Volume 190 of the journal (Solomon et al. 2007b). The objective of publishing the

report was to make it more available to the scientific community.

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6 The Scientific Advisory Team’s Additional Investigation

of Plan Colombia Aerial Eradication Operations
Following the 2005 Risk Assessment

The 2005 risk assessment (Solomon et al. 2005) demonstrated that the Plan Colombia
herbicide spray mixture did not pose a significant health risk to humans or land-based
animals. However, as noted above, the assessment concluded that the herbicide spray
mixture might pose moderate risks to amphibians. The SAT accordingly suggested to
CICAD that additional studies be conducted to supplement the analysis of potential
toxicity to amphibians (Solomon et al. 2005). In addition, the SAT recommended a

human genotoxicity study to investigate data presented at meetings and later published
in the literature (Paz-y-Miño et al. 2007) which suggested that exposure to drift from
Plan Colombia spraying operations caused genotoxicity in humans via the formation of
micronuclei in white blood cells. The SAT also recommended that a study be
conducted to determine the potential extent of drift of the spray during aerial eradication
operations.

Because of the narrower scope of the additional studies, the research was carried out
under the direction of a smaller Scientific Advisory Team (SAT 2). Members of the new
SAT were Gabriel Carrasquilla, MD, Ph.D.; John Marshall, Ph.D.; and Keith Solomon,
Ph.D. As had the SAT with the 2005 risk assessment, the SAT 2 operated
independently of the U.S. and Colombian governments, and of the contractor for the

State Department, DynCorp. As before, none of these entities had input or editorial
control of the reports of the SAT 2. However, the Colombian anti-narcotic Police and
the Colombian Department of Health did provide logistical support for aspects of the
additional studies that were carried out in Colombia. The findings from these additional
studies are discussed below.

6.1 Toxicity of the spray mixture to amphibians
As there were no data on the susceptibility of amphibians to the spray mixture of

glyphosate and Cosmo-Flux used in the Plan Colombia eradication operations, an initial
laboratory study was conducted with larvae of the African clawed frog, Xenopus laevis
(Wildlife International 2006b, a). This study showed that the Plan Colombia herbicide
spray mixture was somewhat less toxic than reported values for other formulations of
glyphosate. The LC50 for the spray mixture as used on coca was the equivalent of
1,100 μg glyphosate a.e./L (95% CI; 560-2,300), while the lowest LC50 previously

reported for formulated glyphosate (Vision®) in larvae of the same species of frog was
800 μg a.e./L (Edginton et al. 2004). An important observation from this data is that the
addition of Cosmo-Flux does not increase toxicity above those values reported in other
frogs for studies using both Vision® and Roundup®. This is also consistent with the
observation that Cosmo-Flux is of low toxicity to fish with an LC50 of 4,417 mg
formulation/L (4,417,000 μg/L) (Rondon-Barragan et al. 2007). With these findings in

mind, two studies were conducted with Colombian frogs.

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The first toxicity study on Colombia frogs was laboratory-based and characterized the

toxicity of the Plan Colombia spray mixture to eight species of Colombian frogs (Bernal
et al. 2009a). The study was conducted in glass containers and in the absence of
sediments and particulate matter. LC50 values for the eight species tested (Gosner
stage-25 tadpoles of Scinax ruber, Dendrosophus microcephalus, Hypsiboas crepitans,
Rhinella granulosa, R. marina, R. typhonius, Centrolene prosoblepon, and

Engystomops pustulosus) ranged from 1,200 to 2,780 μg glyphosate a.e./L. The
important observation from these results is that the data show that sensitivity to
Roundup®-type formulations of glyphosate in the Colombian frog species is similar to
that observed in other tropical and temperate species of frogs for which data have been
published in the literature. That tropical frog species were of similar sensitivity to those

from temperate regions is also consistent with observations with other pesticides and
other organisms (Maltby et al. 2005) and therefore allows the combination of Colombian
data with those from other regions for the purposes of risk assessment.

The second toxicity study in Colombia was designed to characterize the toxicity of the
Plan Colombia herbicide spray mixture to tadpoles and terrestrial stages of frogs under
field-relevant conditions. These experiments were conducted under realistic conditions
with soil and leaf-litter present in the bottom of the exposure chambers. Experiments
were conducted both in Gosner stage-25 tadpoles and in terrestrial stages of frogs

(juveniles and adults) in 15-cm deep microcosms containing a 3-cm layer of sediment
(Bernal et al. 2009b). The results demonstrated that toxicity of the spray mixture is
reduced in the presence of sediments and particulates in the water column. The
reduction in toxicity was similar to that observed by others (Tsui and Chu 2003, 2004,
Tsui et al. 2005, Tsui and Chu 2008) and as discussed in Solomon and Thompson

(2003) for the formulated product and also for the POEA surfactant, which contributes
the greatest to the toxicity of the formulation (Wang et al. 2005). The LC50 of the Plan
Colombia herbicide spray mixture was between 8.9 and 10.9 kg glyphosate a.e./ha in
the tadpoles experiments and between 4.5 and 22.8 kg a.e./ha in the juvenile/adult frog
experiments (consistent with the observations of Dinehart et al. 2009, Mann and Bidwell

1999) and thus were greater than the application rate of 3.7 kg glyphosate a.e./ha
(2,473 μg/L) used in the Plan Colombia coca eradication operations (see Figure 5
below).

The findings of these studies indicated that, even with direct overspray of Plan
Colombia herbicide spray mix, amphibians (representing the most sensitive aquatic
organisms) in shallow water systems (ca. 15-cm deep) would be at low risk. Given
further reductions in exposure through interception of spray droplets by the vegetative
canopy, the overall conclusions of the studies on Colombian frogs are that, under worst-

case exposure conditions, the spray mixture of glyphosate and Cosmo-Flux used for
control of coca in Colombia is of low or negligible risk to aquatic and juvenile terrestrial
stages of frogs.

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8000
Laboratory LC50
Field LC50

6000

Lab-field

4000 margin of
safety

2000

LC50 (μg glyphosate a.e./L)
0

Species

Figure 5. Comparison of the toxicity of glyphosate and Cosmo-Flux to
tadpoles (Gosner 25) of Colombian frogs under laboratory and field
conditions

6.2 Study of potential spray drift and characterization of risks of
off-target deposition

The potential drift of herbicide spray from Plan Colombia aerial eradication operations
was assessed via a wind tunnel analysis and AGDISP modeling conducted by Dr.

Andrew Hewitt, who is a well-known expert in the field of pesticide drift. I do not have
expertise in this analysis and accordingly do not address Dr. Hewitt’s analysis in this
report. It is my understanding that Dr. Hewitt is separately submitting an expert report in

this litigation.

After Dr. Hewitt calculated the potential drift from Plan Colombia aerial eradication

operations, the SAT 2 compared his findings with scientific data on toxicity values for
the herbicide in humans, animals, and plant life to calculate a safety buffer for the
spraying operations, i.e., a distance from the end of the spray swath in which the level

of potential exposure did not present any risk of damage or injury. As discussed above,
the toxicity values for the Plan Colombia herbicide spray mixture in humans and
terrestrial animals were well above the potential exposure levels even directly under the

spray swath. Accordingly, a safety buffer would be necessary only for amphibians in
shallow waters and for non-target plant life.

Using the findings in the amphibian studies discussed above, Dr. Hewitt’s calculations
of potential drift were compared with the toxicity values of formulated glyphosate to the
most sensitive frog species (Xenopus laevis) under the worst-case exposure scenario

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(overspray of a 15-cm deep pool with no exposure reduction via adsorption to

sediments and organic matter). For the worst-case spray drift from the AT-802 and the
OV-10 spray planes, we calculated that a 5 m buffer from the end of the spray swath
would be sufficient to protect 95% of amphibians.2

Not surprisingly, plants are the most susceptible terrestrial organisms to glyphosate.
Data on the susceptibility of crop plants were obtained from the ECOTOX database
(USEPA 2001). In addition to this, more recent data for wild plants from a presentation

by Olszyk et al. (2009) at a meeting of the Society for Environmental Toxicology and
Chemistry have been added to the data set. A commonly used measure of effect on
plants is the EC25 based on growth, yield, or size (Suter et al. 2007). These data were
characterized by the use of Species Sensitivity Distributions (SSDs) using procedures

outlined in (Solomon 2010) and are presented in Table 5 and Figure 6 below.

Table 5. Regression coefficients and intercepts for the toxicity data distributions
for exposures of terrestrial plants to glyphosate (Roundup®)

Herbicide N r² y = ax + b 5 centile intercepts
a b (g a.e./ha)

Glyphosate (Roundup® crop plants) 21 0.89 2.63 1.91 45
Glyphosate (Roundup® wild plants) 13 0.95 2.32 3.02 10

Crop plants are less 99
sensitive to glyphosate 98
Wild plants
tthn wild plants with a 95 Crop plants
5 centile of 0.045 90
compared to 0.01 kg
a.e./ha. Because of 80
70
an error in the SAT 2’s
calculation of the 50
susceptibility of crop
30
plants to glyphosate, 20
the estimates of Percent rank
glyphosate sensitivity 10
in Hewitt et al. (2009) 5

were overstated and 2
the risks of spray drift 1
to non-target plants 0.0001 0.001 0.01 0.1 1 10

were overestimated. Application rate (kg glyphosate AE/ha)
Using new data and a
corrected calculation, I Figure 6. Distributions of EC25s for glyphosate in terrestrial plants
calculate that a buffer

of ~50 m would be

2
Dr. Hewitt calculated that there would be somewhat less drift from T-65 spray planes. Accordingly, the
necessary buffer for spraying operations using T-65 spray planes would be somewhat shorter.

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protective of 95% of crop plants and a buffer of ~75 m would be protective of 95% of
wild plants. These safety buffers are somewhat shorter than, but generally consistent

with, the buffer of 50 to 120 meters calculated in Hewitt et al. (2009).

The overall findings of safety buffers are set forth below in Figure 7.

3000

2500

2000
5 centile amphibians
1500

1000

Deposition (g/ha) 5 centile crop plants
500 5 centile wild plants

00 20 40 60 80 100

Amphibians Crop plants Wild plants
Distance from edge of spray swath (m) for AT-802

Figure 7. Modeled drift deposition values for glyphosate overlaid with the
5thcentile toxicity values for amphibians, crop- and wild-plants.

6.3 Genotoxicits ytudy
Claims of DNA damage in peripheral lymphocytes from a small group of subjects

potentially exposed to glyphosate from Plan Colombia spraying operations were
reported in (Paz-y-Miño et al. 2007). However, problems with the study design,

including the fact that there were only a small number of subjects (21 control and 24
exposed) and the fact that random selection produced 23 females and one male in the

exposed group, do not allow valid scientific conclusions to be drawn from the study.

To investigate whether the Plan Colombia spraying operations could, in fact, be
associated with genotoxic effects, the SAT 2 carried out a study using the micronucleus-
response in peripheral lymphocytes, an index of chromosomal damage, as a biomarker

of potential genotoxicity (Bolognesi et al. 2009). The study was carried out on
volunteers from five regions of Colombia in which the populations had different potential

levels of exposure to glyphosate and other pesticides. The epidemiological design was
a prospective cohort study but, for logistical reasons, without exposure biomonitoring.

The study population was comprised of 274 persons; 137 women of reproductive age
(15-49 years of age) and their spouses. Participants were interviewed to obtain relevant

details about health status, history, lifestyle, past and current occupational exposure to
pesticides, and factors known to be associated with increased frequency of micronuclei.

In regions where glyphosate was being sprayed (by Plan Colombia aerial eradication
spray planes in Nariño and Putumayo and by commercial spray planes in Valle del

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Cauca), blood samples were taken prior to spraying, 5 days after spraying, and 4
months after spraying, and data regarding exposures were collected. Volunteers were

asked if they entered the field immediately after spraying, if they felt spray drops in their
skin, or if they thought they were exposed because they had contact with the chemical
in the air. Lymphocytes were cultured and analysis of micronuclei performed using

standardized techniques on binucleated lymphocytes with preserved cytoplasm.

As shown in Figure 8,
although there was a
transient increase in Prespray
Five days post spray
the frequency of bi- 16 Four months post spray
nucleated lympho-
cytes with micronuclei

(BNMN) five days 9
after spraying of

glyphosate (diagonal
pink arrows pointing
up), there was no 4

consistent pattern in 1000 binucleated cells
BNMN four months
after the spraying, with 1
Number of cells with micronuclei per
the only significant No spraying 3.7 kg/ha 3.7 kg/ha 1 kg/ha
change being a pesticides of coca Rate of application of glyphosate a.e.
decrease in BNMN in
Santa Boyacà Putumayo Nariño Valle del
Nariňo (diagonal Marta Region Cauca
green arrow pointing Figure 8. Frequency of micronuclei in white blood cells in
relation to potential exposures to glyphosate spray used either
down). Moreover, the for control of coca or for production of sugar cane
largest five-day
increase in BNMN

was in Valle del Cauca, where glyphosate was applied aerially for ripening of sugar
cane at an application rate roughly 27% of the application rate of the aerial eradication
operations in Putumayo and Nariño, a finding which is inconsistent with the hypothesis

that glyphosate spray caused even this transient change. Furthermore, there was no
significant association between self-reported direct contact with eradication sprays and

frequency of BNMN at five days after spraying. The frequency of BNMN in participants
who self-reported that they were exposed to glyphosate was not significantly greater
than in subjects living in the same areas but who were not present during spraying.

Overall, the SAT 2 concluded that any genotoxic risk potentially associated with
exposure of humans to glyphosate in the areas of Colombia where the herbicide is

applied for coca (and poppy) eradication would be small and transient at most and of
low biological relevance.

6.4 Presentations of the results of the Phase-2 studies
The results of this second round of studies were presented to various officials and

government representatives in Bogota on August 10, 2009. Additional presentations

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were made to the scientific community at the SETAC LA meeting in Lima, Peru on
October 7, 2009; the SETAC NA in Tampa, Florida, on November 11, 2009; the XI
ECOTOX meeting in Bombinhas, Brazil, September 19, 2010; and the Argentina
Toxicology Association Meeting in Buenos Aires, on September 24, 2010.

6.5 Publication of the results of the SAT 2 studies

At the suggestion of CICAD/OAS, the results of the work conducted in the second round
of studies were written up for publication in the scientific literature. The results were
published in a series of articles in the Journal of Toxicology and Environmental Health A
72. Seven of the papers (Hewitt et al. 2009, Brain and Solomon 2009, Bernal et al.
2009b, a, Lynch and Arroyo 2009, Bolognesi et al. 2009, Marshall et al. 2009) were
reports of the scientific work conducted by the SAT 2, one paper was the publication of

the Time to Pregnancy (TTP) study conducted during the 2005 risk assessment (Sanin
et al. 2009), one paper was an overview of the relevance of the findings (Solomon et al.
2009), and one paper was a preface explaining all of the papers (Solomon and Marshall
2009). These papers were submitted, and handled in the normal peer-review and
editorial process, and were published in the journal in August of 2009. Spanish
translations made by CICAD/OAS were made available via the website of the journal.

7 The Scientific Advisory Team’s Comparative Hazard

Assessment of the Cultivation of Coca vs. Aerial
Spraying for Control of Coca

During the SAT’s work in 2004-2005, it became apparent that the cultivation and
processing of the illicit crops themselves posed a far greater risk to human health and
the environment than did the Plan Colombia aerial eradication spraying. The risks from
coca cultivation and processing were addressed in two reports prepared for CICAD
(CICAD/OAS 2004, 2005), in a book chapter (Solomon et al. 2007a), and in a paper
focused specifically on amphibians (Brain and Solomon 2009).

7.1 Impacts of coca cultivation and cocaine production on
human health and the environment

The degradation of ecosystems associated with the production of coca and the
processing of coca leaves into cocaine paste and then into cocaine hydrochloride has
been identified as one of Latin America’s most important current environmental issues
(UNODC 2007, Karl et al. 2010, Bradford et al. 2010).

As was pointed by Brain and Solomon (2009) the production of illicit crops in regions of
high biodiversity, such as in Colombia, results in clear-cutting and uncontrolled
destruction of natural forests. The land area used for coca cultivation is significant.
From 2000 to 2004, a total of 413,000 ha of coca were planted in Colombia, a quarter
(97,622 ha) of which was established on land cleared from primary forest. Although the
annual conversion rate has decreased steadily by 60% during this time, 13,202 ha of
primary forest were still converted in 2004 (UNODC 2006). The amount of primary

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forest lost to coca production in Colombia between 1990 and 2004 has been
conservatively estimated at 345,233 ha (UNODC 2006). Given the regional specificity
of coca production, it is estimated that certain areas of intense cultivation, such as in the
Colombian Departments of Nariño and Putumayo (UNODC 2006), may have
experienced deforestation levels that caused extinction of animal species.

The cultivation of coca also gives rise to environmental and health risks because coca
farmers use large quantities of fertilizers and agrochemicals, many of which, unlike
glyphosate, are associated with significant adverse human health and environmental

impacts. Moreover, there is little indication that farmers follow the labelled directions for
use of these products. Formulated products are diluted with local sources of water from
a nearby stream, river, or well. Mixing and loading of the herbicide sprayer usually
takes place close to the water source and empty containers are discarded in the field.
Pesticides are typically applied in coca fields with hand-operated backpack sprayers.

Other than anecdotal information, there are little data on the use of protective
equipment; however, from field observations it appears not to be widely used.
(CICAD/OAS 2005).

The processing of coca leaves after cultivation into cocaine requires the use of a

number of potentially toxic chemicals that also give rise to significant risks of adverse
impacts on human health and the environment. The first step in cocaine production is
converting the coca leaf into coca paste. This is accomplished by adding sodium
carbonate, water, and an organic solvent, such as kerosene, to the leaves, crushing the

leaves, and then extracting the cocaine alkaloids into an aqueous acid solution to which
an alkaline material is then added. The next step is the conversion of coca paste to
cocaine base, which is accomplished by dissolving the paste in an acid solution and
then adding ammonia water to form another precipitate that is separated and dried. The
third step is the conversion of cocaine base to cocaine hydrochloride, which requires the

use of acetone to dissolve the cocaine base and hydrochloric acid to crystallize the
cocaine (CICAD/OAS 2005).

Toxicity data for selected substances used in coca cultivation and processing
(CICAD/OAS 2005) were used to prepare a comparative risk assessment of coca

production for humans and for organisms in the environment. As there were no data or
estimates of exposures to fuel oil, nitric acid, potassium chloride, and potassium
permanganate, these chemicals were omitted from the assessment of the coca
production risk and the assessment focused on pesticides used in coca cultivation. This
comparative assessment of risks from coca cultivation and aerial coca eradication are

set forth below. These results were presented at the PacifiChem Meeting in Honolulu in
December 2005 and published as a Chapter in the ACS Symposium Series No 966
(Solomon et al. 2007a).

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7.2 Comparative analysis of potential risks posed from coca

cultivation and aerial coca eradications

7.2.1 Human health risks

Risks to humans from the cycle of coca production were estimated as discussed above
and in (CICAD/OAS 2004, 2005) and (Solomon et al. 2007a), and are shown in Figure

9. For the purposes of this ranking process, the intensity score ranged from 0 to 5, with
5 being a severe effect such as a physical injury or toxicity. The recovery score also
ranged from 0 to 5 and was based on the potential for complete recovery from the

adverse effect. Frequency was based on an estimate of the proportion (%) of the total
number of persons involved in coca and poppy cultivation, production, and the

refinement of cocaine and heroin. The score for impact was the product of the
individual scores and the percent impact is based on the sum of the impact scores.

IMPACTS ON

HUMANS

IMPACTS INTENSITY RECOVERY FREQUENCY IMPACT % IMPACT
SCORE SCORE % SCORE

Clear cutting
and burning 55 3 34 16.7
Planting the

coca or poppy 0 1 100 0 0.0
Fertilizer inputs 0 0.5 10 0 0.0

Pesticide
inputs 5 3 10 150 55.6

Eradication
spray 0 0 10 0 0.0
Processing

and refining 55 3 57 27.8
Figure 9. Ranking of risks to humans of the cycle of activities associated with

the production and control of coca in Colombia

Note that in Figure 9 (and in Figure 10 below), “Pesticide inputs” refers to the pesticides
applied by the coca farmers which, as noted above, included pesticides that are

significantly more toxic to humans than glyphosate. The potential impact of the Plan
Colombia spraying is set forth on the line titled “Eradication spray.”

7.2.2 Ecological risks

A similar procedure to that described above was used for ranking ecological risks

associated with the cycle of coca production (Figure 10). The intensity score was
ranked from 0 to 5, with 5 being most intense, such as the total destruction of the
habitat by clear-cutting and burning when clearing a natural area for agricultural use.

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Intensity of effects in this case also included off-field effects such as harm to non-target
animals and plants.

Recovery time in this scheme is the estimated time for the impacted area to recover to a
state similar to the initial condition. In the case of the clear cutting and burning, it is

recognized that succession will begin immediately; however, full recovery to a mature
and diverse tropical forest may take considerably more than the 60 years estimated
here. Similarly, in the absence of cultivation (e.g., if fields are abandoned), it was esti-

mated that invasive and competitive species will displace coca and poppy in several
years and an estimate of four years was used in this case. Given the need to apply
fertilizer and pesticides frequently because of utilization of nutrients and resurgence of

pests, the recovery time for these ecological impacts was judged to be small. The
scores were multiplied to give the impact score and the percent impact was based on

the sum of the impact scores, as shown in Figure 10.

IMPACTS ON THE
ENVIRONMENT

IMPACTS INTENSITY RECOVERY IMPACT %
SCORE TIME (Y) SCORE IMPACT
Clear cutting
and burning
5 60 300 96.9
Planting the
coca or poppy 1 4 4 1.3

Fertilizer inputs 1 0.5 0.5 0.2
Pesticide inputs 5 0.5 2.5 0.8

Eradication
spray 1 0.5 0.5 0.2

Processing and
refining 2 1 2 0.6
Figure 10. Ranking of risks to the environment of the cycle of activities

associated with the production and control of coca in Colombia

8 Opinions regarding test plaintiffs’ allegations in light of

CICAD risk assessment and studies

8.1 Scientific basis for claims of effects on human health
Based on registration reviews by a number of regulatory agencies in several countries,

including the US and Canada, reviews of the scientific literature, and the multiple
studies conducted on mammalian and human health outcomes of the spray program for

control of coca in Colombia, there is no scientific basis to support an opinion that the

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▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

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from over-water uses of glyphosate. Journal of Toxicology and Environmental
Health B 6:211-246.
Solomon KR, Anadón A, Cerdeira A, Marshall J, Sanin L-H. 2005. Environmental and
Human Health Assessment of the Aerial Spray Program for Coca and Poppy

Control in Colombia. Washington, DC, USA: Inter-American Drug Abuse Control
Commission (CICAD) section of the Organization of American States (OAS).
Report 121 p http://www.cicad.oas.org/en/glifosateFinalReport.pdf.
Solomon KR, Anadón A, Brain RA, Cerdeira AL, Crossan AN, Marshall AJ, Sanin LH,
Smith L. 2007a. Comparative Hazard Assessment of the Substances used for

Production and Control of Coca and Poppy in Colombia. In: Kennedy IR,
Solomon KR, Gee S, Crossan AN, Wang S, Sanchez-Bayo F, editors. Rational
Environmental Management of Agrochemicals: Risk Assessment, Monitoring,
and Remedial Action ACS Symposium Series No 966. Vol. 966. Washington,
DC, USA: American Chemical Society. p 87-99.

Solomon KR, Anadón A, Carrasquilla G, Cerdeira A, Marshall J, Sanin L-H. 2007b.
Coca and poppy eradication in Colombia: Environmental and human health
assessment of aerially applied glyphosate. Reviews of Environmental
Contamination and Toxicology 190:43-125.
Solomon KR, Marshall EJP. 2009. Production of illicit drugs, the environment, and

human health. Journal of Toxicology and Environmental Health A 72:913.
Solomon KR, Marshall EJP, Carrasquilla G. 2009. Human health and environmental
risks from the use of glyphosate formulations to control the production of coca in
Colombia: Overview and conclusions. Journal of Toxicology and Environmental
Health A 72:914-920.

Solomon KR. 2010. Ecotoxicological Risk Assessment of Pesticides in the
Environment. In: Krieger RI, Doull J, van Hemmen JJ, Hodgson E, Maibach HI, rd
Ritter L, Ross J, Slikker W, editors. Handbook of Pesticide Toxicology. Vol. 2, 3
ed. Burlington, MA, USA: Elsevier. p 1191-1217.
Springborn. 2003a. A dermal sensitization study in guinea-pigs with Spray-Charlie.

Modified Buheler design. Spencerville, Ohio, USA: Springborn Laboratories.
Report 3596.21. 40 p
Springborn. 2003b. Purity analysis for glyphosate of Spray-Charlie (active ingredient).
Spencerville, Ohio, USA: Springborn Laboratories. Report 3596.18. 52 p
Springborn. 2003c. An acute oral toxicity study in rats with Spray--Charlie.

Spencerville, Ohio, USA: Springborn Laboratories. Report 3596.16. 29 p

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Springborn. 2003d. An primary skin irritant study in rabbits with Spray-Charlie.
Spencerville, Ohio, USA: Springborn Laboratories. Report 3596.20. 23 p
Springborn. 2003e. An acute nose-only inhalation toxicity study in rats with Spray-

Charlie. Spencerville, Ohio, USA: Springborn Laboratories. Report 3596.18. 52 p
Springborn. 2003f. An acute dermal toxicity study in rats with Spray-Charlie.
Spencerville, Ohio, USA: Springborn Laboratories. Report 3596.17. 29 p
Springborn. 2003g. A primary eye irritation study in rabbits with Spray-Charlie3596.19.
Spencerville, Ohio, USA: Springborn Laboratories. Report 3596.19. 24 p
Stantec. 2005a. Mixture of Glyphosate and Cosmo-Flux® 411F: Acute Toxicity to

Fathead Minnow OECD 203. Guelph, ON, Canada: Stantec. Report 186 p
Stantec. 2005b. Mixture of Glyphosate and Cosmo-Flux® 411F: Acute Toxicity to
(Daphnia magna). Guelph, ON, Canada: Stantec. Report 174 p
Stantec. 2005c. Mixture of Glyphosate and Cosmo-Flux® 411F: Acute Toxicity to
Rainbow Trout OECD 203. Guelph, ON, Canada: Stantec. Report 167 p

Stantec. 2005d. Mixture of Glyphosate and Cosmo-Flux® 411F: Acute Contact Toxicity
to Honey Bee (Apis mellifera). Guelph, ON, Canada: Stantec. Amended 2006-
02-09. Report 246 p
Stantec. 2005e. Mixture of Glyphosate and Cosmo-Flux® 411F: Growth Inhibition Test
With the Freshwater Green Algae Selanastrum capricornutum. Guelph, ON,
Canada: Stantec. Report 186 p

Stephenson GR, Solomon KR. 2007. Pesticides and the Environment. Guelph,
Ontario, Canada: Canadian Network of Toxicology Centres Press. 422 p.
Suter GW, II, Barnthouse LW, Bartell SM, Cormier SM, Mackay D, Mackay N, Norton
SB. 2007. Ecological Risk Assessment. Boca Raton, FL: CRC Press/Taylor and
Francis. 634 p.

Thompson DG, Wojtaszek BF, Staznik B, Chartrand DT, Stephenson GR. 2004.
Chemical and biomonitoring to assess potential acute effects of Vision herbicide
on native amphibian larvae in forest wetlands. Environmental Toxicology and
Chemistry 23:843-849.
Tsui MT, Wang WX, Chu LM. 2005. Influence of glyphosate and its formulation

(Roundup®) on the toxicity and bioavailability of metals to Ceriodaphnia dubia.
Environmental Pollution 138:59-68.
Tsui MTK, Chu LM. 2003. Aquatic toxicity of glyphosate-based formulations:
Comparison between different organisms and the effects of environmental
factors. Chemosphere 52:1189-1197.
Tsui MTK, Chu LM. 2004. Comparative toxicity of glyphosate-based herbicides:

Aqueous and sediment porewater exposures. Archives of Environmental
Contamination and Toxicology 46:316-323.
Tsui MTK, Chu LM. 2008. Environmental fate and nontarget impact of glyphosate in a
subtropical wetland. Chemosphere 71:439-446.
UNODC. 2006. Coca Cultivation in the Andean Region. A survey of Bolivia, Colombia

and Peru. Vienna, Austria: United Nations Office on Drugs and Crime. Report
Not available. 17-48 p http://www.unodc.org/pdf/andean/Andean_full_report.pdf.
[UNODC] United Nations Office on Drugs and Crime. 2007. World Drug Report 2007.
UNODC website http://www.unodc.org/, Accessed January 29 2008.

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Urban DJ, Cook NJ. 1986. Standard Evaluation Procedure for Ecological Risk
Assessment. Washington, DC.: Hazard Evaluation Division, Office of Pesticide
Programs, United States Environmental Protection Agency. Report EPA/540/09-
86/167.

USDA. 2002. Response from Secretary of Agriculture Ann Veneman to Secretary of
State Colin Powell. Washington, DC: United States Department of Agriculture.
Report http://www.state.gov/p/inl/rls/rpt/aeicc/13246.htm.
USEPA. 1992. Framework for ecological risk assessment. Washington, DC, USA:
United States Environmental Protection Agency. Report EPA/630/R-92/001. 41

p
USEPA. 1993. Reregistration Eligibility Decision (RED) Glyphosate. Washington, DC,
USA: United States Environmental Protection Agency. Report EPA 738-R-93-
014. 291 p
USEPA. 1997. Glyphosate: Pesticide tolerances for emergency exemptions. Federal

Register 62:42921-42928.
USEPA. 1998a. Guidelines for Ecological Risk Assessment. Washington, DC, USA:
United States Environmental Protection Agency. Risk Assessment Forum.
Report 191 p
USEPA. 1998b. Glyphosate; Pesticide Tolerance, Final Rule. Federal Register
63:54058–54066.

USEPA. 1999. Glyphosate; Pesticide Tolerance. Federal Register 64:18360-18367.
USEPA. 2000. United States Environmental Protection Agency. Glyphosate; Pesticide
Tolerance. Federal Register Volume 65:57957-57966.
[USEPA] United States Environmental Protection Agency, Office of Pesticide Programs,
Environmental Fate and Effects Division, United States EPA, Washington, D.C.

2001. Environmental Effects Database (EEDB). ECOTOX Database System.
USEPA website http://www.epa.gov/ecotox/, Accessed November 2009.
USEPA. 2004. Letter and Consultations Report from EPA Administrator Leavitt.
Washington, DC: United States Environmental Protection Agency. Report
http://www.state.gov/p/inl/rls/rpt/aeicc/57040.htm.
Wang N, Besser JM, Buckler DR, Honegger JL, Ingersoll CG, Johnson BT, Kurtzweil

ML, MacGregor J, McKee MJ. 2005. Influence of sediment on the fate and
toxicity of a polyethoxylated tallowamine surfactant system (MON 0818) in
aquatic microcosms. Chemosphere 59:545-551.
Wildlife International. 2006a. Glyphosate-Cosmo-Flux® - Poppy Mix: A 96-Hour Static-
Renewal Acute Toxicity Test with the African Clawed-Frog Tadpole (Xenopus

laevis). Final Report. Easton, MD, USA: Wildlife International. Report 628A-102.
42 p
Wildlife International. 2006b. Glyphosate-Cosmo-Flux® - Coca Mix: A 96-Hour Static-
Renewal Acute Toxicity Test with the African Clawed-Frog Tadpole (Xenopus
laevis). Final Report. Easton, MD, USA: Wildlife International. Report 628A-101.

42 p
Williams GM, Kroes R, Munro IC. 2000. Safety evaluation and risk assessment of the
herbicide Roundup® and its active ingredient, glyphosate, for humans.
Regulatory Toxicology and Pharmacology 31:117-165.

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World Health Organization. 1994. Glyphosate. Geneva: International Program on
Chemical Safety. Report EHC 159.
http://www.inchem.org/documents/ehc/ehc/ehc159.htm.

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413Annex 10

Case 1:07-cv-0Document Filed Page 79 of 80

Exhibit B
Dr. Keith Solomon Expert Report

Materials Considered

Case 1:07-cv-01042-RWR -DAR Document 220-13 Filed 08/19/11 Page 80 of 80

Exhibit B

Dr. Keith Solomon Expert Report

Other Materials Considered

The materials I considered in preparing my report are set forth in the references section

at the end of my report. In addition, I have reviewed the following materials:

1) PLS00005881 Disk with Victor Mestanza's 2002 Video
2) PLS00005882 Disk with Victor Mestanza's 2009 Video

414 Annex 11

EXPERT REPORT OF DR A. ATALAY, H.D., CPSS,PREPARED FOR THE

D EFENDANTS IA RIA/QUINTEROS V. YNCORP (D.D.C.),
19 JANUARY 2011

415416 Annex 11

Case 1:07-cvDocumenFiledPage 1 of 43

EXHIBIT 1

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 2 of 43

EXPERT REPORT OF A SMARE ATALAY ,PH .D., CPSS
P REPARED FOR THE DEFENDANTS
INA RIAS/QUINTEROS V.DYN CORP (D.D.C.)

Table of Contents

BACKGROUND & CREDENTIALS..........................................................................................1

STATEMENT OF COMPENSATION........................................................................................3

PRIOR TESTIMONY...................................................................................................................3

SUMMARY OF EXPERT OPINIONS........................................................................................3

IT IS WIDELY KNOWN THAT TROPICAL SOILS (SUCH AS THOSE IN
NORTHERN ECUADOR) ARE FRAGILE SOILS, AND WHEN CONVERTED
TO AGRICULTURAL USE, TROPICAL SOILS MUST BE MANAGED

CAREFULLY IF ONE HOPES TO MAINTAIN SOIL FERTILITY AND WITH
IT HEALTHY AND PRODUCTIVE TROPICAL CROPS......................................................4

POOR SOIL CONDITIONS COMBINED WITH POOR CROP MANAGEMENT
TECHNIQUES MOST LIKELY EXPLAIN MANY OF THE PROBLEMS
ALLEGEDLY OBSERVED IN THE TEST PLAINTIFFS’ CROPS.......................................6

The soils in this region are inherently poor tropical soils ..............................................6

The test plaintiffs’ farming practices are inadequate.....................................................7

THERE IS NO VALID SCIENTIFIC BASIS TO CONCLUDE THAT THE PLAN
COLOMBIA SPRAY MIXTURE ADVERSELY IMPACTS TROPICAL SOIL
FERTILITY....................................................................................................................................9

417Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 3 of 43

BACKGROUND & CREDENTIALS

▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯

▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ientist at the Virginia State University

I am certified nationally and internationally as a Certified Professional Soil Scientist

(CPSS) by the American Registry of Certified Professionals in Agronomy, Crops, and Soils
(ARCPACS); Certification No. 03371. I have been a member of both the Soil Science Society of
America and the American Society of Agronomy since 1979.

At Virginia State University, I hold a 75% research and 25% teaching appointment. My

▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯
science, soil fertility and fertilizers, soil genesis and classification (pedology), and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯
and field experiences. The field experiences incl▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯
▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

▯▯▯▯ ▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯
▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯
▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯ith soil genesis and classification of world
▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯

▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯▯▯▯

▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯▯▯ ▯▯rving on the Virginia Pesticide Control Board
▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯
▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ of registered pesticides in the state. I am an

418 Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 4 of 43

▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯
of Conservation and Recreation (“DCR”). I als▯ ▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯s scientific advice to DCR personnel on the
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯

▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯▯lished over 50 symposia articles and presented
▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯
been cited by many scholars in my area of expertise.

▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯ Exhibit A▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯
a trainer/advisor to farmers, research technician▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯

Ethiopia. For the last 6 years I have been trave▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯
Farmer) from United States Assistance for International Development (USAID) to assist farmers
▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯
in Ethiopia has been devoted to training technicians and research scientists on the operation of
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯

▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯
control methods. Interestingly, the soils in this tropical region of Ethiopia are similar to those in
▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯
▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯

▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯
with the inherent low fertility of these soils, often leads to low yield potentials and other crop
management problems. Only with proper testin▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯

▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯ ▯▯▯ ▯▯▯ ▯
▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯itnessed firsthand the challenges that this
tropical environment presented to the farme▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯
▯▯ ▯▯▯▯▯ ▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯

battling inherent soil fertility p▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯
infections and infestations.

▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯
▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯

419Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 5 of 43

STATEMENT OF COMPENSATION

▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯
deposition and trial testimony.

PRIOR TESTIMONY

▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯

SUMMARY OF EXPERT OPINIONS

▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯
this litigation, many of which are ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯port. A comprehensive list of
materials considered is attached to this report as Exhibit B.

▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯

▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯

▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯
hopes to maintain soil fertility and with it c▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
crops.

▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯

plaintiffs, poor soil conditions combined ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯y observed in the test plaintiffs’ crops.

3. There is no valid scientific basis to conc▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯
adversely impacts tropical soil fertility.

420 Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 6 of 43

IT IS WIDELY KNOWN THAT TROPICAL SOILS (SUCH AS THOSE IN NORTHERN
ECUADOR) ARE FRAGILE SOILS, AND WHEN CONVERTED TO AGRICULTURAL
USE, TROPICAL SOILS MUST BE MANAGED CAREFULLY IF ONE HOPES TO

MAINTAIN SOIL FERTILITY AND WITH IT HEALTHY AND PRODUCTIVE
TROPICAL CROPS.

(Jordan 1985). Tropical soils tend to be older than other soils, and therefore they have been
▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯

▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯
1985).

▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯
Amazonian soils tend to be acidic (Jordan 1985), w▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯

▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯1 ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯
▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ acidic soils rich in oxides of iron and
▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯
▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯

little of it that is available to plants (Mats▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯
plant growth in many acidic tropical soils (Cardoso 2006), and it is a significant limitation on
▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

The rich vegetation of tropical rainforests gives the false impression that these rainforests
▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯cal tree and plant adaptations that allow them
▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯

▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯
▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯ilton 1987). When these organic materials fall to
▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯
the plants by absorbing toxic metals in the soil ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯

1▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯

421Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 7 of 43

▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ 2 ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯
▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯enerally have high concentrations of roots near
▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯
▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ the tree roots, also help the rainforest trees
▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯
sections of the rainforest and then plant crops ▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯
▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯

▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯
and the weathering process, both of which can rapidly deplete the soil of its last remaining
▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯3▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯
its fertility (Hilton 1987) and leads to a host of cro▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯
significantly (Jordan 1985).

▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ter the trees have been cleared and planting

▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯
scientific soil sampling and test▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯e crop rotation, which involves
▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯
▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯

▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯

2▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯

422 Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 8 of 43

▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯rent soil fertility problems and the challenges
▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯

▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯ection of the fragile tropical land rather than
▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯ertilizers, and soil testing that might remedy the
▯▯▯▯▯▯▯▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯
healthy crops over time following the removal of the native vegetation.

POOR SOIL CONDITIONS COMBINED WITH POOR CROP MANAGEMENT
TECHNIQUES MOST LIKELY EXPLAIN MANY OF THE PROBLEMS ALLEGEDLY

OBSERVED IN THE TEST PLAINTIFFS’ CROPS.

The soils in this region are inherently poor tropical soils. The soils in the region at
▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯
▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯

Acrisols (Ultisols) are dominated by low ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯
▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯

y ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯
▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯
plant samples were collected from the Mestanza farm. 4 ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯
▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯

and iron toxicity.” The report also noted that the soil was also acidic, which the report
(correctly) explained is characteristic of the Amazon region, and that this acidity
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯
low cationic exchange capacity typifying deteriorated soil.” The soil had an excess of

4
▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
Corazon Orense and Santa Marianita.

423Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 9 of 43

▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯

soil also had a “very low” level of organic matter content. The report explained that
▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯
▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ by pathogenic microorganisms.” The report

▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯
appropriate farming practices.

y ▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯ 2003, and the interested party was listed as

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯

The test plaintiffs’ farming practices are inadequate. ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯
▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯
constraints often limit appreciation and application of these crop management technologies.
▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯
primitive farming methods typically employed in similar areas, demonstrates that their crop
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯

For example:

y ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯
19-21).

y ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯
▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯

424 Annex 11

▯▯▯▯▯▯▯▯▯▯
▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯

425Annex 11

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 11 of 43

THERE IS NO VALID SCIENTIFIC BASIS TO CONCLUDE THAT THE PLAN
COLOMBIA SPRAY MIXTURE ADVERSELY IMPACTS TROPICAL SOIL
FERTILITY.

Some if not all of the test plaintiffs allege that, for years following the Plan Colombia
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▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯
herbicide did reach the test plaintiffs’ soil, it w▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯r the soil’s fertility or
their crops’ ability to grow in that soil.

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯
very strongly to soil particle▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯
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▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯
6
2005). Following soil deposition, glyphosate is readily degraded by soil microbes to its main
metabolite (AMPA) (Araújo 2003), which is then ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯
▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯
degraded by the soil, it is widely recognized that glyphosate will exert no direct phytotoxic

▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯
no adverse impacts on the soil.

▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯

▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯
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6▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯
▯▯ ▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯

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▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯

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EXHIBIT B

Case 1:07-cv-01042-RWR -DAR Document 220-1 Filed 08/19/11 Page 40 of 43

Asmare Atalay, Ph.D. Materials Considered

Publications

▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯
the Microbial Activity of Two Brazilian Soils. Chemosphere 52: 799-804.

2) Borggaard, O. and A.L. Gimsing. 2008. Fate of Glyphosate in Soil and the

▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯ ▯▯▯▯
Management Science 64:441-456.

▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯
Upper Saddle River, NJ: Prentice Hall.

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The Effect on Soil Fertility of Repeated Applications of Pesticides Over 20 Years.
Pesticide Science 48: 63-72.

▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯m, and P.A. McDaniel. 2003. Soil Genesis
and Classification, 5th ed. Ames, IA: Iowa State Press.

▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯
toxicity and the effects of long-term vegetation control on soil microbial
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯

▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯

▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ in Dixon,
J.B. and S. B. Weed, eds. Minerals in Soil Environments. 2d ed. Soil Science
▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯

▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

herbicide. Pest Management Science 64: 319-325.

10) Environmental Protection Agency (EPA). September 1993. Reregistration
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11) Giesy, J.P., S. Dobson, and K.R. Solomon. ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯

12) Gimsing, A.L., C. Szilas, and O.K. Borggaard. 2007. Sorption of Glyphosate and
Phosphate by Variable-Charge Tropical Soils from Tanzania. Geoderma 138: 127-
132.

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▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯opical Rainforests: Implications for
▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯

16) Jordan, C.F. 1985. Soils of the Amazon Rainforest. Pages 83-94 in Prance, G.T. and
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17) Kang, B.T. and B. Tripathi (main cont▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯
Classification and Characterisation. Page▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯

Centre for Africa.

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▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯

globalization of N deposition: Ecosystem c▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯
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▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯
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22) Motavalli, P.P, R.J. Kremer, M. Fang, and N.E. Means. 2004. Impact Modified
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯nen, and T. Wartiovaara. 1981. Fate of
▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯
▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯mination and Toxicology 27:724-730.

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▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯
Biological Interventions. Pages 531-546 in N. Uphoff et al., eds. Biological
▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯

▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯

429Annex 11

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▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯
Applied Soil Ecology 34:114-124.

▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯
Microbial Degradation of Glyphosate in Soil. Weed Science 23(3):229-234.

▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯
▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯s and its mineralization in a Mississippi
soil. Pest Management Science 63:288-393.

Other Materials Considered

▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯

2) Map showing approximate area of general test plaintiff location in northern
▯▯▯▯▯▯▯▯

3) Mission Verification Reports on Illicit Coca Crop Spraying Operations. 10th-13th
and 15th-19th Reports. Bates labe▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯ ▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯

A) a table with citations to claims of crop damages in certain evidentiary
▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯
declaration of Marco Campana, deposition testimony excerpts, Accion Ecologica
▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯

B) the following information for each test plaintiff (if applicable to the test
plaintiff and/or family):

▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯

iii) excerpt from the Marco Campana declaration specific to each plaintiff

430 Annex 11

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iv) all deposition testimony excerpts re alleged crop damages and related
▯▯▯▯▯▯

v) other test plaintiff-specific information relating to their alleged crop
damages (e.g., photographs and/or vi▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯
prior certifications, Accion Ecologica t▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯
▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

vi) excerpts of certain non-governmental organization and other third
party reports that mention the test plaintiffs or the areas in which they live
with respect to crop damages

▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯ ▯▯▯▯▯▯

D) a map showing the approximate location of the test plaintiffs’ farm and spray
▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯ ▯▯ ▯▯▯ ▯▯▯▯▯▯
members in their depositions

431432 Annex 12

EXPERT R EPORT OFD R J.P. IES, PH.D.ON BEHALF OF THE
D EFENDANTS IA RIA/QUINTEROS . DYNCORP, 11 ANUARY 2011

433434 Annex 12

Case 1:07-cv-010DocumentFiled 0Page 1 of 319

EXHIBIT 6

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 2 of 319

Expert Report of John P. Giesy
on behalf of the Defendants in Arias/Quinteros v. DynCorp

I ExCperetdentials

A. General Professional Credentials

I am John Paul Giesy, Ph.D., FRSC. My business address is: Toxicology Centre and Department
of Veterinary Biomedical Sciences, Western College of Veterinary Medicine, University of
Saskatchewan, 44 Campus Drive, Saskatoon, Saskatchewan S7N 5B4, Canada. I am professor

and Canada Research Chair in Environmental Toxicology at the University of Saskatchewan. I
teach graduate-level classes, advise graduate students and post doctoral fellows and conduct my
own research.

In addition to my primary position as professor and Canada Research Chair at the University of
Saskatchewan, I hold the following appointments: 1) Emeritus Distinguished Professor of
Zoology, Michigan State University; 2) Chair Professor at Large, City University of Hong Kong,
Hong Kong, China; 3) Concurrent Professor, Nanjing University, Nanjing, China; 4) Guest

Professor, State Key Laboratory of Marine Environmental Science, Xiamen University, Xiamen,
China; 5) Distinguished visiting Professor, King Saud University, Riyadh, Saudi Arabia; 6)
Honorary Professor, School of Biological Science, University of Hong Kong, Hong Kong,
China.

I received my B.S., summa cum laude, with honors in biology, from Alma College, Alma
Michigan in 1970. I then received my M.S. in fisheries and wildlife with a specialization in
limnology, from Michigan State University in East Lansing, Michigan in 1971. I received my

Ph.D. in fisheries & wildlife (limnology) from Michigan State University, East Lansing,
Michigan in 1974. Limnology is the scientific study of bodies of fresh (inland) water for their
biological and physical and geological properties with a specialization in environmental
chemistry.

I have been working in the fields of environmental toxicology and environmental chemistry for
40 years. I am an ecotoxicologist and environmental chemist with particular expertise in the
areas of environmental fates of pollutants, including both inorganic and organic residues.

I have published 712 peer-reviewed works: 78 book chapters, 560 peer-reviewed open literature
journal articles, 5 feature articles, 3 theses, 7 books written, 10 books edited, 1 textbook chapter,
4 published reviews, 24 published reports, and 20 special reports. I am among the top 0.001% of
most cited active authors in the world (ISI) and the 2nd most cited author in the world in the

combined fields of Ecology and Environmental Sciences (during the last period the ranking was
published: 1997-2007), with an h-index of 63, based on a total of over 15,000 citations to my
published works. A complete listing of my publications is included in my CV, which is attached
hereto as Exhibit A.

435Annex 12

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I have received a number of awards and distinctions. These are detailed on pages 5-9 in my CV.
A few of the awards and distinctions that I have received include the Founder’s Award, which is
the highest recognition given globally by the Society of Environmental Toxicology and
Chemistry (SETAC) for scientific excellence. I have also received theEducation Award from

SETAC for my impact on the global science of ecotoxicology. I am the recipient of the
Vollenweider Medal from Environment Canada for excellence in environmental sciences and the
Sir John Randal Award from the Royal Soil Science Society. Most recently I was elected to the
status of Einstein Professor by the Chinese Academy of Sciences. A number of the papers that I
have authored have been designated the best paper for a particular year by several leading

journals. I am a fellow of the Royal Society of Canada, in the Academy of Sciences Division of
Earth, Ocean and Atmospheric Sciences, Discipline of Earth Sciences.

B. Herbicide/Agrochemical/GlyphosE atxpertise

I am an expert in the fates and effects of insecticides and herbicides. I was the director of

environmental effects research in aquatic systems of the Pesticide Research Center at Michigan
State University from 1981 until 1997. I have conducted a number of field and laboratory
studies on the movement of herbicides in the environment and their potential for effects on
wildlife including fish. I am also an expert on environmental risk assessments and in particular
wildlife toxicology working with fish, mammals and birds. My attached CV contains the details

of the studies I have conducted and the oral and written presentations that have resulted from that
research.

In regard to the current issue, I am considered to be one of the world’s authorities on the
herbicide Roundup® and its active ingredient Glyphosate® and associated adjuvants. I
published the following paper: Giesy, J. P., S. Dobson and K. R. Solomon. 2000. Ecological

Risk Assessment for Roundup Herbicide. Rev. Environ. Contam. Toxicol. 167:35-120, which is
paper number (JA-228) in my CV.

C. Environmental Fate and Transport Expertise

In addition to my work with herbicides and insecticides referenced above, I have conducted a
number of studies into the fates and environmental distribution of contaminants, including both
organic and inorganic chemicals. I have developed and applied models of environmental fates
and applied these to assess the rate of dissipation of organic residues and the ultimate disposition
of organic residues such as pesticides and herbicides in both the soil and aquatic environments.

The specifics of my experience are listed in my CV.

436 Annex 12

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D. Aquatic Toxicology Expertise

I was trained as a limnologist (the study of water) and fisheries biologist. Both my M.S. (1971)
and Ph.D. (1974) are in the area of aquatic ecology and limnology. Subsequent to attaining my

advanced degrees I have been working as an aquatic toxicologist for the last 36 years. I am
considered to be one of the preeminent aquatic toxicologists in the world. In 2010 I received the
Distinguished Honorary Professor Award from King Saud University, as the leading
environmental toxicologist in the world. The details of my studies and publications on issues

involving aquatic toxicity are set forth in my CV.

E. Compensation and Prior Expert Work

I am being compensated for my work in this matter at a rate of $350/hr. Over the past four years,
I have served as a testifying expert in the following matters:

1. Expert witness for City of Prince Albert, in the Court of Queen’s Bench for

Saskatchewan Q.B. No. 852 of 2000 between Strand Theatre Ltd. (Plaintiff) and the City
of Prince Albert (Defendant).

2. Expert witness for Monsanto Co., In the Circuit Court of Putnam County, West Virginia,

in Zina G. Bibb et al., (Plaintiffs) Civil Action No. 04-C-465 Against Monsanto Co.,
Pharmacia Corp., Akzo Chemicals, Inc., and Flexsys America Co., (Defendants).

3. Expert witness for the Crown, in the case of Mary Williams (Plaintiff) vs. Attorney

General of Canada and Minister of National Defense, in the Supreme Court of
Newfoundland and Labrador, Canada (T2880 CP, 2006).

______________________________________

II. Summary of Expert Opinions

I have been asked to review the individual plaintiffs’ claims of mortality of fish and domestic
1
animals, with specific reference to claims made by the Mestanza family, and based on the
information presented by the plaintiffs and the scientific literature, to assess the likelihood that
the alleged mortalities could have occurred due to spray drift or overspray with the Plan

Colombia herbicide mixture used to control coca in Colombia. My assessment has focused on
those species that I understand the Mestanzas and/or other test plaintiff families alleged were
killed by the spraying operations. These include two species of fish, cachama and tilapia, and a
variety of domestic farm animals, including chickens, ducks, sheep, pigs, cattle, dogs, and

horses, among others.

1
I focused my analysis on the Mestanza family because their farm was in the closest proximity to Plan Colombia
spraying operations at the time of their alleged damages compared to the rest of the test plaintiffs. My opinions
herein, however, are equally applicable to the other test plaintiffs, whose claims arise from even more distant Plan
Colombia spray operations.

437Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 5 of 319

In response to this charge, I have reviewed the plaintiffs’ claims and the available literature both
in the peer-reviewed literature and government documents to assess both the potential duration
®
and magnitude of exposure to and the potential toxicity of Glyphosate and the associated
adjuvants included in the Plan Colombia herbicide mixture. Where possible, I have used dose-
response information for the same formulation used and for the species of concern. I have then

compared the estimated maximal exposure to thresholds for adverse effects.

Based upon my review and analysis, I have reached the following opinions:

1. There is no scientific basis to opine that the herbicide mixture used in “Plan
Colombia” would be transported through soil or water or would persist in the
environment.

2. There is no scientific basis for the Mestanza plaintiffs’ claims that the Plan
Colombia spraying operations could have caused the alleged fish kill of cachama
or tilapia.

3. There is no scientific basis for plaintiffs’ claims that the Plan Colombia spraying
operations could have caused the alleged deaths of farm animals.

The sources of information that I have considered in reaching my export opinions are cited
herein and are listed in Exhibit B.

III. Fate and transport of the three ingredients in the Plan Colombia herbicide
(Glyphosate ® and its degradation product AMPA, POEA, and Cosmoflux 411F ) in ®
the environment.

The fate or movement of a chemical in the environment is referred to as its chemodynamics and
is determined by both the physical-chemical properties of the compound and the environment to
®
which it is released. Here I discuss some of the properties of Glyphosate , and associated
constituents in the Plan Colombia herbicide mix, which determine its fate in air, as well as
aquatic and terrestrial environments. I also discuss some of the properties of the specific
environments to which it is alleged to have been released and the effect that those properties

have on the biological availability and dissipation rates of Plan Colombia herbicide mix and its
component parts.

® ®
The Plan Colombia herbicide mixture is 44% Roundup ® , which includes 41% Glyphosate , 15%
POEA, and 44% water, to which 1% Cosmoflux 411F , is added and the remaining 55% is made
up of water (DOS 2002). The final Plan Colombia mixture contains 18% Glyphosate , 8%
surfactants (1% Cosmoflux 411F ® , 7% POEA) and 74% water. Id. The available data on the
®
physical and chemical properties of the active ingredient, Glyphosate , have been reviewed
extensively (Mackay et al. 1997).

438 Annex 12

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A. SprDaryift

I understand that the potential drift of herbicide from Plan Colombia aerial coca eradication
operations is being addressed by another expert. In light of this, and in light of the fact that my

risk assessments demonstrate that even direct overspray of Plan Colombia herbicide could not
have caused the alleged deaths in fish and farm animals, I will not address the issue of drift in
this report.

B. Mobility in Soils and Water

1. Mobility of Glyphosate.

Although Glyphosate is very soluble in water, its strong sorption to soil limits mobility (Giesy
®
et al. 2000). Consequently, Glyphosate is unlikely to leach into groundwater or runoff from
soils into surface waters after application (Borggaard and Gimsing 2007). Glyphosate is an
amphoteric compound with several pK (acid dissociation constant) values. In other words,
® a
Glyphosate can act as either an acid or a base and can be bound with either acids or bases of
varying strengths. The amphoteric nature of Glyphosate ® accounts for its relatively gread K
(strength of bond) for binding to soil particles. Primary sites of binding are aluminum and iron
®
oxides. Because of this characteristic, Glyphosate herbicides are effective only when applied
directly to the plant surface. Once Glyphosate enters soil it is essentially unavailable to plants
due to its very high affinity for soil. This explains why Glyphosatetreated areas can be planted
®
with crops soon after application. For this reason Glyphosate would not have residual effects
on crops planted in soil that had been sprayed with Glyphosate, and Glyphosate bound to soils
in this way is not mobile in the environment. Also, the very tight binding of Glyphosateto soils

limits its bioavailability to animals walking on or even ingesting soil.

The primary degradation product of Glyphosate ® that is of any toxicological interest is
®
Aminomethylphosphonic acid (AMPA). While Glyphosate is tightly bound to soils and is not
readily available to cause toxicity to plants or animals, it is still degraded by microbes to AMPA,
which is in-turn bound to soils but also degraded.

2. Mobility of Poly-ethoxylated Tallow-amine (POEA).

®
Based on information on adsorption and degradation of the POEA adjuvant used in Roundup ,
leaching and runoff potential is expected to be small. POEA strongly adsorbs to soil. When the

binding of POEA is normalized to the carbon content of soils, the ocvalues in three different
soil types were estimated to range from 2500 to 9600 (Marvel et al. 1974). POEA that was
adsorbed to soil was not readily desorbed; even using ammonium hydroxide as the extracting

solvent removed less than 20% of the POEA adsorbed to soil. Thus, the mobility of POEA in
soil is expected to be less than 2% (Giesy et al. 2000).

3. Mobility of Cosmoflux 411F.

Cosmoflux 411F ® is added to the Plan Colombia mix to facilitate penetration of Glyphosate
®
through the waxy cuticle of plant leaves. Cosmoflux 411F is a mixture of surfactants, including

439Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 7 of 319

linear and branched nonionic polyethoxylates and isoparafins (Solomon et al. 2007; CosmoAgro
®
2003). The active ingredients in Comsoflux 411F are polyol, fatty acid esters and
polyexothylated derivatives, which make up 17% of the product. The remaining 83% of the
product is made up of liquid isoparaffins.

®
I do not have direct data on the mobility of Cosmoflux 411F in soils and water. However, in
general, non-ionic polyethoxylate based surfactants like Cosmoflux would be expected to
adsorb readily to soil and sediment and are unlikely to bioaccumulate because of their low

solubility in water (Krogh 2003; R. Van Compernolle 2006).

C. Degradation.

1. Degradation of Glyphosate ® .

®
Glyphosate is fairly rapidly degraded in soil and the rate of degradation is directly proportional
to temperature. Thus, at higher soil temperatures, the rate of degradation is greater. The results
of both field and laboratory studies have demonstrated microbial degradation of Glyphosate in

water and rapid decreases in co®centrations in both flowing (lotic) and standing (lentic) waters
(Giesy et al. 2000). Glyphosate , which consists of glycine and phosphono-methyl moieties,
degrades to glycine, sarcosine and the primary Glyphosate metabolite, AMPA (Giesy et al.,

2000), which can also be degraded by microbes (Rue®pel et al. 1977). While it is important to
understand the degradation pathways of Glyphosate in the environment, this information is not
critical to address the issue of acute lethality alleged to have occurred at the Mestanza farm or
®
the farms of the other plaintiffs. However, the rapid degradation of Glyphosateo AMPA,
which in turn is further mineralized to non-toxic constituents, is noteworthy in that it precludes
the possibility of any residual effects. That is, any presence of Glyphosatesoil would

dissipate over a relativ®ly short time after the initial application. Indeed, one of the most useful
properties of Glyphosate when it is used in agriculture and one of the reasons for its widespread
use is that Glyphosate is so rapidly deactivated on the surface of soils, that crops can be seeded
®
directly with or shortly after the application of Glyphosate .

2. Degradation of POEA.

When degradation of POEA was investigated in three soils (silt loam, silt-clay loam, and sandy
loam), microbial degradation was the primary process of dissipation, with minimal degradation
occurring under sterile conditions (Marvel et al. 1974). The estimated degradation half-life for

POEA in soil was less than 1 week and possibly as short as 1 or 2 days. In natural water
containing suspended sediment, such as lakes, ponds, and rivers, POEA is degraded through
microbial processes (Banduhn and Frazier 1974). The general half-life of POEA has been

estimated to be less than 3-4 weeks (See also Giesy 2000).

3. Degradation of Cosmoflux 411F . ®

I am not aware of any degradation studies on Cosmoflux 411F ®, but non-ionic nonionic
polyethoxylate based surfactants like Cosmoflux 411F have been found to be readily

biodegradable (Jurado 2007; Krogh 2003; ěezniҁþkovaҁ 2002).

440 Annex 12

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D. Studies of Environmental Fate and Transport of the Plan Colombia

herbicide mixture

1. Soil and Water Testing by the Colombian Government

There is an extensive quality assurance program in place to assure that the Plan Colombia aerial
coca eradication operations are conducted in a manner that minimizes the potential for adverse
effects of non-target plants and off-site wildlife and people (Colombia Ministry of Environment,
Housing and Regional Development 2004). Monitoring has demonstrated that the program is

being strictly managed to the specifications outlined in Ministry directives. When off-site effects
have been reported, they have been either unsubstantiated or found to be minimal. The
Colombian Ministry of Environment states that “The drift effects that were observed in areas

visited on a random basis were temporary in nature and small in extent and basically consisted of
partial defoliation of the canopy of very high trees. No complementary collateral damage from
spraying activities was observed at the sites selected and verified” (Colombia Ministry of
Environment, Housing and Regional Development 2004; see also DOS 2007).

During Plan Colombia operations, extensive monitoring of both soils and water has been
conducted. These studies have examined concentrations of both the active herbicidal ingredient
used in the Plan Colombia mixture, Glyphosate , and adjuvants on soils and surface waters.

During monitoring of locations where Plan Columbia herbicide mixture was sprayed to eradicate
coca, concentrations of Glyphosate® and its degradation product AMPA in water have in all
cases been less than the concentration established to protect human health (Solomon et al. 2007).

2. Soil and Water Testing by the Ecuadorian government

In 2004, the Ecuadorian government conducted sampling campaigns along the border with
®
Colombia to determine if there was any migration of Glyphosate from Plan Colombia aerial
eradication operations near the Colombia-Ecuador border to either water or soils on the
Ecuadorian side of the boarder. Glyphosate ® was never detected in water or soils during any of

this monitoring (Ecuador Atomic Energy Commission Reports 2004).

E. Conclusions on the fate and transport of Plan Colombia herbicide

1. Aqueaticironments .

In aquatic environments Glyphosate ® would be expected to rapidly bind to suspended solids and
organic matter and become inactivated. This would be especially true in shallow ponds where

the surface area of the sediments is large relative to the volume of water. Furthermore, in
shallow fish ponds there is significant turbidity (cloudiness in the water), which would further
reduce the available fraction of Glyphosate and its associated adjuvants. In fact, due to dilution
®
and the fact that Glyphosate would not be able®to be maintained at a sufficient concentration on
the surface of aquatic macrophytes, Glyphosate is generally considered to be ineffective against
aquatic plants at concentrations used to treat terrestrial plants (McClaren Hart Environmental

441Annex 12

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®
1995). The primary degradation product of Glyphosate , AMPA, would be expected to react
similarly.

2. Terrestrial environments.

®
In terrestrial environments, Glyphosate is quickly (within a few hours) tightly bound to soil
such that it is not biologically available and thus not toxic. AMPA would be expected to behave
in a similar manner.

Based on these observations and knowledge of the chemical/physical properties of the
constituents in the Plan Colombia herbicide formulation, and the studies referenced above, there
is no scientific basis to conclude that there was any meaningful transport of the Plan Colombia
herbicide mixture outside the areas in which it was sprayed and certainly no scientific basis to
conclude that there was any trans-boundary migration or accumulation of Plan Colombia

herbicide mixture sprayed in Colombia in soils or water in Ecuador.

IV. Methodology of Toxicology and Hazard Assessments

Toxicity of chemicals to animals is a function of duration and intensity of exposure (the dose to
which they are exposed). Reciprocity between duration and intensity of exposure exists such
that organisms can be exposed to some concentration of chemical for some period of time
without adverse effects. The reciprocity relationship states that there is some concentration for

each duration of exposure and some duration for each magnitude of exposure that relates to the
threshold for effects. The incipient lethal concentration is the concentration less than which an
organism or population of organisms can be exposed for an infinitely long period of time without
dying. The incipient lethal time is the duration to which an organism can be exposed to even the
greatest concentration of chemical possible (water solubility limit) without adverse effects. The

conclusion from this line of reasoning is that all animals can be exposed to any chemical for
some period of time or to some concentrations without adverse effect. Said another way, simply
because an organism is exposed to a chemical does not mean that there will be an adverse effect
on that organism.

The strength of a toxicant is defined as its potency. Chemicals for which a greater concentration
are required to cause the same level of effect during the same duration of exposure are less
potent (less toxic), while those that require less are more potent.

Toxicity testing can be conducted in basically two ways. The first way is to determine the
concentration required to cause some level of effect, such as 50% lethality at some set duration
of exposure, such as 4 days (96 hr). The second way is to determine the duration to which an
organism can be exposed to a defined concentration before an adverse effect occurs. In the

United States, the standard method of reporting toxic potency of chemicals is to express the acute
toxicity as the concentration required to cause 50% lethality. Shorter durations of exposure such
as 96 hr are referred to as acute exposures, while longer durations of exposure, such as 21 or 28
days are referred to as chronic exposures. Similarly, toxicity can be defined as either acute or

chronic depending on the duration of exposure. Greater concentrations of chemicals are required
to cause toxicity in shorter periods of time. Because the effects claimed in this instance were

442 Annex 12

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stated to have occurred in a short period of time, the appropriate duration of exposure is acute or
short-term. Thus, I will define the relevant duration of exposure as less than 96 hr or 4 days and
use the results of acute lethality tests as the relevant toxicity information for my assessments.

There are a number of endpoints or measures of effect that can be used. These range from

biochemical or molecular changes to histological changes or effects on growth or reproduction.
To be an effective measurement endpoint, the response or effect must be ecologically relevant.
The primary ecologically relevant endpoints are survival, growth, and reproduction. Because the
effect claimed in this case for fish and animals was lethality, mortality is the most relevant

endpoint to consider. For the purposes of this assessment, the measurement endpoint that is
relevant is acute lethality. Other more subtle effects are not relevant and will not be considered.

Hazard is a property of chemicals and represents the toxic potency of a chemical. The
relationship used to determine hazard is the dose-response relationship. This is a measure of

how much effect was observed at a particular concentration for a specified period of time. If
there is no exposure, even if a chemical is very hazardous, there is no response or effect.
Alternatively, if there is exposure, but the exposure does not exceed the threshold for effect,
there is no response. For a chemical to cause an adverse effect on an organism there must be an
exposure at a level that gives rise to a hazard. In a risk assessment the probability of these two

conditions occurring is investigated and it is determined if there is overlap between the two
necessary conditions of exposure and hazard.

For this reason, estimated concentrations of the constituents of the Plan Colombia formulation
will be compared to the median acute toxicity value (LC-50) which is the concentration of the

constituent or mixture required to kill 50% of individuals exposed for 96 hr.

The process of assessing the likelihood that exposure to a chemical will affect an organism is
referred to as a hazard assessment. In hazard assessments, point estimates of predicted

concentrations in the environment are compared to the LC-50. Alternatively, in a risk
assessment, the probability of exposure to a chemical resulting in an adverse effect is determined
by estimating the probability of effects. Risk assessment is a more complicated assessment that
determines the chance that a particular outcome will occur and is not relevant in the current case
because the claimed effect was lethality of fish and animals. Here I will apply the methodologies

for hazard assessments which include the following elements: (1) determination of exposure
(duration and magnitude) and (2) hazard (potency of the chemical or mixture). Exposure is the
determination of the concentration that would likely have occurred in the environment and for
how long it would have occurred. Hazard is the relationship between exposure concentration
and duration (i.e., dose) and adverse effects. The hazard assessment determines the likelihood of

the duration and magnitude of exposure exceeding the combination that will result in adverse
effects.

The most basic form of hazard assessment is the calculation of the hazard quotient (HQ), which
is the ratio of the measured or estimated (predicted) concentration of a chemical or mixture in the

environment divided by the measure of potency such as the LC-50.

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V. Toxicity of Plan Colombia Herbicide and Its Constituents to Vertebrate Animals

In its annual Certifications to the US Congress, the United States Department of State, in

consultation with the US Environmental Protection Agency, has provided detailed information
regarding the potential toxicity of the Plan Colombia herbicide. Certifications issued in 2002,
2003, 2004, 2005, 2006 and 2007 have all reported that “The herbicide mixture, in the manner it

is being used, does not pose unreasonable risks or adverse effects to humans or the environment,
including endemic species” (DOS 2007). While I concur with these conclusions, I will present
my own site-specific analysis of the claims made by the Mestanza plaintiffs. This analysis

applies as well to the claims made by the other test plaintiffs who were more distant from Plan
Colombia spraying operations at the times of their alleged exposures. The characteristics of
spray-drift deposition is such that the plaintiffs whose properties are further from the border, or

from actual spray events, would be exposed to less deposition of Plan Columbia mix than the
Mestanza property. Thus, if it is determined that there would be no effects on the Mestanza
property, by logic there would be no effects on the other properties. As noted below, however, it

is my opinion that the alleged deaths of animals could not occur even in the event of multiple
direct over-sprays.

The standard herbicide formulation referred to as Roundup is a mixture of the active herbicidal
®
ingredient Glyphosate and the adjuvant polyoxylated tallow-amine (POEA). POEA is a
cationic surfactant that helps the Glyphosatetick to and or penetrate the waxy surfaces of
vegetation, thus making it more effective. The Plan Colombia formulation is made up of
® ® ®`
Roundup and the surfactant Cosmoflux 411F . Over time, Glyphosate , POEA, and
Cosmoflux 411F degrade and dissipate at different rates, so for longer-term or chronic
exposures, it would be appropriate to consider the toxicity of the individual components

separately. For short-term or “acute” exposures, suchas those at issue in this case, however, it is
more appropriate to consider the toxicity of the applied mixture as a whole. In my analysis, I
have accordingly considered toxicity studies of the Plan Colombia herbicide mixture, of
® ®
Roundup (i.e., the formulation of Glyphosate and POEA) and of the individual components of
the Plan Colombia herbicide mixture. I will rely primarily on the threshold for acute (96 hr)
lethality, but use the information on effects of constituents or chronic effects of the mixture or of

individual constituents as collateral information as appropriate to inform my conclusions.

A. Toxicity of Glyphosate and Roundup (Glyphosate plus POEA)

® ®
The toxicity of Glyphosate and of Roundup has been extensively studied and is well
understood. The mechanism by which Glyphosate ® is toxic to plants has been reported in detail
®
(Franz et al. 1997; Cole 1985). Glyphosate inhibits plant growth by inhibiting the production of
essential aromatic amino acids through competitive inhibition of enolpyruvylshikimate
phosphate (EPSP), a key enzyme in the shikimic acid pathway for the synthesis of chorismate,

which is a precursor for the essential amino acids phenylalanine, tyrosine and tryptophan. While
necessary for plant life, these amino acids are not synthesized by vertebrates, either aquatic or
terrestrial. For that reason, Glyphosates toxic to plants, but is not toxic to vertebrate animals

(Giesy et al. 2000; Williams et al. 2000).

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® £
Formulations of Glyphosate , including Roundup herbicide (Monsanto Company), have been
extensively investigated for their potential to produce adverse effects in non-target organisms.
Governmental regulatory agencies, international organizations, and others have reviewed and
®
assessed the available scientific data for Glyphosatermulations, and independently judged
their safety. Conclusions from three major organizations are publicly available and indicate
Glyphosate -based herbicides can be safely used without effects on humans or wildlife.
® ®
Glyphosate -based herbicides such as Roundup can be used with minimal risk to the
environment (Agriculture Canada 1991; USEPA 1993; WHO 1994). These documents have been
extensively peer-reviewed and the information and discussions in these reviews served as

foundation for the current assessment. Several review articles on the fates and effects of
Roundup ®or Glyphosate in the environment have been published (Carlisle and Trevors 1988;
Smith and Oehme 1992; Malik et al. 1989; Rueppel et al. 1977). In addition, several books have
®
been published about the environmental and human health considerations of Glyphosate and its
formulations (Grossbard and Atkinson 1985; Franz et al. 1997). In addition, Roundup and
®
other Glyphosate formulations have been selected for use in a number of weed control
programs for state and local jurisdictions in the United States. Many of these uses require that
ecological risk assessments be conducted in the form of Environmental Impact Statements or

Environmental Assessments. These documents are comprehensive and specific to local use
situations. Documents are available for risk assessments in Texas, Washington, Oregon,
Pennsylvania, New York, Virginia, and other States (USDA 1989, 1992, 1996, 1997; USDI
®
1989; Washington State DOT 1993). Finally, the properties and toxicity of Glyphosate have
been reviewed extensively (Giesy et al. 2000; Williams 2000).

B. Toxicity of Polyethoxylated Tallowamine (POEA)

Polyethoxylated tallow-amine (POEA) is the surfactant added to many formulations with
®
Glyphosate . Isoparaphyns are not very toxic to mammals (Mullin et al. 1990) and have been
described as essentially nontoxic. Oral L50values have been reported to be in the range of 3 to
15 g/kg body weight. There is little dermal absorption and the most relevant pathway of

exposure is through inhalation. Isoparaphyns are not genotoxic. While POEA can cause eye and
skin irritation, it is fairly non-toxic relative to lethality. While POEA was found to not be
genotoxic or cause developmental toxicity in rat pups, it did cause lethality to adult rats during

chronic exposures to concentrations greater than 100 mg/kg, bw/day (Giesy et al. 2000).

C. Toxicity of Cosmoflux 411F ®

®
Information on the toxicity of Cosmoflux 411F is less extensive, but likewise indicates very
low levels of toxicity to vertebrate animal life. As reported by the U.S. Department of State in
®
consultation with the U.S. EPA, in acute toxicity studies on rats, t50 LD of Cosmoflux 411F
was determined to be 31,600 mg/kg, which is practically non-toxic. (Jacobson 2001). As
discussed more fully below, in a separate study, Cosmoflux 411F was found to be similarly

non-toxic in the fish species cachama, with an 96-hr 50of 4,418 mg/L (Rondón-Barragán et al.
2007).

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D. Toxicity of Plan Colombia Herbicide

The acute lethality of the Plan Colombia herbicide mixture to rats via acute dermal, oral and
inhalation exposure was tested in two sets of studies conducted in the United States and
Colombia (Bonnette 2003a-d; Cruz 2003a-b). The acute oral and dermal LD was > 5,000
50
mg/kg bw. This means that no toxicity was observed even at the greatest dose tested. The acute
inhalation LC50 ranged from 2.5 to 20 mg/L, which similarly classifies the mixture as non-
hazardous.

The acute lethality of the Plan Colombia herbicide to four standard aquatic organisms used in
toxicity tests were determined for the green alga (Selenastrum capricornutum), the water flea
(Daphnia magna), the rainbow trout (Onchorhyncus mykiss) and the fathead minnow

(Pimophales promelas). The median toxicity expressed as the LC 50or EC 50. capricornutum)
for these four organisms were 2.2-5.7 mg/L (Stantec, 2005e), 4.2 mg/L (Stantec 2005b), 1.8
mg/L (Stantec 2005d) and 4.6 mg/L (Stantec 2005c), respectively. These findings indicate that
®
the Plan Colombia herbicide mixture has an aquatic toxicity profile similar to that of Roundup
formulations used in the United States.

A number of studies have been conducted of the effect of the Plan Colombia herbicide on frogs

under controlled laboratory conditions and under field conditions or in mesocosms (experimental
water enclosures) meant to be more realistic. Under laboratory conditions of constant exposure
in the absence of any sediment substratum, when 8 species of frog endemic to Colombia were

tested, the LC50values for the Plan Colombia herbicide ranged from 1.2 to 2.8 mg a.e./L (Bernal
2009b). In the field or in mesocosms (in which the herbicide has the opportunity to become
bound to sediments or otherwise be degraded or dissipated) the LC v50ues ranged from 6.0 to

7.3 mg a.e./L (Bernal 2009b). Similarly, when frogs were exposed in smaller containers that also
included sediment in the bottom, the LC 50ranged from 4.5 to 22.8 kg/ha, which is the equivalent
of 3.0 to 15.3 mg/L, respectively (Bernal 2009b).

Based on this information, the Plan Colombia formulation would be classified as very low
potency as a toxicant, relative to that of other chemicals, especially pesticides.

V. Toxicity of the Plan Colombia Herbicide and Its Constituents to the Fish at the
Mestanza Fish Farm (Tilapia and Cachama)

The sensitivity to Roundup ® varies among fishes with the four-day (96 hr) median tolerance limit

(LC-50) ranging from approximately 2.3 to 54.8 mg/l (Folmar et al. 1979). A detailed discussion
of mechanisms of toxicity and toxicity to other organisms can be found in a paper I published
(Giesy et al. 2000). For purposes of this report, I will focus on the toxic potency of Glyphosate,
®
Roundup , and the Plan Colombia mixture to the two fish species, tilapia and cachama, that are
alleged by Mr. Mestanza to have been killed through exposure to the Plan Colombia herbicide.
Because it was alleged that the fish died within less than a day of the alleged spray-drift events, I
will focus on studies measuring acute toxicity.

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A. Toxicity of Roundup ® to Cachama and Nile Tilapia:

The toxicity of Roundup to tilapia has been studied in both acute and chronic exposure scenarios
(Jiraungkoorskul et al. 2003). For acute exposures, the 96 hr50Cas 16.8 and 36.8 mg/L
®
Roundup for young and adult Nile tilapia, re®pectively. For chronic toxicity, Jiraangkoorskul et
al. (2003) exposed tilapia to 5 or 15 mg Roundup/L for three months and examined some
biochemical and histological responses. A range of effects were observed to occur that could be

useful as forensic diagnostic tools, but these results are not germane to acute lethality, which I
understand to be the issue in this case. What is an important result of this study is that exposure
to concentrations of the formulation of Roundup herbicide as great as 15 mg/L did not cause

any ecologically relevant effects on either survival or even growth. The effects were more subtle
effects on enzyme activities in the liver and changes in the cellular structures of liver, kidney and
gills. These responses were likely adaptive in nature and are consistent with a lack of effects on
®
survival or growth at concentrations of Roundupas great as 15 mg/L. Relative to mortalities
alleged to have occurred in the Mestanza fish ponds, even a prolonged exposure of at least 3
months to 15 mg/L would not have been expected to have caused any relevant effects that would

have affected the number or mass of fish available for sale.

Other studies have reported similar findings. In on® study, no acute toxicity (lethality) was
observed in tilapia at doses of 1, 5, or 15 mg Roundup (mg/l; ppm) but 100% mortality was
observed at 45 mg Roundup ®/ L, within a few hours (González, 2007). In another study, the 96
® ®
hr LC-50 for toxicity of Roundup to tilapia was 7.4 mg Roundup /L (Liong, 1988).®These
toxicities are expressed as concentrations of the active ingredient (“a.i.”) Glyphosate
presence of POEA.

®
The acute lethality of Roundup to cachama as well as other measurement endpoints, such as
histopathology and physiological responses, was measured by Ramirez et al., 2008. The 96-hr
® ®
LC-50 for cachama exposed to Roundup was 97.47 mg /L Roundup , which makes the
cachama almost two times more tolerant of exposure to Roundup® than for most other fishes for
which information is available (Giesy et al. 2000).

B. Toxicity of Cosmoflux 411F ® to Cachama and Tilapia

®
I am not aware of any studies specifically measuring the toxicity of Cosmoflux 411F alone to
tilapia. However, the 96-hr LC-50 of Cosmoflux 411F ®to cachama was reported to be 4,418
®
mg/L (Rondón-Barragán et al. ®007). Thus, Cosmoflux 411F is much less potent at causing
lethality than even Glyphosate.

C. Toxicity of Plan Colombia mixture to Cachama and Tilapia

To my knowledge, the acute toxicity of the Plan Colombia herbicide has not been studied in
® ®
tilapia. The acute toxicity of a mixture of Roundupnd Cosmoflux 411F to cachama, has
been measured, but using a different proportion of the two substances than is used in the Plan
Colombia herbicide (125 to 1, instead of 44 to 1) (Ramirez 2009). The LC-50 was reported to be
® ®
23.42 mg/L Roundup and 0.19 mg/L Cosmoflux 411F . The investigators suggested that this
result indicates a synergistic effect between Roundupnd Cosmoflux 411F , but this
conclusion is contrary to the findings by Bernal et al. (2009a) in their studies of amphibians.

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®
When the toxicity of Roundup to tadpoles was compared to that of the Plan Colombia herbicidal
mixture, the ranges of toxicities overlapped (Bernal et al. 2009a). From this analysis, those
authors determined that the presence of the 1% Cosmoflux 411F ® did not alter the toxicity of
®
Roundup . In any event, an LC-50of 23.42 mg®L (as reported in Ramirez 20®9) demonstrates
that cachama are fairly tolerant of Roundup with added Cosmoflux 411F .

D. Hazard Assessment for Tilapia and Cachama Allegedly Exposed to Plan

Colombia Herbicide in the Mestanza Fish Ponds.

1. ExposAuseessment

Having identified the appropriate toxicity measures, the next step in a hazard assessment is to
compare those measures with the potential concentrations of the Plan Colombia herbicide
mixture in the Mestanza fish ponds. There is no evidence of exposure to or adverse effects of

spray drift from coca eradication program to the Mestanza fish ponds. No measurements of
Glyphosate or its major degradation product AMPA or any of the adjuvants were made in water
or sediments at the time of the alleged fish kill. Nor are there any samples of fish in which
®
Glyphosate , AMPA or any other constituents of the herbicide mix were detected. In conducting
this assessment, I have, accordingly used the methodology of what is referred to as a “Tier I”
assessment, by use of “worst-case” assumptions to calculate a very conservative hazard quotient

(“HQ”). The approach employed was similar to the hyper-conservative quotient method
(Environment Canada 1997). Tier I hazard quotients are designed to be protective; where an
extreme assumed exposure level does not affect the most sensitive species identified in
laboratory tests, there is a high degree of confidence that no adverse effects, such as lethality in

this case, would occur.

In my Tier I assessment, I have assumed, as a worst case scenario, that there was a direct

overspray (not drift) of Plan Colombia herbicide into the Mestanza fish ponds. I have also
assumed that the maximum application rate was applied to the entire surface of the ponds (an
unlikely and thus worst-case assumption even for a direct over-spray incident).

In my assessment, I calculated concentrations of the Plan Colombia®herbicide in the water in
terms of the concentration of the active ingredient (a.i.) Glyphosatebecause this is the manner
in which toxicity is reported in the studies discussed above. It must be noted, however, that both

the toxicity studies and my concentration assessment reflect as well the presence of the
associated adjuvants, such as POEA, which may in fact be contributing the greatest proportion of
the aquatic toxicity of the formulation (Giesy et al. 2000). This method of reporting, i.e., based
upon the a.i. of Glyphosate®, allows direct comparison of the worst-case concentration of the

Plan Colombia herbicide predicted to have been present in the Mestanza fish ponds with the
LC 50concentrations at which one would expect 50% mortality in fish based on the findings of
the toxicity studies.

To determine the exposure portion of the Tier I assessment, I have used an application rate of the
Plan Colombia formulation of 3.69 kg Glyphosate ® (a.i.) on each hectare (“a.i./ha”), which I
understand is the standard application rate used in the coca eradication spraying operations.
2
Since 1 ha is equivalent to 10,000 sq m (m ), this application rate can be restated as 3.69 kg

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® 2 ® 2
Glyphosate (a.i)/10,000 m or 0.369 g Glyphosate (a.i.)/m . From the images of an empty fish
pond in a video provided by Mr. Mestanza, it appears that the Mestanza fish ponds are between
1.0 and 1.5 m deep. To be conservative, I have assumed a depth of 1.0 m. I also assume that

none of the Plan Colombia herbicide mixture was adsorbed to the sediment in the ponds and thus
became unavailable for exposure to the fish (a highly unlikely if not impossible outcome). 2

Based on these extremely conservative assumptions, the concentration of Plan Colombia mixture
in the Mestanza fish pond from a direct overspray would be 0.369 g Glyphosate /m (because
2
the application ra6e of 3.693g/m was assumed to be diluted to a depth of 1 meter). Because one
cubic meter is 10 ml or 10 L, this translates to a direct overspray concentration of Plan
Colombia herbicide mixture in the fish ponds of 0.369 mg Glyphosate ®/L.

To complete the hazard assessment one must compare this worst-case concentration of the

herbicide in the fish ponds to the threshold for mortality in the Mestanza fish. I have done this
for the two species of fish alleged to have been killed, the tilapia and the cachama.

2. Hazard Assessment

®
Based on the toxicity of Roundup to cachama, the HQ for the scenario of a direct overspray
would be 0.0038 (0.369 [concentration]/97.47 [LC ]).50he margin of safety, which is the
®
inverse of the HQ, would be 264. That is, the LC 50 c®ncentration of Roundup is 264 times
greater than the worst-case concentration of Roundup predicted to occur in the fish pond due to
a direct over-spray, even assuming no dissipation, degradation or sequestration of any of the

constituents of the Plan Colombia herbicidal formulation. This means that there would have to
have been 264 direct over-sprays of the same pond during the same spray event to reach the
®
threshold for let®ality. If one uses instead the LC50 from the study of a Roundup and
Cosmoflux 411F mixture by Ramirez (2009), the HQ for a direct overspray scenario is 0.0158
(0.369/23.42) with a margin of safety of 63. That is, a total of 63 over-sprays would have been

required to cause acute lethality of half of the cachama. For a Plan Colombia spraying operation
to have killed all of the cachama in the Mestanza fish ponds, as Mr. Mestanza alleges for the

alleged October 2002 event, there would have needed to have been an even greater number of
direct over-sprays.

The finding for tilapia is similar. Based upon the LC ’50in the paper by Jiraangkoorskul et al
(2003), the HQ for juvenile tilapia would be 0.022 (0.369/16.8) and the margin of safety would

be 45.5 (45.5 direct over-sprays needed to reach the LC co50entration) and the HQ for adult
tilapia would be 0.01 (0.369/36.8) and the margin of safety would be 99.7 (roughly 100 direct

over-sprays). Finally, using the least recorded LC f50 tilapia from the study by Liong (1998)
still results in an HQ of 0.498 (0.369/7.4) and a margin of safety of more than 20 (20 direct over-

sprays).

2 ® ®
In fact, suspended soil is known to bind Glyphoand reduce the toxicity of Rounduand the Plan Colombia
herbicide mixture to aquatic organisms (Relyea 2005; Bernal 2009b). Based on the Mestanza video, the fish ponds
appear to contain a significant amount of suspended sediments that would greatly reduce the concentration of the
herbicide remaining in the water. Thus, by comparing the predicted concentrations of Glyphosateds with
the threshold to cause toxicity without correcting for bioavailability of the herbicide in the water after binding to

sediments, my calculated HQ values will be very conservative and overestimate the potential for effects.

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It is worth noting here that the video evidence provided by Mr. Mestanza of images of the fish
pond and surrounding areas one month after the alleged fish kill are inconsistent even with a
single direct overspray of Plan Colombia herbicide, let alone the more than 20 direct over-sprays
required to result in even 50% mortality of tilapia (and no mortality in cachama) under the most

conservative scenario above. The video repeatedly shows green plant life surrounding the fish
ponds. Had the area been directly over-sprayed even a single time, let alone more than 20 times,
the plant life surrounding the fish pond would all be dead. This video evidence thus directly

establishes the fact that there could not have been any lethal concentration of Plan Colombia
herbicide applied to the fish ponds.3

Based on this analysis, I conclude that it would have been impossible for the Plan Colombia
spraying operations to have killed cachama or tilapia even with a direct over-spray of the
Mestanza ponds with Plan Colombia herbicide mixture. Based upon these findings, there is no

need to continue to the next step in the hazard assessment which would have been to do a refined
assessment of the potential concentration of Plan Colombia mixture that could have reached the
Mestanza fish ponds or other farms under the prevalent climatological conditions in the region.
Of course, any possible concentration of the herbicide in the fish ponds via drift would be much

less than that in a direct over-spray scenario, making the fish kill allegations all the more
untenable.

To put it bluntly, Mr. Mestanza’s allegation that the Plan Colombia spraying operations caused
fish kills at his farm is scientifically impossible.

V. Toxicity of the Plan Colombia Herbicide and Its Constituents to the Farm Animals
at the Test Plaintiffs’ Farms

®
In general, Glyphosate is classified as essentially non-toxic to terrestrial (air-breathing, land-
based) animals at any relevant concentrations in the environment (Giesy et al. 2000). Moreover,
in contrast to aquatic life forms with more permeable skin, surfactants do not increase the
toxicity of Roundup of land-based animals because the surfactants do not have the same ability

to penetrate through their skin.

A. Toxicity of Glyphosate for Farm Animals.

®
Glyphosate has repeatedly been found to have low acute, oral or dermal toxicity to mammals
(Giesy et al. 2000; US EPA 1993; WHO 1994). The acute oral dose to be lethal to 50% of the
®
individuals in a population (LD 50has been reported to be greater than 5000 mg Glyphosate a.i
per kilogram body weight (“a.i./kg bw”), and chronic effects during whole-life exposures in
mice, rats and dogs are only observed at continuous exposures greater than 1000 mg
Glyphosate ® /kg (US EPA 1993). There was no dermal sensitization after repeated dermal

3The video also provides significant circumstantial evidence that the alleged fish kills did not in fact occur. Mr.
Mestanza claimed that 80,000 adult tilapia died following the alleged October 2002 spraying event, but there is no
evidence whatsoever of dead fish, or the remains of dead fish, shown in the video. Furthermore, in light of Mr.
Mestanza’s apparent intent to document his alleged damages and his financial resources both as a large scale farmer
and the owner of a transportation business in Guayaquil, there is no reasonable explanation for his failure to have

taken even a single picture to document the fish kill.

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exposures and no long-term inhalation studies are indicated because there was no toxicity
®
observed in sub-chronic exposures of rats. Although most acute toxicity studies of Glyphosate
have been conducted in laboratory animals, two studies in goats have demonstrated similarly low
acute toxicity in large mammals. In one acute oral toxicity study, th50LDf Glyphosate in

goats was c®lculated as 3,500 mg/kg bw, and in a second, the L50was calculated as 5,700 mg
Glyphosate /kg bw. (USDA, 1987b and c, as cited in WHO 1994). Two studies in mallard
ducks (Anas platyrhynchos) demonstrated similarly low toxicity, with one study reporting an

LD 50 4,640 mg kg/bw and a second longer term study reporting a no-effect concentration level
of 1,000 mg kg/bw for ducks fed Glyphosate for a period of 6 months (Hazleton Lab. Inc. 1973,
Wildlife Int. Ltd. 1978, as cited in WHO 1994).

B. Toxicity of Roundup ® for Farm Animals.

®
There have been a number of toxicity studies of Roundup in farm animals, and they have each
demonstrated that Roundup likewise has low toxicity to these animals.

An acute oral toxicity study of Roundup in goats reported an LD50of 4,860 mg/kg bw,
indicating that Roundup® has the same low toxicity to goats as did Glyphosate in the absence of

POEA.

®
In a study ®f the effects of Roundup on chickens, a concentration equivalent to 6080 mg
Glyphosate a.i./kg in the diet caused reductions in growth of chicks but did not cause any
lethality (Kubena et al. 1981). A concentration of 608 mg Glyphosatea.i./kg in the diet did not

have any statistically sig®ificant effects on growth of chicks. Since, even a concentration in the
diet of 6080 mg Glyphosate a.i./kg for 21 days caused no lethality, exposures for a shorter
period of time, would have required even greater doses to have caused any effects and would

have been even less toxic.

®
An acute oral toxicity study ®f Roundup in mallard ducks reported an LD50f 5,620 mg/kg bw, ®
again indicating that Roundup has the same low toxicity (this time in ducks) as did Glyphosate
in the absence of POEA (Wildlife Int. Ltd. 1990, as cited in WHO 1994).

®
When the Roundup formulation was fed for 7 days to Brahman-cross heifers weighing 160 to
272 kg at a rate of 400, 500, 630 or 790 mg Roundup /kg body weight per day by naso-gastric

tube, there was no effect on heifers fed 400 mg/kg bw in the diet, and there was no mortality
seen until a dose of 790 mg/kg bw dose. The deaths were associated with labored breathing and
pneumonia caused by aspiration of the rumen contents (WHO 1994). This finding was more
®
likely caused by the physical volume of the Roundup ingested than to any toxic effects of the
herbicide.

The results of incident reports of accidental poisoning of domestic and farm animals provides
useful collateral information in the assessment of the potential of Glyphosate-based herbicidal

mixtures to cause lethality. A retrospective assessment of all phone calls received from 1991-
1994 in four animal poison centers is instructive (Burgat et al. 1998). During this three year
period, the poison centers received 482 calls about Glyphosate but only 31 of the calls were
®
assessed as sure or probable cases of Glyphosateintoxication. Of these, 25 exposures were in

451Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 19 of 319

dogs that likely drank concen®rated mixes of the herbicide formulation. There were only two
reported cases of Glyphosate intoxication in farm animals, one in a cow and one in a horse.
None of the animals died. Rather, the predominant clinical finding in the exposed animals was
spontaneous vomiting that occurred a few minutes or 1-2 hours after ingestion of a concentrated

preparation of the herbicide (i.e. before it was mixed with water). This finding suggests that the
initial response of animals exposed to potentially toxic concentrations of Glyphosates to vomit
and thus minimize exposure. If the exposure is not sufficient to cause vomiting, it is also likely

that it would ®ot cause symptoms of toxicity and certainly not death. In fact, in 6 of the 31 cases
of Glyphosate intoxication there were no clinical signs of poisoning whatsoever which further
confirms the low toxicity of Glyphosate® formulations to mammals. In a more recent,

comprehensive review of reported poisoning in farm livestock and poultry in five European
countries over the past decade, there is no mention whatsoever of any poisonings involving
Glyphosate ® (Guitart 2010).

C. Toxicity of Plan Colombia Herbicide for Farm Animals.

I am not aware of any studies of the toxicity of the Plan Colombia herbicide mix specifically in

farm animals, but studies of the acute toxicity of the Plan Colombia mixture in laboratory
animals indicate that it has the same low toxicity in terrestrial (land-based) animals as
Glyphosate ® and Roundup .®

D. Hazard Assessment for Farm Animals Allegedly Exposed to Plan Colombia
Herbicide.

I have conducted a hazard assessment for ducks, goats and cows, the three farm animals at issue
in this case for which we have specific LD50data. As noted above, there is also acute toxicity

data for chickens, but no mortality was seen at the highest dose tested. While it is thus
impossible to conduct a hazard assessment for chickens, the hazard presented to chickens would
be less than that for ducks, which have a lower (albeit still very high50LD

1. Exposure Assessment.

Because no measurement were made of concentrations of Glyphosate ® or associated adjuvants in

air or on the soil, let alone in the tissue of any of the alleged deceased farm animals, estimates of
potential exposure need to be generated. As with the exposure assessment for tilapia and
cachama above, I have prepared a conservative Tier 1 assessment, assuming as a worst case

scenario, that the farm animals were maximally exposed through a direct overspray and were
further exposed through consumption of directly over-sprayed plant life.

For exposure via overspray, I have assumed that Glyphosate ® penetrated through the animal skin

with a maximum penetration of 2% (Solomon 2007; Williams 2000). While this is a reasonable
assumption for pigs, it is a very conservative assumption for the other allegedly impacted farm
animals (cows, horses, goats, chickens, ducks) because those animals have body hair or feathers
®
that would have minimized penetration of the Glyphosate through the skin.

452 Annex 12

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For exposures via plant consumption, I assume that the Plan Colombia herbicide mix remains
fully available in the leaves and edible portions of the plant, which is again an overly
conservative assumption.

i. Ducks

2
If a duck is ass2med to have (0.25 m) of dorsal surface area, and the application rate is assumed
to be 0.369 g/m , the intercepted dose would be a total of 0.023 g. If an average absorption of
2% is applied, the absorbed dose would be 0.00046 g or 0.46 mg. Assuming an average weight
of 1 kg, the absorbed dose would be 0.46 mg/kg bw.

ii. Goats

2 2
If a goat is assumed to have 1 m of dorsal surface area, and the application rate is 0.369 g/m ,
the intercepted dose would be a total of 0.369 g. Applying an average absorption of 2%, the
absorbed dose would be 0.0074 g or 7.4 mg. Assuming an average weight of 75 kg, the absorbed

dose would be approximately 0.098 mg/kg bw.

iii. Cattle

2
Cattle have a body mass of between 500 and 800 kg. Assuming a dorsal surface area of (2 m)
and a direct over-spray with an application rate of 0.369 g/m 2, a cow would receive a total
intercepted dose of 1.476 g and a total absorbed dose (assuming 2% absorption) of 0.029 g or 29

mg, which for the smaller cow would be the equivalent of 0.058 mg/kg bw and for the larger cow
would be 0.03625 mg/kg bw.

2. Hazard Assessment.

i. Ducks

®
Based upon an estimated dose of 0.46 mg/kg bw and a LD for Ro50dup of 5,620 mg kg/bw,
the HQ for a single overspray would be 8.2 x 10 -5(0.46/5,620) with a margin of safety of 12,217.
®
Using ins-5ad the Glyphosate LD of 45040 mg/kg bw, the HQ for a single over-spray would be
9.9 x 10 (0.46/5,620) with a margin of safety of 10,086. In other words, ducks would have to
be directly over-sprayed between 10,086 and 12,217 times before one would see 50% mortality.
.

i i. Goats

Based on an estimated dose of 0.098 mg/kg bw and LD-50 of 4,860 mg/kg bw. The HQ for
-5
goats exposed to a single over-spray would be 2.0x10 (0.098/4,860) with a margin of safety of
49,592. Said another way for the Plan Colombia herbicide to be lethal to a goat (or more
precisely 50% of goats), the goat would need to be sprayed with the equivalent of 49,592 over-

sprays.

Because goats might also be exposed to Plan Colombia herbicide through dietary exposure to
over-sprayed plant life, I have also considered the possibility of lethal exposures through that

453Annex 12

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alternate route. As a worst case scenario, I have assumedthat during an aerial application that all
of the Roundup was deposited on leaves of edible plants. To achieve a dose of 4,860 mg/kg a
75 kg goat would need to consume a total of 364,500 mg of a.i. Glyphosate ®. At an application
2 2
rate of 0.369 g/m a goat would need to eat the equivalent of 987.8 m of vegetation and or soil.
To calculate the weight of vegetation in a square meter, I have used ratio between the weight-to-
area for spinach leaves, which has been reported to be between 26.5 and 40.88 g/m (McLaughlin

1929). Based on this relationship, a goat would need to eat a minimum of 26.17 kg in the period
of a day to reach the LD 50amount. In fact goats eat about 5% of their body weight in food per
day or about 3.75 kg of food per day and can easily survive on as little as 1.0 kg of food/day.

Thus, goats would have needed to have eaten at least 7.0 times their maximum daily rate of food
consumption to reach the LD 50 In this assessment I have assumed that all of the sprayed Plan
Colombia mix was deposited directly on edible vegetation and that goats ate a 100% diet of

maximally contaminated vegetations. This is an extremely conservative scenario, and still there
is no chance that a goat would be killed from dietary exposure. From this analysis, I conclude
that it would have been impossible for goats to have been killed by the worst case situation of a

direct over-spray with Plan Columbia herbicidal mix.

i ii. Cattle

For adult cattle in the size range of 500 to 800 kg, with an estimated dermal dose of 0.03625 and
0.058 mg/kg bw for the 500 and 800 kg cattle, respectively, the HQ based on an LD 50of 790 mg
-5 -5
kg bw, would be 4.58 x10 and 7.34 x10 , for the smaller and larger cattle, respectively. The
margin of exposures for the smaller and larger cattle would be 21,793 and 13,621 respectively.
That is, to be killed (or for 50% to be killed) the smaller and larger cattle would have need to

have been over-sprayed with the equivalent of 21,793 and 13,621 over-sprays using the standard
Plan Colombia herbicidal mixture.

I have also conducted a hazard assessment for potential dietary exposure in cattle. Cattle eat
between 2 and 5% of their body weight in food each day. Thus, if the maximum consumption
rate of 5% is assumed, a cow would eat approximately 25 to 40 kg of food per day, depending on

body mass. Assuming the larger cow (800 ®g) and a LD of 7950mg/kg bw, a cow would need
to consume 632,000 mg of Glyphosate a.i. To accumulate this dose under the conservative
assumption of direct overspray with 100% retention of Glyphosate in the edible portion of the
plants and a diet comprised of 100% Glyphosate ® sprayed crops, a cow would need to eat the
2 2
equivalent of 1,712 m of vegetation. Assuming a conversion rate of 40.88 g/m , this would be a
consumption rate of 69.98 kg, which would be between two and three times the cattle’s daily
consumption of food. As with the analysis for goats, even under this unrealistic consumption

scenario, it would be impossible for cattle to die as a result of ingestion of plants sprayed with
Plan Colombia herbicide.

As with the hazard assessment for tilapia and cachama above, the hazard assessment for farm
animals should also be considered in light of the video evidence presented by Mr. Mestanza,
which makes clear that there was not even a single overspray of Plan Colombia herbicide on his

farm, let alone thousands. At an even more fundamental level, the Mestanza video directly
contradicts Mr. Mestanza’s claims that his farm animals were killed by Plan Colombia herbicide,
as the video is replete with pictures of apparently healthy pigs, cattle, sheep and chickens, as well

454 Annex 12

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as three apparently healthy baby goats that were reportedly born just days before the video was
taken.

VI. Conclusion

For the reasons stated herein, there is no scientific basis to opine that Plan Colombia
herbicide sprayed in Colombia would have been transported via soil or water across the border
into Ecuador. There is also no scientific basis to conclude that Plan Colombia herbicide could
have caused the deaths of tilapia, cachama, and farm animals alleged by the plaintiffs. Indeed, as

my analysis above makes clear, the plaintiffs’ allegations are scientifically impossible.

Date: _January 11, 2011 ____

_________________________
John P. Giesy, Ph.D., FRSC

▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

455Annex 12

Case 1:07-cv-01DocumentFiled 0Page 311 of 319

Exhibit B
Dr. John Giesy Expert Report
Materials Considered

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 312 of 319

Exhibit B

John Giesy Expert Report

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Glyphosate (Glyphos) and Cosmo-Flux to Larval Colombian Frogs 1, Journal of

Toxicology and Environmental Health, Part A, 72:15, 961- 965
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Glyphosate (Glyphos) and Cosmo-Flux to Larval Colombian Frogs 2, Journal of
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23)Kubena L.F. & Smalley H.E. (1981) Influence of Glyphosate (N (phosphonomethyl)
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25)Lynch J.D. & Arroyo S.B., (2009) Risk to Colombian Amphibian Fauna from Cultivation
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Coast Range, Env. Sci. Pollut. Res., 15(3): 266-272
29)McLaughlin L. (1929) The Relation of Vitamin a Content to Size of Leaves, Journal of
Biological Chemistry, 84: 249-256
30)Mullin L., Ader A., Daughtrey W., Frost D. & Greenwood M. (1990) Toxicology Update
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Human Exposure Data, J. Applied Toxicol., 10(2): 135-142
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32)Ramirez W., Rondon I., Vidal H. & Eslava P. (2009) Acute Toxicity and
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35)Rondon-Barragan I., Ramirez-Duarte W. & Eslava-Mocha P. (2007) Evaluacion De Los
Efectos Toxicos y Concentración Letal 50 Del Surfactante Cosmoflux 411F Sobre
Juveniles de Cachama Blanca (Piaractus brachypomus)[Assessment of Toxic Effects and
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(Piaractus brachypomus)] , Rev. Col. Cienc. Pec., 20: 431-446

36)Rueppel M.L., Brightwell B.B., Schaefer J. & Marvel J.T. (1977) Metabolism and
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Animals: A Literature Review, Vet. Hum. Toxicol., 34(6): 531-543
38)Solomon K., Anadon A., Cerdeira A., Marshall J. & Sanin L. (2007) Environmental and
Human Health Assessment of the Aerial Spray Program for Coca and Poppy Control in
Colombia, Rev. Envtl. Contam. Toxicol., 190: 43-125
39)Solomon K., Marshall E.J.P & Carrasquila G. (2009) Human Health and Environmental

Risks from the Use of Glyphosate Formulations to Control the Production of Coca in
Colombia: Overview and Conclusions, J. Toxicol. Envtl. Health, Part A, 72: 15, 914-920
40)Van Compernolle R., McAvoy D.C., Sherren A., Wind T., Cano M.L., Belanger S.E.,
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ethoxylates to effluent and receiving water solids, Ecotoxicology and Environmental

Saftey, 64: 61-74
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Water Hyacinth, Water, Air and Soil Pollution, 74: 397-403
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Herbicide Roundup and Its Active Ingredient, Glyphosate, for Humans, Regulatory
Toxicology and Pharmacology, 31:117-165

Other Materials Considered

1) Agrarian University of Ecuador Faculty of Agrarian Sciences,Lab Analyses of Plants
and Soil, (unpublished Lab Test Results, Ecuador: Agrarian University of Ecuador) (July

17, 2003)
2) Agriculture Canada (1991) Pre-harvest use of glyphosate herbicide. Discussion
Document. November 27. Pesticides Directorate, Ottawa, Ontario.
3) Banduhn M.C. & Frazier H.W. (1974) G 3780A surfactant: biodegradation in natural
waters. Unpublished report no. MSL-0488. Monsanto.

4) Boletín De Prensa No. 443, Republica Del Ecuador [Republic of Ecuador] (Aug. 26,
2004),http://www.mmrree.gov.ec/mre/documentos/novedades/boletines/ano2004/ago…
bol480.htm
5) Boletín De Prensa No. 480, Republica Del Ecuador [Republic of Ecuador] (Aug. 26,
2004),http://www.mmrree.gov.ec/mre/documentos/novedades/boletines/ano2004/ago…

bol480.htm
6) Boletín De Prensa No. 338, Republica Del Ecuador [Republic of Ecuador] (June 25,
2004),http://www.mmrree.gov.ec/mre/documentos/novedades/boletines/ano2004/jun…
ol388.htm

458 Annex 12

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7) Bernal G., Technical Report on Visit to the Province of Sucumbíos (border with
Colombia), (unpublished Technical Report, Colombia: CCTE.) (February 29, 2004)
8) Bonnette K. L., An Acute Dermal Toxicity Study in Rats with Spray – Charlie,
(unpublished Study Report, Spencerville: Springborn Laboratories) (February 20, 2003a)
9) Bonnette K.L., An Acute Dermal Toxicity Study in Rats with Spray – Charlie,

(unpublished Amended Study Report, Spencerville: Springborn Laboratories) (March 17,
2003b)
10)Bonnette K.L., An Acute Nose-Only Inhalation Toxicity Study in Rats with Spray –
Charlie, (unpublished Study Report, Spencerville: Springborn Laboratories) (March 14,

2003c)
11)Bonnette K.L., An Acute Oral Toxicity Study in Rats with Spray – Charlie, (unpublished
Study Report, Spencerville: Springborn Laboratories) (February 20, 2003d)
12)Bonnette K.L., A Dermal Sensitization Study in Guinea Pigs with Spray -- Charlie
(Modified Buehler Design), (unpublished Study Report, Spencerville: Springborn

Laboratories) (March 14, 2003e)
13)Bonnette K.L., A Primary Eye Irritation Study in Rabbits with Spray – Charlie,
(unpublished Study Report, Spencerville: Springborn Laboratories) (February 17, 2003f)
14)Bonnette K. L., A Primary Skin Irritation Study in Rabbits with Spray – Charlie,
(unpublished Study Report, Spencerville: Springborn Laboratories) (February 17, 2003g)

15)Bonnette K.L., Purity Analysis for Glyphosate of Spray – Charlie (Active Ingredient),
(unpublished Study Report, Spencerville: Springborn Laboratories) (March 21, 2003h)
16)Bureau for International Narcotics and Law Enforcement Affairs, U.S. State Department.
(July 2003) Evaluation of the Effects of Glyphosate on Human Health in Illicit Crop

Eradication Program Influence Zones. p. 27. (Attachment 1 to Memorandum of
Justification Concerning the Secretary of State's 2004 Certification of Conditions Related
to the Aerial Eradication of Illicit Coca and Opium Poppy in Colombia),
http://www.state.gov/p/inl/rls/rpt/aeicc/57013.htm
17)Bureau for International Narcotics and Law EnforcementAffairs, U.S. State Department.

(2003) Certification of Glyphosate and AMPA Residue Analyses.(Attachment 2 to
Memorandum of Justification Concerning the Secretary of State's 2007 Certification of
Conditions Related to the Aerial Eradication of Illicit Coca in Colombia) (2003-2007)
18)Bureau for International Narcotics and Law Enforcement Affairs, U.S. State Department.
(May 12, 2004) Letter from Government of Colombia’s Augustin Codazzi Geographic

Institute’s National Soils Laboratory Division to the Narcotics Affairs Office.
(Attachment 2.7.b. to Memorandum of Justification Concerning the Secretary of State's
2004 Certification of Conditions Related to the Aerial Eradication of Illicit Coca and
Opium Poppy in Colombia), http://www.state.gov/p/inl/rls/rpt/aeicc/57037.htm
19)Bureau for International Narcotics and Law Enforcement Affairs, U.S. State Department.

(April 12, 2005) Protocol for Water Sampling for Glyphosate and AMPA Residue
Analysis. (Attachment 2.8. to Memorandum of Justification Concerning the Secretary of
State's 2004 Certification of Conditions Related to the Aerial Eradication of Illicit Coca
and Opium Poppy in Colombia), http://www.state.gov/p/inl/rls/rpt/aeicc/44534.htm

20)Bureau for International Narcotics and Law Enforcement Affairs, U.S. State Department.
(April 12, 2005) Protocol for Soil Sampling for Glyphosate and AMPA Residue
Analysis. (Attachment 2.9. to Memorandum of Justification Concerning the Secretary of

459Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 316 of 319

State's 2004 Certification of Conditions Related to the Aerial Eradication of Illicit Coca

and Opium Poppy in Colombia), http://www.state.gov/p/inl/rls/rpt/aeicc/44532.htm
21)Bureau for International Narcotics and Law Enforcement Affairs, U.S. State Department.
(July 26, 2004) Government of Colombia’s Ministry of Environment, Housing, and
Territorial Development Ruling No. 707. (Attachment 5 to Memorandum of Justification
Concerning the Secretary of State's 2004 Certification of Conditions Related to the Aerial

Eradication of Illicit Coca and Opium Poppy in Colombia),
http://www.state.gov/p/inl/rls/rpt/aeicc/44538.htm
22)Colombia Soil and Water Test Results Received by the USDA on 12/05/03 and 01/05/04,
(Attachment 2.7.a. to Memorandum of Justification Concerning the Secretary of State's
2004 Certification of Conditions Related to the Aerial Eradication of Illicit Coca and

Opium Poppy in Colombia), http://www.state.gov/documents/organization/57138.xls
23)Cosmoagro (2003) Cosmo-Flux 411F Saftey Information Sheet. Cosmoagro S.A.
Accessed November 29, 2010. www.cosmoagro.com English Translation
24)Cruz O.S. (2002) Glifosato 5% + Cosmoflux 1% + Agua 94%, (unpublished

Toxicological Study Report, Colombia: Immunopharmos LTDA.)
25)Cruz O.S. (2002) Glifosato 44% + Cosmoflux 1% + Agua 55%, (unpublished
Toxicological Study Report, Colombia: Immunopharmos LTDA.)
26)DOS 2002, Chemicals Used for the Aerial Eradication of Illicit Crops in Colombia and
Conditions of Application: Report on Issues Related to the Aerial Eradication of Illicit

Coca in Colombia (INL, Sept. 2002), available at
http://www.state.gov/p/inl/rls/rpt/aeicc/13234.htm.
27)Ecuadorian Scientific-Technical Commission, Ecuadorian Atomic Energy Commission:
Ecotoxicology Residue Analysis Laboratory, (unpublished Analytical Report, Ecuador:
CEEA Ecotoxicology Lab.) (Aug. 16, 2004)

28)Ecuadorian Scientific-Technical Commission, Ecuadorian Atomic Energy Commission:
Ecotoxicology Residue Analysis Laboratory, (unpublished Analytical Report, Ecuador:
CEEA Ecotoxicology Lab.) (June 11, 2004)
29)English Transcription of Test Plaintiff Victor Mestanza's 2002 Video
30)English Transcription of Test Plaintiff Victor Mestanza's 2009 Video

31)Environment Canada. 1997. Environmental assessments of Priority Substances under the
Canadian Environment Protection Act. Guidance manual Version 1.0 - March 1997.
Environmental Protection Series. Commercial Chemicals Evaluation Branch,
Environment Canada (EPS/2/CC/3E).

32)Excerpts of Test Plaintiff Victor Mestanza Deposition Transcript, Volume I, November 9,
2009
33)Excerpts of Test Plaintiff Victor Mestanza Deposition Transcript, Volume II, November
10, 2009
34)Exhibit 2-C to Test Plaintiff Victor Mestanza’s Deposition Transcript, November 9, 2009

35)Exhibit 2-E to Test Plaintiff Victor Mestanza’s Deposition Transcript, November 9, 2009
36)González J., Ochoa D., Figueredo D. & González C., Efectos Tóxicos Del Glifosato en
Juveniles De Tilapia Roja (Oreochromis sp.), Yamú (Bryconamazonicus) y Bocachico
Del Magdalena (Prochilodus magdalenae [Toxic Effects of Glyphosate on youthful Red
Tilapia(Oreochromis sp.), Yamu (Bryconamazonicus), and Bochachico Del Magdalena

(Prochilodus magdalenae)], (unpublished PowerPoint Presentation, Grupo de
Investigación en Toxicología Acuática y Ambiental [Investigation Group in Acuatic and

460 Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 317 of 319

Environmental Toxicology]:Universidad Nacional de Colombia [National University of

Colombia])
37)Letter from Stephen Johnson, Assistant Adm’r., U.S. EPA, to Colin Powell, Sec’y of
State, U.S. Dep’t of State, (August 19, 2002),
http://www.state.gov/p/inl/rls/rpt/aeicc/13237.htm
38)Letter and Consultation Report from Michael Leavitt, Assistant Adm’r., U.S. EPA, to

Colin Powell, Sec’y of State, U.S. Dep’t of State, (November 17, 2004),
http://www.state.gov/p/inl/rls/rpt/aeicc/57040.htm
39)Letter from Michael Leavitt, Assistant Adm’r., U.S. EPA, to Colin Powell, Sec’y of
State, U.S. Dep’t of State ( November 17, 2004), (Attachment 3 to Memorandum of
Justification Concerning the Secretary of State's 2004 Certification of Conditions Related

to the Aerial Eradication of Illicit Coca and Opium Poppy in Colombia),
http://www.state.gov/p/inl/rls/rpt/aeicc/57040.htm
40)Letter from Anna Cristina Velez, Directora General de Salud Publica [Managing Director
of Public Health], Ministerio de la Protección Social [Ministry of Social Protection], to

Mario Enrique Falla, Subdirector de Asuntos Regionales y Erradicación [Subdirector of
Regional Affairs and Eradication], Dirección Nacional de Estupefacientes [National
Administration of Narcotics], (May 2, 2004)
41)Letter from Isabel Cristina Buitrago, Directora General de Salud Publica [Managing
Director of Public Health], Ministerio de Salud [Ministry of Health], & Hernan Gonzalez,

Profesional Especializado [Specialized Professional], Ministerio de Salud [Ministry of
Health], to Carlos Herrera, Coordinador Registro y Control Pleguicidas Quimicos
[Registration and Pesticide Chemical Control Coordinator], Instituto Colombiano
Agropecuario [Colombian Agricultural and Farming Institute], (March 14, 2002)
42)McLaren/Hart Environmental Engineering Corporation, Use of the Registered Aquatic

Herbicide Flouride (Sonar) and the Use of the Registered Aquatic Herbicide Glyphosate
(Rodeo and Accord) In the State of New York, (January 10, 1995)
43)Memorandum from Colin Powell, Sec’y of State, U.S. Dep’t of State, to the U.S.
Congress (2004), http://www.state.gov/p/inl/rls/rpt/aeicc/57012.htm
44)Memorandum from U.S. Bureau for International Narcotics and Law Enforcement

Affairs, U.S. Dep’t of State (July 26, 2004), (Attachment 2 to Memorandum of
Justification Concerning the Secretary of State's 2004 Certification of Conditions Related
to the Aerial Eradication of Illicit Coca and Opium Poppy in Colombia),
http://www.state.gov/p/inl/rls/rpt/aeicc/44451.htm

45)Memorandum from Colin Powell, Sec’y of State, U.S. Dep’t of State, to the U.S.
Congress (August 10, 2007), http://www.state.gov/p/inl/rls/rpt/aeicc/111210.htm
46)Mocha P., Sobre los Efectos Del Glifosato y Sus Mezclas: Impacto en Peces Nativos
[About the Effects of Glyphosate and Its Mixtures: Impact on Native Fish] (Universidad
de los Llanos [Univ. of Llanos] ed., 2007)

47)Monitoring – Verification Sampling on Glyphosate and AMPA Since Year 2003. Soil
and Water Sampling. 2 p. (Attachment 2 to Memorandum of Justification Concerning the
Secretary of State's 2007 Certification of Conditions Related to the Aerial Eradication of
Illicit Coca in Colombia) (2003-2007)
48)Original and Translation of Plant Lab Report for Chone 2, Ecuador and Vereda Nueva

Granada, Colombia and translation of soil lab report for Chone 2, Playera Oriental,

461Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 318 of 319

Ecuador, and Vereda Nueva Granada, Colombia, Accion Ecologica website, October 9,
2002
49)Original and Translation of Soil Report at Puerto Meztanza by Agrarian University of
Ecuador Faculty of Agrarian Sciences. July 17, 2003.
50)PLS00005881 Disk with Victor Mestanza's 2002 Video

51)PLS00005882 Disk with Victor Mestanza's 2009 Video
52)Product information website page: Cosmo-Flux 411F, Cosmoagro S.A. (November 29,
2010) www.cosmoagro.com
53)Scribner E., Battaglin W., Dietze J. & Thurman E.M., Reconnaissance Data for

Glyphosate, Other Selected Herbicides, Their Degradation Products, and Antibiotics in
51 Streams in Nine Midwestern States, 2002, (U.S. Geological Survey Toxic Substances
Hydrology Program ed., 2002)
54)Soil Analytical Report of Puerto Mestanza. "Santa Catalina" Experimental Station Soil
and Water Management Laboratory. November 2004.

55)Stantec Consulting Ltd., Mixture of Glyphosate and Cosmo-Flux 411F: Growth
Inhibition Test With the Freshwater Green Alga, Selenastrum Capricornutum, (March
2005 a) (unpublished Study Report, Guelph, ON, Canada: Stantec)
56)Stantec Consulting Ltd., Mixture of Glyphosate and Cosmo-Flux 411F: Acute Contact
Toxicity to Daphnia magna, (March 2005 b) (unpublished Study Report, Guelph, ON,

Canada: Stantec)
57)Stantec Consulting Ltd., Mixture of Glyphosate and Cosmo-Flux 411F: Acute Contact
Toxicity to Fathead Minnows, (March 2005 c) (unpublished Study Report, Guelph, ON,
Canada: Stantec)

58)Stantec Consulting Ltd., Mixture of Glyphosate and Cosmo-Flux 411F: Acute Toxicity to
Rainbow Trout, (March 2005 d) (unpublished Study Report, Guelph, ON, Canada:
Stantec)
59)Stantec Consulting Ltd., Acute Contact Toxicity of Glyphosate/Cosmo-Flux Mixture to
Honey Bees, (March 2005 e) (unpublished Study Report, Guelph, ON, Canada: Stantec)

60)Stantec Consulting Ltd., Mixture of Glyphosate and Cosmo-Flux 411F: Acute Contact
Toxicity to Honey Bee (Apis mellifera), (January 2006 f) (unpublished Amended Study
Report, Guelph, ON, Canada: Stantec)
61)Stantec Consulting Ltd., Mixture of Glyphosate and Cosmo-Flux 411F: Acute Contact
Toxicity to Honey Bee (Apis mellifera), (March 2005 g) (unpublished Study Report,

Guelph, ON, Canada: Stantec)
62)Stantec Consulting Ltd., Glyphosate and Cosmoflux Mixture, (September 2004 h)
(unpublished Definitive Test Concentrations, Guelph, ON, Canada: Stantec)
63)Technical Report on Visit to the Province of Sucumbios, Puerto Mestanza. February
2004.

64)Test Plaintiff Victor Mestanza Deposition Transcript, Volume 1, November 9, 2009
65)Test Plaintiff Victor Mestanza Deposition Transcript, Volume 2, November 10, 2009
66)USDA (U.S. Department of Agriculture) (1989) Final environmental impact statement:
vegetation management in the Coastal Plain/Piedmont. Appendices, Volumes I and II.

United States Department of Agriculture, Forest Service Southern Region. Management
Bulletin R8-MB-23, January 1989.
67)USDA (U.S. Department of Agriculture) (1992) Environmental assessment: vegetation
management in confier plantations. Placerville Ranger District, Eldorado National Forest.

462 Annex 12

Case 1:07-cv-01042-RWR -DAR Document 220-6 Filed 08/19/11 Page 319 of 319

United States Department of Agriculture, Forest Service, Pacific Southwest Region. No.
PL-92-2.
68)USDA (U.S. Department of Agriculture) (1996) Herbicides and wildlife habitat (1954-
1996). United States Department of Agriculture, Forest Service Southern Region.
Technical Publication R8-TP 13. Revised September 1996.

69)USDA (U.S. Department of Agriculture) (1997) Final environmental impact statement:
vegetation management on electric utility rights-of-way. Allegheny National Forest, U.S.
Department of Agriculture -- Forest Service, May 1997.
70)USDI (U.S. Department of the Interior) (1989) Final environmental impact statement:

western Oregon program-management of competing vegetation. United States
Department of the Interior, Bureau of Land Management. BLM-OR-ES-89-1-1793.
February 1989.
71)U.S. EPA (1993) Reregistration eligibility decision (RED): Glyphosate. Environmental
Protection Agency, Office of Prevention, Pesticides and Toxic Substances, Washington,

DC.
72)U.S. EPA, Office of Pesticides Programs, Details of the 2003 Consultation for the
Department of State: Use of Pesticide for Coca and Poppy Eradication Program in
Colombia, (June 2003)
73)Washington State DOT (Department of Transportation) (1993) Final environmental

impact statement: roadside vegetation management, Appendix B, (Draft). Washington
State Department of Transportation, February 1993.
74)WHO (World Health Organization) (1994) Glyphosate: Environmental health criteria
159. World Health Organization, Geneva, Switzerland.

http://www.inchem.org/documents/ehc/ehc/ehc159.htm

463464 Annex 13

EXPERT R EPORT OFDR R.D. SMALLIGAN, M.D., M.P.H.PREPARED
FOR THE DEFENDANTS INARIAS/QUINTEROS . DYNCORP(D.D.C.),

19 JANUARY 2011

465466 Annex 13

Case 1:07-cv-DocumenFiled Page 1 of 62

EXHIBIT 12

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 2 of 62

EXPERT R EPORT OF
DR .R OGER D. SMALLIGAN , M.D., M.P.H.
P REPARED FOR THE D EFENDANTS

INA RIAS /QUINTEROS V .D YN C ORP (D.D.C.)

Table of Contents

EXPERT CREDENTIALS & EXPERIENCE........................................................................... 1

STATEMENT OF COMPENSATION....................................................................................... 4

PRIOR TESTIMONY..................................................................................................................4

SUMMARY OF EXPERT OPINIONS....................................................................................... 4

THERE IS A HIGH BACKGROUND INCIDENCE OF DISEASE IN THE
COMMUNITIES IN WHICH THE TEST PLAINTIFFS LIVE, WHICH IS
CAUSED BY THE TROPICAL ENVIRONMENT IN THE BORDER REGIONS

OF SUCUMBIOS AND ESMERALDAS AND BY THE LACK OF MANY BASIC
AMENITIES, SUCH AS CLEAN WATER, INDOOR PLUMBING, ADEQUATE
HOUSING, PUBLIC SANITATION, HEALTHY DIET, AND AVAILABILITY

OF MEDICAL CARE ...................................................................................................................5

THE MEDICAL PROBLEMS IDENTIFIED BY THE TEST PLAINTIFFS ARE
ENDEMIC TO THE REGION, WITHOUT REGARD TO ANY ALLEGED

EFFECT OF PLAN COLOMBIA HERBICIDE SPRAY .........................................................7

Gastrointestinal problems................................................................................................ 7

Skin problems....................................................................................................................8

Respiratory problems....................................................................................................... 8

Eye problems.....................................................................................................................9

PLAINTIFFS HAVE NOT PROVIDED ANY EVIDENCE THAT WOULD
ALLOW A MEDICAL EXPERT TO RELIABLY OPINE THAT PLAN

COLOMBIA HERBICIDE SPRAY WAS A CAUSE OF ANY OF THE TEST
PLAINTIFFS’ ALLEGED MEDICAL CONDITIONS OR TO EXCLUDE THE
ENDEMIC HEALTH RISKS IN THE REGION AS THE TRUE CAUSE OF

THEIR ALLEGED PERSONAL INJURIES............................................................................10

Quevedo Family .............................................................................................................. 11

467Annex 13

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468 Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 4 of 62

EXPERT CREDENTIALS & EXPERIENCE

My name is Roger D. Smalligan, and I submit this report on behalf of the DynCorp
defendants in the Arias/Quinteros v. DynCorp (D.D.C.) litigation. I am a medical doctor, board
certified in both Internal Medicine and Pediatrics and a Fellow of both the American College of

Physicians and the American Academy of Pediatrics. I am the Regional Chair of the
Department of Internal Medicine at Texas Tech University Health Sciences Center in Amarillo,
Texas and have been in this position for the past year and a half. Prior to coming to this position,
I spent five years in the Departments of Internal Medicine and Pediatrics at the East Tennessee
State University School of Medicine in Johnson City, TN, having been promoted to the Division

Chief of General Internal Medicine before taking my current position. I also serve as the Health
Authority for the City of Amarillo, Texas.

My goal as a young person was to work in a developing country where my medical skills
could help the poor. Therefore, I pursued my medical degree at Johns Hopkins University
(1983-1987) followed by a broad residency in both Internal Medicine and Pediatrics at

Vanderbilt University (1987-1991). After residency I felt the need to further prepare for my
planned work in the developing world, and I then pursued a Masters in Public Health (“MPH”) at
the Johns Hopkins University School of Hygiene and Public Health with an emphasis in
International Health and Epidemiology (1992-1993). This training was ideal for the type of
medical care I would soon be called upon to deliver, as it introduced me to the diseases that are

prevalent in developing countries around the world (such as Ecuador).

During the year that I worked toward my MPH, I learned of a rural Christian mission
hospital in Ecuador that was in need of a physician and began to communicate with them about
joining their efforts. Shortly after finishing my MPH, I (along with my wife and young baby)

traveled to Ecuador and spent a month in the Amazon jungle region of Ecuador at the Hospital
Vozandes del Oriente in Shell, Pastaza, Ecuador (“Shell Hospital”), a busy rural mission
teaching hospital. In that visit I worked on call and covered the emergency room as a physician
and teacher. This month-long experience confirmed my desire to work in that setting, where the
need was so great. However, before beginning full time in Ecuador, further preparation was

required, including raising funds from friends, family, churches and other organizations to allow
intensive study of medical Spanish (for one year in Costa Rica). Following these additional
preparations, I returned to Ecuador in 1996 and spent the next 8.5 years (1996-2004) as staff
physician and then medical director of the Shell Hospital.

At the Shell Hospital, we typically cared for between 10,000-13,000 patients per year.

Due to its location in the tropical rainforest, the extreme poverty of the population, lack of public
health infrastructure and financing, and lack of general medical care, many patients come to the
Shell Hospital for treatment for significant medical problems, many of which are tropical
diseases. The Shell Hospital has the benefit of constantly receiving donations of medications
and updated medical equipment from the U.S. and Europe and for this reason it was utilized as a

referral hospital for the entire region. Patients most commonly came from provinces contiguous
with Pastaza but it was not uncommon to have patients from further away (e.g., Sucumbios and
Esmeraldas), sometimes after having bypassed large cities with advanced medical care available
at a significant cost.

469Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 5 of 62

My role at the Shell Hospital during my first years was as a staff physician, which
involved interviewing, examining, and caring for the many patients – including children and
adults – who came seeking care. These first months and years provided advanced, on-the-job

training in the area of tropical medicine. I also spent a significant amount of time in the local
communities including the small towns and villages. It was helpful to me to see the living
conditions of my patients and I would occasionally fly deep into the jungle to evaluate an
outbreak of disease or to help with a public health brigade. Living conditions varied from

completely primitive in the jungle without water or electricity to simple poverty conditions in the
nearby towns. It was not uncommon for me to be invited for a meal in a local person’s home and
these experiences helped me understand the risks of various diseases and more astutely diagnose
their conditions when they came to the clinic or the hospital.

In my first years at the Shell Hospital, I also daily taught the medical students and

residents on rotation with us about general medicine and tropical medicine. I would regularly
participate in evaluations of these trainees and send letters of evaluation to U.S. universities as
required by visiting students’ and residents’ programs. I was also actively involved in research
projects throughout my years there, including a randomized study of various snakebite
treatments (eventually published in the British Medical Journal) and an emerging infectious

diseases research project sponsored by the US Navy (recently published in the American Journal
of Tropical Medicine and Hygiene).

After approximately three years as staff physician I was asked to serve as the medical
director of Shell Hospital. In this role I continued with my full clinical load but also began to
participate in regional meetings of the Ministry of Public Health for the Ecuadorian government.

These meetings involved joint planning between health outposts, facilities and hospitals
regarding appropriate responses to emergencies and disasters. During my time there, for
example, our town received a number of refugees fleeing a large eruption of the Tungurahua
volcano located about 40 miles away. We also collaborated with the health department in
coordinating and manning flights to the jungle to provide vaccinations and disease outbreak

evaluations. Health systems planning was discussed at these meetings and there was interest in
my input due to the reputation of the Johns Hopkins School of Hygiene and Public Health where
I had studied public health.

Obtaining a medical license in Ecuador is complicated and time consuming for expatriate

physicians. Fortunately, I was granted permission by the Ecuadorian government to practice
medicine in rural Ecuador, due to the great need there, while working on the many legal and
additional educational requirements necessary to have my medical degree recognized. After five
years, I was ultimately granted a Doctor of Medicine degree from the Catholic University of
Quito, Ecuador, and today I have an unrestricted license to practice medicine in Ecuador.

Based upon my training and experience, I consider myself an expert in tropical medicine,
generally, and the practice of tropical medicine in Ecuador, specifically. At Shell Hospital I
personally diagnosed and treated a variety of tropical diseases and conditions in thousands of
patients who are very much like the plaintiffs involved in this case. I have been invited on
various occasions to give lectures both in Ecuador and in the United States about my experiences

including at Marshall University, Vanderbilt University, East Tennessee State University, Texas
Tech University and the University of Chicago. In addition to the publications already

470 Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 6 of 62

mentioned, I have written or collaborated on a number of scientific articles related to the field of
tropical medicine and continue to give lectures and speak at medical conferences on the topic.
Further information regarding my credentials and a listing of my publications are set forth in my

cv, attached hereto as Exhibit A.

The data and other information that I considered in preparing my expert report are cited herein
andarelistedin Exhibit B.

471Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 7 of 62

STATEMENT OF COMPENSATION

I am being compensated for my work in this matter at a rate of $300.00 per hour, including
deposition and trial testimony.

PRIOR TESTIMONY

I have never previously testified as an expert witness in litigation.

SUMMARY OF EXPERT OPINIONS

1. There is a high background incidence of disease in the communities in which the test

plaintiffs live, which is caused by the tropical environment in the border regions of
Sucumbios and Esmeraldas and by the lack of many basic amenities, such as clean water,
indoor plumbing, adequate housing, public sanitation, healthy diet, and availability of
medical care.

2. The medical problems identified by the test plaintiffs are endemic to the region, without

regard to any alleged effect of Plan Colombia herbicide spray.

3. Plaintiffs have not provided any evidence that would allow a medical expert to reliably
opine that Plan Colombia herbicide spray was a cause of any of the test plaintiffs’ alleged
medical conditions or to exclude the endemic health risks in the region as the true cause

of their alleged personal injuries.

472 Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 8 of 62

THERE IS A HIGH BACKGROUND INCIDENCE OF DISEASE IN THE
COMMUNITIES IN WHICH THE TEST PLAINTIFFS LIVE, WHICH IS CAUSED BY
THE TROPICAL ENVIRONMENT IN THE BORDER REGIONS OF SUCUMBIOS

AND ESMERALDAS AND BY THE LACK OF MANY BASIC AMENITIES, SUCH AS
CLEAN WATER, INDOOR PLUMBING, ADEQUATE HOUSING, PUBLIC
SANITATION, HEALTHY DIET, AND AVAILABILITY OF MEDICAL CARE.

Tropical medicine refers to the study and treatment of conditions or diseases that exist

either exclusively or more commonly in tropical regions of the world. The word “tropical” refers
to areas of high humidity, high rainfall, low elevation and usually with a high density of insects
and fauna and flora native to such regions. These tropical characteristics themselves create an
environment ideal for certain disease vectors such as mosquitos, sandflies and rodents which in
turn propagate diseases among the local population. In addition, the overall health status of

residents living in the tropics is further compromised by poor living conditions and a basic lack
of resources.

Ecuador’s rural, tropical communities are quite unlike what one might encounter here in
the U.S. Poverty is widespread in Ecuador and living conditions in rural areas are particularly

poor. The province of Esmeraldas and the Amazon jungle region (which includes a number of
Ecuadorian provinces including Pastaza and Sucumbios) are no exception. Living conditions
throughout these regions can vary, but rural village dwellers usually inhabit homes consisting of
a dirt floor, wood slat walls and a thatched or tin roof with no electricity or running water. These

simple dwellings provide no protection at all from insects or rodents, which gives rise to many
tropical diseases. In an effort to ward off the abundant insect population, many village dwellers
maintain a constant fire inside their hut causing a constantly smoky environment which
contributes to high rates of asthma and complicates other respiratory conditions. Many

communities do not have an available source of clean water, indoor plumbing, or basic sewage
removal and treatment systems. Public health studies have demonstrated that the availability of
clean water is of utmost importance in reducing many of the infectious diseases and chronic
diarrhea conditions that plague the poor (Esrey 1991; Mintz 1995). The largely unsanitary

conditions predispose the population to many diseases including skin conditions like impetigo
and scabies, as well as diseases like tuberculosis, scarlet fever, leptospirosis, and meningococcal
disesase.

The overall poor health status of inhabitants of this region is also compounded by the

lack of variety in their diets due to expense and difficulty of obtaining adequate amounts of
protein. Many poor families eat meat only from time to time when it is available or for special
occasions. Dietary diversity has been shown in studies to promote good health and nutritional
status. The lack of protein leads to protein malnutrition or kwashiorkor, which then makes
1
people more susceptible to many different kinds of infections.

The poor health status of rural Ecuadorians also results from a lack of access to basic
medical care. While small health outposts are situated throughout Ecuador by the Department of

1It is well established that malnutrition can compromise the immune system (Beisel 2000; Chandra

1997).

473Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 9 of 62

Public Health, most do not have adequate staffing, medications or diagnostic capabilities.
Because the pay of local physicians by the government is extremely low (approximately
$300/month during my final years in Ecuador) it is very difficult to staff health posts and even
government hospitals in the rural areas. Most importantly, there is no concept of routine medical

care among young people and adults in these regions of Ecuador. Patients often do not seek
medical care until their conditions are advanced and after they have already tried many local
remedies. Despite a scientific explanation given for a health condition and a clear description of

how to prevent it or cure it, other explanations and cures are often sought outside the western
style of medicine, and this desire to circumvent or avoid modern medicine often compromises
the health and treatment of individuals who need it the most.

While the living conditions are poor throughout much of Ecuador, conditions in the
provinces of Sucumbios and Esmeraldas, where most of the test plaintiffs live, are particularly
impoverished. 2 Statistics collected by the Ecuadorian government show that significant
segments of the population lack access to basic sanitation services (INEC 2001). With regard to

the risk of malaria, these two provinces were two of the top three provinces as measured by the
annual parasite index (PAHO 2007). A government survey in 2005 found that 79% of people
living in rural areas of Ecuador were living in poverty, compared with 39% of those in urban

areas (PAHO 2007). Similarly, measurements of living conditions show that they are3more
primitive in rural areas compared with urban areas (Ministerio de Salud 2007).

2 The Mestanza family live in Guayaquil, a large city 275 miles from the border region of Sucumbios
where their farm is located. Several members of that family claim to have been injured while visiting

their farm in 2000 to 2002, but it is noteworthy that this family is not poverty-stricken like many others in
Sucumbios. Nonetheless, at their farm, they appear to live in primitive conditions typical of rural
Ecuador.

3 Based upon the evidence I have reviewed in this case, the test plaintiffs’ living conditions are similar to
what I would expect for rural inhabitants of Northern Ecuador.

474 Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 10 of 62

THE MEDICAL PROBLEMS IDENTIFIED BY THE TEST PLAINTIFFS ARE

ENDEMIC TO THE REGION, WITHOUT REGARD TO ANY ALLEGED EFFECT OF
PLAN COLOMBIA HERBICIDE SPRAY.

The test plaintiffs have identified a variety of general and non-specific medical ailments

that they a4lege were caused by or might have been caused by Plan Colombia spraying
operations. I will address the test plaintiffs’ individual claims in the following section. To
place the plaintiffs’ allegations in their proper context, however, it is important to first
understand the very high background incidence in rural Ecuador of the medical conditions they

describe. There is nothing unusual or unexpected about the test plaintiffs’ alleged medical
conditions; indeed, they are typical of the patients I treated during my 8.5 years in the Amazon
basin region of Ecuador.

▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯

A number of the test plaintiffs complained of gastrointestinal problems, including
diarrhea, stomach upset, nausea and vomiting. These types of problems are exceedingly
common throughout rural Ecuador and can be directly attributed to the lack of sanitation and

clean drinking water, the close proximity of humans to livestock, and the heavy insect and rodent
populations. Scientific studies have repeatedly reported that upwards of 80% of the people
living in northern Ecuador have intestinal parasites, with some studies finding infection rates that

approach 100% (Cooper 1993; Gatti 2002). A study of children in Esmeraldas by Gatti et al.
(2002) reported that 98.9 % were infected with intestinal parasites. The authors noted that the
“high detection rate is clearly related to poor sanitation, nutrition, use of contaminated water, and
domestic animal promiscuity.” Another study in Esmeraldas found that 75.9 % of those studied

were infected with at least one species of intestinal helminth (Cooper 1993).

The differential diagnosis for gastrointestinal problems in rural Ecuador is broad and
includes (in the approximate order of the frequency with which I would see the various

conditions in my daily practice) such things as acute gastroenteritis (caused by parasites,
bacteria, or viruses), gall bladder disease, gastroesophageal reflux with or without ulcers,
appendicitis, pancreatitis (gall stone, viral or alcoholic), lactose intolerance, infectious colitis,
hepatitis, malabsorption syndromes, Celiac disease and gastric cancer (the leading type of cancer
5
in Ecuador). Because parasitic disease is rampant in rural Ecuador, unless there are specific
signs or symptoms pointing to another diagnosis, one often begins with a stool exam looking for
parasites and, if present, treats them first to see if the symptoms resolve. Some sort of intestinal

4From the array of alleged physical symptoms and health conditions that the test plaintiffs alleged were

caused by the Plan Colombia spraying, plaintiffs’ expert Dr. Wolfson identifies several general conditions
in his report, and I accordingly address these general conditions in this section of my report.
5
On a handful of occasions, I also treated patients who were suffering from gastrointestinal symptoms
associated with intoxication with organophosphates or paraquat, generally following suicide attempts.
The local people were quite aware of the toxic nature of these chemicals to humans and sought them out
for these suicide attempts. In my 8.5 years in Ecuador, I do not recall ever treating a patient whose

symptoms were associated with alleged exposure to glyphosate.

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parasite was present in the majority of my patients who lived in impoverished regions like the
test plaintiffs.

▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯

Another common category of test plaintiff complaints was problems of the skin (e.g.,
recurrent rashes, itching, irritation, infections). Again, these types of problems are widespread

throughout rural Ecuador. Due to the lack of clean water, indoor plumbing and adequate sewage
treatment and disposal, combined with the fact that many people live with dirt or wooden floors,
the opportunity for skin infections is everpresent. There is also a lack of first aid materials and
knowledge of how to clean and dress fresh wounds by the lay public. All of these factors
contribute to the frequency with which we would see Staphylococcal and Streptococcal skin

infections among our patients. Insect bites occur daily to most people due to the homes lacking
glass windows or screens. Scratching of these insect bites with dirty fingernails and hands are a
common method of contamination with these organisms which cause characteristic skin lesions,
namely impetigo, pyodermatitis, furuncles and carbuncles (or small abscesses). These lesions
are quite characteristic and are usually diagnosed and treated clinically. The next most common

recurrent rash is scabies which is caused by a microscopic mite and causes intense itching which
can then become secondarily infected with the Staph or Strep mentioned above. Due to the
humid conditions one also frequently encounters chronic fungal infections in patients ranging
from Candida in baby diaper regions to “ringworm” caused by Tinea species and Tinea
versicolor which causes a hypopigmentation of the skin in many dark-skinned patients. Botfly

myiasis is another common condition, characterized by an itchy, weeping wound that appears to
be an infected insect bite from which one can extract the larvae (maggot) of a fly. I was
unfortunate enough to have to extract nine of these larvae from my daughter’s head at one time
and three from my own body on various occasions. Certain parasites can also cause itchy skin

lesions as well, such as Strongyloides. Contact dermatitis can also occur after exposure to
certain tropical plants (equivalent to poison oak in the USA), and allergy to metals or other
materials. However, in my experience in Ecuador, I never observed any skin conditions from
exposure to glyphosate or other pesticides.

Less common skin conditions that are seen from time to time include cutaneous

Leishmaniasis and the itchy bite caused by the reduvid bug that causes Chagas disease. A study
in the subtropical rainforest of northwest Ecuador found that 14 % of those studied had evidence
of active cutaneous leishmaniasis infection and 33 % had evidence of past infection (Armijos
1997). Calvopina et al. (2004) noted an increase of leishmaniasis over the four preceding years,
with approximately 75 % of the cases occurring in the Pacific region of Ecuador. A study of the

seroprevalence of the parasite that causes Chagas disease reported seroprevalence of 2.4 % in the
Amazon region. The authors noted that their findings suggested that transmission of the disease
is associated with poor housing conditions (Grijalva 2003).

▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯

Respiratory problems were an extremely common complaint among patients coming to
our hospital. Although the causes of these illnesses were often similar to the causes seen in the
United States, a significant additional respiratory hazard in Ecuador is created by the use of fires
within the home to ward off insects, as noted above. Rinne (2006) reported lower pulmonary

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function among children living in households in rural Ecuador that cook with biomass fuel
(which exposes the children to biomass smoke).

Aside from indoor smoke pollution, the most common causes of respiratory ailments in
my practice in rural Ecuador, in approximate order of frequency with which they were
encountered, include viral upper respiratory infections (URI, or common cold and/or influenza),

bronchitis, pneumonia, asthma, bronchiolitis, tuberculosis, Loeffler’s syndrome (a condition that
occurs with wheezing, eosinophils in the bloodstream and infiltrates on x-ray that appears as
certain parasites migrate through the lungs), pertussis and paragonamiasis. The URIs could be
diagnosed clinically and treated symptomatically. If there was concern for pneumonia versus
bronchitis, then an x-ray was often performed to help clarify the situation. Sputum exams for

acid fast bacilli (AFB) were done to detect tuberculosis and paragonamiasis and stool exams to
look for potential acute parasitic infections contributing to Loeffler’s syndrome in patients with
new wheezing. Asthma and pertussis were largely diagnosed and treated clinically in our
relatively low-technology situation.

▯ ▯▯▯ ▯▯▯▯▯▯▯▯

The primary unique risk factor for eye problems in tropical Ecuador is the sun. Because
the equator crosses through Ecuador, it is in the closest proximity to the sun, and the intensity of
the sunlight leads to a higher prevalence of general eye irritation. Thus, for example, one study
found that 89.2 % of school aged children in the Northeastern province of Napo, Ecuador had

pterygium (a fleshy growth on the inner aspect of the eye due to chronic ultraviolet light, wind
and dust exposure) (San Sebastian 1999). In addition, in the 1990s there was a high background
incidence of insect-born ocular disease in Esmeraldas province in particular. In one study, over
33% of the study population had ocular lesions associated with the insect born disease,
onchocerca (Cooper 1995).

In my clinical practice in Ecuador, the the most common diagnoses reached in patients
with eye problems were acute viral conjunctivitis, allergic conjunctivitis, bacterial conjunctivitis,
uncorrected refractive errors due to the lack of optometrists and the cost of glasses, corneal
abrasions due to welding or grinding that caused a foreign body to lodge in the eye, pterygium,
hordeolum (stye), chalazion (chronic inflammatory ball-like lesion of the eyelid), or poor visual

acuity due to the need of refractive correction (glasses).

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PLAINTIFFS HAVE NOT PROVIDED ANY EVIDENCE THAT WOULD ALLOW A
MEDICAL EXPERT TO RELIABLY OPINE THAT PLAN COLOMBIA HERBICIDE
SPRAY WAS A CAUSE OF ANY OF THE TEST PLAINTIFFS’ ALLEGED MEDICAL
CONDITIONS OR TO EXCLUDE THE ENDEMIC HEALTH RISKS IN THE REGION

AS THE TRUE CAUSE OF THEIR ALLEGED PERSONAL INJURIES.

Based upon my clinical practice and my general medical understanding of the potential
health risks of herbicides, I am not aware of any evidence that exposure to a glyphosate-based
herbicide through an aerial spraying operation could cause the types of medical conditions

identified by the test plaintiffs in this case. I do not, however, hold myself out as an expert in
herbicide toxicity, and I understand that there are other experts in this litigation who will speak
more directly and informedly to this question, which I view as a question of general causation
(i.e., is glyphosate capable of causing the medical ailments at issue).

My expertise is focused on the standard methodology used in addressing questions of

specific causation in medicine, which is called development of a differential diagnosis for any
given set of signs or symptoms presented by a patient. This methodology starts with a list of
known potential causes of the patient’s complaints, which is generated during the general
causation analysis based on high-quality scientific studies and research. The specific causation
step, or differential diagnosis, is the systematic consideration of each of the listed potential

causes with unlikely or erroneous diagnoses being eliminated one by one until the most likely
cause of the patient’s condition is identified.

In order to develop a valid differential diagnosis, a physician must first take a careful
history from the patient in an effort to determine the nature and cause of their symptoms. This
includes inquiring about the date and time of onset of the symptoms, parts of the body affected,

remedies that have been tried already and things that alleviate or aggravate the condition. It also
includes obtaining information regarding the patient’s recent travel and exposures as well as
prior health status, personal and social habits and the family medical history. A thorough
physical exam of the patient is the next crucial step and requires special attention to detail of the

parts of the body to which the history has directed the physician. If this combination of careful
history taking and detailed physical exam is followed, some diagnoses are clear while others
require further investigation with laboratory tests, biopsies or radiographic studies. Each piece
of information thus obtained serves to “rule out” one or several plausible conditions (and causes)
that were in the differential diagnosis. Similarly and simultaneously, the correct diagnosis can

often be “ruled in” and appropriate therapy chosen and instituted. A common and dangerous
error in the practice of medicine is to prematurely reach a conclusion without considering the
broad array of possible causes of a patient’s condition.

In seeking to identify an accurate diagnosis for each of the test plaintiffs in this litigation,
the first – and in my mind insurmountable – hurdle is that none of the test plaintiffs have

provided the necessary components of the history, physical exam, and laboratory or radiographic
studies. The nonspecific and vague nature of the complaints in general requires the generation of
a long differential diagnosis without the hope of ruling in or ruling out many of the conditions
with any degree of certainty. As detailed below, the test plaintiffs’ descriptions of their alleged

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medical ailments are varied and in many instances inconsistent and contradictory. The varied
nature of the test plaintiffs’ medical claims (and the inconsistent alleged timing of these ailments
with respect to the alleged spraying), are contrary to the allegation that the illnesses were all

caused by exposure to Plan Colombia herbicide (or indeed to any single alleged toxin), but these
facts do not otherwise assist in the effort to identify the actual causes of their conditions. Many
of the medical ailments that are alleged to develop and often persist over varying time periods
are, as noted above, endemic to the region or commonly found in a general medical practice.

Plaintiffs do provide somewhat consistent facts as to their unhealthy living conditions (poor
housing, lack of clean drinking water and indoor plumbing, etc.). However, they do not provide
any reliable history of other conditions to which they were exposed at the time of their alleged
illnesses. To the extent that the test plaintiffs state that they received medical care for their
conditions, they have not provided any medical records regarding that treatment, nor have they

provided the results of any medical testing. Indeed, except for one case, none of the test
plaintiffs have provided any contemporaneous evidence upon which an expert could reach a
reliable opinion to a reasonable degree of medical certainty as to either the nature of the medical
conditions or the cause of those conditions. For this one test plaintiff where such evidence is

available (Edith Quevedo), the evidence clearly demonstrates that her condition was caused by a
bacterial infection rather than the alleged exposure to glyphosate. Moreover, a number of the
test plaintiffs testified as to treatments that they received for their medical conditions, but in each
case, those treatments were not what would have been provided if the physicians believed that
the conditions were caused by exposure to a herbicide or any other alleged topical toxin.

My assessment of the medical claims of each of the individual test plaintiffs is set forth
below:

A. Quevedo Family

In their depositions, the Quevedo test-plaintiff family members allege that they suffered

various physical injuries caused by the Plan Colombia sprayings. They do not, however, give
specific dates for their exposures. Rosa Altimirano testified that she was exposed in “2002,
towards 2003” (Dep. 37), while her husband Luciano Quevedo did not provide any date of
exposure at his deposition. (His questionnaire response listed his dates of exposure as “2002-

2006” (Questionnaire V.C.).) With one exception, their claims of physical injury are based on
self-reporting. For that exception, a skin condition of daughter Edith Quevedo, which was
documented by photography and video, the condition was diagnosed as a bacterial infection, a
diagnosis with which I agree (discussed in more detail below). The Quevedo family’s personal
injury claims have changed over time and they are often inconsistent in nature, timing, and

duration. For example, though Luciano reports vision problems, no other family member
complains of eye injury from exposure to the spray. These inconsistencies make it impossible to
conclude that one disease or exposure could have caused all of the family’s maladies. All of the
alleged symptoms, however, are consistent with diseases and health conditions that are prevalent

in the tropics and that I saw regularly during my practice in Ecuador. It is highly likely that these

6
In light of the test plaintiffs’ varying allegations, I have chosen to rely primarily upon their sworn
deposition testimony.

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diseases and health conditions, as opposed to the alleged exposure to the Plan Colombia spray,
are responsible for the plaintiffs’ alleged symptoms.

The Quevedo family reports living in a wooden home approximately 5x6 meters in size
with well water piped into the home (Luciano Questionnaire IV.A.1; Rosa Dep. 26). This is

reportedly potable water, and they do not boil or filter it (Luciano Dep. 111). Both Luciano and
Rosa report an indoor bathroom though Luciano also says it is 10 meters from the house (Rosa
Dep. 26; Luciano Dep. 14). The family lives in very close proximity to some of their farm
animals (Rosa Dep. 51, 52, 54; Robinson Dep. 32), which puts the family members at increased
risk for a number of animal-borne diseases.

1. Luciano Quevedo

Luciano is a 50-year-old male who reports various injuries he allegedly experienced
following exposure to the Plan Colombia spraying. He has not produced any medical records to
support his alleged sympoms, and his allegations in his deposition are inconsistent with the

symptoms he was reported to be experiencing in a “toxicology report” prepared for the Quevedo
family during a June 14, 2001 nongovernmental organization’s investigation of alleged health
effects from Plan Colombia spraying.

At his deposition, Mr. Quevedo first complained of itching all over his body and an
inability to read small print as a result of exposure to the Plan Colombia herbicide (Dep. 36, 37).

As explained above, itching of the skin could be caused by any number of conditions that are
common in the region, and Mr. Quevedo’s visual problem is very likely related to age-related
presbyopia. Only after being shown his written questionnaire response, which listed other
alleged physical injuries, Luciano stated that he also experienced headaches, aching bones,
kidney problems, and fever following the spraying (Dep. 47-48, 55). Again, each of these

symptoms could be caused by many different diseases and health conditions that I treated
regularly in the Ecuadorian Amazon. Mr. Quevedo also complains of ongoing bone aches,
kidney problems, and occasional headaches (Dep. 48, 50, 55). One potential cause of these
symptoms is a kidney infection, which can make one feel extremely sick and cause fever. The

lack of a thorough medical exam and laboratory confirmation, however, makes this mere
speculation. Based upon the information Mr. Quevedo submitted, no physician could even
determine what medical conditions he suffered from, much less identify exposure to the Plan
Colombia spray as a cause of those conditions.

2. Rosa Altamirano

Rosa Altamirano is the 51-year-old wife of Luciano. She alleged in her deposition
testimony that following exposure to glyphosate she experienced itching, a rash, headaches,
kidney problems, and bone pain (Dep. 34, 44-45). She still experiences bone pain, kidney
problems, and occasional headaches (Dep. 45). As set forth above, there are any number of
common conditions endemic to the Ecuadorian Amazon basin that could have caused these

conditions. Mrs. Altamirano submitted some medical records, most of which relate to her last
pregnancy in 2000 followed by a tubal ligation. The next entry is from a visit in November of
2004 where she presented with dizziness (mareos), headache (cefalea) and muscle aches
(mialgias) and pains and is diagnosed with acute anemia (anemia aguda). Though Mrs.

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Altamirano contends that her headaches and bone pains were caused by the spraying, this is very
unlikely in light of the fact that this visit occurs approximately one year following the alleged
spraying. Moreover, the symptoms are much more consistent with an acute viral illness or
malaria or dengue fever than any brief topical exposure to glyphosate. None of the medical

records makes any mention of the Plan Colombia spraying.

Moreover, Mrs. Altamirano’s inconsistency in reporting her alleged symptoms makes it
difficult to even determine what conditions she suffered from, let alone identify a cause. Her
questionnaire response states that she experienced fever and diarrhea, among other symptoms
(Questionnaire V.E.1 and V.E.7). But she did not complain of these symptoms in her deposition,

and they were not identified on the “toxicology report” produced by the plaintiffs. (It is also
notable that Mrs. Altamirano claims to have been exposed to the Plan Colombia spray in “2002,
towards 2003” (Dep. 37), but the “toxicology report” listing the Quevedo family’s alleged
injuries is dated June 14, 2001.) Because of these inconsistencies and the lack of any relevant
medical records or other information, no physician could reliably diagnose Mrs. Altamirano’s

symptoms. Any attempt to do so would be pure speculation, and there is no evidence that would
allow a physician to reach a reliable conclusion as to the cause of her health conditions.

3. Edith Quevedo

Edith is the 15-year-old daughter of Luciano and Rosa. Her parents variously testified

that she was affected by itching, a rash, and headaches (Luciano Dep. 39; Rosa Dep. 34-35).
Edith herself testified that she also experienced burning of the nose, stomachache, diarrhea, and
fever (Dep. 49, 60, 95-96). According to Rosa, Edith no longer has any physical effects from the
spray (Rosa Dep. 46). As with their other symptoms, the Quevedo family alleges that Edith’s
rash was caused by exposure to the Plan Colombia herbicide. But this claim is contradicted by

contemporaneous video and photographic evidence, along with a physician’s diagnosis following
direct examination of Edith’s skin condition. Her skin condition was filmed and photographed
by an Ecuadorian physician named Adolfo Maldonado, during a visit to northern Ecuador to
document the alleged effects of the Plan Colombia sprayings. Based upon my review of the
video and photographs, the lesions look typical of impetigo, a type of bacterial infection. This

impression is supported by Dr. Maldonado, who testified that Edith had a bacterial infection
(Maldonado Dep. 55). The lesions were treated with a combination antifungal, antibiotic and
anti-inflammatory cream (Trigentax) along with unspecified “medicine” and they improved
(Dep. 57-60). This identification and successful treatment rules out glyphosate or any other toxic
exposure as the cause of her rash. Edith also complains of itching that occurred several days

after her exposure (Dep. 52), and her mother notes that the family started itching “after weeks
and months that went by” (Rosa Dep. 34). This delayed timing is inconsistent with dermal
exposure to a chemical irritant, where symptoms should be contemporaneous with exposure.

Edith’s other claimed medical conditions are non-specific and do not suggest any toxic

exposure. Headache, fever, stomachache, and diarrhea are common symptoms among children
in rural Ecuador for which there are many potential causes, and without more information it
would be speculation to try to identify the specific cause. The combination of stomachache,
fever, and diarrhea is entirely consistent with an acute gastroenteritis or parasitic infection.
Absent medical records, a physical examination, and laboratory tests, it is impossible to

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determine the cause of any of Edith’s symptoms. There is no reliable basis to opine that they
were caused by exposure to Plan Colombia herbicide.

4. Robinson Quevedo

Robinson is the 10-year-old son of Luciano and Rosa. He was approximately 2 or 3
years old at the time his mother Rosa alleges that the family was exposed. His mother Rosa
testified that he experienced skin infections, headaches, and diarrhea which made him very
skinny (Rosa Dep. 35). 7 Rosa testified that Robinson was completely healthy at the time of her

deposition in 2009 (Rosa Dep. 45-46). The plaintiffs have provided no medical records for
Robinson. Skin infections are prevalent in Ecuador, however, and are not typically caused by
exposure to a toxic substance. Diarrhea is also common, in large part due to the unsanitary
living conditions in the area where the plaintiffs live. Similarly, there are any number of

conditions I treated regularly in Ecuador that cause headaches. With the information available
here, no reliable diagnosis of Robinson’s symptoms can be made.

With respect to Rosa’s complaint that Robinson was underweight, by far the most
common complaint in my clinic over the years at the Shell hospital from parents was that their

children were too skinny and that they had no appetite. It was difficult to convince parents that
their child’s weight was appropriate in spite of showing them where their child was on the
growth chart. As with the other alleged symptoms, the Quevedos have provided no data that
would allow me to determine whether Robinson was in fact underweight or not. But as

mentioned previously, malnutrition is known to be extremely common in rural areas of Ecuador,
and certainly repeated bouts of diarrhea from any of the known common causes endemic to the
region could contribute to being underweight. Any attempt to diagnose Robinson’s alleged
symptoms, let alone ascribe them to an alleged toxic exposure, would be purely speculative.

B. Calero Family

During their depositions, the Calero test-plaintiff family members claim that they
experienced various medical problems caused by an alleged exposure to the Plan Colombia spray

on a single occasion in August 2003. This testimony regarding the circumstances of alleged
exposure differs from the information set forth in their earlier questionnaire responses, which
claimed alleged exposures on a varying array of other dates. The family’s allegations regarding
medical problems are based on self-reporting. They have not produced any medical records,

laboratory tests, or any other contemporaneous evidence that support their claims, and to the
extent they provide testimony as to medical diagnoses they have received, the diagnoses are
directly contrary to the causal claims. The health problems alleged by each family member are
inconsistent in nature, timing and duration, and they have changed over time. No single disease

or exposure could account for all of the family’s wide array of alleged medical problems, but
each of the individually alleged medical problems is common, if not endemic, to the region and
is consistent with the types of medical problems that I treated in my clinical practice in Ecuador.

7Rosa testified that Robinson experienced only skin infections and diarrhea, but she also testified that all

of her children had headaches (Dep. 35).

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The Caleros live in primitive conditions typical of rural Ecuador. Their house is
reportedly made of wood walls and a zinc roof (Calixta Questionnaire IV.A.1), and they have no
running water in the house. They collect rain water and filter it with a cloth (Santos Dep. 68),
which only removes large debris without providing any reduction in microbes. They do not
report that they boil their drinking water. They have no indoor toilet facility and do not use an

outhouse (Santos Dep. 68; Questionnaire IV.B.3, 4), so sewage is likely present in the
environment surrounding the house. As discussed above, these living conditions significantly
increase the risk of medical problems. Given the family’s living conditions, the medical ailments
they identify are not surprising or unexpected.

1. Santos Calero

Santos Calero is a 66-year old male who alleged at deposition that his exposure to Plan
Colombia herbicide spray had caused burning on his skin, pain in his bones and kidneys, and a
burning sensation in his bladder (Dep. 23, 32-33, 84). Mr. Calero has produced some medical
records, and the relevant records establish causes completely unrelated to the spraying for certain

of his alleged symptoms. The testimony that Mr. Calero has provided, while non-specific,
strongly suggests alternative causes for his alleged medical conditions and clearly does not
provide the type of medical evidence that would be needed to reach a reliable opinion that Mr.
Calero suffered any adverse medical effect from his claimed exposure to Plan Colombia
herbicide.

Mr. Calero testified that he felt a burning on his skin a few days after allegedly being
exposed to Plan Colombia herbicide spray, though he denies having felt the spray on his skin
(Dep. 23). This purported timing is not consistent with an acute reaction to a topical irritant, and
is thus contrary to the claim that his alleged exposure to glyphosate was the cause. As noted
above, rashes and other skin problems are endemic in Ecuador, and there is nothing unusual

about the symptoms that Mr. Calero reports. Moreover, Mr. Calero testified that he was given a
cream to put on his arms for burning and itching skin and that his condition resolved within a
few days (Dep. 88). The first medical record entry after 2003 is for May 12, 2004 when he is
diagnosed with a right shoulder abnormality (ankylosis) due to an “old” (antigua) injury and a
severe kidney infection (pielonefritis) and is treated with antibiotics. The kidney infection would

explain Mr. Calero’s complaints of kidney pain and a burning sensation in his bladder. Then in
September 9, 2004 it appears he presented for a disability evaluation regarding some weakness in
his right shoulder due to the previous injury. These diagnoses make his symptoms unlikely to
have been related to the alleged glyphosate exposure as a cause of these symptoms.

Any attempt to reach a reliable medical opinion that Mr. Calero’s alleged ailments were

caused by exposure to Plan Colombia herbicide is further undermined by the fact that Mr. Calero
has not been a consistent historian regarding his medical condition. Mr. Calero’s deposition
testimony as to his alleged medical ailments following his claimed exposure is notably different
from the allegations contained in his earlier questionnaire response, which identified only

headaches, dizziness, vomiting, itching, and skin infections/poisoning (Questionnaire V.D.15,
E.1, E.15). Both his testimony and questionnaire responses differ from information contained in
an NGO “toxicology report,” dated September 12, 2002 and produced by plaintiffs, in which it
was recorded that Mr. Calero was alleging that the herbicide spray caused pain in one lung, eye
irritation, and numbness in his arms. (It is also noteworthy that this “toxicology report” was

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prepared almost a year prior to the date that Mr. Calero now alleges he was exposed to Plan
Colombia herbicide.) In light of this information, it is impossible to reach any reliable

conclusion even as to the nature of Mr. Calero’s medical conditions, let alone that his conditions
were caused by exposure to glyphosate.

2. Calixta Pineda

Calixta Pineda is the 66-year old wife of Santos Calero. At her deposition, Mrs. Pineda

alleged that exposure to Plan Colombia herbicide had caused a rash with itching, a uterine
infection, and headaches (Dep. 16, 50-51). Mrs. Pineda did not provide any medical records or
contemporaneous evidence regarding her alleged medical ailments, and her testimony does not
provide any reliable basis for an opinion that her alleged exposure to Plan Colombia herbicide
caused her any medical impairment.

Mrs. Pineda testified that she experienced a rash with itching approximately one month
after her alleged exposure to Plan Colombia herbicide spray (Dep. 16), a time frame that is
clearly inconsistent with any opinion that the rash could be attributed to her claimed exposure.
Mrs. Pineda testified that she was diagnosed with a skin infection (Dep. 18), which would not be
caused by a cutaneous exposure to a toxic substance. As with her husband, Mrs. Pineda testified

that her rash was transient and successfully treated by a cream (Dep. 18). Mrs. Pineda’s alleged
rash is typical of rashes that are endemic in the region, and there is no basis to look for any cause
for the rash beyond the unsanitary living conditions in which Mrs. Pineda lives. Mrs. Pineda’s
uterine infection likewise cannot be reasonably attributed to glyphosate exposure; indeed, there
is no logical way to medically connect a uterine infection to a brief cutaneous exposure to a

substance. Finally, headaches are a non-specific medical symptom that can be caused by a wide
variety of systemic infections and conditions including a uterine infection. Without more
historical and physical exam information, any attempt to identify a cause for a headache that
reportedly occurred over seven years ago would be purely speculative.

3. Betty Calero

Betty Calero is the 36-year-old daughter of Santos Calero and Calixta Pineda. Betty
Calero alleged in her deposition that she believed that exposure to Plan Colombia caused her to
suffer various health conditions. Betty Calero produced some medical records, most of which
relate to her pregnancies and deliveries. On February 14, 2002, she was seen for a prenatal visit

at 20 weeks of pregnancy and complained of moderate headache along with a vaginal secretion
and she was treated with acetaminophen and a vaginal antifungal suppository. No reference to
fumigation is made. In May 2003, the visit documentation is illegible. In June 2004, a visit is
documented for another pregnancy at 35 weeks when she is having some cramps and is given
anti-inflammatory medication but is stated to be in good condition. In January 2004, she has an

intrauterine device placed for contraception. She was later seen on September 3, 2004, where
she complains of recurrent headaches for over one year and is diagnosed with sinus headaches.
There is no reference to fumigation or spray exposure in the medical record.

Betty Calero testified that her claimed exposure to Plan Colombia spraying caused a rash,
itching, and eye irritation (Dep. 25, 74). As explained above, these conditions are endemic in the

region for reasons entirely unrelated to any potential exposure to herbicide. There is no reliable

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medical basis to opine that these conditions were caused by exposure to Plan Colombia spraying.
She also testified that she experienced a strong cold and burning in her nose, throat, and eyes

(Dep. 74). The burning sensation stopped, but she has had itching of her nose, throat, and eyes
since 2003 (Dep. 93-94), making it highly unlikely to be related to any brief alleged toxic
exposure and much more likely to be an allergic condition. She also complained of kidney
problems (Dep. 74) that cannot be explained by a possible brief cutaneous exposure to
glyphosate, but which are much more likely to be related to recurrent urinary tract infections

which are common in women in Ecuador. She also testified that she experienced pain all over
her body and beginnings of a stroke (Dep. 63), as well as mental problems and pain in her
kidneys and legs (Dep. 56-57, 95). All of these conditions could have a number of different
causes. Finally, Ms. Calero complained of headaches (Dep. 63, 74) which, as noted above,
cannot be reliably associated with any specific cause without a far more extensive and reliable

medical record than has been provided here. Without more information, it is impossible to reach
a reliable diagnosis for any of Ms. Calero’s alleged health conditions.

4. Yuli Calero

Yuli Calero is the 12-year-old daughter of Betty Calero and the granddaughter of Santos

Calero and Calixta Pineda. Yuli was four years old at the time of the alleged Plan Colombia
exposure. Betty Calero testified that the Plan Colombia spraying caused Yuli to experience a
rash and a respiratory problem (Betty Dep. 84, 88). Calixta Pineda testified that Yuli has asthma,
cough, and back pain (Calixta Dep. 116). As explained previously, skin conditions such as
rashes are extremely common in rural Ecuador. Yuli’s respiratory problem reportedly was

diagnosed and treated as bronchitis by a doctor (Betty Dep. 86). She continued to have ongoing
respiratory symptoms in the months and years following the alleged spray episode and still has
them (Betty Dep. 88). As noted above, recurrent viral upper respiratory infections are common
in tropical Ecuador, as are bronchitis, pneumonia, asthma, tuberculosis and Loeffler’s syndrome.
Without more information it is impossible to know which of these common conditions might be

the cause of Yuli’s ongoing respiratory problems. There is no basis to link any of Yuli’s alleged
conditions to an alleged single exposure to Plan Colombia herbicide.

It is also noteworthy that in the Calero family’s September 12, 2002 “toxicology report”
there was no mention of Yuli suffering from any rash or respiratory problems following the then-

claimed exposure to Plan Colombia herbicide. Rather, in that report, it was claimed that Yuli
suffered from stomach pains and loss of appetite. Yuli and her family do not allege any such
ailments in their deposition testimony.

C. Edgar Balcazar

Mr. Edgar Balcazar is a 40-year-old man who reported seeing spray planes at a distance

of approximately 4 or 5 km from his home (he lives 4 or 5 km from the border) but was unable to
testify as to when this occurred. He reportedly lives in primitive conditions in a house that is 6x8
meters in size and made of cement and wood (Questionnaire IV.A.1). He has no running water
and brings his water to the house from a stream about 100 meters from the house (Dep. 26-27).
He does not filter the water (Questionnaire IV.A.5) and did not report boiling the water. There is

no indoor toilet facility, but the family does use a nearby outhouse (Dep. 26).

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Mr. Balcazar alleges in his deposition testimony that he experienced burning of the skin

and eyes, headaches, rash, dizziness, diarrhea, respiratory problems, and a bowel infection (Dep.
40-41, 55-56, 104, 107). He also alleges that he suffered from stomach problems and
stomachache (Dep. 97; Questionnaire V.E.1). All of these started after the spraying was
observed, although he does not provide a date for these alleged symptoms. He testified that the
skin and eye irritation began 1-1.5 hours after the alleged herbicide exposure but his diarrhea

(and potentially some other symptoms) began several days later (Dep. 42). Mr. Balcazar
testified that he has had a bowel infection requiring treatment since the time of the sprayings
several years before (Dep. 55-57). He could not recall the name of the medicine but states that
he continues to take capsules and a syrup for the condition (Dep. 56-57). He testified that
medical records should be available at the “international clinic” where he saw a Japanese

stomach specialist and at Hospital Vozandes in Quito where he was also evaluated along with his
son, but no such records have been provided (Dep. 97-98). Moreover, Mr. Balcazar has not been
a consistent historian. For example, his questionnaire does not mention a bowel infection, and
his questionnaire alleges pain all over his body (Questionnaire V.E.1), which he did not mention
in his testimony.

Mr. Balcazar’s testimony as to the distance of the witnessed Plan Colombia spraying
operations and the time lapse between the spraying and the diarrhea is directly contrary to his
allegation that the symptoms were caused by exposure to the herbicide. Mr. Balcazar’s medical
complaints are most likely due to his unsanitary living conditions and the known diseases
endemic to the region. Diarrhea and stomachache are two of the most common conditions seen

in a primary care setting in rural Ecuador. The plaintiff is very likely infested with parasites of
various types and may also suffer from bouts of bacterial gastroenteritis due to common
organisms found in unsanitary environments, such as Salmonella, Shigella, E. coli,
Campylobacter and other species. In addition, an obvious diagnosis for plaintiff’s ongoing

chronic abdominal pain is chronic gastroesophageal reflux disease (GERD) or chronic gastritis
associated with highly endemic H. pylori infection, although it could be due to an inflammatory
bowel disease such as Crohn’s disease or ulcerative colitis. Gastric cancer is the most common
cancer diagnosed in Ecuador and would need to be ruled out with esophagogastroduodenoscopy
(EGD), though the patient does not report weight loss which is a common symptom if cancer is

present. A bowel infection would not be caused by exposure to a toxic substance.

Mr. Balcazar reports eye irritation beginning 1-1.5 hours after his alleged herbicide
exposure (Dep. 42). Complaints of eye irritation are common and could be caused by numerous
conditions that I saw regularly during my practice in rural Ecuador. The complaint of burning of
the eyes in general is not uncommon in rural Ecuador given its location on the equator and

consequent high levels of UVA and UVB light exposure which is damaging to the eyes. Also,
Mr. Balcazar makes a vague reference to respiratory symptoms occurring after the spraying
episodes, but these symptoms are not characterized to any degree with regard to timing following
alleged spray exposure, exact nature of the respiratory symptoms, relieving or exacerbating
factors, medications used, or other important information that might help one determine the true

cause of his respiratory symptoms. Mr. Balcazar’s alleged dizziness also could have been caused
by a number of diseases and health conditions common in rural Ecuador.

There is no reliable basis to opine that any of Mr. Balcazar’s alleged symptoms are
related to glyphosate exposure.

486 Annex 13

Witness 37

Witness 37
Wit. 37 Wit. 33

Witness 33

Witness 37
Witness 37

Witness 37

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In his deposition testimony, Witness 37 claims that he also suffered from dizziness,
headaches, diarrhea, vomiting, and a rash (Dep. 44-45). As discussed above, each of Witness 37
alleged symptoms are consistent with many diseases and health conditions endemic to rural

Ecuador, making it impossible with the sparse information available here to render a diagnosis or
reach a reliable conclusion as to a potential cause. There is no medical basis to opine that any of
Witness 37's conditions were caused by exposure to Plan Colombia herbicide.

2. Witness 33

Wit. 33 is the 26-year-old son of Witness 3who alleged at deposition that he suffered from

vomiting, diarrhea, headaches, and a rash following his exposure to the Plan Colombia spraying
in 2003 (Dep. 25, 46-47) (notably though, his questionnaire did not identify vomiting or
diarrhea). Wit. 33testified that he experienced these symptoms intermittently for at least six

months (Dep. 28). He reports having gone to see a nurse and having received medication that
helped alleviate his symptoms (Dep. 28). Wit. 33 has submitted medical records from a single

visit that appears to be dated July 15, 2008 (15-07-08). The writing is largely illegible but it
appears he presented with “strong diarrhea and vomiting” and was prescribed oral rehydration,
diclofenac, and ampicillin or amoxillin. There is no reference to fumigation or spray exposure

and this is a visit 5 years distant to the alleged exposure. It is highly unlikely that a brief
exposure to a toxin would cause recurrent symptoms, and they are much more likely due to
parasitic or bacterial infections given the poor living conditions and lack of clean drinking water.

Due to the absence of a complete medical history, medical records, and laboratory tests,
however, a reliable diagnosis cannot be determined. Witness 3claimed medical condition or
conditions could be due to many causes endemic to rural Ecuador, and there is no medical basis

to opine that they were caused by exposure to Plan Colombia herbicide.

3. Witness 37's son

Wit. 37's son Witness 37
is the 15-year-old son of who testified that he saw spray planes three
times when he was approximately 8 years old (Dep. 24), which would be around 2003 or 2004.
Wit. 37'testified that he suffered from itching, headaches, diarrhea and dizziness after each time

he saw the spray planes, and that after the second exposure he also experienced a skin rash (Dep.
27, 37, 44). His father Witness 3testified that the entire family suffered from dizziness,
headaches, diarrhea, vomiting, and skin rash ( Witness 37Dep. 44-45, 49). After the first exposure

Wit. 37'testified that his symptoms lasted 1-2 days, after the second exposure they lasted
approximately 2 days, and after the third exposure they lasted about 3 days (Dep. 27-28, 37, 44).
Wit. 37'reports that he has intermittently experienced headaches, dizziness, and itching skin since

his exposure (Dep. 78). All of these symptoms are commonly caused by diseases and conditions
regularly seen in Northern Ecuador, and there is no medical basis of which I am aware that the
transient exposure to a chemical could cause intermittent symptoms of the types alleged. Rather,
Wit. 37's son
medical history suggests that his recurring symptoms arise from his continued exposure
to the unhealthy, unsanitary conditions where he lives. Given the lack of any distinct symptoms,

medical records or diagnostic tests, it is impossible to reach any reliable conclusion even as to
the specific nature of his medical ailments, and there certainly is no basis to reach a medical
conclusion that his symptoms were caused by exposure to Plan Colombia herbicide.

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E. Salas Family

In their depositions, the Salas family test plaintiffs allege that they suffered various
physical injuries from exposure to the Plan Columbia spray on various inconsistent dates. The 9

family’s allegations of personal injuries from exposure to the herbicide spray are based on self-
reporting. While the plaintiffs submitted medical records for Laura and John, none of these
records even relate to the test plaintiffs’ alleged injuries, much less support their claims. There
are also inconsistencies in the family members’ reports of their alleged injuries.

The Salas family reportedly lives in a house made of cement and wood and they have a
toilet 8 meters from their house (Santos Questionnaire IV.A.1; Laura Dep. 154-55). There is an
oil well approximately 500 meters from their house that pollutes the area (Laura Dep. 138; John
Dep. 74-76). 10 The family filed a complaint about an oil spill from that site, claiming that it

affected the family’s living conditions (Santos Dep. 116-17).

1. Jorge Salas

Jorge Salas is a 56-year-old male who alleges that he received various physical injuries

from exposure to glyphosate on three occasions. Mr. Salas has presented inconsistent accounts
of his alleged medical ailments, testifying that he suffered eye irritation during each herbicide
exposure, but failing to include this alleged injury in his questionnaire. Mr. Salas has submitted
no medical records, and there are no laboratory tests or other evidence to support his claims.

At his deposition, Mr. Salas testified that during his first alleged exposure, he
experienced itching, nose and eye irritation, and a skin infection (Dep. 27, 33), that during the
second alleged exposure, he experienced itching and inflammation of the throat, eyes, and skin

(Dep. 40, 50), and that during the third alleged exposure, he suffered from the same burning and
itching in his throat and eyes (Dep. 60-61). As noted previously, all of these symptoms are
common in rural Ecuador. Mr. Salas testified that he was given antibiotics for a skin infection
after the first alleged spray exposure (Dep. 33). A skin infection would have been caused by one

of many infectious agents which are widespread in Ecuador, and could not have been caused by
a cutaneous exposure to a chemical. Moreover, Mr. Salas’s testimony that he continues to have
itching of his skin (Dep. 127-28) is inconsistent with transient exposures to a chemical irritant,
and may be indicative of impetigo, eczema, scabies, or a parasitic infection, to name just a few of

the possibilities. Mr. Salas’s deterioration of vision (Dep. 127) is likely due to age-related
presbyopia. Without a more detailed history, medical records, or laboratory tests, it would be
speculation to identify a diagnosis for Mr. Salas’s alleged ailments, or to ascribe them to any
specific cause.

9Jorge’s Questionnaire reported exposure on October 4, 2002, and Laura’s Questionnaire claimed that

she had been exposed “since 2002” (Questionnaire V.C.). At the depositions, Jorge testified that he was
exposed in December 2000, May 2001, and October 2003 (Dep. 23-25, 35, 53), while Laura testified that
she was exposed in June 2002, January 2003, and October 2003 (Dep. 33, 60, 71).

10Laura’s Questionnaire stated that the oil well was about 200 meters from the family’s home
(Questionnaire IV.C.1).

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2. Laura Sanchez

Laura Sanchez is a school teacher and the 47-year-old wife of Jorge and mother of John,
who reports several medical problems following three alleged exposures to herbicide spray in
2002 and 2003. Her allegations are inconsistent across her alleged exposures and have changed

over time. Unlike her husband, Mrs. Sanchez has submitted some medical records, most of
which pertain to her pregnancy and gynecological concerns but none are relevant to her claims
here. The plaintiffs have not presented evidence to support a reliable diagnosis of Mrs.
Sanchez’s symptoms, let alone a causal link between her symptoms and herbicide exposure.

Though her symptoms vary across exposures, Mrs. Sanchez generally testified that she

experienced itching skin, burning of the nose, itching and burning of the eyes, headache, burning
in her stomach, and throat problems (Dep. 38, 43, 64, 67). As discussed above, irritation of the
skin and eyes is very common in the tropics because of endemic diseases, environmental factors,
and unsanitary living conditions. Without a more detailed history, medical records, or laboratory
tests, no reliable diagnosis of these symptoms can be rendered. The burning in her stomach

could be due to several diseases and health conditions endemic to the region. The nose and
throat irritation could be caused by an upper respiratory infection, allergies, or sinus problems, as
well as many other common conditions. A headache likewise could be caused by a number of
conditions, and indeed for most headaches there is no known cause.

Any attempt to diagnose Mrs. Sanchez’s conditions or identify a causal connection to a

chemical exposure is further undermined by the fact that we must rely solely upon Mrs.
Sanchez’s self-reporting of her symptoms, but that self-reporting has changed over time. Mrs.
Sanchez’s Questionnaire stated that she experienced, among other symptoms, dizziness and body
weakness (Questionnaire V.E.1, 7). At her deposition, she did not allege that she experienced
either of these symptoms. Moreover, the “toxicology report” submitted by the plaintiffs for Mrs.

Sanchez does not include these symptoms either. (It is also notable that the “toxicology report”
is dated June 28, 2001, approximately a year prior to Mrs. Sanchez’s first claimed exposure.)

3. John Salas

John is the 17-year-old son of Jorge and Laura who is alleged to have experienced

markedly different symptoms compared to his parents following exposure to the herbicide spray.
The plaintiffs have submitted some medical records for John, but they do not relate to his alleged
symptoms and provide no support for the claim that glyphosate caused his physical injuries. All
of the medical records presented are for events between 1993 and 1996 except for a single entry
from 2002 related to a dental visit. The claims of physical injury have changed over time.

John’s questionnaire alleged that the spraying caused only respiratory problems and respiratory
disease (Questionnaire V.E.1, 7). At deposition, he and his parents added a number of
previously-unidentified symptoms. Particularly given the lack of any relevant medical records,
this inconsistent reporting of John’s medical history makes it impossible to render a reliable
diagnosis or establish any cause of his varyingly alleged ailments. Nothing in the Salas’s

testimony or the materials they have submitted could support a reliable conclusion either as to
the identity of John’s diseases or conditions, or what might have caused them.

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John testified that exposure to the herbicide spray caused body pain, bone pain, sore
throat, headache, and an inability to get out of bed (Dep. 49). His mother Laura testified that he
also experienced burning eyes, itching, vomiting, dizziness, throat problems, and a lack of
appetite (Laura Dep. 44, 65, 71). All of these symptoms are non-specific and quite common in
rural Ecuador, and there are many potential diseases and conditions that could have caused each

of them. Jorge testified that John also had the flu (Dep. 109-10), which would explain many of
his alleged symptoms. They are, however, consistent as well with a number of other common
diseases, none of which are related to a chemical exposure. At his deposition, John complained
of ongoing headaches, sore throat, and bone pains which he has experienced since the herbicide
exposure (Dep. 51-52). He testified that these conditions require occasional treatment with

medications by the school principal (Dep. 55). All of these are common complaints and have
many potential causes. Recurrent sore throat in a young person is most commonly due to bouts
of Streptococcal pharyngitis or viral pharyngitis, which are caused by infectious agents and
neither of which would be caused by a chemical exposure. Bone pain in young children who are

going through growth spurts is quite common and can be due to what is termed “growing pains.”
Beyond this most obvious cause, there are other more serious illnesses endemic to the region that
could be considered, such as Dengue fever and malaria. Given the lack of more specific
information, including more in depth history, physical exam, and laboratory tests, it is impossible
to determine a distinct cause of any of his symptoms. There is no medical basis upon which one

could opine that any of his alleged ailments were caused by exposure to Plan Colombia
herbicide.

F. Mestanza Family

In their depositions, the test-plaintiff members of the Mestanza family allege that they

suffered various symptoms as a result of alleged spraying on five occasions between 2000 and
2002. Their exposure allegations are inconsistent with the answers in their questionnaire
responses, which alleged exposures on varying other dates. The family members’ claims are all
based on self-reporting; there are no relevant medical records, medical history, or laboratory tests

that could support a reliable diagnosis. The need to rely on the family’s self-reporting is
particularly problematic because the family has admitted that some of the ailments that they had
at one time attributed to the spraying did not in fact occur. For example, 42-year-old son Edy
Mestanza’s Questionnaire claimed that he saw spray planes, described the spray operations in
detail, and alleged that he experienced various symptoms from the spraying. He admitted at his

deposition, however, that he was never at the farm during the spraying and suffered no physical
injuries because of it. The Mestanza family likewise had previously alleged that the Plan
Colombia herbicide had caused various injuries to three other family members who they
subsequently conceded also were hundreds of miles away from the location of the alleged
spraying (at the family’s principal home in Guayaquil) and who suffered none of the alleged

symptoms (Pls.’ Motion to Dismiss Three Individual Pls. at 1-2; Defs.’ Response at 3-8). For
those family members who still allege that they were physically injured, the allegations of
physical injury are inconsistent and have changed over time.

Moreover, as discussed below, there are a number of other conditions common in rural
Ecuador that could have caused each of the family members’ now-alleged symptoms. Because

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of all of these factors, it would be pure speculation to diagnose their conditions or identify a
causal connection between the symptoms and a chemical exposure.

11
According to their questionnaires, at their farm in Sucumbios, the Mestanzas live in a
home made of wood with no running water (Victor Questionnaire IV.A.1, 4). There were
inconsistent questionnaire answers regarding where the family obtains drinking water, but it is
obtained from some natural body of water (Victor & Ercilia Questionnaires IV.A.2-3). Ercilia’s

Questionnaire response stated that they did not filter their water, while Victor’s Questionnaire
stated that they filtered it by boiling it (Victor & Ercilia Questionnaire IV.A.5). If they indeed
failed to filter or boil their water, it would increase the family’s susceptibility to a number of
potential infectious disease agents. Victor and Ercilia’s Questionnaires both stated that the

family uses an outhouse, but their answers were not consistent as to whether there was a toilet
inside the home (Victor & Ercilia Questionnaires IV.B.3, 4). After reviewing a video of the
family’s living conditions with standing water, goats, pigs, and cows nearby, the unsanitary
living conditions are vividly confirmed. Mr. Mestanza also makes a long speech about the lack
of a school in the community which has caused a number of families to move away seeking an

education for their children.

1. Victor Mestanza

Victor Mestanza is a 60-year-old male who reports exposure to spraying in late 2000,

January 2002, September 2002, and October 7 and 10, 2002. Mr. Mestanza testified that the
spraying caused him to experience itching skin, irritation of his eyes and throat, and bacterial or
fungal infections, and he testified that the spraying may have caused symptoms including
headaches and problems with his stomach, throat, and vision (Dep.46-47, 56, 68, 74, 82-83, 137,

140). Like the rest of the family, Mr. Mestanza has submitted no medical records to document
his alleged conditions. There is similarly no detailed history or confirmatory laboratory results.
Moreover, Mr. Mestanza has not been a consistent historian with respect to his alleged
symptoms. At his deposition he failed to mention several of the symptoms claimed in his
questionnaire, and stated that many of the rest “may be a coincidence” (Dep. 83). He also did

not make any mention of personal injuries from the spraying in a video he made shortly after the
October 2002 spraying, and no such injuries are apparent in the video. In any event, each of Mr.
Mestanza’s varyingly alleged symptoms is common in rural Ecuador, and his testimony does not
provide any reliable basis upon which to opine that they were caused by exposure to Plan

Colombia herbicide.

Mr. Mestanza testified that he experienced some combination of itching of his skin and
irritation (burning and/or itching) of his eyes and throat after each exposure. He reports having
seen Dr. Erwin Gonzabay for these conditions and having received treatment. As mentioned

above, eye and skin conditions are extremely common in rural Ecuador and could be explained
by many diseases that I saw regularly in my practice there. In addition, a number of potential
diseases or health conditions could be responsible for Mr. Mestanza’s complaints of throat
irritation.

11
As made clear in their depositions, the Mestanza family’s principal place of residence, currently and at
the time of the alleged spraying events, is in Guayaquil, 275 miles from the Ecuador-Colombia border.

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Mr. Mestanza also reports other symptoms that he concedes “may have been
coincidence” after the spraying including stomach problems, gastritis, headaches, throat

problems, and loss of eyesight (Dep. 82-83). He appears to have claimed that he had bacterial or
fungal infections and an inability to eat as a result of the spraying (Dep. 137, 140). Mr.
Mestanza has produced a certification signed by Dr. Gonzabay stating that as of October 2002
Mr. Mestanza had chronic contact dermatitis from polluted water, about a 35% diminution in

vision forcing him to wear glasses, and chronic gastroenteritis, all of which Mr. Mestanza
attributes to the spraying. Though this certification is signed by Dr. Gonzabay, Dr. Gonzabay
has testified that he has not reached any opinion that these symptoms were caused by the
spraying and that he did not prepare the certification, which was provided to him by Mr.
Mestanza some ten months after he had seen him. Dr. Gonzabay explained that in signing the

certificate,12r. Gonzabay was simply acknowledging that Mr. Mestanza had made these health
complaints.

All of the symptoms varyingly alleged by Mr. Mestanza are commonly seen in Northern
Ecuador as a result of endemic health problems that have nothing to do with any alleged toxic

exposure. Indeed, many of his health complaints could not occur as a result of a chemical
exposure. Bacterial or fungal infections would be caused by one or more of the many infectious
agents prevalent in rural Ecuador, and could not be caused by a chemical exposure. Chronic
dermatitis also is unlikely to be caused by infrequent and isolated chemical exposures, and in any

event can be caused by numerous conditions endemic to the Ecuadorian Amazon. The decreased
vision was most likely due to age-related presbyopia, especially because Victor used eyeglasses
to correct it (according to the Gonzabay certification). Among a myriad of other causes,
headaches can be caused by patients who need glasses not having them or having an incorrect

prescription. As mentioned earlier, chronic gastritis is extremely common in Ecuador and is
highly associated with H. pylori infection, though there are many other potential causes. There is
no reliable basis to conclude that any of Mr. Mestanza’s symptoms were caused by herbicide
exposure.

2. Ercilia Bosquez

Ercilia Bosquez is the 58-year-old wife of Victor. While her health complaints are
somewhat unclear, she appears to be alleging that she experienced different symptoms following
the different alleged spraying events, and her reporting of her symptoms has changed over time.

As with her husband, Mrs. Bosquez’s claims are based on self-reporting; there are no medical
records or contemporaneous evidence to support her medical complaints. Mrs. Bosquez’s
testimony does not provide a reliable basis to conclude that her claimed symptoms were caused
by exposure to Plan Colombia herbicide.

During her deposition, Mrs. Bosquez testified that she: (1) experienced itching of the
nose and burning of the throat after her first exposure (Dep. 38-39), (2) experienced throat and
stomach problems after her second exposure (Dep. 56), (3) experienced no symptoms after her

12
Dr. Gonazabay testified that the certifications reflected what the patient reported, and he did not
conclude that the spraying caused the reported symptoms (Dep. 61). At his deposition, Victor
acknowledged that his certification only repeated what he told Dr. Gonzabay (Dep. 143).

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third exposure (Dep. 60), and (4) experienced nose and throat irritation, stomach problems, and
after two days or so itching and a rash, after her fourth and fifth exposure (Dep. 70). She
reported a skin problem due to contaminated water (Dep. 102-03). After being shown her
questionnaire responses, Mrs. Bosquez testified that she experienced respiratory problems and
diarrhea (Dep. 89-90). She also testified that she has suffered the following symptoms since the

first sprayings: a sore throat, stomachache, a rash, and an itch (Dep. 46-47). She alleges that her
ongoing rash is intermittent, getting better with cream given her by the doctor and then tending
to recur (Dep. 97-99). Mrs. Bosquez has submitted a certification from Dr. Gonzabay stating
that as of October 2002 she had chronic contact dermatitis due to polluted water, chronic
pharyngotonsillitis, and chronic gastroenteritis. As explained during the discussion of Victor

Mestanza’s claims, this certification merely recounts Mrs. Bosquez’s allegations and does not
represent an opinion by Dr. Gonzabay regarding what may have been responsible for her
complaints.

All of Mrs. Bosquez’s alleged symptoms are non-specific and are symptoms that I treated
quite often during my practice in Ecuador. Mrs. Bosquez’s ongoing rash and itching are far

more likely to be caused by a parasite or bacterial infection than alleged isolated chemical
exposure 8 or 9 years ago. In the Gonzabay certification, Mrs. Bosquez complains of three
chronic illnesses. However, chemical exposures that are not ongoing are unlikely to cause
chronic conditions, and there are a number of explanations for each of the claimed symptoms.
Chronic contact dermatitis could be caused by repeated and ongoing cutaneous exposure to

numerous substances that are everpresent in Ecuador. Chronic pharyngotonsillitis is most
commonly due to recurrent viral or bacterial infections, among many other potential causes. As
mentioned, chronic gastritis is extremely common in Ecuador and is highly associated with H.
pylori infection, though again there are other potential causes. It would be impossible to arrive at
a reliable diagnosis for any of Mrs. Bosquez’s symptoms. The various symptoms Mrs. Bosquez

reported following different exposures makes it significantly less likely that her symptoms would
have been due to any single cause, let alone transient exposures to the Plan Colombia herbicide.

3. Edy Mestanza

Edy Mestanza is the 42-year-old son of Victor and Ercilia. As noted above, despite his

questionnaire responses indicating that he had seen the spray aircraft and suffered various
symptoms from exposure to the spraying, he admitted at his deposition that he experienced no
physical injuries and had not even been at the farm when he was allegedly exposed to the
herbicide (Dep. 66, 81). He identified, however, new claims of emotional and psychological
damages as a result of his alleged property losses from the spraying and his family members’

alleged physical injuries (Dep. 82, 158-59). These claims are unsupported by any medical
records or contemporaneous evidence.

4. Jennifer Mestanza

Jennifer Mestanza is the 14-year-old daughter of Edy and grandaughter of Victor and

Ercilia. Her testimony and that of her family members reveals a wide range of conflicting
symptoms. The symptoms alleged are inconsistent across exposures and the family members
have dramatically different recollections of her symptoms. As with the rest of the family, no
medical records or laboratory tests are available. Neither Jennifer’s nor her family members’

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testimony can provide a sufficient basis to diagnose her symptoms or link them to herbicide
exposure.

Jennifer remembers very little about her first alleged exposure (in 2000), but testified that

after the later exposures (in 2002), she suffered itching skin, burning eyes, and a sore throat
(Dep. 49-50). Victor (her grandfather) testified that during the first exposure she experienced
burning in her eyes and throat (Victor Dep. 47), while Ercilia (her grandmother) testified that
Jennifer had the same symptoms as she did (Ercilia Dep. 44), i.e. itching in her nose burning in

her throat (Ercilia Dep. 38) (and potentially sore throat, stomachache, a rash, and an itch, which
Ercilia stated she had experienced since the first exposure (Ercilia Dep. 46-47)). Like Ercilia,
Jennifer also apparently had no symptoms following the third exposure (Ercilia Dep. 61).
Jennifer testified that she still suffers from itching skin, sore throat, and burning eyes (Dep. 50).
Edy (her father) testified that she still has skin and throat problems (Edy Dep. 92), and that she

previously experienced and may still be experiencing respiratory problems (Edy Dep. 93).
Ercilia testifed that Jennifer still experiences only throat problems (Ercilia Dep. 104). The
plaintiffs submitted a certification signed by Dr. Gonzabay stating that as of October 2002
Jennifer suffered from chronic contact dermatitis due to polluted water, approximately 35%

diminution of vision forcing her to wear eyeglasses, and chronic gastroenteritis, allegations th13
are identical to those set forth in the certificate the family had prepared for Victor Mestanza. In
her deposition, however, Jennifer testified that she could not remember any stomach problems,
that her eyesight is fine, and that she has never worn eyeglasses. (Jennifer Dep. 57-58, 104-106).

It is also notable that Dr. Gonzabay’s treatment of Jennifer suggests that he did not attribute her
condition to any toxic exposure. Dr. Gonzabay testified that he treated Jennifer with corticoids,
antimycotics, and antibiotics, which are standard remedies for bacterial or fungal infections, and
that this treatment was successful (Gonzabay Dep. 62-63).

As with the rest of the family, Jennifer’s alleged symptoms are common in the
Ecuadorian Amazon. It is difficult to postulate how any alleged transient exposure to a herbicide
could cause the ongoing skin problems from which Jennifer is alleged to suffer. It is much more
likely that Jennifer suffers from eczema, scabies, a fungal infection, or contact dermatitis due to

ongoing exposure to some other substance, among many other potential causes. As mentioned
previously, recurrent throat irritation in this age group is common and is usually due to recurrent
viral or Streptococcal infection. Likewise, eye irritation is quite common in the tropics and
could be due to the intense sunlight or numerous other diseases or factors. Nothing in any of the

family’s testimony or any other materials provides a reliable basis to diagnose Jennifer’s medical
conditions or opine to a causal relationship to herbicide exposure.

13As explained earlier, in signing this certificate, Dr. Gonzabay was simply acknowledging the family’s
allegations; he testified that he did not make any determination himself as to whether the Plan Colombia

spraying caused the alleged symptoms.

495Annex 13

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 31 of 62

G. Elvia Alvarez

The last test plaintiff, Elvia Alvarez is a 54-year-old woman who testified at her
deposition that she she saw spray planes near her farm in April 2001, and then approximately six
months later she heard planes but apparently did not see them (Dep. 30, 78-79). She lives in a
wood plank house (Dep. 22; Questionnaire IV.A.1), and she testified that she gets her water from
a stream that flows from a swamp and from rainfall (Dep. 22, 60-61). She does not filter the

water (Dep. 22), which increases the risk that microbes and other organisms could cause
infections and other health problems. She has an outhouse about 30 meters from the house (Dep.
22).

Ms. Alvarez alleged in her deposition testimony that she experienced a headache,

dizziness, body pain, stomachache, diarrhea, and she was spitting up blood (Dep. 34). She
testified that these symptoms began slowly about one or two days after her exposure, and while it
is unclear, it appears that she experienced most of them for about three months (Dep. 34, 63-64).
She apparently experienced fever and cough for three to six months, and she still has bloody
sputum, but it is unclear and she may still experience all of these symptoms (Dep. 63-64). Ms.

Alvarez did not provide any medical records documenting these symptoms. She testified that
she has been told that she has tuberculosis, but she has been afraid to visit a doctor and instead
uses traditional remedies (Dep. 64-65). I agree that her symptoms indeed sound like a typical
case of pulmonary tuberculosis but could also represent a case of bronchiectasis or
paragonamiasis. None of these conditions would be caused by a brief chemical exposure.

Ms. Alvarez also testified that she had a rash that lasted for approximately a month (Dep.
135). As explained earlier, skin conditions are extremely common in rural Ecuador, and her rash
could have been caused by bacterial skin infections or parasitic infestation. Likewise, there is
nothing unusual about Ms. Alvarez’s other claimed symptoms; they are symptoms that I treated
regularly in Ecuador. It is unlikely that a brief chemical exposure would cause either delayed or

chronic symptoms, both of which Ms. Alvarez reports. Indeed, it is unlikely that any single
cause could be responsible for a wide variety of symptoms with varying lengths of time elapsed
from exposure to onset of symptoms. In any event, with the information available no physician
could reliably diagnose Ms. Alvarez’s symptoms.

Any possibility of reaching a reliable opinion as to a potential cause of Ms. Alvarez’s
medical conditions is foreclosed by the fact that she has been an inconsistent historian regarding
her symptoms. Her questionnaire alleges only body aches and cough productive of bloody
sputum (Questionnaire V.E.1 and V.E.7). In her deposition testimony, she adds previously-
unidentified headache, dizziness, stomachache, diarrhea, and rash (Dep. 34, 135). Her

questionnaire states that her symptoms started one year after she saw the spray planes
(Questionnaire V.E.1), but she later testified that the symptoms began “little by little” one or two
days after she saw the spray planes (Dep. 34). These inconsistencies, combined with the
numerous alternative causes for her symptoms and the lack of confirmatory medical records or
laboratory tests, precludes reaching any reliable conclusion even as to a diagnosis of Ms.

Alvarez’s symptoms, let alone opining to a causal connection between those symptoms and
exposure to Plan Colombia herbicide.

496 Annex 13

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CR Note: Dr. Smalligan's CV (Exhibit A), found in CD - Original Annexes

497Annex 13

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EXHIBIT B

Case 1:07-cv-01042-RWR -DAR Document 220-12 Filed 08/19/11 Page 58 of 62

Roger D. Smalligan, M.D. Materials Considered

Publications

1) Armijos, R.X., M.M. Weigel, R. Izurieta, J. Racines, C. Zurita, W. Herrera and M.
Vega. 1997. The epidemiology of cutaneous leishmaniasis in subtropical Ecuador.
Tropical Medicine and International Health 2(2): 140-152.

▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯ aherrera and J.

Valencia. 2007. The Plan Colombia Aerial Spraying System and Its Impact on the
Ecosystem and Health on the Ecuadorian Border. Scientific Commission of
Ecuador. Quito, Ecuador.

3) Beisel, W.R. 2000. Interactions between Nutrition and Infection. Pages 967-970 in
Strickland, G.T., ed. Hunter’s Tropical Medicine and Emerging Infectious Diseases.
8th Ed. 2000. Philadelphia, PA: W.A. Saunders.

4) Bradberry, S.M., A.T. Proudfoot and A.J. Vale. 2004. Glyphosate poisoning.

Toxicology Review 23(3):159-167.

5) Calvopina, M., R.X. Armijos and Y. Hashiguchi. 2004. Epidemiology of
▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯ ▯ ▯ ▯▯▯▯▯▯▯ ▯▯▯ rias do

Instituto Oswaldo Cruz 99(7): 663-672.

6) Chang, C.Y., Y.C. Peng, D.Z. Hung, W.H. Hu, D.Y. Yang and T.J. Lin. 1999.
Clinical impact of upper gastrointestinal tract injuries in glyphosate-surfactant oral

intoxication. Human and Environmental Toxicology 18: 475-478.

7) Chandra, R.K. 1997. Nutrition and the Immune System: An Introduction. American
Journal of Clinical Nutrition 66: 460S-463S.Cooper, P.J., A. Guevara and R.H.
Guderian. 1993. Intestinal helminthiases in Ecuador: the relationship between

prevalence, genetic, and socioeconomic factors. Revista da Sociedade Brasileira de
Medicina Tropical 26(3): 175-180.

9) Cooper, P.J., R. Proano, C. Beltran, M. Anselmi and R.H. Guderian. 1995.

Onchocerciasis in Ecuador: ocular findings in Onchocerca volvulus infected. British
Journal of Opthalmology 79(2): 157-162.

10) Cox, C. 1995. Glyphosate, Part 1: Toxicology. Journal of Pesticide Reform 15(3).

11) Cox, C. 1995. Glyphosate, Part 2: Human Exposure and Ecological Effects. Journal
of Pesticide Reform 15(4).

12) De Roos, A.J., A. Blair, J.A. Rusiecki, J.A. Hoppin, M. Svec, M. Dosemeci, D.P.
Sandler and M.C. Alavanja. 2005. Cancer incidence among glyphosate-exposed

498 Annex 13

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pesticide applicators in the agricultural health study. Environmental Health
Perspectives 113(1): 49-54.

13) Eriksson, M., L. Hardell, M. Carlberg and M. Akerman. 2008. Pesticide exposure as
risk factor for non-Hodgkin lymphoma including histopathological subgroup

analysis. International Journal of Cancer 123(7):1657-1663.

14) Esrey, S.A., J.B. Potash, L. Roberts and C. Shiff. 1991. Effects of Improved Water
Supply and Sanitation on Ascariasis, Diarrhoea, Dracunculiasis, Hookworm
Infection, Schistosomiasis, and Trachoma. Bulletin of the World Health

Organization 69(5): 609-621.

15) Garry, V.F., M.E. Harkins, L.L. Erickson, L.K. Long-Simpson, S.E. Holland and
B.L. Burroughs. 2002. Birth defects, season of conception, and sex of children born
to pesticide applicators living in the Red River Valley of Minnesota, USA.
Environmental Health Perspectives 110(Suppl 3): 441-449.

16) Gatti, S., G. Swiercynski, F. Robinson, M. Anselmi, J. Corrales, J. Moreira, G.
Montalvo, A. Bruno, R. Maserati, Z. Bisoffi and M. Scaglia. 2002. Amebic
infections due to the Entamoeba histolytica-Entamoeba dispar complex: a study of
the incidence in a remote rural area of Ecuador. American Journal of Tropical
Medicine and Hygiene 67(1): 123-127.

17) Giesy, J.P., S. Dobson and K.R. Solomon. 2000. Ecotoxicological risk assessment
for Roundup herbicide. Rev. Environ. Contam. Toxicol 167: 35-120.

18) Grijalva, M.J., L. Escalante, R.A. Paredes, J.A. Costales, A. Padilla, E.C. Rowland,
H.M. Aguilar and J. Racines. 2003. Seroprevalence and risk factors for

Tripanosoma cruzi infection in the Amazon. American Journal of Tropical
Medicine and Hygiene 6(4): 380-385.

19) Guderian, J.R., M. Anselmi, M. Espinel, C. Sandoval, P.J. Cooper, G. Rivadeneira
and R.H. Guderian. 1997. Onchocerciasis in Ecuador: prevalence of infection on
the Ecuador-Colombia border in t▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ rias do

Instituto Oswaldo Cruz 92(2): 157-162.

20) Hardell, L. and M. Eriksson. 1999. A case-control study of non-Hodgkin lymphoma
and exposure to pesticides. Cancer 85(2):1353-1360.

21) Hardell, L., M. Eriksson and M. Nordstrom. 2002. Exposure to pesticides as risk

factor for non-Hodgkin’s lymphoma and hairy cell leukemia: pooled analysis of
two Swedish case-control studies. Leukemia & Lymphoma 43(5):1043-1049.

22) Hurtig, A.K., M. San Sebastian, A. Soto, A. Shingre, D. Zambrano and W.
Guerrero. 2003. Pesticide use among farmers in the Amazon basin of Ecuador.
Archives of Environmental Health 58(4): 223-228.

499Annex 13

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▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯ n y de
Vivienda; Resultados Definitivos. Vivienda. Sucumbios, Esmeraldas, and Pastaza.

24) Maibach, H. 1986. Irritation, sensitization, photoirritation and photosensitization
assays with a glyphosate herbicide. Contact Dermatitis 15:152-156.

25) Marc, J., O. Mulner-Lorillon, S. Boulben, D. Hureau, G. Durand and R. Belle.
2002. Pesticide Roundup provokes cell division dysfunction at the level of
CDK1/Cyclin B activation. Chemical Research Toxicology 15:326-331.

26) Marc, J., O. Mulner-Lorillon and R. Belle. 2004. Glyphosate-based pesticides affect
cell cycle regulation. Biology of the Cell 96: 245-249.

27) Ministerio de Salud, Republica de Ecuador. 2007. Indicadores Basicos de Salud.

28) Mintz, E.D., M.F. Feiff and R.V. Tauxe. 1995. Safe Water Treatment and Storage

in the Home: A Practical New Strategy to Prevent Waterborne Disease. Journal of
the American Medical Association 273(12): 948-953.

29) Pan American Health Organization (PAHO). 2007. Ecuador. Pages 304-321 in
Health in the Americas, Volume II. Washington, DC: PAHO.

30) Raipulis, J., M.M. Toma and M. Balode. 2009. Toxicity and genotoxicity testing of

Roundup. Proceedings of the Latvian Academy of Sciences, Section B, 63(1/2):29-
32.

31) U.S. Department of State. 2002. Chemicals used for the aerial eradication of illicit
coca in Columbia and conditions of application. In Report on Issues Related to

Aerial Eradication of Illicit Coca in Colombia.

32) Richard, S., S. Moslomi, H. Sipahutar, N. Benachour and G.E. Seralini. 2005.
Differential Effects of Glyphosate and Roundup on Human Placental Cells and
Aromatase. Environmental Health Perspectives 113:716-720.

33) Rinne, S.T., E.J. Rodas, B.S. Bender, M.L. Rinne, J.M. Simpson, R. Galer-Unti

and L.T. Glickman. 2006. Relationship of pulmonary function among women and
children to indoor air pollution from biomass use in rural Ecuador. Respiratory
Medicine 100(7):1208-1215.

34) San Sebastian, M. and S. Santi. 1999. The Health Status of Rural School Children

in the Amazon Basin of Ecuador. Journal of Tropical Pediatrics 45: 379-382.

35) Solomon, K., A. Anadon, A. Cerdeira, J. Marshall and L. Sanin. 2007.
Environmental and Human Health Assessment of the Aerial Spray Program for
Coca and Poppy Control in Colombia. Rev. Envtl. Contam. Toxicol. 190:43-125.

36) Solomon, K., E.J.P Marshall and G. Carrasquila. 2009. Human Health and

Environmental Risks from the Use of Glyphosate Formulations to Control the

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Production of Coca in Colombia: Overview and Conclusions. J. Toxicol. Envtl.
Health, Part A, 72:15, 914-920.

37) Stupp, P., K. Ishida and J. Sotomayor. 2009. Stalled Decline in Fertility in Ecuador.
International Perspectives on Sexual and Reproductive Health 35(4): 203-206.

38) United Nations Organization. April 2006. Report from the Preliminary Technical
Mission of the United Nations to Propose Studies Covering the Impact from the
Aerial Spraying and Complementary Actions on the Northern Border of Ecuador.

Quito, Ecuador.

39) Veillett, C. & C. Navarette-Frias. 2005. Drug Crop Eradication and Alternative
Development in the Andes. Congressional Research Service (CRS), CRS Report for
Congress. Order Code RL33163.

40) Vieria, N., S.J. Bates, O.D. Solberg, K. Ponce, R. Howsmon, W. Cevallos, G.
Trueba, L. Riley and J.N. Eisenberg. 2007. High prevalence of enteroinvasive
Escherichia coli isolated in a remote region of northern coastal Ecuador. American
Journal of Tropical Medicine and Hygiene 76(3): 528-533.

Other Materials Considered

1) Binder of Full Deposition Testimony for all Test Plaintiffs.

2) Defendants’ Response to Plaintiffs’ Motion to Dismiss Three Individual Plaintiffs,

No. 1:01-cv-01908-RWR-DAR, ECF Doc. No. 172, January 6, 2010.

3) Expert Report by Plaintiffs’ Expert Witness, Dr. Michael Wolfson.

4) Excerpts of Test Plaintiff Victor Mestanza Deposition Transcript, November 9,
2009.

5) Excerpts of Dr. Edwin Gonzabay Deposition Transcript, July 8, 2009.

6) Response from Stephen Johnson, Assistant Administrator, U.S. EPA, to Colin
Powell, Secretary of State, re Consultation Review of the Use of Pesticide for Coca
Eradication in Colombia. August 19, 2002.

7) Plaintiffs’ Motion to Dismiss Three Individual Plaintiffs, No. 1:01-cv-01908-RWR-
DAR, ECF Doc. No. 171, December 23, 2009.

8) Plaintiffs’ Reply in Support of Their Motion to Dismiss Three Individual Plaintiffs,
No. 1:01-cv-01908-RWR-DAR, ECF Doc. No. 175, January 13, 2010.

9) Order by Judge Richard W. Roberts, No. 1:01-cv-01908-RWR-DAR, ECF Doc.

No. 178, January 29, 2010.

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10) Video featuring Victor Mestanza and the Mestanza farm. November 2002. PLS-

00005881.

11) Video featuring Victor Mestanza and the Mestanza farm. August 2009. PLS-
00005882.

12) a binder for each test plaintiff family containing:

A) a table with citations to claims of physical injuries in certain evidentiary
submissions of the test plaintiffs (initial disclosures, questionnaire responses,
declaration of Marco Campana, deposition testimony excerpts, Accion Ecologica
toxicology sheet and survey)

B) the following information for each test plaintiff (if applicable to the test plaintiff
and/or family):

i) initial disclosure

ii) questionnaire responses

iii) excerpt from the Marco Campana declaration specific to each plaintiff

iv) all deposition testimony excerpts re alleged personal injuries/illnesses and

related issues

v) other test plaintiff-specific information relating to their alleged physical
injuries (e.g., medical records, photographs and/or video, excerpts from
prior lawsuits, prior certifications, Accion Ecologica toxicology sheet and

survey)

vi) excerpts of certain non-governmental organization and other third party
reports that mention the test plaintiffs or the areas in which they live with
respect to diseases or public health conditions

C) a map showing the approximate location of the test plaintiffs’ farm and spray
lines (if any) for the dates of spray exposure alleged by any of the family
members in their depositions

502 Annex 14

EXPERT R EPORT OFDR R.C. PLOETZ, PH.D.ON BEHALF OF
THED EFENDANTS INARIAS/QUINTEROS . DYNCORP,

19 JANUARY 2011

(United States District Court for the District of Columbia,

503504 Annex 14

Case 1:07-cv-01DocumentFiled 0Page 1 of 58

EXHIBIT 11

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 2 of 58

¡ȱȱȱ¢ȱǯȱ£ȱ

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My name is Randy C. Ploetz. I am a tenured Professor of Plant Pathology with the University of
Florida, where I have served on the faculty since 1986. I received a B.S. in Forestry and an M.S.

in Plant Pathology from Purdue University, and a Ph.D. in Plant Pathology from the University
of Florida. My areas of specialization are the etiology, epidemiology and control of diseases in
subtropical and tropical agroecosystems. My current research activities include investigations
of: (a) the epidemiology and management of laurel wilt disease on avocado; (b) the population

biology of Colletotrichum gloeosporioides and the diseases it causes on mango; (c) the
Botryosphaeria pathogens of diverse hosts in South Florida; (d) the phylogeny and geographic
origins of the pathogens that cause mango malformation and the management this disease; and
(e) the biology and management of various diseases of tropical fruit, vegetable and ornamental

crops. My current extension and outreach activities include addressing the threat posed to
banana production in the Western Hemisphere by the pathogen Tropical Race 4 of Panama
disease (TR4 below).

I have a research appointment at the University of Florida (95%) with secondary teaching
responsibilities (5%) as a student advisor (currently seven Ph.D. and one M.Sc.) and an instructor
in HOS 5555 (Tropical Fruit Production and Research in Florida). I am a member of several

professional societies, and have held, and currently hold, leadership positions in the International
Society of Plant Pathology, the American Phytopathological Society, the Florida State
Horticultural Society and the Florida Phytopathogical Society. I received the University of
Florida’s Research Professor Award in 2004 and the American Phytopathological Society’s

International Service Award in 2008.
I am an authority on diseases of tropical crops, with emphasis on those that occur on tropical

fruits. I have written over 300 publications, including papers in refereed journals (90), books (4),
book chapters (54), abstracts (135) and numerous technical bulletins and popular articles. A list
of my publications is included with my CV, which is attached hereto as Exhibit A. I edited and
wrote chapters in Fusarium Wilt of Banana and Compendium of Tropical Fruit Diseases for APS

Press and another book, Diseases of Tropical Fruit Crops, for CAB International; each of which
are standard references for research and teaching. I am interviewed often on tropical plant
disease problems, most recently concerning the perceived threat of extinction of banana and the
serious impact that cacao diseases have on global chocolate production (television: NPR Canada;
radio: Discovery Channel and Ira Flatow’s Science Friday; magazines: Popular Science,

Scientific American and New Yorker; and books: Banana: The Fate of the Fruit that Changed the
World).

Much of my work is conducted in other countries, with on-going collaborations in several
countries and work in 36 since 1990 (Australia, Austria, Bahamas, Benin, Bolivia, Brazil,
Burundi, Canada, China, Colombia, Costa Rica, Dominican Republic, Ecuador, Egypt, France,
Honduras, Indonesia, Israel, Jamaica, Malawi, Malaysia, Mexico, Nicaragua, Nigeria, Oman,

505Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 3 of 58

Peru, Rwanda, South Africa, South Korea, Spain, Swaziland, Taiwan, Thailand, Uganda, United
Arab Emirates, and the United Kingdom).

I have been to Ecuador four times. In 2004, I was an invited participant at a meeting in Quevedo
on cacao diseases and their biological control. While there, I reviewed cacao research programs
at Ecuador’s Autonomous National Institute of Farming Research (INIAP) facility in Pichilingue
and visited cacao production and research sites in the region. Most recently, I spoke at banana

conferences on the threat posed by the pathogen TR4 (outreach activity mentioned above). I was
an invited speaker at the Association of Ecuadorian Banana Exporters (AEBE) (a national
association of banana producers and exporters) conferences in 2007 and 2009, and an invited
speaker at the ACORBAT (biennial hemispheric meeting of banana producers and researchers)

meeting in 2008, all of which were held in Ecuador in the city of Guayaquil. In 2007, I visited
traditional and organic banana production sites in the country, and in 2008 visited agricultural
production and research sites. I was also an invited plenary speaker at the ACORBAT 2010
meeting in Medellin, Colombia, in November 2010.

In general, I am a consultant for international agencies and producers; I assess new disease
outbreaks and the status of other, important problems on tropical crops; and I advise research
projects. I served two consecutive terms as Chair of the Fusarium Wilt Working Group of the

Consultive Group on International Agricultural Research’s (CGIAR’s) International Network for
the Improvement of Banana and Plantain.

B. Compensation and Prior Expert Witness Experience
I am being compensated at a rate of $450 per hour. I have never previously served as a testifying
expert in litigation.

C. MateriC aosnsidered

The materials that I have considered in my report are referenced herein and set forth in Exhibit
B, attached hereto.

II. Summary of Expert Opinions

I have been advised that the Ecuadorian plaintiffs in the above referenced litigation are alleging
that their crops were damaged by herbicide spray used in the Republic of Colombia for the aerial

eradication of coca for Plan Colombia. Based upon my review of the videographic and
photographic evidence, lab tests, and other investigation reports provided by the plaintiffs
relevant to these allegations, along with my general background and expertise in tropical diseases
in crops, I have reached the following opinions:

A. Plant diseases are prevalent in tropical environments (see Ploetz, 2007b, attached
as Exhibit C), and are commonplace in the region in which the plaintiffs reside.

B. The videographic, photographic and laboratory data evidence provided by the test
plaintiffs does not provide any reliable scientific basis for their allegations of
glyphosate based damages. To the contrary, the evidence presented indicates that

the alleged crop damage was likely caused by plant diseases that are endemic to
the region.

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III. Basic tutorial on plant diseases

Disease background. Disease is defined as a disruption of the normal growth or function of a
plant that is caused by the continuous insult of a pathogen, i.e., a disease-causing agent (Agrios,

2005). Disease results from the interaction of a susceptible plant (=“host”) and a pathogen.
Pathogens in two of three Domains of living organisms, the Eukaryota and Eubacteria, cause
plant diseases (Figure 1) (no pathogens are known in the third Domain, the Archaea, and viruses

and viroids, which are not living organisms, have unclear affinities with these life forms). Those
in the Eukaryota have cells with complex structures called organelles (e.g. nuclei) that are
surrounded by membranes, whereas the Eubacteria are similar organisms that do not possess

organelles. The most common pathogens are fungi, which cause 70% of all plant diseases,
followed by bacteria, oomycetes, viruses, nematodes, phytoplasmas, parasitic plants, viroids and
protozoa (Agrios, 2005; Ploetz, 2008). Each host plant species is affected by a specific suite of

diseases, some of which are unique to that plant and others that are caused by generalist
pathogens and also occur on other host plants.

)LJXUH3K\ORJHQHWLFUHODWLRQVKLSVDPRQJSODQWSDWKRJHQVDGDSWHGIURP&LFFDUHOOLHWDO

Disease etiology and diagnosis. In general, pathogens must infect their hosts before they can
cause disease (noninfectious diseases are uncommon; see Woltz, 1978). Infectious diseases

cause a wide variety of symptoms, including blights, fruit and leaf spots, post-harvest decays,
vascular wilts, cankers, rots and tumors (Agrios, 2005).

To prove that a given microbe can cause the disease symptoms that are observed on a plant, a
series of criteria must be met (Agrios, 2005). Koch’s postulates indicate that: i) a microbe must

be associated with and isolated from diseased tissue, ii) that the isolated microbe will infect and

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cause the same symptoms when used to inoculate healthy plants of that species, and iii) that the
microbe can be reisolated from the inoculated, symptomatic plants. With these criteria, proof

has been met that the suspect microbe can cause the indicated disease (i.e., it is a pathogen).
Fulfilling Koch’s postulates are important when it is necessary to establish the cause of a new

disease (new pathogen:host combination). However, they need not be met in investigating the
cause of specific plant damage when a disease is well known and understood. For some
common diseases, fairly reliable identification can be obtained by observing characteristic
symptoms that the disease causes on its host plant and the host species or host tissue on which
the disease occurs. Frosty pod of cacao (aka monilia pod rot or moniliasis) and the Sigatoka

leafspots of banana and plantain are examples of diseases that can be diagnosed based on the
symptoms that they cause (Renard, 2001; Thurston, 1998). In contrast, symptoms caused by
some common diseases have a less distinctive appearance and can be confused with those caused
by other diseases or plant damage (Riley et al., 2002). For example, the damage that root
diseases cause in the above-ground portions of plants is often ambiguous in that the specific

disease can usually not be identified based on above-ground symptoms. When symptoms are
ambiguous, isolation and identification of the causal agent is necessary. If no pathogen is
recovered, unculturable pathogens should then be considered (e.g. viruses, viroids, and some
Eubacteria). And if no evidence is found for the latter pathogens, non-disease possibilities

(injuries and disorders; see below) would then be considered.
In summary, many common diseases produce characteristic symptoms on their hosts that are
diagnostic. However, diagnosing the cause of common diseases that have ambiguous symptoms

requires additional work to identify the causal agent and, thus, the disease. If in the latter cases,
no causal agent can be isolated or identified following appropriate testing of the plant for
potential causative pathogens, other non-pathological causes may be responsible.

How pathogens cause disease. Pathogens cause disease on plants via different mechanisms
(Agrios, 2005). Some pathogens produce toxins that directly kill host plant cells and organs.
Others directly or indirectly affect the host’s vascular system making it unable to conduct water,
nutrients or photosynthates. Some diseases kill and/or macerate host tissue thereby degrading

fruits, seeds or storage organs, connective or other tissues responsible for mechanical support, or
photosynthetic organs. And some perturb normal hormonal balances resulting in abnormal
vegetative or reproductive structures.

Disease impacts. Plant diseases can be incredibly destructive. The most infamous example,
potato late blight, caused the Irish potato famine, and other plant disease epidemics have caused
hardship and fiscal losses (e.g. coffee rust and Panama disease of banana). In the tropics, plant
diseases are among the most significant constraints to crop production (Holliday, 1980; Ploetz,

2007b; Renard, 2001; Thurston, 1998; Wellman, 1972).

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Disease development. Unless measures are

taken by producers to manage diseases, they
will develop wherever susceptible crop plants,
their pathogens, and disease-conducive
environments exist (Robinson, 1976; Zadoks
and Schein, 1978). These relationships can be

conceptualized in Figure 2, in which pathogen
and host interaction are needed for disease
development but each of which, in turn, are
influenced by the environment and man. In

the humid tropics, plant diseases are
commonplace and can be quite difficult to
control (Holliday, 1980; Ploetz, 2007b;
Thurston, 1998; Wellman, 1972). Without )LJXUH'LVHDVHWHWUDKHGURQ=DGRNV 6FKHLQ

control measures, diseases would be expected
to develop on virtually all plants in such areas.

Disease diagnosis, part 2. Of significance to this report, many plant pathogenic fungi cannot
be distinguished microscopically (with morphological features) from related but nonpathogenic

species. The large genus Fusarium is especially problematic in that it contains pathogens,
nonpathogenic parasites and saprobes (Leslie and Summerall, 2006; Ploetz, 2006a). Fusarium
oxysporum alone contains at least 120 distinct vascular wilt pathogens, each of which affect a
specific, limited and related set of hosts (usually a single species) (Michielse and Rep, 2009);

however, it is also an extremely common soil saprobe (Leslie and Summerell, 2006). Under the
microscope, all members of the Fusarium oxysporum species complex appear the same;
pathogenic and nonpathogenic parasites and saprobic members of the species cannot be
distinguished. To identify the numerous and diverse pathogenic and nonpathogenic members of
this species, more discriminating attributes are needed (Michielse and Rep, 2009; O’Donnell et

al., 2009). Traditionally, time-consuming pathogenicity tests have been used to identify the
pathogens, but various genetic approaches, which enable quicker diagnoses, are becoming
available.

Two different types of plant damage may superficially resemble, but are distinct from, diseases.
Physical damages are not considered diseases. These include abiotic injuries, such as those
caused by chemical toxicity, lightening damage or mechanical insult, and biotic damage, such as

that caused by insects. Likewise, disorders are not considered diseases. For example,
imbalances or extreme levels of environmental factors, such as flooding and drought, and
nutrient toxicities and deficiencies are considered disorders, not diseases. Although these types
of damage are usually easily distinguished from diseases, they can interact with diseases

(Datnoff et al., 2007; Schoeneweiss, 1975).
Disease interactions. The occurrence and extent to which plant diseases can interact with
injuries and disorders depends upon the specific disease (i.e., unique host: pathogen interactions).

Interactions that affect a given host: pathogen interaction may or may not affect a different
disease on the same host plant or a similar disease on a different plant.

The identification of such interactions can be difficult, and when they do occur it is seldom, if
ever, possible to demonstrate their occurrence in the past without data from the time of the

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proposed interaction. In general, it would not be possible to prove that an interacting factor

occurred in the past with only a photographic record.
Disease management. The following general tactics can be used to manage plant diseases
(Agrios, 2005; Palti, 1981; Ploetz, 2007b):

▯ Avoidance. Avoiding disease-conducive planting sites or situations can reduce the

incidence and severity of some diseases. For example, low-lying or water-logged soils
exacerbate diseases that are caused by the so-called “water molds” (oomycetes) and should, thus,
be avoided. Likewise, most diseases of foliage and fruit can be reduced if air flow in plantations
is maximized to ensure that these organs dry as soon as possible.

▯ Exclusion and eradication of causal agents. Without a pathogen there is no disease. Thus,
when specific pathogens are not found in an area, their exclusion is important. And once they
are first found in an area, eradication may be possible. However, both situations are not

applicable to the described situation in Ecuador, because the diseases and pathogens that are
indicated were present in these areas well before 2000.

▯ Protection and treatment of host plants. Host plants can be protected from disease
development via cultural and chemical measures. For example, Sigatoka leafspots of banana and
plantain can be managed culturally by removing affected leaves and improving air circulation in
plantations, as well as chemically with fungicides.

▯ Use of disease-resistant plants.When they are available, disease-resistant plants are cost-
effective means by which diseases can be managed. For example, the Cavendish cultivars of
banana are very susceptible to black Sigatoka, but cooking bananas, such as Bluggoe, are not.

IV. Diseases are highly prevalent in tropical crops

Plant diseases can be particularly severe in tropical environments where high rainfall and
uniform, warm temperatures are the norm (Holliday, 1980; Renard, 2001; Thurston, 1998;
Wellman, 1972) (for details, see Ploetz, 2007b, which is attached as Exhibit III). These

conditions are highly favorable for the development of most diseases, and respites from disease
pressure in tropical environments are usually infrequent. Moreover, consistent with the fact that
biological diversity increases with decreasing latitude – a trend that is called the Latitudinal
Diversity Gradient (Hillebrand, 2004; Jablonski et al., 2006; Willig et al., 2003) – Wellman
(1967; 1968; 1972) estimated that there are 10 diseases on a given crop plant in the tropics for

every disease that occurs on it in temperate regions. Thus, plants in tropical environments are
faced with a more prevalent and diverse population of pathogens than in any other environment.
As a consequence, crop losses due to plant diseases are thought to be 50% to 100% higher in
tropical, than in temperate, regions (Hill and Waller, 1982; Thurston, 1998). In total, the
proportion of all plant losses in the tropics that are caused by disease has been estimated at

between 30% (Harlan, 1971) and 50% (Wellman, 1972).
For several reasons, diseases in the tropics are most pronounced, and pose serious management

problems on, perennial crops (e.g. banana, cacao, citrus, coffee, sugarcane and cassava) (Ploetz,
2007b). Perennials are long-lived and, thus, are more prone to inoculum buildup and epidemic
disease development. Perennials also have longer exposures to disease-promoting or
predisposing factors, such as excess water, poor soil nutrition, and insects. Further, in perennial
systems, there are increased opportunities for pathogen dissemination within and among crops.

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Crop diseases are most prevalent in the lowland, humid tropics (i.e., regions in which the test

plaintiffs’ farms are located) (Holliday, 1980; Thurston, 1998; Wellman, 1972). In these areas,
high rainfall and uniform warm weather provide optimum conditions for the development of
most plant diseases, especially those that are caused by fungi, oomycetes and bacteria (Renard,
2001). There are no annual freezes that would reduce the occurrence and prevalence of
pathogens (as occurs in temperate regions) (Thurston, 1998). Plants at different stages of growth

are frequently intermixed in the tropics; thus, pathogen inoculum and susceptible host tissues are
often coincident. And there are a great number and diversity of plant species in these regions; as
host numbers increase, so too do the numbers of pathogens (see Exhibit C).

V. Test Plaintiffs’ Claims

It is my understanding that the plaintiffs in this litigation are alleging that certain damage to their
crops was caused by herbicide spray that was being applied aerially to eradicated coca crops in
Colombia. I have reviewed the videographic, photographic, and laboratory data provided by the
test plaintiffs and it does not provide reliable evidence supporting their allegations of glyphosate-
based damages. To the contrary, the evidence presented demonstrates that the alleged crop

damage is likely due to plant diseases that are endemic to the tropical environment in which the
plaintiffs live.

Plaintiffs Do Not Employ Best Farming Practices. As set forth above, the risk of plant disease
is particularly pronounced in the tropics and, as a result, the importance of proper disease
management tactics is heightened. Based upon the videographic evidence that I have reviewed
from two of the test plaintiff farms (Balcazar and Mestanza), there is no indication that the
individual plaintiffs employed cultural or other management practices for plant diseases. For

example, practices are not evident that would have lowered plantation humidity, facilitated
drying of host plant surfaces, and increased drainage. Leaf removal and mat management in
banana production, raised beds or drainage canals, and weed management would all help reduce
disease pressure in these plantations. And where disease damage was present, as is evident, e.g.,
in the isolated banana, cacao and citrus crops in the videos presented by plaintiffs, there is no

evidence for the use of fungicides or the removal of diseased plant host organs (sanitation).
Moreover, the test plaintiffs’ deposition testimony makes clear that they did not fertilize these
crops nor employ herbicides, insecticides or other tools that are used commonly during crop
production. Unhealthy crops, such as those observed in video and photographic evidence, are
not uncommon under these conditions. And in low-input production systems such as these, it is

probable that propagation materials for these crops were not from pathogen-free stocks; citrus is
especially prone to diseases that are caused by pathogens that are found in non-certified
propagation materials (Timmer et al., 2000).

Laboratory Findings Indicate the Presence of Potential Pathogens in Test Plants on or near
the Plaintiffs’ Farms. As discussed more fully below with respect to the individual plaintiffs’
claims, in various labs, assays were conducted to investigate factors that were associated with
crop health on the different farms (see Laboratory Tests of Plants). Microbial isolations were

made from symptomatic crop plants to identify plant pathogens. In most cases, microbe genera,
but not species, are reported in the provided summaries. However, despite the lack of detail
(e.g., see discussion in Disease Diagnosis, part 2), the data generally support the occurrence of
plant pathogens on the tested plants.

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In general, there was tendency in some of these reports to propose, without supporting evidence,

that “fumigation ” with glyphosate caused observed events or lab results. These conclusions are
usually laced with waffle terminology such as “may be”, “could well be”, or “due to a possible
external influence” all of which indicate the absence of conclusive evidence for their fumigation
hypothesis. There is no evidence to indicate that diseases that were observed were abnormal or

accentuated during the indicated time frames, nor is there corroborating evidence from
neighboring production areas to indicate that healthy crops could be grown in these areas under
these rather poor conditions.

Video Imagery From Test Plaintiff Farms Demonstrates The Presence of Plant Diseases.
Two of the test plaintiffs have provided contemporaneous videographic evidence of the crop
damage that they allege was caused by glyphosate. In fact, the video imagery repeatedly
provides evidence that the crops at issue were in fact suffering from identifiable diseases, and in

many cases, the laboratory findings corroborate the disease symptom imagery (i.e. the expected
pathogen genera were recovered from plants with the observed disease symptoms).
The diseases that were identified, based on the lab and video evidence, are common in the region

and would be expected on the indicated crops. Poor crop health would be expected on these
farms, given the susceptibility of the produced crops, the nutrient-poor soils on which they were
grown, and their deficient management. As outlined above, there is no evidence for good
husbandry in any of the provided evidence (e.g. fertilization, plantation and/or canopy

management, and disease, insect or weed control).
In my opinion, the plaintiffs’ allegations that the crop damages on their farms are due to Plan
Colombia herbicide spraying events confuse correlation and causality. Correlation is not the

same as causality, and it cannot be used to prove these claims. For example, if a disease
develops in one of my experiments in June it does not automatically mean that high rainfall that
occurs during that month in Florida has had an impact on the development of that disease.
Therefore, when floral malformation in mango is observed in the summer, it is not due to high

rainfall [the disease is actually most severe in dry environments (Ploetz, 2003)], but because that
is when flower development and fruit set are most pronounced and disease symptoms are,
consequently, most apparent. Likewise, because crops were in poor health and developed
diseases on the plaintiffs’ farms does not mean that these events were caused by glyphosate
spraying across the border.

My analysis of the evidence relevant to specific individual test plaintiffs is set forth below:

A. The Mestanza Farm

I have been provided three key pieces of evidence in connection with the alleged crop damage at
Mr. Mestanza’s farm in Puerto Mestanza: (1) a 47.5-minute video taken on Mr. Mestanza’s farm
reportedly one month after a Plan Colombia spraying event at the border adjacent to his farm in
late 2002, (2) a 24-minute video taken on Mr. Mestanza’s farm in 2009, and (3) a laboratory
analysis in February 2004 of the soil on Mr. Mestanza’s farm and of plants that were allegedly

impacted by Plan Colombia spraying. This evidence does not provide any scientifically reliable
support for Mr. Mestanza’s allegations that his crops were damaged by Plan Colombia spraying.
To the contrary, this evidence demonstrates that the crop damage that Mr. Mestanza identifies is
in fact due to pathogenic plant disease.

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1. Evidence of Pathogenic Plant Disease in the November 2002 Mestanza
Video (PLS00005881)
The Mestanza video is of poor quality with a general absence of good, diagnostic close-ups of

the crops at issue in Mr. Mestanza’s complaint. However, the video does provide some useful
information regarding the causes or potential causes of plant injuries at Mr. Mestanza’s farm.
This information is set forth below, with time stamps for where the imagery appears in the video.

:09:00. At this point in the video, Mr. Mestanza is displaying Orito, a diploid dessert banana.

Orito is susceptible to yellow Sigatoka (Sigatoka amarillo) (Jones, 2000), symptoms of which
are evident here (as Mr. Mestanza states, “everything is burned”). This disease is first evident as
pale green flecks, <1 mm long, that become chlorotic streaks, 3-4 x 1 mm. They broaden,
lengthen, turn brown to rusty, and become surrounded by chlorotic haloes. As they mature they

enlarge to 12-15 (up to 50) x 2-5 mm, darken and then become grey with a dark brown or black
border. Spots can coalescence to kill large areas of the leaf. In general, these symptoms
resemble those of black Sigatoka (which is a more important cause of such symptoms on other
banana and plantain cultivars in the area) and Eumusae leaf spot (a disease that does not occur in
the Western Hemisphere) (Ploetz, 2003).

:11:33. The camera focuses on a damaged Orito plant and someone is heard stating “This is the
product of spraying” Actually, the Orito plant displays classic Sigatoka damage.

:12:47 and :59. More Sigatoka damage is evident here.

:13:14-40, The husbandry in banana production areas is very poor. For example, there is no
mat management or weed control evident here.

:15:35. At this point in the video, the camera focuses on bunches of Orito in which “black tips”

finger rot is evident. Several different diseases result in this symptomology, including cigar end,
Lasiodiplodia tip rot, Deightoniella swamp spot and anthracnose. Corroborating evidence is
provided for two of these diseases in subsequent lab results; they indicated that Colletotrichum
(musae), cause of anthracnose, and Verticillium (theobromae), cause of cigar-end rot, peduncle

rot, tip rot, cigar-end rot, crown and pedicel rot, were recovered from Orito fruit in the vicinity of
Mr. Mestanza’s farm (see Puerto Mestanza. Technical report, Gustavo Bernal, 27-29 Feb 2004)

:16:53. Mr. Mestanza states that “30 hectares of Orito are destroyed.” Actually considering the
way in which these plants are being managed, his Orito crop appears to be in pretty good shape.

:18:47. Mr. Mestanza is displaying a developing bunch of Orito with small fingers. Mr.
Mestanza alleges that this is evidence of damage caused by glyphosate spray. The visual
evidence, however, is consistent with premature harvest (indeed, Mr. Mestanza cut the bunch
from the tree to show it to the cameraman) or the impact of nematodes or bacteria (possibly

Moko disease or Erwinia sp.).

:19:12. Mestanza indicates that he feeds Orito to his fish and pigs, which is odd. This is a
dessert banana that produces small fingers/fruit; it is usually produced for human consumption.

If animal feed was desired, other, more productive cultivars would/should have been used.

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:20:34. The bunch of Orito displayed here displays the same type of finger rot seen at :15:35:06,
and is consistent with the same diseases mentioned above.

:20:52. The fruit displayed here shows symptoms of anthracnose, cigar-end rot and, possibly

banana streak.

:21:15. This Orito plant has been damaged by yellow Sigatoka.

:31:25. There is a very brief glimpse of papaya. Mr. Mestanza states that the plants “are all

dying already.” Actually, the one shown plant does not show “dying” symptoms.

:31:37. The video focuses here on some defoliated bay trees. However, as with the previous
video display of dragon’s blood trees, no conclusion can be reached other than that the trees
appear to be dead. No cause can be determined based upon this video evidence. However, the

presence of living vegetation surrounding the trees is inconsistent with to the claim that the
problems could have been caused by herbicide drift.

:32:26 – 46. The crops shown at this point in the video also display Sigatoka damage.

:33:00. Mr. Mestanza is removing fruit from a plantain bunch that looks as if it had been on the
ground for at least a week. If the fruit has in fact been lying on the ground for this period of
time, the blackening inside the fruit and on the outside is meaningless (and consistent with what
one would see, for example, if one left a bunch of bananas on a shelf for a week). Based on its

appearance, it is doubtful that the bunch had just been removed from the plant.

:36:30. There is some apparently damaged grass show in the video, but it is interspersed with or
adjacent to healthy grass and other healthy plants. The video does not provide sufficient
information to reach a conclusion as to the cause of the damage, but the fact that other plants in

the area are not damaged again is inconsistent with any claim that the damage was due to drifting
or aerially applied glyphosate.

:43:40. The citrus trees at this point in the video appear to be diseased (e.g. sparsely foliated),
but the poor video quality and absence of close-ups make it difficult to say much with assurance.

It is noteworthy that healthy papaya is visible in the same vicinity as the citrus trees, which is
again inconsistent with the allegations of herbicide damage. There are a number of diseases of
citrus that are common in the tropics that could have caused the observed damage, including
greening, gummosis, and tristeza (Timmer et al., 2000).

2. Evidence of Pathogenic Plant Disease in the 2009 Mestanza Video
(PLS00005882)

:00:41 – :02:00, :03:44, etc. Dead coconut trees are visible amongst healthy coconut trees.
Without better photos and cross-sections of dead and dying trees, it is impossible to determine
cause of damage. However, based on the symptoms on dying trees, red ring disease (caused by
the coconut palm nematode, Bursaphelenchus cocophilus) is possible. Red ring is endemic to

the region and kills coconut and several other species of palm in the region. Again, the evidence

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of a nonuniform distribution of dead and healthy trees is not consistent with the hypothesis that

the damage was caused by drifting or aerially applied glyphosate. However, such nonuniform
distribution is typical of a plant disease with an insect vector, such as red ring.

:13:05. At this point in the video, we can see mummified cacao pod, possibly caused by black
pod, frosty pod or witches’ broom diseases (see discussion below under Balcazar). As is evident
in the video (and consistent with Mr. Mestanza’s deposition testimony regarding his general
farming practices), no care is being given to these plants (fertilizer, weeding, etc.) and they are
grown in full sun (cacao is typically grown in shaded production). Thus, it is not surprising that

the cacao do not look healthy.
No other new plant symptoms/damage is seen in this video that is not already seen and discussed

in Mr. Mestanza’s November 2002 video (PLS00005881).

3. February 2004 Laboratory Analysis of Soil and Crops on or About
the Mestanza Farm and Corroboration of Video Diagnoses

I have also reviewed a February 2004 laboratory report by Gustavo Bernal entitled “Technical
report on visit to the Province of Sucumbios (border with Colombia).” This report provides
information on soil from Puerto Mestanza and fruit crops from neighboring communities in
Corazón Orense and Santa Marianita. It is assumed that disease noted on these plants was caused

by pathogens that are endemic in the affected area, as there are no contrary data presented here or
elsewhere in these reports. Note should be made of report’s finding also regarding the poor soil
here, as indicated on page 2 of the report: “Crops in these conditions fail to grow normally and
do not produce fruits in their normal shapes and sizes…” Clearly, diseases are not the only
natural factors that would impact crop health and productivity in this area.

At page 4 of the report, it is stated that “[t]he symptoms observed [in the samples of fruit] are the
result of the damage caused by pathogenic fungi.” The laboratory results from the fruit
phytosanitary analysis are set forth on page 3. As set forth below, the fungal genera that were

identified are noteworthy in that they contain pathogens that cause disease on plantain and cacao.
Separate laboratory findings are reported in a separate table on a page numbered 21 (the
document is not sequentially numbered). Noteworthy here is the finding of fungi in the plantain
and pasture grass samples that are possible pathogens on those plant species.

The specific findings for the crops analyzed are set forth below:

Banana/plantain . The analysis of plantain as reported at page 3 identified the presence of two
genera: Colletotrichum and Verticillium (Ploetz, 2003). Colletotrichum (musae) causes

anthracnose, which is primarily a post-harvest disease that affects the peel and crown surface
areas (crown rot) but can also develop when green fruit are injured;Colletotrichum (musae) also
causes fungal scald and stem-end rot. The finding of this pathogen in the tested plantains
corroborates the visual diagnosis from the video at :15:35. Verticillium (theobromae) causes
peduncle rot, tip rot, cigar-end rot, crown and pedicel rot, and can transform black tip into cigar-

end rot. The finding of this pathogen corroborates the visual diagnosis from the video at :15:35.
The separate analysis of plantain reported at page 21 identified Mycospherella (sic). Black
Sigatoka would be expected on plantain in this region (Ploetz, 2003); it is caused by
Mycosphaerella fijiensis. Yellow Sigatoka, which was evident on Orito in the video, is caused by

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a related fungus, M. musicola. Orito is unusual; it is susceptible to yellow Sigatoka, but tolerates
black Sigatoka (most banana and plantain cultivars are more susceptible to black Sigatoka).

Yuca (cassava) . Cladosporium spp. are usually saprobes (not pathogens), and there are no
diseases of this crop caused by fungi in this genus (Lozano and Nolt, 1993). There was no
cassava shown in the Mestanza video and the written description of damage to the cassava tested
in February 2004 is ambiguous.

Oranges . The phytosanitary analysis of the orange detected “Phitomyces” and “endophragmia”.
These are not pathogens. Based on the video, the citrus trees on Mr. Mestanza’s farm have other
more serious disease problems, only one of which, gummosis, would show up in routine lab

isolations (it is caused by Phytophthora spp., but the pathogens that cause greening and tristeza,
two other possible diseases here, are not culturable). Dark spots that were mentioned on both
sides of the leaf in the lab analyses may have been symptoms of greasy spot. However, its causal
agent, Mycosphaerella citri, is difficult to isolate in a routine laboratory analysis. All of these

pathogens would be easily moved to new production areas on infected planting materials
(Timmer et al., 2000).
Lemon (lime) . The phytosanitary analysis of the lemon identified Cladosporium. Species in

this genus are commonly saprobes. Lichens mentioned in lab analysis are not plant pathogens.
Cacao . The analysis of cacao detected Phytophthora. Several different species of Phytophthora
cause black pod, a serious and widespread disease on this host (Dollet, 2001; Evans, 2007).

B. The Balcazar Farm

I have been provided two key pieces of evidence that are relevant to my opinions regarding the
allegations of crop damage made by Mr. Balcazar: (1) a short video dated June 21, 2001 and (2)
a laboratory analysis of crops from Mr. Balcazar’s farm dated July 12, 2001. This evidence does
not provide any scientifically reliable basis to opine that the crop damages alleged by Mr.

Balcazar were caused by herbicide spray from Plan Colombia eradication operations. To the
contrary, as with Mr. Mestanza, the Balcazar video and lab test results indicate that the crop
damage on the Balcazar farm was caused bypathogens that are endemic to the region.

1. Evidence of Pathogenic Crop Disease in the Balcazar Video

:02:09. At this point in the video, we can see cacao pod to Mr. Balcazar’s right that display
symptoms of the disease frosty pod, which is caused by Moniliophthora rorei,.

:02:25. Mr. Balcazar asserts that the symptoms seen in his cacao are a new problem. Actually,
frosty pod has been in this region for decades. Black pod, caused byPhytophthora spp., and
witches’ broom, caused by Moniliophthora perniciosa, also mummify cacao pods, but without
covering the pod surface with white spores. Frosty pod, black pod, and witches’ broom are the
most important and damaging diseases of cacao (Evans, 2007; Ploetz, 2007a); all of these

diseases are common in Ecuador.
:03:04. Mummified cacao pods are displayed here. The picture quality is poor, but the cacao

pod on the left appears to be affected by frosty pod.
:03:17. The cacao pods above Mr. Balcazar’s head and to his left display symptoms of frosty
pod. It is also evident in the video (consistent with Mr. Balcazar’s testimony concerning his

farming practices) that proper farming practices are not being followed. There is no evidence of

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proper care of the cacao (fertilizer, weeding etc.) and they are being grown in full sun rather than
in shaded areas. The generally unhealthy appearance of the cacao is thus not surprising.

:03:45. The citrus trees shown at this point in the video are in bad shape and appear to be heavily
diseased; however, the quality of the video is so poor that it is difficult to say much with
assurance. Based on the general appearance of these trees, the following diseases are possible
(Timmer et al., 2000): postbloom fruit drop and lime anthracnose, caused by Colletotrichum

acutatum; greasy spot, caused by Mycosphaerella citri; gummosis, caused by Phytophthora spp.;
tristeza, caused by Citrus tristeza virus; and greening, caused by Candidatus Liberibacter
species.

:5:10. The pasture grass shown here displays symptoms of blight. The poor video quality makes
it difficult to reach any definite conclusion, but the symptoms could have been caused by the
fungi that were recovered in lab analyses of the grass on Mr. Balcazar’s farm (see below).

:7:55. Mr. Balcazar states that he lives 5 km from Colombian border. This is an incredible
distance for herbicide drift.

:8:18. The cacao pod at the right in this point in the video displays symptoms of black pod
disease.

:8:46. The banana plant shown here has severe symptoms of black Sigatoka.

:8:50. More symptoms of black Sigatoka are evident here.
:8:59. Once more, the plants displayed show symptoms of black Sigatoka. It is also noteworthy

that the coffee is being grown in the full sun, rather than in the shade where coffee does best.
2. July 2001 Laboratory Analysis of Crops on the Balcazar Farm and

Corroboration of Video Diagnoses
I have reviewed the results of laboratory analyses of crops on the Balcazar farm that were
conducted by the Ecuadorian Ministry of Agriculture and Livestock on July 12, 2001. These

analyses reported the findings of pathogens in three tested crops on the Balcazar farm as follows:
Cacao. Two fungi were recovered, “Fusarium moniliforme” and “Monilia rorei.” The former

name refers to a corn pathogen (Fusarium verticilloides). “Fusarium moniliforme” is very
confused in the literature and is no longer used (Leslie and Summerall, 2006). Fusarium
decemcellulare causes cushion gall on cacao, but it is distinct from Fusarium verticilloides
(Ploetz, 2007a). Thus, the significance of “Fusarium moniliforme” is not clear. “Monilia rorei”
refers to Moniliophthora rorei, cause of frosty pod (aka moniliasis, helado, etc.) (Evans, 2007;

Thurston, 1998). Frosty pod, which is the most serious disease of cacao, occurs naturally
throughout Ecuador. Frosty pod could have caused the mummified cacao fruit seen in the
Balcazar video (see above comments).

Platano. Three fungal genera were recovered from roots,Fusarium sp., Rhizoctonia sp. and
Trichodema sp. All three genera are common on roots of this crop, and the former two genera
contain plant pathogens. A specific subpopulation of Fusarium oxysporum, f. sp. cubense, is an
important pathogen of some banana cultivars; it causes Panama disease (Ploetz, 2006b).

Marundu. Five fungal genera were recovered from base (root collar) of this grass,Fusarium sp.,
Rhizoctonia sp., Cladosporium sp., Theilaviopsis sp. and Curvularia sp. All contain plant

517Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 15 of 58

pathogenic species. Rhizoctonia blight is a serious disease on this crop and the dead grass shown
in the Balcazar video may have been suffering from this disease.

C. Salas and Calero Farms
It is my understanding that the Salas and Calero test plaintiff families live in the area near Chone

1 and Chone 2. I do not have any video imagery from either of these plaintiff families’ farms
[and the photographs that I have been provided purportedly showing plant damages at the Salas
farm is of a very poor quality and does not provide any evidence of crop damage let alone
information that would provide a basis for a scientific conclusion as to the cause of alleged crop
damage. I have reviewed a document entitled “Report on Verification Mission, Impacts of

fumigations in Putumayo as part of Plan Colombia (October 2002)”, which reports on the results
of testing of certain crops in Chone 2. This report contains various opinions/accusations
regarding alleged impacts of glyphosate from Plan Colombia which are beyond the scope of this
expert report, but which I understand are being addressed by other experts. My analysis focuses
on the plant laboratory findings and the interpretations of those findings in the October 2002

verification report.
Two crops from Chone 2 were mentioned on page 17 of the verification report, peanut and rice.

Fusarium sp., Rhizoctonia sp., Alternaria sp. and Cylindrocarpon sp. were recovered from
peanut roots, leaves and/or soil. Each of these genera contains peanut pathogens (Porter, 1993).
Fusarium sp., Rhizoctonia sp., and Rhizopus sp. were recovered from rice roots and leaves.

The findings of these pathogens in crops from Chone 2 is consistent with what would be
expected in this tropical environment and, in combination with the general problems of
pathogenic plant disease in the area, suggests that any crop damages at the Salas and Calero
farms was likely caused by endemic plant disease. There is nothing in the 2002 verification

report or any other evidence of which I am aware that would provide a scientifically reliable
basis to opine that any crop damage at the Salas or Calero farms was caused by Plan Colombia
glyphosate spray.

The 2002 Verification report contains a number of false statements in connection with the
finding of Fusarium sp. on tested crops. First, the report states that the finding of Fusarium sp
on leaves of tested plants was “noteworthy.” This is incorrect. As noted on page 5 of this report,
Fusarium species are very common worldwide, including tropical environments. The presence

of this genus in northern Ecuador would be expected on many plants, as well as in/on animals,
soil and water; they are ubiquitous fungi (Leslie and Summerell, 2006). The report also makes a
number of allegations about the potential use of Fusarium oxysporum to eradicate coca. I have
been advised by counsel for the defendants that Fusarium oxysporum has never been used in
Plan Colombia eradication operations and that plaintiffs are not alleging such use in this case. I

would note, in any event, that the forma specialis of Fusarium oxysporum that affects coca, F.
oxysporum f. sp. erythroxyli, is a typical wilt strain of this species, in that it is host-specific and
would not affect the indicated crop plants. Accordingly, even if Fusarium oxysporum had been
used, it would not have had any adverse impacts on lawful crops or, indeed, on any plant life
other than coca.

D. The Alvarez, Quevedo, and Witness 37Farms

The remaining test plaintiff families have not provided any useful videographic, photographic or
laboratory data regarding their alleged crop damage.

518 Annex 14

Witness 37

▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

519Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 17 of 58

Published References

Agrios, G. N. 2005. Plant Pathology. 5th ed. Elsevier, San Diego.
Ciccarelli, F.D., Doerks, T., von Mering, C., Creevey, C.J., Snel, B., and Bork, P. 2006. Toward
automatic reconstruction of a highly resolved tree of life. Science 311:1283-1286.

Datnoff, L., Elmer, W. H., and Huber, D. M. (eds.) 2007. Mineral Nutrition and Plant Disease.
APS Press, St. Paul, MN.
Dollet, M. 2001. Pathogens. Pp. 57-86 In: Mariau, D. (ed.) Diseases of Tropical Tree Crops.
Science Publishers, Inc. Enfield, NH, USA.
Evans, H. C. 2007. Symposium Cacao Diseases: Important Threats to Chocolate Production

Worldwide. Cacao diseases - The trilogy revisited. Phytopathology 97:1640-1643.
Harlan, J. R. 1971. Agricultural origins: Centers and noncenters. Science 174:468-74.
Hillebrand, H. 2004. On the generality of the latitudinal diversity gradient. Am. Natural.
163:192-211.
Hill, D. S., and Waller, J. M. 1982. Pests and Diseases of Tropical Crops. Longman, London.

Holliday, P. 1980. Fungus Diseases of Tropical Crops. Cambridge University Press. Cambridge,
UK.
Jablonski, D., Roy, K., and Valentine, J. W. 2006. Out of the tropics: Evolutionary dynamics of
the latitudinal diversity gradient. Science 314:102-106.
Jones, D.R. (ed.) 2000. Diseases of Banana, Abaca and Enset. CABI Publishing. Wallingford,

UK. 544 pp.
Leslie, J.F., and Summerell, B.A. 2006. The Fusarium Lab Manual. Blackwell. Ames, IA.
Lozano, C., and Nolt, B. 1993. Diseases of Cassava (Manihot esculenta Crantz). Accessed
online: http://www.apsnet.org/publications/commonnames/Pages/Cassava.aspx
Michielse, C.B., and Rep, M. 2009. Pathogen profile update: Fusarium oxysporum. Mol. Pl.
Pathol. 10:311–324.

O'Donnell K, Gueidan C, Sink S, Johnston, P.R., Crous, P.W., Glenn, A., Riley, R., Zitomer,
N.C., Colyer, P., Waalwijk, C., van der Lee, T., Moretti, A., Kang, S., Kim, H.-S., Geiser,
D.M., Juba, J.H., Baayen, R.P., Cromey, M.G., Bithell, S., Sutton, D.A., Skovgaard, K.,
Ploetz R., Kistler, H.C., Elliott, M., Davis, M., Sarver, B.A.J., 2009. A two-locus DNA
sequence database for typing plant and human pathogens within the Fusarium oxysporum

species complex. Fungal Genetics and Biology 46:936-948.
Palti, J. 1981. Cultural Practices and Infectious Crop Diseases. Springer-Verlag, Berlin.
Ploetz, R. C. (ed.) 2003. Diseases of Tropical Fruit Crops. CAB International, Wallingford,
Oxon, UK. 544 pp.
Ploetz, R.C. 2006a. Fusarium-induced diseases of tropical, perennial crops. Phytopathology
96:648-652.

Ploetz, R. C. 2006b. Fusarium wilt of banana is caused by several pathogens referred to as F.
oxysporum f. sp. cubense. Phytopathology 96:653-656.
Ploetz, R.C. 2007a. Cacao diseases: Important threats to chocolate production worldwide.
Phytopathology 97:1634-1639.
Ploetz, R.C. 2007b. Diseases of tropical perennial crops: Challenging problems in diverse

environments. Plant Disease 91:644-663.
Ploetz. 2008. Tropical fruit crops and the diseases that affect their production. In: Kleber Del
Claro, Paulo S. Oliveira,Victor Rico-Gray, Alonso Ramirez, Ana Angelica Almeida
Barbosa, Arturo Bonet, Fabio Rubio Scarano, Fernado Louis Consoli, Francisco Jose

520 Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 18 of 58

Morales Garzon, Jimi Naoki Nakajima, Julio Alberto Costello, Marcus Vinicius Sampaio,
Mauricio Quesada, Molly R. Morris, Monica Palacios Rios, Nelson Ramirez, Oswaldo
Marcal Junior, Regina Helena Ferraz Macedo, Robert J.Marquis, Rogerio Parentoni
Martins, Silvio Carlos Rodrigues, Ulrich Luttge (eds.) International Commission on

Tropical Biology and Natural Resources. Encyclopedia of Life Support Systems
(EOLSS) UNESCO, Eolss Publishers, Oxford, UK. [http://www.eolss.net] [Retrieved
March 3, 2009] 27 printed pages (Published online).
Porter, D.M. 1993. Diseases of peanut (Arachis hypogaea L.). Accessed online at:
http://www.apsnet.org/publications/commonnames/Pages/Peanut.aspx

Renard, J.-L. 2001. Symptomatology and economic importance. Pp. 5-55 In: Mariau, D. (ed.)
Diseases of Tropical Tree Crops. Science Publishers, Inc. Enfield, NH, USA.
Riley, M.B., M.R. Williamson, and O. Maloy. 2002. Plant disease diagnosis. The Plant Health
Instructor. DOI: 10.1094/PHI-I-2002-1021-01
Robinson, R. A. 1976. Plant Pathosystems. Springer-Verlag, New York.

Schoeneweiss, D. F. 1975. Predisposition, stress and plant disease. Annu. Rev. Phytopathol.
13:193-211.
Thurston, H. D. 1998. Tropical Plant Diseases. 2nd ed. American Phytopathological Society, St.
Paul, MN.
Timmer, L.W., Garnsey, S.M., Graham, J.H. (eds.). 2000. Compendium of Citrus Diseases. 2 nd

edition. APS Press, St. Paul.
Wellman, F. L. 1967. Relative abundance of diseases on tropical crops. (Abstr.) Phytopathology
57:10.
Wellman, F. L. 1968. More diseases on crops in the tropics than in the temperate zone. Ceiba
14:17-28.

Wellman, F. L. 1972. Tropical American Plant Disease. The Scarecrow Press Inc., Metuchen,
NJ.
Willig, M. R., Kaufman, D. M., and Stevens, R. D. 2003. Latitudinal gradients of biodiversity:
Pattern, process, scale, and synthesis. Annu. Rev. Ecol. Evol. Syst. 34:273-309.
Woltz, S.S. 1978. Nonparasitic plant pathogens. Annu. Rev. Phytopathol. 16:403-430.

Zadoks, J.C., and Schein, R.D. 1978. Epidemiology and Plant Disease Management, Oxford
University Press, New York.

521Annex 14

Case 1:07-cv-010Document Filed 0Page 35 of 58

Exhibit B
Dr. Randy Ploetz Expert Report

Materials Considered

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 36 of 58

¡ȱȱ

¢ȱ£ȱ¡ȱ

Additional Publication Considered

Powell J.R. & Swanton C.J. (2008) A critique of studies evaluating glyphosate effects on
diseases associated with Fusarium spp., Weed Research 48: 307-318

Other Materials Considered

1) Bernal G., Technical Report on Visit to the Province of Sucumbíos (border with
Colombia), (unpublished Technical Report, Colombia: CCTE.) (February 29, 2004)
2) Binder of 20 Test Plaintiff Deposition Testimonies
3) Campaña A. & Nato O.F., Investigation: Pesticide Impacts in Ecosystems, Analysis
Report by UBC/CEAS Laboratory (University of British Columbia, Canada and

Center for Health Studies and Consultancy, Quito, Ecuador) (September 26, 2007)
English summary and Spanish report.
4) Ecuadorian Ministry of Agriculture and LiveStock laboratory test of Edgar Balcazar’s
farm, Test Plaintiff No. 1109, July 12, 2001 (English summary and Spanish report)

5) English Transcription of Test Plaintiff Victor Mestanza's 2002 Video
6) Excerpts of Lab Tests from Annex 2 of Preliminary Economic Valuation and Impact
Assessment of the Environmental Assets and Services Affected by the Fumigations in
the Northern Ecuadorian Border along the Province of Sucumbios, Prepared by

Suarez S., Aguirre D.B., Lozano P., Cabrera R. & Reyes F., Revised and updated
version of January 2008 with English summary and Spanish report.
7) Maldonado, Adolfo et al., Verification Mission Report: Impacts in Ecuador of the
Fumigations in Putumayo as part of Plan Colombia, Accion Ecologica, October 2002.

8) Original and Translation of Plant Lab Report for Chone 2, Ecuador and Vereda
Nueva Granada, Colombia and translation of soil lab report for Chone 2, Playera
Oriental, Ecuador, and Vereda Nueva Granada, Colombia, Accion Ecologica website,
October 9, 2002
9) PLS00005881 Disk with Victor Mestanza's 2002 Video

10)PLS00005882 Disk with Victor Mestanza's 2009 Video
11)Video footage of Edgar Balcazar
12)Photographs excerpts taken from Victor Mestanza’s 2002 Video
13)Photographs produced by Plaintiffs’ Counsel of Salas’s Family farm labeled

PLS00005971
14)Photographs produced by Plaintiffs’ Counsel of Elvia Alvarez’s farm labeled
PLS00005966
15)Summary of Letter by Montenegro G.S. of Test Results from Center of Integral

Analytical Solutions Centrocesal Co. Ltd. Attachment to Annex 2 of Preliminary
Economic Valuation and Impact Assessment of the Environmental Assets and
Services Affected by the Fumigations in the Northern Ecuadorian Border along the
Province of Sucumbios, Prepared by Suarez S., Aguirre D.B., Lozano P., Cabrera R.

& Reyes F., Revised and updated version of January 2008.

522 Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 37 of 58

16) A binder for each test plaintiff family containing:

A) a table with citations to claims of crop damages in certain evidentiary submissions
of the test plaintiffs (initial disclosures, questionnaire responses, declaration of

Marco Campaña, deposition testimony excerpts, Accion Ecologica toxicology
sheet and survey).

B) the following information for each test plaintiff (if applicable to the test plaintiff
and/or family):

i) initial disclosure

ii) questionnaire responses

iii) excerpt from the Marco Campaña declaration specific to each plaintiff

iv) all deposition testimony excerpts re alleged crop damages and related
issues

v) other test plaintiff-specific information relating to their alleged physical
injuries (e.g., photographs and/or video, excerpts from prior lawsuits, prior
certifications, Accion Ecologica toxicology sheet and survey lab tests
taken from their region and related government announcements.)

vi) excerpts of certain non-governmental organization and other third party
reports that mention the test plaintiffs or the areas in which they live with
respect to diseases or crop damages

C) a map showing the approximate location of the test plaintiffs’ farm and spray lines
(if any) for the dates of spray exposure alleged by any of the family members in
their depositions.

523Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-Filed 08/19/11 Page 38 of 58

Exhibit C

Dr. Randy Ploetz Expert Report

2007 Referenced Article

524 Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 39 of 58

R. C. Ploetz

University of Florida, Tropical Research and Education Center, Homestead

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&KDOOHQJLQJ3UREOHPVLQ'LYHUVH(QYLURQPHQWV

The world’s oldest ecosystems are found practices, regardless of the host and envi- boldt (63) discussed the relationship two
in the tropics. They are diverse, highly ronment in which it is grown. These in- centuries ago, and Darwin (26) wrote
evolved, but barely understood. Diseases clude the avoidance, exclusion, and eradi- about it in his famous book. This increase
that impact crops in these regions can be cation of the causal agents. Host protection in diversity is most pronounced in tropical
significant contraints to production, is of great importance, as is the identifica- rain forests, which are thought to host 50%

especially when they occur in lowland tion and incorporation of resistance in the of all species but occupy only 7% of the
environments with high rainfall and host plant. All of these approaches are world’s landmass (162). And it appears to
uniform, warm temperatures; respites from discussed with tropical perennial exam- be a general rule on our planet since it is
disease pressure there are often infrequent. ples. found in the fossil record and re-estab-
Difficulties in managing diseases in the lishes after mass extinctions (67).
Agriculture Begins
humid tropics are multiplied when the Plants are among the most prominent or-
affected crops are perennial. The favorable Agriculture began after the Pleistocene ganisms that conform to the LDG. Thus, it
conditions for disease development and the (last ice age) and started independently in is not surprising that most of the early
presence of susceptible host tissue over several different regions (Table 1). It devel- agricultural hubs (nine of the above 12)
long periods make diseases of tropical oped first in the Near East (sites in the and first crop domestications occurred in

perennial crops serious management chal- Fertile Crescent and in present-day Israel the tropics, i.e., between the Tropics of
lenges. and Turkey) due to a fortuitous combina- Cancer and Capricorn (Table 1). More than
This topic is introduced with a few con- tion of suitable climate and useful plants half the crops in Table 2, 69 of 126 (55%),
cepts on the occurrence and development and animals that could be domesticated originated in the tropics. Some tropical
of these pathosystems. Peculiar aspects (33,76,144). These first farmers appeared annuals, e.g., rice, potato, and maize, are

and scenarios that influence the types of at least 11,000 years ago, and were fol- now also grown in temperate zones during
and extent to which different diseases lowed in quick succession by others in the summer. But essentially all tropical
develop are summarized. Measures that are Northern and Southern China, Meso- perennials are restricted to the tropics due
useful on annual or short-term crops may america, New Guinea, the Andes, and the to their cold sensitivity.
be ineffective against these diseases. They Eastern United States (32–34). Additional A wide range of habitats is found in the

are scientifically interesting problems. areas of independent development may tropics, including humid lowlands, deserts,
New vectors, as for mango malformation, also include Amazonia, Ethiopia, the Sa- seasonally dry forests, grasslands, savan-
or pathogens, as for bunchy top of papaya, hel, Southeast Asia, and Western Africa. nahs, montane environments, and swamps
are associated with some of the diseases. During agriculture’s brief history, hu- (148,161). Further diversity in each of
And some of the diseases are caused by mans have utilized numerous plants these habitats results from variable ed-

two or more distinct taxa; for example, (12,21,91,135,148). At least 3,000 taxa aphic, meterologic, and biotic conditions.
citrus greening, mango malformation, have been used for food and several hun- This vast array of environments enables an
Panama disease, and tracheomycosis of dred more have been used for other pur- equally wide range of plants to be grown;
coffee. Some of the most important poses. In Table 2, the following categories almost every crop in Table 2 can be grown
diseases are host-specific and are caused have been considered: beverage, drug, somewhere in the tropical world. For ex-

by either coevolved or new-encounter elastomer, fiber, food, insecticide, oil, ample, important temperate domesticates
pathogens. Resistance, the most effective spice, and timber and pulp. are grown in the lowland tropics (members
tool with which many of these diseases are Despite the large numbers of useful spe- of the Brassicaceae and Fabaceae are espe-
managed, is usually available in coevolved cies, only a subset is very significant and cially common) and at high elevations
pathosystems but may be uncommon in few are of major importance (114,128,136, where moderate temperatures exist (mem-

new-encounter situations. Inadequate host 143,148). Scarcely more than a hundred bers of the Fabaceae, Poaceae, and
resistance can be a significant barrier in species enter world commerce, and among Rosaceae are most notable) (114).
the management of both coevolved and the food crops, few are staples: About Thurston’s (148) estimate that twice as
new encounter diseases. 0.5% of the food species supply more than many crops are grown in the tropics as in
General tactics are described that are 90% of the world’s food (42,148). the temperate zones of the world is proba-

useful against diseases of tropical Biological Diversity bly accurate.
perennials. The successful management of Studies that compare tropical and tem-
plant disease utilizes several principles and in theTropics perate ecosystems are uncommon, and a
Biological diversity increases with de- disproportionate amount of the research on
creasing latitude (61,67,162). This trend, microorganisms has been conducted in
Corresponding author: R. C. Ploetz, University of
Florida, Deartment of Plant Patholo gy, Tro picalalled the Latitudinal Diversity Gradient temperate zones. For example, in review-
Research and Education Center, 18905 S.W. 280th (LDG), has been observed for a wide range ing the literature on fungi and bacteria in
Street, Homestead, FL 33031-3314, USA; E-mail: of trophic levels and life forms. In general, forest ecosystems since 1963, Lodge et al.
[email protected] species numbers increase dramatically as (87) found only 96 references for tropical
one moves from the poles to the equator. forests, but 2,411 for temperate forests.

doi:10.1094/PDIS-91-6-0644 The LDG is one of the oldest recognized Despite this disparity, the LDG is also
© 2007 The American Phytopathological Society patterns in the biological sciences. Hum- evident among microbes.

644 Plant Disease /Vol. 91 No. 6

525Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 40 of 58

Three groups of nonpathogenic fungi, temperate climates; comparatively little inoculum buildup and epidemic disease

decomposers (86), endophytes (6), and plant pathological research has been con- development.
arbuscular mycorrhizae (64), are very di- ducted in the developing tropical world Managing the large reservoirs of inocu-
verse in the tropics, as are fungi in general (143). Work in the tropics has made sig- lum and high disease pressures that de-

(156,157). Plant pathogens also appear to nificant contributions to the discipline of velop in perennial monocultures can be
be more numerous and diverse in the trop- plant pathology (100,132), but much more difficult and costly. For example, manage-
ics. One group, the flagellated protozoa would be revealed if resources that ap- ment of black Sigatoka leaf spot of banana

(Phytomonas spp.), is rare outside the proached those used in temperate zones (black leaf streak), caused by Mycosphae-
tropics (2), and 60% of the described vi- were devoted to research in the tropics. rella fijiensis, contributes as much as 25%
roid species have tropical, natural hosts Perennial crops: Challenging hosts for of the final retail cost of export bananas
(55). disease managers. When one considers and can fail during periods of high rainfall

If one considers diseases of crop plants, the total areas planted and annual yields, or less than adequate fungicide applica-
there may be an even greater difference the most important food crops are annuals. tions (105). In India, 10% of the total costs
between temperate and tropical areas. Other than sugarcane (its total represents of coffee production went toward the con-

Wellman (161) found a pronounced tem- harvested cane, not a final product), only trol of rust (130). And eradication efforts
perate/tropical bias among the crops that production figures for maize, rice, and can be very expensive. Cacao swollen
were well represented in both zones: wheat exceed 500 million metric tons per shoot, caused by Cacao swollen shoot

pumpkin and squash, 19 temperate dis- year (Table 2). Although they are minor virus, in West Africa and citrus canker,
eases and 111 tropical; sweet potato, components of most natural floras, annuals caused by Xanthomonas axonopodis pv.
15/187; tomato, 32/278; common bean, predominate in agriculture for the follow- citri, in Florida are worst-case examples of
where large sums of money were invested
52/253+; and potato, 91/175. Wellman ing reasons: they produce quick results
(159–161) concluded that for every disease after planting; when stored, they enable in ultimately unsuccessful campaigns.
that occurred on a given crop in temperate escape from unfavorable climatic condi- Due to long-term selection pressure,
areas there were 10 in the tropics. tions (particularly the grains and pulses); there are increased opportunities in peren-

Disease problems can be severe in the and when incorporated in fallow or rota- nial systems for the development of pesti-
tropics, especially where high rainfall and tion cultures, they facilitate the avoidance cide-resistant pathogens. Despite an in-
uniform, warm temperatures are the norm. of pests and pathogens (128). creased awareness of pesticide resistance

These conditions are highly favorable for Despite the importance of annual crops, and the establishment of strategies to avoid
the development of most diseases, and Table 2 indicates that perennial crop plants the build-up of resistant strains (11), a
respites from disease pressure are usually (those that live longer than 2 years [4]) are rapid erosion of the efficacy of new chemi-

infrequent in these areas. Overall, losses more numerous (73 of the 126 [58%]). cals is still common (68,120).
are thought to be 50 to 100% higher in There are several reasons why these most Long-term exposure to disease-promot-
tropical than in temperate regions common hosts are often serious disease ing or predisposing factors can increase
disease development in perennial hosts (7).
(60,148). Estimates of the proportion of all management challenges.
losses in the tropics that are caused by Rather than being protected for a few Host nutritional status is an important
diseases range from 30% (56) to 50% weeks or months, perennial hosts require abiotic factor that can be related to in-
(161). long-term measures. Since they are long- creased disease (27,101). Likewise, an

Plant pathology began in, and generally lived and there are no seasonal breaks in excess of water can encourage the develop-
continues to be a discipline focused on, production, perennials are more prone to ment of diseases induced by stramenopiles

z
Table 1. Crop plants that were domesticated in early agricultural centers

Crops
First dates Grasses and Root and Melons and Fruit and
Area (years B.P.) grains Pulses Fiber tubers squash vegetables

Fertile Crescent 11,500 Emmer and Pea, lentil, Flax None Mufisgkeotne,
einkorn wheat, chickpea
barley

China 10,000 Ricfeo,xtaainld Soybean, adzuki Hemp None None None
broomcorn bean, mung
millet bean
MesoAmerica 10,000 Maize Commobnean, Cotton Jicama Squashes Pepper (Capsicum
tepary bean, (G. hirsutum), (C. pepo, etc.) spp.), avocado
scarlet runner Yucca spp.

bean Agave spp.
Andes, 3,500-1,000 Quinoa Limbaean, Cotton (G. Cassava, sweet Squashes (C. Pineapple
Amazonia common bean, barbadense) potato, potato, maxima, etc.)
peanut oca
West Africa and 3,000 and Sorghum, pearl Cowpea, Cotton (G. Yams White-flowered Watermelon
Sahel 5,000 millet, African groundnut herbaceum) (bottle) gourd
rice

India 5,000 None Hyacinbthean, Cotton CuMcungboer
black gram, (G. arboreum),
green gram flax
Ethiopia 3,000 Teff, finger milletNone None None None None
Eastern USA 2,500-1,000 Maygrass little Jerusalem Squash (C. pepo)
barley, knotweed, artichoke

goosefoot
Newuinea 7,000 Sugarcane None None None None Banana
z Adapted from refs. 33 and 136; additional data are from 32, 34, 76, and 128.

Plant Disease / June 2007 645

526 Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 41 of 58

Table 2. Taxonomy, origins, and production zones of the major crop plants

Family Category/ Center Major production Production,
v
Order (subfamily) Crop(s), taxa usage of origin areas 2005 (t)

Gymnosperms
Coniferales Pinaceae Pines, Pinus spp. Timber, pulp Diverse Temperate to tropical N.A.
Spruces, Picea spp. Timber, pulp Northern Temperate N.A.
Hemisphere

Larches, Larix spp. Timber, pulp Northern Temperate N.A.
Hemisphere
Douglas firs, Timber, pulp Northern Temperate N.A.
Pseudotsuga spp. Hemisphere

Angiosperms Spruces, Picea spp. Timber, pulp Northern Temperate N.A.
Hemisphere
Magnoliid Laurales MyristicaceaeNum tmace,, Spice MoluccasIndG orneensaiad,a, 81,292
complex Myristica fragrans Sri Lanka, India

Malaysia
Lauraceae Avocado, Fruit Tropical Mexico, USA, 3,229,134
Persea americana America Indonesia, South
Africa, Chile

Cinnamon, Spice Sri Lanka Indonesia, Sri Lanka, 134,410
Cinnamomum India, Seychelles,
verum w Madagascar
Piperales Piperaceae Blacpkepper, Spice Southwest India India, Indonesia, 411,359
Piper nigrum Brazil

Monocots Alistamatales Araceae Taro, Colocasia Root and Indo-Malaya WA esfcac,iic0,586,651
esculenta tuber
Yautia (tanier), Root and Tropical Caribbean, West 421,966
Xanthosoma tuber America Africa, Pacific

sagittifolium
Asparagales Orchidaceae Vanilla, Spice SE Mexico, Madagascar, 10,539
Vanilla planifolia C. America Indonesia, China
Alliaceae Garlic, onion, Spice Near East USA, Japan, Spain 14,548,669

Allium spp. 57,400,277
Agavaceae Agavfiebers, Fiber MesoAmerica, Brazil, East Africa 385,463
Agave spp. (mainly Caribbean
sisal, A. sisalana)

Asparagaceae Asparagus Vegetable 6,658,007
Dioscoreales Dioscoreaceae Yams, Dioscorea spp. Root and Asia, Africa, West Africa, 39,856,954
tuber Tropical Southeast Asia,
America Oceania, Caribbean

Arecales Arecaceae Betel nut, Drug- Southeast Asia Southeast Asia 727,425
(Palmae) Areca catechu medicinal
Coconut, Fruit, oil, Southeast Asia Philippines, 55,234,124
Cocos nucifera fiber (coir) Indonesia, India, (fruit),

Sri Lanka 954,290 (coir)
Oil palm, OAirnaaasstaa,,199
Elaeis guineensisx (fruit)
Date, Frufirt, .N Iraq, Iran, Egypt 6,921,950

Phoenix dactylifera Middle East
Poales Bromilaceae Pineapple, FruitASTohilaand, 16,769,660
Ananas comosus Philippines, Brazil
Poaceae Bamboos, many Timber, Mostly tropical Mostly tropical N.A.

(Bambusoideae) genera fiber
Poaceae Rice, Oryza sativa Grain IndoChina Global 618,440,644
(Ehrhartoideae)
Poaceae Oats, Avena spp. Grain Europe Temperwaterld 23,953,749

(Pooideae)
Barley, Grain Southwest Europe, N. Africa, 139,043,947
Hordeum vulgare Asia Near East, Russia,
China, India,

Canada, USA
Rye, Secale cereale Grain Southwestern Europe, Russia 15,515,206
Asia
Wheats, mainly Grain CFreerstcileent Global 629,566,0417

Triticum aestivum
(continued on next page)
u
Listed taxa chosen based on importance described elsewhere (42,135,136). Taxa are listed based on their phylogenetic relatedness (adapted from
Stevens [139]).
vCenter of origin based on best available evidence. Questionable or unclear centers are denoted with a ?.
w
xAt least 10 species of Cinnamomun are sold in the spice trade, notably the cassias, but only C. verum is considered true cinnamon (158).
An American species,E. oliefera, has been used to produce disease-resistant interspecifc hybrids.
yIncludes plantains, as well as dessert and cooking bananas.
zDue to its transcontinental spread via floating seed, kapok has long been a pantropical crop.

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Table 2. (Continued from previous page)

Family Category/ Center Major production Production,
v
Order (subfamily) Crop(s), taxa usage of origin areas 2005 (t)
Poaceae Sugarcane, Sugar New Guinea India, Cuba, Brazil 1,291,685,924

(Panicoideae) Saccharum spp.
Millets, Eleusine Grain Africa 28,559,553
coracana, Pennisetum
americanum

Sorghum, Grain Africa Global 58,668,212
Sorghum bicolor
Maize, Zea mays Grain Mexico, Global 710,675,149
C. America (dry + green)
y
Zingiberales Musaceae Banana , Musa spp. Fruit Southeast Asia Tropical America, 105,815,354
Africa
Abacá (Manila Fiber PhilippinePshipepntreasl, 100,987
hemp), Musa textilis America
Ginger, Zingiber Spice Southeast Asia India, Southeast Asia 1,004,546

officinale
Eudicots Caryophyllales Amaranthaceae Amaranths, Grain Su trbr.p., Asia N.A.
(tricolpates) Amaranthus spp. America
Quinoa, Grain Andes Andes 57,765

Chenopodium
quinoa
Sugar beet, Sugar Europe Eu rope, Russia, 240,984,299
Chenopodium USA

vulgaris
Spinach, Vegetable SW Asia Europe, Americas 12,980,944
Spinacia oleracea
Polygonales Polygonaceae Buckwheat, grain Temperate Russia, France, 2,649,524

Fagopyrum spp. E. Asia USA, Canada
Saxifragales Grossulariaceae Gooseberry, Fruit Europe, 134,452
Ribes spp. N. America
Currant, Ribes spp. Fruit Europe 862,232

Vitales Vitaceae Grapems,ainly Vitus FArusiiM.editerranean 65,584,122
vinifera Europe, USA
Malpighiales Euphorbiaceae Tung, Aleurites spp. Oil East Asia China, Argentina, 517,480
USA, Brazil
(Para) rubber, Elastomer Amazon IndoneMsiaa,la,123,590

Hevea brasiliensis
Cassava, Root and South America South America, 203,061,895
Manihot esculenta tuber Africa
Castor (bean), Oil Africa? Brazil, India, Russia, 1,393,812

Ricinus communis China
Linaceae Flax, linseed, Fiber, oil Eurasia Temperate world 887,227
Linum usitatissimum (fiber),
693,000 (seed)

Passifloraceae Passionfruit, Fruit Tropical Tropical America 1,000,000
Passiflora spp. America
Salicaceae Aspens and poplars, Timber, pulp Temperate to Temperate to arctic N.A.
Populus spp., arctic north north

Fabales Fabaceae Peanut (groundnut), Pulse, oil Argentina, 35,865,389
(Papilionoideae) Arachis hypogaea Bolivia
Pigeon pea, Pulse India India 3,476,995
Cajanus cajan
Chickpea, Pulse Western Asia India, Mediterranean 8,694,192

Cicer arietinum
Soybean, Glycine max Oil, pulse, Northeast Asia USA, South America 214,347,289
forage
Lentil, Lens culinarisPulsEaPsteida,n,a 4,059,587

Ethiopia, Near East,
Mediterranean
Alfalfa (lucerne), Forage Iran N. America, Europe, N.A.
Medicago sativa S. America

Lima bean, Pulse MS.iddle, Subtropics, tropics N.A.
Phaseolus lunatus America
Common bean, Pulse MS.iddle, Global 25,160,509
Phaseolus vulgaris America (dry + green)

Pea, Pisum sativum Pulse Near East? N. Europe, Russia, 20,283,678
China, NW USA (dry + green)
Clovers, Forage Eastern Temperate world N.A.
Trifolium spp. Mediterranean

Broad (field) bean, Pulse Europe, N. temperate world 5,778,600
Vicia faba Near East (dry + green)
(continued on next page)

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Table 2. (Continued from previous page)

Family Category/ Center Major production Production,
v
Order (subfamily) Crop(s), taxa usage of origin areas 2005 (t)
Cowpea, Pulse Ethiopia? India, W. Africa. 3,766,540

Vigna unguiculata (dry)
Bambag raroundnut, Pulse TArfrpiiccaal 61,500
Voandzeia
subterranea

Rosales Rosaceae Strawberry, Fruit Europe Europe, Russia, 3,616,865
Fragaria ananassa USA
Apples, Malus spp. Fruit Temperw aerld 59,444,377
Asia Minor,
Caucasus,
C. Asia
Almond, Nut- Central Temperate world 1,648,916

Prunus amygdalus Western Asia
Apricot, FruitiTe.moplrate,659
Prunus armeniaca
Cherry, Prunus FruitAsiaC. Temw peortde,008,390

(sweet + sour)
Peach and nectarine, Fruit Wh.ina Temperwaterld 15,782,002
Prunus
Plum, Prunus spp. Fruit N. America, Temperate world 9,458,503

Europe
Pears, Pyrus spp. Fruit AEs.ia Temperwaterld 19,539,311
Quinces, Cydonia Fruit 387,540

Raspberries, Fruit Europe, USA Europe, USA 498,102
blackberries,
Rubus spp.
Cannabidaceae Hemp, Fiber, drug- Temperate Asia Russia, India 67,460 (fiber),

Cannabis sativa medicinal, oil 32,160 (seed)
Moraceae Breadfruit, vegetable Polynesia Polynesia N.A.
Artocarpus spp.

Fig, Ficus carica Fruit Southern Arabia Turkey, Egypt, 1,075,174
Greece, Iran,
Morocco
Hops, teuroprartoepe, 100,976

Humulus lupulus world
Urticaceae Ramie, Fiber Malaysia, China 249,500
Boehmeria nivea China, Japan
Cucurbitales Cucurbitaceae Watermelon, Fruit Sofurtihcearn 96,455,182

Citrullus lanatus
Cucumber, Vegetable India 41,836,847
Cucumis sativus
Cantaloupe Fruit Africa 28,349,422

(muskmelon),
Cucumis melo
Squashes, pumpkins, Vegetable Tropical 19,816,731
gourds, Cucurbita America

spp.
White-flowered Vegetable SouthAerrica N.A.
(bottle) gourd
Lagenaria siceraria

Fagales Fagaceae Chestnut, Nut Northern 1,124,999
Castanea spp. temperate
Juglandaceae Walnuts, Juglans spp. Nut Europe, China, Europe, 1,526,816

N. America N. America
Betulaceae Hazulnu(tfsilberts), Nut Europe, 705,219
Corylus spp. SW Asia
Myrtales Myrtaceae Allspice, Spice Cabriabeann 2,481,241

Pimenta dioica
Clove, Syzygium Spice MoluccasZaPnezmibbaar,, 145,370
caryophyllus Madagascar, (whole +
Indonesia stems)

Eucalyptus, Timber Australia N.A.
Eucalyptus spp.
Brassicales Caricaceae Papaya, Fruit Central America Brazil, Nigeria, 6,810,727
Carica papaya India, Mexico,

Indonesia
Brassicaceae Turnip, Vegetable Mediterranean, N.A.
Brassica campestris Afganistan,
Pakistan

(continued on next page)

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Table 2. (Continued from previous page)

Family Category/ Center Major production Production,
v
Order (subfamily) Crop(s), taxa usage of origin areas 2005 (t)
Cabbageksa,les, Vegetable Mediterranean, 86,200,900

cauliflower, Asia Minor
broccoli, Brassica
oleracea
Swedersa,pes, Vegetable Europe- N.A.

Brassica napus Mediterranea
Mustards, Brassica Vegetable 623,2(s5e3ed)
spp., Sinapis alba
Radish, Vegetable Mideast- N.A.

Raphanus sativus Mediterranean?
Malvales Malvaceae Okra, Abelmoschus Vegetable W fr.ica Subtropics, tropics 5,041,694
(Malvoideae) esculentus (Ethiopia?)
Cottons, Fiber, oil Mostly tropics Global 18,586,467
Gossypium spp. (lint),

33,442,393
(cottonseed)
Malvaceae Kapok, Fiber Tropical Southeast Asia 122,000 (fiber),
(Bombacoideae) Ceiba pentandra America z 392,967 (fruit),

331,296 (seed
in shell)
Malvaceae Kola(nut), Cola nitida Drug- W. Africa W. Africa 221,000
(Sterculoidiae) medicinal

Malvaceae Jute, Corchorus spp. Fiber India India 3,250,322
(Tilioideae)
Malvaceae Cacao, Theobroma Confectionary, South America West Africa 3,822,009
(Byttnerioideae) cacao beverage (beans)

DipterocarpaceaeDipterocarps, Shorea Timber Southeast Asia Southeast Asia N.A.
spp., Hopea spp.,
Dipterocarpus spp.,
Vatica spp.

Sapindales Rutaceae Citrus, Citrus spp. Fruit Southeast Asia USA, Brazil 105,440,168
Meliaceae Mahoganies, Timber Tropics Tropics N.A.
Swietenia spp.,
Khaya spp.
Anacardiaceae Cashew, Anacardium Fruit, nut Tropical Tropical America 1,718,010

occidentale America (cashewapple)
2,337,358
(cashew nut)
Mango, FruitSoIhieaa,st India, China, 28,221,510

Mangifera indica Asia Mexico, Thailand,
Pakistan
Pistachio, Asastte4r9,209
Pistacia vera

Ericales Sapotaceae Karite (shea) nut, Oil W. Africa W. Africa 693,000
Butyrospermum
paradoxum
Actinidiaceae Kiwifru(thinese Fruit S. China New Zealand, Chile 1,120,938

gooseberry),
Actinidia deliciosa
Ebenaceae Persimmon, Fruit Asia Asia, N. America, 2,561,732
Diospyros kaki S. Europe
Theaceae Tea, Beverage China ChIinndai,a 3,436,180

Camellia sinensis
Lecythidaceae Brazilnut, Nut Northern Bolivia, Brazil 73,960
Bertholletia excelsa S. America
Ericaceae Blueberrcyr,anberry, Fruit N., S. America, 242,610

Vaccinumspp. Europe 386,160
Solanales Convolvulaceae Swepeo ttato, Root and Tropical Subtropics, tropics 129,392,309
Ipomea batatas tuber America
Solanaceae Pepper, chile, Vegetable, Tropical Temperate, tropical 24,941,587

Capsicum spp. spice America world
Tomato, Vegetable Tropical Global 122,659,873
Lycospersicon America
esculentum

Tobacco, Drug- Tropical Global 6,564,017
Nicotiana tabacum medicial America
Eggpla(natubergine), Vegetable India? Subtroptirc,ics30,477,775
Solanum melongena

Potato, Root and Tropical Global 323,102,918
Solanum tuberosum tuber America
(continued on next page)

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Table 2. (Continued from previous page)

Family Category/ Center Major production Production,
Order (subfamily) Crop(s), taxa usage of origin areas 2005 (t)

Gentianales Rubiaceae Cinchon(auinine), Drug- Andes Indonesia N.A.
Cinchona spp. medicinal
Coffees, Beverage Ethiopia, Tropical America 7,779,495

Coffea arabica, W. Africa (green beans)
C. canephora
Lamiales Oleaceae Olive, Olea europaea Oil Mediterranean Spain, Italy, Greece14,442,435
Lamiaceae Teak, Timber N.A.
Tectona grandis
Pedaliaceae Sesame, Oil Africa? India, China, Sudan, 3,325,679
Sesamum indicum Mexico, Venezuela,

Burma
Apiales Apiaceae Carrot, Daucus carota Vegetable Afganistan Temperwaterld 24,481,021
Asterales Asteraceae Safflower, Carthamus Oil Near East India, USA, Mexico 805,667
tinctorius
Pyrethrum, Insecticidal Caucass,W 13,405
Chrysanthemum spp. Persia (dry flowers)
Sunflower, Oil Midwestern Russia, Argentina, 30,944,162

Helianthus annuus USA Balkans
(Globaer)tichoke, Vegetable Mediterranean, Europe, USA 1,203,775
Cynara cardunculus Canary Islands
Lettuce, Lactuca spp. Vegetable Eastern N. America, 22,204,280
Mediterranean Australia, Europe,
S. America

and bacteria, whereas water deficits can eases that are innocuous in mixed or natu- most important (118,133). Given the dra-
predispose crops to other diseases ral systems but become enormous prob- matic fluctuations that occur in global cof-

(39,101,107). Insect damage and other lems in monocultures (40,92). fee prices (1), it is reasonable to assume that
diseases are among the biotic factors that Multilines and cultivar mixtures have fungicide applications for rust control would
affect host susceptibility (101,131,147). been used to discourage epidemic disease be reduced if market returns were low.

For example, canker and Phytophthora development in annual crops, and rusts and
root rot, caused by Phytophthora palmi- powdery mildews of cereals are common Diseases
vora, are diseases of citrus whose sever- targets (49,98). This approach is relatively of Tropical Perennial Crops
ities are increased by, respectively, the uncommon with perennials, especially
The disease challenges that face pro-
citrus leaf miner, Phyllocnistis citrella, and when cultivar identity is required in the ducers of tropical perennial crops are
the Diaprepes root weevil, Diaprepes ab- marketplace. There is also evidence to outlined in the following sections. As
breviatus (150), whereas the development suggest that when hosts are large, autoin-
discussed above, the overall picture is one
of anthracnose of avocado, caused by Col- fection may negate the beneficial impact of of diverse pathogens and host plants in what
letotrichum gloeosporioides , is increased heterogeneous host mixes (17,49,116). In a are often disease-conducive environments
by scab damage, caused by Sphaceloma recent review, Mundt (98) mentioned only (148,161). These are difficult problems. Due
perseae (95). one perennial crop in the tropics, coffee, in
to their polycyclic nature, measures that are
In perennial systems, there are increased which mixes of resistant cultivars were useful on annual or short-term crops may be
opportunities for pathogen movement used to combat rust. ineffective. In general, more effective and
within and among plantations. This occurs Replacing susceptible perennial hosts is
durable management options are needed in
with all contagious diseases, but can be costly, and it often takes several years perennial situations, especially when there
especially important with slow-moving before widespread changes can be made. is no winter or off-season during which
diseases that might retain a restricted dis- Schieber (130) indicated that it took about inoculum and disease pressure would be

tribution in a short-season crop 10 years for rust-susceptible coffee culti- reduced (see Buddenhagen [14] for a
(107,140,166). Given sufficient time, even vars to be replaced; and the transition to contrasting view). It is not surprising that
sedentary soilborne problems can spread Cavendish cultivars that resisted Panama diseases can be serious constraints in the
significantly. disease, caused by Fusarium oxysporum f.
production of tropical perennials, and that
When explosive aboveground diseases sp. cubense, in the American banana trades special strategies may be needed to effect
are involved, new strains (47) or taxa (151) took a decade or longer (140). their management.
that are more fit or virulent than pre-exist- Finally, perennial crops are more apt to
Below, some basic concepts are pre-
ing populations can rapidly increase to be affected by variable production or eco- sented on the occurrence and development
dominate a field or region. This process is nomic factors than annual crops. The im- of these pathosystems. Peculiar aspects of
most rapid when there is no seasonal op- pact of coffee rust provides examples. these diseases and scenarios that influence
Avelino et al. (7) demonstrated that sea-
portunity to change to resistant genotypes the types and the extent to which they
and hosts are grown in monocultures. Dis- sonal and site-specific variation affected develop are summarized. They are sci-
eases are usually far less damaging in the development of coffee rust and resul- entifically interesting problems. New vec-
intercropped production (147) and in natu- tant yield; fungicidal management of this
tors (mango malformation) or pathogens
ral ecosystems (15,17) than they are in disease was justified only in some years (bunchy top of papaya) are associated with
uniform plantings. Yellow rust of coffee, and some locations. In marginal produc- some of these diseases, and several are
Coffea arabica, caused by Hemileia vasta- tion areas where low yield potentials re-
caused by two or more taxa, for example,
trix, and South American leaf blight of sulted in narrow profit margins, the use of bud rot of betel nut and coconut, citrus
Para rubber, Hevea brasiliensis, caused by fungicides was never justified (130). In greening, mango malformation, Panama
Microcyclis ulei, are two examples of dis- these areas, rust-resistant cultivars were disease, phytoplasma diseases of coconut,

650 Plant Disease /Vol. 91 No. 6

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and tracheomycosis of coffee (29,58,89, not speciate at the same time as the host have been proposed, the absence of co-
107, 109,117,123,150; C. S. Lima, L. H. (122). Nonetheless, coevolution appears to evolved plant pathogens often plays a
Pfenning, S. S. Costa, M. A. Campos, and be an important factor in the development significant role. When species display
J. F. Leslie, unpublished). Some of the of many pathosystems (17). Several enhanced fitness in new habitats, they have

most important diseases are host-specific criteria can be used to identify possible often been “released” from important
or have restricted host ranges; they are coevolved pathosystems (10,16,19,25,46, coevolved enemies (54,96).
caused by either coevolved or new- 53,57,62,129,136,146). These include: The so-called “Enemy Release
encounter pathogens. Resistance, the most x a limited, often specific host range for Hypothesis” has been used by ecologists to
explain the development of weed species
effective tool with which many of these the pathogen;
diseases are managed, is usually available x an original geographic distribution of in new habitats. In an investigation of the
in coevolved pathosystems but is un- the pathogen that overlaps with that hypothesis, Mitchell and Power (97) found
common in some new-encounter situa- of the host; 24% fewer viruses and 84% fewer rust,
tions. Inadequate host resistance represents x the occurrence of significant disease smut, and powdery mildew fungi on 473

a significant barrier to managing many resistance in the host’s primary center nonendemic plant species in the United
new-encounter diseases. of origin; States than in their native habitats in
This review concludes with general tac- x regional overlap of resistance and Europe. Invasive weed species (those that
tics that are useful against diseases of pathogenicity factors and phenotypes were most fit) were more completely

tropical perennials. The successful man- in the respective host and pathogen released from the pathogens (had fewer)
agement of plant disease utilizes several populations (i.e., geographic evidence than their nonweedy counterparts.
principles and practices, regardless of the for reciprocal selection); There are many examples of tropical
host and the environment in which it is x gene-for-gene relationships; and crops that are most productive in non-
grown (101,143,154,165). These include x tandem speciation (aka parallel clado- native habitats (114,135). For some of

the avoidance, exclusion, and eradication genesis). these crops, the absence of a single or a
of the causal agents. Host protection is of Most examples of supposed coevolved few key pathogens is a pivotal reason for
great importance, as is the identification pathosystems possess some, but not all, of this productivity. The continued production
and incorporation of resistance in the host these attributes (25,40,92,112), and there of such crops in the new areas depends

plant. All of these approaches are dis- are relatively few examples of unequivocal upon the continued exclusion of the pivotal
cussed with tropical perennial examples. host–pathogen coevolution where unam- (most dangerous) pathogens, and failure to
Coevolved pathosystems. Although the biguous molecular data underpin the do so can be costly. For example, the co-
term “coevolution” was first coined in relationship (62,129). However, the num- evolved Sigatoka leafspot pathogens, My-
1964 to describe butterfly:plant inter- bers of unequivocal coevolved pathosystems cosphaerella musicola and M. fijiensis ,

actions (38), the idea that tandem evolution will surely increase as greater sophistication dramatically affected banana ( Musa spp.)
occurs between species was discussed by is used in the identification of these rela- production whenever they were reunited
Darwin (26) and described in the 1950s in tionships and the coevolution process is with their host in new production areas.
a plant-pathological context (20). In better understood. In the meantime, co- Other tropical perennial crops that have

describing results from his classic research evolution will remain a useful concept for been released from destructive, coevolved
on flax rust, Flor (46) suggested that the study of host–pathogen interactions. pathogens in new production areas include:
“…obligate parasites, such as the rust Centers of origin, the enemy release x banana, major production of which
fungi, must have evolved in association hypothesis, and new-encounter diseases. occurs outside Southeast Asia where
with their hosts” and that “…during their The great plant explorer Vavilov (155) tropical race 4 of F. oxysporum f. sp.

parallel evolution, host and parasite recognized different geographic regions in cubense does not occur (109);
developed complementary genic systems.” which important sets of crops plants were x Para rubber, production of which
Gene-for-gene systems have now been domesticated and utilized by primitive predominates in Southeast Asia in the
identified in many other pathosystems, and societies, and where, subsequently, ancient absence of South American leaf blight

the specific adaptation of pathogens to host civilizations began. The concept of agricul- (40);
taxa, such as those described as formae tural centers of origin has been criticized, x pineapple, Ananas comosus , major
speciales, is generally accepted as “the refined, and more fully developed in recent production of which occurs where the
outcome of coevolution” (25). years (33,56). coevolved fusariosis pathotype of
Although some of the centers that Fusarium guttiforme is not found
These relationships can be conceived of
as arms races in which increased disease Vavilov (155) recognized might be ques- (117);
resistance develops in a host in response to tionable, centers of origin for domesticated x coffee, Coffea arabica and C. robusta,
increased virulence in a pathogen (10,74). crops are usually clear (76,128,135). Ge- most of which is produced outside
The flux of resistant, rare host genotypes netic diversity is often greatest in the pri- Africa where coffee wilt disease (aka

and susceptible, common genotypes has mary centers (where the crop first tracheomycosis), caused by Gibber-
been studied most closely for obligate evolved), but can also be considerable in ella xylarioides (anamorph: Fusarium
pathogens that have specific host ranges secondary centers. In extreme cases, dis- xylarioides) is found (123) (dissemi-
and possess the complementary gene-for- tinct types of host plants may be found in nation of another coevolved disease,
yellow rust, has had a major impact
gene relationships described first by Flor secondary centers: for example, the East
(46), but it also occurs in nonobligate African Highland cooking bananas, highly on C. arabica production worldwide)
situations (25). diversified in upland East Africa but not (92) (Fig. 1);
Coevolutionary interactions are spatially found or unrecognized in the primary x cacao, Theobroma cacao , 85% of
and temporally complex and thus can be Southeast Asian home of banana (71,134). which is produced where the co-

difficult to study and document (10,16, Given the heterogeneous nature of tropi- evolved witches’-broom pathogen,
146). And there are reasons why co- cal environments, one might assume that Moniliophthora (syn. Crinipellis) per-
evolution might not develop between co- tropical crops perform best where they niciosa, does not occur (110) (Fig. 2);
occurring hosts and pathogens, even when evolved, i.e., under conditions to which and

these are obligate relationships (122). For they had adapted over time. In fact, signifi- x oil palm, Elaeis guineensis, more than
example, insufficient genetic variation may cant production for many tropical crops 90% of which is produced outside
exist in the host or pathogen for occurs outside the native ranges (Table 3). West Africa (42). Until recently, Fusa-
coevolution to occur, or the pathogen may Why is this so? Although several factors rium wilt, caused by F. oxysporum f.

Plant Disease / June 2007 651

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sp. elaeidis, was found only in West parents is a common strategy used by can be just as devastating as coevolved
Africa, where it coevolved with its breeding programs. Unfortunately, habitat diseases, but may be more difficult to

host (45). Fusarium wilt has a major destruction, deforestation, and mismanage- control. Serious new-encounter examples
influence on oil palm production in ment cause losses of these genetic for which little conventional resistance is
Africa, and would undoubtedly resources (21,30,40). The extinction of known include Phytophthora root rot of

impact the primary Southeast Asian these valuable sources of disease and pest avocado, caused by P. cinnamomi (166),
production centers if it was moved resistance, productivity, and environmental and citrus greening, caused by three
there. adaptibility is a serious problem. different ‘ Candidatus Liberobacter’ spp.

As mentioned above, resistant parents Although resistant parents are usually (S. Halbert, personal communication).
for coevolved hosts are often found in the available for the coevolved diseases, they New-encounter diseases develop when a

respective centers of origin (81,136). may not be available for new-encounter plant is confronted with a pathogen with
Prospecting in these areas for resistant diseases. Thus, new-encounter diseases which it has not had an evolutionary

Table 3. Selected coevolved and new encounter pathogens of tropical perennial crops

Pathogen (disease) w
Relative
Crop production x enRcoenrercoelsved New

Avocado Moderate * Sphaceloma perseae (scab), *Phytophthora cinnamomi (Phytophthora 39, 95, 166
Mycosphaerella perseae (silver spot) root rot)
Banana Major * Fusarium oxysporum f. sp. cubense *Ralstonia solanacearum phylotype II 13, 43, 112, 140, 141,
y
(Panama disease), *Mycosphaerella (Moko disease), *Xanthomonas 145, 149, 151, 164
fijiensis and M. musicola (Sigatoka campestris pv. musaearum (xanthomonas
leafspots), Uredo musae (rust) bacterial wilt)
Cacao Major * Moniliophthora perniciosa (witches’- *Moniliophthora rorei (frosty pod), 8, 19, 37, 40, 41, 52
broom) *Cacao swollen shoot virus (swollen

shoot), *Oncobasidium theobromae
(vascular streak dieback), *Phytophthora
megakarya (black pod), *Ceratocystis
cacaofunesta (vascular wilt)
Cinchona Major Phytophthora quininea Phytophthora cinnamomi, Phytophthora 39, 161

nicotianae
Citrus Major *‘ Candidatus Liberibacter africanus’, 115, 150
‘Candidatus Liberibacter asiaticus’ and
‘Candidatus Liberibacter americanus’
z
(huanglongbing [greening]) , Xylella
fastidiosa (variegated chlorosis),
phytoplasma (witches’-broom of lime)
Coconut Moderate *Phytoplasmas (lethal yellowing, Awka 58
wilt, coconut lethal disease, etc.),

Bursaphelenchus cocophilus (red ring),
Phytophthora katsurae (bud rot),
Phytomonas (hart rot)
Coffee, Coffea Major * Gibberella (Fusarium) xylarioides *Mycena citricolor (ojo de gallo), Xylella 92, 115, 118, 123, 133,
arabica (tracheomycosis), Hemileia coffeicola fastidiosa (variegated chlorosis) 152

(grey rust), *Hemileia vastatrix (yellow
leaf rust)
Eucalyptus Major Puccinia psidii (rust) 24
Guava, Psidium Moderate Puccinia psidii (ruvsetr)mniicillium ? (guava wilt) 24, 83
guajava

Mango Moderate * Fusarium mangiferae (malformation) *Fusarium sterilihyphosum and 3, 89, 106, and
*Fusarium sp. (malformation); footnote y
*Ceratocystis fimbriata (seca, sudden
wilt)
Opiallm Major * Fusarium oxysporum f. sp. elaeidis *Thielaviopsis paradoxa? (pudricion 12, 31, 36, 45, 104

(Fusarium wilt) cogilla [bud rot]), Phytomonas
(marchitez sopresiva), *Ganoderma
boninense (ganoderma butt rot),
*Phytoplasma? (marchitez letal [lethal
wilt])

Papaya Major * Papaya ringspot virus (papaya ringspot), 9, 103
*Phytophthora palmivora (fruit, root, and
stem rot), *‘Candidatus Phytoplasma
australasia’ (papaya dieback, yellow
crinkle and mosaic)

Pineapple Major * Fusarium guttiforme (fusariosis) 117
Rubber Major * Microcylis ulei (South American leaf 40
blight)

wCoevolved and new encounter pathogens are defined using criteria listed in the text. Those marked with an asterisk are major problems.
xRelative production: Major = more than 70% of all production for crop occurs outside endemic range(s); moderate = 30 to 69%; minor = 5 to 29%;
negligible = less than 5%.
y
zC. S. Lima, L. H. Pfenning, S. S. Costa, M. A. Campos, and J. F. Leslie, unpublished.
The Candidatus species that are associated with citrus greening (huanglongbing) appear to be new encounters in Africa (Liberobacter african),
Asia (originally India?) (Liberobacter asiaticus), and Brazil (Liberobacter americanus) (S. Halbert, personal communication).

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history (102). Two types of new en- originated on coconut palm, Cocos Although new encounters usually occur
counters have been described (17). nucifera, in Asia (36,104); and over great distances, this is not always the
The first, apparently uncommon (or at x Puccinia psidii , cause of rust of case, and there are instances when new-

least not commonly documented), results eucalyptus, Eucalyptus spp., origi- encounter pathogens evolved in close
from an evolutionary host jump. Genetic nated on other genera and species in proximity to the new-encounter host. For
changes in the pathogen (somatic hybridi- the Myrtaceae in the Americas (24). example, M. rorei probably originated on
zation, chromosome loss, and recombina-
tion are among the mechanisms) result in

its adaptation to a co-occurring, previously
nonsusceptible host (9,122,138).
The second kind of host jump results
from dissemination of either the host or

pathogen to effect a new interaction
(14,57). Often, the original host of the
new-encounter pathogen is not known;
examples include:

x Ceratocystis wilt of cacao, caused by
Ceratocystis cacaofunesta in tropical
America (8,37);
x seca or sudden decline of mango

caused in Brazil and Oman by
Ceratocystis fimbriata (3,106) (Fig.
3);

x wilt of guava, Psidium guajava ,
caused in Malaysia, South Africa, and
Taiwan by a fungus with unclear
taxonomic affiliations (83);

x witches’-broom of lime, Citrus
aurantifolia, caused in the Middle
East by a phytoplasma (150) (Fig. 4);

x mango malformation, caused in
Brazil (and possibly elsewhere in the
Americas) by Fusarium sterilihypho-
sum, an unnamed mating population

of the Gibberella fujikuroi species
complex, and possibly other taxa
(119; C. S. Lima, L. H. Pfenning, S.
S. Costa, M. A. Campos, and J. F.
Leslie, unpublished) (Fig. 5); Fig. 1. A, Adaxial and B, abaxial surface of a leaf of coffee,Coffea arabica, affected by
yellow rust, caused by Hemileia vastatrix. Rust caused little damage in natural, hetero-
x vascular streak dieback of cacao, geneous stands of coffee in Ethiopia, and in the arid Arabian Peninsula where the crop
caused in Asia by Oncobasidium was first produced outside Africa. However, beginning in the late 1800s in humid Sri
theobromae (52); and Lanka and India, the disease started to spread and cause serious damage in monocul-
ture production.
x xanthomonas wilt of banana, caused
in Africa by Xanthomonas campestris
pv. musaearum (it was reported
initially on a banana relative,Ensete

ventricossum, but it is not clear
whether this first host was coevolved
or new encounter [149,151,164]) (Fig.
6).

When the original hosts of new-
encounter diseases are known, they are
usually closely related to the newly

encountered host. For example:
x Colletotrichum kahawae , cause of
coffee berry disease, originated on
Coffea eugenioides , a close relative
(precursor?) of C. arabica (152) (Fig.

7);
x Moniliophthora rorei, cause of frosty
pod of cacao, probably originated on
Theobroma gileri (40) (Fig. 8);

x Ralstonia solanacearum phylotype II,
cause of Moko disease of banana,
evolved on banana relatives in the
Americas, Heliconia spp. (13,43) Fig. 2. Witches’-broom, caused by the hemibiotroph Moniliophthora perniciosa, is the
most serious coevolved disease of cacao. A, Hypertrophied brooms are induced dur-
(Fig. 6); ing the pathogen’s biotrophic phase. B, Brooms die as the disease transitions from the
x Ganoderma boninense, the basal stem biotrophic to the necrotic phase. C, Basidiomes of the pathogen form later on necrotic
rot pathogen of African oil palm, tissues, such as this pod.

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the western flank of the Andes, a short
distance from the cacao center on the
range’s eastern flank (40).

Disease Management
in Tropical Perennial Crops
To devise effective management strate-

gies, it is usually necessary to understand
the disease’s etiology and epidemiology.
When causal agents are not known, or
when they cannot be cultured and used to

artificially induce disease, it is usually not
possible to test treatment efficacy in a
controlled manner. Two debilitating citrus
diseases provide examples: blight, which

has an unknown etiology, and greening,
which has at least three unculturable, puta-
tive agents (150). And even when causal
agents are known, unclear epidemiologies

or an inability to reproduce symptoms
artificially with a given agent are signifi-
cant handicaps. Both of these factors con-
tribute to management problems with basal

Fig. 3. The new-encounter disease known as seca and Recife sickness in Brazil and stem rot of oil palm, a disease that kills as
sudden wilt in Oman is caused by Ceratocystis fimbriata and vectored by A, the scoly- many as 70% of the palms in plantations in
tid beetle, Hypocryphalus mangiferae . B, Internal symptoms caused by the disease Indonesia and Malaysia (36,104).
and galleries of H. mangiferae . C, Unilateral death of portions of affected trees in In general, effective disease manage-
Oman; ultimately trees are killed.This disease is an example of failed quarantine
measures, in that it was restricted to Brazil until it was recently introduced into Paki- ment relies on a delay in the onset or
reduction in the intial levels of disease
stan and Oman; it poses a grave threat to a primary center of mango germplasm in (xO), or a reduction in the rate at which
India. disease develops over time ( r) (154,165).

Below, I briefly relate these epidemiologi-
cal principles to the following tactics:
avoidance, exclusion, and eradication of
causal agents; protection of, or develop-

ment of resistance in, the host plant; and
treatment of affected plants.
Avoidance. Planting site selection is an
important first step in establishing a pro-

duction area, and can be an important tac-
tic for disease avoidance (101,165). In
general, the conditions under which dis-
ease development is favored or hosts are

predisposed to disease development should
be considered. For example, swamp spot
of banana, caused by Deightoniella toru-
losa, is exacerbated in low-lying and

poorly drained situations, as are numerous
root rots that are caused by stramenopiles
(39,107,141,153) (Fig. 9). By avoiding
chronically wet sites, it is possible to re-

duce xOfor these diseases, but especially r.
Likewise, production areas in which
hosts might be predisposed to disease de-
velopment should be avoided. Predispos-

ing factors are usually physical, but indi-
rect in their impact (131). Water and
temperature extremes are most often indi-
cated, although optimal temperatures for

the host might still lead to enhanced dis-
ease if it also favors the pathogen (101).
For example, Phytophthora root rot of
avocado is most severe between 15 and

27°C, temperatures that are also optimum
for the host (166). Physical damage to the
host might also predispose it to disease
development, and this can be abiotic, as is
Fig. 4. Lime witches’-broom is one of several serious new-encounter diseases of citrus
(here on Citrus aurantifolia). Found in the Middle East and caused by a phytoplasma, it the case with wind damage and the devel-
initially, A, dwarfs and malforms terminal portions of the canopy and, B, later kills large opment of bacterial black spot of mango,
portions of the tree. caused by Xanthomonas sp. pv. mangifer-

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aeindicae, or biotic, as for the enhanced growing areas in Florida and Queensland, sensitive plants can be damaged if exacting
development of citrus canker in leaves Australia, and the purposeful movement of temperature controls are not available.
damaged by the citrus leafminer (48,150). Moniliophthora perniciosa into cacao Only some pathogens lend themselves to

Managing the predisposing factors is al- plantations in Bahia, Brazil, are good ex- this approach, and most of the successful
ways helpful. amples of the anthropogenic dissemination examples that are available are for annual
The importance of using disease-free of harmful plant pathogens (51,65,72,73). and/or temperate crops (101). However,
planting materials cannot be overstated, The removal of trade barriers may also be heat treatment is effective for some tropi-
and any measure or legislation that would problematic; the concerns that nonendemic cal perennials. For example, heat treatment

produce disease/pathogen free materials pathotypes of Guignardia musae and Ral- eliminates the ratoon stunt pathogen,
and disseminate them to growers would be stonia solanacearum might be introduced Clavibacter xyli subsp. xyli, from sugar-
useful (66). For example, clean nursery into Australia if Philippine bananas are cane cuttings (50), and the burrowing
stock and budwood schemes are hallmarks shipped to this country are examples nematode, Radopholus similis , from ba-

of successful citrus programs (113). (70,113). nana suckers (126).
Vegetative propagules can harbor bacte- Pathogens that are moved in debris and Some pathogens can be eliminated from
ria, fungi, nematodes, viruses, and viroids, on machinery, tools, and other implements true seed, especially if contamination is
and it is with them that many economically can be excluded by surface disinfestation restricted to the seed exterior. Although

important pathogens are moved and estab- with chemical and physical measures (Fig. heat treatment is also used for this purpose
lished (65). True seed are less apt to carry 10). Likewise, seed and planting material (77), surface disinfestation with chlorine or
pathogens, but they can also pose signifi- can be treated to kill pathogens. Heat treat- fungicides is most frequent. For seedborne
cant risks. The key with both vegetative ment (thermotherapy) of vegetative propa- pathogens of quarantine concern, such as

materials and true seed is to know what gation materials is useful against bacteria, Fusarium oxysporum f. sp. elaeidis (Fusa-
diseases can be moved in these ways on a fungi, nematode, and virus pathogens. rium wilt of oil palm), extra precautions
given crop. However, there must be a significant dif- are needed to ensure that all seedborne
Tissue-culture plantlets should be used ference between the temperatures at which inoculum is killed or intercepted (45). This
whenever possible, since they are free of a pathogen dies and the host is adversely
has been of vital concern when oil palm
fungal, bacterial, and nematode pathogens affected. This can be a fine line, and heat- seed from Africa has been disseminated. In
(xO= 0) (66). They are also free of virus
and viroid pathogens when they are pro-
duced from indexed mother plants. Only in

rare cases are tissue-culture plantlets not
safe (the badnaviruses, such as Banana
streak virus , cause exceptional problems;
see ref. 84).

Many diseases of perennial crops origi-
nate in propagation nurseries, and soil-
borne diseases whose symptoms are not
readily apparent can be most problematic.

Phytophthora root rot of avocado is a good
example. P. cinnamomi originated in New
Guinea, but has been disseminated world-
wide in contaminated planting stock (166).

Its establishment in new avocado orchards
usually results from planting trees that
were infected in the nursery (95).
Exclusion. Diverse tactics exist for the
exclusion of plant pathogens (66,101).

Although the idea that “there is no disease
without the pathogen” is a simple one,
excluding pathogens from production areas
(x = 0) can be difficult. When it is possi-
O
ble, exclusion is a most cost-effective dis-
ease management strategy.
The early detection and accurate identi-
fication of pathogens are often important

first steps in exclusion, and the certifica-
tion of pathogen-free status and safe move-
ment of germplasm rely on their success
(66,101,113). All too frequently, pathogens

move via human intervention. Quarantines
can be an important first line of defense
against their intended or unintended move-
ment, and most countries have lists of
forbidden or restricted pathogens and host

plants (66,88,113,143). Unfortunately,
these rules are not always enforced suffi-
ciently to ensure border safety, and there Fig. 5. Mango malformation is caused by several different fungi. In most of the world,
are numerous examples of destructive including a presumed coevolved center in India, Fusarium mangiferae is responsible
for the disease. However, in tropical America, F. sterilhyphosum, an unnamed mating
agents moving despite quarantines. The population of the Gibberella fujikuroi species complex, and possibly other taxa cause
recent accidental introduction of Xantho- and/or are associated with malformation. Note the similar panicle symptoms induced
monas axonopodis pv. citri into citrus- by A, F. mangiferae in Florida and B, Fusarium sp. in Mexico.

Plant Disease / June 2007 655

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these cases, seed have been vacuum infil- eradication is often considered first. Al- extreme measures that were used for a
trated with fungicides and the resultant though the goal of eradication is to reduce highly mobile pathogen on a widely dis-

seedlings placed in intermediate (UK) and xO to 0, in practice these measures are persed alternate host [18]).
postentry (Malaysia) quarantine before most often rate limiting. Sanitation, the removal of infested de-
release to breeding programs. When they are significant reservoirs of bris and host materials, is another common
Pathogen vectors can also be eliminated inoculum, alternate (i.e., hosts of heter- eradication strategy. As above, its impact

to exclude pathogens of concern, but there oecious rusts) and alternative hosts are depends upon the ease with which these
are obvious requirements, including removed from plantations and destroyed. reservoirs of inoculum can be removed
knowledge of which vectors are problem- Disease pressure is usually reduced in such from plantations. Roguing infected plants
atic, where they reside, and how and cases and, when alternative host species is a key strategy, especially if the crop

whether they can be managed effectively. are involved, is most effective when their plant is the primary or sole source of in-
As for the causal agents, complete elimina- host ranges are limited. However, patho- oculum. For example, bunchy top of ba-
tion of vectors is often difficult. gens with wide host ranges can also be nana, caused by Banana bunchy top virus ,
Eradication. If pathogen exclusion has managed in this manner: for example, can be managed only if affected plants are

failed or is not possible, a different set of weed hosts of Cucumber mosaic virus in identified frequently (Fig. 11A), removed
strategies is needed. These measures are banana plantations (85). The effectiveness from plantations, and destroyed (Fig. 11B)
diverse, always more expensive than of removing alternate and alternative hosts (145). Successful control can also result
pathogen exclusion, and seldom entirely depends on their size (is accomplished

effective. The recent investment of ca. $1 most readily when plants are small enough
billion to eradicate citrus canker in Florida to be easily uprooted and removed) and the
is an extreme example of the expense of an pathogen’s mobility (the regional barberry
unsuccessful effort to eliminate a pathogen eradication programs that were instituted

(51; T. Gottwald, personal communica- to manage wheat stem rust is a prominent,
tion). Among these options, pathogen albeit annual and nontropical, example of

Fig. 7. Colletotrichum kahawae, cause of
coffee berry disease, probably coevolved

with a close relative of Coffea arabica, C.
eugenioides.

Fig. 8. The new-encounter disease frosty
pod, caused by Moniliophthora rorei, is
the most destructive disease of cacao,
due in large part to the billions of thick-
Fig. 6. Two new-encounter diseases of banana, A and B, Moko disease, caused by walled, long-lived infective spores that

phylotype II of Ralstonia solanacearum , and C and D, xanthomonas bacterial wilt, are produced on affected pods. Dissemi-
caused by Xanthomonas campestris pv. musaearum, cause similar symptoms and nation of frosty pod and witches’-broom
have similar epidemiologies, despite their different geographic origins (respectively, (Fig. 2) to the im portant West African
tropical America and Ethiopia) and etiologies. Photos A and B courtesy of I. W. production areas would be disastrous
Buddenhagen, and C and D courtesy of Eric Boa. for the world’s chocolate trades.

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when specific organs of the host are re- tions that are needed to effect disease con- which is caused by Papaya ringspot virus
moved. For example, the black pod and trol may not be cost effective unless the and vectored by transitory populations of
frosty pod diseases of cacao can be effec- crop is valuable, the treatments are highly aphids that do not establish on papaya (it is

tively and economically managed via the effective, and region-wide programs are not a preferred host), is one such disease
removal of affected pods (137). In contrast, utilized. The successful management of (103). Some vectors reside in protected
root pathogens that have wide host ranges citrus greening in South Africa is a locations that are relatively inaccessible to
can be difficult to manage in this way since relevant example, in that large areas are pesticides and thus are difficult to control.
it is usually impossible to completely re- treated for the psyllid vector (82). And Examples include the phytophagous

move these host parts when preparing a even when these conditions are met, mango bud mite, Aceria mangiferae ,
site for planting. Armillaria spp., Gano- additional measures may be needed, such which vectors Fusarium mangiferae and
derma spp., Phellinus noxious, and Rigido- as the use of pathogen-free planting stock resides under leaf bud scales, and the
porus lignosus are among the most notori- and the removal of alternative weed hosts banana aphid, Pentalonia nigronervosa ,

ous examples of these pathogens because of a pathogen. For diseases in which a which vectors Banana bunchy top virus
they are good saprophytes and colonize single feeding event by the vector is suffi- and lives at the bases of and underneath
dead roots and stumps in disturbed sites cient to infect the host, effective host pro- leaf sheaths (107). Finally, efficacious
(99,107). Once affected materials are re- tection is impossible; papaya ringspot, measures for controlling vectors may not

moved from plantations, it is important
that they be destroyed (Fig. 11B). “Cull
piles” are significant sources of inoculum
for many diseases.

Different biocidal measures can be used
to eliminate pathogens from soil. Their
impacts range from nonspecific to some-
what specific, and due to their expense,
they are used only for high-value crops.

Flooding and broad-spectrum fumigants,
such as methyl bromide + chloropicrin,
eliminate large portions of the soil biota,
resulting in what is essentially a biological

vacuum. This can be a serious problem
when the targeted pathogen has sapro-
phytic capabilities. For example, formae
speciales of Fusarium oxysporum rapidly

recolonize treated soils since they are fac-
ultative saprophytes (59,90,140). Other
treatments such as steam and solarization
have less dramatic effects and usually

eliminate only temperature sensitive organ-
isms (most plant pathogens are killed at
the 60 to 70°C that is generated by steam
or the recurring more moderate tempera- Fig. 9. Severity of Phytophthora root rot of avocado, caused by the new-encounter
pathogen P. cinnamomi, is increased dramatically in fl ooded soil.These plants have
tures, 45 to 55°C, that are generated in been flooded for 2 weeks.Those on the left are in noninfested soil and those on the
solarized soils) (75,101). Most of these right are in soil infested with P. cinnamomi.
treatments, including fumigation, solariza-
tion, steam, and chemical drenches, affect
only the surface horizons of soil. This can

be a significant problem with pathogens
that survive at lower depths.
Protection. Diverse chemical, physical,
and biological measures can be used to

protect tropical perennial hosts from dis-
eases. Ultimately, these are all rate-limit-
ing measures.
Protectant fungicides are among the

most common disease-management tools
in agriculture. In tr opical perennials, they
are used at all stages of production and
are key in the management of foliar and

fruit diseases; without them, many high-
value commodities could not be produced
(102). Those that are highly susceptible to
damaging diseases are among the most
prominent examples; they include: banana

(primarily Sigatoka leafspots), citrus
(several fruit and foliar diseases), coffee
(rust), and mango (primarily anthracnose)
(5,7,105,107,133). Fig. 10. Precautions against the movement of subtropical race 4 of Fusarium oxy-
sporum f. sp. cubense in South Africa: A, Altus Viljoen disinfests the soles of Mike
Vector control can be used to indirectly Rutherford’s shoes before he moves from an infested area, and B, the pathogen is
protect the host from the pathogen, but isolated in a former production area by a fence; note the fine-mesh barbed wire at the
there are several caveats. Pesticide applica- fence’s base for small animals.

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be available. For example, papaya bunchy sulfur to acidify those that are basic), it is studied extensively (69). The unique
top was effectively managed with DDT, not possible to do so with all soils. For niches that are protected and the posthar-
since it controlled the leafhopper vectors, example, it is virtually impossible to lower vest environmental control that is possible
Empoasca papayae and E. stevensi ; the pH of calcareous soils due to their for many of these commodities have as-

however, an effective replacement for this buffering capacity. sisted the development of effective treat-
insecticide has not been indentified (28). Host nutrition and fertilization practices ments, and commercial products exist that
Other issues that surround pesticide us- can have a large impact on disease devel- reduce disease to levels achieved by
age will not be covered here for lack of opment (27,101). Although most examples chemical measures (69,78,79). Some vi-
rus-induced diseases have also been man-
space, including: different chemistries that are for annual or short-season crops, some
are available and their spectrums of activ- perennials that are grown in the tropics aged biologically, primarily with strains of
ity; the development and use of disease have been studied. The amounts of certain the causal agents with attenuated viru-
forecasting models; application formula- elements can be important; for example, lence. For example, a nitrous acid–induced
tions, equipment, and methods; the use of applications of silicon-based amendments mutant of Papaya ringspot virus was used

spray oils, spreader stickers, and other decreased the severity of ring spot of to cross-protect papaya plantings in Hawaii
amendments; applicator safety; and envi- sugarcane (27). And the forms of nutrients (163) in much the same way that mild
ronmental concerns that are associated can be important. For example, ammonia- strains of Citrus tristeza virus have been
with pesticide usage (113). cal nitrogen increased the severity of Phy- used to protect citrus (150).

Modifications of the producing environ- tophthora root rot of citrus, whereas nitrate Biological control of plant disease is
ments are often useful. The density of nitrogen decreased its severity (94). never easy, and can be especially difficult
plant cover/canopy has a pronounced ef- Physical exclusion is useful in some for systemic diseases that increase in
fect on several diseases, although its im- situations. Greenhouse production of ba- severity over the lifespan of a given plant-
pact varies depending upon the disease nana in Morocco creates a requisite warm ing. Research on the biological control of

(101). Shade reduces the severity of black environment, but also protects plants from Panama disease illustrates the point with a
Sigatoka of banana, but it promotes the important leaf and fruit pathogens. Like- crop that is typically grown for several
development of diseases that require high wise, bags that are used to cover banana years (108). Although numerous research-
humidity or free moisture, such as black bunches in export plantations provide ers have investigated the biological control

pod of cacao and coffee berry disease physical protection from insects and me- of this disease, to date an 18% annual loss
(107,141,152). In the later cases, orienting chanical damage, but also assist posthar- has been the best result achieved that has
rows such that prevailing winds and the vest disease control by protecting fruit been reported in a refereed journal (127).
morning sun have the greatest opportunity from inoculum in the field. Physical barri- This loss rate might be acceptable in a
to dry the canopy can be helpful (111). ers, such as fences, are also used to keep short-season crop, but would be disastrous

Diverse edaphic modifications are used. inoculum out of clean fields or inside those in a perennial crop like banana (for exam-
Improved drainage and the use of mounds that are affected by an important disease ple, a compounded loss of 63% would
or beds can significantly reduce strameno- (Fig. 10B). In export banana production in result after 5 years of ratoon production).
pile-induced root diseases (22,39,95,147). the Americas, mats that are affected by Resistance. Resistance to disease can be

Soil pH impacts many soilborne diseases. Moko disease are routinely isolated from a formidable, rate-limiting tool in disease
Acidic reactions generally favor Fusarium the rest of the plantation until they have management. Genetic resistance obtained
wilts and those caused by Rosellinia spp., decayed and no longer pose a threat to the via conventional breeding has been respon-
whereas basic conditions favor diseases rest of the plantation (149). sible for some of the most important ad-
caused by Phymatotrichum omnivorum Biological disease control measures are vances in production agriculture during the

(101). Cultural practices may indirectly receiving increased attention in tropical last century (136). For an interesting
effect detrimental changes; for example, perennial crops due to declines in the num- synopsis on disease resistance and breed-
monoculture and the fertilizer that was bers of pesticides that are available, de- ing in tropical crops, see Buddenhagen
used in Hawaiian pineapple production creased efficacy of some pesticides due to (14).

reduced soil pH and thereby favored Roty- resistance, and concerns about human and The source and effectiveness of the
lenchus reniformis, a serious pathogen of environmental safety that are associated genes that are used depend on whether the
this crop (14). Although it may be possible with pesticide use (69,108,124,125). Bio- pathogen is a generalist (resistance to dis-
to change a soil’s pH with amendments control of postharvest diseases of tropical eases they cause is usually poor) or host-
fruits, caused mainly by fungi, has been specialized. As mentioned above, resis-
(e.g., lime to raise the pH of acidic soils or
tance is often available for the coevolved,
host-specialized diseases in the centers of
origin (81,136). Many breeding success
stories result from the use of such resis-

tance.
Useful resistance may be available to
some new-encounter diseases. For exam-
ple, cacao parents that resist swollen shoot
and vascular streak dieback are important

in breeding programs in, respectively,
Ghana and Papua New Guinea (R. J.
Schnell, personal communication ). How-
ever, useful genes may be infrequent in the

new-encounter host crop. The poor resis-
tance that exists in new-encounter situa-
tions can be circumvented if the original
host of the new-encounter disease is sexu-

Fig. 11. The management of banana bunchy top, caused by Banana bunchy top virus , ally compatible with the new-encounter
in Egypt and elsewhere relies on: A, frequently identifying symptomatic plants, and B, host. Intertaxon hybrids may be immedi-
removing and destroying such plants. Banana cannot be grown successfully wherever ately useful. For example, interspecific
this disease is found and these practices are not followed. hybrids between African oil palm, E.

658 Plant Disease /Vol. 91 No. 6

539Annex 14

Case 1:07-cv-01042-RWR -DAR Document 220-11 Filed 08/19/11 Page 54 of 58

guineensis, and American oil palm, E. Although they may be critical for foliar dangers of vertical resistance. Although
oleifera, resist two new-encounter diseases diseases that progress rapidly (high r), high levels of resistance can be achieved
in the Western Hemisphere, bud rot and susceptible genotypes may be used for with it, it is almost always pathotype spe-
lethal wilt (12,31) (Fig. 12). Or resistance years before they need to be replaced if a cific. Its use in perennial crops is danger-

genes can be introgressed into the host slow-developing soilborne disease is in- ous since it can be easily overcome by the
crop. The late Phil Rowe’s success in volved. McDonald and Linde (93) classi- evolution or selection of virulent patho-
breeding disease-resistant banana hybrids fied the durability of host resistance based types. Coffee/Hemileia vastatrix and rub-
relied on incorporating genes from dispa- on the life strategies and niches of the ber/Microcylis ulei are two tropical peren-

rate taxonomic backgrounds into hybrid causal agents. nial pathosystems for which vertical
diploids that were then used as pollen par- Genetic resistance obtained via conven- resistance has not been durable (80,118,
ents (121). tional breeding is often classified as verti- 133,136).
The need for and usefulness of resistant cal (usually controlled by one or a few The phenomenon of initial, excellent
perennial crops in the tropics should con- major genes) or horizontal (several genes) disease control that eventually erodes in

sider the type of disease that is addressed. (93,154). Much has been written about the vertically resistant hosts has been called
the “boom-and-bust” cycle. It is most com-
mon with foliar diseases that have the
potential for rapid epidemic development

and are caused by genetically variable
pathogens with both sexual and asexual
life cycles, i.e., those classified by McDon-
ald and Linde (93) as having “a high evo-
lutionary potential.” Although vertical

resistance is usually not durable, it can be
useful in some situations. For valuable
crops in which good production (the
“boom” part of the cycle) can be very prof-

itable, long-term resistance may not be
necessary. Acceptable production may be
possible during the time that is needed to
develop new resistant germplasm to com-
bat the eventual, resistance-breaking

pathotypes, especially when the pathogen
has a low evolutionary potential (93,136).
When considering horizontal resistance,
disease impact must be taken into account.

Horizontal resistance in perennial crops
might be valuable against nonlethal dis-
eases but less so against those that kill
plants. Coffee improvement schemes have
developed both vertical resistance to rust in

C. arabica selections and hybrids as well
as horizontal resistance in intra- and inter-
specific hybrids (the other parental species,
C. canephora, is highly tolerant) (118,133).

Genetic transformation for disease resis-
tance (the creation of Genetically Modified
Organisms, GMOs) can be quite effective
(93,143). Virus-induced diseases have lent
themselves to this approach far more often

than diseases caused by other pathogen
groups, and there are some notable success
stories. For example, the papaya industry
in Hawaii was saved by selections that

were genetically engineered for resistance
to Papaya ringspot virus (44). In general,
conventional materials are more accepted
in the marketplace than are GMOs, espe-

cially in Europe. As consumers become
better educated about the benefits and
safety of GMOs, a greater acceptance of
these products may occur.
Treatment of diseased plants. Diseased

plants can be treated effectively with vari-
ous curative (systemic) chemicals, and by
the removal of affected portions of the host
Fig. 12. The new-encounter disease lethal wilt (marchitez letal) rapidly kills oil palm in (i.e., surgery) to reduce inoculum levels.
the Llanos region of Colombia. A and B, From the first stages of the disease until C,
death, usually takes less than 6 months. Although its cause is not known, useful resis- These are rate-limiting measures.
tance is found in the American oil palm, Elaeis oleifera, which has been utilized in in- Since the development of the first sys-
terspecific hybrids with E. guineensis (note that hybrids have been planted in the dis- temic fungicides, an increasing number of
ease focus in C). these compounds have been developed for

Plant Disease / June 2007 659

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M., Power, A. G., Seabloom, E. W., Torchin, sistance to coffee rust. Annu. Rev. Phytopa- 139. Stevens, P. F. 2003. Angiosperm Phylogeny
M. E., and Vázquez, D. P. 2006. Biotic thol. 13:49-70. Website. University of Missouri, St Louis,
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9:726-740. P., and Ploetz, R. C. 2006. Fusarium sp. char- cation.
97. Mitchell, C. E., and Power, A. G. 2003. Re- acterization causing mango malformation in 140. Stover, R. H. 1962. Fusarial Wilt (Panama
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98. Mundt, C. C. 2002. Use of multiline cultivars 120. Romero, R. A., and Sutton, T. B. 1997. Sensi- Surrey, UK.
and cultivar mixtures for disease manage- tivity of Mycosphaerella fijiensis , causal 141. Stover, R. H. 1972. Banana, Plantain and
ment. Annu. Rev. Phytopathol. 40:381-410. agent of black Sigatoka of banana, to propi- Abaca Diseases. Commonwealth Mycologi-
99. Nandris, D., Nicole, M., and Geiger, J. P. conazole. Phytopathology 87:96-100. cal Institute, Kew, Surrey, UK.
1987. Root rot diseases of rubber trees. Plant 121. Rowe, P. R., and Rosales, F. E. 2000. Conven- 142. Stover, R. H. 1990. Sigatoka leaf spots: Thirty

Dis. 71:298-306. tional banana breeding in Honduras. Pages years of changing control strategies: 1959-
100. Nolla, J. A. B., and Fernandez Valiela, M. V. 435-449 in: Diseases of Banana, Abaca and 1989. Pages 66-74 in: Sigatoka Leaf Spot
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Annu. Rev. Phytopathol. 43:83-116. banana in Uganda. Plant Pathol. 53:802. thology 57:10.
144. Tano, K., and Willcox, G. 2006. How fast was 152. van der Graaff, N. A. 1992. Coffee berry 160. Wellman, F. L. 1968. More diseases on crops

wild wheat domesticated? Science 311:1886. disease. Pages 202-230 in: Plant Diseases of in the tropics than in the temperate zone.
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2000. Bunchy top. Pages 241-253 in: Dis- Sugar, Forest, and Plantation Crops. A. N. 161. Wellman, F. L. 1972. Tropical American Plant
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for Plant Disease Management in Traditional 154. van der Plank, J. E. 1963. Plant Diseases: 163. Yeh, S.-D., Gonsalves, D., Wang, H.-L.,
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544 Annex 15

EXPERT R EPORT OFD RR.I. KRIEGER, H.D. PREPARED FOR THE
D EFENDANTS INARIAS/QUINTEROS . DYNCORP(D.D.C.),

19 JNUARY 2011

(United States District Court for the District of Columbia,

545546 Annex 15

Case 1:07-cv-01Document Filed 0Page 1 of 45

EXHIBIT 9

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Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 2 of 45

EXPERT REPORT OF ROBERT I. KRIEGER

Prepared for the DynCorp Defendants in
Arias/Quinteros v. DynCorp (D.D.C.)

Table of Contents

BACKGROUND & CREDENTIALS............................................................................................ 1

STATEMENT OF COMPENSATION .......................................................................................... 2

PRIOR TESTIMONY..................................................................................................................... 2

SUMMARY OF EXPERT OPINIONS.......................................................................................... 3

INTRODUCTION .......................................................................................................................... 3

THERE IS NO BASIS TO CONCLUDE THAT THE TEST PLAINTIFFS’ ALLEGED
AILMENTS COULD HAVE BEEN CAUSED BY EXPOSURE TO THE PLAN COLOMBIA

SPRAY MIXTURE ........................................................................................................................ 5

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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herbicides.................................................................................................................................. 8

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THERE IS NO BASIS TO CONCLUDE THAT THE TEST PLAINTIFFS’ ALLEGED

INJURIES TO THEIR LIVESTOCK COULD HAVE BEEN CAUSED BY EXPOSURE TO
THE PLAN COLOMBIA SPRAY MIXTURE............................................................................ 14

Deaths ..................................................................................................................................... 14

Birth defects and miscarriages................................................................................................ 16

CONCLUSION............................................................................................................................. 16

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BACKGROUND & CREDENTIALS

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Program in Environmental Toxicology. I hold a B.S. cum laude in Chemistry from Pacific
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I am a board certified Fellow of the American Academy of Toxicological Sciences (1983 to
present) and a Fellow of the American College of Toxicology (2007-present). I am a longtime
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Society of Toxicology since 1975. I became a Fellow of the American Association for the
Advancement of Science in 2011.

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the American Chemical Society’s International Award for Research in Agrochemicals in
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(1981-1986), where I was Professor of Veterinary and Comparative Toxicology. I was a
Veterinary Toxicologist in the Washington Animal Disease Diagnostic Laboratory (WADDL)
while in the WOI Program. There I teamed with WADDL veterinarians in the investigation and
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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Department.

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▯▯▯▯▯▯▯

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which is attached to this report as Exhibit A▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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STATEMENT OF COMPENSATION

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deposition and trial testimony.

PRIOR TESTIMONY

Date Nature of Testimony Case Information

2009 Deposition and Trial Bober v. Killroy Pest Control, Inc., No. 1:06-cv-062427
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549Annex 15

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SUMMARY OF EXPERT OPINIONS

animals, and then (2) respond more specifically to the opinions offered by plaintiffs’ expert
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▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of data and information considered in reaching my opinions is attached to this report as Exhibit

INTRODUCTION

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
societies, for instance, identified poisons – some extremely toxic – in their diets. Some of the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
was first recognized as a separate discipline in the early 19▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in vivo and in vitro▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

following goals:

550 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 6 of 45

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of chemicals;

2. Determine the relationship between dose and the appearance of adverse effects in
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ientifically reliable data and information in order
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

551Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 7 of 45

THERE IS NO BASIS TO CONCLUDE THAT THE TEST PLAINTIFFS’ ALLEGED
AILMENTS COULD HAVE BEEN CAUSED BY EXPOSURE TO THE PLAN
COLOMBIA SPRAY MIXTURE.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
characterized or quantified▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Despite this absence of critical evidence, Dr. Wolfson, the test plaintiffs’ sole (initial) expert
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
1
plaintiffs” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2
allegations of persistent or chronic health effects. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯caused by▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯3▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1Dr. Wolfson identifies the test plaintiffs’ alleged health complaints as “itchiness to the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ vomiting; respiratory problems; headaches; dizziness;
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯rning throat” (Wolfson Rpt. 3).

2
Dr. Wolfson does not ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯of the test plaintiffs’ alleged
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯r that there is no evidence th▯▯▯▯▯▯▯▯▯▯▯▯▯▯ glyphosate
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

552 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 8 of 45

Colombia herbicide at those dose levels – Dr. Wolfson’s “consistent with” opinion is simply
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

y Glyphosate formulations are safely used worldwide and have been extensively

studied.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

553Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 9 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
registered by the United States Environmental Protection Agency (“EPA”), based on
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯4▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
1993).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
World Health Organization (1994) and comprehensive reviews prepared by Williams et
al. (2000), Giesy et al. (2000), and Solomon et al. (2005, 2007) 5▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2009).

4
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
evidence-based pesticide ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

5▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Health (Solomon et al. 2009).

554 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 10 of 45

555Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 11 of 45

556 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 12 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

There is no basis for Dr. Wolfson’s conclusions about eye irritation. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯http://apps.cdpr.ca.go▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯.

8▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯possible relationship indicates that health effects
correspond generally to the ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯idence is not availab▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯probable
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯orts a relationship to pe▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

definite relationship indicates that both physical and medi▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
effects. (See http://apps.cdpr.ca.g▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

557Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 13 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯tial of the Plan Colombia herbicide and/or
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
reference the California PISP data. The PISP data indicate eye irritation following
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

There is no basis for Dr. Wolfson’s conclusions about gastrointestinal symptoms.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

558 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 14 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯10▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
to even reference the far more relevant scientific evidence that ingestion of glyphosate-
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
application. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

9The “list of references” attached to Dr. Wolfson’s report▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the rest of the references cited there ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ance of this article in the body of his
report.

10
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯. (1999), none of the patien▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
experienced grade 3 gastrointestinal in▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
necrosis,” and the most significant findings were▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯level, the commodity will be
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯this finding, EPA considers (1) the toxicity of the pesticide
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
selected will be safe. The tolerance applies to food imported into th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
U.S.” (http://www.epa.gov/pesticides/factsheets/stprf.htm#tolerancesst visited December 2010).)

559Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 15 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯16▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
water (Williams et al. 2000).

There is no basis for Dr. Wolfson’s conclusions about respiratory injuries. ▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯

however, rats were similarly exposed to airborne concentrations of the Plan Colombia
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

12
The EPA determined that all of the ingredients of Cosm▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯in pesticides applied to ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

13▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯y of the samples collected (0.025 mg/L detection limit).

14
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯aminant levels are available at
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ntaminants/index.cfm#List▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

15Williams et al. (2000) reported that the highest level of ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ing of .045 mg/L.

16Williams et al. (2000) reviewed EPA’s chemical “fate” ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ter at average concentrations of 0.000063 and 0.0000011
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

560 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 16 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
-3
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯-10▯▯▯▯▯3▯▯▯▯-1▯▯▯▯▯▯▯▯▯▯▯▯▯▯ mPa at 25°C) and a low
Henry’s Law Constant (4.6 x 10 Pa m mol ), which indicate that glyphosate vapor will
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Aerodynamically, particles of this size do not remain airborne for long; rather, they reach
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

THERE IS NO BASIS TO CONCLUDE THAT THE TEST PLAINTIFFS’ ALLEGED
INJURIES TO THEIR LIVESTOCK COULD HAVE BEEN CAUSED BY EXPOSURE
TO THE PLAN COLOMBIA SPRAY MIXTURE.

Deaths.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

561Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 17 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
herbicides.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
vomiting, increased salivation, mild diarrhea, and similar symptoms. No animal deaths were
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
poisonings.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
glyphosate-based herbicides. However, I have personally reviewed claims of chlorate pesticide
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

562 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 18 of 45

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯17▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Birth defects and miscarriages.▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
family 18▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

CONCLUSION

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
certain doses, glyphosate-based herbicides have been associated with minor and transient health
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

doses at which they or their animals were allegedly exposed to Plan Colombia herbicide, let
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Robert I. Krieger

▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

17
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯spected poisonings in cattle,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
that some cattle entering th▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

18According to Mr. Santos Calero, cows ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯Plan Colombia spray events are alleged
to have given birth to deformed calves (Dep. 58). His wife, Ms. Calixta Pineda, also testified that deformed calves
were born and that other of their cows had miscarriages (Dep. 78, 81-82, 89).

563Annex 15

Case 1:07-cv-010Document 2Filed 08Page 39 of 45

Exhibit B
(Materials Considered)

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 40 of 45

Publications

1) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

3) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Toxicology and Environmental Health, Part A. 72(15):961-965.

4) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Toxicology and Environmental Health, Part A. 72(15):966-973.

5) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Review. 23(3):159-167.

6) Brain, R. and K. Solomon. 2009. Comparison of the Hazards Posed to Amphibians by the
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

7) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
367.

8) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

9) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
herbicide. Pest Management Science. 64:319-325.

10) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

11) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

12) Hernandez-Divers, S.M., P. Villegas, F. Prieto, J.C. Unda, N. Stedman, R. Branson, R.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

20(3):147-158.

564 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 41 of 45

13) Hewitt, A.J., K.R. Solomon and E.J.P. Marshall. 2009. Spray Droplet Size, Drift
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

72(15):921-929.

14) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

15) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

16) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

17) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(Phosphonomethyl) Glycine) on Performance and Selected Parameters in Broilers.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

18) Lindholm, A., E. Hewitt, P. Torres, M. Lasso, C. Echeverria, J. Shaw and J. Hernandez.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

19) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

20) Maibach, H. 1986. Irritation, sensitization, photoirritation and photosensitization assays

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21) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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22) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

23) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

24) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

25) Riley, C.M., C.J. Wisener and W.A. Sexsmith. 1991. Estimating off-target spray
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565Annex 15

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26) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Regional differences in time to pregnancy among fertile women from five Colombian
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Health, Part A. 72(15):949-960.

27) Smith, E.A. and F.W. Oehme. 1992. The Biological Activity of Glyphosate to Plants and
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28) Solomon, K.R., A. Anadon, A.L. Cerdeira, J. Marshall and L.H. Sanin. 2005.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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29) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

72(15):913.

30) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

31) Solomon, K., A. Anadon, A. Cerdeira, J. Marshall and L. Sanin. 2007. Environmental
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in Colombia. Rev. Envtl. Contam. Toxicol. 190:43-125.

32) Solomon, K.R., A. Anadon, R.A. Brain, A.L. Cerdeira, A.N. Crossan, J. Marshall, L.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Solomon, J.G. Shirly, A.N. Crossan, S. Wang & F. Sanchez-Bayo. (eds) Rational

Environmental Management of Agrochemicals. September 2007. Oxford University
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33) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Springborn Laboratories) (March 14, 2003).

34) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
17, 2003).

35) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
17, 2003).

566 Annex 15

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37) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Charlie, Amended▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(March 17, 2003).

39) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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40) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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41) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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43) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
300736; FRL 6036-1]. Fed. Reg. 63(195), 54058-54066.

44) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2002-0232; FRL-7200-2]. Fed. Reg. 67(188), 60934-60950.

45) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2004-0323; FRL-7683-9]. Fed. Reg. 69(217), 605081-605088.

46) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
HQ-OPP-2006-0177; FRL-8105-9]. Fed. Reg. 71(244), 76180-76185.

47) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

HQ-OPP-2008-0385; FRL-8408-1]. Fed. Reg. 74(242), 67129-67132.

48) WHO (World Health Organization). 1994. Glyphosate, environmental health criteria 159.
World Health Organization, Geneva, Switzerland

49) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Toxicology and Pharmacology. 31(2: Part 1):117-165.

567Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 44 of 45

Other Materials Considered

1) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2010

2) Deposition testimony:

a. Test Plaintiff depositions

b. Excerpts of DynCorp Employee Dave Crago Deposition Transcript, December 9,
2009

c. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
2010

d. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

2010

3) ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

a. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
responses, declaration of Marco Campana, deposition testimony excerpts, Accion
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

b. the following information for each test plaintiff (if applicable to the test plaintiff

and/or family):

i. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

ii. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

iii. excerpt from the Marco Campana declaration specific to each plaintiff
iv. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

v. other test plaintiff-specific information relating to their alleged physical
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯

568 Annex 15

Case 1:07-cv-01042-RWR -DAR Document 220-9 Filed 08/19/11 Page 45 of 45

vii. a map showing the approximate location of the test plaintiffs’ farm and
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
family members in their depositions

4) DynCorp Incident Reports:

a. DEDP- 00105966

b. DEMP-00144555 – 58

c. DEDP-00105992 – 94

d. DEMP-00037503 - 04

e. DEMP-00087983 – 85

f. DEMP-00149056 – 58

5) U.S. Department of State materials:

a. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
of Illicit Coca in Colombia.

b. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
for the Department of State. Use of Pesticide for Coca and Poppy Eradication
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

c. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
for the Department of State. Use of A Herbicide for Coca and Poppy Eradication
Program in Colombia. October 2004.

569570 Annex 16

EXPERT REPORT OFD R G.M. W ILLIAM, M.D.ON BEHALF OF THE
DEFENDANTS INARIAS/QUINTEROS . YNCORP, 18 ANUARY 2011

571572 Annex 16

Case 1:07-cv-0DocumentFiled 0Page 1 of 103

EXHIBIT 14

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 2 of 103

EXPERT REPORT OF GARY M. WILLIAMS ON BEHALF
OF THE DEFENDANTS IN ARIAS/QUINTEROS V.

DYNCORP

I. Credentials and Expert Disclosures

AR. elvanetrtise

I am presently Professor of Pathology and Professor of Clinical Public Health at

New York Medical College, Valhalla, NY. I have been affiliated with the College

since 1975. My curriculum vitae, which includes a list of my publications over the

past 40+ years, is attached as Exhibit A.

I have published 513 papers or chapters, most dealing with chemical toxicology,

genetic toxicology or carcinogenesis.

I have served on the editorial boards of Cell Biology and Toxicology (Founding

Editor), Chemico-Biological Interactions, Drug and Chemical Toxicology (Area

Editor for Carcinogenesis), European Journal of Cancer Prevention,

Fundamental and Applied Toxicology, In Vitro, Mutation Research, Nutrition and

Cancer, Toxicologic Pathology (Associate Editor), Toxicology and Applied

Pharmacology and I currently serve on the editorial boards of Archives of

Toxicology, and Food and Chemical Toxicology (Associate Editor). I have also

frequently served as an expert advisor on carcinogenicity and toxicology issues

573Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 3 of 103

for the U.S. Environmental Protection Agency, the National Institutes of Health,

the International Agency for Research and Cancer, and the World Health

Organization, among others.

I have received the following awards: Sheard-Sandford Award, American Society

of Clinical Pathologists and Alpha Omega Alpha, University of Pittsburgh School

of Medicine, 1967; Research Training Fellowship, International Agency for

Research on Cancer, 1971; Arnold J. Lehman Award, Society of Toxicology,

1982; Ambassador in Toxicology Award, Mid-Atlantic Chapter of the Society of

Toxicology, 2001; Enhancement of Animal Welfare Award, Society of Toxicology,

2002; Distinguished Scientist Award, Westchester Chemical Society, American

Chemical Society, New York Section, Inc., 2005; New York Medical College

Dean’s Distinguished Research Award, 2006; Merit Award, Society of

Toxicology, 2009.

B. Compensation and Prior Expert Work

I am being compensated for my work in this matter at the rate of $500 per hour.

I have not provided expert testimony in any other matter during the past four

years.

574 Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 4 of 103

C. Materials Relied Upon.

The materials upon which I have relied in preparing this expert report are cited

herein and are included in the attached Exhibit B.

II. Summary of Expert Opinions

I have been asked to review the December 17, 2010 expert report issued by Dr.

Michael Wolfson on behalf of plaintiffs in this action and respond to his opinion

that “glyphosate and glyphosate-based herbicides have been recognized in the

peer-reviewed literature as likely causative agents in the development of several

cancers” and that the alleged “exposure of plaintiffs, as a result of the aerial

spraying, very likely places them at significant risk for the development of

cancers in the future.” As set forth in detail below, the available scientific

evidence does not support Dr. Wolfson's opinion.

III. Detailed Discussion of Expert Opinion

In 2000, I co-authored a comprehensive review of the toxicology data available

®
on glyphosate and Roundup , the commercial herbicide containing glyphosate

commonly formulated with a surfactant predominantly polyethoxylated tallow

amine (POEA) (Williams et al., 2000). Inci dentally, Dr. Wolfson does not refer to

this widely cited review. That review found that the chronic toxicity and

575Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 5 of 103

oncogenic potential of glyphosate have been evaluated in one study with mice

(Knezevich, 1983) and two studies with rats (Lankas, 1981; Stout and Ruecker,

1980). Few chronic effects occurred, and those were limited to the highest

dietary levels tested (20,000 ppm in rats or 30,000 ppm in mice). Glyphosate

was not oncogenic to either species.

Genotoxicity is considered to be an indicator of potential carcinogenicity,

particularly in humans (Williams, 1987). The extensive genotoxicity data base on

glyphosate and formulations in a wide variety of in vitro and in vivo assays was

reviewed by Williams et al. (2000). No genotoxic activity of glyphosate was

observed in standard assays conducted according to international guidelines.

These assays include the S. typhimurium (Ames assay) and E. coli WP-2

reversion assays, recombination (rec-assay) with Bacillus subtilis , Chinese

hamster ovary cell gene mutation assay, hepatocyte primary culture/DNA repair

assay, and in vivo mouse bone marrow micronucleus and rat bone marrow

cytogenetics assays. Some investigators have reported evidence of genotoxic

effects mainly chromosome aberrations, of formulations in a limited number of

studies. These assays however, used toxic dose levels, and/or deficient testing

methodology, and/or endpoints/test systems not relevant to potential

carcinogenicity and were not confirmed by other investigators.

The review by Williams et al. (2000) affirmed the earlier assessments by the US

Environmental Protection Agency (US EPA, 1993, 1998) and the World Health

576 Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 6 of 103

Organization (WHO, 1994) that glyphosate is not mutagenic or carcinogenic.

The US EPA has repeatedly reaffirmed its conclusion that glyphosate is not

mutagenic or carcinogenic during the past decade (US EPA, 2002, 2004, 2006,

2008). In a December 3, 2008 Final Rule on glyphosate tolerances for certain

plant commodities and all animal commodities published in the Federal Register,

EPA stated: “There is an extensive database available on glyphosate, which

indicate that glyphosate is not mutagenic, not a carcinogen, and not a

developmental or reproductive toxicant.” (US EPA, 2008).

Dr. Wolfson’s expert report lists in references, without comment, several

toxicological studies (Marc et al., 2002, 2004; Richard et al., 2005 and Raipulis et

al., 2009). Richard et al. (2005) did not address carcinogenicity but instead

investigated potential impacts of glyphosate on aromatase activity in placental

cells as a potential indication of potenti al effects on estrogen synthesis. Richard

et al. (2005) noted, moreover, that “[t]he physiologic significant of these effects

can be questioned, in regard to the concentration used.” The other papers

identified by Dr. Wolfson involved studies of glyphosate in nonstandard systems

such as sea urchins (Marc et al., 2002, 2004) and Daphnia magna (Raipulis et

al., 2009). Marc et al. (2002) noted that the “concentration of Roundup that

provokes cell cycle disruption [in his sea urchin model] appears to largely exceed

the recommended usage concentration as an herbicide.” Marc et al. (2004)

stated of their findings, “they do not establish a direct link with the development

of cancer.”

577Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 7 of 103

Raipulis et al. (2009) reported positive results for Roundup in a single experiment

using the Escherichia coli SOS chromatest, which indicates induction of the

bacterial SOS DNA repair system. The authors conclude that their results

“suggest that glyphosate, especially, Roundup, possesses both toxic and

genotoxic properties.” However, the single experiment is inadequately described

to evaluate. Importantly, there is no mention of controls, negative or positive, or

the use of an exogenous bioactivation system, implying that none was used. The

finding of an effect in the absence of an activation system would indicate that a

component of the formulation was directly reactive, which is not supported by

abundant previous reports reviewed by Williams et al. (2000). In view of the

clear negative responses in relevant, well-validated assays conducted under

accepted conditions, I do not consider that the single experiment of Raipulis et al.

(2009) alters the conclusion of Williams et al. (2000) that glyphosate and its

formulations are not genotoxic. This conclusion is supported by the more recent

evaluation of Solomon et al. (2009). Accordingly, no carcinogenic potential of

glyphosate or Roundup® has been identified in genotoxicity tests, consistent with

the negative carcinogenicity studies.

Two studies have reported on biomonitoring of genetic alterations in circulating

white blood cells of individuals potentially exposed to glyphosate (Paz-y-Miño et

al., 2007; Bolognesi et al., 2009). The small study of Paz-y-Miño et al. (2007)

examined a group of allegedly exposed individuals, compared to unexposed

578 Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 8 of 103

individuals, from an area close to the border between Ecuador and Colombia.

They reported a genotoxic effect in the allegedly exposed individuals, but

methodological deficiencies, including lack of precise information on intervals

between exposure and sampling in the study groups and inadequate

measurement procedures, preclude any reliable scientific conclusion, and the

reported genetic differences were in any event too small to be of any biological

significance. A much larger study by Bolognesi et al. (2009) examined groups in

Colombia before and after exposure. These authors concluded that the

genotoxic risk of exposure is low.

The Bolognesi study had the potential to confirm the Paz-y-Miño report, but did

not. I agree with the conclusion of the Bolognesi study and moreover conclude

that neither report presents findings indicative of a cancer hazard.

579Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 9 of 103

IV. Conclusions

The available scientific literature identified in the reference list to the Expert

Witness Report for Plaintiffs, December 17, 2010 by Michael A. Wolfson, MD,

MPH and discussed herein, do not provide a scientifically reliable basis to opine

that exposure to glyphosate or glyphosate-based herbicides would give rise to a

“significant increased risk for the development of cancers in the future.” To the

contrary, the available evidence attests to the noncarcinogencity of glyphosate

and glyphosate-based herbicides.

Dated: Jan. 18, 2011
WiMlamrs.,

▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯ ▯▯ ▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯

580 Annex 16

Case 1:07-cv-0Document Filed 0Page 101 of 103

Exhibit B
Dr. Gary Williams Expert Report
Materials Considered

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 102 of 103

Exhibit B

Gary M. Williams Expert Report

Publications

1) Bolognesi, C., G. Carrasquilla, S. Volpi, K.R. Solomon, E.J.P. Marshall. 2009.

Biomonitoring of Genotoxic Risk in Agricultural Workers from Five Colombian
Regions: Association to Occupational Exposure to Glyphosate. J. Toxicol.
Environ. Health A. 72(15):986-87.
2) Knezevich, A. L. 1983. A Chronic Feeding Study of Glyphosate (Roundup
Technical) in Mice. Unpublished report, Bio/Dynamics, Inc., East Millstone, N.J.

3) Lankas, G.R. 1981. A Lifetime Feeding Study of Glyphosate (Roundup
Technical) in Rats. Unpublished report, Bio/Dynamics, Inc., East Millstone, NJ.
4) Marc, J., O. Mulner-Lorillon et al. 2002. Pesticide Roundup provokes cell division
dysfunction at the level of CDK1/Cyclin B activation. Chem Res Toxicol. 15:326-

331.
5) Marc, J., O. Mulner-Lorillon, and R. Belle. 2004. Glyphosate-based pesticides
affect cell cycle regulation. Biology of the Cell. 96:245-249.
6) Paz-y-Miño, C., M. Eugenia Sanchez, M. Arevalo, M. Jose Munoz, T. Witte, G.

Oleas De-la-Carrera, P.E. Leone. 2007. Evaluation of DNA damage in an
Ecuadorian population exposed to glyphosate. Genet Mol Biolog. 30(2):456-460.
7) Raipulis, J., MM Toma, and M. Balode. 2009. Toxicity and genotoxicity testing of
Roundup. Proceedings of the Latvian Academy of Sciences, Section B.

63(1/2):29-32.
8) Richard, S., S. Moslomi, et al. 2005. Differential effects of glyphosate and
Roundup on human placental cells and aromatase. Environ Health Perspect.
113:716-720.
9) Solomon, K.R., E.J.P. Marshall, G. Carrasquilla. 2009. Human Health and

Environmental Risks from the Use of Glyphosate Formulations to Control the
Production of Coca in Colombia: Overview and Conclusions. Journal of
Toxicology and Environmental Health, Part A. 72:914-920.
10) Stout, L.D. and F.A. Ruecker. 1980. Chronic Study of Glyphosate Administered

in Feed to Albino Rats. Unpublished report, Monsanto Environmental Health
Laboratory, St. Louis, MO.
11) Williams, G.M., Definition of a human cancer hazard. In: NonGenotoxic
Mechanisms in Carcinogenesis. Banbury Report 25, Cold Spring Harbor

Laboratory, New York, pp. 367-380, 1987.
12) Williams, G.M., R. Kroes, I.C. Munro. 2000. Safety evaluation and risk
assessment of the herbicide Roundup and its active ingredient, glyphosate, for
humans. Regul. Toxicol. Pharmacol. 31(2 Pt 1):117-165.

581Annex 16

Case 1:07-cv-01042-RWR -DAR Document 220-14 Filed 08/19/11 Page 103 of 103

Other Materials Considered

1) Wolfson Expert Report for Plaintiffs, Arias/Quinteros v. DynCorp, No. 07-1042
(D.D.C. Dec. 17, 2010).

2) U.S. Environmental Protection Agency. 1993. Re-registration Eligibility Decision
(RED): Glyphosate. U.S. Environmental Protection Agency, Office of Prevention,
Pesticides and Toxic Substances, Washington, D.C.
3) WHO. 1994. Glyphosate. Environmental Health Criteria No. 159. World Health
Organization, Geneva.

4) U.S. Environmental Protection Agency. 1998. Glyphosate: Pesticide tolerance,
Final Rule – 40 CFR, Part 180 [OPP-300736; FRL 6036-1]. Fed. Reg. 63(195),
54058-54066.
5) U.S. Environmental Protection Agency. 2002. Glyphosate; Pesticide Tolerances.
Final Rule – 40 CFR, Part 180 [OPP-2002-0232; FRL-7200-2]. Fed. Reg.

67(188), 60934-60950.
6) U.S. Environmental Protection Agency. 2004. Glyphosate; Pesticide Tolerance.
Final Rule – 40 CFR, Part 180 [OPP-2004-0323; FRL-7683-9]. Fed. Reg.
69(217), 605081-605088.

7) U.S. Environmental Protection Agency. 2006. Glyphosate; Pesticide Tolerance.
Final Rule – 40 CFR, Part 180 [EPA-HQ-OPP-2006-0177; FRL-8105-9]. Fed.
Reg. 71(244), 76180-76185.
8) U.S. Environmental Protection Agency. 2008. Glyphosate; Pesticide Tolerances.
Final Rule – 40 CFR, Part 180 [EPA-HQ-OPP-2008-0385; FRL-8408-1]. Fed.

Reg. 74(242), 67129-67132.

582 Annex 17

TESTIMONY OF POLICEOFFICER VICTIM OF A LAND, NNUALR EPORT
BY THEANT-NARCOTICSDIRECTORATE OF TCEOLOMBIANNATIONALPOLICE

(DIRAN), “ESULTS OF TBEREAKINPOINT ANH ISTORICMLANAGEMENT
IN THEFIGHTAGAINSTDRUG TRAFFICKING FOR THE 2008”

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯)

583584 Annex 17

585Annex 17

586 Annex 18

A NT-NARCOTICSD IRECTORATE OF THCOLOMBIAN NATIONAL POLICE

(DIRAN), ERADICATION OFILLICIC ROPSDIVISIO, NALYSIS OFCERTAIN
SPRAYINGO PERATIONALASPECTS

OCTOBER 2011:

I. Analysis of time records

II. ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
III. Spraying mission cancellation due to weather
IV. Spraying data and witness statements confronted

587588 Annex 18

MINISTRY OF NATIONAL DEFENSE

NATIONAL POLICE
[Seal]
ANTINARCOTICS DIRECTION

No. S-2011 – 019814 / ARECI – GUVGA-22

Bogota D.C. 10 October 2011

Sirs
MINISTRY OF FOREIGN AFFAIRS
Affairs before the International Court of Justice Group
Calle 10 No. 5-51 Oficina LM 301

Reference: Submission of information

I am submitting in hard copy and digital file the report in which some aspects of the

execution of the Programme for the Eradication of Illicit Crops by Aerial Spraying
with Glyphosate are analyzed. The report includes, among others, the following

information:

1. Spraying missions time of day

2. Space – time analysis of witness statements produced in the Memorial of
Ecuador v. spraying events recorded in DEL NORTE System.
3. Verification of wind conditions (through Beeper)
4. Record of non-spraying days due to bad weather conditions.

Sincerely,

Colonel EDUARDO CARDENAS VELEZ

Chief Illicit Crops Eradication Division

Enclosure: As announced

Prepared by: Ofc. Manuel Sanchez Pinzon
Date of preparation: 10 October 2011unjano Villaraga
File: D\Respaldo_gruve_01\Oficios

589Annex 18

COLOMBIAN▯NATIONAL▯POLICE▯

Anti-Narcotics Direction
Eradication of Illicit Crops Division

▯

ANALYSIS OF CERTAIN SPRAYING OPERATIONAL ASPECTS
▯

▯

▯
Bogotá, October 2011

TABLE OF CONTENTS

▯

I. ANALYSIS OF TIME RECORDS ………….............................................. 2

II. VERIFICATION OF WIND CONDITIONS (BEEPER) …………………… 40

III. SPRAYING MISSION CANCELLATION DUE TO WEATHER …………. 43
▯

▯
IV. SPRAYING DATA AND WITNESS STATEMENTS CONFRONTED...… 60
▯ ▯

590 Annex 18

I. ANALYSIS OF TIME RECORDS

No aerial spraying operations for the eradication of illicit crops in the Nariño or

Putumayo provinces have been conducted during night time. The records
documenting night times referred to by Ecuador and obtained from the SATLOC
and DelNorte softwares do not reflect the actual spraying time, but are rather the
result of a discrepancy caused when the pilots manually set the offset of the

system’s clocks.

Given that the default software time is GMT + 0:00 (Greenwich Meridian Time) and
local time in Colombia is GMT minus 5 ho urs (– 5:00), pilots would have to key in

“– 5” (minus five) on the DelNorte software’s offset in order for it to record the local
time at which the spraying actually took place.

However, some pilots key in “5” as offset, which the software records as GMT +

5:00 causing a 10-hour time-lag with regard to the real local time of spraying. Other
pilots do not make any such adjustment, and therefore the software remains at
GMT + 0:00, causing a time-lag of 5 hours with regard to local time.

These differences of 10 or 5 hours plus, between the software time and Colombian

local time are evidenced on the spraying records. For instance, in the case of a
10-hour time-lag, spray events conducted at 13:00 local time, were recorded by the
software as if they had been conducted at 23:00; if the time-lag was 5 hours, spray
events were recorded as conducted at 18:00. That is the reason why the DelNorte

software recorded numerous spray events as if they had taken place at night, when
they were actually conducted in broad daylight.

It should be noted that there is a format that allows for corroboration of the times at

which each spraying mission was carried out. On this hand-written format, called
Pilot’s Spray Data Sheet (Figure 1), pilots are required to fill out the local start
time of the spraying mission (takeoff). When returning to base, the pilots deliver
the Pilot’s Spray Data Sheet duly filled out to the Mission Planner, along with the

SATLOC or DelNorte Software card that contains the data with the records of the
spray events.

The Mission Planner transcribes all the data relevant to the mission on an Excel

spreadsheet called Daily Flight Summary –DFS - ( Figure 2 ), based on the
Software Card, except for the start (takeoff, TO) time and duration. This is due to
the fact that SATLOC or DelNorte softwares only record the start and duration of
each of the tens of spray events 1 comprised within a single spraying mission.

Therefore, the start (takeoff, TO) time and duration of the spraying mission itself,
as a whole, are taken from the Pilot’s Spray Data Sheet.
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

1▯Spray▯event▯is▯understood▯as▯each▯instance▯in▯which▯the▯pilot▯presses▯and▯releases▯the▯button▯(trigger)▯for▯

releasing▯the▯spray▯mix.▯

591Annex 18

In sum, whenever pilots correctly adjusted local time (GMT - 5:00), the records in

the SATLOC or DelNorte softwares will be within the range of the time recorded on
the DFS. Otherwise, a time-lag of plus 5 or 10 hours between the DFS and the
Software Card will appear. Therefore, to determine the actual time of spraying it is

necessary to refer to the one recorded on the DFS.

Figure 1. (Pilot’s Spray Data)Sheet

592 Annex 18

Figure 2. DFS. (Daily Flight Su)mary

Records of the DelNorte software for spraying operations

The DelNorte software records the following data for each of the spray event:

FID: A field maintained by ArcGIS that guarantees a unique ID for each row in
the table.

SHAPE: File format.
SEG: Event number generated by DelNorte software.
FILE NAME: Binary Log filename.
MISSION: Job number.
SIDE: Right or Left flight patterns.

LINE: Target line within a job area being flown.
START TIME: Start time of spray event.
LATITUDE: World Geographic Coordinate System, expressed in decimal degrees.
LONGITUDE: World Geographic Coordinate System, expressed in decimal degrees.

ALTITUDE: Altitude over mean sea level, MSL, of the spray event.
DOP: (Dilution of precision), term used in global positioning satellites (GPS) to
specify GPS precision.
FLT TIME: Length of time of spray event in seconds.
FLT LENGTH: Spray event length calculated in metres.

OTE: Deviation from planned flight path measu red in meters, off track error
(same as XTRACK).
SPEED GPS: Ground speed calculated in miles per hour.
VOLUME: Chemical application rate in gallons per hectare

AREA: Calculated area for each spray event in hectares.
LENGTH: Spray event length calculated in metres.
MONTH: Month of spray event.
SWATH: Half of the effective swath width in feet (used to buffer the lines in ArcGIS).
AIRCRAFT: Describes the aircraft type.

A_C_CROP: Describes the aircraft type and target crop.
GROUP: Assigned names given to groups or squadrons.

The foregoing explanation will now be demonstrated by analysing cases in which

the software recorded different times for the 3 or 4 aircraft taking part in a single
spraying mission:

593Annex 18

1. Spray Mission with three aircraft departing from Tumaco Spraying Base,

on 17 February 2003:

MISSION ACTUAL TIME DELNORTE DURATION OF
SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS RECORDED TIME MISSION

B17325AC 11:55 17:18 05:23 01:00

B1730CAC 11:55 12:18 00:23 01:00

B1731QAC 11:55 22:18 10:23 01:00

Line Code:
Each mission is assigned a code as follows: A011LWAC
A: Indicates the month in which the spraying mission took place:
A JANUARY
B FEBRUARY
C MARCH
D APRIL
…L DECEMBER
01: Day on which the spraying mission took place
1: Year in which the spraying mission took place (last digit of the year is taken)
L: Code assigned to each aircraft (alphanumeric)
W: Code assigned to each pilot (alphanumeric)
A: Number of each spray mission of the day
A: First mission.
B: Second mission.
C: Third mission.
D: Fourth mission.

C: Type of crop to be sprayed (C=coca)

In this particular case, mission code B17325AC stands for:

B = February

17 = day
3 = last digit of the year, i.e., 2003.
2 = aircraft code
5 = pilot code

A = number of mission of the day
C = coca crops

From the chart above, it may be seen that it refers to a mission carried out on 17

February 2003 on coca crops, in which 3 aircraft identified with codes 2, 0, 1 took
part. Rows 1 and 3 show the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code 2. It may be seen that the time

recorded by DelNorte software was 17:18, while the time recorded on the DFS
(Daily Flight Summary) was 11:55, evidencing a time-lag of plus 5 hours and 23

minutes of the aircraft’s flight to spray area and preparation for spraying.

x Row 2 corresponds to the aircraft with code 0. It may be seen that the time

recorded by DelNorte software was 12:18, and that on the DFS was 11:55, thus
showing that the pilot set the offset correctly (GMT – 5:00), and therefore there

594 Annex 18

was no time-lag, and the only difference is that of the minutes corresponding to

the aircraft’s flight to spray area and preparation for spraying.

x Row 3 corresponds to the aircraft with code 1. It may be seen that the time
recorded by DelNorte was 22:18, while the time recorded on the DFS was

11:55, evidencing a time-lag of plus 10 hours, and the 23 minutes of the
aircraft’s flight to spray area and preparation for spraying.

Additionally, it is worth recalling that the flight range of spray aircraft and escort
helicopters is approximately 4 hours and, therefore, it would be impossible for
planes departing from the base at the same time, to remain in flight for 9 or 14

hours as the DelNorte software records would allow to infer, when the time-lag of 5
or 10 hours is present.

This all shows that no spraying operations take place after sunrise, and thus none
were conducted at night, but rather the situation is that the times recorded by
DelNorte software often appear as such due to a discrepancy caused by the offset

of the system’s clocks set by the pilots. The example explained above is a clear
evidence of this. In Row 3, the DelNorte software recorded a spray event at 22:18,

when it actually took place at 12:18 as is borne out of Row 2 (where the offset was
correct) and is consistent with the time recorded on the DFS.

595Annex 18

1/2

5AC
2
17:18 2

MIAIICRACOTEOBD73

NARIÑO

0AC

12:18

MIAIICRCFOTEOB173

QAC
1
1
22:18

MIAIICRCFOTE: D1E73

596 Annex 18

21/2/2
2_Co2c_aCoca
8
AT802_Coca

RAFT CROP A_C_CROP

One Spray Mission with 3 Aircraft from Tumaco Spray Base on February 17, 2003

DFS Record.

FID61816301 1B17DELNORTE System Record .tg11ig117:18:00:17 1.32864219 ▯78.53715917547825410,890,80,9693LE3,4242,64,811,5E4172,304,72,50,40,947 B17325AC1QA73,9321,30302302IRC

597Annex 18

2. Spray Mission with four aircraft departing from Tumaco Spray Base, on 13

May 2003:

DELNORTE DURATION OF
MISSION ACTUAL TIME SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS
RECORDED TIME MISSION
E1334RAC 09:15 19:34 10:19 00:48

E1330QAC 09:15 09:34 00:19 00:48
E1331CAC 09:15 19:34 10:19 00:48

E1332PAC 09:15 14:34 05:19 00:48

From the chart above, it may be seen that it refers to a mission carried out on 13
May 2003 on coca crops, in which 4 aircraft identified with codes 4, 0, 1 and 2 took
part. Rows 1, 3 and 4 show the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code 4. It may be seen that the time
recorded by DelNorte software was 19:34, while the time recorded on the DFS

was 09:15, evidencing a time-lag of 10 hours, and the 19 minutes of the
aircraft’s flight to spray area and preparation for spraying.

x Row 2 corresponds to the aircraft with code 0. It may be seen that the time
recorded by DelNorte software was 09:34, and that on the DFS was 09:15, thus

showing that the pilot set the offset correctly (GMT – 5:00), and therefore there
was no time-lag, and the only difference is that of the minutes corresponding to
the aircraft’s flight to spray area and preparation for spraying.

x Row 3 corresponds to the aircraft with code 1. It may be seen that the time
recorded by DelNorte was 19:34, while the time recorded on the DFS was

09:15, evidencing a time-lag of 10 hours, and the 19 minutes of the aircraft’s
flight to spray area and preparation for spraying.

x Row 4 corresponds to the aircraft with code 2. It may be seen that the time
recorded by DelNorte was 14:34, while the time recorded on the DFS was

09:15, evidencing a time-lag of 5 hours, and the 19 minutes of the aircraft’s flight
to spray area and preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software
for the aircraft shown in Row 2 the offset was set correctly by the pilot and is thus

consistent with the time recorded on the DFS.

598 Annex 18

1/2
10

PAC QAC 1AC
2 0
14:34 0 09:34 19:34
2 1

MIASICNRCOTDEO:E133
MISSION CODE: E133AIICRCFOTE:OD1E33

NARIÑO

RAC
4
19:34
4

MIASICNRCOTDE:OED1E33

599Annex 18

11 2/2
a AT802_Coca NANINNNNONOINONRONRNNONNOINOINNNROINO

2 Coca AT802_Coca
RAFT CROP A_C_CROPoca AT802_Coca

Due to:
Duty Day

Mission Terminated
N N 01° 17.39' - W 78° 31.13'21'

PLOT 0909901

09901/09001

AT-802 0,00

882,13882,13

SubTotaltal HA

TIME Sprayed GALS Hect. Hect. CAL CAL

13/05/2003

One Spray Mission with 4 Aircraft from Tumaco Spray Base on May AC# 2003 PILOT FLT MSN GALS DN DN ADJ ADJ DN
DAILY FLIGHT SUMMARY - TUMACO
Date:
TO TIME 091031240404004 0,1,11,8 E E 45458440456457440,1 73,7315,20 6,25

DFS Record.

LOG NameE1E1E313C1ECCE32E3231E3AE13E31E3A330CC0C115032445004500511E0,E1,E1,80,81,11,E E E4484594234484,5

DELNORTE System Record .
FID 351637240114226 1163 E1330QAC.B999▯199▯1ighRight:47:3▯9:34:46:501.31179339 ▯78.5259630530555,770,7700,61,638,162,440,50,36,300 187,700402,800631,719 E1330QAC 134,548

600 Annex 18

3. Spray Mission with five aircraft departing from Tumaco Spray Base, on 16
March 2004:

DELNORTE DURATION OF
MISSION ACTUAL TIME
CODE DFS RECORDS SOFTWARE TIME-LAG THE SPRAY
RECORDED TIME MISSION
01:48
C16445AC 12:05 23:16 11:11
C1640RAC 12:05 13:17 01:12 01:48
01:48
C1646CAC 12:05 23:17 11:12
C1642~AC 12:05▯ 13:17 01:12 01:48

C1641QAC 12:05 ▯ 13:17 01:12 01:48

From the chart above, it may be seen that it refers to a mission carried out on 16

March 2004 on coca crops, in which 5 aircraft identified with codes 4, 0, 6, 2 and 1
took part. Rows 1 and 3 show the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code 4. It may be seen that the time recorded

by DelNorte software was 23:16, while that on the DFS was 12:05, evidencing a
time-lag of plus 10 hours, and the 1 hour and 11 minutes of the aircraft’s flight to

spray area and preparation for spraying.

x Row 2 corresponds to the aircraft with code 0. It may be seen that the time
recorded by DelNorte software was 13:17, and that on the DFS was 12:05, thus

showing that the pilot set the offset correctly (GMT – 5:00), and therefore there was
no time-lag, but only the difference due to the aircraft’s flight to spray area and

preparation for spraying (1 hour and 12 minutes).

x Row 3 corresponds to the aircraft with code 6. It may be seen that the time recorded

by DelNorte was 23:17, while that on the DFS was 12:05, evidencing a time-lag of
plus 10 hours, and the 1 hour and 12 minutes of the aircraft’s flight to spray area

and preparation for spraying.

x Row 4 corresponds to the aircraft with code 2. It may be seen that the time recorded
by DelNorte was 13:17, and that on the DFS was 12:05, thus showing that the pilot

set the offset correctly (GMT – 5:00), and therefore there was no time-lag, but only
the difference due to the aircraft’s flight to spray area and preparation for spraying

(1 hour and 12 minutes).

x Row 5 corresponds to the aircraft with code 1. It may be seen that the time recorded

by DelNorte was 13:17, and that on the DFS was 12:05, thus showing that the pilot
set the offset correctly (GMT – 5:00), and therefore there was no time-lag, but only

601Annex 18

the difference due to the aircraft’s flight to spray area and preparation for spraying

(1 hour and 12 minutes).

Consequently, it may be seen that on the time recorded by the DelNorte software for
the aircraft shown in Rows 2, 4 and 5, the offset was set correctly by the pilot and is

thus consistent with the time recorded on the DFS.

602 Annex 18

1/2

QAC
1

13:17

2AC

2
MISSION CODE: C164

13:17

MISSION CODE: C164

0AC

6AC
NARIÑO 23:17
6
MISSION 13:17 C164

MISSION CODE: C164

4AC

23:16 4

MISSION CODE: C164

603Annex 18

ca a
Coca CocaCoca
2/2

T AC_CROP CROP

,630 0,1 7,8 7,100 175,400 1,700 0,041 7,848 0403 85 AT802 AT802_Coca Coc

One Spray Mission with 5 Aircraft from Tumaco Spray Base on March 16, 2004

DFS Record.

FID 88238861 56C1646CAC.B99.B9993▯593▯RightRig4tig23:17:07:10 1.37658455 ▯78.66398084284012021210,6300,631,80,2,9,2145,5223,2,700 180,9002,21,6001,0,7541,145,863,704035,944

604 Annex 18

4. Spray Mission with three aircraft departing from Larandia Spray Base, on 11
June 2004:

MISSION ACTUAL TIME DELNORTE DURATION OF
SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS RECORDED TIME MISSION

F114UHBC 11:48 22:04 11:28 00:54
F114W4BC 11:50 12:04 00:14 01:12

F114ISBC 11:45 12:04 00:19 01:18

From the chart above, it may be seen that it refers to a mission carried out on 11 June
2004 on coca crops, in which 3 aircraft identified with codes U, W, I took part. Row 1
shows the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code U. It may be seen that the time

recorded by DelNorte software was 22:04, while that on the DFS was 11:48,
evidencing a time-lag of plus 10 hours, and 16 minutes of the aircraft’s flight to

spray area and preparation for spraying.

x Row 2 corresponds to the aircraft with code W. It may be seen that the time

recorded by DelNorte software was 12:04, and that on the DFS was 11:50, thus
showing that the pilot set the offset correctly (GMT – 5:00), and therefore there was
no time-lag, and the only difference is that of the 14 minutes of the aircraft’s flight to

spray area and preparation for spraying.

x Row 3 corresponds to the aircraft with code I. It may be seen that the time recorded

by DelNorte was 12:04, and that on the DFS was 11:45, thus showing that the pilot
set the offset correctly (GMT – 5:00), and therefore there was no time-lag, and the

only difference is that of the 19 minutes of the aircraft’s flight to spray area and
preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software for

the aircraft shown in Rows 2 and 3, the offset was set correctly by the pilot and is thus
consistent with the time recorded on the DFS.

605Annex 18

1/2

4BC
W
W

12:04

IBC

MISAIICRCOTDE:D1E14 I

12:04

MIASICNRCOTDE:D1E14

PUTUMAYO

HBC
U

23:16

MIAIICRACOTEO:D1E14

606 Annex 18

2/2

18 Coca CocaCoca
_Coca Coca

T AC_CROP CROP

One Spray Mission with 3 Aircraft from Larandia Spray Base on 11 June 2004

DFS Record.

DELNORTE System Record .
FID 1055 41075 1115 1119 F114W4BC.B9989▯4289▯4ghtRight458:0412:04:30:90 0.35513290 ▯76.90677118961148,6300,6308 51,89247,2552,7,5002,700 209,4000032,600652,157 168,55806

607Annex 18

5. Spray Mission with six aircraft departing from Tumaco Spray Base, on 20
January 2005:

MISSION ACTUAL TIME DELNORTE DURATION OF
SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS RECORDED TIME MISSION

A205BYAC 08:45 09:03 00:18 00:48
A205P&AC 08:45 09:03 00:18 00:48

A205MV 08:45 19:03 10:18 00:54
A205L%AC 08:45▯ 19:03 10:18 00:54

A205NT0A8:45 ▯ 19:03 10:18 00:54
A205K6AC 08:45▯ 19:03 10:18 00:54

From the chart above, it may be seen that it refers to a mission carried out on 20
January 2005 on coca crops, in which 6 aircraft identified with codes B, P, M, L, N and

K took part. Rows 3, 4, 5 and 6 show the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code B. It may be seen that the time
recorded by DelNorte software was 09:03, and that on the DFS was 08:45, thus

showing that the pilot set the offset correctly (GMT – 5:00), and therefore there was
no time-lag, but only the difference in the 18 minutes of the aircraft’s flight to spray

area and preparation for spraying.

x Row 2 corresponds to the aircraft with code P. It may be seen that the time

recorded by DelNorte software was 09:03, and that on the DFS was 08:45, thus
showing that the pilot set the offset correctly (GMT – 5:00), and therefore there was

no time-lag, but only the difference in the 18 minutes of the aircraft’s flight to spray
area and preparation for spraying.

x Row 3 corresponds to the aircraft with code M. It may be seen that the time
recorded by DelNorte was 19:03, while that on the DFS was 08:45, evidencing a

time-lag of plus 10 hours, and 18 minutes of the aircraft’s flight to spray area and
preparation for spraying.

x Row 4 corresponds to the aircraft with code L. It may be seen that the time

recorded by DelNorte was 19:03, while that on the DFS was 08:45, evidencing a
time-lag of plus 10 hours, and 18 minutes of the aircraft’s flight to spray area and

preparation for spraying.

x Row 5 corresponds to the aircraft with code N. It may be seen that the time

recorded by DelNorte was 19:03, while that on the DFS was 08:45, evidencing a
time-lag of plus 10 hours, and 18 minutes of the aircraft’s flight to spray area and

preparation for spraying.

608 Annex 18

x Row 6 corresponds to the aircraft with code K. It may be seen that the time
recorded by DelNorte was 19:03, while that on the DFS was 08:45, evidencing a

time-lag of plus 10 hours, and 18 minutes of the aircraft’s flight to spray area and
preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software for
the aircraft shown in Rows 1 and 2, the offset was set correctly by the pilot and is thus

consistent with the time recorded on the DFS.

609Annex 18

1/2
21

09:03
19:03

19:03

NARIÑO
09:03

19:03

610 Annex 18

2/2

NANRIRIROIRIRAROIRIRONRIRIROIRIRANRIRIROIRININO

T AC_CROP CROP

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 97,85AT802AT8A0T2802_ACTo8c0a2_CCooccaa Coca0250185050185AT80825AT8A0T28A0T28_A0CT2o8c0a2_ACTCo8oc0ca2a_CCooccaa Coca

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯5022,394▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ 0,654 2,412 0,326
PLOT

AT-802

0,00 0,00
1331,58

Adj Total HA

TIME Sprayed GALS Hect. Hect. CAL CAL

1 19:03:35:30 1.40242792 ▯78.75523787 1,100 5,94 462 2,700 174,000 Total Time 19,5

20/01/2005

AC# PILOT FLT MSN GALDAILY FLIGHT SUMMARY - TUMACOJ ADJ DN REASONS

One Spray Mission with 6 Aircraft from Tumaco Spray Base on 20 January 2005
TO
TIME

LOG Name
A20A202A06B60CA0210N1TAT12A2308C5P130500C13AY40C430.10.151.3E.9.DFS Record.1.4283.1.423.98198025502,169950593,3
DELNORTE System Record .
FID 9817 3019EA205BYAC.B99O92▯2E RightS6ART▯9:03:40:1.40420773 ▯78.7536856561 DOP 1,100T_TIM1,29T_LENG97 OTE 2,000SPEE168,200LUME 1,600EA LENGTH MONTH SWATH AIRCRAF
10049130325060 320C5.BL9%9AC.B9992▯2 92▯▯3▯▯19:03:37:64 1.40322521 ▯78.75478819:0t3:1,10016,1901,7,100 126,12020 4,900456,3165,900,9 3971,70000 6,700 31,06070,401067,601065,1010,700 1,700 1,700

611Annex 18

6. Spray Mission with two aircraft departing from Tumaco Spray Base, on 8
December 2005:

DELNORTE DURATION OF
MISSION ACTUAL TIME SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS RECORDED TIME MISSION

L085NQAC 13:26 23:41 10:15 00:54

L085B~AC 13:30 13:41 00:11 00:54

From the chart above, it may be seen that it refers to a mission carried out on 08

December 2005 on coca crops, in which 2 aircraft identified with codes N and B took
part. Row 1 shows the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code N. It may be seen that the time

recorded by DelNorte software was 23:41, while the time recorded on the DFS was
13:26, evidencing a time-lag of 10 hours, and the 15 minutes of the aircraft’s flight to

spray area and preparation for spraying.

x Row 2 corresponds to the aircraft with code B. It may be seen that the time
recorded by DelNorte software was 13:41, and that on the DFS was 13:30, thus

showing that the pilot set the offset correctly (GMT – 5:00), and therefore there was
no time-lag, and the only difference is that of the minutes (11) corresponding to the

aircraft’s flight to spray area and preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software for

the aircraft shown in Row 2 the offset was set correctly by the pilot and is thus
consistent with the time recorded on the DFS.

612 Annex 18

1/2

QAC
N
N

23:41

MISSION CODE: L085

~AC
B
B

13:41

MISSION CODE: L085

NARIÑO

613Annex 18

25 aacoC
oca Coca
2/2

T AC_CROP CROP

PLOT

AT-802

0,00 129,70

Adj Ha
Total HA

1,8
e

12/08/2005 Total FLT Tim

DAILY FLIGHT SUMMARY - TUMACO

One Spray Mission with 2 Aircraft from Tumaco Spray Base on 8 December 2005
Date:

TIME TIME Sprayed GALS Hect. Hect. CAL CAL

DELNORTE System Record . LOG Name TO AC# PILOT FLT MSN GALS DN DN ADJ ADJ DN
FID SEG FILE_NAME MISSION SIDE LINE START_TIME LATITUDE08~LONGITUDE31ALTITUDE9006CDOPDbAFrdFLT_TIME FLT_LENGTHS RecoOTE0tltt430SPEED51r(srVOLUME,47s expAREAationLENGTH MONTH SWATH AIRCRAF
13325 668 7L085B~AC.B99B9992▯2 92RightR11ht 13:41:03:23 1.39828493 ▯78.743228163067 76 0,8900,890 0,62 1,79 48,3147,9 1,9003,900 174,3004,800 6,100,100 0,250,76648,361

614 Annex 18

7. Spray Mission with two aircraft departing from Villagarzon Spray Base on 26
December 2006:

DELNORTE
MISSION ACTUAL TIME DURATION OF THE
CODE DFS RECORDS SOFTWARE TIME-LAG SPRAY MISSION
RECORDED TIME

L266JDAC 09:45 19:48 10:03 00:24
L266AJAC 09:45 09:48 00:03 00:18

From the chart above, it may be seen that it refers to a mission carried out on 26
December 2006 on coca crops, in which 2 aircraft identified with codes J and A took
part. Row 1 shows the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with code J. It may be seen that the time recorded

by DelNorte software was 19:48, while that on the DFS was 09:45, evidencing a
time-lag of 10 hours, and the 3 minutes of the aircraft’s flight to spray area and

preparation for spraying.

x Row 2 corresponds to the aircraft with code A. It may be seen that the time

recorded by DelNorte software was 09:48, and that on the DFS was 09:45, thus
showing that the pilot set the offset correctly (GMT – 5:00), and therefore there was

no time-lag, and the only difference is that of 3 minutes of the aircraft’s flight to
spray area and preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software for

both aircraft shown in Row 2 the offset was set correctly by the pilot and thus is
consistent with the time recorded on the DFS.

▯

615 Annex 18

1/2
27

PUTUMAYO

DAC
J

MIAICNRCOTDE:OLD2E66
09:48

19:48

JAC
A
A

MIAIICRCOTDE:OLD2E66

616 Annex 18

_Cocaoca

2/2

28 T AC_CROP

NGITUDE ALTITUDE DOP FLT_TIME FLT_LENGTH OTE SPEED VOLUME AREA LENGTH MONTH SWATH AIRCRAF

One Spray Mission with 2 Aircraft from Larandia Spray Base on 26 December 2006

DFS Record.

DELNORTE System Record .
FID 17142 7011 L266AJAC.B99.B292▯1292Right 281 219:48:22:30 0.48674345 ▯76.3685804443329 2760,890018003,9 3,4 281,1250,0,700 161,200,06,700,50,857 281,5861,00612

617Annex 18

8. Spray Mission with two aircraft departing from Villagarzon Spray Base on 08

January 2007:

DELNORTE DURATION OF
MISSION ACTUAL TIME SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS
RECORDED TIME MISSION
A087D0JAC5 12:35 05:20 01:00

A087ABAC 07:15 17:34 10:19 01:00

From the chart above, it may be seen that it refers to a mission carried out on 8
January 2007 on coca crops, in which 2 aircraft identified with codes A and D took
part. Row 1 shows a time-lag of 5 hours in the start time and row 2 a time-lag of 10

hours, as follows:

x Row 1 corresponds to the aircraft with code D. It may be seen that the time
recorded by DelNorte software was 12:35, while that on the DFS was 07:15,

evidencing a time-lag of 5 hours, and 20 minutes of the aircraft’s flight to spray area
and preparation for spraying.

x Row 2 corresponds to the aircraft with code A. It may be seen that the time
recorded by DelNorte software was 17:34, and that on the DFS was 07:15, thus

showing a time-lag of 10 hours, and 19 minutes of the aircraft’s flight to spray area
and preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software for
both aircraft the offset was set incorrectly by the pilots and is thus inconsistent with the

time recorded on the DFS.

618 Annex 18

0°20'N 0°15'N

30 RÍO PUTUMAYO

Scale: 1:100,000
the river is the International boundary
76°25'W 76°25'W

SprInterNote:nal boProjection: UTM zone 18; Datum: WGS-84
17:34
BAC
A 0 1 2 3m 4k 5

MIAIRCRAFT CODE087

76°30'W 76°30'W
RÍO SAN MIGUEL
PUTUMAYO

COLOMBIA

ECUADOR

JAC
D
12:35
D

76°35'W COLOMBIA 76°35'W

MISSION CODE: A087

One Spray Mission with 2 Aircraft from Villagarzon Spray base on 8 January 2007

OCEAN ECUADOR
PACIFIC

Figure 10. 0°20'N 0°15'N

619Annex 18

2/2
5_C5_Coca Condor
31
T AC_CROP GROUP PUPTUUAMUMUTUTUOUAMUMUTUOYOYO

N0°34.08' W76°29.70'

28001/03

339,40

SubToTotal HA40 0,00

Total time 6,4
08/01/2007

One Spray Mission with 2 Aircraft from Villagarzon Spray Base on 8 January 2007
Date: TIME 07084027010TIME270 Sprayed GALSE 0E,6 Hect. 1Hect. 24CAL,50 2CAL6

COCA T65 DAILY FLIGHT SUMMARY - Villa Garzon, Putumayo
LOG NamA087DJACJ8C80715 3078CCB3073C90940202701,060,4E,61E,270,20,22692E2443,73450315148 25,2040,36
DELNORTE System Record .
FID3543 33527923 3A405897AAB0A8C7.DBJ9A9C.B29992▯1292▯▯7▯▯▯▯ Rig1ht 121,0301,108,70,8 644,67559,634 43958,450101526,8005,90001066,70027301 303

620 Annex 18

9. Spray Mission with five aircraft departing from Larandia Spray Base, on 01
January 2007:

MISSION ACTUAL TIME DELNORTE DURATION OF
SOFTWARE TIME-LAG THE SPRAY
CODE DFS RECORDS RECORDED TIME MISSION

A017KQAC 12:04 22:25 10:21 01:24
A017LAAC 12:04 23:25 11:21 01:24

A017OPAC 12:04 17:25 05:21 01:06

A017P-AC 12:04 12:25 00:21 01:06
A017FEAC 12:04 22:25 10:21 01:24

From the chart above, it may be seen that it refers to a mission carried out on 1
January 2007 on coca crops, in which 5 aircraft identified with codes K, L, O, P and F
took part. Rows 1, 2, 3 and 5 show the time-lag in the start time, as follows:

x Row 1 corresponds to the aircraft with tail number PNC 4002, code K. It may be
seen that the time recorded by DelNorte software was 22:25, while that on the DFS

was 12:04, evidencing a time-lag of plus 10 hours, and the 21 minutes of the
aircraft’s flight to spray area and preparation for spraying.

x Row 2 corresponds to the aircraft with tail number PNC 4003, code L. It may be
seen that the time recorded by DelNorte was 23:25, while that on the DFS was
12:04, evidencing a time-lag of plus 11 hours, and the 21 minutes of the aircraft’s

flight to spray area and preparation for spraying.

x Row 3 corresponds to the aircraft with tail number PNC 4007, code O. It may be

seen that the time recorded by DelNorte software was 17:25, while that on the DFS
was 12:04, evidencing a time-lag of plus 5 hours, and the 21 minutes of the

aircraft’s flight to spray area and preparation for spraying.

x Row 4 corresponds to the aircraft with tail number PNC 4008, code P. It may be

seen that the time recorded by DelNorte software was 12:25, and that on the DFS
was 12:04, thus showing that the pilot set the offset correctly (GMT – 5:00), and

therefore there was no time-lag, but only the difference of the 21 minutes of the
aircraft’s flight to spray area and preparation for spraying.

x Row 5 corresponds to the aircraft with tail number PNC 4011, code F. It may be
seen that the time recorded by DelNorte was 22:25, while that on the DFS was
12:04, evidencing a time-lag of plus 10 hours, and the 21 minutes of the aircraft’s

flight to spray area and preparation for spraying.

621Annex 18

Consequently, it may be seen that on the time recorded by the DelNorte software for

the aircraft shown in Row 4, the offset was set correctly by the pilot and is thus
consistent with the time recorded on the DFS.

622 Annex 18

0°20'N

1/2

Scale: 1:50,000
the river is the International boundary
COLOMBIA

Spray lNote:o2r0dProjection: UTM zone 18; Datum: WGS-84
PUTUMAYO

m k 555 ,2,1,0210

77°5'W 77°5'W

AAC 23:25
~AC 12:25
P FAC 22:257:25
A017 O

A017 A017A017

QAC 22:25
K

A017
RÍO SAN MIGUEL COLOMBIA

One Spray Mission with 5 Aircraft from Larandia Spray base on 8 Junary 2007

ECUADOR
PACIFIC ECUADOR

Figure 11.
0°20'N

623Annex 18

2/2

02_Cocao2Lo02_CocaLoLobo
802_Coca Lobo

T AC_CROP GROUP

N N0°02°287.'-'9.2.'-.2.5-0.-.'a°r.1au'NtariNt/riayumaayumayomayayo

28802 5880258805880528805

267021,7801,4801,4890490428904

AT-802 45,03
699,15

ADJ HA
Total HA

14,7

01/01/2007 Total FLT Time

One Spray Mission with 5 Aircraft from Larandia Spray Base on 1 January 2007

Date:

TIME TIME DAILY FLIGHT SUMMARY - LARANDIAHect. Hect. CAL CAL

DELNORTE System RecorLOG NA0107K7K0ACAL7120O714-4CB00403004070070808b-oc1,41,1,4E,E,1E,4,26190E00012,48,0,677,,402,,844,39,604,957,1tion.
FID 368036940604117410.0A9BA78PA7P▯99g8R5g852g85:2522554:724812:519▯57340.759184821805351317007,62570,490,58990,672,25673041921003103076004,0,9010,620632090,350801060,3,4368059

624 Annex 18

10. Analysis of a single aircraft (Code K) on separate missions during 2006

Below is an example in which a follow-up of the same aircraft (tail number PNC4011
Code F), shows a time-lag of 10 hours in several missions during the year 2006:

MISSION ACTUAL TIME DELNORTE SOFTWARE TIME-LAG
CODE DFS RECORDS RECORDED TIME

C056K0BC 13:13 23:43 10:30

E036KPAC 11:13 22:22 11:09
L256KAAC 10:32 20:56 10:24

The chart above shows records for the Code-K aircraft, of missions conducted on 5
March 2006, 3 May 2006, and 25 December 2006, on coca crops. All the Rows the
plus 10-hour time-lag in the start time, as follows:

x Row 1 shows that on 5 March 2006, DelNorte software recorded the start time for
that aircraft as 23:43, while that on the DFS was 13:13, evidencing a time-lag of
plus 10 hours, and the 30 minutes of the aircraft’s flight to spray area and

preparation for spraying.

x Row 2 shows that on 3 May 2006, DelNorte software recorded the start time for that

aircraft as 22:22, while that on the DFS was 11:13, evidencing a time-lag of plus 10
hours, and 01:13 minutes of the aircraft’s flight to spray area and preparation for

spraying.

x Row 3 shows that on 25 December 2006, DelNorte software recorded the start time
for that aircraft as 20:56, while that on the DFS was 10:32, evidencing a time-lag of

plus 10 hours, and the 24 minutes of the aircraft’s flight to spray area and
preparation for spraying.

Consequently, it may be seen that on the time recorded by the DelNorte software for
the referred-to aircraft, on separate missions, the offset was not set correctly by the
pilots, and thus maintains a 10-hour difference with regard to the time recorded on the

DFS.

625 Annex 18

1°25'N 1°20'N

Scale: 1:100,000

the river is the International boundary

Spray leNote: riverundary
Projection: UTM zone 17; Datum: WGS-84
78°35'W 78°35'W

0 1 2 3m 4k 5

NARIÑO

COLOMBIA

0BC
23:43 K

▯

78°40'W MIAIRCRAFT CODE056 78°40'W

ta
íoMa ECUADOR
R

Analysis of a single aircraft (Code K) on two sep22:22 missions during 2006

KAC

Figure 12.
COLOMBIA

78°45'W 78°45'W

MISIRORNACTDCEOE036

PACIFIC ECUADOR

1°25'N 1°20'N

626 Annex 18

0°25'N

Scale: 1:50,000

COLOMBIA the river is the International boundary

Spray eorder riveroundary
Projection: UTM zone 18; Datum: WGS-84
PUTUMAYO
m k 5 55,2,1,20 10

77°5'W 77°5'W

20:56

KAC

Analysis of a single aircraft (Code K) on a mission during 2006

MISSION CODE: L256

Figure 13.

RÍO SAN MIGUEL

COLOMBIA

ECUADOR
PACIFIC ECUADOR

0°25'N

627Annex 18

CR NOTE: PAGE 39 BLANK IN THE ORIGINAL

II. VERIFICATION OF WIND CONDITIONS (BEEPER)

Prior to the start of spray missions, a reconnaissance aircraft flies over the areas

targeted for eradication and its pilot verifies if weather conditions are appropriate to
authorize the beginning of the operations.

During the reconnaissance flight, the pilot determines if wind conditions are

appropriate. He releases a discharge of smoke –known as Beeper– (Photograph 1)
and how it behaves once it is in contact with the wind is observed. If the smoke
moves only slightly, indicative of mild winds, spray operations are authorized;
otherwise, they are cancelled.

Photograph 1: Smoke trail, to validate wind conditions.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ce), showing validation of wind conditions
present at Plot targeted for eradication.

This procedure is repeated by the pilots during the spray missions in order to
confirm that wind conditions as observed by the reconnaissance pilot remain so
(photograph 2). Risk of drift is thus reduced to minimal.

628 Annex 18

Foto 2: Smoke trail and spray, seen from below the aircraft.

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯hows the difference between trail left by spray
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

CR NOTE: PAGE 42 BLANK IN THE ORIGINAL

629Annex 18

III. SPRAYING MISSION CANCELLATION DUE TO
WEATHER ▯

Before each spraying mission begins, a reconnaissance aircraft flies over the
selected areas for the eradication of illicit crops, and its pilot verifies if weather
conditions such as rain, wind and cloud cover are in compliance with the
operational parameters.

If weather conditions are not appropriate, the mission is cancelled. The fact that it
was not possible to comply with spraying tasks due to weather reasons is recorded
on the Spray Mission Record (some samples are included below).

Records are kept for all non-spray (cancelled) missions, and they are at the Court’s

disposal. They show that Colombia has been careful not to spray under bad
weather conditions. With regard to the relevant period in the present case, the
following Spray Mission Records are available:

2001: Caquetá-Putumayo: 15 records.

2002: Caquetá-Putumayo: 22 records.
2003: Nariño-Cauca: 136 records.
2004: Caquetá-Putumayo: 48 records.
2004: Nariño-Cauca: 39 records.
2005: Nariño-Cauca: 12 records.

2006: Caquetá-Putumayo: 17 records.
2006: Nariño-Cauca: 54 records.

A chart showing the number of ops days cancelled due to weather between 2000
and 2010 is also included below.

630 Annex 18

SPRAYING▯OPS▯DAYS▯CANCELLED▯DUE▯TO▯WEATHER▯2000▯2010

SPRAYING▯OPS▯DAYS▯
YEAR ▯BASE▯LOCATION DAYS▯OF▯ CANCELLED▯DUE▯TO▯
SPRAYING▯OPS
WEATHER
LARANDIA▯(CAQUETA) 319 65
2010 TUMACO▯(NARIÑO) 255 133

Total▯2010 574 198
LARANDIA▯(CAQUETA) 33 14
2009
TUMACO▯(NARIÑO) 281 155
Total▯2009 314 169
LARANDIA▯(CAQUETA) 120 40

2008 TUMACO▯(NARIÑO) 300 129
VILLAGARZON▯(PUTUMAYO) 90 28

Total▯2008 510 197
LARANDIA▯(CAQUETA) 137 57
2007 TUMACO▯(NARIÑO) 223 86

VILLAGARZON▯(PUTUMAYO) 14 1
Total▯2007 374 144
LARANDIA▯(CAQUETA) 105 35

2006 TUMACO▯(NARIÑO) 209 70
VILLAGARZON▯(PUTUMAYO) 104 24

Total▯2006 418 129
LARANDIA▯(CAQUETA) 172 48
2005 TUMACO▯(NARIÑO) 165 60

CHACHAGUI▯(NARIÑO) 29 28
Total▯2005 366 136

LARANDIA▯(CAQUETA) 247 117
2004 TUMACO▯(NARIÑO) 131 58
VILLAGARZON▯(PUTUMAYO) 57 19

Total▯2004 435 194
LARANDIA▯(CAQUETA) 11 5
TUMACO▯(NARIÑO) 215 114
2003
VILLAGARZON▯(PUTUMAYO) 79 36
CHACHAGUI▯(NARIÑO) 14 7

Total▯2003 319 162
LARANDIA▯(CAQUETA) 250 81
2002 TUMACO▯(NARIÑO) 102 46

VILLAGARZON▯(PUTUMAYO) 187 26
Total▯2002 539 153

LARANDIA▯(CAQUETA) 228 74
SOLANO▯(CAQUETA) 32 13
2001 TUMACO▯(NARIÑO) 54 14

VILLAGARZON▯(PUTUMAYO) 48 11
Total▯2001 362 112
LARANDIA▯(CAQUETA) 285 60

2000 SOLANO▯(CAQUETA) 12 4
TUMACO▯(NARIÑO) 27 5

Total▯2000 324 69

631Annex 18

ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
SPRAY▯AIR▯BASE▯–▯VILLA▯GARZON▯PUTUMAYO

▯

▯
MINUTE▯ NO.▯ 027/▯ ▯▯ NON▯SPRAYING▯ OF▯ COCA▯ ILLICIT▯ CROPS▯ IN▯ THE▯ JURISDICTION▯ OF▯ THE▯
PROVINCE▯OF▯PUTUMAYO▯
▯

▯
In▯Villagarzón,▯on▯January▯12,▯2007,▯staff▯participating▯in▯the▯Eradication▯of▯Illicit▯Coca▯
Crops,▯ Major▯ VALERO▯ TORRES▯ WILLIAM,▯ Spraying▯ Operation▯ Commander,▯ and▯ Mr.▯

CAMILO▯ GUERRERO▯ BETANCOURT,▯ representative▯ of▯ the▯ Public▯ Ministry,▯ met▯ at▯ the▯
administrative▯premises▯of▯the▯Spray▯Air▯Base▯of▯Villagarzón▯in▯order▯to▯put▯on▯record▯that▯
no▯spraying▯operations▯were▯conducted▯due▯to▯BAD▯WEATHER▯CONDITIONS▯IN▯THE▯ZONE.▯▯

▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯read▯and▯signed▯for▯all▯those▯who▯
took▯part▯in▯it.▯

▯
▯
▯

[Signed]▯
▯
Mr.▯CAMILO▯GUERRERO▯BETANCOURT▯
Regional▯Ombudsman▯Villagarzón▯

▯
[Signed]▯
Major▯VALERO▯TORRES▯WILLIAM▯

Commander▯Spraying▯Operation▯
▯
▯
E▯mail:▯[email protected]▯

Avenida▯El▯Dorado▯Entrada▯6▯Base▯Aérea▯de▯Bogotá▯Telefax▯4397433▯

632 Annex 18

▯
▯
▯

ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
AERIAL▯SPRAYING▯BASE▯–▯POPAYAN▯

▯
▯
▯
MINUTE▯ NO.▯ 017/ ▯ ▯▯ NON▯SPRAYING▯ OF▯ ILLICIT▯ OPIUM▯POPPY▯ CROPS▯ IN▯ THE▯ PROVINCES▯ OF▯

CAUCA▯AND▯NARIÑO▯
▯
In▯Popayán,▯Cauca,▯on▯April▯2,▯2003,▯Capt.▯Carlos▯Arturo▯Téllez,▯ARECI▯Spraying▯Coordinator▯and▯

Operation▯ Commander;▯ Capt▯ Germán▯ Pineda,▯ Turbo▯ Thrush▯ Pilot,▯ Mrs.▯ Emma▯ Vernaza▯Niño,▯
Delegated▯ Procurator▯ met▯ at▯ the▯ administrative▯ offices▯ of▯ the▯ Popayán▯ Air▯ Base▯ in▯ order▯ to▯
proceed▯with▯the▯aerial▯spraying▯of▯illicit▯opium▯poppy▯crops▯in▯the▯Departments▯of▯Cauca▯and▯

Nariño.▯Operations▯could▯not▯be▯conducted▯due▯to▯bad▯weather▯conditions▯in▯the▯zone.▯
▯
▯

▯
Mrs.▯EMMA▯VERNAZA▯NIÑO▯
Delegated▯Procurator▯

▯
▯
[Signed]▯
Capt▯GERMÁN▯PINEDA▯

Turbo▯Thrush▯Pilot▯
▯
[Signed]▯▯

Capt▯CARLOS▯ARTURO▯TÉLLEZ▯
ARECI▯Spraying▯Coordinator▯and▯Operation▯Commander▯
▯

▯
▯
▯
▯

▯
▯▯
▯

633Annex 18

▯

▯
▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯

AERIAL▯SPRAYING▯BASE▯–▯VILLAVICENCIO▯
▯
▯

▯
MINUTE▯NO.▯001/ ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯CROPS▯IN▯THE▯PROVINCE▯OF▯NARIÑO▯
▯
▯

In▯Tumaco,▯Nariño,▯on▯December▯6,▯2003,▯Capt▯LUIS▯FERNANDO▯ARISTIZÁBAL▯TAMAÑO;▯
Spraying▯ Operation▯ Commander,▯ Vice▯First▯ Sgt▯ GUSTAVO▯ MEJIA▯BÁEZ,▯ ARECI▯ Spraying▯
Coordinator,▯Mr.▯DIEGO▯ARIAS▯GAVIRIA,▯Delegated▯Procurator▯met▯at▯the▯administrative▯

offices▯of▯the▯Tumaco▯Air▯Base▯in▯order▯to▯proceed▯with▯the▯aerial▯spraying▯of▯illicit▯coca▯
leaf▯crops.▯Operations▯could▯not▯be▯conducted▯due▯to▯bad▯weather▯conditions▯in▯the▯zone.▯

▯
▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯read▯and▯signed▯for▯all▯those▯who▯

took▯part▯in▯it.▯
▯

▯
[Signed]▯
Mr.▯DIEGO▯ARIAS▯GAVIRIA▯
Delegated▯Procurator▯

▯
[Signed]▯
VF▯Sgt▯GUSTAVO▯MEJÍA▯BÁEZ▯

ARECI▯Spraying▯Coordinator▯
▯
▯
[Signed]▯

LUIS▯FERNANDO▯ARISTIZÁBAL▯TAMAYO▯
Spraying▯Operation▯Commander▯
▯
▯

▯▯
▯

634 Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
SPRAY▯AIR▯BASE▯–▯LARANDIA▯

▯
▯
▯

MINUTE▯ NO.▯ 066/ ▯ ▯▯ NON▯SPRAYING▯ OF▯ COCA▯ ILLICIT▯ CROPS▯ IN▯ THE▯ JURISDICTION▯ OF▯ THE▯
PROVINCES▯CAQUETA▯AND▯PUTUMAYO▯
▯
▯

In▯Larandia▯(Caquetá)▯on▯December▯1,▯2004,▯the▯staff▯participating▯in▯the▯Eradication▯of▯
Illicit▯Coca▯Crops▯in▯Jurisdiction▯of▯the▯Departments▯of▯Caquetá▯and▯Putumayo▯met▯at▯the▯
premises▯of▯the▯Spray▯Air▯Base▯of▯Larandia,▯in▯order▯to▯put▯on▯record▯that▯spraying▯of▯illicit▯

crops▯could▯not▯be▯conducted▯due▯to▯bad▯weather▯conditions.▯
▯

▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯signed▯by▯those▯who▯took▯part▯in▯
it.▯

▯
[Signed]▯
▯Mrs.▯AMPARO▯CUELLAR▯QUIMBAYA▯

Criminal▯Judicial▯Procurator▯96▯–▯II▯
▯
[Signed]▯

Capt.▯AUGUSTO▯AMADOR▯VILLEGAS▯
COMMANDER▯LARANDIA▯MISSION▯

▯
▯
▯
▯▯

▯

635Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
SPRAY▯AIR▯BASE▯–▯VILLA▯GARZON▯PUTUMAYO▯

▯
▯
▯

▯
MINUTE▯ NO.▯ 028/ ▯ ▯▯ NON▯SPRAYING▯ OF▯ COCA▯ ILLICIT▯ CROPS▯ IN▯ THE▯ JURISDICTION▯ OF▯ THE▯
PROVINCE▯OF▯PUTUMAYO▯
▯

▯
In▯Villa▯Garzón,▯on▯December▯1,▯2004,▯staff▯participating▯in▯the▯Eradication▯of▯Illicit▯Coca▯
Crops▯met▯at▯the▯administrative▯premises▯of▯the▯Spray▯Air▯Base▯of▯Villa▯Garzón.▯

▯
▯
NO▯AERIAL▯SPRAYING▯WAS▯CONDUCTED▯DUE▯TO:▯bad▯weather▯conditions▯in▯the▯zone.▯

▯
▯

▯
[Signed]▯▯
Mr.▯CAMILO▯GUERRERO▯

Regional▯Ombudsman▯Villa▯Garzón▯
▯
[Signed]▯

Major▯HECTOR▯MONTENEGRO▯MONTENEGRO▯
Commander▯Spraying▯Operation▯
▯

▯
▯▯
▯

636 Annex 18

▯

▯
▯
DIRECTORATE▯OF▯ANTI▯NARCOTICS▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯

AERIAL▯SPRAYING▯▯BASE▯–▯TUMACO▯
▯
▯

▯
MINUTE▯NO.▯153/ ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯CROPS▯IN▯THE▯JURISDICTION▯OF▯THE▯
PROVINCE▯OF▯NARIÑO▯
▯

▯
In▯Tumaco,▯Nariño,▯on▯May▯7,▯2004,▯the▯air▯mission▯staff▯met▯at▯the▯administrative▯offices▯
of▯the▯Tumaco,▯in▯order▯to▯proceed▯with▯the▯aerial▯spraying▯of▯illicit▯crops.▯▯oPerations▯

could▯not▯be▯conducted▯due▯to▯the▯transfer▯of▯the▯Base.▯
▯

▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯▯Record▯is▯read▯and▯signed▯for▯all▯those▯who▯
took▯part▯in▯it.▯

▯
▯
Mr.▯CESAR▯JAVIER▯CASTRO▯QUIROZ▯

Municipal▯Ombudsman▯
(Did▯not▯attend)▯
▯

▯
[Signed]▯
MY▯LUIS▯ALBERTO▯CARDOZO▯BERNAL▯CARDOZO▯
Spraying▯Operation▯Commander▯–▯Tumaco▯

▯
▯
▯
▯▯

▯

637Annex 18

▯
▯
▯

ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
SPRAY▯AIR▯BASE▯–▯LARANDIA▯
▯

▯
▯
MINUTE▯ NO.▯ 073/ ▯ ▯▯ NON▯SPRAYING▯ OF▯ COCA▯ ILLICIT▯ CROPS▯ IN▯ THE▯ JURISDICTION▯ OF▯ THE▯
PROVINCE▯OF▯PUTUMAYO▯

▯
▯
In▯Larandia,▯Caquetá,▯on▯April▯13,▯2004,▯the▯air▯mission▯staff▯met▯at▯the▯administrative▯
premises▯of▯the▯Spray▯Air▯Base▯of▯Larandia▯in▯order▯to▯conduct▯spraying▯of▯coca▯illicit▯crops.▯

Activities▯could▯not▯be▯conducted▯due▯to▯BAD▯WEATHER▯CONDITIONS▯IN▯THE▯AREA.▯
▯

▯
▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯Minute▯is▯read▯and▯signed▯by▯those▯who▯took▯

part▯in▯it.▯
▯
▯

[Signed]▯
Maj.▯JAVIER▯PERDOMO▯RAMÍREZ▯
Commander▯Spraying▯Air▯Mission▯

▯
▯
[Signed]▯

ORESTES▯OÑOTE▯RIVERO▯
Criminal▯Judicial▯Procurator▯97▯

Representative▯of▯the▯Public▯Ministry▯
▯
▯
▯

▯
▯▯
▯

638 Annex 18

▯
▯
▯

ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
AERIAL▯SPRAYING▯▯BASE▯–▯TUMACO▯
▯

▯
▯
MINUTE▯NO.▯108/ ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯CROPS▯IN▯THE▯JURISDICTION▯OF▯THE▯
PROVINCE▯OF▯NARIÑO▯

▯
▯
In▯ Tumaco,▯ (Nariño),▯ on▯ March▯ 23,▯ 2004,▯ Major▯ WILLIAM▯ ALBERTO▯ ORTÍZ▯ISAZA,▯
Commander▯Spraying▯Mission;▯Capt▯CARLOS▯ALFREDO▯CURREA▯BARRERA,▯Police▯Pilot,▯Mr.▯

DIEGO▯ARIAS▯GAVIRIA,▯Delegated▯Procurator,▯met▯at▯the▯premises▯of▯the▯Spray▯Air▯Base▯of▯
Tumaco▯in▯order▯to▯proceed▯with▯the▯aerial▯spraying▯of▯illicit▯crops.▯Operations▯could▯not▯

be▯conducted▯due▯to▯bad▯weather▯conditions▯in▯the▯zone.▯
▯
▯

▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯read▯and▯signed▯by▯those▯who▯
took▯part▯in▯it.▯

▯
▯
▯

[Signed]▯
▯Mr.▯DIEGO▯ARIAS▯GAVIRIA▯
Delegated▯Procurator▯

▯
[Signed]▯

Capt▯CARLOS▯ALFREDO▯CURREA▯BARRERA▯
Pilot▯National▯Police▯
▯
[Signed] ▯

Maj.▯WILLIAM▯ALBERTO▯ORTIZ▯IZASA▯
Commander▯Spraying▯Operation▯Tumaco ▯
▯

▯
▯▯
▯

639Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
AERIAL▯SPRAYING▯BASE▯–▯TUMACO▯
▯

▯
▯
MINUTE▯NO.▯067 ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯CROPS▯IN▯THE▯JURISDICTION▯OF▯THE▯
PROVINCE▯OF▯NARIÑO▯

▯
▯
In▯Tumaco,▯(Nariño),▯▯on▯March▯12,▯2005,▯staff▯taking▯part▯in▯the▯Eradication▯of▯Coca▯Illicit▯

Crops▯in▯jurisdiction▯of▯the▯Department▯of▯Nariño▯met▯at▯the▯premises▯of▯the▯Spray▯Air▯
Base▯of▯Tumaco▯the,▯to▯put▯on▯record▯that▯no▯spraying▯activities▯of▯illicit▯coca▯crops▯was▯▯
conducted▯due▯to▯rain▯the▯work▯area.▯

▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯read▯and▯signed▯by▯those▯who▯
took▯part▯in▯it.▯

▯
▯
▯

▯
[Signed]▯▯

Mr.▯DIEGO▯ARIAS▯GAVIRIA▯
Judicial▯Prosecutor▯282,▯Criminal▯Affairs▯
▯

▯
▯
[Signed]▯

Major▯LUIS▯ANTONIO▯BARRAGAN▯SALGUERO▯
Spraying▯Operation▯Commander▯▯Tumaco▯▯
▯
▯

▯
▯▯
▯

640 Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
AERIAL▯SPRAYING▯BASE▯–▯TUMACO▯NARIÑO▯

▯
▯
▯

MINUTE▯NO.▯074/ ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯CROPS▯IN▯THE▯JURISDICTION▯OF▯THE▯
PROVINCE▯OF▯NARIÑO▯
▯
▯

In▯Tumaco,▯(Nariño),▯on▯March▯19,▯2005,▯the▯staff▯taking▯part▯in▯the▯Eradication▯of▯Illicit▯▯
Coca▯Leaf▯Crops▯met▯at▯the▯Spray▯Aerial▯Spraying▯Base▯of▯Tumaco.▯
▯

NO▯SPRAYING▯ACTIVITIES▯WERE▯CONDUCTED▯DUE▯TO▯BAD▯WEATHER▯CONDITIONS▯IN▯THE▯
AREA.▯
▯

▯
▯

Representative▯of▯the▯Public▯Ministry▯
▯
[Signed]▯

▯Ms.▯ANGELA▯ROSA▯MONTOYA▯DUQUE▯
Regional▯Ombudsman▯–▯Tumaco▯
▯

[Signed]▯
Major▯JAVIER▯PERDOMO▯RAMÍREZ▯

Spraying▯Operation▯Commander▯▯
▯
▯
▯

▯▯
▯

641Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
SPRAY▯AIR▯BASE▯–▯VILLA▯GARZON▯
▯

▯
▯
MINUTE▯ NO.▯ 056/ ▯ ▯▯ NON▯SPRAYING▯ OF▯ COCA▯ ILLICIT▯ CROPS▯ WITH▯ GLYPHOSATE▯ IN▯ THE▯
JURISDICTION▯OF▯THE▯PROVINCE▯OF▯PUTUMAYO▯

▯
▯
In▯ Villagarzón,▯ on▯ October▯ 3,▯ 2006,▯ Maj.▯ LUIS▯ FERNANDO▯ ARISTIZÁBAL▯TAMAYO,▯

Commander▯ of▯ Spraying▯ Operations▯ and▯ Mr.▯ CAMILO▯ GUERRERO▯BETANCOURT,▯
representative▯ of▯ the▯ Public▯ Ministry▯ met▯ at▯ the▯ premises▯ of▯ the▯ Spray▯ Air▯ Base▯ of▯
Villagarzón▯▯in▯order▯put▯on▯record▯that▯spraying▯of▯illicit▯crops▯could▯not▯be▯conducted▯due▯

to▯BAD▯WEATHER▯CONDITIONS.▯
▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯signed▯by▯those▯who▯took▯part▯in▯

it.▯
▯
▯

▯
▯
[Signed]▯

Mr.▯CAMILO▯GUERRERO▯BETANCOURT▯
Regional▯Ombudsman▯
▯

[Signed]▯
Maj.▯LUIS▯FERNANDO▯ARISTIZÁBAL▯TAMAYO▯

Commander▯Spraying▯Operations▯
▯
▯
▯

▯▯
▯

642 Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
AERIAL▯SPRAYING▯BASE▯–▯TUMACO▯NARIÑO▯

▯
▯
▯

MINUTE▯NO.▯113/ ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯▯CROPS▯IN▯THE▯JURISDICTION▯OF▯THE▯
PROVINCE▯OF▯NARIÑO▯
▯
▯

At▯ the▯ Spray▯ Base▯ of▯ Tumaco,▯ Nariño,▯ on▯ March▯ 08,▯ 2006,▯ the▯ Spraying▯ Operation▯
Commander,▯Mr.▯DIEGO▯ARIAS▯GAVIRIA,▯representative▯of▯the▯Public▯Ministry▯and▯MAJ.▯
LUIS▯FERNANDO▯ARISTIZÁBAL▯TAMAYO,▯Commander▯Spray▯Operation▯met▯in▯order▯to▯put▯

on▯ record▯ that▯ it▯ was▯ not▯ possible▯ to▯ conduct▯ spraying▯ activities▯ due▯ to▯ bad▯ weather▯
conditions▯in▯the▯zones▯to▯be▯sprayed.▯
▯

There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯signed▯by▯all▯those▯who▯took▯part▯
in▯it.▯

▯
▯
▯

(Signed)▯
Mr.▯DIEGO▯ARIAS▯GAVIRIA▯
Judicial▯Procurator▯282▯▯

▯
▯
▯
(Signed)▯▯

Major▯LUIS▯ANTONIO▯BARRAGÁN▯SALGUEROL▯
Spraying▯Operation▯Commander▯–▯Tumaco▯
▯
▯

▯
▯▯
▯

643Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
AERIAL▯SPRAYING▯BASE▯–▯TUMACO▯NARIÑO▯

▯
▯
▯

MINUTE▯NO.▯182/ ▯▯▯NON▯SPRAYING▯OF▯ILLICIT▯COCA▯LEAF▯▯CROPS▯IN▯THE▯JURISDICTION▯OF▯THE▯
PROVINCE▯OF▯NARIÑO▯
▯
▯

At▯ the▯ Spray▯ Base▯ of▯ Tumaco,▯ Nariño,▯ ▯ on▯ May▯ 16,▯ 2006,▯ the▯ Spraying▯ Operation▯
Commander,▯MAJ.▯LUIS▯FERNANDO▯ARISTIZÁBAL▯TAMAYO▯and▯Mr.▯DIEGO▯ARIAS▯GAVIRIA,▯
representative▯ of▯ the▯ Public▯ Ministry▯ ▯ met▯ in▯ order▯ to▯ put▯ on▯ record▯ that▯ it▯ was▯ not▯

possible▯to▯conduct▯spraying▯activities▯due▯to▯bad▯weather▯conditions▯in▯the▯zones▯to▯be▯
sprayed.▯
▯

There▯being▯no▯other▯matter▯to▯deal▯with,▯this▯Minute▯is▯signed▯by▯all▯those▯who▯took▯part▯
in▯it.▯

▯
▯
▯

(Signed)▯
Mr.▯DIEGO▯ARIAS▯GAVIRIA▯
Judicial▯Procurator▯I▯▯

▯
▯
▯
(Signed)▯▯

Major▯LUIS▯ANTONIO▯BARRAGÁN▯SALGUEROL▯
Spraying▯Operation▯Commander▯–▯Tumaco▯
▯
▯

▯
▯▯
▯

644 Annex 18

▯
▯

▯
ANTI▯▯NARCOTICS▯DIRECTION▯NATIONAL▯POLICE▯
ILLICIT▯CROP▯ERADICATION▯AREA▯
SPRAY▯AIR▯BASE▯–▯VILLA▯GARZON▯PUTUMAYO▯
▯

▯
▯
▯
MINUTE▯ NO.▯ 039/ ▯ ▯▯ NON▯SPRAYING▯ OF▯ COCA▯ ILLICIT▯ CROPS▯ WITH▯ GLYPHOSATE▯ IN▯ THE▯

JURISDICTION▯OF▯THE▯PROVINCE▯OF▯PUTUMAYO▯
▯
▯
In▯ Villagarzón,▯ on▯ September▯ 16,▯ 2006,▯ Capt.▯ EDISO▯ ARMANDO▯ RUBIANO▯BELTRÁN,▯

Commander▯ of▯ Spraying▯ Operations▯ and▯ Mr.▯ CAILO▯ GUERRERO▯BETANCOURT,▯
representative▯ of▯ the▯ Public▯ Ministry▯ met▯ at▯ the▯ premises▯ of▯ the▯ Spray▯ Air▯ Base▯ of▯

Villagarzón▯in▯order▯to▯put▯on▯record▯that▯spraying▯activities▯could▯not▯be▯conducted▯due▯
to▯WEATHER▯FACTORS▯IN▯THE▯AREA▯TO▯BE▯SPRAYED.▯
▯

▯
There▯being▯no▯other▯matters▯to▯deal▯with,▯this▯Minute▯is▯signed▯by▯those▯who▯took▯part▯in▯
it.▯

▯
▯
▯

[Signed]▯▯
Mr.▯CAMILO▯GUERRERO▯BETNCOURT▯
Regional▯Ombudsman▯▯

▯
▯

[Signed]▯
Capt.▯EDISON▯ARMANDO▯RUBIANO▯BELTRÁN▯
Commander▯Spraying▯Operation▯
▯

▯
▯▯
▯

CR NOTE: PAGE 59 BLANK IN THE ORIGINAL

645Annex 18

IV. SPRAYING DATA AND WITNESS STATEMENTS

CONFRONTED

ANALYSIS METHOD

Based on the description provided by each witness in his or her statement, the

relevant community or communities in Ecuador where the witness lived at the time
of alleged spraying were determined. As accurately as possible, given the
imprecise statements of years from some witnesses, the year or years a given
witness claims to have been affected by spraying were also noted.

The spray events (spray lines), from the Department of State data, for each
year/witness location combination were then overlaid onto a map of the Colombia-
Ecuador border region in a standard Universal Transverse Mercator Projection
(zone 17 for the Río Mataje area and zone 18 for the Río San Miguel area). The
map was centered near the Ecuadorian community location specified by the
witness.

Using the measurement tools in ESRI’s ArcGIS software, and a heads-up visual
proximity assessment, the spray line closest to the specific community for the
specific year was identified. More than one spray line was selected when several
were near the same distance away.

Once the closest spray line to the witness’s community had been determined, two
distances were measured.

x First, the straight-line distance (in meters) was measured from the closest

end of the closest spray line to the center of the Ecuadorian community as
identified by the witness.

x A second distance was measured from the closest end of the closest spray
line to the point along the Ecuadorian bank of the border river (either the Río
San Miguel or the Río Mataje) that intersected the straight line in part “a”

above.

If there were additional details about the location of the witness at the time of
alleged spraying, as distinct from a location at the center of the community, these
details were incorporated into measurements.

x There is an additional measurement for some locations, for instance, when
a statement such as “I have lived in San Francisco 2, province of
Sucumbíos, about two kilometers from the border” is found.

x For cases where the witness claimed a house location near the river, a
closest-case scenario was used to measure the distance from the closest

646 Annex 18

spray line to the community directly to the river (the line would then not be
along the straight line from the closest spray line to the community center as
described above).

For cases where the only spray lines for the location and year being evaluated are
not directly across from the community or have an interceding area of land on the
Ecuador side of the border between the spray line and the general area of the
community, the spray lines are not considered relevant and no measurements

were made.

647Annex 18

0°20'N 0°15'N

,,0

Scale: 1:100
theSrpivraeyr iasrtonmal boundarynna3tiK

SpraIntenaotridoenrarlibvProjection: UTM zone 18; Datum: WGS-84

0 1 2 3m k4 5

COLOMBIA

76°55'W 76°55'W
DisDtai(ctnteuStathnaable(u))a:d2ia7nmbank on the border river: 2062 m

P
P !

Salinas (2)

RÍO SAN MIGUEL
ECUADOR

P
!

Salinas (1)

77°0'W 77°0'W

COLOMBIA

Salinas, Spray Lines in 2000 (Witnesses 1-2-3-6-7) (locat(second▯location▯from▯Ecuador▯1:50000▯Topographic▯Map)▯Map)

ECUADOR
DisDtai(catnteutatlhaaEl(1u1)a:)dia0nbank on the border river: 3890 m
Figure 1 PACIFICAN
0°20'N 0°15'N SalinaSalinas▯(2)▯

648 Annex 18

0
▯▯2▯3▯6▯7)

▯Witnesses
2000
IN
▯
▯1)

▯ALINAS
▯O

(witnesses▯1▯2▯3▯6▯7) ▯INE

SPRAY Attribute▯Table▯2
Attribute▯Table▯1 ▯

▯
▯LOSEST
▯HE ▯ver
OF
Salinas,▯2000 ▯
Metadata▯of▯the▯closest▯spray▯line
▯ABLE
▯ltitude

Line
ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SALINASA▯TTRIB20TE0T▯BiLesFsTs▯▯2L3▯E▯S7T)SPRAY LINE TO SALINAS (1) IN 2000(Witnesses 1▯2▯3▯6▯7)

MILES/HOUR Ground▯Level▯(Metres) 26▯September▯200tres)
Spray▯Line▯Altitude▯over▯ Spprray Line Altitude over
▯

T ▯ltitude

▯ADDED▯ATTRIBUTES ▯ADGrDrounndd Altitude
▯Grover▯MSL▯(Metres) ▯ over▯MSL▯(Metres)
▯

Altitude
▯
335 281 36554 299 66
▯ine
3813 002721 12:59:06.39 1,100 ▯39,59 19544,22200 003600 131:44:19.205 1,2001 837,888 0185,8▯210 11260kda1c 91,217502,9771,2000011
OBJECTID LINE_ID TIME ALTITUDE XTRACK OBPECTID HELANIEID S SPIRAEY_RATAELTUDE SXTRUASCEKD DSTPHID HEAACIINGASESPRAYL_ERNAGTTEH DM
PARAMETERSpray▯Line▯Altitude▯9 FEE PARAMETESpprrayLine Altitude)4 FEET MILES/HOUR

649Annex 18

0°20'N NN 0°15'

76°55'W 76°55'W
!
!! !

San Francisco I
Sccaallee:: 11::110000,,000000
theSrpivraeyr iasrtonmal boundarynna3tiK

P SprayynBeoNote:river
International bounProjection: UTM zone 18; Datum: WGS-84

Virgen del Cisne
! 0 1 2 3 m 4k 5
P
!!

Salinas (2)

! Salinas (1)
COLOMBIA
P P

77°0'W 77°0'W

RÍO SAN MIGUEL

ECUADOR
Diista(catnoeutatinabEl(u4)do5ranmbank on the border river: 2750 m

77°5'W 77°5'W

COLOMBIA
(locat(second▯location▯from▯Ecuador▯1:50000▯Topographic▯Map)▯Map)
Salinas, Spray Lines in 2001 (Witnesses 1-2-3-4-5)
Distai(ctnteuttathaaEl(u3)a)orian bank on the border river: 3131 m

ECUADOR

Figure 2
PACIFIC SalinaSalinas▯(2)▯
0°20'N NN 0°15'

650 Annex 18

Coca
_
T65 Coca
65

_ines
sl
_

200011 sl lines sh

a041#acc

65
T65

Cocaa

0101

2001▯(Witnesses▯1▯2▯3▯6▯7) 2001▯(Witnesses▯1▯2▯3▯6▯7)
a041#acc

1
▯

(witnesses▯1▯2▯3▯4▯5) 11

11
Attribute▯Table▯3 Attribute▯Table▯4
800
1 800

Salinas,Metadata▯of▯the▯closest▯spray▯line
2

9 600

ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SALIATS▯1I▯NT▯ E▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SALINAS▯(2)▯IN▯

,20 Ground▯Level▯(Metres)
Spray▯Line▯Altitude▯over▯
165 120

502 57

,00
1 200

▯ADDED▯ATTRIBUTES ▯ADDED▯ATTRIBUTES
.0 ▯Groover▯MSL▯(Metres)
:2
:6
07 36 22 30

002771

365 295 365 70 286 79

13644 14039 001711 12:18:52.05 1,200 215,84 156,040 11,700 1 0
OBJECTID LINE_ID TIME ALTITUDE XTRACK OBJECPTHID LINEEAING STISPERAYRALTTIEDEOPXTSRVKSED DMFPHSTNID HEAADSINASMSPRAYLERGTTEHMOOPNTSHV SU
PARAMETERS Spray▯Line▯Altitude▯) FEET PARILESE/RSpray▯Line▯Altitude▯ ▯Ground▯Altitude▯ Spray▯Line▯Altitude▯over▯y▯2001

651Annex 18

0°15'N

Sccaallee:: 11::110000,,000000

P !! yine theSrpivraeyr iasronmal boundaryrnna2tiK
ra
Salinas (2) Sy International boundary
Projection: UTM zone 18; Datum: WGS-84

0 1 2 3 m 4k 5
P

P !

Salinas (1)

77°0'W 77°0'W

RÍO SAN MIGUEL
COLOMBIA

ECUADOR

77°5'W 77°5'W

Dista(ActtneutatTnaEl(u6)a:))ia4nbank on the border river: 1760 m

Dista(catnteutathaaEl(u5)a:)dia8nbank on the border river: 2498 m

COLOMBIA
Salinas, Spray Lines in 2002 (Witnesses 2-3) (loca(second▯location▯from▯Ecuador▯1:50000▯Topographic▯Map)c▯Map)

Figure 3 OCEAN ECUAADOORR
PACIFIC SalinSalinas▯(2)▯
0°15'N

652 Annex 18

65_Coca

T▯65 Coca T▯65_Coca

H AI0CRAFT CROP A_C_CROP H AIRCRAFT CROP A_C_CROP

I082EZBC 7,8 0209 5

174,5

(witnesses▯2▯3)

Attribute▯Table▯5 Attribute▯Table▯6

Salinas,▯2002

Metadata▯of▯the▯closest▯spray▯line

ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SALINAS▯(1)ItnTeEes▯L2E▯▯3O)F▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SALINAS▯(2)▯IN▯2002▯(Witnesses▯2▯3)
48

0.28979779 ▯76.98222492 1097 0,770 0,1 25,6 4,70
0

12:15:30:7 Spray▯Line▯Altitude▯over▯ Spray▯Line▯Altitude▯over▯

▯TTRIBUTES
2855

▯ADDED▯ATTRIBUTES ▯DDDDEED ATTRIBUTES
▯Grover▯MSL▯(Metres) ▯Groover▯MSL▯(Metres)

I082EZBC.B99 301▯2 Right 3

4
3333 318 282 36

21443 91 23513 2994 I082KBCC.B99 301▯1 Right 54 18:40:28:00.28433029 ▯76.95826520
OBJECTID SEG FILE_NAME MISSION SIDE LINE STAORBTTEDTLASTEIGTUFLLENIAUEE ALTIIIOEN DSOIPD_TEIMSFLT_ENEGTLATITEETDLOSNEEITDUDE VA
PARAMETERSpray▯Line▯Altitude▯▯2002 PA1R2A:1MSpray▯Line▯Altitude▯)2002 FEET 13:40 MILES/HOUR

653Annex 18

20'N 'N 0°15

kk
55

22 Scale: 1:100,000

theSrpivrearyisartehaewInittheirnna2tioKnmal boundary
11
SprayInternaNote:l boundaProjection: UTM zone 18; Datum: WGS-84

76°40'W 00 76°40'W

DisDtarve(rettb5utamTEaclee7oria:n6b2a0non the border

COLOMBIA

RÍO SAN MIGUEL

P P
76°45'W 76°45'W
Corazon Orense

ECUADOR

COLOMBIA
Coraz76°50'Wse, Spray Lines in 2001 (Witness 9) 76°50'W

DisDtartv(rcttib3utmTEacOereo)ra:n6b0a8n5on the border ECUADOR
Figure 4
PACIFICN
2200'N° ''N0°15

654 Annex 18

▯)

(Witness
▯
2001
▯

▯RENSE

(witness▯9) CORAZON
▯
▯O

▯INE

▯PRAY

Attribute▯TablCLOSEST Attribute▯Table▯8
▯
▯

▯ECOND ▯ver

▯HE
Corazón▯Orense,▯2001 ▯F
Metadata▯of▯the▯closest▯spray▯lines
Altitude
▯ABLE ▯

▯ine
ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯CORAZON▯ORENSE▯IN▯2001▯(Witness▯9)

Spray▯Line▯Altitude▯over▯ ATTRIBUTTE TABLE OF TSprrayy Line Altitude overNE TO CORAZON ORENSE 2001 (Witness 9)

▯

▯ltitude

▯ADDED▯ATTRIBUTES ▯ADGrrouundd Altitude
▯Grover▯MSL▯(Metres) ▯ over▯MSL▯(Metres)
▯

▯ltitude

335 273 335 62 272 63
▯ine

OBJECTID2 LINE_ID52 TIME9:31ALTITUDE XTRACK7,49OBJPEHCTIHLEIANDG S SIREY_RAATLETITDUOTRAUCSKED DFMSPTHNIHAESANGMSE SPREY_GRTAHTONP
PARAMETERSpray▯Line▯Altitude▯ FEET PAIRASETOSprrayyLine Altitude FEET MILES/HOUR 18▯January▯2001

655Annex 18

0°15'N

!
0m

: 271
76°45'Wio 76°45'W
n ! Puerto Escondido
P
sco Corazon Orense
E
rt
ue

oP
t
ne
t
s a ce o ue o sco d do 0
DistaiDcstv(CttibutemEaruede:ran40amnk on the border
P

RÍO SAN MIGUEL

ECUADOR

dr
or
b
e
th

kon
an
-4 b

in
76°50'W dr 76°50'W

cua
E
e
Scale: 1:50,000 th
li t
theSrpivrearyisarnal boundCOLOMBIAa1tiKom COLOMBIA
pray ance
Corazón Orense – Puerto EscondidPrroojjUTM zzoonDaam:WGGS 84esses 8-9-20-21-22-23)
DistaDtsrtn(tttb9tttoEiuliDarncn:oortzórtohrenosr:dro:29m2k5 m th b d

ECUADOR
m0 1 k 2 3 PACIFIC
Figure 5
0°15'N

656 Annex 18

H AIRCRAFT CROP A_C_CROP H AIRCRAFT CROP A_C_CROP H AIRCRAFT CROP A_C_CROP

10 85 OV▯10 Coca OV▯10_Coca

,493 0210 85 OV▯10 Coca OV▯10_Coca
232,761 0210 85 OV▯10 Coca OV▯10_Coca

▯3)
▯2
21
20
▯
8

nesses▯

(Witnesses▯8▯9▯20▯21▯22▯23) ▯Wit 8 9 20 21 22 23)

▯002
2002▯(Witnesses▯8▯9▯20▯21▯22▯23) ▯N

ESCONDIDO
(witnesses▯8▯9▯20▯21▯22▯23) ▯

▯▯▯RTO

▯RENSE

▯ORAZON
▯O
Attribute▯Table▯9 Attribute▯Table▯10 Attribute▯Table▯11
▯INE

SPRAY
▯

▯LOSEST
Metadata▯of▯the▯closest▯spray▯line
▯HIRD

▯HE
▯F

▯ABLE

Ground▯Level▯(Metres) Ground▯Level▯(Metres) Ground▯Level▯(Metres)
ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯CORAZON▯ORENSE▯▯▯PUERTO▯ESCONDIDO▯IN▯ude▯over▯ Spray▯Line▯Altitude▯over▯
ATTTRIUTTEE TABLE OF THE THIRDCLOSESTSPRAY LINE TO CORAZON ORENSE PUERTO ESCONDIDO IN 2002
ATTRIBUTE▯TABLE▯OF▯THE▯SECOND▯CLOSEST▯SPRAY▯LINE▯TO▯CORAZON▯ORENSE▯▯▯PUERTO▯ESCONDIDO▯IN▯2002▯

Corazón▯Orense▯– Puerto▯Escondido,▯2002

▯ADDED▯ATTRIBUTES ▯ADDED▯ATTRIBUTES ▯ADDED▯ATTRIBUTES
▯Ground▯Altitude▯ ▯Ground▯Altitude▯ ▯Ground▯Altitude▯
over▯MSL▯(Metres) over▯MSL▯(Metres) over▯MSL▯(Metres)

323 280 313 43 265 316 48 274

1084 399 J102Q7AC.B99 ▯▯▯▯▯302▯1 Right 1105806 ▯17:4480:▯▯▯0C.99558▯8▯▯▯▯30▯▯78ig0h21t703▯40:064018:52J:1070,4829Q▯3072▯6▯▯▯1t10691,515212:,84980:0470,8▯9▯▯0▯2▯▯,▯06.020603,6403066
OBJECTIPARAMETERSpray▯Line▯Altitude▯▯2002DE OLBIJEECTPARAMETERSpray▯Line▯Altitude▯02NGITSDEEOBCTLPARAMETEFSpray▯Line▯Altitude▯▯2002SIUETDEELINEALET_EMILEFSE/E1HT2O:4U8RFLT_LLOELG

657Annex 18

0°20'N 0°15'N

kk
55

76°40'W 76°40'W
44

22 Scale: 1:100,000
theSrpivrearyisartehaewInittheirnna5tioKnmal boundary

SpraInternational boun1Projection: UTM zone 18; Datum: WGS-84

DisDta567(ttrbortcTaadlren3)ea:n1on0the border river:

P
! Corazon Orense

76°45'W 76°45'W

RÍO SAN MIGUEL

COLOMBIA P

ECUADOR

Dista(cetneuttohazóncO1r)nsenPb2360omn the border river: 6460 m
76°50'W 76°50'W

COLOMBIA

Corazón Orense, Spray Lines in 2003 (Witness 8)

ECUADOR

PACIFICN
Figure 6 0°20'N 0°15'N

658 Annex 18

_oca
▯5 5_Coca
TT65 Coca
73
Cooccaa CROP A_C_CROP
T

TT65

H AIRCRAFT CROP A_C_CROP HRCIRAF
50

03005

,29
4022 029

E233AADAC

,23
3 023

,
25

,00
1666 600

2003▯(Witness▯8)
700
11 700

(witness▯8) ,
▯2
13116 9

Table
, ▯
54

,70
0 770 Atttributte Table 12 Attribute▯Table▯13

10882

Corazón▯Orense,▯2003 .3405338
Metadata▯of▯the▯closest▯spray▯line5338
▯▯▯▯▯

ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯CORAZON▯ORENSE▯IN▯
ATTRIBUTE▯TABLE▯OF▯THE▯SECOND▯CLOSEST▯SPRAY▯LINE▯TO▯CORAZON▯ORENSE▯IN▯2003▯(Witness▯8)

0 30162120
▯▯▯▯▯▯

Ground▯Level▯(Metres) Ground▯Level▯(Metres)
Spray▯Line▯Altitude▯over▯ Spray▯Line▯Altitude▯over▯

▯3:36:35474

6077

Riihtt
1
▯
2899 1 ▯ADDED▯ATTRIBUTES ▯ADDED▯ATTRIBUTES
▯▯▯▯▯ ▯Ground▯Altitude▯ ▯Ground▯Altitude▯
over▯MSL▯(Metres) over▯MSL▯(Metres)
.99

E233AADAC B99

6944
328 288 322 40 276 46

122273 2993 286 G093ABBC.B99 290▯1 Right 347 11:18:06:50 0.32928509 ▯76.73853981 1060
OBJECTID SEG FILE_NAME MISSION SIDE LINE START_OTIJEECTID LATUDEFILE_NLAONEGITUMDIESALTSUEDELDOEPSTFALRTIMEE FLT_LLAETNITOTE LONGISTPEED AVLTOUMEE DAORPEAFLT_TILM
PARAMETESpray▯Line▯Altitude▯03 P1A36MESpray▯Line▯Altitude▯)003 FEET 11:18 MILES/HOUR FEET

659Annex 18

N 0°20' 0°15'N

Scale: 1:100,000

theSrpivrearyisartehaewInittheirnna2tioKnmal boundary
RÍO SAN MIGUEL
Spray lineNote:r riverProjection: UTM zone 18; Datum: WGS-84

0 1 2 3 m4 k 5

76°50'W 76°50'W

COLOMBIA

ECUADOR

Distaitc(cetteataFranciscis):iI:n03am0kon the border river: 1960 m
DistaDtcDtstta(tttecteisensI11I18:17nmhemborder river: 1817 m

76°55'W San Francisco II 76°55'W
!!
!!

San Francisco I
P P

, Spray Lines in 2000 (Witnesses 14-18-19)

COLOMBIA

77°0'W PACIFIC ECUADOR77°0'W

Figure 7 San Francisco I – II
N 0°20' 0°15'N

660 Annex 18

Coca T▯65 T▯65_Coca Coca

▯4▯18▯19)

▯Witnesses

▯000
▯N
YI
▯

▯1 l260kdac 152,977 0012 5

0 ▯RANCISCO
(witnesses▯14▯18▯19)
▯AN
▯O

▯INE
1 8 8
Attribute▯Table▯1SPRAY Attribute▯Table▯15
▯

0 ▯
▯LOSEST
▯ver
1
▯ECOND
Metadata▯of▯the▯closest▯s0ray▯line THE
3,60 ▯
544 ▯F ▯ltitude
San▯Francisco▯I▯– II,▯2000
0 ▯ABLE Line
▯

ATTRIBUTE▯TABLE▯OF▯THE▯CGround▯Level▯(Metres)SAN▯FRANCISCO▯I▯Y▯II▯IN▯20Ground▯Level▯(Metres)9)
Spray▯Line▯Altitude▯over▯ ATTRIBUTETABLEOF THESECONDCLOSESTSPRAY LINETOSAN FRANCISCO I Y II IN 2000(Witnesses 14▯18▯19)
▯

▯ltitude
2881

▯ADDED▯ATTRIBUTES ▯ADDED▯ATTRIBUTES
▯Grover▯MSL▯(Metres) ▯rrover▯MSL▯(Metres)
▯

Altitude
▯
3335 335 282 53
▯ine
3813 002721 12:59:06.39 1,100 ▯39,59 33194,20 002748 12:58:57.00 1,100 ▯81,45 177,280 3,560 1
OBJECTID LINE_ID TIME ALTITUDE XTRACK OBJM ECPID LNEEIDING TISERAY_ARLAEUDDEOPXSACUSED MDFPHSTNIDHEADIANCISASMPERAY_RALTEENGDTO
PARAMETESpray▯Line▯Altitude▯ FEET PAMAILEESprray Line Altitude FEET MILES/HOUR 26▯September▯2000

661Annex 18

0°15'N

kk
55

Scale: 1:100,000
22
theSrpivrearyisartehaewInittheirnna2tioKnmal boundary

SpraInternational boundary
Projection: UTM zone 18; Datum: WGS-84

76°50'W 76°50'W

DisDtairvn(rtttb00tFmranbcisdo7rI:n4b8a8n0on the border

ECUADOR

P
P
COLOMBIA

RÍO SAN MIGUEL

76°55'W 76°55'W
P ! San Francisco II

, Spray Lines in 2001 (Witness11)

COLOMBIA

ECUADOR
DisDtarrv(rrt9ib5ueFTranclisdo6rI:n3b8a6non the border PACIFIC

Fig77°0'WSan Francisco II 0°15'N 77°0'W

662 Annex 18

_ROP

77 AC CROP

SOURRCEHM

LOG

AIRCRAFT

TYPE

SWAATH

MOONTH

LENGTHH

▯ine

spray ASCINAAME
▯

STNIDD
DFF
▯losest

USED
▯he
SV
▯f Attribute▯Table▯16 Attribute▯Table▯17
DOOP

RATE
_

San▯Francisco▯II,▯2001▯(Witness▯11)RATE
Me etaadaatta of tSe closest spray line

ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SAN▯FRANCISCO▯II▯▯IN▯2001▯(Witness▯11)
HEADDNGN Spray▯Line▯Altitude▯over▯
ATTRIBUTE▯TABLE▯OF▯THE▯SECOND▯CLOSEST▯SPRAY▯LINE▯TO▯SAN▯FRANCISCO▯II▯IN▯2001▯(Witness▯11)

MPPH

XTRACK

▯ADDED▯ATTRIBUTES) ▯ADDED▯ATTRIBUTES
ALTIUDDE
▯Ground▯Altitude▯over▯

TIME

ID
_

LLNE ID
304 274 365 30 287

FIDD8959 003527 13:24:17.48 1,000 ▯9,94 82546,27001979,812:52:41.20,1,200A1137,11PH 163,280D▯1G1,730272kbac0,0000,001SED DF STNID
Spray▯Line▯Altitude▯ Spray▯Line▯Altitude▯ ▯Ground▯Altitude▯over▯ Spray▯Line▯Altitude▯over▯(Metres)
PARAMETERS 13:24 FEET PARALEEST/EHROSUR 12:52 FEET MILES/HOUR 27▯January▯2001

663Annex 18

0°20'N 0°15'N

P P

P
76°55'W COLOMBIA 76°55'W
! San Francisco La Condor
!

77°0'W 77°0'W

DistastaDct(ttttaureonciwc:4I:i5es4a2nkand t1h325r4d7r river: 547 m

RÍO SAN MIGUELCUADOR

DisDtatcstt(Sttteaueoncinc:48:i40m0amndk1o3thceatbis: riv6e7467 m

77°5'W 77°5'W

Scale: 1:100,000 COLOMBIA
theSrpivreayr iasnal boundaryheirnna1tiKom

San Francisco IISprayoliNote:r riverLines in 2002 (Witnesses 12-13-17)
Projection: UTM zone 18; Datum: WGS-84

ECUADOR
0 1 2 3 m 4 k 5
Figure 9 PACIFIC
0°20'N 0°15'N

664 Annex 18

H AIRCRAFT CROP A_C_CROP H AIRCRAFT CROP A_C_CROP

209 50 T▯65 Coca T▯65_Coca 09 50 T▯65 Coca T▯65_Coca

line
▯

▯pray

▯losest

the
▯ Attribute▯Table▯18 Attribute▯Table▯19
▯f

Me ettaddatta of the closest spray li▯eetres) ▯Metres)

ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SAN▯FRANCISCO▯II▯IN▯2002▯(Witnesses▯12▯13)
▯evel ▯evel
ATTRIBUTE▯TABLE▯OF▯THE▯SECOND▯CLOSEST▯SPRAY▯LINE▯TO▯SAN▯FRANCISCO▯II▯IN▯2002▯(Witnesses▯12▯13)

San▯Francisco▯II▯and▯La▯Condor,▯2002▯(Witnesses▯12▯▯ 13)
Spray▯Line▯Altitude▯over▯) Spray▯Line▯Altitude▯over▯)

(Metres) (Metres)
▯ ▯

▯SL ▯SL
▯ADDED▯ATTRIBUTES ▯ADDED▯ATTRIBUTES
▯Ground▯Altitude▯ ▯Ground▯Altitude▯
ovverMSL(Metres) oveerMSL(Metres)

▯Metres) ▯Metres)
324 279 322 45 279 43
▯SL ▯SL

OBJECTIDSEG528 FILE_NAME.BMISSION SIDE LISTIDRT_EGEM3FITLIET_UNLONIGSONE SIDANEESTDAORLTE_TIMELALEENGTH LEITUDESPEEADLTITUDVEOLU
PARAMESpray▯Line▯Altitude▯res) PARAMESpray▯Line▯Altitude▯2es) FEET 11:05

665Annex 18

0°20'N 0°15'N

Scale: 1:100,000

theSrpivrearInitthenal boundary

SpraInternational boundaProjection: UTM zone 18; Datum: WGS-84

0 1 2 m3 k4 5

76°50'W 76°50'W

Distairvn(rttib00tmraancis2o1rI:n6a55kmon the border

ECUADOR

P COLOMBIA

P
76°55'W RÍO SAN MIGUEL 76°55'W
!

San Francisco II

COLOMBIA

San Francisco II, Spray Lines in 2003 (Witnesses11-17)
77°0'W 77°0'W

Distairvn(rttib10tmuaancii2o0r):7n615onmthe border ECUADOR

Figure 10 PACIFIC

0°20'N 0°15'N

666 Annex 18

65_Coca

T▯65 Coca T▯65_Coca

H AIRCRAFT CROP A_C_CROP H AIRCRAFT CROP A_C_CROP

11)
▯

(Witness
▯
▯003(Witness 11)
2003▯(Witness▯11) II
▯

▯RANCISCO

▯AN
▯O
▯INE

▯PRAY

Attribute▯Table▯ Attribute▯Table▯21
▯LOSEST

▯ECOND
▯HE
▯F

▯Metres) ▯ABLE
San FranciMeoettaddaatta ooff thee ccllosseesstt spprrayy llinee
ATTRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯SAN▯FRANCISCO▯II▯IN▯
▯evel
ATTRBUTE TABLE OF ▯Line▯Altitude▯over▯RAY LINE TO SAN FRANCISCO II IN
y
ra
Spray▯Line▯Altitude▯over▯) py Ground▯Level▯(Metres)

▯Metres)

▯SL

▯AD▯Ground▯Altitude▯ ▯ADDED▯ATTRIBUTES
oveerMSL(Metres)

▯Metres)
356 293 345 63 296 49
MSL ▯Line▯Altitude▯ ▯Ground▯Altitude▯ S
▯ y
2701 730 G103JJDC.B99289▯1 Right 333 141:40142:3ra80 2901.29G4144535R173t 3805,771,1:300.226,1431 ▯763.839484171978,3010135
OBJECTIPARAMETSpray▯Line▯Altitude▯E LINE SOTBAIMPARA4:S0T4ERS▯M14▯July▯2003overFEET▯(Metres)10:02ETH LOEITUDESAETMILES/HOFUERET

667Annex 18

Santa Rosa de los Cofanes

Scale: 1:50,000

theSrpivrearyial boundaryittheirnna1t0ioKnm

CofnoRNote:errrviveer
RÍO SAN MIGUEL Projection: UTM zone 17; Datum: WGS-84

0 m1 k 2 3

77°10'0"W 77°10'0"W

COFAN RESERVE

ECUUAADDOORR

COOLLOMMB BIAA

PERU

COLOMBIA

l
ue
Reserva Cofàn Bermejo, Spray Lines in 2000 (Witnesses 26-27-29-31)
Mn
aS
oí
R ECUADOR
PACIFIC
Figure 11

668 Annex 18

Santa Rosa de los Cofanes

Scale: 1:50,000

theSrpivrearyial boundaryittheirnna1t0ioKnm

CofnoNote:serrrviveer
RÍO SAN MIGUEL Projection: UTM zone 17; Datum: WGS-84

0 m1 k 2 3

77°10'0"W 77°10'0"W

COFAN RESERVE

ECCUUAADDOORR

COOLLOOMMBBIIA

PERU

COLOMBIA

el
u
Reserva Cofàn Bermejo, Spray Lines in 2001 (Witnesses 26-27-29-3M)
n
S
íR
ECUADOR
PACIFIC
Figure 12

669Annex 18

52 0°

84 kmm
33

Scale: 1:50,000
11
theSrpivrearyisartehaewInittheirnna1tioKnmal boundary

SprayConoRNote:errrviveer
Sa!ta Rosa de los Cofanes Projection: UTM zone 17; Datum: WGS-84

RÍO SAN MIGUEEL

77°10'W 77°10'W

ECUADOR

DisAtattnrio thaebecuadorian bank on the border river: 393 m

COFAN RESERVE

PERU

COLOMBIA

Cofán Bermejo Reserve, Spray Lines in 2002 (Witnesses 26-27-29-31)

ECUADOR
PACIFIC
Figure 13
5'N0°2

670 Annex 18

▯65_Coca
85

H AIRCRAFT CROP A_C_CROP

(Witnesses▯26▯27▯29▯31)

▯
Attribute▯Table▯22
over
▯

Altitude
Me etaddaatta off thee clloseesst spprrayy linees

▯ine
METADATO▯SEGUNDA▯LINEA▯DE▯ASPERSION▯MAS▯CERCANA▯COFAN▯BERMEJO▯2002▯
Spray Line Altitude over
▯
Cofán Bermejo Reserve, 2002 (Witnesses 26-27-29-31)

▯ltitude

▯AD▯rEun▯dTTltBuUdeES
▯ over▯MSL▯(Metres)

▯ltitude

Line 423 362 61
▯
15196 358 I262A1BC.B99287▯3 Righ64 12:12:06:60.3758077▯77.20217691392 0,890 0,1 20,9 3,700
OBJECTIPARAMETERSy 26▯▯SEPTEMBER▯2002LINE START_12:12UDE LONGITUDEALTITUDE FEETFLT_TIME FLT_LENGTH OTE

671Annex 18

86
km
3

! 2

Santa Rosa de los Cofanes

Scale: 1:50,000
1
theSrpivrearyisaronmal boundaryrnna1tiK

SprayConoRrdeeserrrviveer
RÍO SAN MIGUEL Projection: UTM zone 17; Datum: WGS-84

77°10'W 77°10'W

COFAN RESERVE

ECUADOR

COLOMBIA PERU

COLOMBIA

l
ue
i
Cofán Bermejo Reserve, Spray Lines in 2003 (Witnesses 26-27-29-31) M
a
S
í ECUADOR
R

PACIFICN
Figure 14

672 Annex 18

0°20'N

87
kmm
33

EL 22
GU
Santa Rosa de los Cofanes

AN MI
OS GU
RÍ Scale: 1:50,000
11
theSrpivrearyisartehaewInittheirnna1tioKnmal boundary

SpryolnoRrNote:rrrviProjection: UTM zone 17; Datum: WGS-84

77°10'W 77°10'W

Distattnriothaebecuadorian bank on the border river: 439 m

COFFAN RESSERVEE

ECCUUA ADDOOR R

COLOMBIA

P
P PERU

COLOMBIA

l
u
gi
Mn
S
Cofán Bermejo, Spray Lines in 2004 (Witnesses 26-27-29-31) ío
R
DisAanrceuo thebecu4adorran bank on the bordeerrveerr3440 m

PACIFIC ECUADOR
Figure 15'W 77°15'W
0°20'N

673Annex 18

oca

RCRAFT AC_CROP CROP RCRAFT AC_CROP CROP

nes
li

spray
t

lses

e c

fth
Attribute▯Table▯23 Attribute▯Table▯24
a o
t
a
d
t
e

Mtdt h ft l t il

ATRIBUTE▯TABLE▯OF▯THE▯CLOSEST▯SPRAY▯LINE▯TO▯COFAN▯BERMEJO▯IN▯2004▯(Witnesses▯26▯27▯29▯31)
23
Cofan Bermejo, 2004 (Witnesses 26-27-29-31) ATTRIBUTE▯TABLE▯OF▯THE▯SECOND▯CLOSEST▯SPRAY▯LINE▯TO▯COFAN▯BERMEJO▯IN▯2004▯(Witnesses▯26▯27▯29▯31)

Ground▯Level▯(Metres) Spray▯Line▯Altitude▯over▯
Spray▯Line▯Altitude▯over▯

380

▯ADDED▯ATTRIBUTES ▯AD▯Ground▯Altitude▯
▯Grover▯MSL▯(Metres) over▯MSL▯(Metres)

429 396
403
817 4264 L244A1AC.B01 287▯1 Right15 ▯7:55:48:70.36581905 ▯77.22639118
947 4399 L244A1AC.B01 287▯1 Right 51 OBJECTID:3SEG7561FILE_NAME058MISSION SIDE LINE START_TILATITUDE,400
OBJECTID SEG FILE_NAME MISSION SIDE LINE START_TIMLPARAMETERSray▯Li24▯DECEMBER▯2004T_TIME FLT_LENGTHO07:55
PARAMETSpray▯Line▯Altitude▯▯2004 08:27 FEET

674 Annex 18

Santa Rosa de los Cofanes

Scale: 1:50,000

theSrpivrearyial boundaryittheirnna1t0ioKnm

CofnoNote:serrrviveer
RÍO SAN MIGUEL Projection: UTM zone 17; Datum: WGS-84

0 m1 k 2 3

77°10'0"W 77°10'0"W

COFAN RESERVE

ECCUUAADDOORR

COOLLOOMMBBIIA

PERU

COLOMBIA

el
u
Cofán Bermejo Reserve, Spray Lines in 2005 (Witnesses 26-27-29-3M)
n
S
íR
ECUADOR
PACIFIC
Figure 16

675Annex 18

0°20'N

90
kmm
33

! 22

Santa Rosa de los Cofanes

Scale: 1:50,000
11
theSrpivrearyisartonmal boundarynna2tiK

RÍO SAN MIGUEL CofanoRrdeeNote:viveer Projection: UTM zone 17; Datum: WGS-84

77°10'W 77°10'W

ECUADOR

COLOMBIA

PERU

COLOMBIA

l
u
ii
Cofán Bermejo, Spray Lines in 2006 (Witnesses 26-27-29-31) M
nn
S
oí
R ECUADOR

PACIFICN
Figure 17 0°20'N

676 Annex 18

91
33m

! 22

Santa Rosa de los Cofanes

Scale: 1:50,000
theSrpivrearyisonmal boundaryeirnna2tiK

Spry oBorder riverrvProjection: UTM zone 17; Datum: WGS-84
RÍO SAN MIGUEL

77°10'W 77°10'W

Distattnriothaeecu25dorian bank on the border river: 932 m

ECUADOR

COFAN RESERVE
P

PERU

COOL LOM MB BIIA

COLOMBIA

l
u
i
Cofán Bermejo Reserve, Spray Lines in 2007 (Witnesses 26-27-29-31) M
na
S
íR ECUADOR

PACIFIC
Figure 18

677Annex 18

GROUP

92
_ROPCoca Lobo
AC CROP

ARCRAFTT

SWATH

MONTH

ENGTHH

ARAA

VOUMME

SEED

OTE

_ENGTH
FT LENGTH

_IME
FT TIME

DOP

ATIUDDE Attribute▯Table▯25

ONNGTUDE

Me ettaddaatta ooff thee ccllosseesstt spprraayy line es

METADATO▯LINEA▯DE▯ASPERSION▯MAS▯CERCANA▯COFAN▯BERMEJO▯2007▯(Witnesses▯26▯27▯29▯31)

Cofan Bermejo, 2007 (Witnes_es 26-27-29-31)

SART TIME

LNEIN

SDEID

MIISONSIIO
Spray▯Line▯
Altitude▯over▯
2007 11:17 METERS MILES/HOUR
NAME
_
FFE NAME

▯ADDED▯ATTRIBUTES
SGG 367 49

FDIID 4257 A147&VAC.B99 287▯3 ▯▯▯▯▯1 21:17:48:90.38050949 ▯77.20436179416 1,100 0,76 64,023 4195,700
▯Ground▯Altitude▯
PARAMETERSover▯14▯JANUARY▯)

678 Annex 18

0°15'N

mkm
33

76°25'W 76°25'W

Scale: 1:50,000

theSrp11raeyr iasional boundaryirnn3atK

Spray lineBoNote:riverdary
Projection: UTM zone 18; Datum: WGS-84

RÍO SAN MIGUEL

ECUADOR

COLOMBIA

DisDtaAttnreutoatnaelecuardoria7n10ank on the border river 2406 m

76°30'W 76°30'W
P Ya!a Amarum

COLOMBIA

Yana Amarum, Spray Lines in 2002 (Witness 28)

PACIFIC ECUADOR

Figure 19
0°15'N

679Annex 18

H AIRCRAFT CROP A_C_CROP

,,3 0210 85 OV▯10 Coca OV▯10 Coca

J032YSCC 36
0

,,0
2

(Witness▯28)

,,0 202

,,1

8 1,, 1

,,0 0

Attribute▯Table▯26

Yana Amarum, 200METADATO▯LINEA▯DE▯ASPERSION▯MAS▯CERCANA▯YANA▯AMARUM▯2002▯
Me etaddaatta ooff thee cllosseestt spprrayy lineess

▯▯▯▯▯▯0.25738970 ▯▯▯▯▯71007000188
0
Ground▯Level▯(Metres)
Spray▯Line▯Altitude▯over▯

gt 163 ▯18:06:45:9

▯AD▯Ground▯Altitude▯
over▯MSL▯(Metres)

306 266 40

1638 51 J032YSCC.B99▯▯▯▯▯303▯1 Ri
OBJECTIDSEG FILE_NAME MISSION SIDE LINE START_LATITUDE LONGITUDEALTITUDE DOP FLT_TIME FLT_LENGTH SPEED VOLUME AREA
PARAMETERSay▯03▯DE▯OCTUBRE▯2002 13:06 FEET MILES/HOUR

680 Annex 18

1°20'N

Scale: 1:50,000

theSrpivrearyisartehaewInittheirnna3tioKnmal boundary
SpryoliNote:r river
Projection: UTM zone 17; Datum: WGS-84

m k555 ,21,,0120

Distatctnetoataee5ua0drian bank on the border river 4560 m

COOL LOMMB BIIA

78°40'W 78°40'W

j
a
M
Ro

ECUADOR

COLOMBIA

!
Mataje , SprMatajees in 2000 (Witnesses 30-32-33-34-36-37-38-39)

PACIFIC ECUADOR
Figure 20
1°20'N

681Annex 18

)

((tn)sses▯30▯32▯33▯34▯36▯37▯38▯39

Attribute▯Table▯27

(Witnesses)▯30▯32▯33▯34▯36▯37▯38▯39

▯Metres)

Meettaddatta off the cclossesst sppraay linees
▯evel
Mataje, 2000

ATTRIBUTE▯TABLESpray▯Line▯Altitude▯over▯E▯TO▯MATAJE▯IN▯2000▯

▯Metres)

▯SL
▯ADDED▯ATTRIBUTES
▯GoverMSL(Metres)

▯M151es) 97 54

932 002835 11:39:53.497,500▯249,73 151,900 46,400 1 62,390 0,800 10 9 0 ▯1
OBJECTID LINE_ID TIME ALTITUDE XTRACK MPH HEADING S SPRAY_RATE DOP SV USED DF STNIDASCIINAME
PARAMESpray▯Line▯Altitude▯ FEET MILES/HOUR

682 Annex 18

0'1°2

P
78°40'W 78°40'W

COLOMBIA

Matajee
!

j
t
M
í
R

DisDtatctnreutoataeje5cua0dmrian bank on the border river 5160 m

ECUADOR

78°45'W 78°45'W

Scale: 1:50,000
COLOMBIA
theSrpivrearyiasrtenal boundaryrnna5tiKom

Mataje, Spray LSprayolirNote: rivers 32)
Projection: UTM zone 17; Datum: WGS-84

ECUADOR
0 0,5 1 1,5 2 2,5 km PACIFIC

Figure 21
'N001°2

683Annex 18

H AIRCRAFT CROP A_C_CROP

347 0202 85 OV▯10Coca OV▯10_Coca

( )tness▯32)

Attribute▯Table▯28

d▯over▯
Mataje, 2002 (Witness 32) u

Meettadaatta off thee cllossessttspprrayy lineeCERCANA▯MATAJE▯2002▯
ne▯
Li

pray▯
S GroLid▯LAltit detres)

d▯
u

▯ltit
d

roun
▯A▯DEover▯MSL▯(Metres)

d▯
u

Altit
ne▯ 119 87 32
Li

2905 240 pray▯202U$CC.▯▯▯▯▯▯▯▯▯▯1 ▯18:46:34:68 ▯▯▯▯▯▯▯1.36273717391▯▯▯078.5,34441639,6 19,100
OBJECTIPARAMETERSov20▯DE▯FEBRERO▯2002INE STARLA13:46E LONGITUDEALTITUDE DMETERS_TIME FLTOTENGSPEED

684 Annex 18

N 1°20'

P
78°40'W
78°40'W

COLOMBIA
P

Mataje

e
a
a
M
í
R

DisDtaAttnreutoataeje5u9a0dmrian bank on the border river 5200 m

ECUADOR

78°45'W 78°45'W

COLOMBIA
Scale: 1:50,000

theSrpivrearyiasrtnal boundaryirnna5tiKom

Mataje, Spray LSprayoliNote:r riverProjection: UTM zone 17; Datum: WGS-84

ECUADOR
m k 555 ,,2,10 210 PACIFIC

Figure 22
N 1°20'

685Annex 18

100

2 Coca AT802_Coca

H AIRCRAFT CROP A_C_CROP

)

(( )ess▯32

Attribute▯Table▯29

e▯over▯
Mataje, 2003 (Witness 32) d
u
Me etaddaatta off hee cclosseestt sprrayy linee▯CERCANA▯MATAJE▯2003▯
Altit
ne▯
Li

SrGroLid▯LAltit detres)

e▯
u

▯ltit
d

roun
dt i t l A▯dD▯ATTRIBUTES
over▯MSL▯(Metres)
d▯
u

Altit
ne▯ 124 89 35
Li

16457 928 pray▯25BC.B9993▯1 ▯▯▯▯▯1 15:06:19:15 1.36189819 ▯78.409640,890 1,85 453,2 1,400
OBJECTIPARAMETERSve20▯DE▯ENERO▯2003 LINE STAR15:06ELONGITUDE ALTITUDEFEET FLT_TIME FLT_LENSPEEDTE

686 Annex 18

1°15'N

101

kk
225

22
78°30'W 78°30'W

,
115 RÍO SAN JUAN

11 Scale: 1:50,000
theSrpivrearyisaonmal boundaryirnna2tiK

SpraInternational b005daryeiver
Projection: UTM zone 17; Datum: WGS-84

RÍO MIRA

DisDta(catnteuttohajbEecta1:o3ra0nmbank on the border river: 970 m
DisDta(tatnteuttoeaajbEclta0:ora0nmbank on the border river: 1430 m

P P !Mataje Alto

P
P

Awa Reserve

ECUADOR

COLOMBIA
78°35'W 78°35'W

t
a
ío COLOMBIA
R

Awa - Mataje Alto, Spray Lines in 2002 (Witnesses 40-41)

ECUADOR

Figure 23 PACIFIC
1°15'N

687Annex 18

▯10_Coca ▯10_Coca

102

RAFT CROP A_C_CROP RAFT CROP A_C_CROP

41)

tness▯
▯Wi
2002
▯N

▯LTO

MATAJE
TO
▯
▯INE

▯PRAY

CLOSEST
▯ Attribute▯Table▯30 Attribute▯Table▯31
▯HE ▯
▯F
▯ver
▯ABLE

Me ettaddaatta ooff thee ccllosseesstt spprraayy lineIesTOMATAJEALTOIN 2041)Wi
Mataje Alto, 2002 (Witnesses 40 - 41) ▯ ATTRIBUTE▯TABLE▯OF▯THE▯SECOND▯CLOSEST▯SPRAY▯LINE▯TO▯MATAJE▯ALTO▯IN▯2002▯(Witness▯41)

▯ine

SprrayLine Altitude over Spray▯Line▯Altitude▯over▯
▯

▯ltitude ▯TTRIBUTES

▯ADGrrounnd Altitude ▯DDDEED ATTRIBUTES
▯ over▯MSL▯(Metres) ▯Grover▯MSL▯(Metres)
▯

▯ltitude
211 171 220 40 183
Line
▯
FID 5051EG F66E_E142Q4ACS▯▯▯▯▯▯9RightS45RT_IM5▯085TI▯▯▯0▯▯1▯1.25E8▯▯▯8▯▯.20ight 66920,770ME0 ▯▯▯▯▯▯▯1.253▯▯▯2▯▯1▯7,980.5055339
PARAMESprrayLine Altitude) NPA▯RISESpray▯Line▯Altitude▯ FEET NO▯REGISTRA

688 Annex 18

0°20'N 0°15'N

103

m
kk
55

44
76°40'W 76°40'W

22 Scale: 1:100,000

theSrpivrearyisarteonmal boundaryna1tiK

SpraInternational boundary
Projection: UTM zone 18; Datum: WGS-84

76°45'W 76°45'W

Puerto Mestanza
!

RÍO SAN MIGUEL

ECUADOR
COLOMBIA

76°50'W 76°50'W

COLOMBIA

Puerto Mestanza, Spray Lines in 2004 (Witness 10)

OCEAN ECUADOR
PACIFIC

Figure 24 0°20'N 0°15'N

689Annex 18

0°20'N 0°15'N

104

kk
55

76°40'W 44 76°40'W

22 Scale: 1:100,000
theSrpivrearyisartonmal boundarynna2tiK

SpraByoldNote:ver11
Projection: UTM zone 18; Datum: WGS-84

76°45'W 76°45'W
P

P !Puerto Mestanza

RÍO SAN MIGUEL

ECUADOR
COLOMBIA

76°50'W 76°50'W

COLOMBIA

Puerto Mestanza, Spray Lines in 2005 (Witness 10)

ECUADOR
DistairvnArtr5o3tetoaMclatdonran: 277k9 mPACIFICorder

Figure 25 0°20'N 0°15'N

690 Annex 18

Coca

105

RCRAFTAC_CROP

Attribute▯Table▯32

Puerto Mestanza, 2005 (Witness 10)st spprayy liness

METADATO▯LINEA▯DE▯ASPERSION▯MAS▯CERCANA▯PUERTO▯MESTANZA▯2005▯(Witness▯10)

Spray▯Line▯Altitude▯over▯

▯ADDED▯ATTRIBUTES

276 46

3295 1238 J135VMAC.B99 303▯1Right22 ▯8:43:14:20 0.28998635 ▯76.322820,890 1,2 109,7
OBJECTPARAMETERSer▯13▯OCTOBER▯2005IDE LINE STAR08:43E LONGITUDE ALTITMETRESP FLT_TIME FLT_LENGTH OTE

691692 Annex 19

INSTITUTE HFYDROLOGY, METEOROLOGY ANE NVIRONMENTALSTUDIES
(IDEAM), CLIMATECHARACTERIZATION THEN ARIÑO ANPUTUMAYO

BORDER ZONEW ITHECUADOR, 7ECEMBER 2011

693694 Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

ID07/M2/2011
Ms.

SONIA PEREIRA PORTILLA
Ambassador
Ministry of Foreign Affairs
[email protected]

Dear Ms. Pereira:

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
OF THE NARIÑO AND PUTUMAYO BORDER ZONE WITH ECUADOR, prepared by

officials from the Under Division of Meteorology▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Moreno, and Ernesto Rangel Mantilla

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Sincerely,

▯▯▯▯▯▯▯▯▯

RODRIGO JOSE LOZANO P.
General Director

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

695Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

CLIMATE CHARACTERIZATION OF THE NARIÑO AND PUTUMAYO

BORDER ZONE WITH ECUADOR

1. Information used

shown in Table 1 and map 1, respectively.

LATITUDE WEST
Degrees (°) Minutes LONGITUDE ELEVATION

NAME Municipality (‘) Degrees (°) Minutes (msl)
(‘)
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Control Center - CCCP ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯
Table 1. Identification data weather stations

Weather stations: agrometeorological; ordinary climatologic; main climatologic; special weathermain synoptic, secondary synoptic

Map No. 1. Location of meteorological stations on the COLOMBIA - ECUADOR border zone

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

696 Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,

Meteorology,
and Environmental Studies

2.1 Trend of precipitation, temperature and humidity in Putumayo and Nariño

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

(Geographical coordinates: 00° S, 74° 46’ W, elevation: 147 m)

2.1.1 Trend of precipitation
▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯

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2.1.2 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯ Daily Trend of Puerto Leguizamo temperature (Jan to Dec)
JANUARY▯ 23.7▯▯ 30.3 26.8▯▯
FEBRUARY▯▯ 23.6▯▯ 30.2▯ 26.8▯
MARCH▯▯ 23.6▯ 29.0 25.8▯
APRIL▯▯ 26.3▯ 28.5▯ 25.5▯
MAY▯▯ 23.5▯ 28.0 25.1▯

JUNE▯▯ 22.9▯ 27.5▯ 24.8▯
JULY▯▯ 22.5▯ 27.5 24.6▯
AUGUST▯▯ 22.8▯ 28.6▯ 25.1▯
SEPTEMBER▯▯ 23.3▯ 29.4 25.7▯
OCTOBER▯▯ 23.7▯ 29.8▯ 25.8▯
NOVEMBER▯▯ 24.0▯ 30.1 26.1▯
DECEMBER▯▯ 23.9▯ 30.0▯ 26.4▯

Figure No. 1A. Daily Trend (07, 13, 19 hours) of the air temperature in Puerto Leguízamo

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represents a month. Overall it can be seen that:

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
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697Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

x ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
in November.

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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
the land in accordance with standards set by the World Meteorolog ical Organization and
adopted by the IDEAM. To estima▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

noted that it decreases at a rate of 0.65° C per 100 m of displacement in height. For
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2.1.4 Trend of the relative humidity thro ughout the year in Puerto Leguizamo
(Putumayo) (see Figure No 1B)

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▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
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698 Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,

Meteorology,
and Environmental Studies

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ PUERTO LEGUIZAMO STATION
Municipality: Puerto Leguizamo - Putumayo
MONTH (%)
ESTACIÓN PUERTO LEGUIZAMO
JAN 81 Municipio: Puerto Leguizamo -Putumayo
FEB 83 Coor. 00°19'S 74°46' W Elev. 147 m
100
MAR 86 90
APR 89 80

MAY 89 70
60
JUN 89 50
JUL 89
40
AUG 86 30
Hu20dad relativa (%)
SEPT 86
OCT 85 10
0
NOV 85 ENE FEB MAR ABR MAY JUN JUL AGO SEP OCT NOV DIC
DEC 84
MESES

MONTHS
JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC
Figure No 1B. Monthly Mean air humidity trend in Puerto Leguízamo

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the Pacific-CCCP, whose geogr aphical coordinates are 1° 48’ N, 78° 46’ W, elevation: 1

msl.

2.2.1 Trend of precipitation

2.2.2 ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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HLC).

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Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
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699Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,

and Environmental Studies

▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯ DECREASE OF MEAN AIR TEMPERATURE (ºC) THROUGHOUT THE YEAR
JANUARY▯ 24.3 27.6 25.7 CCP STATION - TUMACO
FEBRUARY▯▯ 24.4 27.7 25.7
MARCH▯▯ DISMINUCION DELA TEMPERATURA MEDIA DEL AIRE(º C ) DURANTEEL AÑO
24.7 28.2 26.3 ESTACION CCP - TUMACO
APRIL▯▯ 24.8 28.4 26.4
MAY▯▯ 24.9 27.8 26.3 29.0
JUNE▯▯ 24.6 27.8 26.0
JULY▯▯ 28.0
24.4 27.7 25.8
AUGUST▯▯ 24.4 27.8 25.6 27.0
SEPTEMBER▯▯ 24.4 27.2 25.5 26.0
OCTOBER▯▯ 24.5 27.6 25.6 ºC
NOVEMBER▯▯ 25.0
24.5 27.5 25.2
DECEMBER▯▯ 24.3 27.4 25.2 24.0
23.0

22.0
Promedio de las07 hrs Promedio de las13 hrs Promedio de las19 hrs

Mean at 07 hours Mean at 13 hours Mean at 19 hours
Figure No 2A. Daily trend (07, 13, 19 hours) of the air temperature in Tumaco

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December and 24.9° C in May

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28.4° C in April.

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December and 26.4° C in April.

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Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
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700 Annex 19

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Institute of Hydrology,
Meteorology,

and Environmental Studies

2.1.4 Trend of humidity during the year in Tumaco (Nariño) (see Figure No 2B)

The monthly performance of the relative ai▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
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PUERTO LEGUIZAMO STATION
Relative humidity Municipality: Puerto Leguizamo - Putumayo
MONTH
(%) ESTACIÓN CCCP DEL PACÍFICO

JAN 89 Municipio: TumacoCoor. 01°48'N 78°46' W Elev. 1 m
FEB 88
100
MAR 87
APR 88 80

MAY 89
60
JUN 89
JUL 88 40

AUG 87 Humedad relativa (%)
SEP 88 20

OCT 88 0
NOV 88
ENE FEB MAR ABR MAY JUN JUL AGO SEP OCT NOV DIC
DEC 88 MESES

MONTHS
JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC

Figure No 2B. Monthly Mean trend of humidity in Tumaco

Lang’s climate classification is based on a▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

INDEX TYPE OF WEATHER INDEX TYPE OF WEATHER
▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯
40-60 Semiarid tanreater ▯▯▯▯▯▯▯▯▯▯▯▯
160

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
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701Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯
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Map No 2 Province of Nariño Map No 3. Province of Putumayo

It can be observed that in the province of Na riño (Map 2) there are three types of climate:
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

4. Wind trend

▯▯▯▯ ▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ological stations located in the Colombian
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Province JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC
EL MIRA –Tumaco
(Nariño) 1.31.1. 1.1 1.1 1.0 1.1 1.2 1.3 1.2 1.2 1.2 1.2
APTO. SAN LUIS-Ipiales
(Nariño) 1,1 1,1 1,2 1,2 1,3 1,7 2 2,1 1,81,51,2 1,1
LA TAGUA- Pto
Leguizamo (Putumayo) 1,8 1,8 1,8 1,9 1,7 1,7 1,9 1,6 1,6 1,7 1,9 2,1
Puerto Leguízamo

(Putumayo) 2 1,6 1,4 1,5 1,6 1,51, 5 1,5 1,6 1,4 1,5 1,6
Table No 2: Mean monthly wind speed (m/s)

The analysis of the above table allows revealing that the Mean monthly wind speeds
▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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702 Annex 19

REPUBLMeteorology,te of Hydrology,
and Environmental Studies

ANNEXES

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
www.ideam.gov.co - meteorologí[email protected]. 2117 and Environmental Studies

ANNEX No. 1

WIND FIELDS

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
(1996).

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ with recent data obtained from satellites

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
and Kistler, 1996) and may be represented in the monthly Mean wind fields shown in
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ction, that is, they head to the northeast .

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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703Annex 19

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Institute of Hydrology,

Meteorology,

and Environmental Studies

Wind vector at 10 meters January Wind vector at 10 meters February Wind vector at 10 meters March Wind vector at 10 meters April
Wind vector at 10 meters May Wind vector at 10 meters June Wind vector at 10 meters July Wind vector at 10 meters August
Wind vector at 10 meters September Wind vector at 10 meters October Wind vector at 10 meters November Wind vector at 10 meters December

Figure 1. Mean monthly wind maps (vectors or arrows) for Colombia, Ecuador and neighboring areas, based on data from the

NCAR/NOAA Reanalysis Project of the U.S.

Wind speed m/s Mayuary Wind speed m/s Juneuary Wind speed m/s Julyh Wind speed m/s August
Wind speed m/s September Wind speed m/s October Wind speed m/s November Wind speed m/s December

Figure 2. Maps of monthly Mean wind speed for Colombia, Ecuador and neighboring areas, based on data from the

NCAR/NOAA Reanalysis Project of the U.S.

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704 Annex 19

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Meteorology,
and Environmental Studies

BIBLIOGRAPHY

Hastenrath, S., 1996. Climate dynamic of the tropics. 2ª Ed. Kluwer Ac ad. Press. Dordrecht. The
Netherlands, 448 pp.

Kalnay, E., M. Kanamitsu y R. Kistler, 1996: The NCEP/NCAR 40- years Reanálisis Project. Bull. Am.

Soc.,77: 437-471.

Krisnamurti, T. 1979. Compendi um of meteorology, Vol II, part 4, Tropical Metorology. World

Metorological Oraganization, WMO N° 364, Geneva, Switzerland, 428 pp.

Rielh, H. 1979. Climate and weather in the tropics. Acad. Press, London New York San Francisco,
611 pp.

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705Annex 19

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Institute of Hydrology,
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and Environmental Studies

ANNEX 2A
MONTHLY MEAN WIND MAPS FOR THE PROVINCE OF NARIÑO

AND BORDER WITH ECUADOR

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – January
Ð Predominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ors, the wind comes from the West, that is,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

separates from it and enters into the province of Nariño, in the northeastern border area.

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706 Annex 19

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Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – February
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯borderline from the West to the East on the

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
Colombian territory. In a small area located in ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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707Annex 19

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Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – March
Convention m/s
ÐPredominant direction

In March, the wind flows parallel to the borderline from the West to the East on the western

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708 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – APril
Convention m/s
ÐPredominant direction

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709Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – May
Convention m/s
ÐPredominant direction

▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯

border toward Colombia), speed intensifies a litt▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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710 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – June
Convention m/s
ÐPredominant direction

strongest in the northeast of the border area, ove r the province of Nariño, where it reaches
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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711Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,

Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – July
Convention m/s
ÐPredominant direction

▯▯ly has the same wind path of the previo▯▯▯▯onths, that is, blowing predominantly from
Ec▯ador to Colombia. The wind speed va▯▯▯s range from 0.5 m/s (dar▯▯▯▯▯▯), to the west of

the bord▯▯▯▯ ▯▯ to 2.5 m/s ( ▯▯▯▯▯▯ ▯▯▯a bl▯e) on the east of the area. the wind speed
strengthens in the northeastern part of Nariño, far from the border, reaching va▯▯es of 5.0

m/s (olive green).

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712 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – August
Convention m/s
ÐPredominant direction

the area. The wind speed strengthens in the northeastern part of the border, over Nariño,
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – September
Convention m/s
Ð Predominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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714 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – October
Convention m/s
ÐPredominant direction

direction and northwest, respectively.

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715Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – November
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
western and central sectors and the East and Northe ast prevails at the east of the area.

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716 Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,

and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Nariño
Multi-annual Mean – December
Convention m/s
ÐPredominant direction

▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯ ▯▯▯▯▯

ANNEX 2B

MEAN MONTHLY WIND MAPS FOR THE PROVINCE OF PUTUMAYO
AND BORDER AREA WITH ECUADOR

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717Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – January
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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718 Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – February
Convention m/s
Ð Predominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

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719Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – March
Convention m/s
Ð Predominant direction

intensify to reach 2.0 m/s ▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
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www.ideam.gov.co - meteorologí[email protected]

720 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – April
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

721Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – May
Convention m/s
ÐPredominant direction

While the direction of wind contin▯▯s predominant from the ▯▯▯th (from Ec▯▯dor and Per▯

to Colombia), its speed is enhanced, reaching val▯es of 2.0 m/s ▯▯▯▯a▯▯▯▯e) and 2.5 m/s
(▯▯▯▯▯ a▯▯▯ma▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

722 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – June
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

723Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – July
Convention m/s
ÐPredominant direction

▯▯▯▯▯ ▯▯▯ ▯▯▯ ▯▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯ ▯▯▯▯▯▯▯▯▯ ▯▯▯ ▯▯▯▯ ▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

724 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – August
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

725Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – September
Convention m/s
Ð Predominant direction

In September, th e condition is▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯e Colombian territory), while the wind speed
▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

726 Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – October
Convention m/s
Ð Predominant direction

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

727Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – November
Convention m/s
Ð Predominant direction

November is atypical comp ared to other months of the year. The wind flow is

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

728 Annex 19

REPUBLIC OF COLOMBIA IDEAM

Institute of Hydrology,
Meteorology,
and Environmental Studies

Map of the Mean speed and predominant surface wind
Province of Putumayo
Multi-annual Mean – December
Convention m/s
ÐPredominant direction

▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯▯ its normal condition, being predominant in

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
Telefono PBX (571) 3527160 – Fax: 3527160 Ext. 2117
www.ideam.gov.co - meteorologí[email protected]

729Annex 19

REPUBLIC OF COLOMBIA IDEAM
Institute of Hydrology,
Meteorology,
and Environmental Studies

I Annex 1 additional information on trend of wind mean fields is provided.

In Annexes 2A and 2B maps of monthly mean wind (predominant direction and mean speed) are

shown for the provinces on Nariño and Putumayo, respectively. Wind speed is classified based on a
color scale, in which blue and black tones correspond to speed below or eq ual to 2,5 m/s (9 Km/h);
the green ones to speed between 2,5 and 6,0 m/s ( 9 to 21,6 Km/h), and the yellow and red colors
correspond to speed above 6,0 m/s (21,6 Km/h). On these maps, predominant wind direction is

shown by the arrows or vectors direction.

In general terms, maps in Annexes 2A and 2B allow to state that for most part of the year,
predominant winds in the border zone betwee n both countries blow from Ecuador towards Colombia
and their speeds are low. At the bottom of each map a brief description of the wind trend is given for

the corresponding month.

The following officials from the Meteorology Under-division of IDEAM to ok part in the preparation of
this report:

[Signed]
Franklin Ruiz Murcia

Physicist and MSc. in Meteorology

[Signed]
Gloria Leon Aristizabal
Meteorologist

Coordinator Weather and Climate Modeling Group

[Signed]
Gonzalo Hurtado Moreno

Meteorologist
Coordinator Climatology and Agro-meteorology Group

[Signed]
Ernesto Rangel Mantilla

Meteorologist
Meteorology Assistant Director

[Signed]

Henry Benavides Ballesteros
Chemical Eng. and MSc. in Meteorology

Carrera 10 No. 20 – 30 Piso 6º. Bogotá D.C. –
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730

Document Long Title

volume II