volume III

Document Number
17568
Parent Document Number
17564
Document File
Document

INTERNATIONAL COURT OF JUSTICE
____________________________________________

CASE CONCERNING
AERIAL HERBICIDE SPRAYING

(ECUADOR v. COLOMBIA)

REJOINDER OF THE

REPUBLIC OF COLOMBIA

VOLUME III

ANNEXES 20 - 33

1 FEBRUARY 2012 LIST OF ANNEXES

VOLUME III

Annex 20 National Narcotics Directorate (DNE),Environmental Management

Plan (EMP) Eradication of Illicit Crops, Chapter VII, Identification
and Assessment of Environmental Impact, 30 Oct. 1998. ............... 1

Annex 21 National Narcotics Directorate (DNE), Environmental Impact of
Illicit Coca Crops and their Eradication by Aerial Spraying with

Glyphosate in the Bio-geographical Region of the Colombian
Amazon and Orinoco Basins, Dec.1994. ........................... 35

Annex 22 Colombian Law 30 of 1986. ..................................... 53

Annex 23 Colombian Law 99 of 1993. ..................................... 57

Annex 24 Note from the Minister for the Environment, Mr. Juan Mayr
Maldonado, to the Secretary General of the Colombian Senate,
10 Aug. 2001. ................................................ 63

Annex 25 Note N° 0001-1-928 of 17 August 2001 from the Ombudsman
requesting a public hearing to the Minister for the Environment on
the Program for the Eradication of Illicit Crops byAerial Spraying
with Glyphosate, and the corresponding minutes of the hearing,

24 Aug. 2001. ................................................ 73

Annex 26 Note N° 01888 from the National Narcotics Directorate (DNE),
Appeal submitted by DNE, of Order 599 of 1999 from the Ministry
for the Environment, 1 Feb. 2000 ................................. 87

Annex 27 Council of State of Colombia, Chamber of Contentious
AdministrativeAffairs, Order of 15Aug. 1995. ..................... 103

Annex 28 National Narcotics Council, Minutes N° 01 of 8 Mar. 1996. ........... 107

Annex 29 Note N° 11430 from the Ministry of Justice and Law, National
Narcotics Directorate (DNE) to the Ministry for the Environment
enclosing the Environmental Management Plan for theApplication
of Glyphosate in the Eradication of Illicit Crops, 30 July 1998.. ....111.

iiiAnnex 30 Note N° 16341 from the Ministry of Justice and Law, National
Narcotics Directorate (DNE) to the Ministry for the Environment
enclosing Chapter VII of the Environmental Management Plan for
the Application of Glyphosate in the Eradication of Illicit Crops,
30 Oct. 1998. ................................................ 115

Annex 31 National Narcotics Directorate (DNE), Environmental Management
Plan for the application of glyphosate herbicide in the eradication of
illicit crops with Supplementary Information, submitted by the DNE
to the Ministry for the Environment, 13 Sep. 2000. .................. 119

Annex 32 Note N° 24171 from the National Narcotics Directorate (DNE) to
the Ministry for the Environment, 8Aug. 2001 ..................... 199

Annex 33 Note N° 32280 from the National Narcotics Directorate (DNE)

to the Ministry for the Environment enclosing the Environmental
Management Plan (EMP) of the Program for the Eradication
of Illicit Crops by Aerial Spraying with Glyphosate (PECIG),
6 Nov. 2001. ................................................ 203

iv Annex 20

NATIONAL NARCOTICSD IRECTORATE(DNE),ENVIRONMENTAL
M ANAGEMENT PLAN(EMP)E RADICATION OFILLICIC ROP,

C HAPTERVII, DENTIFICATION ANASSESSMENT OF
ENVIRONMENTAL IMPACT,30O CTOBER1998.

(Archives of the Colombian Foreign Ministry)

12 Annex 20

1. IDENTIFICATION AND EVALUATION

This identification and assessment of environmental impact of representative zones
located in natural regions of Colombia in which the program for the eradication of

illicit cropswith the glyphosate herbicide is being executed through spraying, seeks to
make a direct specification of environmental conflicts which may be generated both by
the establishment of illicit crops and by the program.

It is important to note that the establishment of illicit crops in Colombia, where coca -
leaf, opium poppy or marihuana is in breach of established law and regulations. They
also fall within the description of activities causing environmental degradation defined

in Law 99/1993, Article 5.14. Therefore, the eradication program for illicit crops
arises as a response for the interdiction of the problem caused. Therefore,
eradication program is in no way similar to an economic or social development
project which seeks to consolidate a specific area of production. On the contrary, its
objective is to do away with or reduce a problem of a criminal natu re, contrary to the
laws in force in Colombia on the subjec .t

1.1 IMPACTANALYSIS

1.1.1.General matters and methodology

The currently existing environmental conditions in the zones representative of the
natural regions considered in the study have been t aken into account for the

assessment of impacts, as follows:

- The current environmental situation, without the program, Scenario A.
- The current environmental situation with the program, Scenario B.

The method used to assess environmental impacts identified in this study is based

essentially on the appreciation of the magnitude, extent, duration, reversibility and
recoverability of identified impacts, whether positive or negative. This allows to make
an overall judgment of impacts identified for a component, as a result of
interventions on the environment.

The assessment method followed the next main step:s

- Identification of project/environment interactions
A matrix is prepared, capturing the interrelationships between activities in each
scenario and the ele ments of the environment grouped into biophysical and socio-
economic components.

- Identification of impact in each Scenario, and classification
Here, the effects caused are described, and qualitatively assessed, making it
possibleto identify the actionscausing most impact and the elements of the

3Annex 20

environment potentially most affected. At the same time, effects were considered in
accordance with their importance, and estimate was made of the assimilation
capacity of the environment: principally onland, i.e., soils, vegetation and water; in
the face of environmental risks generated by the establishment of illicit crops, and

the eradication with agricultural chemicals

The impacts identified must be assigned a value, and their occurrence must be
predicted, in order to identify which are the most important and environmental

aspects. This defines the areas on which environmental management should focus
its attention, since it is there that the important results may be obtained, with the
greatest possible economic efficiency.

1.1.2.Classification of environmental impact

The classification of impact is a complex exercise which means that the points of
view of different specialties intervening in the assessment needs to be recognized.

For this study, an arbitrary scale was drawn up as shown in Table 7.1, developed
with the experts who took part in the study. We say that the scale is "arbitrary",

because there is no particular criterion applied, and it only tends to reflect the
importance of the matter evaluated.

The importance of the aspect is simply the sum of the foregoing criteria, when

applied to the analysis of one issue in particular.

- Probability of occurrence

The probability that an impact will materialize is given by the following scale of
values, which is also arbitrary:

Frequent: 1.0

Occasional:0.5
Rare: 0.1.

Chart 7.1

CRITERIA FOR ENVIRONMENTAL IMPACC TLASSIFICATION

CRITERION MEANING SCALE OF VALUES
Magnitude Degree of incidence of the impact Low 1 Medium 2 High 4 Very high 8

Extent Area of influence Specific1 Partial2 Widespread4
Persistence Permanence/duration Fleeting (<1 month) 1 Temporary (1 -12
months 2 Prolonged (1- 5 years) 4
Permanent (over 5 years) 8
Reversibility Natural return to original conditionsrt term (<1year) Medium term 1 -5
years Long term (over 5 years)
Recoverability Possibility of reconstruction Immediate 1 Medium term 2 Mitigable 3
Unrecoverable 8

4 Annex 20

FIGURE 7.1

ESTABLISHMENT AND ERADICATION OF ILLICIT CROPS
ENVIRONMENTALIMPACTASSESSMENT PROCESS

Identification of
program activities — Identification of

actions for the
establishment

illicit crops actions

Definition of elements <—
—>
and/or environmental
components potentially Characterization of

affected environmental
Characterization of elements used by

environmental growers

elements potentially Identification of
affected by the environmental impact Identification of

program element of potential
degradation

Analysis criteria for
environmental impact

assessment

Significant environmental
issues

Environmental
Management plan

actions

5Annex 20

d. Interaction matrix

The interaction matrix ‘establishment of illicit crops-environment’ points to cases
in which a given activity causes some type of effect, whether beneficial or harmful
for one of the environmental elements. In total, 62 interactions were found, as
shown in Chart 7.3.

The greater part of the interactions occur during the felling and burning of native

forest, and the execution of crop tasks (agronomic practices

1.2.2.Effects of the project

Initially, in Chart 7.4, the activities and actions for the establishment of illicit crops

that cause impacts on the environment are identified and described.
Subsequently, and depending on the environmental element affected, the impact
causedis determined, and finally, the nature of the impacits described.

In Chart 7.5.,The actions for the establishment ofillicit crops are shown, as well as
the elements that the affect positively or negatively, and they are classified
according to the following criteria:

• Character

It was Classified as positive when it corresponds to interaction whose activity
generates an imp rovement or at least allows observation of the initial
environmental conditions of a given indicator. N egative corresponds to the

interaction whose activity generates deterioration decrease of a given indicator in
comparison to the identified baseline,

• Magnitude

This refers to the impact as an environmental change produced, and it is a

function of the variation in baseline conditions. This is classed as low, medium,
high and very high.

• Extent

This refers to the area of influence where a given effect develops, in our case, to
the representative zones of the regions studied. It is determined as specific forthe

effect around the site of the impact, it is partial for those effects inside the
representative zone, and it is extensive for the regions of study, and also, at
national and international level.

• Persistence

6 Annex 20

This refers to the existence of the impact over time, since it may be very variable
in each case, and is classified as fleeting, temporary, prolonged and permanent

• Reversibility

This considers the possibilities of natural return to the original conditions of the
media after the occurrence of the impact. This is classed as short-term, medium-
term or long-term.

• Recoverability

This refers to the possibility of the environment , or (resilience) man's capacity to
reconstruct or mitigate the impact caused. This is class ified as immediate, mid-
term, mitigable, and unrecoverable.

• Importance

This is an aspect which takes into account the sum of all the preceding criteria,
when an expert judgment is made on a particular issue.

7Annex 20

alpine Utricularia and

(Crocodylus intermedius).

-fauna. species threatened are melastomes.among the reptiles: the stifle

palm {Zamia cupatensis, Zamia jirijimensis),
n the Colombian Amazon and Orinoco Biogeographic

the species are restricted to the Andes; ferns with

(Tapirus terrestris); among birds: the hawk (Falco sp.)
on rates
i

interaction of soil-plawhich 80% of
7.4 c r
\

communities "Forestry shrubs" and gallery forests. Among the mammals

TABLE No. -100,000 per poppy crops

hectare in

DESCRD IPepleioOcsfeuoipot6fmricnlvcnoiiilhfoi;aihoiiserrofgeaaf:whemuen,0a0rt)septirrliouu)rarrrchuui.tantpseuanoaftnketglo

truction of

IMPACT Deforestation Desiodiversity

SCENARIO A: WITHOUT THE ILLICIT CROP ERADICATION PROGRAM

ENEVLEMVEeCeTation

OF and
woods
cover of

to indiscriminate
Uncontrolled fire of
DEASCTIIPTvIteetuonfefeeneiieiobiecgtivity

native
IDENTIFICATION OF ENVIRONMENTAL IMPACT DUE TO THE PRESENCE ILLICIT P SourPeYEnvionCmenAaNAudit.AnvIJU

8 Annex 20

in

-

the soil
na) m
current or past natural processes

or marihua ructure sing reduction in production capacity of goods

poppy soil st

the ogic niches

ed)

-ducation resources to know

Continu

7.4

lation of biocide agents in fauna populations in streams, rivers and swamps and

(TABLE ations of fauna to other habitats and alteration of local and regional ecological balance
sappearance of microbiota (fungi and bacteria)
DESCRIPTstEImuiDatotAotirDiofroiphoffoooericrrpccuaofptvChanges in biologic composition of communitiestsitrletadtwotea)poyfiaarorordinoglcreaaothefavsep

of

ectation of
IMPACT typfeication Destruction DeserContamination
oreossleoratoaioleseuctioions Sucrfocaboatetsfnfanrd,Mrdduicacrivrqyanll)idties

ENEVLEMVEEgeTaEionFloorFauna Soil Water Fauna Lanscenic beauty

uncontrolled
DEO SCRAIPTrOepauraliodn of Inand useiappliitfdrtiierd

VITY SoRurec;E.vidaptednftohedi. EPn.vironmental Impact of Coca Illicit Crops and the Eradication by Aerial Spray with Glyphosate in the Colombian Amazon and Orinoco Biogeographic

ACTI
Crolapbor

9Annex 20

onstruction of camps and

c, metallic and non perishable containers

ethical values

and

pray with Glyphosate in the Colombian Amazon and Orinoco Biogeographic

OF IMPACT

Continued)

7.4

(TAB DLESCRD IPcIDyilftoceiestIertdmClearingCoofnatinaftrent,ydeslrtlehnyorfcaibrovs,getatbusftrnc gasses and solid particles,gailporo

ctation of
Destruction andn of
IMPACT socioquvthroaliieessand vegGaasnAmfociotnoafofgahtonlinursletionnsal

-

ENVNTAEFFEultTaoDal VegetatAiomoWspahtereoilSoeconomic

d steps.

DEOSFCRAIPTTIONY grmaccoeratoauvasavxtitsrssaelization,

Sourecgn.nvroanteedarthueitEn.vironmental Impact of Coca Illicit Crops and the Eradication by Aerial S

Production of
ACTIVITY

10 Annex 20

AL IMPACT
H 1 l
EN-IRONM-IT - l 1 - -I -
VA22E OF16 VHI 8 8 16 20 22
30

1 1 1 1 1 1 1 1
VALUE SCALE

Y
PROBABILIT
OCCURENCE equent
FrequenrtequentFrequenOccasionOccasional FrequentFrequent

RELE22NCE 15 30 16 16 ]6 20 22
VALUESCAL

4 4 8 4 4 4 4 4

LITY

RECMitigablietigablegableMitigableMMitigable MitigableMitigable
SCALE
VAL4E 2 4 2 2 2 4 4

DURATION term
TY OR
REVERSIBMid term Longrm Mid MiMtiedterm Longerm Longerm

VALUE 4 8 4 4 4 4 4

E
SISTPAEPermanentongeProlongedProlongedroPloloendged Prolondrolonged Very highly important

SCALE
VALU2 2 2 2 2 2 4 2

ial
EXTEPartiPartial Partial Partial ParPtiaarltial Part
Exteensi
SCALE
VAL4E 4 8 4 4 4 4 8

INTENSITY
MAGNHighE High High Highigh High
Veryigh Vehrigh

CHA(ACTER( ( ( ( (-) (-) ( Highly Important VHI

ction
IMPACT

Modforest typesodelatdnreductionnCooftuoperiofelcaionaoflanditaperltesn

tatioSoil Soil Very important HI
Fauna Water Fauna –
ENVMEETAALFNTTEDege Lanans/oneeicauty

7.5

CHART and
DESOCICTTIVNITY
Agrpoeoariactailon of Unconitrdoilslcerdiminate

Little important VI
-
ACTIVITY Croactivities LI

11Annex 20

AL1IMPACT I Í
EN-IRONMENT - - Í I I V V
VA20E OF 6 6 - - - - - -I
22 18 VI 18 16 13 18 28

VA1UE SCALE 0.5 0.5 t 1 1 1 1 1 1

al ai
Y
PROBABILIT
OCFrequent Frequent Frequent FrequentFrequent Frequent Frequent Frequent
Occasionccasion

RELE22NCE 12 22 15 18 16 13 18 28
VALUESCALE
4 4 4 4 4 4 2 4 4

LITY
REMitigable Mitigable itigableMitigable MitigableMitigablMed term Mitigable Mitigable

SCALE
VAL2E 2 2 4 2 4 2 1 4 4

DURATION
TY OR
REVEMed.IBmILIMed. Med.Term Longerm Med.erm Longerm Medterm Shortrm Longerm Longerm

VA4UE 4 2 4 4 4 4 2 4 8

E
PERSISTANCed ProlongTemporary Permanentry highly important
ProlongedProlonged ProlongedProlongedTemporaryrolonged –
SCALE
VALU2 2 2 2 2 4 2

EXTEPartial Partial Partial Partial Partial Partial
Extveensi Extveensi Extveensi
SCALE
VA8UE 2 2 8 4 4 4 4 4 8

INTENSITY
MAGNITUDE High High High High High
VeHryigh Meudi meudí Veryigh Vehryigh

- - - - - - Highly Important VHI
CHAR(CTER (+) (-) ( ( ( ( ( (-) (-) –

tion
IMPACT alth, Lw
Locreanonaaclrease Vioilneasecee
ReiiopProppuebAfffetaitDetaeo/rfonpsbclieervicescompmatinwork forcenmefhliciatayln,vdalues

-
- Very important HI

Socfalilyervice Education Culture Socsecurity
ENVMIEETAALFNTTEEconomic infrastructure Comparticipationent

-

7.5
DESOCFICTIIVNITY Bulateoxfclpcneesdisdnrcilercsonaonrrcial iz

CHART Little important V
-
ACTIVITY
LI

12 Annex 20

1.2.3.Analysis of elements

The elements most affected b -eneficially or otherwise-and the related actions are:

• Land (soils, geoforms, stability and landscape)

Affected by total removal of the vegetation cover. This leaves it exposed to the
phenomena of erosion by action of rain and wind. This phenomenon has its

greatest impact in the r epresentative zones where opium poppy, marijuana and
coca leaf are grown on mountainsides, as in the case of the Andean region, the
Caribbean and Catatumbo.

As a consequence of the steep slopes there, and the instability of the soil, there
are phenomena ofmass removal and processes of erosion in furrows or gullies.

At the same time, the action of burning off vegetation cover which has been felled
or stripped seriously affects the edaphobiota, reducing existing populations. In all
cases, there is a conflict on regarding the use of the soil, because the natural use
of the soils is not precisely for agricultural work. In particular, this negative effect is
increased in zones with steep slopes, in which any type of crop established (local
or otherwise) comes into conflict with the environment.

Further, the structure of the scenic beauty of the landscape is affected and
seriously diminished when the visual values of the basins intervened are lost.

Farm crop work modifies the structure of the soil and affects ecol ogical niches of
microorganisms in the soil. Likewise, the incorporation of fertilizers and pesticides
of different kinds, indiscriminately, reduces the possibility of recovering the different
biota. Finally, unsuitable management of waste generated by these agricultural

chemical practices (containers, bags, small implements, etc), and the activities of
processing and refining of drugs (containers, bags, metal drums, precursors,
plastic, cement, leaf bagasse, etc) produce phenomenon of contamination of the
soil and water which have not yet been evaluated.

• Water (quality, alteration of water courses, sedimentation)

The activities of establishment of illicit crops cause negative effects on adjacent on
adjacent bodies of water. These effects are expressed in an alteration of the
physical and chemical conditions of water quality due to the direct or indirect
discharge of residues of fertilizers, pesticides and chemical precursors used in
processing of drugs.

At the same time, the process of deforestation and subsequent burning off alters
the courses of small streams, and means that smaller drainage systems disappear.

13Annex 20

The erosion processes subsequent to slash and burn practices, especially all the
phenomena of mass removal caused in the Andean zones, increas ed
sedimentation of streams, watercourses, lakes and rivers, so affecting the fauna
populations of the environment,

• Air (climate change)

This element is to affected temporarily and regularly by the effect of emissions of
particles in suspension and gases , is a product of the burning off of vegetation
cover. Similarly, the use of generating plants and the unsuitable handling of
pesticides and chemical precooked curses eventually and specifically deteriorate

air quality,

• Biotic aspects

Wildlife and native flora are the elements most affected by the establishment of
illicit crops.

Flora..............

Conjugal, non-parental, single-person and reconstituted families.

In the Caribbean, Amazon, Andean and Orinoco regions there is a wide cultural
heterogeneity, and a wide range of family structures and dynamics.

In most of these regions, the dynamics of the population have generated a high
proportion of families in the expansive stage of the life- cycle, producing a greater
demand for support services for family functions of socialization and rearing of the
young.

Generally, these regions have processes of an economic adjustment which have

been disengaged from social processes, which have affected sectors of the
population and have had a range of effects on the performance oa ff ily functions.

In these regions, for a number of reasons, including the increased poverty,
conditions of violence, drug trafficking, illicit crops, the improper use of alcohol and
drugs, family violence and violence in the media, have placed many families in

situations of crisis and particular vulnerability, including notably forcible separation,
displacement, and disintegration of the family.

Most of the economic and social policies and programs do not consider family
affairs as an integral matter, and do not evaluate the impact of their actions on the
structure, function and quality of life of the families,

There is a weak presence of public and private institutions in the area of family,

and information and gaps in is in the quality of information, staittics and research
on the situation, due to insufficient financial capacity and installed technical
capacity to make an adequate approach to the proper family problem.

14 Annex 20

In particular, there is a greater participation by women in the workforce, and the
change which in which the composition of the workforce has suffered. The
proportion of farmworkers has fallen, and the number of workers in commerce and
services, in particular, has increased. The salaried workforce seems not to have
increased, but the number of self -employed has risen. Further, the coverage of
Social Security is still very low among subsistence farmers.

The families in these regions have some special characteristics, which are
constantly changing, adapting different forms in their struc ture depending on the
point of life-cycle all conjugal cycle in which the members of the central nucleus
are, and according to survival strategies which they have two adopt, proper to the
social factors to which they are exposed daily.

The practices of child-rearing in rural areas are mediated by the intr-familiar intra-

family violence, and this produces the phenomenon which some have called
rootlessness,which appears when there is a traumatic rupture with break with the
past, a deficient or non- existent adaptation to the present, an uncertain future
which is not desired by those who live it. In this situation, there is a real inability to
construct a new project of life, and therefore, to participate effectively and fully in
community life.

The municipalities indicated as the object of study, by their pack characteristics
present complex panorama of poverty, which exceeds any social service, and
which are permanently exposed to high indices of social risk and vulnerability in
the face of unemployment, lac k of work, alcoholismand drug addiction.

The municipalities studied previously are a representative sample of what may be
occurring in the other municipalities in which there are illicit crops, which seem
mainly lack development plans, an indicator which may allow an inference of the

level of organization and management in the municipalities. There are also no
programs for inter -institutional coordination which would allow integrated action
and joint development projects.

1.3. Scenario B. Analysis of impac ts with the execution of the

illicit crop eradication program

According to the methodology explained for scenario A, the simple matrices are
drawn up for the interaction, identification and classification of impact

1.3.1.Interaction of crop eradicatio-environment

The illicit crop eradication program using glyphosate generates impact on the
biophysical and socio-economic components, and - as in Scenario A- a local,
regional and national area of influence, and even an international one.

15Annex 20

a. Biophysical component

a. Land

This includes the elements of soil, geoforms, stability and landscape. Likewise, the

physical and chemical conditions of this oil

• Water

Surface water is considered for its physical and chemical environmental qualities

• Air

Considerationis given to eventual contamination produced by the application of the
herbicide

Biotic Component

• Flora

Consideration is given to the illicit crop affected and the adjacent vegetation cover

• Fauna

Wildlife and then, fauna in the soil are considered

b. Socio-economic components
• The local economy
• The regional economy

• Social infrastructure
• Civic participation
• Security
• Population
• Public health

• Regional culturec. Activities or actions proper to the illicit crop eradication
process
• Preparation of the mix
• Loading of aircraft

• Transport of aircraft
• Application of the herbicide
• Solid waste management at the base
• Liquid waste management at the base
• Support for the alternative development process

16 Annex 20

CHART7.5
SCENARIO B

MATRIX OF INTERACTIONS -PROGRAM FOR THE ERADC I ATION OF ILLICIT

CROPS- ENVIRONMENT
CUADRO Conceptos Verticales

COMPONENTS
PHYSICAL
EARTH WATER AIR
SOIL QUALITY CONTAMINATION FROM SPRAYING
GEOFORMS ALTERATION OF COURSES

STABILITY SEDIMENTATION
LANDSCAPE
BIOTÍC

FLORA FAUNA
BIODIVERSITY LAND
LAND AIR

AQUATIC AQUATIC
SOCIOECONOMIC

LOCAL ECONOMY
REGIONAL ECONOMY
FAMILY

SERVICE INFRASTRUCTURE
EDUCATION
EMPLOYMENT
POPULATION
HEALTH
COMMUNITY PARTICIPATION
CULTURE

Horizontal concepts
ACTIVITIES THAT MAY CAUSE IMPACT
PREPARATION OF THE MIX
LOADING OF AIRCRAFT

TRANSPORT OF AIRCRAFT
APPLICATION OF HERBICIDE
SOLID WASTE MANAGEMENT
LIQUID WASTE MANAGEMENT
ERADICATION OF ILLICIT CROPS
SUPPORT FOR ALTERNATIVE DEVELOPMENT

Biodiversity landsoil

17Annex 20

sites, nearby districts or their

gram’s implementation

ne and heroin Increase in

n the Colombian Amazon and Orinoco Biogeographic

ment Maintenance
)

ed

Continu
DESCRIPTExististicondostitaOsrnnteosrriiyitnltriciofrasgtfrumtrlmuipltriyetoiinrtiirfnflfistilnsalctaeirhntoccafsumnitiueltabicouanryagricultural
7.7

(TABLE

ation and lack of

Attacks to the public forces
IMPACTDeterihtorptiblwofpaviiytlfatletevlelosv.emenof wnok iornecomeconomyervescoffinetrnnaonnaalevels.

-amily ipation -

ENVNTAEFSoMcaElTfrasEtctptmricnity EmploymosenEtcroitnyomy

DEOSCRAIPTTOITY

ion. Adapted for the EMP.

Sourcge: Environmental Audit, Environmental Impact of Coca Illicit Crops and the Eradication by Aerial Spray with Glyphosate i

ACTIVITYAerSplraying with

18 Annex 20

ALIIMPACT
EN-IRONMENT I l l L
VA27E OF - - - .5
3 17 4 3

VAiUE SCALE 0.5 1 0,5 05

^
Y
PROBABILIT ai al ai
OCFrequent Occasion Prequent Occasion Occasion

RELEVANCE
27 6 17 8 7
VALUESCALE
8 1 2 2 2

LITY able
REUnrecover Immediate Mid term Mid term Mid term
SCALE
VALUE
1 1 2 2 2

DURATION -
TY OR
REVShortILI Shortm MidTerm Shortm
Mid term
SCALE
VALUE 2 8 2 2

E
PERPermanent Temporary Temporary Temporary Very highly important
7.8 SCALE Permanent –
VAL2E ! 1 1 1

CHART

EXTPartial Specific Specific Specific Specific
SCALE
VA3UE 1 4 1 1
INTENSIT

UDE
MAGNITVeryigh Low High Low Low

) ) Highly Important VHI
CHARACTER ( (+) ( ( –

a
IMPACT coca and drift of plant on souViolencese
Destruction ofaffecotsondoef toionge Effedalophobiotntaminad

AL
Soil Water Very important HI
ENMEENLTBFBENCTTEDVegetation –
SCENARIO B: WITH EXECUTION OF ERADICATION OF ILLICT CROPS PROGRAM BY SPRAYING WITH GLYPHOSATE

QUALIFICATION OF ENVIRONMENTAL IMPACT DUE TO PRESENCE OF ILLICT CROPS OF POPPY, COCAINE AND MARIJUANA
illicit 48%
cro

of crops of ana crops
THE ACTIVITY crops litres of dilitres ofn
DESCRIPTION O commercial liquid commercial liquid commercial liquid (no eradication of
Applicatiglyph4s8ltietrafldti.r5L/hg"hRDsat7l5vpetppyionl3.5L/hga"Ro4o4tdupaeraatruidctua)na being

-ittle important VI
ACTIVITY sraying
Aerialwith ate LI

19Annex 20

AI IMPACT
ENVIRONMENTÍ I
VA8-UE OF - L -
10 8- 16

VALUE SCALE 05 0.5
1 !
al
Y
PROBABILIT al
OCCFrequent Occasion Frequent
Occasion

RELE16NCE 20 16 16
VALUESCALE
4 4 4 4

LITY
RECOVERABI
Mitigable Mitigable Mitigable Mitigable
SCALE
VAL2E 2 4 4

DURATION
TY OR
REVERSIBILI Metderm Longrm Longerm

VA4UE 4 4 4

ghly important

E
PERSISTANCed Prolonged Prolonged Very hi
Prolonged –
SCALE
(Continued) AVUE 4 2 2 2

7,8

EXTEExtensi Partial Partial Partial

CHART SCALE
VAL4E 8 2 2
INTENSITY
E
MAGNITUD um um
High Vehryigh Medi Medi

Highly Important VHI
CHARACTER (+) (+) (+) –

and tof and
IMPACT Diminutiontors andtal municipal
Decrecropped areaelimiention ofmof life qualitImprovemdevelopmentrticipation

-
Very important HI
ENVMENELEMENTTED –
Socioecocnuioc,,slaldn

ity

through

DESCRIPTION OF criteria and social
Develsmall pcopstteogecretoeboitdaaenisfrsatabail tonomy

m
Little important VI
-
ACTIVITY Alternativeeetpo
LI

20 Annex 20

21Annex 20

Chart 43

COMPARISON BETWEEN DATA OF GLYPHOSATE TOXICITY ACCEPTED
BY SEVERAL INTERNATIONAL AGENCIES FOR RISK EVALUATION

FAO IPCS BPA WSSA Health
Ministry

Acute toxicity

LD 50 oral >5,000 >5,000 >5,000 5,600 >5,600
LD50 skin >17600 >5000 >S00O >50G0 >5,000

LC 50 inhalationmg/kg (1) >3.8 >3.5 >3-5 >3.2 >5.48

Skin irritation No No No No No

Eye irritation Moderate/severeSlight/moderate Slightly Slightly Irritating
irritation irritation irritating irritating
formulas
Dermal sensibilization No No No No No

Sub-acute toxicity NOAEL2) 1,267mg/ka 1,267 mg/ka 4,320 mg/kg 1,400 1,400
mg/kg mg/kg

Chronic toxicity NOEL(3) 3l0 mg/ka 4l0 mg/ka 410 mg/ka 400 mg/ka 362 mg/ka

Cancerogenicity (4) No No No No No

Teratogenicity (5) No No No No No
Gcnotoxicity/Mutagenicity(6) Not mutagenic Not mutagenicNot Not Not

mutagenic mutagenic mutagenic
Toxicity in birds >2,500 mg/kg >2500 mg/kg >2500 mg/kg 960 mg/kg 960 mg/kg

Toxicity in fish 15-26 mg/L 14-33 mg/L 15-26 mg/L 86 mg/I.

Toxicological category NA NA Ill NA IV

(1) Applicable to glyphoend commercial formulations as salts, corresponds to that used in PECIG
(2) Eradication of illicit crops
(3) Without observable adverse effect
(4) Without observable adverse effect
(5) Opacity to produce crnce
(6) Production of congenital malformation
(7) Toxicity in the genome in the form of mutations and malformation of chromosomes

FAO United Nations Food and Agriculture Organization
LPCS International Program for Chemical Safety (FAO/WHO/UNEP/ILO)
WSSA: Weed Science Society of Americacy
Minsalud: Colombia Health Ministry

22 Annex 20

[The first section of this document is illegible for the most part Translation of random
words will not aid in its understanding. It has therefore not been translated.]

CHAPTER HI

OF THE CLASSIFICATION OF TOXICITY AND THE PERMIT OF USE IN THE COUNTRY

Article13.OF THE OPINION OF CLASSIFICATION OF TOXICITY AND THE PERMIT
OF USE IN THE COUNTRY. All individuals or legal persons that import or
manufacture pesticide products for application in the country, independent of the
quantity that they need to import or market, must obtain favorable opinion of the

Ministry of Health or its delegate of the toxicological classification and use permit in
the country, complying with what is established in Chapter X of this Decree»
Paragraph. When the matter pertains to pesticides with experimental purposes, there
must be total compliance with the specifics of this Decree.

Article 14. OF THE CATEGORIES. For purposes of classification, the following
toxicological categories of pesticides are established, whether for the formulation of
one of its components.

CATEGORYE Ixtremely toxic
CATEGORYH I ighly toxic

CATEGORYM I oderately toxic
CATEGORYS Ilightly toxic

Article15.OF THE CLASSIFICATION CRITERIA. For pesticide classification, the
followingcriteria will be considered:
a) Lethal oral and inhalation dose on rats and dermal on rabbits

b) Studies of chronic toxicity
c) Potential carcinogen, mutagenic and teratogenic effects
d) Appearance and formulation
e) Application form and dose
f) Persistence and degradability
g) Toxic, acute, sub-acute and chronic action on humans and

animals h) Feasibility of medical diagnosis and total recovery
treatment
i) Environmental effects in the short term

Article16. OF THE CLASSIFICATION ACCORDING TO LETHAL DOSE 5T 0.e table
of ranges and values of lethal dose 50 referred to in section a) of the previous article

for each category shall be established by the Ministry of Health by resolution.

23Annex 20

Article17. OF THE CHANGE IN CLASSIFICATION. The Ministry of Health may vary
the toxicological classification of pesticides when toxicity tests or risks of use so
justify.

Article18.OF THE OPINION OF CLASSIFICATION OF TOXICITY AND THE PERMIT OF
USE.Once the doc umentation has been studied, the Ministry of Health, through the
Division of Potentially Toxic Substances, will issue the opinion of classification of
toxicity and willallow or deny the use of the product in the country. The technical

information provided will have the character of reserved and will be protected
under the law.

Article19.OF THE REVIEW OF THE OPINION. The Ministry of Health ex officio or upon
application will review the opinions issued on pesticide products that it deems
appropriate, for which the holders of the respective register must attach the updated
toxicology information to the Division of Potentially Toxic Substances.

Article20.OF OPINIONS FOR DEFINED AREAS. For purposes of the toxicological opinion
of the pesticides for applic ation in buildings, vehicles, products and public area s,

interested
parties must satisfy the pertinent regulations herein.

24 Annex 20

25Annex 20

.

Toxicology of Crop Protection Products in Combination 1

1. Introduction

Human beings are permanently exposed to
a variety of chemical substances, both natural and
synthetic, throughout their lives. The human body is highly fit to address the day to day variations
of such exposure by preparing its defense mechanisms in a way that they are not overloaded.

Therefore, it is almost impossible to address and define a single assessment of all possible
combinations of substances to which an individual might be exposed daily. However, there is the
obligation to try to assess the exposure impact to combinations of certain products when the

extension and type are known.

For instance, in agriculture, crop protection workers are sometimes exposed to more than one

agrochemical by applying combinations of products or sequential applications of more than a
single product. In the cont ext of crop residues, ¡t may be possible that individuals consume the

residues of than a product present in food. In these cases, questions are whether health
assessment of exposure to the combination of components is different than that expected for
individual components. This document analyzes the factors that can be taken into account when

making the assessment and describes how security assessment must be made in these
circumstances.

2. Definitions

The investigation of combined effects basically implies the comparison of equivalent effects. In the
context of this document, the following effects are differentiated (Doul et al) (1)

3. Synergic Effects

This occurs when the combination effect of active ingredients is much higher than what is expected

from its individual effects (Super-additive effects)

4. Potentiating effect

When a substance by itself does not have a toxic effect on certain organ, it makes other substance

substantially more toxic when administered in combination therewith, and this is known as
potentiating effect.

Antagonism
An interaction of two or more active ingredients may lead to reduce the effect of these substances
in combination than that expected from its individual effects, is known as antagonism.

26 Annex 20

Toxicology of Crops P ortection Products in Combination

1. Introduction

Human beings are constantly exposed to a variety o f chemical substances, both
naturaland syntheticalthroughout their live.sThehuman body is quite capaboldealing
with day to day variations of exposure provided its defence mechanisms are not

overburdened.It is of course almost impossible to try and define, let alone assess,
every possible combination of substances to which a person may be e xposed
daily. There is however some obligation to try to assess the impact of the
exposure to combinations of certain products when the extant and type of their

usage is known

For example, in agriculture, crop protection operators are sometimes exposed to

more than oneagrochemicaleither, through applying productsin combination or by
sequential application of more than one individual product. In the context of crop
residuesit may be possible for consumers to ingest the residueof more than one
product present in foodstuffs. In cases such as these, questions are s ometimes

raised whether the health assessment of exposure t o a combination of
components is different from that expected of the individual components . This
paper reviews the factors that should be taken into account when making such

assessmentsand describes howsafety evaluations should be undertakenin these
circumstances.

2. Definitions

The investigation of combined effects basically involves the comparison of affect
equivalent:In the context of this paper the following effects are differentiated and outlined
by Doull et al (.1)

27Annex 20

i

28 Annex 20

ACTION OF GLYPHOSA TE IN THE PLANT

TRANSLOCATION
ABSORPTION

*CHLOROSIS NECROSIS OR
DEATH

PRODUCT AND MODE OF ACTION

GLYPHOSATE (C 3 80P5

O O
II II N (phosphomethyl) glycine
OH-C-CH2-NH-CH2-P-0 Isopropanolamine salt

I
OH

MODE OF ACTION

• Exclusive amino acidsof plants are not synthetized by animals: lysine, isoleucine, methionine and veline.
• Glyphosate inhibits synthesis of chemi» synthesis of amino acids: (two words illegible) and
tyrosine

29Annex 20

OPERATING PARAM ETERS OF THE PROGRAM FOR THE ERADICATION OF ILLICIT CROPS BY AERIAL
SPRAYING
PARAMETER UNIT/MEASURE VALUE OR RANGE VALUE OR RANGE

COCA POPPY

FLIGHT ALTITUDE Meters Less than 25 Less than 12

Aircraft speed Miles 120 -150 T 65 120 -150 T 65 j

Cargo of Aircraft Gallons 350 - 500 200-350

Discharge expected Liters/hectare 234 (30-50 drops/cm2) 50 (15-20 drops/cm2)

Deposit of mixture mm3/cm2 0,40-0.70 0.20-0.50

Droplet size Microns 300-1500 300-1000

Hours of application Optimum hours 5:30 to 10:00 a.m.
5:30 to 10:00 a.m.

4:00 to 5:00 p.m.

Magnitude of recovery In % of the spraying >80% >80%

Pump pressure Pounds per cm2 (psi) 20 to 25 20-25

Expected drift Meters <5 <2

Swath width Meters 30-52 16-20

T.V.B. Nozzles hole mm 2 2

Ambient temperature Degrees Celsius <32. 13

Wind KNOTS <4 <4

Relative humidity Percentage >75 >75

Notes:

(1) In the case of the OV-10 aircraft, this speed is 170 knots.
(2) These are the most adequate times, however, operating time may be extended depending

wind speed.

Operating and technical parameters of the process are within a continuous enhancement program.

30 Annex 20

COSMOAGRO

Technical specification 313.0M 3ay30/94

COSMO -FLUX® 411F
Coadjuvant of Agrochemical application

Lie. ICA05.4 2-2186 - Colombia

Specifications

Classification Spraying additive

Chemical description Mixture of Mineral oil and non-ionic specialized surfactants

with coupling agents
Active Ingredient Mixture of Mexitan esters. Linear EPA regulation:
Tolerance exempt under
alcohols + aryl ethoxylate,
Mixtures of stereospecfiinon-ionic regulation 40 CFR 180.1001 (
tensoactive based on ethoxylated c);{e)
propoxylated linear alcohols with small

quantities of aryl ethoxylated compound.
Active Ingredients Liquid isoparafins EPA regulation: Tolerance
Highly pure, very low phyto-toxicity, exempt underregulation 40
content of aromatics and low superficiCFR 180.1001 (c);(e)

stress isoparafinlc oil that enhances
humectability, thus promoting efficacy of
active ingredients.

General characteristics

Appearance at 25°C Yellowish liquid

Flash point >148°C
Specific gravity 0.89

Viscosity at 25°C 60mPa
pH in (illegible) solution of distilled water Between 63 and 6.8

Solubility

(Illegible) oils Soluble

Vegetable oils Soluble
Organic solvents Soluble

Water Dispersible, forming a rapid
emulsion

31Annex 20

COSCOSMOAGRO

Characteristics of Mixtures generated with COS -FLUX® 411F

Homogeneity Excellent
Persistence <24 hours

Compatibility with active Excellent (see ANNEX "Assessment of physical compatibility''
ingredients
Mixture speed Rapid

adherence Excellent

Toxicological summary

Classification by Ministry of healthToxicological concept LP -0593 corresponding to

(Colombia) TOXICOLOGY CATEGORY IV- SLIGHTLY TOXIC (G reen
band)
Classification as poison Not classified

Irritation in rabbit eyes Virtually non-irritant
(according to Kay D. Calandra's application)
Irritation in rabbit skin After 24 hours of non- diluted application, small irritation

could be observed.
Sensibility in human skin Does not cause irritation nor sensitization in human
skin,

Biodegradability (OECD's method for Non-ionic components of COSMO -FLUX 411F have
non-ionic tensoactives) biodegradability of <90%

First aid In any case, you must saeedoctor

Skin contact Wash with water and soap

Eye contact Wash immediately with abundant clean water or eye-
wash solution for 15 minutes

inhalation Symptomatic treatment
Ingestion Do not induce vomit Drink milk or water,

Symptomatic treatment
See a doctor and show him the label

32 Annex 20

READ THIS LABEL COMPLETELY BEFORE USING THE PRODUCT

COSMOFLUX

411 COSMOFLUX 411 F
SALES LICENSE
COADJUVANT
Colombia I.C.A. No. 2186 BIODEGRADABLE
Ecuador MAF No. 03199075
NON-IONIC
STEREOSPECIFIC ACTION
GUARANTEED COMPOSITION

t-.M n:
ACTIVE INGREDIENTS :

Ethoxylated -aryl ethoxylated linear 17%
alcohols

Mixturesof stereospedfno-inonictensoacbased
on ethoxylatedpropoxylated linear alcohols with small
quantities of aryl ethoxylated

83%
ADDITIVE INGREDIENTS

20 litres

NET CONTENT 200 litres

Calle 42 No. 30-39 Telélon ■ (S2) 2?5 1a 81 Fax: (92) 273 SG 76 Palmira (V )
COLOMBIAN INDUSTRY

•**"**«sw

TOXICOLOGICAL CATEGORY IV

SLIGHTLY TOXIC "USE WITH CARE"

PRODUCTS REGISTRATION PROCESS OF FOR CROP PROTECTION .COLOMBIA

ICA

Relevant National
Authority

Health Ministry Ministry for the Environment ICA

Experimental Permit Import Environmental License Agronomical Efficiency Tests

Toxocological Opinion Impact Assessment Per Crop Per Plague

1. Physical-chemical properties

2. Mechanism of Action
3. Acute Toxicity
4. Sub-acute Toxicity
5. Chronic Toxicity

3334 Annex 21

NATIONAL NARCOTICSDIRECTORATE (DNE),ENVIRONMENTAL
IMPACT OFLLICITCOCA CROPS AND THEIERADICATION BY

AERIALSPRAYING WITHG LYPHOSATE IN TBEI-GEOGRAPHICAL
REGION OF THC OLOMBIANA MAZON ANDO RINOCOBASINS,
DECEMBER 1994

(Archives of the Colombian Foreign Ministry)

3536 Annex 21

MINISTRY OF JUSTICE

NATIONAL NARCOTICS DIRECTORATE

ENVIRONMENTAL IMPACT OF THE ILLICIT COCA CROPS
AND THEIR ERADICATION BY AERIAL SPRAYING WITH
GLYPHOSATE IN THE BIOGEOG RAPHIC REGION OF THE
COLOMBIAN AMAZON AND ORINOCO BASINS

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       1
Santafé de Bogota D.C. LUIS EDUARDO PARRA P
December 1994 Head of Environmental Audit
Illicit Crop Eradication
1. INTRODUCTION

The millennial existence in South America of over 200 species of the 250
Erythroxylum species that exist throughout the world, forming the floral composition

of the so-called cocas, is the clearest example of humanity’s poor use of a lush
nature, by giving only two of the species, E. coca and E. novogranatense, some
use for cocaine production purposes.

The most serious of the associated problem s is the environmental deterioration of

valuable –and still poorly scientifically understood– ecosystems. This is particularly
true in the case of the Colombian Amazon and Orinoco regions.

Little or nothing is known about the serious environmental consequences of the
cultivation and production of the coca paste. However, there is plenty of evidence

that both activities have a lasting impact with irreparable consequences in the
ecosystems developed today.

The devastation of a number that ranges between 160,000 and 240,000 hectares
of lowland tropical forest means about 30% of the annual deforestation rate in

Colombia for several reasons. This destr uction in ecological terms represents, for
the country and its people, the loss or impairment of:

− 380 tons/ha of biomass 1, for a cumulative deficit of 60.8 to 91.2 million tons

of biomass that have been turned water bodies to ashes and sediments.

− Some 210 species of mammals reported in the Colombian Amazon,
seriously endangered by habitat alteration.

− In other animal species the numbers are: 600 birds, 170 reptiles, 100
amphibians and 600 fish.

− In flora, danger is encroaching on some single species in the world

(endemism), since 80% of all reported tree species only exist in this biome.

− In the case of the Colombian Amazon region, there is risk of deforestation

associated with illicit crops on 96 to 120 species of trees/ha with more than
500 individual trees per hectare. This represents losing 140 m 3/ha of wood

of which 30% have proven commercial potential.

− Unknown biogenetic potential and with great pharmaceutical, food,

recreational and economic value.

                                                       
1 The figure of 380 Ton/Ha is an index according to Klinge (1972).

 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 
 

37Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       2

− The Sierra de la Macarena biome, considered unique in the world by
UNESCO scientists and experts for its biophysical characteristics. Without a

doubt threatened before the nation’s dauntlessness.

− A valuable accumulated flow of the rivers Vichada, Guaviare, Caquetá,
Putumayo, Apoporis, Inirida, V aupés, Guainía, Orteguaza, Caguán and

Amazon.

− Structural heterogeneity of the ethnic groups inhabiting the region. This
wealth, also threatened today, is represented in 52 ethnic groups divided

into 15 linguistic groups which posses a sociopolitical, territorial and
culturally well-defined reality.

 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
  Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 

38 Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       3

2. ECOLOGICAL CHARACTERIZATION OF THE ILLICIT COCA CROP

Illicit coca crops in Colombia are subst antially located in different biogeographic
regions, that is, with areas by region, which easily surpass the figure of 1,000
hectares.

Among them the following can be mentioned:

a. Serrania de San Lucas . A nature reserve that has significant coca crops
(Erythroxylum coca, Var coca and E. Novogranatense). These varieties are

grown and processed locally. The ex istence of such crops has been
reported since 1988. The serrania (mountai n range) is located in southern
Bolivar Province.

b. Provinces of Cauca and Nariño. This nucleus is located south of the
Cauca and north of Nariño. These crops date from the 80’s and have settled
in smallholder rural areas and indigenous reservations. Mainly E.

novogranatense is grown.

c. Biogeographic regions of the Amazon and Orinoco Basins . The areas

with the highest individual crop-cultivated land are located here, by plots or
as nuclei. The estimated coca surface is between 40-60 thousand hectares.
In cases a and b, the crop develops in undulating to hilly physiographic landscapes

(slope crops), at altitudes ranging from 500-1500 m.s.l. and at temperatures
between 24° C and 20° C on average. Rainfall varies between 1,500 - 2,500 mm
per year on average. In general, crops are medium sized (2.0 to 6.0 hectares) and
small (less than 2.0 hectares). Also, most owners are colonizers who settled over 5

years before, or marginal rural economy farmers and indigenous communities.
In the third case (c), which constitutes the central focus of this report, coca
cultivation is developed, perhaps, in the biogeographic region with the largest

biodiversity in the world: the Amazon. And to complete the stage, next to it, that is,
in the Orinoco, the existence of coca cult ivation is also the main activity of the
colonization fronts. Next, the document will refer to this natural area specifically.

2.1 COCA CULTIVATION IN THE ORINOCO BASIN

The entire region covers an area of 23,096.725 ha which correspond to 20.23% of
the national 2surface, which are an integral part of the provinces of Arauca,

                                                        
2 Soils and forests of Colombia. IGAC, Archaeology Branch. 1988

 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
  Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 

39Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       4

Casanare, Meta and Vichada. In the case of coca, the region of interest is the one
that extends to the south of Vichada River and to Guaviare River, as well as the

natural reserve of high biodiversity and ec ological value known as the Sierra de la
Macarena.

Briefly, some of the ecological considerations of these biomes are listed:

2.1.1 Natural Plains with Gallery Forests and Transition Forest Biome

These are areas with predominantly flat to undulating landscape bearing dissected
terraces, where a transitional vegetation of tropical very wet forest of the Amazon
and the less humid savanna vegetation of the Orinoco River grows.

The flora consists of trees up to 35 m high and a diameter ranging between 40-100
cm., palms and grass or smaller species such as heliconia, Heliconia bihai and
Tarriago (Euphorbia lathyris).

The eco-system interaction of the gallery forest (borders of streams and rivers) and
water body (flow, aquatic flora and fauna) is the most important biotic and

ecological relationship and it is seriously threatened by the coca crops.

The future persistence of water resources in that biome depends, in great part, on

this ecological balance.

2.1.2 Sierra de la Macarena Biome

This corresponds to a set of ecosystems that occur, as a special biome of the
Colombian Andes, in isolation. It has three thermal floors (warm, temperate and
cold) with different types of forests. Their flora richness is unquestionable,

becoming a unique gene bank for the region and country.

2.2 COCA CULTIVATION IN THE AMAZON

This biogeographic region covers an area of 39,205,918 hectares, of which 81%
are natural forests (32,349,775 hectares). Vegetation is composed of several
layers (3 or 4), with tree canopy reaching up to 40 meters. It consists of the

provinces of Guaviare, Amazonas, Putumayo, Guainía, Vaupés and Caquetá.

The region is divided into three major biomes:

2.2.1 Dense Forest of the Amazon, Pu tumayo, Caquetá and Apoporis Rivers
Biome

                                                                                                                                                                        

 
 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
  Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 

40 Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       5

This is the first south-north large region with little or no human intervention. This
flora consists mainly of large trees (40 m high) with extended epiphytes and

parasitism. The understory is dense and rich in species. Its rich fauna is immense
and with proven ecological and economic value.

2.2.2 Dense Forest and Terrace Plains and High Erosion Surfaces of the
Vaupés Biome

Composed of under-dissected terraces with less dense forest, up to 40 m-tall trees

and abundant epiphytes and parasitism. Natural rubber grows in almost
homogeneous patches in regions close to Miraflores and Mitu.

In the previous two biomes Coca crops are located in these nuclei, namely:

Putumayo Province: Guaumués River Valley, La Hormiga, Orito, San Miguel

and Puerto Leguizamo

CaquetaProvince: Cagúan River, Tres Esquinas region upward, and Cartagena
del Chaira

GuaviareProvinceS : an José-Calamar-El Retorno, Tomachipán, Sierra de la
Macarena and Miraflores

2.2.3 Mixed Forests and Plains of the Guainía Region Biome

Consisting of by high terraces and flat to undulating topography, sandy soils of the
Guiana Shield. The size of the trees decreases from 30 m in some places to 10 m
in others, and their trunks are thinner than in the other two biomes.

In general, in both the Orinoco and the Amazon, the soils are characterized by:

− Low to extremely low organic carbon content (1.5% -0.5%).

− Organic matter undergoes a rapid process of mineralization that is absorbed
largely by the trees and the rest is washed by heavy rains.

− Very acid soils (pH 3.5) with high aluminum saturation, a situation that is
considered critical for most agricultural crops.

− 90% of the soils are within agrologic Classes V, VI, VII and VIII, which are
considered forest land.

 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
  Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 

41Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       6

− Soils that show all levels of eros ion (slight, moderate and severe) caused

primarily by slash and burning.

− The crop and livestock productivity is considered very low, and improving it

would mean getting a negative return.

 

NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 
 

42 Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       7

3. ENVIRONMENTAL IMPACT OF COCA CROP ON

THE ORINOCO AND THE AMAZON BASIN

Undoubtedly, the greatest loss in ecological terms is derived from illicit crop model
implemented by the settlers and farmers in the region of the Colombian Amazon

and Orinoco basins. The following is a summary of the four (4) categories of
environmental impacts caused by these activities:

a. The first and most obvious environmental impact : is the deforestation of

hundreds of thousands of hectares, whose largest and single vocation, in
more than 90%, is the protection of watersheds, surface water production,
the habitat of countless, unknown record of flora and fauna species and

conservation of land whose vocation is, fundamentally forest. In Colombia,
the Coca cultivation alone has destroyed more than 160,000 to 240,000
hectares of rainforest in the biomes of the Orinoco and the Amazon basins;
along the lines of 30% of the annual deforestation rate estimated in

Colombia.

b. The second environmental impact: the resulting erosion as soils are
unprotected of their vegetation cover in areas where annual rainfall is

estimated between 2,500 and 4,500 mm. In addition, some clay and sandy
soils which actually aid in growing the estates of some extensive farms
whose agriculture and livestock practices are highly deteriorating to the

ecosystems where they are established.

c. The third environmental impact: is the contamination of surface water by
the indiscriminate and uncontrolled use of pesticides (herbicides, fungicides

and insecticides, all of them highly to xic), the intensive use of inorganic
fertilizers and chemical use, highly polluting, in the processing of the coca
base.

d. The fourth environmental impact: and, perhaps the one causing the most
concern in the future survival of humanity, is the destruction of some
unknown and valuable flora and fauna genetic resources. In other words,

without being able to quantify the real dimension, on account of the illicit
coca crops, true gene banks are disappearing; vast habitats of mammals,
fish, insects, etc., and the next generations are being deprived of scenic
beauty, which are uplifting steps of human dignity.

Table No. 3.1 further details the listing of: the specific source of impact (action or
cause), brief description of the action, the impact or environmental impacts

generated, the environmental component affected and the nature of impact.

 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
 Carrera 32 No. 24‐60 
  Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 

43Annex 21

 

TABLE No. 3.1

IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT

ENVIRONMENTAL
ELEMENT AFFECTED
Slash and burning Removal of rainforest vegetation Vegetation Deforestation. Exhaustion of national inventories of flora
(slash and clearing). Lower vegetation destruction, epiphytes and parasites

Uncontrolled fire of felled plant Impact on ecological soil-plant-fauna interactions
material and nearby forest by Decrease in food supply to air and land fauna
indiscriminate fire action. Destruction of native vegetation
Decreased rates of evapotranspiration

Destruction of Biodiversity Floristic richness decrease
Disappearance of endemic species
Loss of Biotechnological potential
Exhaustion of strategic resources

Decreased genetic material and germoplasm bank destruction
Deterioration of ecosystems
Disappearance of valuable and endangered species

Soil Erosion Soil denudation increases erosivity index from high to very high
(1500-3000 Kg-mm/m2)
Loss of detrital formations
Accelerated loss of scarce topsoil

Reduction of microflora and microfauna communities
Loss of soil of agro-ecological vocation
Increased structural susceptibility
Increase annual erosion rate and in mild to severe degree

Increased mass movements (diffuse, runoff and spoon effect)

 

TABLE No. 3.1
IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT
ENVIRONMENTAL
  ELEMENT AFFECTED

Slash and burning Removal of rainforest vegetation Water Impaired streams and Upper watershed destruction or “water sources,” affect primary
(slash and clearing). water supply sources of water
Uncontrolled fire of felled plant Modification of flow regimes
material and nearby forest by Morphological modification of flows

indiscriminate fire action. Decreased quality and quantity of water supply
Destruction microflora, Impact on food chains
Migration and reduction of aquatic species

Sedimentation Increased total solids in water bodies
Pollution of water bodies beds and food chains

Atmosphere Climate change Alteration of local and regional system of rainfall and other
climatic parameters
Increased CO2 in biosphere and increased suspended particulate
matter

Modification of moisture in atmospheric masses by altering rates
of evapotranspiration

Tillage Agronomic preparation of field Vegetation Changing forest types Establishment of monocultures (Coca)

(weeding, make holes, rings, Removal of lower vegetation and break of plant succession
earth up, etc.) Reduced food availability for wildlife
Destruction food chains

Soil Alteration potential use Changing land use, Altered natural disposition of soil structure

 

44 Annex 21
 

TABLE No. 3.1
IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT
ENVIRONMENTAL
ELEMENT AFFECTED

Tillage Agronomic preparation of field Fauna Destruction and decline of Affect species of microfauna
(weeding, make holes, rings, populations Destruction of habitats and ecological niches
earth up, etc.) Disappearance of arthropod fauna communities, insects, birds
and terrestrial vertebrates

Migration of wildlife habitats and other ecological balance altering
local and regional levels

Use and application uncontrolled Soil Desertification Loss of fertility caused by decline in production capacity of goods

and indiscriminate use of and services from the forest
pesticides and inorganic
fertilizers
Pollution Accumulation and persistence of parent molecules in soils

Water Contamination of surface Bioaccumulation of biocides in wildlife populations of streams,
water rivers and swamps and in other food chains
Ion scattering to bodies of water

Increased eutrophication processes in lakes, swamps and old
streams

Wildlife Impact on aquatic, land Biological changes in composition of communities

and air fauna Disappearance of microbiota (fungi and bacteria)

Landscape Changing landscape Disappearance of scenic beauty
structure and primary Destruction of educational science resources to know current or

(visual) qualities past natural processes
Destruction of plastic and emotional values of the environment
Changing view sheds

 

TABLE No. 3.1

  IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT
ENVIRONMENTAL

ELEMENT AFFECTED
Production of illicit Leaf Collection (“scraping”), Cultural Anthropological impact Affecting native communities by pressure on land and foreign
Coca crops paste or base production and agricultural practices
processing to cocaine Decomposition of indigenous cultures

hydrochloride Marketing Disrespect for indigenous cultural values
Destruction of biogeographical sites
Generation of groups of “effervescent economy,” “boom” type
Abandonment of moral and ethical values

Increased administrative corruption
Increased prostitution

 

45Annex 21

 

TABLE No. 3.1
IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT

ENVIRONMENTAL
ELEMENT AFFECTED
Production of illicit Leaf Collection (“scraping”), Socio economic Negative return Decreased ability to produce goods and services derived from
Coca crops paste or base production and ecosystems

processing to cocaine Inadequate change of potential land use
hydrochloride Marketing

Increased local and Unusual demand on sumptuous goods and services
regional inflation Abnormal increase in prices and tariffs for goods and services

Improving regional GDP Increased labor for floating population (employment generation)
Increase family income
Entry of food and agricultural products from neighboring centers
(Villavicencio)

Increased construction indicators

Demand for goods and Dissatisfaction with low supply of public services
services Increased volumes of household waste

Increased risk of parasitic diseases by increased vectors

Increased violence Increased use of firearms deaths
Deteriorating of law and order, increase crime and arms
trafficking

Increased crime rates
Emergence of vigilante groups

Colonization Destruction of nature reserves and national parks affected
Increase of floating population in urban centers

Creation of economic expectations that are impossible to meet
Displacement of indigenous communities of ancestral lands
Conflict over land ownership

 

46 Annex 21

ENVIRONMENTAL IMPACT ILLICIT COCA CROPS       12
 

4. ENVIRONMENTAL IMPACT OF ERADICATION BY AERIAL SPRAYING

WITH GLYPHOSATE

The establishment of illegal coca crops, as seen in the previous chapter, generates
a series of im pacts that can only be lessened or mitigated by a technically and

environmentally sound m ethod of eradication. For this particular c ase the aerial
spraying of glyphosate was considered the method to be applied, always under the
environmental model established for this purpose, which yields better results in

those areas where extensions, by crop plots justify implementation.

On the other hand, the comprehensive solution requires additional efforts within the

framework of alternative development for communities in marginal rural economy
as compensation measures. At large areas of cultivation, with intensive technology
and financial resources, only effective eradication is applicable with programs for

environmental restoration an d cons ervation of n ature rese rves that m ean
tremendous efforts on the national treasury as a cost that the nation assu mes for
having this scourge and socio-environmental disturbing factor.

Aerial spraying with Glyphosate has two environmental impact areas as follows:
a. On the crops themselves
Causing effects connected to the very destruction of illicit crops and which include

the following components: biotic, physical and socio-economic development.

b. On-site natural vegetation

Represented mainly by isolated trees left o n the plots (with epiphytes and parasitic
plants), in addition to the soil of the plot itself, which is specifically and temporarily
affected by the ap plication of glyphosate. However, the magnitude is low and the

duration is temporary (no m ore than 2 weeks) i n t erms of quant ifying t he
environmental impact.

Table No. 4.1 pres ents more detail of t he im pacts cau sed by t he er adication

activities. Manual eradication is not included given it is not being applied, because
the program has focused efforts on plots larger t han 6.0 hectares and up to 50
existing in this biogeographic region.

 
NATIONAL NARCOTICS DIRECTORATE  Luis Eduardo Parra‐Rodríguez 
Environmental Auditor 
Carrera 32 No. 24‐60 
  Tel. 244‐2363, 344‐0323  Fax. (91) 244‐2363 

47Annex 21

 

TABLE No. 4.1
IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS BY AERIAL SPRAYING WITH GLYPHOSATE

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT
ENVIRONMENTAL
ELEMENT AFFECTED

Aerial spraying with Application of a dose of 10.4 Vegetation Coca crop Destruction Elimination by systemic action of the product in an approximate
glyphosate 1iters / ha of Roundup (48%) dose of 1.04 cc of Roundup per plant/m2
dissolved in 60 liters of water- Eventual affectation of epiphytes and parasites

Vegetation restoration Appearance of light-demanding pioneer species and initiation of
succession regenerative processes of forest growth

Soil Timely disposal of water- Residuality of 1 to 2 weeks maximum of mixing ratio that may

Glyphosate mix eventually fall to the ground
microbial biodegradation and Fixing of organic matter present
Low to very low drop of mixture to the ground, Less than 0.1 cc of
Round-up / m2

Low removal of minor native succession vegetation and grasses
present in plots

Social Attacks on security forces Increased acts with a firearm against police

Socio-economic Reduction of regional GDP Decrease in family income and employment decline
Recovery of agricultural activities

Reduced consumption of chemicals and fuels
Closing of business establishments (clubs' (especially liquor)

Social National and international Decrease in local productions of cocaine

supply of narcotics

 

TABLE No. 4.1
IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS BY AERIAL SPRAYING WITH GLYPHOSATE

 
SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT
ENVIRONMENTAL
ELEMENT AFFECTED
Alternative Development of small areas of Socio-economic, Decrease in cultivated State presence and increased citizen solidarity

Development illicit crop production, through cultural, biotic and area Decrease and disappearance of factors of violence
actions to the progressive physical Reduction and elimination Transfer and validation of appropriate technologies
reduction of cultivated area and of factors and causes of Natural and induced environmental restoration
establishing a basis for local and environmental degradation Conservation, improvement and land reclamation

regional development under Improved level and quality Management planning and watershed management
criteria of sustainability and social of life Amazon biotechnology development
and economic autonomy Ecotourism and establishment of community protectors-producers
forests

Control, monitoring and preservation of national parks and
reserves
Return of ethical and moral values
Technical assistance and eco-production and sustainable

marketing
Empowering a “rearguard economy” by small coca crops

48 

TABLE No. 4.1

IDENTIFICATION OF ENVIRONMENTAL IMPACT CAUSED BY ILLICIT COCA CROPS BY AERIAL SPRAYING WITH GLYPHOSATE

SOURCE OF ACTION DESCRIPTION OF THE ACTION COMPONENT AND/OR IMPACT NATURE OF IMPACT
ENVIRONMENTAL

ELEMENT AFFECTED
Aerial spraying with Application of a dose of 10.4 Vegetation Coca crop Destruction Elimination by systemic action of the product in an approximate
glyphosate 1iters / ha of Roundup (48%) dose of 1.04 cc of Roundup per plant/m2
dissolved in 60 liters of water- Eventual affectation of epiphytes and parasites

Vegetation restoration Appearance of light-demanding pioneer species and initiation of
succession regenerative processes of forest growth

Soil Timely disposal of water- Residuality of 1 to 2 weeks maximum of mixing ratio that may
Glyphosate mix eventually fall to the ground
microbial biodegradation and Fixing of organic matter present
Low to very low drop of mixture to the ground, Less than 0.1 cc of

Round-up / m2
Low removal of minor native succession vegetation and grasses
present in plots

Social Attacks on security forces Increased acts with a firearm against police

Socio-economic Reduction of regional GDP Decrease in family income and employment decline

Recovery of agricultural activities
Reduced consumption of chemicals and fuels
Closing of business establishments (clubs' (especially liquor)

Social National and international Decrease in local productions of cocaine
supply of narcotics

 Annex 21

 

ANNEX NO. 1
CHARACTERIZATION OF ENVIRONMENTAL EFFECTS

SPECIFIC SOURCE OF IMPACT IMPACT NATURE OF IMPACT

Tillage Erosion Increased fragility against internal exploitation
• Preparing the ground Increased sediment to streams
• Weeding Reduced vegetation cover

• Peals and hilling Eventual mass movement (diffuse runoff)
• Pesticide Application
• Use fertilizers and correctives

Contamination Modification of chemical and physical conditions of the soil
Destruction of miorofauna
Migration of fauna species
Deterioration of water quality
Effects on the human quality

(Gastrointestinal diseases)

Decreased food Decrease and/or impoverishment of traditional agricultural activities

- Poppy Crop production Improvement Regional GDP Employment generation
• Collection Increase family income
• Storage Waste of windfall profits
• Packing Increased local and regional inflation

• Marketing Import of essential nutrients

Violence Lack of state leadership
Deteriorating law and order
Family dissolution

Increased criminal activity
Increased crime rates
Peasant migration
Socio-cultural deterioration

Loss of values Deterioration of the legal situation
Abandonment of moral values
Corruption

Administrative inefficiency
Increased individualism
Lloss of cultural values

 
 

Figure 3-1

Audit process

Stage 1 Stage II Stage III Stage IV

Preparation Verification Execution Assessment

Information Collection and Detailed aerial reconnaissance, Verification of eradication by Periodic monitoring of sprayed
processing of coca areas GPS location fumigation operations, Site audit areas

Planning aerial surveys for Estimation of plots and total Recognition equipment, product, Identification of environmental and
location of plots area and dose ecological considerations

Identifying sensitive Selection of manual or chemical Coordinate field record Verification of effectiveness of

ecosystems treatment: airplane or helicopter treatment Recognition site in plots

IGAC Pre identification Report to DNE, Ministry of Justice
mapping and Anti narcotics Police

Planning stage Operation and evaluation phase

50 Annex 21

 

Figure No. 3-2

THEORETICAL PRACTICAL CONTEXT OF ENVIRONMENTAL AUDIT

COMPLIANCE�AUDIT�
�������������������and�
Regula ons)�
includes�environmental��
audit�and�directs�the�
audit�process��

�������������������

�������������������

������������������� MULTIPURPOSE�
ENVIRONMENTAL�AUDIT�

PROCESSAUDIT MANAGEMENT�AUDIT�
(Aircra , EEquipment, (Environmental�Development,�
Police,�Organiza on,�A tudes�
Product,Dosage, and� and�Training)�
Technology, Etcc..)

eradication of illicit coca crops

   

TABLE No. 2-1
ACTIONS AND RECOMMENDATIONS - AUDIT OBSERVATIONS

ACTION RECOMMENDATIONS/OBSERVATIONS

AERIAL RECONNAISSANCE • Should be permanent and, if possible daily

• Identification of crop and potential environmental risks

• Selection of treatment: manual, chemical (by plane or helicopter)

• Determination of problem regions (with crops) and estimation of area involved

• Checking mapping, Comparison of coordinates and local and/or province (approximate) jurisdictions

SPRAYING SIMULATION TEST • Accuracy check on the application of the mixture, minimal drift

• Definition of minimal height of flight and identification of obstacles on the ground
Maximum 10 to 12 feet above the ground for the planes

• Review of regional weather conditions and definition of daily range of fumigation, up to at 10 am

• Definition of plots to be fumigated according to the size, Plane for plots larger than 4.0 hectares and for helicopter between 2.0 - 4.0 ha.

DRIFT TEST • Determination of operating conditions for Turbo - Trush aircraft

• Apply mixture of 17 gallons/Ha

• Glyphosate doses of 2.5 liters/ha of commercial product (1.2 kg/ha of glyphosate technical grade)

• Discharge pressure: 10-12 psi

• Optimal weather conditions: temperature ≤ 20º C, relative humidity ≥ 80%, Wind speed less than 2 miles/hour

• An extension of these parameters, see paragraph 2.5.2

Continued...

51

 Annex 21

 

TABLE No. 2-1
ACTIONS AND RECOMMENDATIONS - AUDIT OBSERVATIONS

ACTION RECOMMENDATIONS/OBSERVATIONS

FUMIGATION BY HELICOPTER • For plots between 2.0 - 4.0 Ha

• For lots located below 2,800 meters (8500 feet) in the case of the Bell 212
The Ranger max. at 2400 m.s.l.

FUMIGATION BY PLANE • For plots larger than 4.0 hectares

• In plots at any level of altitude

• Keep nozzles open only on plots with poppy

• Register coordinates for each plot and make records using the PathLink Analyzer program

• Spraying only on preselected plots

EQUIPMENT AND PRODUCT
• Review approved dose (2.5 l/ha) mix In water
CHECK
• Maintenance of nozzles and spraying equipment

• Check water quality used in the mix

• Maintain discharge pressure 10 to 12 psi

INTER-INSTITUTIONAL • With regional and national entities
MEETINGS

• With communities

• With international institutions

IDENTIFICATION OF
• See paragraph 6. 1
ENVIRONMENTAL EFFECTS
• Notify the natural resource management agencies (INDERENA, R egional Corporations) about the environmental impact on biodiversi ty by
deforestation in high-value ecosystems

 

52 Annex 22

C olombian law 30 of1986,
artiCle91,para. G, 31 anuary 1986

(Official Journal No. 37.355, 5 February 1986)

5354 Annex 22

Colombian Law 30
(31 Jan 1986)

Implemented according to National Decree 3788 of 1986
Whereby the National Statute on Narcotics is adopted and other issues
are ruled

[…]

Article 91. The National Narcotics Council has the following duties:

[…]

g) Provide for the destruction of coca, marijuana and other crops from
which substances causing dependence may be extracted, using the
most appropriate means, following the favourable opinion of the

agencies entrusted with protecting the health of the population and the
preservation and balance of the country’s ecosystem.

2

5556 Annex 23

Colombian law 99 of1993,
artiCles49, 52and117, 22 deCember1993

(Official Journal No. 41.146, 22 December 1993)

5758 Annex 23

COLOMBIAN LAW 99 OF 1993

Whereby the MINISTRY FOR THE ENVIRONMENT is created,
the Public Sector in charge of management and preservation of the
environment and renewable natural resources is re-structured,

the National Environmental System –SINA- is organized
and other issues are ruled

[…]

TITLE VIII

OF THE ENVIRONMENTAL LICENSES

Article 49. Of the compulsory nature of the environmental license:
The executions of works, establishment of industries or the
performance of any activity that, according to law and regulations,
may cause serious deterioration of natural renewable resour ces or the

environment[,] or introduce considerable or notorious modifications to
the landscape will require an environmental license.

[…]

Article 52. Competence of the MINISTRY FOR THE

ENVIRONMENT. The MINISTRY FOR THE ENVIRONMENT
will exclusively grant the environmental license in the following
cases:

1. Undertaking of works and activities for exploration, exploitation,
transport, and storage of hydrocarbons and the construction of oil

refineries.

2. Undertaking of large-scale mining projects.

3. Construction of dams or water -collecting areas with a greater
capacity then two hundred million cubic metres and the construction

of electricity generating plants that exceed 100,000 Kw installed
capacity, as well as setting the transport cables of the electric
interconnection national system, and exploration projects and use of
virtually contaminating alternative energy.

4. Construction or expansion of deep-draft sea ports.

59Annex 23

5. Construction of international airports.

6. Undertaking of public Works for national road, fluvial or rail
networks.

7. Construction of irrigation districts for over 20,000 hectares

8. Production and importation of pesticides, and those substances,
materials or products subject to control pursuant to international
treaties, agreements, and protocols.

9. Projects that affect the National Natural Parks System.

10. Projects undertaken by the Regional Autonomous Corporations
referred to in numeral 19, article 31of this law.

11. Transfusing of one basin into another of water streams that exceed
two (2) m/s during low flow seasons.

12. Bringing into the country parent species for reproduction of fauna
and wild flora foreign species that may affect the stability of
ecosystems or wildlife.

13. Generation of nuclear energy.

Paragraph 1. The right to grant environmental licenses for
construction ports will be applied without prejudice to the legal
competence of the General Superintendence of Ports to grant port
concessions. However, the environmental license is a pre -requisite to

grant the port concession

Paragraph 2. The MINISTRY FOR THE ENVIRONMENT will
grant a general environmental license for the exploitation of oil and
gas fields, without prejudice to the capacity of the environmental
authority to add or establish specific e nvironmental terms required for

each case, within the authorized production field.

60 Annex 23

[…]

Article 117. Transition of procedures . Permits and licenses already
granted will continue to be valid through the issuance time period. The
on-going administrative acts will continue its process before the
authorities that take on its competence at the stage they are at. The

regulations and competences established in the current law will enter
in force immediately and will be applied upon issuing of the
corresponding regulatory acts, when required.

6162 Annex 24

NOTE FROM THM INISTER FTRHEENVIRONMENT,MR.JUAN
MAYR MALDONADO,TO THESECRETARYGENERAL OF THE

COLOMBIAN SENAT,10AUGUST 2001

(Archives of the Colombian Foreign Ministry)

6364 Annex 24

MINISTRY FOR THE ENVIRONMENT

Bogota, D.C. 10 AUG 2001

Mr.
MANUEL ENRIQUEZ ROSERO
Secretary General Hon. Senate of the Republic
National Capitol

City

Dear Sir:

I am enclosing the answers to the questionnaire sent to the Ministry
for the Environment based on Proposal 04 approved by the Honorable

senate of the Republic.

I hope to have solved all questions with regard to illicit crops and
sprayings. However, if any additional information is required, we will
gladly provide it.

Sincerely,

[Signed]

JUAN MAYR MALDONADO
Minister for the Environment

Encl.: As announced

65Annex 24

MINISTRY FOR THE ENVIRONMENT

QUESTIONNAIRE TO THE MINISTRY FOR THE

ENVIRONMENT

PROPOSAL 04

1. What are the biophysical and biochemical effects of sprayings
in t he a reas with i llicit c rops an d on flora, f auna, an d water
sources nearby the sprayed areas?

According to the information that the Ministry for the Environment
has related to possible effects that may result from the application of
Glyphosate f or t he er adication of i llicit c rops, under t he c ountry’s

environmental c onditions, t here i s no e vidence of bi ophysical a nd
biochemical changes that affect the flora, fauna, and water sources
structure.

Specialized international literature o1234 ysical and ch emical aspects
and ecotoxicology report as follows :

- Glyphosate is an herbicide that, just like any other pesticide, must be

handled a ccording t o t echnical s pecifications r ecommended b y t he
manufacturer and relevant authorities.

- The physical chemical characteristics of the compound, according to
scientific s tudies, s tate th at it d egrades moderately b y s oil
microorganisms action.

- During this period, the compound is absorbed by the soil, where it
disappears t hanks t o t he m icrobial a ctivity, which pr events i ts
displacement to underground and surface water.

- According to studies, Glyphosate disappears rapidly from water; it is
absorbed by sedi ments and microbial activity. Based on l iterature in

1
Ministry for t he E nvironment. S ome c riteria for e valuation of E nvironmental I mpact
2tudies. Bogota, 1.996
The pesticide manual. The British Crop Protection Publishing Company. Tenth Edition.
3.994
Pesticides Manual. Pesticides Program (Development, Health, and environment). EUNA.
4ditors Luisa Castillo. Universidad Nacional de Costa Rica. 1.995
September. 1.993Pesticides. “ Reregistration Elig ibility d ecision (RED ), G lyphosate”.

66 Annex 24

laboratory conditions it is s lightly to xic f or f ish a nd a quatic
invertebrates, without causing mass death in these species.

- Because of its low volatility, the product does not have any effects in
air.

- The compound, being soluble in water and therefore little compatible
with fatty compounds, has not been proven to accumulate in animal
tissue.

- According to studies reported in specialized bibliography, the

compound is classified as slightly toxic for mammals by oral and
dermal route and by inhalation. It causes slight eye irritation in
mammals.

- In studies reported by the industry, FAO, and WHO neither cancer
effects, nor genetic mutations, are evidenced; no neurotoxic effects are

suspected either.

- For other species such as birds and bees it is slightly toxic.

Now, in order to determine other adequate management measures to

mitigate or control possible effects in the framework of the common
natural conditions present where the programme for the eradication of
illicit c rops is imp lemented, th e M inistry f or t he E nvironment b y

Resolution 341 required the National Narcotics Directorate to develop,
among others, a Contingency Plan, an Inspection, Verification, and
Control P rogramme, a Compensation P rogramme, a nd a R esearch

Program for that purpose.

2. According to Resolution 341 of 2001, the Spraying Programme
does not have an Environmental Management Plan, why haven´t
sprayings been suspended in virtue of the precautionary principle
stipulated in Law 99 of 1993?

To answer that question, it is necessary to make some clarifications
before, namely:

Pursuant to provisions in paragraph g) [article 5 sic] of Law 30 of
1.986, it is the National Narcotics Council (CNE)duty to provide for
the destruction of coca, marijuana and other crops from which
substances causing dependence may be extracted, using the most

67Annex 24

appropriate means, following the favourable opinion of the agencies
entrusted with protecting the health of the population and the
preservation and balance of the country’s ecosystem.

Following on the aforementioned, on 31 January 1.992, the CNE
approved the aerial eradication method by use of chemical agent

Glyphosate for the eradication of opium poppy and then it was
extended to coca and marihuana crops.

Similarly, and in compliance with the aforementioned provision, the
then cal led INDERENA ( National Institute o f R enewable N atural
Resources, for its acronym is Spanish) by note dated 8 October 1993,

ratified the acceptance of the action strategy set by the CNE “pointing
out the importance that must be given to compliance with the specific
and t echnical p arameters es tablished f or t he e radication pr ocess of
poppy c rops a nd t hat m ust be ke pt f or e radication of c oca a nd
cannabis crops” and sustaining the observations made previously with
regard to the “need to have an Environmental Audit for environmental

supervision and control of the illicit crops eradication.”

In i ts t urn, t he H ealth M inistry b y not e da ted 11 O ctober 1993,
addressed to the Narcotics General Director, ratified the validity and
convenience of t he a ction strategy s et b y th e N ational N arcotics
Council, recalling that said Ministry submitted to the CNE a “Health

Plan ba sed on t he e pidemiological s urveillance pr inciples, w hich
becomes, t ogether with t he en vironmental au dit, a s afeguard f or
human health and environmental protection.”

There are also technical studies by the ICA -Colombian Agriculture
and L ivestock I nstitute- (Experimental pha se i n t he a pplication of
Glyphosate for the eradication of sp cannabis in the Sierra Nevada de

Santa Marta. June 20 1984, and experimental phase in the application
of Glyphosate for the eradication of poppy crops. February 1992), in
which it was concluded that Glyphosate herbicide and the equipment
used for its application is effective to eradicate this type of crops and
that no e ffects ha ve be en obs erved ne ither on ve getation nor on
animals.

All th is me ans th at th e a erial a spersion w ith g lyphosate h ad th e
favourable opinion of the environmental authorities of the time and
was in accordance with environmental regulations, duly supported in
technical studies provided by the DNE and as well as those requested
by the INDERENA.

68 Annex 24

Subsequently, the newly created Ministry for the Environment issued
Decree 1753 on 3 August 1994, which in its article 38 stipulated that
“Projects, works or activities that, in compliance with legislation in
force be fore i ssuing of t his de cree, obt ained t he r equired

environmental permits, concessions, licenses, and authorizations will
be allowed to carry on, but the competent environmental authority
may r equire, b y m eans of a r easoned ad ministrative act , t he
submission of environmental management, recuperation or restoration
plans.”

The provision transcribed above is absolutely clear in two aspects:

first, it refers to those activities that had been authorized in compce
with l egislation i n f orce i ssuance of t he D ecree, a nd s econd, t he
relevant e nvironmental a uthority h ad t he pow er t o r equire a n
environmental management plan.

In ot her w ords, a lthough t he s ubmission of t he e nvironmental
management plan is compulsory, it is not a prerequisite for continual

of t he act ivity, w hich as has been s aid m any t imes, w as dul y
authorized in compliance with legislation in force.

In conclusion, the activity of aerial spraying with Glyphosate was duly
authorized in compliance with the environmental legislation in force at
that t ime; t hat i s, Law 30 of 1986 and t he M inistry for t he
Environment in application of the aforementioned article 38, by Order

No. 558 of 1996 submits to National Narcotics Directorate –DNE, as
the entity in charge of coordinating and managing such programme.

In compliance with the above, on 30 J uly 1998, the DNE submitted
the requested document, without including Chapter VII on impacts
identification, which was submitted in December that year.

By O rder N o 599 of 23 D ecember 1999, upon e valuating t he
document submitted by the DNE, the Ministry for the Environment
requested supplementation and broadening of the information based
on the basic consideration that gaps detected in the information made
it di fficult t o de fine ne cessary m easure of e nvironmental c ontrol,
prevention, c ompensation, a nd r estoration t o m itigate pos s ible
negative impacts of eradication.

The DNE appealed Order 599 of 1999, which was set by Order 143 of
March 2000 and a 3-month term was given to submit supplementary

69Annex 24

information and the other requirements established in Order 599 of
1999 were ratified.

On 10 M ay 2000, t he DNE appealed Order 143 of 2000 r equesting

extension to 12 months of the time period established to submit the
additional information. That request was not granted and provisions
set in the Order were confirmed.

On 13 S eptember 2000, t he D NE s ubmitted t he doc ument
“Supplementary information to the Environmental Management Plan

for the Application Glyphosate Herbicide in the Eradication of Illicit
Crops.”

In December 2000, i n a meeting held between the Ministry for the
Environment and the DNE, it made a commitment to submit a more
detailed doc ument w ith r egard t o c haracterization a nd f ocused on

impacts assessment and risk analysis according to what was requested
in t he t erms of r eference f or t he E nvironmental M anagement P lan
foreseen in Order No 558/1996 issued by this Ministry, for Putumayo
area, with a overall perspective for the whole country.

Subsequently, on 30 January 2001, the DNE submitted the document
“Environmental Management Plan based on a ssessment of potential
operation r isk resulting f rom t he e radication of illic it c rops b y
spraying in Putumayo province.”

On 4 M ay 2001, b y Resolution N o. 341 t he M inistry f or t he

Environment di d not a ccept t he E nvironmental M anagement P lan;
reason why it demands immediate application of certain prevention
measures so that they served, ba sed on their development and results,
as f oundation f or t he M inistry t o i mpose t he E nvironmental
Management Plan.

Lastly, the Ministry, by Order No. 516 of last 16 July requested the
DNE t o i nform a bout t he pr ogress s tatus and c ompliance w ith
obligations set in the aforementioned Resolution.

The precautionary principle

The precautionary principle is founded on t he essentially preventive
nature of the action for protection of the environment5 and it has been

5
Juste Ruiz, Jose. Environmental International Law. Mc Graw-Hill. Madrid, 1999.

70 Annex 24

expressly s et since 1982 i n s everal i nternational de clarations. T he
definitive incorporation was set in principle 15 of the Rio Declaration
on Environment and Development, according to which, “In order to
protect the environment, the precautionary approach shall be widely
applied b y S tates according to th eir c apabilities. W here th ere a re

threats of s erious or i rreversible da mage, l ack of f ull s cientific
certainty shall not be used as a reason for postponing cost-effective
measures to prevent environmental degradation.”

In Colombia, the precautionary p rinciple , besides the international

obligations that include it and that were ratified by the country, it was
expressly incorporated in numeral 6 of article 1 of Law 99 of 1993, in
the following terms: “Environmental policies making will take into
consideration the result of scientific research process. Nevertheless,
environmental authorities and individuals will apply the precautionary

principle according to which, where there are threats of serious or
irreversible damage, lack of full scientific certainty shall not be used
as a reason f or pos tponing c ost-effective m easures t o pr event
environmental degradation.”

According t o t he a forementioned, i n t he c ase s praying w ith
Glyphosate, t he M inistry for t he E nvironment considered th at th e
precautionary princ iple does not apply because based on the technical
information contained in the environmental file there aren´t threats of
serious or irreversible damage, as well as there isn’t either absolute

lack of scientific certainty regarding its environmental effects. As it
has been stated in previous occasions, the technical literature on the
active compound does not report evidence of serious and irreversible
damage on the environment.

6 Vienna c onvention f or t he pr otection of t he O zone L ayer a nd its M ontreal Protocol,
Convention on Climate Change, Convention on Biological Diversity, among others.

7172 Annex 25

NOTE 0001-1-92OF17 AUGUST 2001FROM THEO MBUDSMAN

REQUESTING A PUBLIC HEARING TO THENISTER FOR THE
E NVIRONMENT ON THEPROGRAM FOR THEE RADICATION OF
ILLICIC ROPS BYAERIALSPRAYING WITHG LYPHOSATE,AND THE
CORRESPONDING MINUTES OF THE HEARING4A UGUST2001

(Archives of the Colombian Foreign Ministry)

7374 Annex 25

OFFICE OF THE OMBUDSMAN
Bogota, August 17,2001 0001-1-928
Juan Mayr-Maldonado
Minister, Ministry of Environment
Calle 37 No. 8-40
Bogota

Dear Dr Mayr,

As part of the faculties conferred upon us by the Constitution and the law, it is of interest
to the Ombudsman to hold a Hearing with regard to the program for aerial eradication of
illicit crops with glyphosate, and part of the National Plan for the Struggle Against Drugs,
1998-2002.

With this Hearing, the Ombudsman's Office wishes to broaden its understanding as to the
nature and scope of the program, and to unify criteria to guide the tasks of the various
entities engaged in its development, and to become aware of the perception which the
various sectors of society have of it.

With the contribution you have made in this field, I wish to invite you to take part in

discussions to take place on F riday, 24 A ugust 2001, a t 2PM in the Auditorium of the
Ombudsman's Office. In the attached document, please find a specification of objectives
and the agenda for the Hearing, and the terms of reference for your intervention. I would
be grateful if you could put your points of view in writing, and deliver the document on the
day of the hearing. If you have any questions, please contact the Deputy Ombudsman for
Collective Rights and the Environment, phone 3144000, extension 2324.

Cordially
(signed)
Eduardo Cifuentes -Muñoz
Ombudsman

[Page 1]

75Annex 25

OFFICEOF THE OMBUDSMAN

OMBUDSMAN'S HEARING ON THEPROGRAMFOR THE ERADICATION

AERIALERADICATION OFILLICIT CROPS WITH GLYPHOSATE

Background

Law 30/1986 gave the CNE the mission of "providing for the destruction of crops of
marihuana, co ca l eaf an d o ther substances a nd addictive s ubstances, u sing t he most
appropriate means, subject to the favourable opinion of the bodies responsible for public
health and the preservation and balance of the Colombian ecosystem". From that time on,

the strategy for aerial eradication of illicit crops has been founded on the actions of the
health and environment authorities.

In the 1991 Constitution, and subsequent legislation, health, the environment, sustainable
development and biological diversity, amongst other questions, have become issues open
to claims for the protection of fundamental rights, which demand effective mechanisms
for protection from the State as a whole, and the materialization of those rights even in
circumstances of exception, such as the aerial eradication of illicit crops.

Objectives

To broaden understanding as to the nature and scope of the program for aerial eradication
of illicit crops with glyphosate, based on knowledge of the criteria which guide the actions
of State agencies in the design, execution and control of the program, and the perception
of different sectors of society of the program.
[Page 2]

Agenda of the Hearing)

Opening
Part 1 Development of the program for forcible eradication ofillicit crops

1. Background to the program of forcible eradication of illicit crops through aerial
spraying with chemical substances

Organizational matters

Participants and methodology

The Hearing will have two types of participant: Representatives of public agencies that
intervene in the design, execution and control of the program for the forcible eradication of
illicit crops, and members of NGOs and private organizations

The various issues on the Agenda will be approached from the perspective of the type of
participant Each exponent will have a maximum of 10 minutes to present a synthesis of his
main proposals, with regard to the questions put by the

76 Annex 25

Ombudsman, with several days prior to the Hearing. Further to the oral presentation, each
exponent will deliver the document which it is hoped will contain the greatest breadth and
depth of argument and evidence to support the position of the position of the organization
represented.

When the programmed interventions have been completed, other persons present will be

invited to express their opinions on the issues on the Agenda, or the positions proposed
by the various departments.

Place and date

The hearing will be held on Friday, August 24, 2001, at 2p.m., in the Auditorium of the
Ombudsman's Office, Address Calle 55 No. 10.-32 Bloque A

[Page 3]

77Annex 25

OFFICEOF THE OMBUDSMAN

HEARINGON PUBLIC POLICY FOR THE FORCIBLE
ERADICATION OF ILLICIT CROPS

Terms of reference

Proposers:
Julio Cesar Rodas, former Official of the office of the Public Service Procurator for
Environmental Affairs
Juan Mayr-Maldonado, Minister ofEnvironment

Topic
The actions of the environmental authorities in the program for the forcible
eradication of illicit crops

Aspects of interest

The 1991 Constitution brings together a set of rights and duties which together formulate a
right to a healthy environment. This formula, in addition to being an expression ofpopular
will,also implies an option for forms of peaceful coexistence and development, and the
project for the future of society.

Therefore, all decisions and actions of the State must share this sense, and must comply
with the precept. In other words, the State as a whole has a duty to provide project effective
protection to the environment, which entails a guarantee of diversity, and rational use of

resources, and prevention and control of factors of environmental deterioration; in short,
that sustainable development will be achieved.

For these purposes, the Constitution and law have defined several precise criteria of action,
and provide mechanisms instruments for action which are differentiated depending on
circumstances. This is the sense of the principle of precaution, and also that of planning,
consultation, and environmental licensing, amongst others.

In this context, it is of interest to establish:

1. Is the program of eradicationof illicit crops with glyphosate part ofthe transitionregime
provided for in Decree 1753/1994?

2. In the context of the program for the eradication of illicit crops with glyphosate, what is
an Environmental Management Plan? What differences are there between the Plan and an
Environmental Licence?

[Page 4]

78 Annex 25

HEARINGON PUBLIC POLICY FORTHE
FORCIBLEERADICATION OF ILLICIT CROPS

Terms of reference
Topic Environmental
audit

Aspects of interest

1. Report on environmental audit made by the program for the eradication of illicit drug

crops with glyphosate (functions pursued, and impact on the program), and progress in the
definition of terms of reference for the contracting of environmental audit and inspection in
the context of Resolution 5/2000 and Resolution 341/2001. Proposer, Gabriel Merchan,
DNE.

2. Report on the execution of environmental audit contracts signed by DNE.

Proposer: Dr Carlos Ossa-Escobar, Comptroller General.

3. Terms of reference for the technical audit and inspection in the context of Resolution
5/2000 a nd R esolution 341/ 2001. Expectations of t he e nvironmental authority, i n
accordance w ith p recepts o f the co nstitution an d t he law. Proposer: D r Juan M ayr-
Maldonado, Minister of Environment.

[Page 5]

79Annex 25

HEARING OF THEOMBUDSMAN

1. Is the program for the aerial eradication of illicit crops with glyphosate
registered as part of the transition regime of Decree 1753?

A. In accordance with Section g) of Law 30/1986, it is the duty of the CNE to "order the
destruction of crops o f m arihuana, c oca l eaf and ot her s ubstances a nd addictive
substances, using the most appropriate means, subject to the favourable opinion of the
bodies responsible for public health and the preservation and balance of the Colombian
ecosystem".

Based on this, on January 31,1992, CNE approved the method of aerial spraying through
the employment with the use of the chemical agent glyphosate to eradicate opium poppy
crops, and this was subsequently it expanded to crops of coca leaf and marihuana.

Likewise, and following the same provisions cited, INDERENA, in a letter of October
8, 1993, ratified to DNE that it accepted the strategy of the action set by CNE in its
communication of January 31, 1992, and repeated the importance of observers of specific

technical regulations established for the process of crops of opium poppy, coca leaf and
marihuana, a nd t he ne ed t o ha ve an e nvironmental audit, t o s upervise a nd provide
environmental control ofthe eradication process.

CNE, as the senior authority on policy on the illicit drugs, issued Resolution 1 of February
11,1994, approving aerial spraying with the chemical agent glyphosate to eradicate illicit

crops, having received the pronouncement of INDERENA and the Ministry of Health,
competent at that time to do so.

Given t hat t he pr ocedure was a uthorized p rior t o t he creation of t he M inistry of
Environment, t he e nvironmental m easures w ere c overed b y the tr ansitional r egime
established by Article 38 of Decree 1753/1994, which establishes that project, works or
activities which, in accordance with laws in force prior to the issue of this decree, had
obtained permits, concessions, licences or authorizations of an environmental nature, as

then required, might continue, but the competent environmental authority might require
them, t hrough m otivated or der, t o pr esent environmental m anagement, r ecovery a nd
restoration plans..." [Page 6]

Therefore, this Ministry, in Order 558A of August 13, 1996, ordered the presentation of
an Environmental Management Plan in accordance with the terms of reference given by
DNE, as the body responsible for directing and administeringthat program.

This administrative instrument should contain the following points:

- Identification of impacts which the eradication program may cause to
environmental, physical biotic and social economic components in the areas

80 Annex 25

selected
- Evaluation of the offer and vulnerability of ecosystems exposed to the action

glyphosate
- Identification of critical, sensitive and environmentally important ecosystems, and
national Nature Parks to be excluded from the program or to receive special
management.
- Design of programs for follow -up and control of environmental aspects in the
program

2. In the context of the program for aerial eradication of illicit crops withglyphosate,

what is an Environmental Management Plan? What difference is there between a
plan and an environmental licence?

A. An Environmental Licence is an administrative instrument through which the
execution or development of projects, works or activities that may cause significant
environmental impact or impact on renewable natural resources may be to be executed or
developed.

This authorization is supported by a tool known as the Environmental Impact Assessment
(positive or negative), specifying the impact that these projects, work s or activities may
cause to the environment, whether in relation to their proper or intrinsic characteristics, or
location in areas of special management, or for reasons of vulnerability and sensitivity of
the environment in which they are located. This assessment is made ex-ante, that is, prior
to the execution of the project, basically in the prefeasibility and feasibility phases of the
project, in order to evaluate their cost -effectiveness, and therefore take decisions with
regard to the convenience or otherwise, as a function of variables all kinds such as

technology, environment, social and economic considerations

The assessment of environmental impact is a tool which can be used at different points or
instances in the planning, development and execution of projects, works activities, but in
each case, the results are different. If the exercise is ex-ante, it means that a determination
can be made whether the project can be undertaken or not, and if it can, what conditions,
terms or obligations apply; f it is made during the project or exposed, and the intention is

to adjust the that different conditions or measurements of environmental management
provided for, in order to exercise effective control on the impacts caused; and in this latter
case, it is the basis supporting the environmental management, recovery and restoration
plans of the activities in the transition regime.

In consideration of the foregoing, the Environmental Licence should be required only for
projects, works activities which are projected into the future, and not projects, works or
activities which are already being undertaken, since there is a presumption of legality that
such projects, works or activities m ust have started execution under the legal and

administrative rules then applicable, and because the decision to undertake them was
taken at the appropriate time, and therefore

81Annex 25

the correct course is to review performance and adjust it, as a function of the various
impacts generated, should they not have been foreseen during the planning phase.

Therefore, the Environmental Licence as an instrument is a development of the
obligation of the State to secure development planning, f or the purposes of controlling
deterioration of the environment.

It is illogical to require an Environmental Licence for an activity which is already in
progress, since the environmental studies which support an Environmental Licence are
designed in the first instance to determine whether the activity can be undertaken; and

then, if it is possible, on what conditions of environmental management, for the purpose
of controlling impact or managing it in such a way that it may be possible to make a cos-t
effective weighting of the convenience or otherwise of undertaking or developing the
project, work or activities.

Now, in relation to project works activities in the transition regime, that is, those which
were already in progress in Colombi a prior to 1993, the intention in regulations, and in
scientific techniques (Assessment of Environmental Impact) is the possibility of making a
review of the conditions under which the activity is being pursued, in order to adjust those

conditions through an Environmental Management Restoration or Recovery Plan, but
never in terms of demanding an Environmental Licence.

The Environmental Management Restoration or Recovery Plan for activities in the
transition regime aims, as its name suggests, to determine (subject to express review and
assessment of the kind already adopted), and to define measures of environmental
recovery or restoration management, as the case may be, so that the project, work or

activity will meet the new requirements of an environmental nature, in order to manage
environmental impacts which as it has not been possible to control or mitigate.

This implies that the activity of is already in progress, and that it will continue to be
developed. Nonetheless, if the environmental authority, after a review of actions taken,
considers it convenient to adjust the environmental management measures which are being
applied to the activity, it may demand that this be done, and thefuture development of the
activity must be re-planned and re-adjusted, with regard to the relevant points, in order to

adapt to new legal requirements.

That is to say, the activity must be the object of new planning actions in order to correct
the impact of the impacts being caused, but in that instance, there is no option to take
decisions such as to proceed or not with developing activity, since the activity is part of
the transition regime.

(See attached chart)

82 Annex 25

3. In the absence of an Environmental Management Plan or Environmental
Licence, how has control and supervision been exercised over actions
undertaken in the context of the program for aerial eradication of illicit crops
with glyphosate?

A. The following follow-up and monitoring activities of the program for the eradication

of illicit crops are set forth in CNE Resolution 1/1994 and Resolution 5/2000, for
implementation by a technical audit.

Likewise, Ministry of Environment Resolution 341 of May 4, 2001, establishes a series of
preventive measures designed to secure appropriate environmental management of the
eradication of illicit crops.

With regards to attention to complaints:

• A request has been sent to the competent CARs, to make verification visits and
send in reports about complaints

• DNE and DIRAN have been asked for information with regard to activities
undertaken in places where complaints originate

• Complaints which are not of an environmental nature have been sent to the
competent authorities

• A proposal has been made to the need to improve the processing of complaints
currently managed by DIRAN.

Further, the following activities have been undertaken:

• Reactivation of the meetings of the inter-institutional Technical Committee for the
program of eradication of illicit crops, to adjust itself to technical and
environmental procedures.

• A proposal has been made to amend CNE Resolution 1/1994.

• A proposal has been made to contract a technical audit, which will be external and
independent of the entities engaged in the program

4. In the absence of an Environmental Management Plan or Environmental
Licence, how has the right to participation and the State'sresponsibility for
planning been guaranteed?

A. Given that the development of an activity is an integral action which involves
environmental, social and economic impacts, in which environmental management is only
one part of the whole, civic participation in this type of project, in addition to
administrative instances as such, can be exercised with the environmental

83Annex 25

authorities if they are in order; and there are other instances of participation of a general
nature, as described below.

If an Environmental Licence is to be a requirement (that is, if in the case of new projects,
works or activities), the instances of participation before the environmental authorities, in
accordance with the law, are: the right to intervene inthe administrative action, the right

to request public hearings, subject to compliance with requirements of law, prior
consultation in the case of projects which affect ethnic communities, and the right to make
petitions for information and consultation.

With regard to civic participation in initiative process of an environmental nature arising
with the involvement of the Ministry of Environment, the exercise of this right has been
guaranteed as follows:

The file related to the program for the eradication of illicit cro ps through spraying with

glyphosate (No. 793), has been consulted by all persons who have made a request to do
so, taking account of the fact that the files passing through the Ministry of Environment
are of a public nature.

The right to intervene in Envir onmental Administrative Proceedings has been applied,
and in effect has been exercised in relation to the file in question, consulted by the
Ombudsman, FUNDEPUBLICO, Claudia Sampedro and Hectgor Alfredo Suárez-Mejía,

who were recognised as third parties intervening in the process, and who had been served
notice of the respective orders based on the recognition under Articles 69, 70 and 71 of
Law 99/1993.

During the environmental administrative process pursued in this Ministry, a request from
the Ombudsman has been studied with regards to the holding a public hearing.

Likewise, the various petitions for information presented by authorities and private

individuals in general have been attended to, in relation to the process of the project in
question (Article 74, Law 99/1993).

Although planning is an ex-ante-exercise, that is, it is prior to the taking of a decision to
execute what is planned or not, it is also a dynamic action over time, especially where the
environment is concerned, since the tools of evaluation of environmental impact allow
planning of the project to be adjusted so that the impacts which may potentially be caused
(ex-ante-evaluation) may be adjusted to the impacts which are actually produced, and to

the results which measures for management, control and mitigation (evaluation exposed)
that have been adopted, in order to produce adjustments and re -planning.

In accordance with the foregoing, the State is guaranteeing theanpl ing of the use of natural
resources in all cases, whether in the form of a demand for an Environmental Licence,
or with the production of Environmental Management

84 Annex 25

Plans, because in both cases, there is insistence on evaluation, whether before or after the
environmental effects of action, in order to determine that they be foreseen or corrected,
as the case may be.

At the same time, the Stated duty to plan in the program of the for the eradication of illicit
crops is also provided for in CNE Resolution 1/1994 and Resolution 5/200w 0,ith regards to
the preliminary procedure required prior to the implementation of eradication of illicit
crops.

Ministry of Environment Resolution 341 of May 4/2001, establishes some obligations for
account of DNE, designed to in relation to the planning of activities, and the creation of
mechanisms for dissemination to the communities (Articles 5and 9)

It is important to clarify that the pursuit of aerial spraying activities for the eradication of
illicit drug drugs crops with glyphosate is part of the National Policy for the Struggle
Against Drugs, known as the "National Plan for the Struggle Against Drugs Colombia
1998-2002".

In consequence, this National Plan for the Struggle Against Drugs Colombia 1998-2002 is

the framework on which the Colombian State will, with the concurrence of government
agencies, NGOs, the organized community and the population in general, mount a
comprehensive fight against the causes and manifestations of the problem of drugs.

85Annex 25

WHY AN ENVIRONMENTAL MANAGEMENT PLAN AND NOT AN

ENVIRONMENTAL LICENCE?

ENVIRONMENTAL MANAGEMENT PLAN ENVIRONMENTAL LICENCE
The Plan gives details of actions required to prevenAuthorization delivered prior to development of the
mitigate, correct and compensate for possible negative
activity, which in accordance with law or regulation may
environmental impacts caused in the course of the acproduce serious deterioration to natural resources or the
Includes plans for follow-up, evaluation and monitorenvironment, or introducesubstantial changes to the
contingency plans (Article 1, Decree 1753/1994) landscape. The license establishes r equirements
obligations and conditions which the beneficiary must
observe in order to prevent, mitigate correct or
compensate the environmental effects of the activity
(Article 49, Law 99/1993, Article 2, Decree 7053/1994)

As under Section 38.1 of Decree 1753/1994, projects whichSection 38.3 of Decree 73/1994 states that activities
are obtained environmental authorizations formerly initiated prior to Law 99/1993, do not require an
required may continue, but the envonmental authority environmental licence, but that this is no bar on

may issue a motivated decision ordering the presentacompliance with environmental regulations. Further,
of an Environmental Management Plan (Order 558 Article 52 of Law 99/1993, establishing the exives
A/1996). competency of the Ministry of Environment to grant
Environmental Licences, did not provide the activity of
eradication of illicit crops with glyphosate as an activity
requiring an Environmental Licence
In a decision of the Council of State of October 27,1995, in
Section 1, Administrative Disputes, taking account oSection 91 g) of Law 30/1986 states that CNE will order
91 g) of Law 30/96 and Article 38 of Decree 1753/199the destruction of illicit crops subject to thandrior
concluded that "the activity oferadication of illicit crops isfavourable opinion of the entities responsible for the
governed by the transition regime, and in order to
preservation and equilibrium of Colombia's ecosystem
implement it, CNE must comply with the regulations (Ministry of the Environment), and the health of the
applicable at the time, and in the opinion of the Copublic (Ministry of Health), ad not subjectto the
State, there is no breach of Law 99/1993 or provisioobtaining of an Environmental Licence.
the Constitution invoked by the claimants, and therefore in
decision for the execution requested is not in order .

CONCLUSION: the destruction of illicticrops by spraying with glyphosate was initiated and authorized prior to the
creation of the Ministry of Environment (CNE Resolution 1/1994), INDERENA opinion of October 8,1993), and
for this reason, the activity does not require an Environmental Licence but does require an Environmental
Management Plan in accordance with the terms of Article 38 of Decree 1753/1994, shared by the Council of State. At
the same time, account should be taken of the fact that both the Environmental Licence and Environmental

Management Plan are instruments designed to prevent, mitigate, correct and compensate the negative impact of
inactivity. Neither Article 52 of Law 99/1993 nor Article 7 of Decree 1753/1994 states that the application of
pesticides requires an Environmental Licence, and therefore the aerial spraying with glyphosate is not an object of
Environmental Licensing.

86 Annex 26

NOTEN°01888 FROM THENATIONALNARCOTICSD IRECTORATE

(DNE),APPEAL SUBMITTED DNE, OFO RDER599OF 1999FROM
THE MINISTRY FOR TEENVIRONMENT,1FEBRUARY2000

(Archives of the Colombian Foreign Ministry)

8788 Annex 26

REPUBLIC OF COLOMBIA

Ministry of Justice and the Law
National Narcotics Directorate

Santafé de Bogotá D.C. 01888 FEB 01

GUILLERMO ACEVEDO-MANTILLA
Deputy Director of Environmental Licenses

Ministry of the Environment
Bogotá. D.C.

RE: Transfer Order No. 599 of December 23, 1999

GABRIEL MERCHAN BENAVIDES, of age, residing in this city, identified with Id. card No.
3.226.822 from Usaquén, in my capacity as National Narcotics Director, a position for
which I was appointed by Decree 1362 o f July 23, 1999 and sworn in by Minute 380 of

August 20, 1999, through this writing and still within the legal term, do lift the transfer of the
Order of the reference based on the following:

WHEREAS

In connection with the statement made by the Ministry for the Environment on the request
of attaching Chapter VII of the Environmental Management Plan (Identification and
Assessment of Environmental Impact) by official letter dated November 13, 1998 for not
having been included in the initial submission, we clarify that the Environmental

Management Plan document was presented in its entirety to Office of the Deputy Director
of Environmental Licenses on July 30, 1998, as recorded in official letter No. 11430 of the
National Narcotics Directorate.

1. On the Opinion of ICA: Aspects of the Management Plan.

Page 6

The request for the Environmental Audit payroll does not apply since this request is out of
context given that the purpose of this evaluation is the Environmental Management Plan
for the eradication of illicit crops with glyphosate.

[ Page 1]

The ICA calls into question the eff ectiveness of spraying aircraft, including the eradication
program. The most striking demonstration to evaluate the effectiveness of the aircraft is
sampling or verification conducted on the coca fields sprayed with Glyphosate. Based on

the verification protocol signed by the governments of Colombia and the United States to
evaluate the effectiveness of the applications , such activities have been developed and
have shed efficiency above 90%. Engineer agronomist Orlando Briñez (ICA official)
attended t he verification protocol conducted in October 1999 and endorsed the

89Annex 26

effectiveness of the application, as recorded in the minutes of the Anti -Narcotics Police
signed on October 20, 1999 (see attached copy).

Pages 9 and 11

Reconnaissance activities of illicit crops have been developed regularly, and the various
state entities have been extended invitation to participate. Suffice it t o say that officials

from the Ministry for the Environment, Plante, National Parks and Attorney General ’s
Office were invited to the Air National Census of illicit crops developed in March 1999. This
same process is currently being developed with the interagency participation of such
entities.

The spraying of illicit poppy crops was authorized by the National Narcotics Council in
January, 1992, based on Resolution 001 of 1994. The spraying of illegal poppy crops
commenced at that time.

Information on the license issued by the ICA for the purchase of the herbicide glyphosate
was obtained based on the product listings authorized by the ICA, and by opinion of the
Ministry of Health.

Pages 14 and 18

It should be noted that the Program for the eradication of illicit crop s is a sui generis
program and that it is very difficult to apply the methodologies developed for commercial
agriculture aviation to illicit crop eradication . The parameters considere d in commercial

agriculture cannot be applied to the program of eradication of illicit crops. For these
circumstances we have developed new methodologies, techniques and systems to make
the application of herbicides in extreme conditions safe (altitude, speed, stroke, obstacles,
etc.). These practices are in constant research and adjustment due to the particular

operating conditions.

[ Page 2]

On flight altitude. As is well known, illicit crops are located in varied landscapes, variations

in topographical conditions and many plots have obstacles, in addition to the danger of the
drug dealers, which makes it impossibl e for the operation to have fixed parameters. It is
important to remember that these are not plots of rice, cotton and bananas that are being
sprayed, where the conditions for spraying are uniform and there are no obstacles.

However, with a variable range in altitude the spraying of illicit crops has been a success.

Speed of the aircraft. In Chapter III, paragraph 4.47, the speed range of operation is
regulated, depending on the type of crop to be sprayed. While theore tically the discharge
may vary with the speed, the aircraft now have an electronic valve that controls the flow of

output, allowing regularity in the application.

The methodology used for the calibration of equipment is the one described in the
manuals published by CIBA -GEIGY. Due to technological improvements , currently the

equipment is calibrated with “Satloc” software, which is electronic calibration.

To clarify the above ICA inquiries, attached are a letter and documents “Experimental
Protocol Criteria” and “Testing of Equipment Calibration Protocol,” which contains all the

90 Annex 26

results of tests performed by the firm Sociedad las Palmas Ltda., at the request of the
consultant who ran the study.

The firm Sociedad las Palmas Ltda. delivered to ICA a report containing the original data,
tables, copies of the Records, etc., data that is contained in Annex F of the Environmental
Management Plan, which were not evaluated by ICA (see copy of the cover letter). It is
clarified that these results lie in the offices of the Ministry of the Environment in the volume

ANNEXES of Environmental Management Plan.

Page 19

It is clarified that the herbicide Glyphosate is purchased directly from the Monsanto

Company, which is the company that is licensed to market the product and is responsible
for the sale and relevant paperwork. The Anti-Narcotics Police purchases the commercial
product, as would anyone else.

In connection with the information in Table 3.3 of the Environmental Management Plan
Chapter III, the mixture applied to the treatmentof illicit coca crops …

[ Page 3]

… is 23.65 L /ha, it is clarified that due to clerical error a different figure appears (50
L/ha).

The agrochemical products manufacturers recommend dose ranges, according to the

plant species treated. Because the manufacturer does not r ecommend dose for the
treatment of the coca plant species, the eradication program, based on applied research,
determined the effective dose for the control of coca crops.

It must be remembered that the manufacturer says on the label, “ The manufacturer
guarantees that the product matches the technical specifications of this label but does not
assume responsibility for the results obtained, whether or not thesuggest is dose used”
because the operation is out of its control.

If ICA has a recommended dose for the control of illicit crops, it would be desirable that it
suggest or recommend it for use in the Program.

Page 20

The volume ratio of glyphosate, water and surfactant, can be seen in the table below.

COMPOSITION OF THE MIXTURE PER HECTARE FOR THE CONTROL OF ILLICIT

COCACROPS

Component Liters

Glyphosate 10.40
Cosmo-Flux 411F 0.23
Water 13.02
Total mixture 23.65

91Annex 26

Page 28

We believe that if the product was approved by the Ministry of Health and the ICA, the
multitude of studies made on these issues should not be ignored; they clarify the behavior
of the herbicide in different media and were at the time evaluated by such institutions
before granting the appropriate license for its marketing in Colombia.

[ Page 4]

Page 65

In connection with t he information in Table 3.3 of Chapter III, the mixture applied to the
treatment of illicit coca crops is 23.65 L/ha; it is clarified that due to a clerical error , a
different figure appears (50 L/ha).

It is important to bear in mind that the combination of different types of nozzle diameters
and v ariation in the number of these perfectly makes possible the calibration of a
discharge. What is ultimately sought in a calibration is that the total flow per area be
uniform.

Pages 70, 71 and 72

These issues are clarified in the attached document , Equipment Calibration Test, which
describes the methodology and results of these tests.

2. On the Opinion of the General Ecosystem Directorate - Ministry for the
Environment

a. Chapter II: Background

This chapter presents the historical review of the actions taken by the program in
accordance with the policies and priorities emanating from the national government, in
terms of eradication efforts since the year 1987. ANNEX B of the study presents the tables

listed y province and municipality from the year of 1992 for the poppy crop and since 1994
for the coca crop.

The criteria which take into account chemical eradication are those defined in previous

studies for the selection of the herbicide glyphosate in phases I, II and III as shown in
Chapter II, paragraph 4.

Besides that and overriding the above are the decision criteria of the State to exercise the
drug policy referred to in the Master Plan for the fight against addictive substances,

through the following four plans:

• National Control and Enforcement Plan
• National Plan for Prevention, Treatment and Rehabilitation

• Informationand Logistics Support Plan
• National Plan for replacement of illicit crops

[ Page 5]

92 Annex 26

There are also some legal grounds set forth in the nation al law, which criminalizes
activities related to illicit crops.

This is included in Chapter lI, paragraph 2.

The coordination of the program’s actions is defined in the previous plans and law s of the
Republic, which define the responsibilities of eac h institution against combating the drug

problem. In addition, the CNE defines the policies and strategies to be developed by
members of the CNE as outlined in Chapter III, paragraph 1.1 Program Management and
Administration, which defines the functions and duties of the National Narcotics Council
(CNE), the National Narcotics Directorate(DNE) and the Anti-Narcotics Police.

The convenience and advantages of the use of a chemical alternative is considered by the
lower risk of toxicity attributed to the her bicide glyphosate in accordance with the
provisions of Chapter II, paragraph 4.1.1, Table No. 2.5 and, due to the magnitude of the
areas seeking to be controlled.

b. Chapter IV. Identification of the Area of Reference

Criteria for the selection of nuclei chosen in this study are listed in Chapter I II, Project

Description.

The problem of establishing illicit crops has expanded to a large part of the Colombian
territory. Thus, the national government through the CNE has defined areas where there is
greater activity of illegal crops and it is there, where the program is applied with the highest

priority. The geographical area of each nucleus is defined by the altitudinal distribution
where illicit crops are developed. So for poppy, it covers a range from 1,800 to 3,500 m.s.l.
and for coca, lower altitudes to 1,200 m.s.l. It is on this area of influence where direct
environmental impact in the natural (biophysical) environment is caused. However, this

impact is reflected or enhanced on the socio -political and cultural context of the
surrounding communities. Therefore, and according to official letter 04 dated January 7/98
(appendaged hereto) addressed to Dr. Eduardo Verano de la Rosa from the Study
Director, the considerations or criteria for the definition of the representative areas
considered for the study were sent. These criteria appear in Chapter VI: Analysis of Field

Tests, section 2.2 Ecosystem Representativeness Criteria.

[ Page 6]

This offic ial letter requested approval of the representative areas a nd sample sites
previously discussed with Dr. Juan Diego Peña, Program Coordinator of the Illicit Crop
Eradication of the Ministry for the Environment . Since there was no response thereto, an
administrative silence in favor of the DNE was established.

It is important to note that by letter No. 05/98 dated January 7/ 98 addressed to Dr. Carlos
Mario Hoyos, Acting Director Sustainable Development of the Ministry for the Environment
(attached hereto), we requested a meeting with Ministry for the Environment officials, the
consultant and other stakeholders, to define the scope of the terms of reference. The

meeting was actually held on January 16, 1998 at the offices of the Ministry for the
Environment and in letter No. 06/98 dated January 21 (attached here to) addressed to Dr.
Juan Diego Peña , Program Coordinator of Illicit Crop Eradication - Ministry for the

93Annex 26

Environment, we sent the record of the most relevant results of the meeting of January
16/98.

The cartography was drawn to the scales that were available for these areas in the
Agustín Codazzi Geographic Institute of Colombia - IGAC. The country’s shortcomings in
this area are no secret . The study did not include the production of new or updated base
mapping as this requires aerophotogrammetric restitution.

Because illicit crops are distributed in buffer areas of National Parks and even within them,
in any area of the country, it was considered prudent to include these areas in each
representative area to show the impact that they may be causing. But there is no indication
in any section of the study that there would be eradicat ion of illicit crops by chemical

means in these parks.

Also, there, in the areas that are either barren or f arther removed from the urban or
agricultural nuclei, is where illicit crops are established in order to prevent the action of the

authorities and with the knowledge that these are areas that, due to their special control
status, prevent eradication by chemical means or methods.

The management plan to be applied in communities that are located within National Park

areas refers to the cultural aspects covered here.

c. Chapter V: E nvironmental Characterization (physical and biotic
components)

[ Page 7]

The preparation of this chapter followed the guidelines set forth in the ter ms of reference
for each item considered, at the level of a framework of regional physical biotic zoning. In

this sense it is good to remember that illicit crops are scattered throughout the
biogeographic area with potential to sustain them, and therefore, to specify the baseline at
a very detailed level would involve virtually the entire national territory, which was not the
object of this study. For this reason, at the meeting of January 16, 1998 at the premises of
Ministry for the Environment, chaired by Dr. Juan Diego Peña, Program Coordinator for

the Eradication of illicit crops - Ministry for the Environment and consultants, the scope of
the study was defined . At that meeting it was indicated that “ ... the emphasis of the
evaluation will be based on as sessment of environmental and health risk s from the
handling and application of the herbicide. The starting point will be the information

available in the technical literature, analyzed for the conditions of application–
characteristics of the receiving ecosystem –” Other points cons idered can be seen in the
official letter dated No. 06/98 January 21/98, annexed hereto.

Chapter VI in paragraph 7 presents the geotechnical risk analysis, which is reflected in the

respective EMP geotechnical risk maps CI - VI - 12, 13, 15, 15 at scales of mapping
available on the IGAC, and authorized by the general commander of military forces since it
is restricted material.

According to the recommendation proposed by the Ministry for the Environment , of the
exclusion of some areas of the country of the chemical eradication program virtually most
areas of illicit crop eradication program would be excluded , which would be greatly
considered by growers and drug traffickers.

94 Annex 26

3. On the Opinion of the Deputy Office of Planning and Management of the National
Parks Special Administrative Unit:

Point 1

The supply and vulnerability of the ecosystem is included in Chapter V paragraph 1:

Physical-biotic Component. The vulnerability and supply are incl uded in various issues
included in the baseline.

Point 2

In the Chapter cited above, paragraph 1.5, the critical, susceptible or environmental ly
significant ecosystems are itemized for each nucleus and in section 1.5.7 Plant
biodiversity, these areas are spelled out in general terms , and the status of management
of critical areas are specified (section 1.5.7.4).

[ Page 8]
Point 3

The actions in the Environmental Management Plan must obey an integrated and
coordinated action of various state institutions under the coordination of the DNE, which
is clearly explicit in Chapter VI II paragraph 1: Introduction. However, the DNE may clarify
or expand these competencies and may set a model of inter institutional coordination to
define budgets, schedules and competency.

Currently in the coordination framework established for implementing the Nat ional Plan to
Combat Drugs 1998- 2002, through the Management Units for each of the six strategic
objectives, DNE has embarked on a process of inter-institutional agreement, which defined

strategic plans for four years and annual operating plans. In each of them, strategic
actions, responsible parties , resources and indicators for monitoring and evaluating
compliance with activities were identified.

Point 4

As special control areas administered by the National Parks Unit, this unit is responsible
for implementing the eradication of illicit crops, since these areas–from a legal standpoint–
cannot be the object of forced eradication. It should be noted that the Environmental

Management Plan is for the applicati on of glyphosate in the eradication of illicit crops and
therefore, at no time, either in earlier times, or today, or in the future, will the DNE program
consider intervention to eradicate illicit crops by chemical methods.

Point 5

The DNE, in coordinati on with the Special Unit of the National Parks, may establish the
special eradication strategies that are relevant, because after the delivery of EMP to the
Ministry for the Environment , manual eradication programs in concert with communities

affected by this scourge have been agreed upon.

Point 6
[ Page 9]

95Annex 26

Answered in Paragraph 1 subparagraph b, of this document

Point 7

Answered in Paragraph 1 subparagraph b, of this document

Point 8

What is expressed there is not understood; however, we clarify that the monitored areas
had been previously sprayed.

Point 9

The mandatory parameters established for the operation to eradicate illicit crops are in
accordance with the laws of pesticide use in Colombia (Decree 1843/91). APPENDIX B of

the study reiterates that obligation.

Point 10

These statements are not true since areas of the National Parks have never been sprayed
unless the Ministry for the Environment has evidence to support this comment.

The DNE reiterates that it is complying with paragraph 8 of r esolution 0001/94 concerning
that the eradication of illicit crops in special management areas and natural reserves will

be done by mechanical and man ual character process. When deciding to perform such
operation it will be agreed with the Ministry for the Environment.

It is inadmissible that actions are undertaken and project financing occurs for productive

sustainable alternatives in special reserve areas and national parks , as stated by the
Ministry for the Environment, since is strictly prohibited by Colombian law. Furthermore, it
would encourage growers of unlawful crops to invade special reserve areas. In this sense
the Ministry for the Environment through the Special Unit of National Parks should apply
the penalty in force for this type of situation.

Point 11

We reiterate that EMP does not consider the chemical method appli cable with glyphosate

in national parks areas.

[ Page 10]

Point 12

This is n ot true ; the level requested in the terms of reference of the environmental
characterization is broad and sufficient for the aims of the study. The ecosystems present
are identified for each media.

The selection of the sample sites was defined in agreement with the Ministry for the
Environment as expressed in paragraph 1 subparagraph b of this document . The

96 Annex 26

multitemporality study suggested by the Ministry for the Environment is not appropriate
since it is not covered by the terms of reference for this study.

The environmental impacts of glyphosate herbicide application were evaluated as shown
in Chapter 7: Impact Identification and Assessment. These impacts are applicable to the
areas of national parks, special reservations as well as the unprotected areas.

4. On the Clarification Opinion of Deputy Office of Planning and Management of
the National Parks Special Administrative Unit

The formulation of measures referred to in the EMP by the relevant Records are applicable
to the national parks system.

5. On the Opinion of the Office of Environmental Education Citizenship
Participation and Population.

Point 1, section A

Table No. 7.7 of Chapter 7 describes the impact caused by the implementation of the
specific and particular program at the levels:

• Social - family
• Service infrastructure
• Education

• Community Participation
• Employment
• Social - security

• Economic
• Alternative development

While it is true that eradication affects important indicators, the Program , in light of

Colombian law, cannot assume the full …

[ Page 11]

… social costs in areas with illicit crops because they are derived from an acti vity that is

illegal.

However, in the framework of a comprehensive global action, the National Plan to Combat
Drugs 1998 - 2002, provides for alternative development as a long-term policy, and one of

the central pillars of the current policy of peace, aim ed at restoring the legality of
marginalized populations and prevent the expansion of subsistence farming. In this sense,
it helps to promote the conditions for economic and social development and environmental
management, with the purpose of linking areas affected by illicit crops to regional and local
development.

It is clear that the Colombian state policy against illegal crops is differentiated according to
the extension and purpose of crop cultivation, that is, its type or category; for industrial or
extended crops, forced eradication is planned by aerial method or manual eradication, and

97Annex 26

as noted above, for the farmer and indigenous subsistence economy , alternative
development is scheduled.

As for Record 21 “National and International Cooperation and Alternative Development for
Illicit Crop Substitution,” it is part of a global and comprehensive perspective on the drug
problem. In this regard, the Record proposes strategic actions by major components
aimed at achieving international cooperation resources to intervene in the problem of illicit

crops, from a perspective of sustainable development that addresses economic and social
issues to promote in the affected areas of farmer and indigenous economy.

Point 1, section B

The DNE is the Colombian state agency that governs and is responsible for the
coordination process for planning, implementation and monitoring of drug policies through
management units, interagency and management teams, provided for each of the strategic
objectives aimed at intervention in this problem.

Specifically, regarding the problem of illicit crops, there are three strategic objectives which
are linked and are complementary, namely an alternative development policy, aimed at the
illicit crops of farmer and indigenous economy, environmental management policy aimed

at promoting ecological conservation and integral sustainable development in regions of…

[ Page 12]

… illicit crops and high risk of incidence, and technical and controlled actions to eradicate

illicit crops by hand or air.

Each strategic objective has an agreed interagency plan with activities, responsibilities,
resources and management indicators.

Point 1, section C

According to the drug policy in Colombia, it is the National Narcotics Council (CNE), who
sets the strategies. Plante is part of the CNE, as a permanent guest. All forced eradication

programs and Plante’s programs in common areas are properly agreed. Proof of this is the
interinstitutional agreement with the Guambiano community , and the current process
underway with the Yanaconas, among others.
Also answered in Point 1, section b.

Point 2

Agreements with the communities product of the 1996 farmer marches are agreements for
which the National Government at the time created the Southern Management for

monitoring and, in the different assessments, the government has always demonstrated
compliance. It is also important to understand that the only agreements signed were made
in the provinces of Putumayo and Caquetá and social and infrastructure investment
present in the agreement s was made through the various State institutions involved in

each of the components listed.

Point 3

98 Annex 26

The Ministry for the Environment interpretation does not correspond to reality, since the
owners of large or industrial crops are directly financed by the powerful drug barons,
deriving their profits at the expense of national heritage. In these largeplots there are no

food crops planted. Farmers and settlers have smaller crops, not object of spraying
because of the agreements of the farmer marches in 1996.

6. About the Requirements:

Point 1

The problem of combating the drug problem in Colombia is such that the struggle is
comprehensive and inter institutional, as …

[ Page 13]

… envisaged in the National Plan to Combat Drugs. T his way, all state institutions are
committed and responsible, according to their objectives, to advance the programs

proposed in the Environmental Management Plan.

Based on decree 2159 of December/92, it is DNE responsibility to execute the decisions of
the National Narcotics Council, and to coordinate the development and implementation of

national government policies on the control, prevention and suppression of narcotics. As
such, to manage the commitment of institutions and define together the budgets fo r
implementation. Also answered in Point 1 subparagraph b.

Point 2

EI alternative development (Plante) is a permanent guest of the regular meetings that the
CNE develops, where they set policies and strategies. Permanently, they approve, with the
municipal and provincial authorities, the necessary agreements with both farmer and the

indigenous communities.

Point 3

The information analyzed in this study concerning municipal development plans is limited

by the absence or decontextualization of the current problems. These plans are very poor
in design and analysis of municipal issues.

The development plans consulted were designed in order to comply with a legal term but

not to solve the existing problems. Chapter II: Social Component clearly indicates the
difficulties in achieving basic information to enable a more comprehensive analysis.
However, an analysis was performed on the subject according to the request in the terms
of reference and depth that the study period allowed.

Point 4

DNE was not required to submit a design of a citizen oversight program to ensure a
monitoring plan for the Social Management Plan ( SMP), because this subject is not

included in the terms of reference.

On this it is decided
[ Page 14]

99Annex 26

Article 1, point 1

A reasonable term is requested to supplement those aspects that are required, following

the resolution of this appeal for reconsideration. For this, the DNE suggests a meeting with
the Ministry for the Environment to reach an agreement on the scope of each point
considered, as well as the terms and time required. Also, mapping handled by the Ministry
for the Environment will be confronted with that presented in the study to verify the

geographical location of sampling sites.

Article 1, point 2

It is reiterated that the extensions of the national parks in the Program are not being

fumigated by aerial spraying. Also, it is clarified that there has been no manual or
mechanical eradication. The DNE will send the standing information on the existence of
illicit crops in these extensions in order for appropriate action to be taken.

Article 1, point 3

Efficacy trials are conducted by the Narcotics Police and they deliver the full reports to the
ICA for evaluation.

Adjuvants are compounds properly registered with the ICA. When a sked about this,
Monsanto believes its use is possible. These adjuvants are specific for glyphosate a s
registeredin their labels, duly authorized by the ICA.

The technical criteria for adjuvant use is as follows:

• That the product is compatible with the herbicide glyphosate
• Low toxicity of adjuvant

• Absence of synergism that would cause greater toxicity
• Reduced drift risks (reducing)
• Ensure a rapid translocation of the product

• Improve the quality of the mixture
• Avoid herbicide washing by rain

In general terms to ensure to the maximum that air applications are effective and that illicit

crops sprayed are eradicated.

Article 1, point 4

[ Page 15]

The DNE may establish and deliver the dates of fumigation of the sampling sites and
determine whether they were sprayed at different times. However , the multitemporal study

sought by the Ministry for the Environment was not performed since it was not part of the
terms of reference.

Article 1, point 5

100 Annex 26

This requirement is the subject of a specific study and we request agreeing on terms and
time for its realization. It is important to clarify that as of the date of completion of the study
there was not a laboratory capable of performing the analysis in the country ; such tests

could be sent to the laboratories in Quebec (Canada).

For this reason it was agreed with Dr. Juan Diego Peña Program Coordinator of Illicit Crop
Eradication - Ministry for the Environment, to emphasize the water analysis on the grounds

that these presented the greatest risk.

If these studies are agreed upon, it is necessary to investigate if there is now a laboratory
in Colombia that can perform the corresponding analysis. The former impasse is framed
within the terms of reference in the point Objectives, paragraph 7 defines as identifying

gaps in information.

In order to complete information of toxicity in animal species especially in aquatic
organisms (although what appears in the EMP is considered sufficient) we request

agreeing with the Ministry for the Environment the terms and time of implementation.

Article 1, point 6

At this point we request a meeting to agree the precise terms for what is required and the
time to achieve this.

With regard to the oversight program, the DNE reiterates that since it is not included in the
terms of reference, this requirement is not appropriate.

In relation to the paragraph, the risk analysis presented in Chapter VII of the EMP is
sufficient and meets the requirements of the terms of reference. If an expansion of
information is required, it will be necessary to agree on the scope and time for

implementation.

For the foregoing reasons, I respectfully request the extension of the term to comply with
the provisions of the operative part …

[ Page 16]

… of the referred Order, since this requires consultation meetings with the entities
involved in the subject.

Sincerely,

[Signed]
GABRIEL MERCHAN BENAVIDES

Director

[ Page 17]

101102 Annex 27

COUNCIL OFSTATE OFCOLOMBIA,CHAMBER OF CONTENTIOUS
A DMINISTRATIVAFFAIRS,ORDER OF15AUGUST 1995

(Archives of the Colombian Foreign Ministry , pp.15, 17)

103104 Annex 27

Council of State of Colombia, Chamber of Contentious Administrative
Affairs, Order of 15 August 1995

COUNCIL OF STATE, CHAMBER OF CONTENTIOUS ADMINISTRATIVE

AFFAIRS
Presenting Counsel: CONSUELO SARRIA OLCOS

Santa Fe de Bogota, D.C., fifteen (15) de August nineteen ninety -five

(1995)

Received number: ACU-2820

“Having duly established that the eradication of illicit crops is an activity

entrusted to the National Narcotics Council since 1986, which executes it
through the Anti-Narcotics Directorate of the National Police, and that it started
it prior to the issuance of Law 99 of 1993 and its regulatory decree, as shown by

the opinions of the health and environmental authorities referred- to above, it is
concluded that the transitional regime provided for in that same law and
developed in its regulatory decree, according to which an environmental license

is not required is to be applied to said activity, and that it can continue to be
carried out, without prejudice to the fact that the environmental authorities can
intervene when they deem necessary to enforce compliance with the laws that

regulate the environment in order to maintain it healthy, recover it or restore it
as the case may be.

The Minister for the Environment so considered it, in letter of 20 December
1994, addressed to the Minister of Justice and Law, in page 119 of the case file,

where she states that: ‘It is necessary to point out that the opinion rendered by
Inderena maintains its legal validity, since it was the relevant agency for

105Annex 27

environmental matters prior to the entry into force of Law 99 of 1993 and it
applied the provisions in force at that time. It should be added, that the

spraying is in pursuance of a policy of control of the public order, therefore,
there is no discontinuance, and thus the situation of the sprayings fits perfectly
within the transitional regime”.

[Page 15]

In virtue of the foregoing, the Council of State, through its Chamber Contentious
Affairs

DECIDES

Confirm the ruling of 18 May 1995 of the Administrative Tribunal of
Cundinamarca – Section one, whereby it decided to refrain from taking any
execution action against the National Narcotics Council, the Nation – Ministry of
Interior and Justice.

[Page 17]

106 Annex 28

NATIONALN ARCOTICSCOUNCIL,
MINUTESN°01 OF8M ARCH 1996

(Archives of the Colombian Foreign Ministry , Numeral 5)

107108 Annex 28

REPUBLIC OF COLOMBIA

NATIONAL NARCOTICS COUNCIL

MINUTES No. 01

Session held on 8 March 1996

[…]

5. Compliance with requirements before the Ministry for the
Environment, to carry on with the Programme for Eradication of Illicit
Crops by spraying with Glyphosate. Request of resources allocation

CNE-4-8-MAR-96.

The National Narcotics Director made a presentation on the legal
requirements and controls that the Programme for Eradication of Illicit

Crops was subject to prior to entering into force of Law 99 of 1993,
and the specific powers conferred upon the National Narcotics
Council in virt ue of Law 30 of 1986. Likewise, it was explained to
the Council members that the corresponding authorizations had been

obtained from the National Institute of Renewable Natural Resources
[Inderena for its acronym in Spanish] and the Health Ministry to
implement the Eradication Programme in 1992.

Next, she stated that after issuance of Law 99 of 1993, a new
environmental requirement was set out, namely a management plan
that must establish the necessary actions to prevent and/or mitigate
possible environmental impacts resulting from the implementation of

the eradication programme, and that previously the Ministry for the
Environment requested an Environmental Impact Assessment, within
the framework of the Eradication Program. On this regard, she made
clear that this activity was within the transitional regime stipulated in

article 117 of Law 99 of 1993, and for that reason, the Programme did
not require an Environmental License. She also stated that Decree
1753 of 1994, in article 38 rules that activities that began prior to
issuance of that law, which had obtained the environmental permits or

authorizations could carry on and that the environmental authorities
might require of them “presenting environmental management,

109Annex 28

recovery or restoration plans”. On this last matter, she pointed out that
in 1993 the National Narcotics Council requested and obtained from
Inderena and the Health Ministry the corresponding authorizations to
eradicate illicit crops by spraying with Glyphosate.

On the other hand, she stated that the management plan, described in
article 1 of Decree 1753 of 1994, was the one that should be
implemented to continue with the Eradication Programme, because
that activity should develop actions to prevent, correct, mitigate or

control possible envi ronmental impacts resulting from the
implementation of said programme and clarified that, given that
eradications activities began since 31 January 1992, mitigation of their
effects should be established, which should be carried out in the

framework of the environmental management plan. She went on
recalling all verifications that Glyphosate was subject to by
institutions in charge of safeguarding people’s health, such as the
Health Ministry and Inderena. In virtue of the foregoing, she asked the

Deputy Minister for the Environment to specify if the requirement was
a management plan or if it was necessary to make an environmental
impact assessment.

On this regard, Mr. Ernesto Guhl, Deputy Minister for the
Environment, stated that he agreed that an Environm ental
Management Plan should be made, not an Environmental Impact
Assessment, just like the National Narcotics Directorate had

interpreted it.

Disclaimer: Some excerpts have been redacted in the original annex
given the classified nature of the Minutes of the National Narcotics

Council (pursuant to article 94 of Law 30 of 1986) and they do not
deal with issues concerning the current case

110 Annex 29

NOTE 11430FROM THEMINISTRY OJUSTICE ANLAW,NATIONAL

N ARCOTICD IRECTORATE(DNE)TO THEMINISTRY FOR THE
ENVIRONMENT ENCLOSING THENVIRONMENTALM ANAGEMENT
PLAN FOR THAPPLICATION OGLYPHOSATE IN THERADICATION
OFILLICIC ROP,30JULY1998

(Archives of the Colombian Foreign Ministry)

111112 Annex 29

REPUBLIC OF Ministry of Justice and Law
COLOMBIA National Narcotics Directorate

11430

Santafé de Bogotá D.C.

GUILLERMO ACEVEDO MANTILLA
Deputy Director of Environmental Licenses

Ministry for the Environment
Bogotá. D.C.

Dear Mr. Acevedo:

I am pleased to submit your office the ENVIRONMENTAL

MANAGEMENT PLAN FOR THE APPLICATION OF
GLYPHOSATE IN THE ER ADICATION OF ILLICIT CROPS,
prepared by the consulting firm GEMSI LTDA., which was developed
from December 1, 1997, and which includes a typical page on how

content was structured and its final form.

This plan consists of 10 chapters containing background, project
description, identification of reference areas, Environmental

characterization, analysis of field testing, identification and
assessment of environmental impact, environmental management
plan, contingency plan for the program for the eradication of illicit
crops by aerial spraying with glyphosate and t he environmental audit

area for the program for the eradication of illicit crops by aerial
spraying with glyphosate.

Likewise, the aforementioned study includes annexes on: opinions and

permits in connection with the use of the herbicide glyphosate,
General weather information, maps, physical -chemical analysis, and
photographic record.

Sincerely,

[Signed]
CARLOS ENRIQUE GALLEGO SILVA
General Secretary

July 30/98]

113114 Annex 30

NOTE 16341FROM THEMINISTRY OJUSTICE ANLAW ,NATIONAL

NARCOTICSDIRECTORATE(DNE)TO THM INISTRY FOR THE
ENVIRONMENT ENCLOSINGCHAPTER7OF THEENVIRONMENTAL
M ANAGEMENT PLAN FOR THAPPLICATION OGLYPHOSATE IN
THE ERADICATION OLLICITCROPS,30OCTOBER 1998

(Archives of the Colombian Foreign Ministry)

115116 Annex 30

Ministry of Justice and Law
REPUBLIC OF National Narcotics Directorate
COLOMBIA

Santafe de Bogotá 16341
30 October 1998

Mr.
GUILLERMO ACEVEDO MANTILLA

Under Director Licenses
Ministry for the Environment
City

REF: Environmental Management Plan

Dear Mr. Acevedo:

In response to your request made in Note No 221- 2-315 dated 2
October this year, for the corresponding purposes, I am enclosing the
copies of Chapter 7 called: IDENTIFICATION AND ASSESSMENT

OF ENVIRONMENTAL IMPACT of the aforementioned document.

Sincerely,

[Signed]
BEATRIZ PADILLA MEZA
Acting Director

Carrera 16 A NO. 79-08 Santafe de Bogota D.C.
Tel. 636 2139 Fax. 2578416 E-mail [email protected]

117118 Annex 31

NATIONALN ARCOTICSDIRECTORATE (DNE), NVIRONMENTAL

M ANAGEMENT PLAN FOR THE APPLICATION OF GLYPHOSATE
HERBICIDE IN THE ERADICATION OF ILLICIT CROPS WITH
SUPPLEMENTARY INFORMATION,SUBMITTED BY THEDNE TO THE
M INISTRY FOR TEENVIRONMENT, 13EPTEMBER 2000

(Archives of the Colombian Foreign Ministry, Table of contents; chapters 2, 3, 5;
section 5.1., pp. 53 – 83; sections 7.1 and 7.2, pp. 127-131)

119 Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

NATIONAL NARCOTICS DIRECTORATE

-DNE-

SUPPLEMENTARY INFORMATION TO THE
ENVIRONMENTAL MANAGEMENT PLAN FOR
THE APPLICATION OF THE HERBICIDE
GLYPHOSATE IN THE ERADICATION OF ILLICIT
CROPS

BOGOTA , SEPTEMBER 2000

120 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

NATIONAL NARCOTICS DIRECTORATE

-DNE-

SUPPLEMENTARY INFORMATION TO THE
ENVIRONMENTAL MANAGEMENT PLAN FOR

THE APPLICATION OF THE HERBICIDE
GLYPHOSATE IN THE ERADICATION OF ILLICIT
CROPS

BOGOTA , SEPTEMBER 2000

121Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

TABLE OF CONTENTS

1 POLITICAL FRAMEWORK 2

2 DETERMINATION OF ASPECTS AND CRITERIA (ENVIRONMENTAL, SOCIO-

ECONOMIC, AND OPERATIONAL) CONSIDERED IN THE SELECTION OF
REFERENCE AREAS 8

2.1 CRITERIA FOR THE SELECTION OF THE SPRAY TARGET AREAS
RESOLUTION 001/94 AND RESOLUTION 005 OF 2000 NATIONAL NARCOTICS

COUNCIL 10

2.2 DETERMINATION OF REPRESENTATIVENESS CRITERIA OF REFERENCE
AREAS 10

3 DESIGNING THE SPECIFIC MEASURES FORSEEN IN THE PLAN FOR
ENVIRONMENTAL PREVENTION, CORRECTION, MITIGATION, AND
COMPENSATION FOR THE EFFECTS THAT MAY RESULT FROM THE
APPLICATION OF GLYPHOSATE FOR THE ERADICATION OF ILLICIT CROPS

IN AREAS NEIGHBORING THE NATIONAL NATURAL PARKS SYSTEM.
(AMENDMENT OF NUMERAL 2 OF ARTICLE 1 OF ORDER 599 OF DECEMBER
1999 BY ORDER NO. 143 OF MARCH 2000) 23

3.1 DESCRIPTION OF ILLICIT CROPS PLANTED IN AREAS NEIGHBORING

PROTECTED AREAS OF THE NATIONAL NATURAL PARKS SYSTEM. 24

3.2 ERADICATION OF ILLICIT CROPS IN AREAS NEIGHBORING PROTECTED
AREAS. 34

4 CONTEXTUALIZING THE FIELD TESTS OCCURING AT THE TIME OF
SPRAYING. 47

5 ASSESSMENT OF ENVIROBNMENTAL IMPACTS OF ERADICATION WITH

GLYPHOSATE IN THE SHORT, MID, AND LONG TERM. 48

5.1 ANALYSIS OF VERIFICATION IMAGES OF ERADICATION OF ILLICIT
CROPS. 53

6 EVALUATION OF EQUIPMENT, AIRCRAFT, APPLICATION PARAMETERS,
AND MIX DOSE EFFICACY. 86

7 COMPLEMENTING DETERMINATIONS OF GLYPHOSATE IN SOIL AND THE

EFFECT ON ITS MICROORGANISMS. 126

7.1 HERBICIDES DISPLACEMENT IN SOILS

122 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

7.2 REPORTS ON RESEARCH ON THE EFFECTS OF GLYPHOSATE

HERBICIDE ON TROPICAL SOILS. 129

7.3 EFFECTS OF GLYPHOSATE HERBICIDE REPORTED ON SOIL
MICROORGANISMS. 131

8 COMPLEMENTING THE INFORMATION AND ANALYSIS OF GLYPHOSATE
EFFECTS ON OTHER TREE SPECIES AND FOOD CROPS. 134

9 COMPLEMENTING TOXICITY INFORMATION ON ANIMAL SPECIES,

PARTICULARLY ON AQUATIC ORGANISMS. 140

10 COMPLEMENTING INFORMATION ON SOCIAL ISSUES. 171

10.1 CRITERIA TO ASSIGN INSTITUTIONAL LIABILITIES 173

10.2 PLAN NEGOCIATED WITH “PLANTE” 175

10.3 APPROACHING REGIONAL INSTITUTIONS. 175

10.4 DESIGNING A CITIZEN OVERSIGHT PROGRAM. 176

11 REDEFINING OF THE MANAGEMENT PLAN 178

11. VEGETATION. 179

11.2 WATER. 209

11.3 SOIL COMPONENT. 214

11.4 FAUNA. 228

12 REDEFINING THE ENVIRONMENTAL RISK ASSESSMENT (ERA) 256

13 MECHANISMS FOR THE FUNCTIONING OF THE MANAGEMENT PLAN 258

14 [sic] FOLLOW-UP AND MONITORING PLAN 260

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Supplementary Information to the Environmental Management Plan for the eradication of illicit
crops

[Chapter 2]

2. DE TERMINATION O F F ACTORS AND CRI TERIA ( ENVIRONMENTAL,
SOCIO-ECONOMIC AND OPERATIONAL) CONSIDERED IN THE SELECTION
OF THE REFERENCE ZONES

In order t o determine f actors a nd criteria ( environmental, so cio-economic a nd op erational)
considered in the selection of reference zones, it is important to re-emphasize the principles of
selection of spraying areas in Colombia, in order to establish a reference framework that will allow

analyses to be made from the point of view of the representative nature of the zones.

In other words, if a national reference framework is established for the illicit crop zones which are
the object of spraying, a clear statement can be made of the representative nature of the reference
zones.

2.1. CRI TERIA F OR S ELECTION O F T HE ARE AS FOR SPRAYING
RESOLUTION 1 /94 AND RE SOLUTION 5 /00, NAT IONAL NARCO TICS

COUNCIL.

√ Detection of plots with industrial-type crops, through the analysis of satellite images and

aerial photography. Estimation of the area of the illicit crop detected. Verification of the
existence of illicit crops by overfly1ng the areas, and determination of the area of the crop
through the use of the SATLOC system .

√ Integration of information about crops detected with the cartographic bases in the GIS.

Location of crops with regards to population centres, protected areas and water bodies.

√ Programming of spraying work, in accordance with the characteristics of each plot verified.

√ Subsequently, at each antinarcotics police base, the execution of spraying is programmed
in accordance with predominant weather conditions, the presence of armed groups, and
guarantees for operation.

√ In areas in excess of 2 ha, the illicit crop must be a single one- coca-leaf (Erithroxylum
coca) or poppy (Papaver somniferum), taking account of topographical considerations and
closeness to human settlements.

√ Areas of illicit crops where it can be shown that there has been fragmentation or mixing
with illicit c rops, and forms o f illicit crops used to evade t he actions of the herbicide
eradication program. .

Fragmented crop area: an area of land divided by living or artificial barriers, with a sequence of
lawful crops, subsistence crops, or native woodland, with illicit crops.

Mixed crop area . And i llicit p lant pr opagation a rea, w hich c ontains lawful a nd i llicit crops
intersparced.

√ Crops with of an industrial production nature, such as:

1
2Geopositioning system installed in each of the aircraft used in spraying
As defined in Resolution 005 of August 11, 2000, National Narcotics Council

124 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

 Defined lines and uniform distribution of plants
 Continuous, fragmented or mixed areas with illicit crops, in areas larger than 2 ha.

 High density of planting. Distances for coca crops are 0.7-0.8 m between one plant and
the next, which allows densities to be between 10,000 and 15,000 plants per hectare
approximately, and for opium poppy, 0.3 m between one plant and the next and 0.8 m
between the lines, for an approximate density of 45,000 plants per hectare.

√ Illicit crops located outside protected areas, including:

 Areas included in the National Natural Parks System
 Micro basins supplying municipal and rural area water supplies
 Consolidated suburban settlement areas

√ Crops where strategic ecosystems are being affected, and which meet the above conditions,
show a new front of destruction of vegetation for the establishment of illicit crops.

√ Operational location, including the following criteria (distance from the operations based to

the crop area, risk factors (activities of armed groups), predominant factors of climate, and
the 100m buffer zone for water bodies.

Therefore, in the areas where spraying has been conducted with glyphosate in Colombia, using the
criteria given above, the following reference zones were selected, using the environmental

management plan used for the formulation of the environmental management plan

Nucleus of Sierra Nevada de Santa Marta. Palomino basin, Municipality of Santa Marta.
Nucleus of Serranía de Perijá . R. Magiria, tributary of R. Cesar. Municipalities of Manaure and

Agustin Codazzi, Department of Cesar and Villanueva, Department of La Guajira.
Nucleus of the Municipalities of Páez, Cauca and Iquira abnd Teruel, (Huila).

Nucleus of the Municipalities of Chaparral and Rio Blanco, Department of Tolima.

Nucleus of La Gabarra, Municipality of Tibú, Department of Norte de Santander.

Nucleus of the Municipality of Puerto Rico, Department of Meta.

Nucleus of Caño Grande – La Lindosa. Municipalities of Calamar and El Retorno, Department of
Guaviare

2.2. DETERMINATION OF CRITERIA OF THE REPRESENTATIVE
NATURE OF REFERENCE ZONES

The selection of reference zones took into account the following criteria, considered decisive for
initial evaluation.

1. The intention was to ensure that the reference zones were representative of the natural region in

which they stand, with respect to flora, fauna, water resources another environmental elements
which are part of the ecosystem, and which may have been part of the activities of the establishment
of illicit crops, and so, of the program for the eradication of illicit crops by spraying.

125Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit

crops

2. At the same time, the intentio n was to ensure that within the representative zones there were
some which had not been the object of spraying (Sierra Nevada de Santa Marta, La Gabarra), in

order to be able to make a comparative analysis between the zones already sprayed and those not
sprayed, and this in the first instance allowed a determination as to whether there were differences

with regard to one of the components of the environment which were sampled.

3. In operati onal terms, the intention was to ensure that the representative zon es should offer the

greatest possible security for taking the samples, that is, to determine the zone of influence and/or
military action by the illegal armed groups.

4. Each of these zones has a high percentage of representative value with regard to the total area of

illicit crops in the Department, and at national level, with the area percentages presented in the chart
below, in accordance with the 2000 census data. Trends in the establishment of illicit crops in these

representative zones have fluctuated with regard to those observed in 1998, when the formulation of
the Environmental Management Plan began, since in the areas which have not been sprayed, such

as Sierra Nevada de Santa Marta and La Gabarra at that time, the area of illicit crops has now
tripled, and for the remaining representative zones, these values have markedly decreased, as can be

seen in the information reported for the poppy crop in the departments of Tolima and Huila , from
1500 ha in 1997, to only 337 ha today (2000). Sources: Antinarcotics Police, US Department of State, or

Environmental Audit cited by the EMP for the eradication of illicit crops, census of illicit crops for 2000)

126 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

REPRESENTATIVE MUNICIPALITIES PREDOMINANT TOTAL AREA % OF TOTAL FOR % OF TOTAL
ZONE ILLICIT CROP OF ILLICIT DEPARTMENT FOR
CROP PER COLOMBIA

MUNICIPALITY
(HA)
1 SIERRA NEVADA RIOHACHA, COCA 760 100 1
DE SANTA MARTA SANTA
MARTA
2 SERRANIA DE MANAURE, POPPY 832 33 1

PERIJA AGUSTIN
CODAZZI
3 PAEZ-IQUIRA-& IQUIRA & POPPY 222 15.5 82
TERUEL TERUEL
PAEZ 0.5
4 LA GABARRA TIBU COCA 7373 95 7

5 CAÑO GRANDE - CALAMAR COCA 982 33 3
LA LINDOSA EL RETORNO 1687
6 PUERTO RICO PUERTO RICO 806 28 1
COCA
7 CHAPARRAL-RIO CHAPARRAL POPPY 63 52 4

BLANCO
RIO BLANCO 45

% REPRESENTATIO, 22.5%
ILLICT CROPS
COLOMBIA

Source: Map of Illicit Crops in Colombia 2000 Census, amended with the most recent data supplied by the Antinarcotics

Police DIRAN

Chart 1 Representative standing of illicit crops in the nuclei selected in terms of areas of crops of the same
type at Municipal, Departmental and national levels.

127Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit
crops

An analysis of the figures reported in C hart 1 shows that the study was made in the most
representative areas of the country with regard to concentration (continuous planting areas, higher
density, that is, a larger number of plants per hectare), per sistence and spread of illicit crops at the

date of the analysis.

Likewise, for the selection of representative zones, an analysis of other variables, summarized in
Chart 2, was made. It allows a clear definition to be made of the geographical location of nuclei, the

predominant in the illicit crop, the presence of strategic ecosystems, existing environmental
information, vegetation formations, existing hydrographic basins, nearby protected areas, and the
presence of armed groups.

For the spatial location of illicit crop areas, and so, of spraying areas, we present the cartography of

illicit crops by Province supplied by the A ntinarcotics Police DIRAN, clearly showing the illicit
crops by Province and their location with respect to the national Nature Park System. Likewise, we
attach the illicit crop location map on a national scale, with an updated locationof protected areas
and National Natural Parks supplied to the DIRAN, by Special Administrative Unit of N ational

Natural Parks Unit –UAESPNN- in July 2000.

128 Annex 31

ARGMREPORNTesPSSE Yes Yes

the

paramo

STERCAOTSEYGSICTEMStslyedtehenerNpetSaeoiadefrrdtatalshne,eedicaHigfohrpeAseotnasoeesnsteibiocitnheageetghslhtmsasattobhrserseyoisgfoaoauaftea,fugrocadtiasenisbnttherroeianeynsgetgdoaebfbliilyslhicmitecnrtops

Park
al
a Marta
of illicit crops
NEPAROBRTYEECATSEDandaat de SerPraenriíjaá de NevHaudiolaatduerl

on

adication between Santa l (Huila)
er

the BASINS Palomaagifntecn(banrtirtjcicclrisrsnityTcnlcdliliec,detd,cltlgyrseiisaneoTetrietnttabTiVnndtlhlcdpaeaerzasnoazrjuR. Paez and R. Iquiraatllaideucoriicucrtastec)tioraonnpdosfIquira

for
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ATIO -
Tt - - , B - - , B
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VENGEFTORMATION bmbhmahndHigAhnfdoeraenst bmbhmh

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DOILLIICAITNTCROP Poppy Poppy

MUNICIPALITYMacahrtaa, Santa AgVusitlilnanCuoedvaazzi, IquPiraae,zTeruel,

PROVINCE GUM AAJRDAA, LEN Cesar, Guajira Huila

Information to the Environmental Management Plan

REGION CARIBBEAN ANDEAN

TA

Supplementa ZOrNyE SIENRERAANDAARDE SEDRERAPNERIAIJÁ PAIEQZUTIRRAUE&L

129Annex 31

Yes Yes Yes Yes

- T
s,
paramo o, of bh

HigfohreeAcauafteafrugrocdtiaesnisbntComcaalienalyf dirnopthseoresaeiuzbhnuedeciddeahCosmapvelaecntbdeepsisantsgrtoutyureerdlnaenddin

-

of illicit crops LasHeNrmaotusraesPark CatBaaturbkoature NuMkaakRk-uireia,btuiqrueePtearkrePnaark

elop

adication

er
s in the middle

the R tArbjuirsayduoiripeedfrlsaaapñinCnaCatcartourpemabcohebsaosfint,heillrlboaaunsupgiprreycfrrirodorofdepmalsechaensd. lower RcourseeeafsrlrtoPoidvnueegR

for -

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- -aBnd T, bmh - Tt
- -
bmbhmh bhT, bmh- bmh Bh

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Poppy Coca Coca Coca

io

ChBaplaarnrcaol R TibGúa,bRarDraLas Calamar PueRretornioco, El

Tolima NoSrtaentdaneder Guaviare Meta

Information to the Environmental Management Plan

ANDEAN CATATUMBO AMAZONAS ORBIAOSICNO

-
LA
-

Supplementary CHRAIPOABRLRAANLCO LAGABARRA CAGÑROANDEOSA PUERTO RIO

130 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

131Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

132 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

133Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

134 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

135Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

136 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

137Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

138 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

139Annex 31

Supplementary Information to the Environmental Management Plan for the eradication of illicit crops
[Chapter 3]

3. To de sign s pecific mea sures cont ained i n t he Program for t he
prevention, correction, mitigation and environmental compensation of the

effects th at ma y be g enerated b y the ap plication of glyphosate i n t he

location of illicit crops in zones close to the National Natural Park System
(modification of section 1.2 of Order 599 of December 1999, by Order 143

of March 2000).

For the development of this point, the limit of the protected areas was established in each of the nuclei, and the

location of illicit crops in areas close to them was also determined, in order to define specific measures to be
taken in those zones.

At the same time, and for each representative zone, a context was established for the development of illicit crops,
both inside and outside protected areas, in order to set up programs which would help return the areas close to
the protected areas to t he transition areas between productive zones a nd protection zones, and to draw up
proposals to discourage or eradicate illicit crops.

For this purpose, the base document was the "Environmental Management plan for the eradication of illicit
crops", for the identification and environmental ch aracterization of the nuclei object of the eradication program
3 4
is pursued by DIRAN and coordinated by DNE .

This additional technical information was compiled by consultation at the documentation centre of UASEPNN 5
of the Ministry of Environment, and specialized information was taken by search from libraries and journal

collections.

The analysis and processing of this information allowed special measures to be considered for the eradication of

illicit crops in the Nature Parks areas and nearby zones.

Below is an analysis of the introduction of illicit crops into the nuclei object of the study, and particularly the
introduction which affected buffer zones close to the protected areas.

3.1. DESCRIPTION OF THE ESTABLISHMENT OF ILLICIT CROPS IN ZONES CLOSE TO
PROTECTED AREAS IN THE NATIONAL NATURAL PARK SYSTEM

3.1.1. ANDEAN ZONE

3.1.1.1. Chaparral-Rio Blanco (Tolima) nucleus. Influence on t he Las Hermosas Natural Park
(HER)

The Las Hermosas Natural Park, located between the Provinces of Valle del Cauca and Tolima on the Western

range of the Andes has been affected by illicit crops, in the context of the Chaparral-Rio Blanco nucleus,
particularly i n t he z one c lose to the l imits of the Park lo cated in th e Province of Tolima, be tween t he
municipalities of Chaparral and Rio Blanco.

The main characteristic of Las Hermosas Park is its very humid paramo-type climate, which classifies it as a
strategic ecosystem of vital importance since it supplies water to a number of human settlements both in Valle
del Cauca and in Tolima, and indeed, a good part of an agro-industry established in Valle del Cauca depends on

3Antinarcotics Direction National Police
4National Narcotics Directorate
5The Administrative Unit of National Nature Parks System

140 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

water sources from the Park (Sarria and Londoño, 1991) 6

Landholding in the properties close to the Park is characterized by possession (settlers), generally protected by
deeds of sale, but the characteristics of landholding for the whole Park are not known. (Sa rria and Londoño,

1991).

There is also no knowledge of the landholding of properties located in the buffer zone of the Las Hermosas Park;
it is likely that the owners are wealthy, and have left the care of these lands in the hands of caretakers or tenants

(Sarria and Londoño, 1991).

The main productive system of the Las Hermosas P ark and its nearby areas is cattle-ranging, with a small

presence of crop-farming, mainly potato, on small plots. Burning of f his frequent in the dry season, and is used
as a method for rejuvenating meadows, and making them palatable for cattle (Sarria and Londoño, 1991).

The climate conditions, relative inaccessibility, and the great distance from important urban centres all
encourage illegal activities, in particular the growing of opium poppy in small areas, and in places with steep
slopes, generating a fragmented landscape of Paramo vegetation, surrounded by man -made type matrix, is
7
characterized by areas of pasture and opium poppy crops (EMP, 1999) .

The main limiting factors for the establishment of this productive system - both legal and illicit - are the strongly

scarped relief, and the humid cold climate, typical in the region (EMP, 1999).

Based on the map "Location of illicit crops in Colombia, 2000 census", prepared by the DIRAN, it was possible

to determine that the buffer zone of the Las Hermosas P ark has been affected by opium poppy crops in the
municipalities of Chaparral and Rio Blanco. In the Chaparral there are 63 ha planted, and in Rio Blanco, 45 ha.

This means is that the area of opium poppy crop in these two munic ipalities is equal to 52% of the total crop of

total illicit crop areas in the entire Department of Tolima, and this in turn is equal to 4% of the total opium poppy
crops grown in Colombia. According to the same map, and on the cartographic base map of the antinarcotics
division , the location of the illicit opium poppy crop areas is outside the Park, that is, within the zones close to

it, in the jurisdiction of the Department of Tolima.

3.1.1.2 Paez Iquira and Teruel Nucleus ( Provinces of Huila and Cauca ). Area of

influence of the Nevado del Huila Natural Park (NH).

Nevado del Huila Natural Park contains a complex diversity of flora, typical of the high Andean forests, which
is a mixture of tree and shrub vegetation, covered by thick layers of moss, l ichen, orchids, philodendron, and
anthurium, with a high degree of epiphytism , and a high concentration of water vapour in the environment,
which make it a "natural water factory" (DIRAN and Environmental Audit , 1999) 9

Based on the map "Location of illicit crops in Colombia, 2000 census", it has been possible to determine that in
the municipality of Ter uel (Department of Huila) there are 72 ha planted with opium poppy (6% of the

Departmental total), and in the municipality of Iquira there are 150 ha (12.5% of the Department total). I n the
municipality of Paez (Department of Cauca) there are 15 ha (2% of the Departmental total).

This means that the area of the opium poppy crop in these municipalities is equivalent of 0.7% of total opium
poppy crops in Colombia. However, these data are considered to be an underestimate, since when the illicit crop
census was taken, spraying activities had already begun and it is probable that with the vegetative cycle of these

6Sarria S Stella and Londoño Janeth 1991 Parque Nacional Natural Las Hermosas. Monografía, Convenio Corporación Autónoma Regio nal del Cauca
CVC y Corporación Autónoma Regional del Tolima CORTOLIM A. Co-ordinator Luis Fernando Gómez, Palmira, Valle del Cauca 169pp.
7GEMSI Ltda Environmental Management Plan for Eradication of Illicit Crops
8DIRAN Illicit Crop Eradication Division, Aerial Detection Group, Base Map for the Provinceof Tolima, April 2000 (1:20000)
9DIRAN and Environmental Audit for the Eradication of Illicit Crops 1999 Eradication, an environmentally sustainable policy. Bogota. 46 pp.

141Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

species, considered as short, the expansion of the areas has been recurrent.

According to the DIRAN base map , the location of the areas of illicit crops of opium poppy located both inside
and outside the Nature Park (NH).

That is to say, the opium poppy crops in the jurisdiction of the Department of Tolima are in the areas close to the
Park, while the crops located in the jurisdiction of the Departments of Huila and Cauca affect both the inside and

outside of the Park.

10DIRAN Illicit Crop Eradication Division, Aerial Detection Group, Base Map for the Department of Tolima, Huila and Cauca, April 2000 (1:20000)

142 Annex 31

Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

3.1.2. THE ORINOCO REGION

3.1.2.1.The Puerto Rico (Meta) Nucleus. Influence on the areas of the La Macarena
Natural Park (SMA)

La Macarena is a unique space due to its ecological and biogeographic characteristics, hosting a very high
diversity of flora and fauna and a large number of endemic species, and it plays an important role as a

Pleistocene refuge; it is a centre of species dispersion, as it contains habitats of reproduction or food for land and
water migrant species. Under L aw 52/1948, it was declared a H eritage of Mankind and an I nternational
Monument, which gives it both national and national importance (CORMACARENA 1995, CORMACARENA

et. Al. 1997).

The process of human occupation of the La Macarena biological reserve, started by settler activity in the 1930s,

11ant that the area initially proposed as a reserve had to have about 70% of its surface withdrawn (Caicedo 195)
and that the Special Management area of La Macarena (AME M), was declared, demarcated and zoned under
its present name in 1989 (Legislative Decree 99/1989). The regime of the national Nature Park La Macarena was
12
also set up in that year (CORMACARENA et al 1997) .

The withdrawal of part of the former reserve has encouraged settlers to move into areas around Mesetas, Puerto
Rico and Bocas del Ariari; and road infrastructure was generated, with consolidation of productive nuclei
13
exercising strong pressure on the Nature Park (Avellaneda, 1989 . Today, the human settlements have tended to
consolidate in the special management area AMEM , and new processes of certain settlement have decreased in
numbers, due to the restrictions imposed by armed groups present in the area (CORMACARENA et al, 1997).

Human intervention in the special management area AMEM is mainly effected by the following practices
(CORMACARENA et al 1997)

1. Establishment of subsistence economies, proper to founding settlers, who slash and burn, and introduce crops
clearing the way to jungle areas.

2. Extractive practices of forestry resources, linked to national markets, mainly pochota quinata, Bombacaceae
or cedar tree, which is extracted selectively in the buffer zone of the Macarena Park, and from inside of it. This

extraction generally precedes establishment of the meadows for cattle raising. The wood extracted from this area
is sold in situ, and some 50,000 pieces of cedar are estimated to have been disposed of in that manner in 1990.

3. Coca-leaf crops, generally the area for this is no larger than 3 -4 ha per smallholding, in areas which were

previously opened up and in which some trees are still standing.

4. Cattle ranging. This is a mean s of capitalization. This productive system is seen by settlers as a means of

increasing the value of their property, and causes serious environmental problems in addition to the gradual loss
of productivity and load-bearing capacity of the pastureland established.

5. Opening up of communications. Roads are used for the commerce of legal products (cattle and crops), and
illicit crops alike (coca-leaf). However, they may generate the fragmentation of biological corridors between the
Macarena, Tinigua and Los Picachos Parks.

11Caicedo T. Hernan Basis to styructure an environmental management policy for the Sierra de la MacNERNA, Villavicencio,rve, ID
Meta
12Corporación para el Desarrollo Sostenible del Área de Manejo Especial la Macarena CORMACARENA, Asociación para la Defensa de la Reserva de la
Macarena ASOMACARENA and UAESPNN, 1997. Project for preservation and recovery of plateau zones in the National Natural Parks La Macarena
and Tinigua La Macarena, Special Management Areas, Bogotá, 14pp.

13Avellaneda Mario 1989 Preliminary Study ofImpact from Settlers on La Macarena Nationa Reserve and determination of current condition of tyhe
natural system in altered áreas.Final Report. Universidad Nacional Bogotá.

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Further, social, political and territorial control is exercised by the g uerrilla group FARC, for whom it has been a
"traditional" territory, and who in recent years have regulated the extraction of natural resources in the form of
timber, wildlife and fish, and they have restricted the area planted with coca leaf crops (only 4 hectares per

smallholding, for the sustenance of the family unit) (CORMACARENA et al, 1997).

La Macarena Nature Park (SMA) is influenced by the Puerto Rico nucleus, at the confluence of the River Guejar

into the River Ariari , affecting the inside of the Nature Park and the buffer zone in the north eastern end of the
Sierra La Macarena.

The municipality of Puerto Rico is considered to be a semi-urban settlement or area of unconsolidated settlement

(CORMACARENA, 1995), and is the second largest producer of coca leaf in the Department, after Puerto
Lleras.

According to the map "Location of illicit crops in Colombia 2000 C ensus", it can be established that there are

806 ha planted with coca leaf in the municipality of Puerto Rico, or 28% of total area with this crop in the
Department of Meta, and equivalent to 1% of the total crop area in Colombia. According to the DIRAN base
map 14, the location of the areas of illicit coca leaf crops are mainly outside La Macarena, that is, they are in its

buffer zone, with only a small percentage inside the Park.

Coca leaf crops in La Macarena Nature Park (SMA) buffer zone are located mainly in the floodplains of the
rivers Guejar, Ariari and Caño Cabra in the foothills of the Sierra La Macarena, and D IRAN (the A erial

Detection Group of the A ntinarcotics Police) have classified them as medium density. At t he same time, it has
been determined that there are coca leaf crops in the Municipality of Vistahermosa and La Macarena, but since
these are in the "cooling off" area assigned to the guerrilla groups, no quantification has been possible.

3.1.3. AMAZONIA

3.1.3.1. Caño Grande – La Lindosa (Guaviare) Nucleus. Influence on the Nukak Nat ure
Reserve (RNN NUK)

The Nukak Nature Reserve (RNN-NUK), created by Resolution 122/1989, is located at the eastern end of the
Department of Guaviare, between the rivers Inírida and Vaupés ; it forms part of the Guyana Shield, which
extends into Colombia in the Departments of Guainía, Vichada, Vaupés, Guaviare and Caquetá.

The Nature Park (NUK) is characterized by being an ecotone zone between the Orinoco Plains and the Amazon
jungles, and therefore conserves fauna and flora species typical of both ecosy stems, and adapted and endemic

species for the region.15hese characteristics give it national importance as an area, in terms of diversity
(IDEADE, at al 1996)

The Reserve is mainly inhabited by indigenous communities, but settlement processes have broug ht subsistence

farmers from other parts of the interior of Colombia, who have settled mainly in consolidated centres such as
San Jose del Guaviare, and subsequently, moved out to their places of settlement

The distance and lack of infrastructure has encou raged the establishment of illicit crops, particularly coca leaf,

which is produced generally with three production systems (IDEADE at Al 1906):

1. Owner-sharecropper. The owner of the land hands the process of coca productionover to a
Manager-caretaker, who is paid a percentage of the production

14DIRAN Illicit Crop Eradication Department, Aerial Detection Group, Base Map for the Department of Meta, March 2000 (1:20000)

15IDEADE, Universidad Javeriana, Instituto Alexander von Humboldt, UAESPNN, Government of France, Colciencias, FES, Governor o f Guaviare and
Guainía, Instituto Nacional de Salud 1996. Fieldwork in the Nukak Nature Reserve, Department of Guaviare.

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2. Rent. The owner of the land pays rent to another settler in his coca -leaf plantation, and at the end of the
production period, the other settler pays the owner a percentage of the total produced.

3. Partnership. The owner of the coca plantation becomes a partner of the process of production process and the
extraction of the coca base. The owner put s up the land and the crop, and the partner supplies labour and

materials. They then split the proceeds equally.

The chagras (clearings in the jungle, producing legal and illicit crops), may perform large contiguous zone, or
zones separated by nearby or distant jungle corridors (IDEADE at al 1996).

The Nukak Nature Reserve (NUK) has been affected by the penetratio n of settlers and the medium -density
establishment of the illicit crops, principally to the north -west and south- west, and high- density crops to the
south, on the border with the Department of Vaupés. These crops are located on a strip along the main rivers and

streams in the area, including Caño Grande in the jurisdiction of El Retorno, the river Unilla, in the jurisdiction
of the municipality of Calamar, R. Vaupés (municipality of Miraflores, and the river Inírida (jurisdiction of
Tomachipán- Puerto Paloma), and in general, along their banks at a distance of not more than 1.5 km from the

water (SIMCI project, 1999).

According to the map "Location of illicit crops in Colombia, 2000 census", it has been determined that the Caño
Grande nucleus affects the Nukak Nature Reserve in areas of jurisdiction of M unicipalities of El Retorno and

Calamar. In El Retorno there are 1687 ha planted with coca leaf, and in Calamar, 982 ha. This is equivalent to
32% of the total coca grown in the Department of Guaviare, and equivalent to 2.6% of the total crop area in
Colombia. According to the same map, and to the DIRAN base map 16, the locations of the illicit crop areas for
coca leaf plantation are principally to be found to the north, west and south of the Nature Reserve, both in the

buffer zone and inside the Reserve. The individual plots are larger than 4 ha, and there are some with an area of
more than 10 ha, surrounded by extensions of rough brachiaria pasture, other legal crops, or small amounts of
woodland (IDEADE et al 1996).

The incidence of the establishment of illicit crops inside the Reserve has resulted in the slash -and- burn
destruction of a large part of the original forest in this part of the country, selective exploitation of fine woods,
principally for the co nstruction of housing in the settlement at Tomachipan, the hunting of wild life ( tapirs,

boars, deer) and fishing. Given the dynamics of the population and the transitory presence of labourers for the
coca leaf harvest, this impact causes serious problems in terms of the population of flora and fauna species, in
addition to the displacement and de-culturalization of the indigenous tribes settled in the Reserve (IDEADE et al,
1996).

3.2. Influence on the Chiribiquete Nature Park (CHR)

This Nature Park is located at the south-western end of the Department of Guaviare and the north-eastern end of

the Department of Caquetá. It is one of the few of the remaining important sections of the rocky chain belonging
to the Guyana Shield, which rises up as a series of isolated geological formations through the surface of the
Amazon Plains. This makes it an intense focus of speciation and enemies of flora and fauna, some yet to be
17
discovered (Fundación Puerto Rastrojo 1992) .

The Precambrian and Mesozoic basement which covers almost all the Nature Park serves as "protection" for the
establishment of illicit crops inside the Park, and the establishment of settler communities, however this

important system is influenced in the south- western buffer area, by the dynamics of coca leaf production
established in the municipality of Miraflores (which has 3866 ha of coca leaf, equal to 47% of the total area of
the Department and 4% of the national total), on the banks of the River Vaupés and the Macaya river

16DIRAN Illicit Crop Eradication Department, Aerial Detection Group, Base Map for the Department of Guaviare, March 2000 (1:20000)
17Fundación Puerto Rastrojo 1992 Manejo y conservación del Parque Nacional Natural de Chiribiquete, 19pp.

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floodplains.

3.1.4. CATATUMBO REGION

3.1.4.1. La Gabarra (Norte de Santander) Nucleus. Area of influence of the Catatumbo-Bari Nature Park

(CTB)

The Catatumbo Nature Park (CTB) is in the extreme north of the Department of Norte de Santander , in the

jurisdiction of the muni cipalities of El Carmen, Convención, Teorama, Tibú and El Tarra . The natural
characteristics of the Park have been little studied, and there is an absence of detailed studies of flora and fauna,
however, there is in particular the presence of hillside, Andean woodland, and foothill woodland . (EMP, 1999).

The initiation of oil production in the Catatumbo area since the 1970s has attracted processes of settlement
which have slowly invaded the Reserve, with the subsequent loss of the lands of the indigenous communities and
the exhaustion of natural resources, mainly forestry. Further, settlement processes have caused socio-economic

transformation, forcible cultural, religious, political and language pressures, and there has been forced labour in
the producti on of oil and coal, the influence of the g uerrillas and the settlers: all this has brought about
substantial changes in the indigenous communities (Rodriguez 1997) . 18

The settlers established in the area both inside the P ark and in the nearby zones, have been engaged partly in the
extension of the agricultural frontier, and partly in the establishment of illicit coca leaf crops, particularly in the
Catatumbo, generating environmental and social problems (Rodriguez 1997).

The Baíi community derives part of its subsistence from crop farming and low intensity cattle ranging. Some of
the indigenous community s ell timber, particularly species such as Cariniana pyriformis, Bomnbacopsis sp,

Jacaranda copaia and Cordila alliodora, amongst others, which the middlemen buy at extremely low price, and
then resell in Cucuta. In addition to the problems proper to the community, there is the presence of three
guerrilla groups, the drug traffickers, the timber cartel and common criminals , all generating a climate of

instability and social insecurity, which have influenced welfare in the region (Rodriguez 1997).

La Gabarra nucleus affects the Catatumbo Park (CTB) due to the establishment of high -density coca leaf crops
by the settlers inside the P ark, and in the buffer zone mainly at the eastern end in the jurisdiction of the rural

district of La Gabarra, municipality of Tibú. According to the map " Location of illicit crops in Colombia 2000
census", it has been established that the municipality of La Gabarra has 7373 ha planted with coca leaf, or 94.5%
of the total area grown in the Department of Norte de Santander , and 7.1% of total for Colombia. According to
the same map, and the Antinarcotics Police base map 1, the location of the areas of illicit coca- leaf crops

affecting the Catatumbo Park are principally due to be found to the east, in the buffer zone and inside the park
itself.

3.1.5. CARIBBEAN REGION

3.1.5.1. Sierra Nevada de Santa Marta (Magdalena) Palomino Basin Nucleus, affecting
Sierra Nevada de Santa Marta Nature Park (SNS).

This Nature Park (SNS) forms part of the Sierra Nevada de Santa Marta Massif , declared by UNESCO as a Man
and the Biosphere R eserve. It is an isolated formation, independent of the Andes Range of Mountains, with an
area of 17,000 km², with all thermal floors and important vegetal formations of the tropics in the Americas, with

great diversity of flora and fauna. During the Pleistocene, this mountainous island served as a refuge for a

18Rodriguez A. Olga 1997 Informe de gestión, Parque Nacional Natural Catatumbo -Bari, Bogotá
19DIRAN Illicit Crop Eradication Department, Aerial Detectio n Group, Base Map for the Department of Norte de Santander, March 2000 (1:20000)

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number of species, of which 40-60% are endemic (Hernández, 1992, cited by Fundación Pro Sierra Nevada et al.
1997) .20

The colonization of the Nature Park (SNS) began in the mid-1950s, with the establishment of a range of different
human groups and the displacement of the local indigenous communities, to places higher up in the mountain. In

particular, there is the "coffee belt" (a strip between 900-1500 m above sea level), started by subsistence farmers
emigrating from the Andean zone. They produce coffee and subsistence crops to supply communities lower
down, and exercise strong pressure on the natural resources, particularly fine wood and wood for fuel , and

generate contamination due to the waste material from the coffee crop, which is thrown into streams. Another
human group which occupied the lower levels of the Sierra were the subsistence farmers from the coast, who
immigrated to the area after the banana and cotton crisis. They are mainly engaged in cattle ranging, with small
areas of subsistence crops (Fundación pro Sierra Nevada de Santa Marta et al 1997).

The human intervention in the Palomino basin took place with the opening up of the Caribbean Highway
(Troncal del Caribe) , and marihuana crops which in 1986 arrived at 500 m above sea level. The limits of the

Nature Park (PNN) which runs down to the sea be tween the Don D iego and Palomino r ivers 21s been
extensively colonized, has been subject to strong pressure by marihuana growers (Barbosa at al 1986) .

Poverty, and the marginal existence caused by state neglect has encouraged the substitution of the su bsistence
economy with marihuana, an activity which led to the rapid disappearance of woodland, with indiscriminate
felling to make way for the crop, which in the 1980s produced what was known as the "Bonanza marimbera",
strengthening new processes of colonization of the Nature Park (SNS)(Barbosa at al 1986).

Today, these crops are mixed with illicit lo w-density coca-leaf crops, mainly on the northern side of the P ark,
and inside it and in its buffer zone, mainly in the Palomino basin. In accordance with the map "Location of illicit

crops in Colombia 2000 census" (SIMCI project), it could be established that this Nature Park, the Palomino
basin, is affected by the coca leaf crops in the municipality of Rioacha , where there are 91 ha planted, and Santa
Marta, which has 669 ha has planted, equal to 100% of the area grown in the P ark, and in turn 1% of total crops
22
in Colombia. According to that map, and the DIRAN base map , the location of the illicit coca leaf crops is
mainly in the north of the Park, in the buffer zone and inside the park itself.

3.1.5.2. Serranía de Perijá Nucleus, Municipalities of Manaure and Agustín Codazzi
(Cesar) an d Villanueva (La Guajira). Affecting the Forestry Reserve created by Law
2/1959.

The municipalities of Manaure and Ag ustin Codazzi are in the lower part of the Western watershed of the
Serranía de Perijá and Serranía de Los Motilones in the Department of El Cesar. It should be noted that the

Serrania de Los Motilones Forestry Reserve, created by Law 2/1959 has been nominal, and has not prevented the
penetration by settlers, and even less, the extraction of natural resources.

The typical climate of Perijá is cold humid páramo, generally steep relief, which has favoured the establishment

of illicit opium poppy crops on soils with slopes of more than 50° (DIRAN and Environmental Audit 1999).

According to the map "Location of illicit crops in Colombia 2000 census", it has been established that the

Serranía de Perijá and particularly , the Los Motilones F orestry Reserve has b een mainly affected by opium
poppy crops in the Municipality of Manaure (239 ha) and Agustin Codazzi i (343 ha planted), this is equivalent

20
Fundación Pro Sierra Nevada de Santa Marta and UAESPBB The Nature Conservancy 1997 Evaluación Ecológica Rápida, definición de áreas crít icas
21ra la conservación de la Sierra Nevada de Santa Marta, Bogotá
Barbosa C, Rodriguez G and Avellaneda A, 1986. Precisión de los términos de referencias para estudios ambientales en la SiearrNevada de Santa Marta
22ectada por cultivos de marihuana y fumigación con glifosato. Commission report, INDERENA Bogota 31pp.
DIRAN Illicit Crop Eradication Department, Aerial Detection Group, Base Map for the Department of La Gaujira, March 2000

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to 61% of the total opium poppy crop in the Department of Cesar; and in the municipality of Villanueva there are
55 ha planted, equivalent to 36% of the total in the Department of La Guajira . These areas taken together are

equivalent to 21% of the total area of crop in Colombia. According to the same map, the areas of illicit opium
poppy crops are mainly to be found in the east of the forestry reserve.

3.2. Eradication of illicit crops in zones close to the bridge protected areas

3.2.1. Measures of prevention

1. Safety strip, for the spraying area

According to D ecree 1843/1991 Article 87 "Safety strip", it is stated that the application of pesticides and in
rural areas will not be effected less than 10 m on the ground or 100 m in the air as a safety strip along or around
watercourses or bodies of water, main roads, human and animal population or any other area requiring special

protection.

Therefore, this principle will be applied to the nearby areas as defined in environmental legislation, in addition to

measures in other current environmental legislation.

2. Operational planning

During the operational planning for the execution of the program for spraying illicit crops, the nuclei of illicit
crops detected and verified will be superimposed on the cartographic base for protected areas, in order to plan
spraying flights outside the limit of the protected area.

Given that the SATLOC system provides a precise geographical location of places where spraying is taking
place during the operational program, the flight lines in the program will be superimposed on the map in order to

ensure that spraying does not take place inside the project each protected area.

3. Permanent exchange of inter- institutional information

In the context of institutional and integration, efforts will be made to secure a permanent exchange of
information with the UAESPN N administration in order to establish the dynamics of illicit crops in side the
Nature Parks, and to adopt appropriate measures , whether for manual eradication by local c onsensus or by

imposition. Given that the limitation of the establishment of illicit crops allows strategic ec osystems and nature
reserves to be conserved.

At the same time, strategies will be considered jointly with the UAESPN N of strategies to be adopted in
coordination with the N ational Police and the Municipalities, to discourage the advance of illicit crops into
protected areas.

3.2.2. Formulation of specific programs

The Plan is set in the context of current environmental regulations, and within the illicit crop eradication
program coordinated by the DNE. The criterion for development falls in the framework of investigation, and as a
general objective, proposes activities providing new knowledge with regards to follow -up of potential impacts
which may be generated with the eradication of illicit crops by air in zones close to protected areas.

3.2.2.1. Program: Monitoring of successional dynamics in vegetal communities in lots

sprayed close to protected areas

IDENTIFIED ENVIRONMENTAL IMPACT

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Potential effects generated on vegetation, caused by the eradication of coca leaf crops in Nature Park buffer
zones

TYPE OF MEASURE PROPOSED

Research

OBJECTIVES

− To evaluate the impact caused on vegetation in the Nature Parks due to the eradication of illicit coca leaf

and opium poppy crops in buffer zones and areas bordering the Nature Parks.
− To compile this information to identify future research work.

− To record changes occurring in vegetation due to the effect of the eradication of coca leaf and opium
poppy crops.

LOCATION

REGION NUCLEUS PARKS Location of buffer zones
Orinoco basin, Coca Puerto Rico, Meta Sierra de la Macarena Buffer zone (NE edge)

Amazon basin, coca Caño Grande -La Lindosa, Nukak Buffer zone (N and SW
Guaviare edges)
Caribbean, Coca Sierra Nevada de Santa Sierra Nevada de Santa Buffer zone (N end,)
Marta Marta Palomino basin
Catatumbo, coca. La Gabarra, Norte de Catatumbo-Bari Buffer zone (E edge)
Santander
Andean, poppy Iquira-Teruel-Páez, Nevado del Huila Buffer zone.
Chaparral – San Antonio

JUSTIFICATION

The protected areas are affected by activities undertaken outside the boundari es, such as ecological processes,

and physical, cultural and socio-economic changes.

The eradication of coca leaf and opium poppy crops in the Nature Park buffer zones and in the Nukak Nature

Park (RNN) may affect vegetation inside those parks. There is a lack of knowledge directly related to this
problem, and given that the protected areas have to be managed in a complementary fashion, and not in isolation
from the dynamics of the ecology of the landscape, which involve the protected zone and its surround ings

(Simonetti 1997).

The influence exerted by local communities close to the areas of natural forest in protected zones is a decisive

factor when planning conservation strategy, especially addressed to the maintenance of gene flow supporting
biodiversity in the Nature Parks.

Amongst the research efforts required, priorities must be observed in the identification and understanding of the
effects of external factors arising from the matrix surrounding the Nature Park s (Sauders et al 1991), where

situations are directly related to adjacent anthropic activity, and the attitude of the community to the natural area.

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METHODOLOGY

Taking as a basis the information supplied byRapid Ecological Assessment (REA), the general procedure

consists of the following:

− Location of places which have been the object of the eradication of illicit crops in buffer zones and the
detailed map locations prepared in the REA.

− Selection of sample areas

− The sample areas must meet certain minimum requirements, such asthat they must be located in a

fringe of 1 km from the edge of the Park (that is, on the edge of the buffer zone), there must have must
be facilities and access for data taking, and spraying activities must have been undertaken.

− The selection of sampling sites ll be made in accordance with statistical procedures for random

stratified sampling, taking account of the requirements mentioned.

− The area selected will be located on the ground with the help of a GPS, and will be demarcated for easy
subsequent identification, for which purpose of the link will be formed witntinarcotics Police

GIS.

− An experimental design will be used, to treat the area between the eradicated crop and the edge of the
park, and where the control will be a nearby area which does not have this type of intervention (illicit
crop), with related replicas.

− Each area selected will involve treatment and control, and a transect will be established with a suggested
length of 100 m x 10 m wide (0.1 ha), in turn comprised of five rectangular plots of 20 m long by 10 m
wide (Parde and Bouchon 1994, Prodan et al 1994).

− The composition of flora of all arboreal species with a diameter breast height of more than 10 cm will be
recorded, implying a recording form and calipers (Prodan et al 1994, Parde and Bouchon 1994).

− The plots will then be subdivided into some concentric subplots of 10 m long by 5 m wide ( Prodan et al
1994), which will be established to record saplings, small trees, shrubs and scrub (Gysel and Lyon,
1980, Zevallos and Matthei 1994).

− There will be an evaluation of 1) Composition and structure of vegetation, such as composition of fauna,
frequency, abundance and dominance of species, 2)phytosanitary status, 3) ratio between area and
wealth of species based on linear regression modes (Gle ason 1922, Arrhenius1921), 4) species
diversity indices, 5) effects of the influence of the surrounding matrixlight intensity, relative

humidity, temperature.

− Liu and Ashton (1999) ha ve suggested that changes in variables suchthe diametric structure and
composition of species are good indicators to evaluate the impact of man on vegetal communities.

− A statistical comparison will be made of results of the plots inside and outside ark, both in
treatment and in the control trans ect. This comparison will enable the real impact of eradication to be
established for illicit crop eradication in buffer zones, on vegetation inside the Nature Parks.

− It should be noted that the samples will be made regularly - twice a year and at least for fiv e years - in
order to establish a monitoring mechanism for the dynamics of vegetation over time. However, it is

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clarified that studies of this kind generally involve periods of more than five years (Laurence, 1991).

− Information compiled will be input into a custom-made database.

The analysis of partial results will be used as and when obtained to propose new research, and as a source of
information for monitoring the dynamics of vegetal succession and the offer of flora is;the Nature Park
also, this will establish the capacity of resilience of these systems.

Likewise, the areas provided for in the project will act as pilot units for estimating subsequent environmental
impact in similar ecological areas or other types of an impact not provided for in the short term.

Total time for execution of the project: five years

TIMETABLE PROPOSED FOR THE FIRST TWO YEARS

This includes activities for the first two years

Time (quarters)
Activity 1 2 3 4 5 6 7 8
Identification and
selection of samplX

areas
Preparation of
maps, recording X XXX
forms, field
equipment, etc-

Set up field
sampling units XXX XXX
Field sampling X X X X
Create and feed XXX XXX X X X X

database

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COST IN 2000 PESOS

Description Amount Col$000

COSTS YEAR 1
2 Professionals, 1 field assistant 84,000
Mapping, database** 30,000

General information 1,000
Office materials 3,000
Field materials 4,000
Transport 3,000

Publications 2,000
SUBTOTAL YEAR 1 127,000
COSTS YEAR 2

Professionals (4 months a year) 48,000
Perdiems (1 months a year) 4,500
Student degree papers (10) (2 per region) 4 32,000
months/year/4 years

Transport allowance per nucleus 3,200
SUBTOTAL YEAR 2 87,700
TOTAL COST OF PROGRAM 214,,700

** This item will be paid for by integration of the Program into the SIMCI system

OPERATION OF THE PROGRAM

The operation of the program will be undertaken in each of the area selected in the item of “Location”, and

results will be made public every six months, with regard to the results of sampling and analysis incorporated for
each of the regions.

For the program to be implemented in parallel for each of the regions, with the development of a unified

methodology, the intention will be to develop th is research together with the development of graduate and
undergraduate degree papers, coordinated by specialist professionals, and with ample recognition of the
successional dynamics of vegetal communities.

The results obtained in the first year of research will be used to determthe successional dynamics in each
region, and measures will be adopted as considered relevant with regard to the formulation of specific programs
to encourage these processes of restoration of vegetal cover. At the same time, analysis will be mae of the
relationships between the results of the other programs formulated in the components of vegetation, soil, water,
fauna and the social component.

The results of this program will be publishedevery six months, and will be made available to national-order
institutions which research into vegetation, educational institutions and NGOs, in order to form discussion
groups for the results and to make joint proposals of measures to be adopted.

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ENTITIES
Coordinating entity; DNE, through its Regional Technical Units
Support entities: Ministry of the Environment, UAESPNN, universities, NGOs, research institutes (Alexander
van von Humboldt, SINCHI, CONIF).

CONDITIONS

− Budget availability for entities engaged in the program

− Problems of public order in buffer zones, or in municipalities close to the Parks

BIBLIOGRAPHY SUPPORTING THE PROGRAM:

Arrhenius O. 1921. Species and area. Journal of Ecology.9 9 :95-99

Gleason H.A. 1922. On the relation between species and area. Ecology 3: 158-162.

Gysel L.W and L.J L yon 1980 Habitat analysis and evaluation. In: Wildlife management techniques manual.

Schemnitz S (Ed) The Wildlife Society. Washington, D.C. U.S.A. 686 p.

Laurance, W.F. 1991: Edge effects in tropical forest fragments: application of a model for the desig n of nature
reserves. Biological Conservation 57: 205-210.

Liu J. and P. Ashton. 1999. Simulating effects of landscape context and timber harvest on tree species diversity.
Ecological Applications 9 (1): 186-201.

Saunders D.A., R.J Hobbs and C.R. Margule s. 1991. Biological consequences of ecosystem fragmentation : a

review. Conservation Biology Vo 5(1): 18-32

Simonetti J.A. 1997. Áreas silvestres protegidas ¿Protegidas y protectoras? In: Diaz-Pineca, F., J.M. de Miguel
y M.A. Casado (Eds) La diversidad biológica y la cultura ural en la base de la gestión ambiental del desarrollo.
P 85-91.

William-Linera G, V. Domínguez -Gastelú & M.E. García- Zurita 1997. Microenvironmental and floristics of
different edges in a fragmented tropical rainforest. Conservations Biology 12(5): 1091-1102.

Zevallos, P.A. and O.R. Methei. 1994. Caracterrización del bosque nativ o del Fundo Escuadr ón, Concepción,
Chile. Bosque 15 : 3-13.

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3.2.2.2. Program. Follow-up and monitoring of vegetal cover in areas which are the obj ect of
the eradication of illicit crops in zones close to protected areas through remote sensing. A

vision of landscape ecology.

ENVIRONMENTAL IMPACT IDENTIFIED

− Temporary loss of vegetal cover
− Change in the use and vegetal cover in areas close to the Nature Parks systems

TYPE OF MEASURE PROPOSED
Research

OBJECTIVES

− To monitor changes in the landscape over time, occurring due to establishment- eradication dynamics of
illegal crops, in areas close to the Nature Parks system (SPPN).
− To quantify the impact on areas close to the Nature Parks affected by the establishment -eradication of

illicit crops over time.
− To determine areas in which special programs for rehabilitation and recovery of ecosystems affected by
the dynamics of establishment-eradication of the illicit crops could be implemented.

− To protect and recover fragile systems of great strategic value to regional and national development.
− To consolidate special management areas in places made critical by the establishment and eradication of
illicit crops.

LOCATION

REGION NUCLEUS PARKS Location of buffer zones

Orinoco basin, Coca Puerto Rico, Meta Sierra de la Macarena Buffer zone (NE edge)
Amazon basin, coca Caño Grande -La Lindosa, Nukak Buffer zone (N and SW
Guaviare edges)
Caribbean, Coca Sierra N evada de Santa Sierra Nevada de Santa Buffer zone (N end,)
Marta Marta Palomino basin
Catatumbo, coca. La Gabarra, Norte de Catatumbo-Bari Buffer zone (E edge)
Santander
Andean, poppy Iquira-Teruel-Páez, Nevado del Huila Buffer zone.
Chaparral – San Antonio

JUSTIFICATION

The natural landscape cover is the result of complex series of interactions between climate, soil, water and biota
(Fuentes 1989). The alteration of the landscape is due to natural phenomena (for example, volcanic eruption),

and human activity (for example, introduction of crops into woodland areas, drastic changes in soil use), which
modify the surroundings.

Formulation of alternative occupation in a given area, whether to propose cultural use, forestry, or conservation,

requires knowledge of the biophysical and socioeconomic medium as close as possible to reality ( Andrade
1994).

The ecology of the landscape is the theoretical and methodological framework which is most appropriate to for
the integrated study of the landscape, which is determined overall, and not as simply the sum of its parts
(Burrough 1986).

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The external characteristics of landscape are those which determine and permit the recognition and
differentiation within it, and principally composed of geo- forms and di fferent types of cover (Foreman and
Godron 1986).

Further, timeseries studies and analysis of the dynamics of changes in the landscape using comparisons of
photographic records, theme-maps, or remote sensing images, have frequently been used to make comparisons
of different types of soil or vegetal cover through the dynamics of time ( Noss 1990, Ripple and S pies 1991,
Fallas 1998).

In Colombia, the methods which come closest to this approach are the "Ecological Landscape Surveys", made by
IGAC Rural Survey Unit and in IDEADE of the Javeriana University. Recently, the methods for landscape
ecology have been used by the GIS-PAFC Project, developed by IGAC (Andrade 1994).

METHODOLOGY

The general methodology proposed combines that used by the IGAC GIS-PAFC Project, which in turn is based
on methodological guidance proposed by FAO, with some adjustments for application to the case of follow -up
and monitoring of vegetal cover in target areas for illicit crop eradication in zones close to the Nature Park s

system. The procedure is described below:

Diagnosis. This is based on the identification of the central problem with regard to the effects generated by illicit
crops which are the object of spraying in Nature Park buffer zones. This diagnosis would be made with from the

results obtained in a Rapid Ecological Assessment.

Formulation of specific and general objectives, which in turn allow the level of detail to be established, along
with the volume of information required and inputs to be used. For this case, it is suggested that studies are made
at reconnaissance level (working scale of 1:500,000 to 1:100, 000, allowing the use of satellite image, radar and

aerial photography images on a small scale 1: 60,000), or semi-detailed (working scale 1 : 25,000-1:10,000, by
the use of satellite radar images or aerial photography on medium scale between 1:20,00 0 and 1:40,000) (CIAF,
1981)

Identification of indicators of variation of landscape dynamics, which will allow changes occurring over time
to be measured and monitored. It is suggested that a competent group of professionals be formed which will
approach the problem from different standpoints. The indicator will be the measurement of the effect on the
descriptor element (part of the variable identified), as selected. S ome indicators may be more relevant than
others, and they should therefore be weighted, to give a better analysis the setting of priorities of variables to

monitored, and the development of subsequent research or management (Montenegro, 1998).

Some indicators suggested to quantify the spatial heterogeneity and dynamics of spatial variation of landscape
are (Ripple at al 1991, Forman 1995): 1) Variation of size of crop areas, and eradicated areas, 2) Changing shape

of these units, 3) Spatial distribution and density of the same, 4) Abundance in the Nature Park buffer zones, 5)
Spacing between areas, 6) Density and dispersion of the units.

The analysis of results will be made in the light of the application of statistical tests (parametric or otherwise,
depending on the indicator), which will allow evaluations to be made with reliability criteria (level of

significance of α = equals 0.05).

Multi-temporal analysis. Based on the use of remote sensing and GIS , and in accordance with the level of
detail proposed in the formulation of objectives, it is proposed that specific monitoring studies be effected on the

dynamics of vegetation in areas close to Nature Parks affected by the establishment of an illicit crops where the
eradication program has been implemented, in order to 1) verify the rate of substitution of native woodland by
crops; 2) evaluate the recovery rate of ecosystems once the crops have been eradicated; 3) monitor the ecological
comportment of the landscape impacted (through the application of indicators) ; 4) evaluate the comportment

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(invasive or exclusive) of surrounding vegetation in the areas affected ; 5) observe the growth of vegetation in
buffer zones, etc. This, considering that the multiplicity of information which can be obtained through the use of
instruments such as remote sensing and GIS.

The study of monitoring will be made through the through appation and interpretation (visual or digital,
depending on the sensor selected) of the indicators proposed and on images recorded in sequential time periods
(six monthly, yearly). In addition, images may be selected from previous years s o that retrospective studies can
also be made. This will allow greater precision in the sp atial quantification of dynamics which have occurred in
the landscape in areas close to the Nature Parks.

Finally, the information recorded will provide important elements in the formul ation of programs for recovery,
management, rehabilitation and research at landscape level, which can be effected in these areas.

TIMETABLE time in quarters
Activity 1 2 3 4 5 6 7
Diagnosis XXX
Selection and XXX

identification of
indicators
Selection of sensor type,XXX XXX XXX
acquisition of material,

interpretation
Multitemporal analysis of XX XXX XXX XXX
images and statistics of
results

Preparation of reports, XXX XXX
formulation of new
programs

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TOTAL EXECUTION TIME
1 YEAR

COSTS

Description Col$000
for professionals (two forestry specialist GIS 144,000
forestry engineers, one biologist and one

geographical or land survey engineer with
specialist studies in GIS)
Remote sensing and cartography 7,000
General information 1,000

Office materials 4,000
Field materials 4,000
Transport 16,000
Publications 5,000

Socialization of results 5,000
TOTAL COST OF THE PROGRAMME 186,000

ENTITIES

Coordinating entity: DNE
Support entities: DIRAN, Ministry of the Environment, UAEESPNN, IGAC, universities, NGOs, Research
institutes (Alexander from Humboldt, SINCHI, CONIF).

CONDITIONS

Budget availability of entities engaged in the program
Availability of equipment and qualified personnel in the agencies engaged.

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5. Assessment of Environmental Impacts of Eradication with Glyphosate in
the Short, Mid, and Long Term

The assessment of environmental impacts resulting from spraying with Glyphosate

herbicide in the different regions of the country requires not only contextualizing the
program regarding the areas where illi cit crops are established and beyond the
identification of potential effects be it negative and / or positive and their evaluation,
as well as the moment in which they occur in the short, mid or long term. It is also
necessary to clearly determine what the mobility of the herbicide is in the natural
settings where it is applied.

Therefore, the development of this aspect is aimed at determining what the gaps in
existing information are , which, once solved with specific research programs, will
allow to establish on solid ground the short, mid, and long term environmental
impacts and the environmental measures that should be adopted depending on the
nature of the impact and its characteristics.

Taking as start point the conditions of applications, it follows that:

a. Spray mix:

Coca Crops Commercial Glyphosate formulation: Roundup 10.4 liters /

hectare, water 12.85 liters / hectare, and Cosmoflux 0.25 liters /
hectare

Poppy Crops Commercial Glyphosate formulation: Roundup 2.5 liters /
hectare, water 47.25 liters / hectare, and Cosmoflux 0.25 liters /

hectare

b. Application Conditions:

Flight altitude: 15 to 20 meters depending on the topographic conditions
Aircraft speed: between 120 and 150 Miles / hour

Mean volumetric diameter of droplets on foliage surface: >250 micra

c. Weather conditions for application

Weather condition Coca crop Poppy crop
Maximum wind speed for 6 knots 4 knots

application
Relative humidity > 75% >85%
Temperature <30 centigrade degrees <13 centigrade degrees
Optimal application time Between 6 and 10 a.m. Between 6 and 9 a.m.
Topography Flat to wavy Mountainous to very

mountainous
Source: Antinarcotics Direction, Environmental Management Plan 1998.

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These weather conditions for application are strictly observed in order to achieve

the greatest efficacy in application.

Location of plots with geographic coordinates , each aircraft has a SATLOC
unit system, which has been previously programmed according to satellite images
available for plot location and with the prior reconnaissance over flight, which

allows the pilot to release the herbicide with precise coordinates. Likewise, this
system records the start and finish point of discharge; this length times the swath
width allows to estimate with precision the amount of sprayed hectares.

Growing stage of the illicit crop

Poppy crop. The optimal application age is at one and four and a half months,
because at this point, the plants have not reached their physiological maturity,
therefore it cannot act as a dryer or ac celerator of seeds production. To conduct
spraying in that period, permanent monitoring of the areas by interpretation of

satellite images and field verifications is carried out.

Coca crop. It is applied to foliage of plants between 2 and 4 months after planting.
When the crop is more developed, it is conducted when the crop shows greater
density, that is, when leaves have not been harvested. Taking into account that

the planting density are as high as 90.000 per hectare, and leaves are tender due
to continuing harvesting, it guarantees a greater effectiveness of the herbicide for
eradication of the illicit crop.

Frequency of application per plot of illicit crop .

The aim of spraying is to considerably affect the illicit crop, in 70% at least, so that
it is considered economically unfeasible, that is, production costs are higher than
profits obtained from it.

Therefore, in each plot of illicit crop in av erage, 2 sprayings in different swaths are
conducted with the purpose of considerably affecting its production.

These applications are conducted a 1 year time period for security reasons and are
carried out in different sectors of the plot in different swaths 2, which means that a

same swath of the plot is sprayed twice.

It often happens that these applicati ons are not necess ary because growers
abandon the illicit activity because they feel they have been spotted by the police.

______________________________
23 The application swaths correspond to the aircraft swath (between 30 and 50 meters). Source DIRAN

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With these specifications about the spraying activity, the network diagram was
selected as the method for the Assessment of Environmental Impacts of
Eradication with Glyphosate in the short, mid, and long term because it integrates

the causes of impacts and their effects through interrelations existing between
causal actions and environmental elements that receive the impact.

The diagram shown below allows to clearly establish what the potential effects
resulting from the application of herbicide fo r eradication of illicit crops are and it
also allows to identify the information lack that needs to be solved to estimate

these impacts and propose environmental measures according to them.

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In the first level we start from the assumption that the introduction of a chemical
substance generates a modification of the environmental element and that such an
effect is considered negative to the extent that there is contamination

In other words, there is contamination of an environmental element when the limits
in which this element is able to degrade external substances (contaminant) are
exceeded and these substances cause a change in its dynamics. The modification
that this substance causes will depend on the amount that enters the
environmental element, the time it remains in it, and the frequency of its entrance.

Thus, it is considered essential to start research programs which, included in the
environmental management Plan, become mitigation Programs that monitor the
ecosystems to determine if there are changes in its interrelation and start
investigating their causes.

It is important to point out that these programs will be coordinated by the National
Narcotics Directorate and for its implementation will count on research agreements
with national entities, universities, and international organizations.

Taking as start point the assumption that there will be contamination of the
environmental elements, the need for research programs is then reached.

However, if the results from the Verification Processes of the Program for the
Eradication of Illicit Crops in Colombia are analyzed, which are presented below as
photographic records and the field samplings done within the Environmental
Management Plan performed in1998, it can be observed that there is no evidence
of the environmental effects previously described and that, therefore, the

Environmental Management Plan must be oriented towards prevention and control
measures that guarantee the correct application of the herbicide in each of the
country zones.

Bringing these two considerations together is summarized in developing structured
researches that include systematic samplings in every region target of the

management Plan and that they are carried out in the lab and field.

These researches will allow to know with certainty the environmental effects on
each component and to determine its magnitude and intensity in order to propose
the concrete environmental measures to revert, compensate or correct them.

In order to relate the environmental impacts from the program for the eradication of
illicit crops by spraying with the reports of the environmental audit, a series of
photographic images have been selected from the plots that were sprayed at
different dates and that upon carrying out the eradication verification at different
time intervals after spraying, it is observed that that there is an efficient recovery of
vegetation covers.

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Supplementary information to the Environmental Management Plan for the eradication of illicit crops 

5.1. Analysis of verification images of eradication of illicit crops

Images of fumigated illicit crops were taken at various times since 1995, with different lapses of time in

days after spraying and in different crops (coca-leaf and opium-poppy).

It should be appreciated that the range of information that can be extracted from these image and the
figures of the Environmental Audit is very wide. The following can be observed from these images:

That, given the size of the plots chosen for eradication, it is unlikely that nearby vegetation would be
affected due to the effects of drift.

The processes of natural regeneratio n are rapid, indicating that persistence in the soil is moderate

because the high density of the illici t crop prevents any significant q uantity from reaching it, and the
biomass is deposited in the illicit cr op. These considerat ions are the result of observations made by
the eradication verification commission, formed by the environmental audit, NAS officers from the US

Embassy and active members of DIRAN.

The photographs also show that the effects on nearby native vegetation, and specifically lawful crops
(plantain and maize) are minimal evidenced by partial yellowing of the foliage, though this not threaten

survival.

The analysis of the vegetation close to the sprayed plots allows information to be extracted in relation
to the adaptive strategies of plants there with regard to extreme conditions to which they are

subjected. The analysis of these symmorphies is made at the point of potential ill-effects on vegetation
due to spraying with glyphosate.

There follows an account of the images included, arranged in order of time elapsed since spraying.

The attached images correspond to those of reports of the inter-institutional verification committee for

the eradication of illicit crops.

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LIST OF IMAGES SUPPL IED BY THE INTER- INBST ITUTI ONAL VE RIFICATI ON COM MITTE ES FOR
THE E RADI CAT ION OF I LLICIT CROPS.

LOCATION. TIME ELAPSED AFTER SPRAYING

MUNICIPALITY OF CHAPARRAL NOT SPRAYED

MUNICIPALITY OF MAPIRIPAN NOT SPRAYED

MUNICIPIO DE SAN ANTONIO 8DAYS

M!UNICIPALITY OF PLANADAS- TOLIMA 5 DAYS

DEPARTMENT OFHUILA 8 DAYS

IQü iRA (RIO l\:EGRO) 10 DAYS

C.AÑOGRANDE (EL RETOR.NO) 40 DAYS

SANJOSE DELGUAVIARE 45DAYS

RIOBLANCO- TOLIMA 53 DAYS
RIOBLANCO -TOLIMA 53 DAYS

CHAPARRA L-TOLIMA 61DAYS

CHAPARRAL - TOLIMA 62DAYS

SANJOSE DEL GUAVIARE 70 DAYS

RIOBLANCOTOLIMA 77DAYS

CHAPARRAL -TOLIMA 86DAYS

CHAPARRAL -TOLIMA 86 DAYS

SANJOSE DEL GUAVlARE 90-120 DAYS

EL RETORNO -CANO GRANDE (GUAVIARE) 125 DAYS

MIRAFLOR.ES(GUAVIAR.E) 133 DAYS
SANJOSE DEL GUAVIARE 139 DAYS

SAN JOSE DEL GUAVIARE 180 DAYS

MIRAFLOR.ES -GUAVIARE 227 DAYS

EL RETORNO 232 DAYS

EL RETORNO 284 DAYS

SAN ANTONIO -CHAPARRAL 360 DAYS

SECTOREL RETORNO 12 MONTHS

RIO BLANCO 12-14 MONTHS

Si\N JOSE DEL GUAVIARE 14MONTHS

RIOBLANCO 2YEARS

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PHOTO No.: VA 21 ROLL: RVA 118

LOCATION N 03º 49'12,0" w 75° 38' 28.4" Chaparral

VERIFICATION DATE: Feb. 13/96 TIME SINCE SPRAYING

COMMENTS - Large plot being cleared for future planting of opium pop20 ha.er

- Note the “ crimi nal" destruction of the Andean jungle

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PHOTO No.: VC 9 ROLL: RVC 112

LOCATION N 02º 52' 06 W 72° 03' 02.3 " Mapiripan

VERIFICATION DATE: TIME SINCE SPRAYING

COMMENTS - The Plot prior to spraying

- Note in photo VC 7 the effects of aerial spraying with glyphosate

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PHOTO No.: VA 08 ROLL: RVA 118

LOCATION N 03º 52' 18.3 W 75° 38' 18.3 " San Antonio

VERIFICATION DATE: Feb. 13/96 TIME SINCE SPRAYING ± 8 days

COMMENTS - Plot sprayed not more tan 10 days before

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PLOT Nº 7

PHOTO No.: VA 15 ROLL: RVA 138

LOCATION N 02º 58.240' W 75° 46.480' PLANADAS – TOLIMA

VERIFICATION DATE: 27/02/97 TIME SINCE SPRAYING 5 days

COMMENTS - Note the plot only a few days after glyphosate spraying

- Note that the plant s have a yellowish tinge, indicating certain death
(100% control).

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PHOTO No.: VA 13 ROLL: RVA 91

LOCATION N 03º 16.46' W 74° 40.25' COLOMBIA (HUILA)

VERIFICATION DATE: June 22 de 1995 TIME SINCE SPRAYING 8 days

COMMENTS - Police officer trying to tear out a maize plant

- Note that the dosage of 2,5L/Ha of glyphosate affected the opium poppy-plants;
maize plants between them only slightly affected

- No effect on surrounding vegetation

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PHOTO No.: VA 36 ROLL: RVA 118

LOCATION N 02º 46' 04.6” 75° 45' 41.2” Iquira (Rio Negro)

VERIFICATION DATE: Feb. 13/96 TIME SINCE SPRAYING ± 1O days

COMMENTS - Sprayed with glyphosate about 10 days ago. Not the effectiveness of the
herbicide which has killed almost 100% of the crop

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PLOT 11

PHOTO No.: VC 1 ROLL: RVC 129

LOCATION N 02º 16.414' W 72° 24.512' Caño Grande (El Retorno)

VERIFICATION DATE: Dic. 11 de 1996 TIME SINCE SPRAYING ± 40 days

COMMENTS - In (A). note the plot of ±3 ha of coca

- Area around Caño Pava and Caño Grande.

- This plot was not part of the simple selected but was visited in the

company of the JIFE-UNDCP Observer to see the results of aerial spraying
with glyphosate after 40 days.

- No damage or negative environmental impact on nearby shrubs and trees

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PHOTO No.: VC 26 ROLL: RVC 105

LOCATION N 02º 32' 25.3” W 72° 27' 52.4” San Jose del Guaviare

VERIFICATION DATE: Nov. 29, 1995 TIME SINCE SPRAYING ± 45 days

COMMENTS - Surrounding trees minimally affected by glyphosate spraying

- Tons of biomass destroyed to make way for illicit coca-leaf crops.

- Yarumo and balso are the species most susceptible to glyphosate. They recover

in a few months after slight loss of foliage.

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PLOT 4

PHOTO No.: VC 36A ROLL: RVA 137

LOCATION N 03º 27'550” W 75° 45' 190” Rio Blanco

VERIFICATION DATE: 27/02/97 TIME SINCE SPRAYING ± 53 days

COMMENTS - Destruction – slash-and burn and deforestation – are common practices in
illicit crops.

- (1) note the total destruction of opium poppy..

- (2) See newly planted poppy, not more than 30 - 45 days.

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PLOT 4

PHOTO No.: VA 35 ROLL: RVA 137

LOCATION N 03º 27'550” W 75° 45' 190” Rio Blanco – Tolima

VERIFICATION DATE: 27/02/97 TIME SINCE SPRAYING ± 53 days

COMMENTS - Note the maize crop (1) unaffected, but the poppy plants are eradicated.

- Note that the trend in the establishment of illicit crops is to look for areas

of higher ground (over 2.500 m).

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PLOT 4

PHOTO No.: VA 15A ROLL: RVA 132

LOCATI ON N 03º 41.82' W 75° 42.03” Chaparral Tolima

VERIFICATION DATE: DEC 18 1996 TIME SINCE SPRAYING 61 days

COMMENTS - Note the excellent application of glyphosate spraying.

- Efficiency is 100%. Plot of 20 – 25 ha.

- Note the insensitivity of the drug crop growers in destroying invaluable High
Andean Woodland systems.

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PHOTO No.: VA 8 ROLL: RVA 132

LOCATION N 03º 41.98'W 75° 41.03” Chaparral Tolima

VERIFICATION DATE: DEC 17 1996 TIME SINCE SPRAYING 62 days

COMMENTS - Plot of 6 - 10 ha.

- Note spraying e fficiency of 80% - 90%

- Note the phenomenon of serious erosion caused by
deforestation

on steep slopes (1 ).

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PHOTO No.: VC 5 ROLL: RVC 105

LOCATION N 02º 29' 04.6” 72° 26' 41.” San Jose del Guaviare

VERIFICATION DATE: Nov. 29 de 1995 TIME SINCE SPRAYING ± 70 days

COMMENTS - Palms are another species that quickly invade abandoned land. 1, after
spraying.

- The coca crop disappeared after aerial spraying with glyphosate and
the effects on surrounding vegetation are.nil, 2

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PLOT 2

PHOTO No.: VA 31 ROLL: RVA 137

LOCATION N 03º 27.100' W 75° 50.600'

VERIFICATION DATE: 27/02/97
TIME SINCE SPRAYING ± 77 days

COMMENTS - Plot in Rioblanco - Tolima.

- Note the track of the aircraft (1), which was effective in eradicating the illicit
poppy crops.

- Note that the areas eradicated are used for cattle ranging, an activity

inappropriate for this type of soil and physiography

- In (2) plots sprayed in previous years are now in the process of natural

regeneration or restoration

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PHOTO No.: VA 27 ROLL: RVA 137

LOCATION N 03º 39.380' W 75° 39.300'

VERIFICATION DATE: 27/02/97 TIME SINCE SPRAYING ± 86 days

COMMENTS - Plot in Chaparral - Tolima, towards San José de Las Hermosas.

- Note that 90% of the area planted with opium poppy was eradicated.

- Note that the natural forest was not affected by aerial spraying.

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PHOTO No.: VA 29 ROLL: RVA 137

LOCATION N 03º 39.380' W 75° 39.300 Chapa rral

VERIFICATION DATE: 27/02/97 TIME SINCE SPRAYING ± 86 days

COMMENTS - Note that the trees are not affected by aerial spraying with glyphosate

- Note in (1) a small area of opium-poppy not sprayed but abandoned
because, no doubt, its small size was not economically viable

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PHOTO No.:
VC 33 ROLL: RVC 104

LOCATION N 02º 24' 41.4” W 72° 31' 09.9San Jose del Guaviare

VERIFICATION DATE: Nov. 29 1995 TIME SINCE SPRAYING ± 90 – 120 days

COMMENTS - Natural restoration is excellent and vegetation on the edge of the plot shows no
signs of negative effects from spraying 1.

- In 2 note the ecological crime of the destruction of nature, large trees. palms etc

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PLOT 2

PHOTO No.: VC 20 ROLL: RVC 137

LOCATION N 02º 16.609'W 72° 33.530

VERIFICATION DATE: 26/02/97 TIME SINCE SPRAYING 128 days

COMMENTS - Note completely necrotic (dead tissue) logs and branches.

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PHOTO No.: VC 31 ROLL: RVC 129

LOCATION N 01º 26.64' W 71° 52.76' Miraflores (Guaviare)

VERIFICATION DATE: Dic. 12 1996
TIME SINCE SPRAYING 125 days

COMMENTS - Plot size: 30 - 50 ha.

- Effectiveness of spraying:

80%-90%.

- Note the track of the aircraft. Here, the coca is completely dead
and out of production (1).

- In (2) the coca continues, but in a bad state.

- In (3),natural regeneration secondary succession (rapid-growth
species) e.g. yagrumo, balsa tree, e.c

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PHOTO No.: VC 8A ROLL: RVC 121

LOCATION N 02º 47' 00.2”W 72° 05' 45.8”San Jose del Guaviare

VERIFICATION DATE: Nov. 29 1995 TIME SINCE SPRAYING ± 90 – 120 days

COMMENTS - Note the size of the coca plot, abandoned after spraying with glyphosate

- Totally dead coca-plants (1).

- Note the invasion of yagrumo (2), shrubs and grasses

- An overflight determined that crops sprayed had been eradicated

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PHOTO No.: VC 8 ROLL: RVC 105

LOCATION N 02º 30' 11.2” W 72° 27' 38.0San Jose del Guaviare

VERIFICATION DATE: Nov. 29 1995 TIME SINCE SPRAYING ± 180 days

COMMENTS

- NAS personnel in Colombia took part in the verification.

- This plot was completely eradicated. The picture shows very encouraging
natural regeneration of forest
.

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PLOT 1

PHOTO No.: VC 10 ROLL: RVC 137

LOCATION N 01º 24.230' W 71° 58.703' Miraflores - Guaviare

VERIFICATION DATE: 26/02/97 TIME SINCE SPRAYING 227 days

COMMENTS - Plot sprayed 08/07/96 in the area of Miraflores, size about 15-20 ha.

- USDA/ARS estimate that at least 90% of the plot had been eradicated.
... ,
- Note the invasion of natural vegetation (grasses and herbaceous). Note that
some plants had non-productive leaves and the stems are completely necrotic
(dead)

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PLOT 3

PHOTO No.: VC 34A ROLL: RVC 121

LOCATION N 02º 07 ' 45.8”W 72° 10 01.3” El Retorno

VERIFICATION DATE: May 06, 1996 TIME SINCE SPRAYING ± 232 days

COMMENTS Note the process of succession after the eradication of coca.

Invasion of gramineous species (1).

Invasion of heliophytes (Balsa, Yagrumo) (2).
Succession of shrubs (3).

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PLOT 2

PHOTO No.: VC 30A ROLL: RVC 121

LOCATION N 02º14 ' 06.1”W 72° 03' 40.2” El Retorno

VERIFICATION DATE: May 06, 1996 TIME SINCE SPRAYING ± 284 days

COMMENTS - Note totally eradicated plots (1) now again invaded by native vegetation

- Shrubs and trees are the best evidence that the plot was abandoned

- Distances calculated by GPS Between A- B = 479 m. Between C- D = 333m.

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

PHOTO No.: VA 04 ROLL: RVA 118

LOCATION Tolima-Sector de San Antonio-Chaparral N 03" 57' 22,8" W 75 n 32' 48,8"

VERIFICATION DATE: Feb. 13/96
TIME SINCE SPRAYING ± 360 days

COMMENTS Process of natural restoration of plots sprayed a year ago.

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

PHOTO No.: VC 23 ROLL: RVA 104

LOCATION N 02" 21' 29.2" W 72” 32' 13.0" Sector El Retorno

VERIFICATION DATE: Nov 29 1995 TIME SINCE SPRAYING 12 MONTHS

COMMENTS - The large spreads of coca near El Retorno have disappeared due to the Eradication

Program.

- Plot invaded by natural vegetation… Excellent restoration

- No clinical cases attributable to glyphosate application have been reported

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

PHOTO No.: VA 30 ROLL: RVA 118

N 03" 34' 40.2" W 75” 48' 04.4" Rio Blanco
LOCATION

VERIFICATION DATE: Feb 13/96 12 – 14 MONTHS
TIME SINCE SPRAYING

COMMENTS - Large plot with opium-poppy 1, more tan 6 ha.

- Plot sprayed about a year ago 2. Note the process of natural regeneration.

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

PHOTO No.: VC 17 ROLL: RVC 105

LOCATION N 02" 30' 47.5" W 72” 27' 26.7" San Jose del Guaviare

VERIFICATION DATE: Nov 29 1995 TIME SINCE SPRAYING ± 14 MONTHS

COMMENTS - Note the excellent succession of plants: heliconia, balsa, yagrumo, grass, palms,
etc., in coca crops abandoned after spraying 1.

- The few surviving species of coca are eliminated by the dynamic process of succession.

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

PHOTO No.: VA 25 ROLL: RVA 118

LOCATION N 03" 39' 50.0" W 75” 42' 06.6" Rio Blanco

VERIFICATION DATE: Feb 13/96 TIME SINCE SPRAYING ± 2 Years

COMMENTS - Plots sprayed about 2 years ago. Note the abandoned houses
Note the good degree of natural restoration.

[Page 83]

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

7.1 Herbicides displacement in soils

LETEY and FARMER (1.994) state that displacement of an herbicide in soil may occur as a
result of diffusive and mass flow phenomena

Diffusion is the process by which matter is transported as a result of random molecular
movement caused by the thermal energy of molecules. It causes a uniform distribution inside

the system. It occurs in movement networ k of high to low concentrations. Mass flow occurs
as a result of external forces. Displacement of Glyphosate will occur, then, as a result of water

current or particles in soil, which combine with the pesticide molecules.

[Page 127]

STIKLER, KNAKE, and HINESTRY (1.969), cited by the former authors, found that the
effectiveness of an herbicide depends on the water contents in soil. Some herbicides become

more effective as water contents in soil increases. This effectiveness is attributed to water
contents present in the displacement of the diffusion process.

To date, different models have been developed to describe the mass flow of chemical
products through the water and soil profiles. All of them have to do with water flow and,
especially, its velocity. The most important parameter in the absorption coefficient between

the herbicide and soil. For instance, the herbicide with a high absorption coefficient will be
relatively immobile in soil.

Based upon researches carried out, there is an inverse order be tween displacement and
absorption and an inverse relation between absorption and lixiviation.

Likewise, there more modern evidence of the inverse relation between absorption and
displacement of herbicides through soil due to water. As the content of orga nic matter

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

increases, depth of lixiviation decreases. Similarly, as organic matter content increases,
pesticides absorption coefficient increases. On the other hand, in very “heavy soils”, with

increase of clay content the absorption coefficient increases and pesticides mobility
decreases.

WEED and WEBER (1.994) point out that bio- activity (organic matter), displacement, and
persistence of pesticides in soil depend greatly on the interaction of the pesticide molecules

with the absorption of the complex soi l. Absorption reduces concentration in the soil solution,
thus, part of the pesticide is removed from power center. The effect depends on the nature of
the absorbed molecule, on the absorbing surface, the soil chemistry, and the form of bio-

influence.

On the other hand, RILEY and EAGLE (1.994) mention that inactivation processes,

adsorption, lixiviation, volatilization, up- taking by plants the soil granulometry, and residues of
herbicides are the most important items in displacement of the herbicide in soi l.

• Inactivation. Herbicides may be lost in soil when physically removed as a result of
molecular exchange or degradation (physical mechanism of transport or elimination)

• Adsorption. Herbicides distribute in soil, according to the solid, liquid or gaseous
phases. Although it is very important to acknowledge that there is not a true
thermodynamic balance in soil, it is described by the absorption coefficient because
the concentration of herbicides in soils controls the biological profitability and its
mobility. Organic matter of soils and the pH influence the herbicide adsorption.

[Page 128]

• Degradation. Decomposition is the most effective process to eliminate herbicides in
soil. Photochemical degradation of herbicides may be important on the plants’ surf ace,
particularly when they have been incorporated into the soil. The main degradation
mechanism is chemical and biological. Many of the herbicides containing chemical

groups, which are susceptible to hydrolysis, in aqueous solution, and with similar pH
may be different under aerobic or anaerobic conditions. Although chemical degradation
occurs, the microorganisms are involved in some later stages, which lead the herbicide
to mineralization of carbon dioxide (CO )2

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

• Lixiviation. The concentration of a chemi cal product affects its lixiviation for the
draining through the soil pores. A strong absorption, soil aggregates, with a high
amount of micro pores, tend to significantly reduce the gravitational movement of the

soil profile. In practice, the least mobile residues are found confined in the first
centimeters of the soil profile, some more mobile ones are found up to a meter below
the surface.

• Volatilization. The incorporation of herbicides into soil, the use of granulated
formulations, soil humidity, and light rain, after application, help displacement of
herbicides in soil and reduce volatilization as well as adsorption.

7.2 Reports on research on the effects of Glyphosate herbicide on tropical soils.

Now, other researches found on herbicide displacem ent in soil and that are part of a wide

range of researches reported in the Environmental Management Plan, Chapter III, pages 34
and 35, Chapter Vi, pages 17 – 21, and Chapter VII, pages 36 – 48.

Thus (WILLIS, 1.994), concludes that the toxicity of herbic ides in soil depends on the

proportion of the component in the soil solution, in relation with that absorbed by the soil
colloids, properties vary with water contents and weather factors.

According to the Environmental Management Plan for the Eradication of Illicit Crops, “the
molecular degradation seems to occur in a relatively short period of time in tropical soils.
There is a lot of information on the subject, but to the effect, it is enough to make reference to

one of the most in-depth researches prepared by the researcher C.S. …

[Page 129]

… Helling, engaged in the Research Services of the United States Department of Agriculture”

“Data by C.S. Helling (1.997) from the researches made Environmental Dissipation of

Glyphosate and other herbicides in soils experimentally treated in certain regions of Panama
and Peru, with substantially higher doses than the ones required for weed control, show that

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

no residues of the parent product or its main metabolite, the Aminomethylphosphonic acid
(AMPA) were not detected in soil samples taken 1,5 and 3 months after applying treatments

on coca crops”

According to MONSANTO (1.972b) and cited in the Environmental Management Plan for the

Eradication of Illicit Crops, the Glyphosate degradation rate in soils “seems to be quick”. The
fact is that the Aminomethylphosphonic acid AMPA is more persistent than Glyphosate; in
which amounts of AMPA 111 days after application, rates were 10 to 17% of the amount

initially applied.

With regard to the mean life of parent product i n soil (AMPA), i.e., the time [ sic] required for

half of the product applied to metabolize or disappear may range between 3 and 141 days
(Environmental Management Plan for the Eradication of Illicit Crops.)

CLAES (1.998) mentions that Glyphosate is a pers istent herbicide. Tests carried out by

Monsanto (company that manufactures Glyphosate- based products) showed that up to 140
days were necessary for half the amount of the product applied to decompose or disappear.

However, “there are authors that state that usually the biocide effect is very short in tropical
soils because the molecule is susceptible to degrade rapidly and can break and transform into

components such as CO2, water, certain nitrogen fraction, and some phosphates; all this due
mainly to micr oorganisms action”. (Environmental Management Plan for the Eradication of
Illicit Crops).

The same author mentions that 2the high persistence of the parent molecule only occurs in
ecosystems with temperatures below the freezing point, such as some regions in Canada,

where, besides low temperatures, there is also an almost complete reduction of
microorganisms activities, responsible for decomposition of the parent molecule.

MENDOZA et al (1.999) made in vitro tests to determine the toxic effect of herbicides

Glyphosate and paraquat on the nitrification process on sandy loam soil (pH: 5,8, moisture:
13,05%), in the village of Rio Frio, Magdalena. A reduction in nitrification and an increase in

the delay period were observed as concentrations increased. Howev er, with high doses of

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Supplementary Information to the Environmental Management Planfor the eradication of illicit crops

commercial Glyphosate (100 and 1000 ppm of Round Up) and commercial paraquat (1000
ppp of Gramaxone) there was inhibition of nitrification.

[Page 130]

Both standard and commercial paraquat, at 10 and 100 ppm, caused slight disturba nce on
nitrification, which returned to relative normality after 30 days.

Similarly, a significant difference was observed between commercial Glyphosate (maximum
nitrate concentration) and standard Glyphosate at a concentration of 1000 ppm, which
suggests that adjuvants in the commercial product contribute to increase the toxic effect of

the herbicide.

These data reported based on in vitro tests are of interest to develop pesticides use

techniques that allow for the recovery of microbial populations for s oil fertility.

[Page 131]

198 Annex 32

NOTEN°24171FROM THE NATIONALNARCOTICSDIRECTORATE
(DNE)TO THEM INISTRY FOR TENVIRONMENT,8A UGUST2001

(Archives of the Colombian Foreign Ministry)

199200 Annex 32

REPUBLIC OF COLOMBIA Ministry of Justice and Law
National Narcotics Directorate
Bogota, D.C.

ASE 24171

Mr.
JUAN MAYR MALDONADO
Minister for the Environment
City

Dear Mr. Minister:

In compliance with your Order 516 dated July 2001 issued by that
Ministry, I am submitting the progress report of the liabilities set upon
this Directorate according to Resolution No. 0341, following the order

established in the chart outlined, as a minute, after the fol-up
meeting on the work carried out by the National Narcotics Directorate,
last July 23.

In order to comply with the terms set out in the Resolution, I would
appreciate it if the comments on the report are submitted by August

22.

Sincerely,

[Signed]

GABRIEL MERCHAN BENAVIDES
DIRECTOR

201202 Annex 33

NOTE N° 3228FROM THENATIONALN ARCOTICD IRECTORATE(DNE)
TO THEMINISTRY FOR TEENVIRONMENT ENCLOSING TEENVIRONMENTAL

M ANAGEMENT PLAN(EMP) OF THEPROGRAM FOR THE RADICATION OF
LLICITCROPS BYAERIALSPRAYING WITGLYPHOSATE (PECIG),
6 NVEMBER 2001

(Archives of the Colombian Foreign Ministry)

203204 Annex 33

Ministry of Justice and Law
REPUBLIC OF COLOMBIA
National Narcotics Directorate

Bogotá, 6 Nov. 2001 32280

Mr.

JUAN MAYR MALDONADO
Ministry for the Environment
Bogotá

Dear Mr. Minister:

It is my pleasure to submit the Environmental Management Plan for the Program for the
Eradication of Illicit Crops by Aerial Spraying with Glyphosate, within the submissions time

period set out by Resolution 0341 issued by that Ministry.

Likewise, I am sending the progress status of compliance with Resolution 0341.

I will be awaiting for your Ministry’s comments in order to make the corresponding

adjustments; nevertheless, the Directorate has started the necessary arrangements to
implement it.

Truly yours,

[Signed]
GABRIEL MERCHAN BENAVIDES
Director

Enclosures: Environmental Management Plan for the PECIG
Annexes of the Environmental Management Plan
CD of the Environmental Management Plan for the PECIG
Second progress report of Resolution 0341 with 2 CD’s containing

characterizations made by DIRAN during 2001.

GGE

205Annex 33

ENVIRONMENTAL MANAGEMENT PLAN OF THE

PROGRAM FOR THE ERADICATION OF ILLICIT
CROPS BY AERIAL SPRAYING WITH

GLYPHOSATE (PECIG)

MAIN VOLUME

BOGOTA, NOVEMBER 2000

206 Annex 33

TABLE OF CONTENTS

Introduction

EXECUTIVE SUMMARY

1. GENERAL ASPECTS
1.1. General Objective
1.2. Specific Objectives

1.3. Background
1.4. Location and approaches
1.5. Justification

1.6. Legal Framework
1.7. Organizational structure
2. PROGRAM DESCRIPTION AND ANALYSIS

2.1 Objective
2.2 Scope
2.3 Stages of the program
2.3.1 Detection
2.3.2 Spraying
2.3.3 Verification

2.4 Glyphosate characterization
2.4.1 Physical-chemical composition and characteristics
2.4.2 Commercial formulation types
2.4.3 Surfactants and inert ingredients of basic formula
2.4.4 Classes, materials and capacity of the containers
2.5 Herbicide application method

2.5.1 Herbicide application technique
2.5.2 Exclusion areas of the operation and buffer strips
2.5.3 Herbicide tanking system
2.5.4 Methods and frequency of calibration of the spraying equipment
2.5.5 Limitations caused by environmental conditions
2.6 Technological equipment, material and tools of the program

2.6.1 Equipment
2.6.2 Material and elements used
2.6.3 Technological tools
2.7 Program for the Eradication of Illicit Crops
2.7.1 General aspects
2.7.2 PECIG structure and organization

2.7.3 Inter-institutional coordination activities
2.7.4 Program goals
2.7.5 PECIG’s schedule
2.7.6 PECIG’s costs
3. ENVIRONMENTAL BASELINE
3.1. Identification of the area of influence

3.1.1 Criteria for the selection of the areas for aerial spraying

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3.1.2 Areas of influence for PECIG
3.2 General conditions of the illicit crop areas in Colombia
3.2.1 Physical components

3.2.2 Biotic conditions
3.2.3 Social, economic and cultural components
3.2.4 Social deterioration induced by illicit crops: social frame of PECIG
3.2.5 Environmental deterioration due to illicit crops: environmental
framework of PECIG
3.3 Environmental zoning
3.3.1 General conclusion

3.3.2 Criteria of environmental zoning for spraying
3.3.3 General zoning
4. ENVIRONMENTAL IMPACT-RISK ASSESSMENT
4.1 General aspects
4.1.1 Assessment criteria
4.1.2 Effects of glyphosate

4.2 Impact on physical environment
4.2.1 Impact on soil
4.2.2 Impact on water
4.2.3 Impact on atmospheric resources
4.3 Biotic impact
4.3.1 Impact on vegetation

4.3.2 Impact on fauna and migratory birds
4.4 Socioeconomic impact
4.4.1 Impact on public health
4.4.2 Impact on agricultural production and livestock
4.4.3 Impact on human settlements and migration
4.4.4 Cultural impact

4.4.5 Other impacts
4.5 General summary
5. ENVIRONMENTAL MANAGEMENT PLAN (EMP)
5.1 Objectives
5.2 Structure of the EMP
5.2.1 Operations management

5.2.2 Mitigation measures
5.2.3 Social feasibility of the Program
5.3 Schedule
5.4 Environmental measures’ cost estimates
SPECIFICATION RECORDS ATTACHED
Record No. 1: Spraying operation management program

Record No. 2: Handling of glyphosate and its coadjuvants at operations
bases
Record No. 3: Fuel, vehicles, equipment and transportation of glyphosate
management program
Record No. 4: Solid waste management program
Record No. 5: Management program for wastewater at bases

208 Annex 33

Record No. 6: Inspection, verification and control program on spraying
operations
Record No. 7: Research program for representative and demonstrative plots

Record No. 8: Basic environmental monitoring program
Record No. 9: Social measures and compensation program
Record No. 10: Educational communications program
Record No. 11: Integral safety program at the operations bases
Record No. 12: Environmental management program
Record No. 13: Contingency plan
Glossary

Bibliography
VOLUMES ATTACHED
No. 1: Methodology of the Monitoring of the Integrated Project for Illegal
Crops
No. 2: Illegal crop areas listing by departments, municipalities and nuclei.
August 2000 census

No. 3: Quotation for a compact wastewater treatment plant for bases
No. 4: Opinions of the Ministry of Health on toxicity of glyphosate. POEA
and Cosmoflux

[Page 3]

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INTRODUCTION

This Environmental Management Plan (EMP) has been prepared according to the

regulations provided for in Decree 1753, 1994 and the requirements included in
Resolution 0341, 2001 issued by the Ministry of the Environment to the National
Narcotics Directorate (DNE).

The mentioned Plan includes five chapters and an Executive Summary:

. Chapter 1 comprises an introduction to the EMP with a general description of the
objectives, sites of the illicit crops, justification for the Program for the Eradication
of Illicit Crops by Aerial Spraying with Glyphosate – PECIG -, legal framework,

background and institutional structure.

. Chapter 2 includes a description of the Program, its stages of development, the
characterization of glyphosate as herbicide, application method, equipment and

materials used and the institutional and operational organization to execute same.

. Chapter 3 describes the general basel ine of the Program comprised by the
general physical, biotic and socioeconomic conditions of the coca and poppy areas
and the socioeconomic and environmental impac t created by the illicit crops, the

stage within which PECIG control activities are performed.

. Chapter 4 includes an assessment of the environmental impacts created by the
eradication of illicit crops by aerial spraying with glyphosate, particularly on soil,

water, vegetation, fauna, health of the human population exposed to it and
agriculture and livestock production.

. Finally, as a result of the above, Chapter 5 shows the Environmental

Management Plan as such, encompassing a set of preventive, corrective,
mitigation and compensation measures of the impacts generated.

According to the regulations in force, although an environmental management plan
must be focused on the measures to be appl ied for the control of impacts of a

certain activity or project, it has been deemed convenient to give this EMP a similar
structure as that of a regular Environmental Impact Study, due to the high
sensitivity existing around the subject of aer ial spraying of the illicit crops with

glyphosate.

It must be observed, however, that this is the framework of an Environmental
Management Plan at a national level and coverage, developed to encompass the

eradication of illicit crop activities through aerial spraying with glyphosate in all the

210 Annex 33

areas where they are found, now or in the future. Thus, and due to the illicit nature
of these crops, the detailed environmental characterization of the areas to be

sprayed is considered to be the object of the immediate stage prior to the spraying
operation in order to determine, in real time, the environmental and socioeconomic
conditions to be taken into account during the spraying process.

[Page 4]

EXECUTIVE SUMMARY

The purpose of the Environmental Management Plan (EMP) is to establish the
actions which will be used by the entities responsible for the Program of

Eradication of Illicit Crops through Aerial Spraying with the Glyphosate Herbicide –
PECIG – in order to prevent, mitigate, control, compensate and correct the
eventual negative environmental effects or impacts caused by the program,

including follow-up, assessment, monitoring and contingency plans. The Plan has
been set up according to the provisions of the Ministry of the Environment by
decrees and resolutions issued on the matter, specifically Resolution 0341/2001 in

aspects related to an environmental management plan, and provisions issued by
the National Narcotics Council on the eradication of illicit crops. The purpose of the
application of the EMP is not only to control the environmental impacts of the Aerial

Spraying with Glyphosate Program but to reduce the great impact generated by the
illicit crops to the Colombi an ecosystems, such as deforestation, erosion, water
pollution, migration of population and effects over indigenous people and cultures,

amongst others.

Twenty four provinces in the country are the main coca crop areas, although 74.3%
of those areas belong to the provinces of Putumayo, Caquetá, Guaviare and Meta.
Poppy crops are found mainly in the provinces of Cauca, Nariño, Tolima and Huila

(72.6%). Notwithstanding the mentioned illicit crops distribution, the Program for
Eradication of Illicit Crops by Aerial Spraying with the Glyphosate Herbicide will

take place only in those areas where the crops are considered industrial, such as
was determined by the National Narcotics Council’s Resolution 0005 of August
11/2000.

In general, the areas chosen for coca cultivation are located in hot, humid and very

humid climates, flat to uneven land, soils with low or very low potential for
traditional agricultural activities and high drainage density, with a great number of
rivers and streams with permanent flow due to abundant rainfall.

Therefore, coca crops are located in humid to very humid tropical forests
(equatorial evergreen forests or ombrophilous forests) frequently intervened and, in
some cases, felled almost in their entirety, such as that at Serranía San Lucas in

211Annex 33

southern Bolivar, among others. These forests have a great variety of flora and
fauna and also several endemic factors and endangered species. On the other

hand, poppy crops are situated in potential Andean and high Andean forest areas
of great relevance due to their biodiversity and the interest existing in water
conservation, the sources of which are used for rural and urban waterworks. There

are protected areas to be affected or which are affected by illicit crops mainly in the
areas of PECIG, but not to be sprayed, according to Decree 1843/1991, included
and geo-referenced in the SATLOC system, which alerts the aircrafts when they

are approaching such areas.

In general, from the socioeconomic viewpoint, coca crops are situated in low
populated areas, characterized by extreme pov erty levels and no utilities, with

economy based on extractive activities a nd with no economic infrastructure to
develop traditional economic activities, or with a low coverage level (roads,
electricity, others). On the other hand, poppy crops are carried out in a relatively

higher population density but, in any case, lower in comparison to the middle levels
of the country and with extreme poverty and lack of utilities as well; traditional
farmers, with a low-coverage level in economic infrastructure to carry out traditional

economic activities. Indigenous population is present in almost all the illicit crops
areas, particularly in the Meta-Guaviare-Vaupes, Choco, Caqueta-Putumayo and
Cordoba sites, although the larger indi genous population is found in the areas

influenced by poppy crops (Chaparral-Iquira-Paez-Teruel).

From the environmental point of view, a very important characteristic is that
generally coca crops are not located inside the forests but in open areas with
grasses and traditional crops which is a sign that these are situated more in

consolidated colonized areas or in the process of consolidation.

If the problem of illicit crops is to be analyzed as a whole, in the light of the legal
regulations in force in Colombia which consider them to be a crime, of the

international commitments of the country regarding the production and control of
the narcotic traffic and of the huge environmental and socio-cultural impacts which
the drug traffic development has caused and continues to cause, specifically in the

most fragile ecosystems in Colombia, such as humid forests, tropical rainforests
and the Andean forests, it could be considered that the eradication of illicit crops by
aerial spraying with glyphosate is a measure to mitigate the environmental impact

caused by those crops.

PECIG is a Governmental strategy, supported by national and international policy,
and technical, economical, social, environmental and regional development

reasons, amongst others:

212 Annex 33

• Colombian Government policy, with specific plans and programs designed
and executed by each successive government.

• Coca, poppy and marihuana crops with more than 20 plants are considered
by Colombian law (among others, Law 30/1986) as a crime that has to be
sought after at the sites where they are located.

• They are part of accords and treaties signed by Colombia at a multilateral
level (United Nations) and at a bilateral level.

• During recent years, satellite detection techniques have allowed larger illicit
crop areas to be identified, mainly in southern Colombia where physical and

socio-economic conditions have encourag ed it. To overcome this situation,
the Government has carried out essential actions in operation for the
organization of methodologies to identify and monitor permanently the

dynamics of the crops, develop operations to destroy industrial-type illicit
crops and, as a long-standing strategy, an alternate development in order to

reduce the participation of target population in unlawful activities.
• The entry of illicit crops in several regions of Colombia has wreaked havoc
in the traditional economy and has fostered migratory processes and

increased the intensity of violent actions since it has become a source of
financing for several and numerous groups of illegal armed forces.

• The illegal drug-trafficking industry is at present the largest factor in
environmental degradation in Colombia, not only due to the deforestation of

areas of extensive tropical rainforest and Andean forest of these plantations,
but also due to contamination of the ecosystems as a result of the large
volumes of pesticides and chemical ingredients used on the inadequate

removal of waste, activities which are performed without any control. In view
of the above, the environmental impact caused by the eradication of the

illicit crops using aerial spraying with glyphosate is just a minimal part of the
impact caused by the different activi ties of the drug traffickers, which

conceals the real environmental problem generated by this industry, besides
the social, economic and health impact created by the illicit crops activity.
• According to studies conducted in recent years, it has been established that

to have one hectare of coca, farmers must destroy 4ha of forest and for one
of opium-poppy, 2.5ha of Andean forest . 1

• Burning down forests and woods means the destruction of 380 tons of
biomass per hectare, that is, an accumulated total of 152 million tons of
2
biomass, which turn into ashes, CO² and sediments .
• Destruction of these ecosystems severely harms the ecological
homeostasis, which in the Amazon is determined by the great diversity of

                                                            
1 Parra L.E., 1997, Impacto ambiental en los cultivos ilícitos en Colombia. Rev. Coloquio No. 3, pp 69‐107 
2 Parra L.E., 1997, ibid 

213Annex 33

flora, unique in the Planet – between 96 and 120 tree species per hectare –

an unknown number of minor species, aside from micro-flora and micro-
fauna with an infinite genetic potential .
• Frequently, illicit crops such as poppy and coca are located in ecosystems

of an incalculable environmental value, those being the largest gene-banks
worldwide, with a vital ecological importance due to their capacity to

regulate CO² and keep the emissions to the atmosphere stabilized.
• Available technical reports show that 98.7% of farmers use pesticides and
fungicides for plague and disease control; 92.5% use chemical fertilizers

and 95.5% controls the competition of other plants with herbicides, in
quantities such as to constitute an additional factor of imbalance of the

fragile ecosystems of the Amazon and Orinoco regions, Pacific platform and
high Andean areas (Uribe S., 1999).
• Along with the degradation of the forest ecosystems, there are changes in

the habitat of the indigenous population still living in the forests, thus
creating a loss of cultural diversity, a process which is increased by the
incoming settlers and coca leave pickers in search for quick fortune, which

leads to the loss of cultural identity of the indigenous communities who
come in contact with them.

• Since a large amount of the crops are considered industrial, and due to the
difficulty in accessing the sites by land or water or due to public
disturbances, they cannot be eradicated manually; therefore it is necessary

to eradicate them by aerial spraying with the herbicide.

Regarding this situation, the Program of Eradication of Illicit Crops by Aerial
Spraying with Glyphosate – PECIG – in general causes a low environmental

impact, a situation closely related to the following facts:

• Through the disincentive and targeting of the main factor of this
environmental problem, which constitutes the growth of illicit crops, PECIG

seeks to stop the deforestation process of the Colombian humid rainforest
and high Andean forests.

• During this process, aerial spraying of the illicit crops may cause some
impacts on the neighboring forests to such crops, but those impacts are not
highly important as this EMP confirms. Moreover, in such cases where there

are impacts, they shall be duly compensated by the environmental
authorities.

• International scientific literature and local experience show that the use of
glyphosate in lawful crops quickly degrades in soil and water, is not bio-

                                                            
3 Parra L.E., 1997, ibid 

214 Annex 33

accumulating and the concentrations it may reach in the food chains as a
result of spraying are lower than the limits established by the local and

international authorities to be able to cause any significant harm over the
land and water fauna and on human health. The US EPA (Environmental
Protection Agency of the United States) has accepted, based on available

research, that glyphosate is not a carcinogenic, oncogenic or teratogenic
agent, nor does it cause any delayed neurotoxicity in humans and animals.
• The environmental management to be given to the Program excludes the

areas of the Natural National Parks System, water bodies, human
settlements and economic areas of interest as well as buffer strips of land
regarding the same elements and mulched areas other than illicit crops.

Likewise, it has a series of operating procedures to reduce the impacts
caused by the same aerial spray to a minimum and to the handling of the
herbicide at the base of operations, as well as all other elements or activities

susceptible to create environmental impacts.

The main negative impacts are those caused on the lawful crops, due to the
fact that they were inserted into or associated with illicit crops as a strategy of

the coca-leaf and opium-poppy growers, and over the forests in the same
situation. Nevertheless, the importance of these impacts has been deemed as
low, given the operational technical specif ications and the safety measures of

the anti-narcotic bases. Likewise, it is important to note that there is a possibility
of attacks on the bases and aircraft by the illegal armed groups.

On the other hand, the Program will undoubtedly have positive impacts,

particularly due to disincentive in deforestation in order to establish illegal crops
and pollution generated by all the drug traffic industry responsible for
contamination due to not yet tested pesticides in those areas.

The proposed Environmental Management Plan includes thirteen (13) specific

programs, distributed as follows:

• Prevention programs: Handling of spraying operations; handling of
glyphosate at the operational bases; handling of fuel, vehicles, equipment

and transportation of glyphosate and handling of solid residues.
• Mitigation programs: Handling of residual waters; inspection, verification and
control of spraying operations; research in demonstrative and representative

plots and environmental monitoring.
• Social feasibility programs: Social administration and compensation;
educational communication and integral safety at the operational bases.

• General programs: Environmental administration: Contingency Plans.

215Annex 33

Total annual cost of the environmental activities amounts to COP603.942.000 per
base and COP4.227.594.000 per year for the foreseen 7 main bases, that is

COP67.792 per hectare. This cost represents 5.8% of the spraying cost per
hectare for coca and 6.3% for poppy.

[CHAPTER 1]

1. GENERAL ASPECTS OF THE PROGRAM

1.1 GENERAL OBJECTIVE
The purpose of the Environmental Management Plan is to establish the
actions to be applied by the authorities in charge of carrying out the

Program for the Eradication of Illicit Crops by Aerial Spraying with
Glyphosate – PECIG -, in order to prevent, mitigate, control, compensate
and correct the possible negative environmental effects or impacts

caused by the Program, including follow-up, assessment, monitoring and
contingency plans.
1.2 SPECIFIC OBJECTIVES

• Identification and brief description of the environmental resources and
values which may be affected by the proposed project under the existing

conditions.
• Description of the effects PECIG ma y have over environmental resources
and values.

• Description of the specific manner by which the EMP aims to minimize
adverse effects and maximize the positive effects.

In order to achieve these objectives, the report starts with general knowledge of

the present conditions – physical, biot ic, socioeconomic and cultural – of the
areas in which the Eradication Program is to be applied, as well as the
characteristics of the aerial spraying of herbicide process emphasizing those

susceptible to create environmental impacts.

Based on the knowledge of the environmental conditions and on the
characteristics of the project, there is an assessment phas e to answer these
four basic questions:

• What are the expected changes as a result of PECIG? It is the identification
of impacts or determining the possibility of interaction between the project
and the environmental conditions of the area.

• What would be the scope of changes ? The prediction of the expected
magnitude of impacts, or the quantificati on of same in physical, biological,
economic, social terms or others, according to their nature.

216 Annex 33

• Are the changes important? It is the assessment or the determination of the
real importance of each impact facing the present situation, to the

expectations of the population or to the existing legislation or to other
relevant parameters.

• What is to be done to manage or contro l changes? It is the determination of
the necessary mitigation measures for those impacts which are significant
during the assessment.

This process is repetitive until the meas ures that show that the project is

feasible are found from the environmental point of view. In the chapter
regarding the assessment of impacts, the four previous stages were presented
in a unified and synthetic manner, seeking to emphasize the real significant

impacts of the project, although they were completely considered in the
analysis.

For operational purposes, impact assessment has been organized according to the

affected area, thus, impacts on the physi cal, biotic and socioeconomic-cultural
media.

Each impact has been graded according to the following criteria:

* Character: direct, indirect

* Sense: negative, positive

* Probability of its occurrence: sure, probable, unlikely

* Duration: long or residual term, medium term, short term

* Reversibility

* Real importance: insignificant or worthless (0), very low (1), low (2), medium (3),

high (4), very high (5)

Impacts are summarized and shown in synthesis in the reduced matrix of the
environmental impact of PECIG (see Fig. 4.3 in chapter 4).

[Page 10]

1.3 BACKGROUND

The Program for the Eradication of Illicit Crops by Aerial Spraying with Glyphosate
– PECIG – for many years has been an official Colombian Governmental policy,
has been recorded in the drug plans prepared by the relevant authorities and

217Annex 33

involves the institutions for its implem entation with the least social impact and
without significantly harming the environment.

For approximately three decades, illicit marihuana ( Cannabis sativa), coca
(Erythroxylum coca var. Coca, E. Coca var., Ipadu and E. Novogranatense var.
novogranatense) and poppy (papaver sonmiferum) crops activities have been

established and, thus, processing and traffic of narcotics derived from these plants
have been developed.

Due to this situation, the National Government was committed to eradicate the
illicit crops at the different bio-geographic regions of the country, including

private properties, reservations, natural forests and parks, taking into
consideration social, political, economic, legal, environmental and health
aspects in an attempt to solve the problem once and for all.

Law 30, 1986 determines a procedure for t he destruction of illicit plantations
and specifically assigns to the Consej o Nacional de Estupefacientes – CNE
(National Narcotics Council) the mission of “ arranging for the destruction of the

marihuana and coca crops and other plantations from which substances
producing dependence may be extracted, using the most appropriate methods,
with a prior favorable concept of the entities in charge of looking after the health

of the population and the preservation and balance of the country’s ecosystem”.
To this effect, this Entity issued Resolution 0001/94 through which the
eradication of illicit crops in Colombian territory is authorized and the relevant

procedures are established.

Through Decree-Law No. 423, 1987, Article 2 and Resolution 0001/94, the
action of repression of the criminal conducts related to illicit crops was assigned
to the Anti-Narcotics Police. This action to eradicate is to be implemented

following criteria of responsibility and environmental control, where prevention,
mitigation, correction and compensation of the eventual impacts caused by the

eradication on the natural and bio-physical environment as well as the socio-
economic factors must necessarily be considered.

The Program for the Eradication of I llicit Crops has developed the processes
detailed below to determine the use of Glyphosate during the aerial spraying of

illicit crops.

The Colombian Government has been using the aerial spraying method as a
highly efficient and effective mechanism for the elimination of illicit crops since

1984, without prejudice of the ongoing plans, social agreements for voluntary
eradication with the participation of local communities. Thus, from 1988, the
ruling Government considered convenient to involve the environmental variable

218 Annex 33

in the application of the mentioned method, by petition of the INDERENA
(National Institute for Natural Renewable Resources and the Environment).

Based on this decision, several studies were carried out tending to
environmentally characterize the illicit crop areas and to establish
environmental administration methods.

It is clear from past studies that the decision to recommend Glyphosate was
due to a systematic and scientific procedure which considered the most
advisable environmental and toxicological risk variables, as elements guiding

the criteria for its selection, to date.

In the beginning of 1994 a Scientific and Technical Agreement between the
National Narcotics Directorate (DNE), the United States Department of
Agriculture (USDA-ARS) and the Programming Office of the Narcotics Affairs

Section (NAS) of the Embassy of the United States in Colombia was entered
into with the purpose of carrying out tests for “ Control, Estimate and
Environmental Impact of Illicit Coca Crops”; those tests were performed in San

Jose del Guaviare.

In December 1996, the final considerations of the report on the Legal and
Technical Aspects for Eradication of Illicit Crops were presented to the National

Narcotics Council, by which it is established that according to health and
ecological studies, aerial spraying with Glyphosate carried out subject to
technical parameters was not harmful either to human health nor to the

environment.

Moreover, actions towards developi ng environmental measures have been
taken, among which the following could be mentioned: the incorporation of
environmental prevention programs and campaigns, seminars which have been

held with different regional entities on the effects of the Eradication Program,
the setting up of protocols and operational procedures allowing for prevention

and minimizing possible impacts on areas which are not the objective of the
Program, the determination and geographical references of those sites where
the Program is not in operation such as: National Parks, Alternative

Development Projects, Eradication Agreements, etc. as well as permanent
surveillance on the sprayed areas.

All these decisions, at the time, have been judicially and legally justified by the

[Page 11]

219Annex 33

National Narcotics Council - NNC, based on, among others, Law 30, 1986, Law
99,1993, Decree 2811/74, Decree 1753/94, Decree 1843/91 and Resolutions

0001/94 and 0005/2000 from the NNC.

PECIG has displayed a set of technical actions which have allowed the National
Narcotics Council to take the decision to authorize the activities of eradication

of illicit crops.

Thus, in compliance with the recent environmental regulations it was necessary
to prepare the “Environmental Management Plan to Eradicate Illicit Crops”
according to Law 99, 1993 and its regulatory Decree 1753, 1994 through which

titles VIII and XII of Law 99, 1993 on environmental licenses are partially
regulated, and where Article 38 indicates a “transition regime for projects, works
or activities which, according to regulat ions in force before the issuance of this

Decree, have obtained the environmental permits, licenses and authorizations
required. These activities may continue but the environmental relevant authority
through motivated decision may demand the presentation of environmental

management, recovery or restoration plans”.

Likewise, the Colombian Government signed an Environmental Audit contract
under which work has been proceeding since March 1992, the date on which

the eradication of illicit poppy crops program was established.

Since 1992, the Colombian Government has formulated the National Plans to
Combat Drugs, facing different areas of intervention, the product of analysis of
the structural causes and of associated factors, as well as the identified fields of

action by different planning efforts and gathered experiences. Its approach has
an integral character where processe s and strategies are united towards
minimizing the possibilities of individuals or social groups to be linked to any of

the practices related to the different manifestations of the drug problem, and
repressive measures to combat the i ndustrial-type crops, narcotics processing,

traffic and distribution.

Within the framework of the National Plan to Combat Drugs 1998-2002, the
following strategic objectives were designed:

1. Alternative development, oriented towards reducing the participation of the

affected population by the illicit crops as means of livelihood and towards
the construction of social and economic licit alternatives, generating
favorable conditions for the peace process in Colombia.

2. Reducing supply, directed at fighting illegal planting of seeds causing
addiction, drug production, trafficking and distribution, as well as
infrastructure supporting the illegal drug business.

220 Annex 33

3. Judicial and institutional strengthening, tending to strengthen judicial
and operative instruments of the State’s institutions in order to fight the

narcotic drug organization and the different manifestations of the drug
problem.
4. Reducing demand, with the purpose of controlling the use of illicit drugs,

the growing trend to improperly use legal drugs and offer treatment
alternatives, rehabilitation and social reinsertion to drug addicts.
5. Environmental management, designed to foster ecological conservation

and sustainable integral development in regions of illicit crops and high-
relapse risk.
6. International policy, through which Colombia’s leadership role before the

international community may be strengthened in order to consolidate, at a
global and hemispheric level, the principles of shared responsibility,
integrality and balance, and fostering cooperation on this matter.

Within this context, those actions planned to prevent and control this problem are
the response to an unified internal policy and to international principles framed
within the United Nations Convention Against Illicit Traffic in Narcotic Drugs and

Psychotropic Substances, the Anti-Drug Strategy in the Hemisphere and the
Global Action Plan approved at the United Nations General Assembly, indicating in
one of its sections “the importance to combine repressive measures with

alternative development programs”.

Legal follow-up to the aerial spraying with pesticides, and the activity of cultivating,
processing and distributing drugs produci ng addiction was established as a crime
through Law 30, 1986 or National Narcotics Statute. The National Narcotics

Council, through Resolution 0001, 1994, authorized for control aerial spraying with
Glyphosate as an effective mechanism to er adicate illicit crops, as long as it was
carried out with due technical conditions and under strict control procedures.

According to the strategic purposes indica ted, a series of goals to achieve the
above was foreseen and institutional responsibilities for its execution were
assigned. The National Narcotics Council is the entity responsible for the

development of the plan through the National Narcotics Directorate as the entity
responsible for coordinating the execution of the policies planned by the
Government on this matter. At a regional level, the relevant Sectional Narcotics

Councils must be on the alert at provincial and municipal levels to assume the
policies, strategic purposes and goals planned at a national level.

In the National Plan to Combat Drugs currently in force, it is important to highlight

its objectives since they reflect the policies and experiences gathered in the
country for several years to fight this problem. Its main purpose is to progressively

221Annex 33

and systematically reduce the causes and manifestations of the drug problem
based on the principles of integrality, co-responsibility, consensus, autonomy,

multi-laterality and social content.

The Environmental Administration of PECIG

Within the development of the strategic purpose of the ENVIRONMENTAL
ADMINISTRATION of the National Plan to Combat Drugs, the National Narcotics

Directorate has been coordinating the development of goals, actions and activities
indicated in the Strategic Plan designed for four years and in the Operative Plans
which are established yearly, through Administrative Units with the participation of

several central state entities.

The purpose of the Strategic Plan 1998-2002, established jointly between the
Ministry of the Environment, the Special Administrative Unit of Natural National

Parks, the National Plan for Alternative Development,

The National Police – Anti-Narcotics Direct orate -, the Ministry of Agriculture and
Rural Development and the Agustin Codazzi Geographical Institute, is to “…foster

ecological conservation and sustainable integral development in the regions of illicit
crops and with high incidence risks”. Moreover, this Strategic Objective has three
goals which deal directly with this problem from different points of view. The goals

established for this inter-institutional group are as follows:

“Goal 1. To protect, restore and monitor the fragile areas such as national parks,
strategic ecosystems, natural reserves and critical environmental areas affected by

illicit crops and its joint activities.

Actions:

• To strengthen surveillance, monitoring and follow-up systems to protected
and environmentally important areas.

• To foster the elimination of illicit crops at the National System of Natural
Parks through manual eradication actions, preferably agreed on.
• To promote programs and projects for the restoration of Natural National

Parks areas, buffer and environmentally important areas affected by illicit
crops.
• To increase the capacity of local intervention in territorial ordinance to

incorporate alternative development and management of environmentally
important areas in municipalities with problems of illicit crops.

222 Annex 33

• To incorporate within the environmental and rural education the component
of the environmental, social and economic impact generated by the illicit

crops.

Goal 2. To carry out those actions to reduc e the impacts in the environment
derived from the application of the program of eradication of illicit crops with

glyphosate.

Goal 3. Handling and appropriate disposal of narcotics and chemical substances
seized.

Actions:

• To develop a research project to handle and dispose of residues of seized
chemical substances towards the formulation of a protocol to manage this
problem.

• To train the workers of State entities in handling and final disposal of
chemical substances, taking into account the safety of the involved agent as
well as the protection of the environment.

• To adapt facilities for the warehousing and technical destruction of chemical
substances and narcotics seized with the purpose of minimizing the danger
that this substances may represent for the community and the environment.

During 1999 several activities were established in the Operating Plan of the
Environmental Administration Unit tending to comply with the above actions. A
coordinating process began between the National Park Unit, the DNE, the

Eradication of Illicit Crops Directorate of the Narcotics Police (DIRAN) and the
Environmental Audit under contract through DNE with the purpose of
exchanging information related to the intervention in national parks. Thus,

monitoring in these regions shall be easier, not only regarding the
implementation of illicit crops, but on the effects derived from them as well,
such as displacement of population towards those areas, among others”.

On the other hand, the action of eradication of illicit crops with aerial spraying of

Glyphosate is considered an activity in a transition regime, according to Article
38 of Decree 1753, 1994, and that is the reason why the Ministry of the
Environment demanded from the National Narcotics Directorate – DNE – the

presentation of an environmental management plan for such activity.

[Page 14]

Given that carrying out of the preventive measures imposed by the ministerial

resolution must have an appropriate design and that the continuation of the

223Annex 33

Program for the Eradication of Illicit Crops by Aerial Spraying with Glyphosate

Herbicide – because it is a decision of the National Government – must have a
tool to allow it to prevent, correct, mitigate and compensate the impacts caused
by such an activity, the National Narcotics Directorate – DNE – has decided to

prepare this ENVIRONMENTAL MANAGEMENT PLAN, collecting the
preventive measures imposed by the Mi nistry and designing new measures

tending to guarantee an integral environmental administration to the Program,
with the purpose that all the participating institutions have a common
environmental action framework.

On presenting this management plan to the Ministry of the Environment, the
DNE considers that it has all necessary elements for its design and
implementation according to the provisions of Law 99, 1993 and its Regulatory

Decree 1753, 1994, and that the demands contained in Resolution 0341/2001
regarding impact assessment, characterization of the areas to be sprayed and
research on the representative plots are more appropriate for the follow-up and

monitoring stage than for the design of the EMP as such.

As a consequence, this EPM does not have aspects of Resolution 0341/2001
which are part of the purpose of other different programs or instances or

stages, such as cartography and environmental characterization of the areas of
the eradication program in the 1:25.000 scale (article 5, subparagraphs a and

b), of the impact assessment based on a long period of observation (art. 2),
which should be part of the normal environmental follow-up and monitoring
stages of the Program, or that requires the prior existence of an environmental

management plan under which to act, as would be the case of international
environmental audit, among others (articles 3,8,9,10,11 and 12).

1.4 LOCATION AND APPROACHES

According to recent statistics, main coca and poppy crop areas are those

indicated in Chart 1.1 and Fig. 1.1. Ma in areas of coca crops are found in 24
provinces of the country, although 74.3% of the cultivated area is found in

Putumayo, Caqueta, Guaviare and Meta. Poppy crop are mainly in Cauca,
Nariño, Tolima and Huila (782.6%) . Notwithstanding the previous distribution
of illicit crops, the Program of Eradication by Aerial Spraying with Glyphosate

shall only be carried out in those areas where crops are considered industrial,
such as those determined in the National Narcotics Council’s Resolution 0005
of August 11, 2000.

                                                            
 Census August 2000. SIMCI Project. 

224 Annex 33

In general terms, and with very few exceptions, the crop areas are far away
from communicating roads and their access is mainly done via rivers (such as

Putumayo, Caqueta, Guaviare) or by air.

[Page 15]

CHART 1.1

LOCALIZATION OF ILLICIT CROP AREAS OBJECT OF THE PROGRAM

PROVINCE CULTIVATED COCA CULTIVATED POPPY

AREA FOR THE YEAR AREA FOR THE YEAR
2000 (Ha)1 2000 (Ha)2
Antioquia 2.547
Arauca 978
Bolivar 5.960

Boyaca 322
Caqueta 26.603
Cauca 4.576 2000
Cesar 779 700
Cundinamarca 66

Cordoba 117
Guainia 853
Guajira 321 200
Guaviare 17.619
Huila 1.000

Magdalena 200
Meta 11.123
Nariño 9.343 1.500
Norte de Santander 6.280
Putumayo 66.022

Santander 2.826
Tolima 800
Valle del Cauca 76
Vaupes 1.493

Vichada 4.935
Choco 250
TOTAL 163.289 6.200
Sources: 1 Census August 2000 by satellite images. SIMCI Project. 2 Anti-
Narcotics Police – verification through aerial reconnaissance.

1.3JUSTIFICATION OF THE PROGRAM

The Program for the Eradication of Illicit Crops by Aerial Spraying with
Glyphosate Herbicide – PECIG is justified due to the following reasons:

225Annex 33

National and International

• The eradication of illicit crops is a Co lombian Government policy, which has

been realized with specific plans and programs designed and carried out by
the ongoing governments. Since it is a State policy, the decision to aerially
spray comes from the highest political authority established to that effect,

such as is the National Narcotics Council.

[Page 16]

• The Colombian laws (Law 30, 1986, among others) consider coca, poppy
and marihuana crops as a crime should they surpass the amount of 20

plants, and must be persecuted in the sites where they are found. The
above mentioned independently from transportation, processing and
distribution.

• The eradication of illicit crops is part of covenants and treaties signed by
Colombia at a multilateral level (United Nations) and at a bilateral level,
particularly those commitments acquired in the United Nations Convention

Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances signed
in Vienna in 1988, the Anti-Drug Strategy in the Hemisphere and the Global
Action Plan approved during a special meeting of the United Nations

General Assembly in June 1998.

Regional and Economic

• The Colombian Government is aware of the growing trend the coca

plantations have had during the past years, mainly in the southern part of
the country where physical and soci oeconomic conditions have favored its
introduction. Facing this situation, integral actions have been introduced,

articulating the development of methodologies to permanently indentify and
monitor the dynamics of the illicit crops in the national territory; the
development of destruction operations of commercial illicit crops under

technical parameters minimizing the environmental impact and, as a long-
lasting strategy, alternative development leading towards the reduction of
participants of the target population in unlawful activities through regional

and local construction of social and economic and lawful and sustainable
processes.
• The aerial spraying actions with glyphosate are duly carried out under technical

conditions and strict control procedures because of the considerable increase
of illicit plantations, its location in fficult-to-access geographical areas for
governmental control and the presence of unlawful organizations in the areas.

226 Annex 33

From 37.500 hectares detected in 1991 by intelligence and reconnaissance, in
the year 2000 (by satellite images) 163.289 hectares were discovered, mainly

in the provinces of Putumayo (40.4%), Guaviare (11%), Caqueta (16%) and
Meta (7%). It is to be noted that for the year 2000, 37 satellite images were
used and 45% of the national territory was interpreted, with 80% reliability.

• During recent years, poppy crops have been stable with an average of 6.600
cultivated hectares. Concentration of crops was located in the provinces of
Huila, Cauca, Nariño, Tolima and Serrania del Perija (Cesar-La Guajira).

• The introduction of these illicit crops in several of the regions of Colombia has
disrupted its traditional economy and has created migratory processes and

increased the intensity of violent phenomena since it has been a source of
financing for several and numerous illegal armed groups.
• It is usual that there is a price increase in the essential consumption products of

a family and the generation of luxury prod ucts as staples (satellite dishes, cars
and others)…
[Page 17]

…in those regions where illicit crops are found.

Environmental

• Perhaps, currently, the illicit drugs industry is the greatest factor of

environmental degradation in Colombia, not only through deforestation of vast
areas of tropical rainforests and Andean forests used for cultivation, but by
contamination of ecosyste ms caused by the large amounts of pesticides and

chemical ingredients used and by inadequate waste removal; both activities
which are carried out without any control.
• The environmental impact caused by the eradication of illicit crops through

aerial spraying with glyphosate is just a minimal part of the impact caused by
the different illegal drug traffic activiti es, which conceals the real environmental
problem caused by this mentioned industry.

• It has been established that in order to prepare one hectare of coca-leaf,
growers must destroy four (4) hectares of forest, and for one of opium poppy,

two and a half (2.5) hectares of Andean forest, according to the study of
Environmental Impact of Illicit Crops (Parra L.E., 1997).
• In accordance with the same document, burning of forests and woods means

the destruction of 380 tons of biomass per hectare, which implies an
accumulated total of 152 million tons of biomass which turn into ashes, CO² and
sediments.

• The destruction of these ecosystems severely alters the ecological homeostasis
which, in case of the Amazon region, is determined by the great flora diversity –

227Annex 33

unique in the planet – between 96 and 120 tree species per hectare – an
unknown number of minor species, besides micro-flora and micro-fauna with an

inestimable genetic potential (Parra L.E., ibid).
• Frequently, poppy as well as coca illic it crops are situated in incalculable
environmental value ecosystems, char acterized by being the greatest

genebanks in the planet, due to the presence of biotic communities (fauna and
flora) that in many cases are unique and exclusive of these regions. Thus the
Amazon plain, for example, chosen for coca cultivation, has a vital ecological

importance due to its capacity to regulate CO² and keep the balance of
emissions to the atmosphere. Moreover, the Amazon-Orinoco regions
represents for humanity, and particularly for Colombia, an environmental bank,

characterized by its large biodiversity. Equal situation exists with the Andean
forests which are affected by the cultivation of poppy crops, which, according to
the Institute of Hydrology, Meteorology and Environmental Studies - IDEAM

(Instituo de Hidrología, Meteorología y Estudios Ambientales), occupy
9,134,270 hectares corresponding to 8% of the national territory.

• Two of the most important hotspots ( Priority Terrestrial Eco-regions) of the
planet are found in Colombia, that is the Tropical Andes and the Bio-geographic
Choco, the first of which shows at pres ent a high level of illicit crops and the

second is in the initial affectation process.
• It is not an exaggeration to say that an average of one in ten plant or animal
species in the world are found within Colombia’s borders, in a territory not

surpassing 0.77% of the landmasses in the world (McNeely, et al, 1990),
according to several biodiversity reports.
• In a report prepared for the DNE (Uribe, 2000) it was confirmed that 98.7% of

cultivators use insecticides and fungicides for plague and disease control,
92.5% uses chemical fertilizers and 95.5 controls other plants with herbicides.
On the other hand, research from Instituto SINCHI (1) (Amazon Institute for

Scientific Research) shows that producers of staple food crops, are meticulous
in carrying out cultural labors in their illicit plantations, as well as weeding and
chemically controlling insects and plagues.

• Taking into account that in the implementation of a coca cultivation producers
generally use 6 Paraquat gallons (Gramoxone) for the first crop and a gallon in

the following two crops; 2 liters of Dinitroanilines (Waxal) in each crop, 240
cubic centimeters of Carbamates (Furadan ) in each of the three crops of the
first year, 12 Kg of Urea and 12 Kg of triple 15 (chemical fertilizer), we could

infer that in the census taken of coca crops between 1999 and 2000 the
following agrochemical quantities were used (Bernal H., 2001):

228 Annex 33

ESTIMATES OF USE OF AGROCHEMICAL SUBSTANCES BETWEEN 1999
AND 2000

AGROCHEMICAL 1999 2000 TOTAL
Paraquat* (gal) 640.476 653.156 1.293.632
Dinitr*l0i.nes 1.306.312 2.587.264
Carbamates *lt 153.714 156.757 310.471

KgUrea 1.280.952 1.306.312 1.587.264
Triple 15 Kg 2.561.904 2.612.624 5.174.528
Source: Estimates: Hernando Bernal C. Strategic and Research Sub-
directorate office – DNE

The above reasons plainly justify the efforts of the Colombian Government to

combat illicit crops by any legal means within reach.

Institutional

(1)Oscar H. Arcvila, Adriana Rodriguez, 1997. Estudio de caso de la
propducción de coca en el departamento del Guaviare (case study of
coca production in Guaviare). Instituto Amazonico de Investifaciones

Cientificas SINCHI.
* According to URIBE, 1999, SINCHI 1997 and the States security
bodies, those most used, in their order are are Paraquat, Wax Up and

Furadan.

* Because the eradication program is a commitment of the Colombian
Government, the environmental management plan demands an inter-institutional
coordination at a national, regional and local level, as well as from the organized

communities around the objectives of prev ention, mitigation and compensation of
the environmental impacts generated by aerial spraying with glyphosate.

Cultural

• In parallel to the degradation of wooden ecosystems, there is a change of
habitat for the indigenous communities still living in the forests, thus
generating the loss of cultural diversity. This process is increased with the

arrival of settlers and coca leave pickers, quick fortune-seekers, which leads
to a loss of cultural identity of the indigenous communities entering in
contact with them.

• It is to be expected that, as in the above case, the eradication of illegal crops
may stop the cultural diversity loss and forced adaptation to other cultures
by the indigenous communities.

229Annex 33

Technical

• A great amount of the crops, due to their industrial size and by the difficulties

for land and fluvial access or because of public order problems, they cannot
be eradicated by hand, so it is necessary to eradicate by aerial spraying with
the herbicide.

The opposition of some sectors of society

Some NGOs and sectors of society have expressed their opposition to aerial
spraying with glyphosate because they are not aware of the implemented
technique during the spraying operations, asserting that they are carried out

indiscriminately and ignoring technical parameters of aerial spraying. In this same
manner, it is stated that glyphosate spraying is a very important factor in the
destruction of the Amazon and Andean forests and the native fauna, as well as

food crops of the farmers and that the health of the population of the sprayed areas
would be seriously affected.

In fact, existing evidence does not allow for proving the veracity of those

asseverations or hypotheses; therefore, it is necessary that the information
allowing for a rational idea on the real scope of such impacts be supplied through
environmental verification, follow-up and monitoring foreseen in this Environmental

Management Plan.

1.5 LEGAL FRAMEWORK

This plan is framed within the land use regulations regarding environmental,
occupational health and professional risks matt ers, on narcotics control and use of

herbicides, such as they appear in Chart No. 1.2 Likewise, international
conventions signed by Colombia in refer ence to narcotics production and traffic
have been taken into account.

230 Annex 33

CHART No. 1.2

LEGAL FRAMEWORK

REGULATION S U B J E C T

ENVIROMENTAL REGULATIONS
Resolution0341,2001 From the Ministry of the Environment,
through which the EMP is not
approved for the Program of

Eradication of Illicit Crops and imposes
preventive measures
Decree321,1999 From the Ministry of the Environment
on the National Contingency Plan
Law 430, 1998 Harmful residues
Resolution415,1998 Through which management of used

oils is established
Decree1521,1998 From the Ministry of the Environment
on transportation of liquid fuels
Resolution0372,1998 From the Ministry of the Environment,
ruling on retributive rates tariffs

Law373,1997 Through which the program for the
efficient use of water and saving it
Decree 901, 1997 Through which the retributive rates are
regulated due to the direct or indirect
water use as receptor of point
discharges

Decree 1791, 1996 Ministry of the Environment on forestry
exploitation
Decree2107,1995 From the Ministry of the Environment,
partially amending Decree 948/95 and
contains the protection and control of
air quality regulation

Decree948,1995 From the Ministry of the Environment
through which the prevention and
control of atmospheric pollution is
regulated
Decree1753,1994 From the Ministry of the Environment

on the regulations on environmental
licenses
Resolution000189,1994 From the Ministry of the Environment
to prevent harmful residues from
entering the country
Law1421,994 Through which the public utilities

231Annex 33

regime and other provisions are
established
Law134,1994 Through which regulations on citizen

participation mechanisms are
established
Law99,1993 Through which the Ministry of the
Environment is created, the public
sector in charge of Administration and
Conservation of the Environment and

the Renewable Natural Resources is
rearranged, the National
Environmental System SINA is
organized and other provisions are
dictated

Law 67, 1993 Through which the United Nations
Convention against Illicit Traffic in
Narcotic Drugs and Psychotropic
Substances is approved
Politicl onstitutio,991 Setting of general regulations on
environmental rights and obligations

Decree 0919, 1989 Through which the National System for
Prevention and Relief of Disasters is
organized and other provisions are
dictated
Decree1594,1984 Regulation for the use of water and
liquid residues

Decree2206,1983 Chapter XVI on surveillance, control
and sanctions of Decree 02, 1982 on
atmospheric emissions is substituted
Decree 2105, 1983 Water supply is regulated
Decree2104,1983 Regulatory of Law 09, 1979 on solid

residues
Decree 02, 1982 Regulatory of Law 09, 1979 on air
Law 09, 1979 Health regulations are dictated
(National Health Code)
Decree1715,1978 Partially regulated Decree 2811, 1974
and Law 154, 1976 regarding

landscape protection
Decree 1608, 1978 Regulatory of Decree 2811/734 on wild
fauna
Decree 1541, 1978 Regulatory or Decree Law 2811/74 on
non-maritime waters

Decree 622, 1977 Through which Chapter V, Title II, Part
XIII of Book II of Legislative Decree
2811/74 on “Natural National Parks,
Law 23/73 and Law 2/1959 is partially

232 Annex 33

regulated
Law 154, 1976 On landscape preservation

Decree877,1976 Determines protected forestry reserve
areas
Decree2811,1974 Through which the Natural Resources
and Environmental Protection Code is
dictated
Law23,1973 Through which extraordinary faculties

are granted to the President of the
Republic in order to issue the Natural
Resources and Environmental
Protection Code and other provisions
are dictated
Law2,1959 Through which some forestry reserve

zones are determined
HEALTH REGULATIONS
Resolution0026,1996 From the Ministry of Health through
which an operating Sanitary License is
issued to eradicate illicit crops

Decree 1771/94 From the Ministry of Labor and Social
Security, through which Decree
1295/94 is partially regulated
Decree 1295/94 From the Ministry of Labor and Social
Security through which organization
and administration of the General

Professional Risks is established
Decree 1843/1991 Through which Law 09/79 regarding
handling and use of pesticides is
regulated
Resolution 1792/1990 From the Ministry of Labor and Social
Security through which permissible

limit values are established for
occupational exposure to noise
Resolution 2013, 1986 From the Ministry of Labor and Social
Security, regulates the organization
and operation of the Medicine, Health
and Industrial Safety committees at the

working place
Decree 1594, 1984 Through which Title I of Law 09/79 is
partially regulated, as well as Chapter
II of Title VI – Part III – Book II and
Title III – Part III – Book I of Decree

2811/74 regarding use of water and
liquid residues
Resolution 8321; 1983 Through which regulations to comply
with limits of sound and assurance of

233Annex 33

noise control are dictated
Decree 02, 1982 Through which Title I of Law 09/79 and
Decree 2811/74 regarding

atmospheric emissions (technical part)
are regulated
Resolution 2400, 1979 From the Ministry of Labor and Social
Security on provisions regarding
housing, hygiene and safety in the
workplace

ON THE ERADICATION OF ILICIT CROPS (PECI)
Resolution 0017, 2001 From the National Narcotics Council to
attend to the complaints due to
damages presumably caused by
glyphosate spraying

Resolution 005, 2000 From the National Narcotics Council,
amending Resolution No. 001, 1994
on the authorization for the destruction
of illicit crops in the country
Resolution 0017, 2001 From the National Narcotics Council to
attend to complaints due to damages

presumably caused by glyphosate
spraying
Resolution 001, February 1994 The National narcotics Council
extends and specifies the
authorizations granted to the Anti-
Narcotics Division of the National

Police for the eradication and
destruction of illicit crops in the country
through the relevant means
established to that effect
MINISTRY OF ECONOMIC DEVELOPMENT

Resolution10962,000 Through which the regulation for
drinking water and basic sanitation
RAS is adopted
Resolution 822, 1998 Through which the regulations for
drinking water and basic sanitation is
dictated

Decree605,1996 Through which Law 142, 1994 is
regulated regarding rendering of public
utilities for waste disposal
AGRONOMICAL REGULATIONS
Resolution1098,1996 From ICA (Colombian Agriculture and

Livestock Institute), through which
guides on the application of pesticides
are established
Resolution 3079, 1995 From ICA, through which regulations

234 Annex 33

on the industry, commerce and the
application of bio-ingredients and
similar products, mulch and fertilizers,

soil conditioners and similar products,
chemical pesticides, physiological
regulators, agricultural coadjuvants
and similar products
INTERNATIONAL REGULATIONS
ViennaConvention 1988 United Nations Convention against

Illicit Traffic in Narcotic Drugs and
Psychotropic Substances
United Nations General Assembly Anti-Drug Strategy in the Hemisphere
and the Global Action Plan

1.6 ORGANIZATIONAL STRUCTURE

The following organizational structure is in charge of executing the Program for
Eradication of Illicit Crops By Aerial Spraying with the Pesticide Glyphosate –

PECIG:

The National Narcotics Council is in c harge of the political guidance of the
program

• The National Narcotics Directorate – DNE - is in charge of the national

coordination of the program
• The Anti-Narcotics Directorate of the National Police (DIRAN) is in charge of

the operational execution. The eradication actions are carried out from nine
Operational Bases distributed in the main illicit crops areas. These actions
are developed based in operational plans established by DIRAN.

• For follow-up and control, DNE has an Environmental Audit
• For advisory matters, the Program has the support of the Inter-institutional
Technical Committee made up by several State entities.


[CHAPTER 2]

2. PROGRAM DESCRIPTION AND ANALYSIS

According to the legislation in force, the National Narcotics Council authorizes the

National Police – Anti-Narcotics Division to develop the Program of Eradication of
Illicit Crops, an activity which is entrenched in the drug policy of each Government.

2.1 OBJECTIVE

235Annex 33

To develop the Program for the eradication of Illicit Crops taking into account
aspects of social, political, economic, legal, environmental and health matters, with

the purpose of carrying it out in a controlled manner from the operational and
environmental point of view.

2.2 SCOPE

The Eradication Program is carried out in regions where the presence of illicit crops

is identified taking into account their differ ential character, that is, for extensive or
industrial crops. The Program for the Eradication of Illicit Crops does not operate in
environmentally sensitive areas, in populated areas, in parks and natural reserves,

in waterworks and water bodies.

2.3 STAGES OF THE PROGRAM FOR THE ERADICATION OF ILLICIT
CROPS

Spraying of illicit crops with Glyphosate is planned and carried out through three

very distinct phases:

• Detection
• Spraying

• Verification

2.3.1 Detection process

Its purpose is to identify, characterize and space out the illicit crops affected areas
and determine the exclusion zones of the program.

Interpretation of satellite images SPOT/LANDSAT/IKONOS type, processed by the

Integrated Project for Monitoring Illicit Crops –SIMCI - with alert mechanisms for
the exclusion zones. As a complement, the following software for satellite
recording and interpretation analysis is used: ILWIS, ERDAS, PCE, ILLISYS.

• When the existence of illicit crops has been detected, verification flights are

scheduled for each of the areas in which the nuclei to be visited are located,
or to quantify in cartography from the Agustin Codazzi Geographic Institute
–IGAC –at a 5:500.000 to 1:400.000, or in processed satellite images by the

Integrated Project for Monitoring Illicit Crops in a scale of 1:50.000 or
1:30.000.

• From cartography and satellite images, the observers perform the following
activities:

º Selection of a representative area from the nuclei

236 Annex 33

º Verification of the location of the plots: coordinates, site, township and
municipality and identification of natural boundaries.

º Estimates of surface of illicit crops plots.
º Approximate density of the crops
º Type of local cover

º Verification of the high risk zones and exclusion zones, such as human
settlements, water bodies, waterworks, indigenous reservations, natural
parks and productive projects, among others.

• Aerial photographs and filming of the areas, which are analyzed by the Anti-
Narcotics Police before the operations.

• Reconnaissance of industrial and farming nuclei. Methodology for the
reconnaissance of each of the nuclei (groups of plots with areas of more
than 2 hectares) is carried out by using radials with a distance between

them of two (2) nautical miles (when there is coverage by satellite images),
and three (3) nautical miles (when there is no coverage of satellite images,
but of cartography). 95% is the coverage of each coca zone or region.

EXAMPLE OF A SATELLITE IMAGE PRESENTING DENSITY OF ILLICIT
CROPS (picture)

(inside) SIG CONSULTATION – SCOPE IN HIGH DENSITY AREAS IN COCA
CULTIVATION – PUTUMAYO

Coca crops less than 3 Has. – Coca crops between 3 and 10 Has. – Coca crops
between 10 and 30 Has. – Coca Crops between 30 and 50 Has. - Coca crops
between 50 and 100 Has. – Crops larger than 100 Has.

2.3.1.1 Characterization of the areas to be sprayed

* In complement, the location of illicit crops and exclusion zones developed in the
previous point, the National Police – Anti-Narcotics Directorate – collects all
relevant information to carry out research of the areas to be sprayed. According to

the provisions of Resolution 0005, 2000, information and cartography are
requested from the following institutions:

º Ministry of the Interior (indigenous reserves)

º Offices of Agriculture Secretariats

º National Plan for Alternative Development

º Social Solidarity Network

º Offices of Health Secretariats

237Annex 33

º Governors

º Mayors

º Regional Autonomous Corporations

º ICA Agencies

º Offices of the Secretaries to Governors

º Provincial Directorates of Health and Secretariats

º Universities

º Institute of Hydrology, Meteorology and Environmental Studies – IDEAM

º Instituto Geográfico Agustin Codazzi

º National Statistics Administrative Department

• Available information is collected, analyzed and assessed by DIRAN, jointly
with DNE. Subsequently the exclusio n zones where PECIG is not applied

are geo-referenced.
• DNE and DIRAN with the available information, determine the potential risks
relating to health, the environment and agricultural and livestock activities in

the areas to be sprayed.
• Characterizations of the areas to be sprayed are presented by the DNE to
the Technical Inter-institutional Committee for its recommendations.

2.3.1.2 Appraisal of collected information

Once the previous stages have been completed, DNE and DIRAN analyze
the information evaluating the following parameters:

º Incidence of illicit crops in the region (c omparative analysis of data of illicit crops

established at present with those of previous satellite images)

º Ecosystems that are affected with the establishment of illicit crops

º Analysis of on the socio-economic and specialized information and determination
of populated areas

ºAnalysis of the bodies of waterclose to the nuclei

º Analysis of the areas of National Natural Parks

º Determination of actions by illegal armed groups

238 Annex 33

º Intelligence information

2.3.1.3 Determining and spacing out the buffer strips

Buffer strips are established with the purpose of providing protection to each of the

environmental elements to be potentially affected by the spraying actions.

For the operation of the Program the provisions of Article 87 of Decree 1843, 1991
is taken into account in regards to “the application of the pesticide in rural areas

may not be carried out in less than 10 meters in land and 100 meters from air for
areas with water bodies, roads or human and animal population or any other
requiring special protection”. In addition, buffer strips were established for other

environmentally sensitive areas, which are presented in Chart No. 2.6.

With the purpose of determining with precision the buffer strips, reports are to be
prepared to allow for assessment of those already established taking into account
the operation of flights in conditions that are not normal such as those in areas of

armed conflict. Additionally, the Verification, Inspection and Control Process shall
be the mechanism which allows for follow-up on the functionality of the established
strips.

2.3.2 Spraying process
2.3.2.1 Planning operation (by each Operational Base of DIRAN)
2.3.2.1.1 Gathering of operational information

• The vertical superposition of the gathered information in the previous phase,
allows for determining by cartography the areas of operation which are
situated through exact geographical coordinates.

• The armed conflict situation in the area subject to be sprayed: identification
of subversive groups operating in each region, number of gang, number of
men, areas of operation and influence, intelligence information.

• Quantification of raw material to be used according to the dosage of
application of the pesticide and the area to be eradicated.

2.3.2.1.2 Planning and control

Meetings to plan the operation

The Commander of the aerial spraying base holds a daily meeting with the
commander of the company, pilots of fixed and rotating wings, technical

personnel and artillerymen to comprehensively analyze the spraying procedure.

EXAMPLE OF A SATELLITE IMAGE WHERE WATER BODIES ARE SHOWN

(Inside) “Details of coca plots at different distances from water bodies-

239Annex 33

CA: Water bodies – ZU: Urban zones – Crops located less than 100 M from
flowing water – Crops located between 100 and 1000 M from flowing water –

Crops located at more than 1000 M from flowing water”

This process evaluates a set of alternatives to develop the operation and
establishes the necessary parameters for co mpliance of the mission, by reviewing

and analyzing the following aspects:

• Information obtained in the detection stage, starting of guiding operational
analysis as is the geographical localiz ation and physiographic setting of the
illicit crops nuclei, meteorological fact ors, areas of illicit crops and those of

exclusion in order to start the schedules of the number of mission.
• Determination of the mode of operation. Each one of the analyzed

parameters shall determine how to carry out spraying using methods
developed according to adverse safety conditions with which the program
operates and the types of crops. The methods may be briefly described as

follows:

(Picture at left) Parallel or by lines method This method allows for spraying an
illicit crop lot simultaneously by a fleet of aircraft flying in formation. It is used in
plots considered industrial or commercial.

Traditional, or “racecourse” . This method consists of spraying over the illicit
crop using one aircraft which flies over the lot be sequenced, using parallel
flight lines. Use of this method is mainly carried out in plots with small and

scattered areas between 2 and 3 hectares.

2.3.2.1.3 Coordination of Intelligence Operations

Intelligence operations are coordinated with the armed forces (Army, Air Force,
Navy) and other safety entities with the purpose of learning about recent

movement of subversive groups, number of men and weapons at the
programmed area of operations. Likewise , land support is requested in case it
is needed.

Example of integration of photographic files and satellite images

(Inside) VERIFICATION OF COVERAGE – PHOTOGRAPHIC AND
SATELLITE IMAGES FILES – 4 PICTURES

2.3.2.1.4 Definition of the organization of the operation

The organizational moment, human conditions of those who are to participate in

the operation, number of officers, deputy officers, agents, executive level and

240 Annex 33

civil personnel is evaluated at this point. Duties and responsibilities are
assigned as well as number of aircraft, commander of the mission, observers,

operational area, time of flight, know n threats, friendly forces, height of
pesticide release, autonomy in the aircraft flights, leaders and changes in
leader, hostile fire procedures, SAR (Search and Rescue Procedure), survival

equipment, etc.

For each operational area previously indicated, a provisional procedure for
search and rescue (SAR) is prepared, with aspects such as possible

unexpected actions, wounded and aircraft failures. Likewise, in this same
phase, the final operational analysis is carried out, with the distance from the
fumigation base to the nuclei to be eradicated, alternate chemical material and

fuel supply sites for autonomy reasons in the flight of the aircrafts.

Working and flight plans are prepared with the indicated coordinates and the
personnel is advised on the targets (nuclei) to be sprayed. To develop each
operation, two alternatives or flight plans are proposed.

• Programming of logistic resources supporting each mission

In this phase there is preparation of human, technological and of required
material resources for the performance of each operation.

• Human resources

In this phase, the number of pilots to be used for the operation and the number
of existing pilots in the facilities to be employed in the mission and the military
personnel assigned.

In this phase moreover, an activity takes place for the information of pilots and

others taking part of the mission where data obtained in the previous detection
phase is given. In addition, a review of the safety regulation protocols and
checking lists to be developed in each operation takes place as well.

• Materials and equipment to be used

During this phase the equipment to be used in each mission is programmed.

º 1:5000.000; 1:50.000 and 1:30.000 scale planimetric maps

º SATLOC software for precision on discharge

º GPS

241Annex 33

º Filming equipment

º Photographic cameras

º Operational protocols forms

º One (1) Caravan aircraft for pers onnel or ambulance and reconnaissance
services transportation

º One (1) S.A.R. helicopter on stand-by

º One (1) helicopter to support on stand-by

º Anti-narcotic bases for logistic support

2.3.2.1.5 Coordination with state entities to accompany the spraying
operation

During this phase coordination in carried out with the national and provincial
authorities, Environmental Audit, Delegate Attorney’s Office for the Environment

and other entities of state control required in order to be part of the inter-
institutional team foreseen in Resolution 0005/00 and who will accompany the
spraying process, verifying compliance with the parameters to guarantee that the

areas that are not included as illicit crops do not suffer any damage.

2.3.2.1.6 Assessment of potential operational risk

Assessment of potential risk for the operation of the program for the eradication of

illicit crops by aerial spraying pretends to identify areas in which the accidents of
the operation may have important effects of the environment. That is why the
places where the discharges are to take place in case of eventual incidents occur

should be geographically indicated.

The above must allow for indications of the measures to be taken in case of an
accident and the components of the environment to which the efforts should be
directed; likewise, it is a tool to plan de program and implement the measures to

improve efficiency and optimize the operation.

Taking into account the program’s characteri stics, it is necessary to consider two
different scenarios, when evaluating potential risks. In the first one, the activities

are performed under favorable public or der conditions. The second one considers
potential risks for the operation under adverse public order conditions.

For the two scenarios, potentially dangerous events are assessed and the same
are graded according to the implications it would cause in the environment.

242 Annex 33

Subsequently, the threats are assessed and graded regarding the probability of
dangerous events to be present and likewise, an evaluation of the components of

the environment which may present more susceptibility to identified dangers and its
vulnerability is carried out. Finally, the information is integrated and the risk levels
are identified for the areas subject to evaluation.

The proposed methodology is expounded in the contingency plan.

2.3.2.2 Development of the Operation (in charge by each Operational Base of
DIRAN)

This phase requires exact knowledge of the site of illicit crops, exclusion zones and

buffer strips carried out previously through aerial detection, satellite information,
aerial reconnaissance, intell igence reports, characteriza tion studies on the social,
cultural, epidemiological, health, economic and environmental surroundings and

potential risks to carry out spraying in an optimal manner in the environmental,
technical and operational aspects.

Records of application of glyphosate for the program are approved by ICA the
relevant entity.

The parameters to be taken into account in the operation have been formulated
under the environmental, aeronautic and aeria l safety regulations in force and
applicable to the program. The parameters to be strictly complied with in the

program are:

• Buffer strips to water bodies, populated center, nearby vegetation and the
national parks system areas.

• Compliance of the Protocol of operation (height of flight, velocity of the
aircraft and spraying equipment) and climatic conditions.

2.3.3.5.1 Follow-up satellite system for precision of the operation

The program for the Eradication of Illicit Crops must have a satellite follow-up

system (currently the SATLOC System), installed in the spraying aircraft so that the
operation may be carried out with precision, bearing in mind the geographical
coordinates determined in the first detection phase. Later, through recording of all

and each of the spraying operations with the relevant routes, geographic
registration of the areas to be applied and the amount of glyphosate discharged
per minute, an exact verification of the geographical site where the operations were

carried out and the amount of areas sprayed shall be obtained, to the effect of
verification in case any claims are formulated.

2.3.2.5.2 Protocols for the Program’s Operation

243Annex 33

Setting up of the operational parameters is the product of the different field tests to
guarantee the program’s effectiveness, which leads to not only environmental but

economic benefits. The effectiveness of the application under these operational
parameters was guaranteed by ICA according to the concept issued the same day
to the Ministry of the Environment on the visit to the anti-narcotics base Larandia

on August 3 and 4, 2000 and during the complementation of the Management Plan
in September 2000.

Each one of the parameters is the maximum range covering the operation, adding

a safety factor in order to guarantee the precision of the application. However, to
obtain greater efficiency in the operation and a reduction of the flight times,
operational tests at the anti-narcotics bases are carried out to establish in each

region the best possible conditions fo r application, such as the aeronautic
parameters as well as the meteorological conditions according to the climatic
phenomena of each region. Chart No. 2.4 shows in detail each one of the

operational parameters taken into account. Chart 2.5 shows the dosages of
application and the volumes of discharge by hectare adopted by the program (refer
to the following sub-chapter).

2.3.2.5.3 Execution of the action plan

Procedure

• The pre-flight operations by the ae ronautical maintenance personnel from
the Aviation Area are started, consisting in preparing the machines.

• Fifteen minutes later an aerial reconnaissance of the area is carried out to
determine the atmospheric conditions (temperature, direction and speed of

the wind and relative humidity). Should the conditions allow for it, the
reconnaissance aircraft confirms the operation and then the chemical
materials used for spraying are prepared.

(Two pictures)
• Subsequently, the safety operational group for the convoy helicopters is
embarked determining the departure order and arrival to the target; the

personnel selected during the planning phase goes into these helicopters.
Likewise, among these there is a representative of the Environmental Audit,
a delegate from the Public Ministry or an officer from the Attorney General’s

Office and, eventually, an officer from the Ministry of the Environment and
from the Ombudsman, and other casual observers. In the SAR helicopter
(search and rescue) a specialist paramedi c in aid and recovery is present.

Likewise, a Hughes 530F helicopter also embarks the purpose of which is to
give safety and support in case of descent, accident or incident.

244 Annex 33

(One picture)

• Departure of aircraft towards the spraying nuclei directed by the leading pilot
of the aircraft and the leader commander of the helicopters. On arrival to the
target (lot), according to orders, the area to be worked over is to be

maintained; the helicopters are positioned at the tactical height over the lot
to ensure the area to be sprayed.

• Spraying of the illicit crops is carried out with T-65 or OV-10D aircraft,
keeping the helicopters as convoys for immediate security. After the aircraft
passes, the team goes back to the base of operations. This maneuver is

carried out inversely to the first one, being coordinated in advance and with
communication to the last aircraft ending its task.

2.3.2.5.4 Results of the Operation

Once the operation ends, minutes of the operation are prepared with indications

of place, hour, number of hectares, geographical coordinates, names of the civil
authorities, pilots who participated and notes of any incident, in order to carry
out the contingency plan or mitigation of damage.

To analyze the information, there is a data card installed inside the aircraft and

once the spraying operation ends, the data is downloaded en the matrix
computer where the routes, traces and coordinates covered by the aircraft are
visualized (SATLOC or Del Norte Program). Data generated by the program is

incorporated to a Geographical Information System, the purpose of which is to
situate, through geographical coordinates, the cartographic location of the
nuclei affected by the illicit crops.

Minutes of the operation have filming or photographic records and the graphic
records of the Satellite Follow-Up Syst em (recording software and electronic
signals system). Likewise, formats of the operation are developed where the

hours of departure and arrival, ingredients used, incidents in the aircraft and
any other relevant data and actions in the operation are recorded. In this
document, the formats used for the operation are attached.

It is important to highlight that the minutes, formats and records of the Satellite

Follow-Up System (SATLOC or DELNORTE) are extremely important to find
out the results of the spraying operations, to verify the relevance of the

formulated claims and the adjustment of possible errors committed.

Regarding the environmental results, they are carried out during the Inspection,
Verification and Control program for the spraying operations.

245Annex 33

2.3.2.5.5 Post-flight operations

* The number of hectares of illicit crops sprayed with information on the area,

analyzing the SATLOC system, the amount of agricultural ingredients used in
the operation (Glyphosate and surfactants), the number of aircrafts used, the
number of flight hours and the technical parameters with which the operation

was carried out is determined.

* A spraying polygram for illicit crops is prepared and is immediately forwarded
to the anti-narcotics communications office.

* The spraying orders by the judicial research unit is prepared with the

signature of all who took part in the spraying operation over the illicit crops.

* Reports, photographic records, activity registration with all information
received and the immediate forwarding of the polygrams to the Anti-Narcotics
Division.

* Systemized statistics is made on detection, spraying and verification activities
carried out at the jurisdiction.

Attached are the models of polygrams on spraying of illicit crops and the
minutes on application of glyphosate in coca or poppy plantations which are

completed on the same day of the operation.

2.3.3 Verification process
• Once the Satellite Follow-up System report (flight lines of each of the

aircrafts, spraying lines) is analyzed, it is determined if the operation was
carried out in the indicated areas though the Geographical Information
System, satellite information and the fixed alert system.

• Compliance in the technical parameters of the model is assessed regarding
the exclusion zones and the buffer strips. Should these established
parameters not be complied with, relevant actions are taken according to

the provisions of the contingency, verification, inspection and control plan.
• A final report is prepared with the results of the operation, with what was

previously indicated.
- Participants of the verification activities
- Minutes and polygrams

- Methodology of the process
- Results of the operation
- Recommendations

- Photographic records of the sample plots and nuclei

246 Annex 33

This report shall be prepared by operatio n, that is, daily and sent to the
Commander of the DIRAN based and the DNE. In the base, as well as in

the offices of DIRAN and DNE in Bogota, the reports must be available for
consultation by the environmental authorities.

Progressively during the execution of the action strategy, reconnaissance

operations and result assessment are carried out through air verification and
field work as well as in inter-institutional meetings to evaluate the results
which will allow for the responsible and representatives of the committed

institutions to analyze the dynamics and behavior of the areas where the
Program has been operating, in order to guarantee in this manner that
possible errors in this process be adjusted and corrected.

Card No 6 of the EMP has a detailed description of the inspection, verification and

control of the spraying operations proc edure, including the environmental aspects.
In this card, the indicators to evaluate the efficacy and efficiency of PECIG are
established in the technical aspects of spraying and its relation to the destruction of

illicit crops as well as in the environmental aspects. On the other hand, the
Monitoring Program of the EMP includes the permanent carrying out of SIMCI
(Integral Monitoring of Illicit Crops System), through which a follow-up process

through satellite is made of the annual evolution of the illicit crops by municipality,
province and nuclei. Chart No. 2.1 depicts the main actions, responsible entities
and indicators of the evaluation.

CHART. 2.1

EVALUATION OF THE PROGRAM FOR THE ERADICATION OF ILLICIT
CROPS

ACTION RESPONSIBLE INDICATOR
Identification, characterization Anti-Narcotics Police Report on
and specialization of the areas National Narcotics characterization of the
affected by illicit crops and Directorate areas subject to
exclusion zones Environmental Audit spraying.
Institutions from which

information is
requested according to Geo-reference of the
the provisions of Res. areas with illicit crops
0005. and exclusion zones
Alternate National
Development

Plan(PNDA)

247Annex 33

Social Solidarity
Network
Planning and decision on National Narcotics Operative programs

spraying operations Council
Developing spraying operations Anti-Narcotics Police Technical and
applications under technical Environmental Audit environmental
parameters in accordance with parameters and
operating and environmental operative protocols
regulations set up in the approved by the

Environmental Management program
Plan
Development of a Satellite Anti-Narcotics Police There is a Satellite
Follow-up System installed in Follow-up System
the spraying aircrafts in order to when the operation of
guarantee that the operation is the program starts

carried out with precision

248 Annex 33

MODEL OF POLYGRAM OF SPRAYNIG ON ILLICIT CROPS

NATIONAL POLICE

ANTI-NARCOTICS DIVISION

POLYGRAM NO. ___________ DATE ________

FROM _________________

TO __________________

TEXT:

SPRAYED HECTARES ________________

COORDINATES JURISDICTION MUNICIPALITY
PROVINCE

N. W.

N. W.

PARTICIPATING AIRCRAFT IN SPRAYING

PNC PILOFTMIGATEHas)

CONVOY AIRCRAFT INTERVENING IN OPERATION

PNC PILOT

*GLYPHOSA ADJUTA GLYPHOSA ADJUTA GLYPHOSA ADJUTAN
TE NT TE NT TE T
DEPOSIT DEPOSIT USED USED IN IN
EXISTENCE EXISTEN
CE

INNOVATIONS

249Annex 33

PERSONNEL

AIRCRAFT

(SIGNED) Head Spraying Base (SIGNED) Radio Operator

ANTI-NARCOTICS POLICE DIRECTORATE

AREA OF COMMAND_______ JUDICIAL RESEARCH UNIT

MODEL OF MINUTES No.___/__ ON SPR AYING WITH GLYPHOSATE OVER
ILLICIT COCA CROPS IN THE JURISD ICTION OF _______ MUNICIPALITY OF

______ PROVICE ______

On _____, at ____ ( )day of the month of ___ Two Thousand (2000), in the
neighborhood of the rural districts of_____, jurisdiction of the municipality of ____

Province of _____. From ____ hours to ___ hours of today, in the following
coordinates:

N N N N N

W.W.W.W.W.

N N N N

W.W.W.W.

Mr. CT______ Pilot PNC_______, Mr. CT____ Pilot of the PNC____, Mr.
TE________ Copilot PNC_____, Mr. TE______ Copilot PNC_____, CAPT______

Pilot of PNC_______, CAPT______, TE______ Commander Anti-Narcotics
Group______, CAPT _______ Pilot of TURBO TRUSH PNC_____, CAPT______
Pilot of the TURBO TRUSH PNC_______, Dr.___________ Criminal Officer from

the Attorney General’s Office, Mr. PT ______ Anti-Narcotics Judicial Officer from
Zone _________, appeared with the purpose of carrying out the matter of
destruction of plantation of coca trees, previously detected and identified on

____Hectares of illicit crops locateat the above mentioned coordinates; the
owner of the property where the crops were located was not established.

Thus, the provision of Article 77 of Law 30 could not be complied with, because it is
a high-risk zone and there is no place with in the area where aircrafts could land.

Once the above matters were done, destruction of the plantations was carried out
by Aerial Spraying in the neighborhood of the rural districts of _____, jurisdiction of
the municipality of _____, Province of _______.

250 Annex 33

NOTE: ________________

_______gallons of commercial formulation of the active ingredient Glyphosate

were used

_____hectares of coca trees were sprayed, being identified previously according to
the above mentioned coordinates.

Through communication No. _____ dated _______ Mr(S) Regional Delegate from

the Attorney General’s Office in _______was requested to be present at the
operation of eradication of illicit crops.

Through communication No. ______ dated _______ The Agrarian Officer from the
Attorney General’s Office was requested to be present at the operation of

eradication of illicit crops.

There being no further business, this matter has ended, and the record was read
and approved in all and each of its parts, it is signed by all who intervened, as

follows:

CT______________________ TE __________________

Pilot PNC___________ Pilot PNC ___________

CT______________________ TE __________________

Pilot PNC___________ Pilot PNC ___________

CT______________________ TE __________________

Pilot PNC___________ Pilot PNC ___________

251Annex 33

2.4. GLYPHOSATE CHARACTERIZATION

Glyphosate is a simple, broad spectrum, non-selective herbicide with systemic

action and suitable for the control of m any weed species in the post-emergence
treatment to foliage. It has no effect on seeds that are below ground and it is also
not absorbed by the roots. Things being equal it can also be said that it has no long

term residual action and that it is neither a soil sterilant herbicide nor does it act as
one.

It is the most widely used herbicide in the world due to its effectiveness, safety and
its multiple applications. Glyphosate formulations are registered in more than one

hundred (100) countries including the United States, where it has been approved
by the US Environmental Protection Agency to be used in over sixty agricultural
crops, in forest management undergoing intervention for preservation, and different

cropping systems, including maintenance of canals, roads and public and domestic
gardens. (130 total applications)

2.4.1 Physical-chemical composition and characteristics

Glyphosate is a molecule made up a fraction of glycine and a radical amino
phosphate joined as substituent of one of the hydrogens of the α-amino group.

Composition: Isopropylamine salt of N-(phosphonomethyl) glycine.

ROUNDUP: a light amber viscous solution, pH 4.4 to 4.9, specific gravity 1.17, faint

amine odor, molecular weight 169.08 and melting point 200° C.

Chemical Group: N-phosphono amino acid

                                                            
 According to Fred Slyfe, University of Illinois. 1992. 

252 Annex 33

Pure compound (active ingredient)

O O

II II

OH – C – CH – N2 – P – OH
CH –
2

I

OH

Glyphosate salt - isopropylammonium

O O

CH 3

II II I

OH – C – CH – NH – P – O
2 +
CH 2 H 3 –
CH

I I

OH

CH 3

Almost all commercial formulations of glyphosate are easy to handle; they are very
soluble in water and are chemically very stable in any proportion. In addition, the

vapor pressure is low, which renders the formulations for use in the field not
volatile.

Chart 2.2 shows the major physical and chemical properties of the herbicide.

253Annex 33

CHART No. 2.2

PHYSICAL-CHEMICAL PROPERTIES

PROPERTY PURE COMPOUND GLYPHOSATE SALT

(ACTIVE INGREDIENT) ISOPROPYLAMMONIUM

Molecular formula C H NO P C H N O P
3 8 5 6 17 2 5

Molecular weight 169.1 g/mol 228.2 g/mol

Physical state Solid white Amber to yellow viscous

liquid

Smell Odorless Virtually odorless, slight
amine odor

Density 0.5 g/mL 1.160 to 1.180 g/mL

Melting point 184.5° C Not applicable (liquid)

-7 -7
Vapor Pressure 1.84 x 10 mm Hg at 45° 3 x 10 mm Hg at 25° C
C

Boiling point It decomposes It decomposes

pH at 1% solution 2.5 4.7

Solubility in water 12,000 ppm at 25° C 900,000 ppm at 25° C

Other solvents None Only water-soluble

Stability 32 days at 25° C and pH 32 days at 25° C and pH
= 5.7 or 9 = 7 or 9

Octanol - water Pow = -2.8 N.A.
partition coefficient

Henry’s Law < 7 x 1011 N.A.

Constant

Corrosivity Non-corrosive Non-corrosive

254 Annex 33

Flashpoint

Combustion Products

Reactivity towards
container material

Reactivity towards This chemical can react with galvanized steel but not
container material with stainless steel containers to produce hydrogen

which could form a highly explosive mixture. It may
react with caustics (bases) to release heat. It is
corrosive to iron. This chemical is stable for two

weeks at a temperature of 60° C, if protected from
light. Solutions of this chemical in water, ethanol 95%
or acetone are stable for 24 hours under normal

conditions.

Source: Environmental Management Plan for the Eradication of Illicit Crops,
1999, 2000, 2001. DNE.

2.4.2. Commercial formulation types

Before referring to commercial formulations, it is appropriate to provide the
following definitions, in accordance with Decree 1843 of 1991 and other sources

(CIAT, 1977; Revelo, 1976):

Herbicide: A pesticide used to destroy plant material

Active ingredient: The biologically active part of the pesticide

Surfactant: A reducer of surface tension of the pesticide molecule, to allow

greater contact area with the leaf of the plant

Adjuvant: An inert additive substance without biological activity. It is used
to reduce evaporation, resistance to ultraviolet rays and

others. Cosmoflux is in fact a drift reducer.

Inert substance: A substance that imparts a desirable feature to the herbicide.

255Annex 33

Glyphosate is a herbicide which is sold in the form of soluble concentrates of

isopropanolamine salt of N-(phosphonomethyl) glycine, in which the Glyphosate
and the required inert ingredients are combined for each type of commercial
formulation. Although the most common marketing form is the water-soluble

concentrate, the following preparations are also available for specific uses.

• Chemically pure grade ingredient (for laboratory use)
• Technical grade ingredient
• Emulsifiable concentrates and concentrates in inverse emulsions

• Water-soluble concentrates, in different concentrations
• Wettable powders, soluble in water and for dusting and fumigant
formulations
• Granular formulations, pellet formulations and encapsulated formulations

In the Colombian market commercial presentations are made by companies
established in the country, with current sales records to April 1997, as indicated in
Chart No 2.3.

2.4.3 Surfactants and inert ingredients of basic formulation

In the process of preparing the formulations of glyphosate for commercial use,
solvents and mixtures or anionic and nonionic surfactants are used. According to

the manufacturer, the typical formulation of glyphosate in commercial use, in its
soluble liquid presentation, corresponds to:

Active ingredient: Glyphosate. N-(phosphonomethyl) glycine, in

isopropylamine salt 41.0%

IEtrtoxylatldwamine)*
59.0%

Some commercial formulations of glyphosate, including the one used in PECIG,
incorporate a surfactant known as POEA in a ratio nearing 15%.

256 Annex 33

Also part of the formulation for use is a fraction of a surfactant and alleged drift and

evaporation reducer, commercially called Cosmoflux 411 F, on which the
production and/or distributor company, Cosmoagro, has supplied the following
technical specifications. It is fitting to provide such comment because, according to

several publications, various environmentalists identify it toxicologically as one of
the hazardous constituents.

CHART NO. 2.3

COMMERCIAL PRESENTATIONS OF GLYPHOSATE

COMMERCIAL PRODUCTION CONCENTRATION* ICA
NAME COMPANIES REGISTRY

Faena 320 Proficol SA 320 g/L 1800

Faena 320 SL Monsanto Colombiana 320 g/L 1775

Fuete SL Monsanto Colombiana 480 g/L 2475

Ranger SL Monsanto Colombiana 240 g/L 2312

Rocket SG Monsanto Colombiana 74-75% 1993

Rocky SL Monsanto Colombiana 120 g/L 1757

Roundup Monsanto Colombiana 480 g/L 2670
madurante SL

Roundup SG Monsanto Colombiana 74-75% 2488

Roundup SL Monsanto Colombiana 480 g/L 756
(Salt)

Glifosato 48 SL Coagro Ltda. 48% 2699

Clinofox Cedar Crystal 480 g/L 2490

Chemical

Glifosol SL Colijap Ind. 480 g/L 2337

257Annex 33

Agroquimica

GlyfosanSL Químicos e Insumos 480 g/L 2234

Agrícolas

Glyphogan 480 Magan de Colombia 480 g/L 2530
SL

Candela 120 SL Agroser SA 120 g/L 2233

Candela XL Agroser SA 120 g/L 2800

Coloso SL Basf Química 480 g/L 2609
Colombiana

Panzer 320 SL Invequímica SA 320 g/L 2569

Panzer 480 SL Invequímica SA 480 g/L 2399

Regio SL Quimor SA 480 g/L 2211

* All commercial formulations refer to active ingredient contents such as salt.

Classification: Sprayiditive

Physical State: Liquid at 25° C

Viscosity at 25° C: 60 mPas, approximately

Specific Gravity: 0.89

Flash Point: above 149° C

pH (1% aqueous solution): 6.3

Oil concentration: 80 - 85% p/p

Solubility: < Soluble in mineral and vegetable oils

< Dispersible in water

< Insoluble in ethanol

Classification as poison:Not classified

Eye irritation: Non irritating

258 Annex 33

Rabbit skin irritation: Undiluted produced mild irritation after 24 hours

Human skin irritation: Not irritating or sensitizing

Biodegradability: Greater than 98%

In opinion of October 4, 2001, the Ministry of Health established the classification
of the mixture GLYPHOSATE + POEA + COSMOFLUX (1%) as follows:

a) Glyphosate active ingredient: Toxicological category IV (Slightly

Toxic) non carcinogenic, mutagenic
or teratogenic

b) Glyphosate + POEA (polyoxy-ethyleneamine): Toxicological category III

(Mildly Toxic)

c) Other formulations in the market: Toxicological category IV (Slightly

Toxic)

d) Cosmoflux 411 F: Toxicological category IV (Slightly
Toxic)

e) Mix of glyphosate + POEA + Cosmoflux 1%: Toxicological category III
(Mildly Toxic)

The Ministry adds in its opinion that “pesticides in that category are admitted

according to their action for use in domestic environments as in the case of
household pesticides such as Baygon spray, Raid mosquitoes and flies, Rayol
spray, Rodasol, Cupex kills flying bugs , and even for public health use such as

Malation, Fenitrothion and Solfac used for the control of dengue and malaria.”

259Annex 33

Annex No 2 presents the aforementioned opinion and the descriptive annexes of
the Cosmoflux 411 F adjuvant.

The title bearer of the sales registry of glyphosate in Colombia is the company
Industria Colombiana Agropecuaria.

2.4.4. Classes, materials and capacity of the containers

Plastic containers (polyethylene) are used for glyphosate, with a capacity of 55 gal
(approximately 200 liters). In the case of surfactant Cosmoflux, 5-gallon plastic
containers (approximately 20 liters) are used.

2.5 HERBICIDE APPLICATION METHODS

2.5.1 Herbicide application technique

General

For it be effective, the spraying method to be used should ensure a uniform
distribution of the herbicide in the required active ingredient dose on the illicit crop
to be eradicated, with the use of the mix of the formulated commercial product with

the water as a transport means, to produce evenly dispersed droplets over the crop
to be applied. The coverage or density of coverage is measured by the number of
droplets/cm2 captured by the crop foliage, which will determine the biological

success or the effect of the application.

Studies conducted to date by the DNE however, together with the Anti-Narcotics
Police (DNE, 1998, 2000, 2001), show that no aerial spraying equipment produces

a steady droplet size, therefore, the standard should be the Volume Median
Diameter (VMD), defined as the droplet size that satisfies the distribution of a
spraying volume producing 50% of a fine droplet size and the other 50% of a large

size.

260 Annex 33

The droplet size depends, nonetheless, on a number of factors such as physical

characteristics of the product, viscosity, vapor pressure, density, pump pressure,
spraying unit position with respect to the airflow, speed and operation altitude of
aircraft, environmental conditions related to temperature, relative humidity, speed

and wind direction and characteristics of the spraying equipment. To achieve
optimum results, the DIRAN has established operating parameters that allow the
control of the negative effects of these conditions. These parameters are illustrated

in Chart No 2.4.

Spraying Method

Two modes of spraying can be applied: parallel and “race track.” These methods

were described above (Section 2.1.2.2)

Factors that alter the effectiveness of spraying

Before spraying, the pilot and the commander of the operation should take into

account a number of factors, with the aim of making the final decision on whether
or not to spray and, if so, the parameters to adopt. Factors to consider may include
the following:

• Meteorological factors (very variable in the tropics, especially in the
mountains)
* Rain: affected by washing and leaching of the product (runoff)

* Wind or air currents: drift losses

* Temperature: evaporation losses

• Application factors
* Height: friction loss (underdosing)

* Speed: losses for breakup of the droplet and weakening of the application

261Annex 33

Consequently, the expertise and professionalism of the pilot plays the biggest role

in the success of the spraying.

The effectiveness of the eradication methods depends on the criteria used in the
mission to define the one that best meets the established goal. For this, the type of

crop (density, size, location), the distance from the center of operations and
operating time should also be taken into account, so that the mission is swift, safe
and effective.

Application dose and total discharge volume

The application dose, the characteristics of the mix with water and with the
adjuvant and the total discharge volume is shown in Chart No. 2.5.

The volume of applied or discharged mixture, with reference to crop density, i.e.
the effective discharge of mixture, is 23.65 L/ha for coca and 51.09 L/ha for poppy,
calculated for a “boom” of 28 nozzles, 2 mm in diameter 1.6 mm and 1.2 mm. The

doses applied are 10.4 L/ha of commercial glyphosate formulation and 2.5 L/ha for
poppy. It should be noted that this is not solely an active ingredient but rather the
commercial formulation, with a concentration of 480 grams of active ingredient per

liter of IPA salt.

Number of applications and frequency

One pass for each type of crop (coca, poppy or marijuana)

262 Annex 33

CHART NO. 2.4

OPERATING PARAMETERS OF THE PROGRAM FOR THE ERADICATION OF

ILLICIT CROPS BY AERIAL SPRAYING

PARAMETER UNIT/MEASURE VALUE OR VALUE OR
RANGE RANGE

COCA POPPY

FLIGHT ALTITUDE Meters Less than 25 Less than 12

Aircraft speed T65 mph 120 - 150 T 65 120 - 150 T 65

Aircraft speed OV-10 kt 180 OV-10 (not used)

Cargo of Aircraft Gallons 350 - 500 - 800 200-350

Discharge expected Liters/hectare 23.65 51.09

Discharge of cubic m.m./cm2 0.0384-0.0480 * 0.0096 to 0.012 *
Glyphosate i. a.

Commercial Liters/hectare 10.0 2.5

glyphosate

Droplet size Microns 300-800 300-800

Hours of application Day/night hours 5:30 to 10:00 5:30 to 10:00
a.m. a.m.

4:00 to 6:00 p.m. 4:00 to 6:00 p.m.

2:00 to 10:00
a.m.

Magnitude of In % of the 75% to 80% 75% to 80%

recovery spraying

Pump pressure Pounds per cm2 20 to 25 20 -25
(psi)

Swath width Meters 25-30 25-30

Expected drift Meters < 5 to 7 < 5 to 7

263Annex 33

T.V.B. Nozzles hole mm 2 2

Ambient temperature Degrees Celsius Up to 30 degrees up to 20 degrees

C. C.

Relative humidity Percentage 75 to 90% 75 to 85%

Wind speed In meters per 0 to no more than 0 to no more
second 2.0 than 2.0

* Due to the extent of recovery, the effective dose is estimated at 20% less than
that discharged

The ICA recommends changing the dose of the commercial glyphosate as follows:

For coca crops under one year old: use 8.0 L glyphosate, diluted in 15.413 L water

For coca crops over one year old: use 10.0 L glyphosate, diluted 13.423 L water

For both formulations, 236 cc of Cosmoflux should be added.

Source: this study

Operational parameters of fumigation operations

The parameters considered in the operation are due to existing environmental,
aviation and air safety regulations and which apply to programs. They are
summarized in Chart No. 2.4.

[Page 46]

CHART NO. 2.5

APPLICATION DOSE AND COMPOSITION OF THE MIXTURE USED BY TYPE
OF CROP

SUPPLY COCA (L/ha) POPPY (L/ha)

Commercial formulation with glyphosate 10 2.5
active ingredient (480 grams per liter of IPA

264 Annex 33

salt)

Cosmoflux 411 F Adjuvant 0.23 0.51

Water 13.42 48.08

MIX RATIO (%)

Commercial formulation with glyphosate 42 5
active ingredient (480 grams per liter of IPA

salt)

Cosmoflux 411 F Adjuvant 1 1

Water 57 94

MIX DISCHARGE PER HECTARE (L/ha)

Discharge of mix per hectare 23.65* 51.09

Source: Anti-Narcotics Police, 2001. * Calculated in accordance with the ICA
recommendation of 10 L/ha of commercial formulation diluted in 13.423 L/ha of
water for crops over a year.

2.5.2 Exclusion areas of the operation and buffer strips

In order to protect the environmental aspects of the spraying program areas, a
number of elements not to be sprayed have been identified; these are the

exclusion zones which include the national nature parks, human settlements, water
bodies and socioeconomic interest areas (substitution projects).

Additionally, buffer strips have been established around the illicit crops themselves,

in order to provide a protection area for each of the environmental elements
potentially affected by the spraying operation. Chart 2.6 shows the exclusion zones
and buffer strips currently being used in the program. The proposal is to adopt, in

addition, a 1,000-meter alert distance, that is, the area where the SATLOC system
will notify the pilot not to spray on exclusion areas or buffer strips surrounding
them.

265Annex 33

2.5.3. Herbicide tanking systems

Glyphosate is pumped from the 55-gallon plastic drums into a 500-gallon deposit,

where it will be kept to feed, also by pumping, the tanks of the aircraft (fiberglass
for T-65 and stainless steel for OV-10). In fixed doses for the mixture, the
encapsulating agent (Cosmo Flux 411 F) is added simultaneously with the tanking

of the herbicide and finally water. Each tanking equipment is equipped with flow
meters that register the exact values to be mixed.

[Page 47]

CHART NO. 2.6

BUFFER STRIPS ON ENVIRONMENTAL ELEMENTS APPLIED IN THE
OPERATION OF THE PROGRAM

ENVIRONMENTAL EXCLUSION ZONES ALERT DISTANCE
ELEMENT AND BUFFER STRIPS (SATLOC SYSTEM)*

Bodies of Water
No spraying over bodies
Static: lakes, lagoons,
of water
ponds, fish farms and 1,000 meters
wetlands. Buffer strip at least 100
meters
Flowing: brooks, rivers

No spraying within them
Areas of zones belonging

to the National Nature Spray the outside leaving 1,000 meters
Parks System a safety belt of at least
100 meters

Areas of human No spraying within them.

settlements
Spray the outside with a 1,000 meters
Rural settlements, safety belt of at least 100
reservations, urban areas. meters.

Areas with plant cover No spraying

266 Annex 33

other than illicit crops. The pilot must open and
close the valve within the

plot.

Areas of socioeconomic No spraying.
interest: productive
Establish a safety belt of 1,000 meters
projects, areas of
covenants. at least 100 meters.

Source: DIRAN, 2001. * The alert distance is the area where the SATLOC system

installed inside the aircraft must notify the pilot to respect the buffer strip, which
should not be sprayed. The distance of 100 meters as the sole buffer strip is
adopted in accordance with Article 87 of Decree 1843 of 1991.

2.5.4. Methods and frequency of calibration of the spraying equipment

The most frequently used methods for calibration of spraying equipment are:

• Definition of flow . 300 gallons of water measured on the ground, for one

minute of flight at 208 MPH with the spraying equipment open and pressure of
55 psi (bypass completely open) after several tests, it is determined that the
equipment sprays 200 gallons. Back on land the tank is filled again and if there
is a difference between the amount sprayed and the replacement, the
calibration number should be adjusted. The operation should be repeated on
several successive flights to ensure that the calibration is correct.

• In order to observe the distribution of the spraying and to measure coverage in
relation to the number of droplets/cm2 and width of effective pass, 46 cards are
placed transversely to the direction of flight, each 1 meter apart starting from
number 4 to 43 and the last 3 at each end, every 5 meters, in order to see the
effects of drift. The criterion to measure the lateral drift is the displacement of

the droplets smaller than 200 microns and densities under 10 droplets/cm2

• To measure the accuracy of the opening and closing of nozzles in the
application area, cards are placed in the direction of the flight, 7 in the (south)
entrance and another 7 at the (north) exit, aligned with the flags and 10 meters
apart from each other. The criterion is a minimum of 10 droplets/cm2.

267Annex 33

Calibration for determining the flow must be conducted before each operation.
Other calibrations can be performed every month, in a representative area of the

conditions of the operation nucleus.

2.5.5. Limitations caused by environmental conditions

As noted above, for optimum results in the application of the herbicide, the
conditions of wind speed, relative humidity, temperature, time of day and
topography of the land should be taken into account, together with the flight altitude

and speed of the aircraft. Chart No 2.4 summarizes the ranges where operations
should be conducted. Meteorological data can be taken from the stations of the
nearest airports. Where possible, at eac h anti-narcotics base there should be an

automatic weather station available to measure the parameters mentioned.

Limitations by evaporation and drift

Evaporation and drift are two major issues in the application of pesticides by

aircraft. Evaporation causes more or less significant herbicide “loss,” depending on
flight altitude, the size of the particles sprayed and the environmental conditions. At
high altitude flight, low relative humidity and high ambient temperature, the rate of

evaporation can reach 80% or more. This condition occurs in a 2-meter-high fall, if
the initial size of the droplet is less than 100 microns in diameter, the relative
humidity is approximately 50% and the temperature is above 30° C. The spraying

from 10 m high is unlikely to reach the surface of the crops if the initial particle size
is less than 200 microns in diameter.

“Drift” or lateral displacement by wind of a part of the pesticide spraying is one of

the main drawbacks of the spraying program, due to the effects that may result on
crops, people, water sources and all other ecological constituents of which sprayed
crops are part. In the case of treatment with glyphosate, the main concern is the

condition that it may cause to crops and other plants around them.

268 Annex 33

The phenomenon of drift depends essentially on the velocity of the crosswind, the
altitude of the sprayer aircraft, the initial size of the droplets sprayed, the density of

the chemical compound, ambient temperature and the spraying experience of the
pilot of the aircraft, and other less common factors. In general it can be noted that,
at higher altitudes, lower initial particle size, wind speed greater than 8 km/hour

and eventual presence of phenomena of “thermal inversion” (light wind, cold air at
ground level and warmer in the upper layers, commencing at 2 to 3 meters high),
the product drag increases because it exte nds the period of particle “suspension”

in air.

The particles with initial sizes of 200 microns produced by 1.0-density fluids take
slightly over 4 seconds to fall 3 m and 11 seconds when the size is 100 microns.

With winds of 8 to 10 km/h, particles of 100 microns in diameter can be dragged up
to 400 m, when the spraying is made from 6 m high. That drag, however, does not
get deposited on the surface near the ground because most of the material is lost

by dissipation in the atmosphere (volatiliz ation or evaporation) before reaching the
ground.

This is demonstrated by tests conducted in previous phases of the environmental
studies, on the effect of drift, droplet size and coverage pattern (droplets/cm2), and

the results were delivered to the Ministry of Environment in September 2000.

Limitations of coca control with Glyphosate

Glyphosate herbicide effectiveness depends in part on the stage of development

and physiological activity of the botanical species to be controlled. In the case of
coca species of the Erythroxylum genus, it is estimated that the development stage
most susceptible to the effect of glyphosate is between 3 and 12 months of age in

the field.

Given that commercial coca crops covered by the Program to Eradicate in some
cases exceed 12 months in age in different parts of the country, including the

geographic region of San Jose del Guaviare, the technical strategy to be adopted
must include, as a mandatory measure, special procedures able to override the
negative effect of having to make applications on crops whose ages are not, for the

most part, the most susceptible to the herbicide effect, without using too high (and
expensive) doses of the product, per surface unit (hectare).

On the other hand, cutting the plant at the neck of the root, which growers perform
post-spray, prevents the herbicide from being absorbed by the plant. Also, growers

269Annex 33

have developed plant washing systems with products such as brown sugar water
to minimize the effect of the herbicide.

2.6.TECHNOLOGICAL TOOLS, EQUIPMENT AND MATERIAL OF THE
PROGRAM

2.6.1. Equipment

General equipment

• Twin Otter aircraft for transport of commission personnel
• C-26 aircraft with technological support equipment
• SAR, UH - 1N, Bell 212, UN II helicopters
• Huey II helicopters

• Black Hawk helicopters, to transport VIP/Protection
• PNC Huey II helicopters
• PNC Bell 212 Helicopters
• Turbo Thrush aircraft with differential GPS and SATLOC system

• OV-10D with FLIR with SATLOC system
• Air Tractor aircraft with differential GPS and SATLOC system
• Night Navigation instruments (Night Vision)

Types of aircraft used in the spraying

Turbo Thrush Aircraft, OV-10 and Air Tractor AT-802

Technical Specifications

• Turbo Thrush

Aeronautical:

* Pratt and Whitney Engine PT 6A-65 AG

* 1230 HP Power

270 Annex 33

* The instrument panel is designed to facilitate the installation of additional
equipment such as GPS (Global Position System) and flow meters.

* The wings are 90 inches each and 16 meters long (built in chromed steel).

* Maximum takeoff and landing weight allowed 5,670 kg (1,250 lbs)

* 228-gallon fuel capacity

* Tank Capacity 660 gallons

* Cruise speed 175 MPH

* Maximum permissible speed 200 mph (322 kph)

* Minimum takeoff distance 1,500 ft (457 meters)

* Distance needed for landing 600 ft (183 meters)

* Fuel tanks are located inside the wings and are part of the airframe, the 2
main tanks have a capacity of 115 gallons and are interconnected.

* The dashboard is equipped with:

* Artificial electric horizon

* Fuel Gauge

* Oil temperature

* Vertical speed indicator

* Altimeter

* Air Speed

* Anemometer

* Compass

* Voltmeter

* Maximum herbicide load: 450 gallons

* Capacity up to 550 gallons

271Annex 33

• OV-10

* Maximum herbicide load: 350 gallons

* Twin Engine

* The dashboard is equipped with:

* Electric artificial horizon

* Fuel Gauge

* Oil temperature

* Vertical speed indicator

* Altimeter

* Air Velocity

* Anemometer

* Compass

* Voltmeter

• Air Tractor AT-802

* Fuel tank capacity: 254 gallons

* Tank Capacity: 800 gallons

* Maximum takeoff and landing weight: 16,000 lb

* Empty weight with spraying equipment installed: 6,320 lb

* Total weight loaded: 9,680 lbs

• Spraying Equipment

272 Annex 33

2.6.2. Materials and elements used

• Bullet-proof vests
• Binoculars

• GPS
• Video cameras
• Cameras
• MP8 Videos

• Photographic film
• Cartography
• Forms

2.6.3. Technological tools

The technological tools used in developing the spraying program are:

• SPOT and LANDSAT satellite images updated with of 20 and 30-meter
resolutions respectively. These are regularly acquired from distributors in

Colombia and managed by the SIMCI Project (DNE-DIRAN-UNDCP).

• Software for recording, analysis and interpretation of satellite images
(ILWIS, ERDAS, PCI, ILLISYS). The Pr ogram has these types of satellite
image processors, which can be used according to the characteristics of the
images and the needs.

• Field registration software (SATLOC). This software serves for satellite
tracking of aircraft in each of the spraying operations. After each flight, the
computer provides a list and coordinates that allow the plotting of the flight
paths of the aircraft.

• Panchromatic aerial photographs with a resolution to 1 meter.

• IGAC and DMA base mapping

• High precision geopositioning

273Annex 33

To ensure accuracy of the operation, the Police rely on the SIMCI project (Illicit
Crops Integrated Monitoring System), which interprets the images aimed at

establishing the various types of coverage in different provinces, with emphasis on
the characterization and quantification of illicit crops. Each image is processed and
integrated at the province level not only for updated information regarding the size

and location of illicit crops, but also for other physical type of information that may
be obtained from the satellite image, which allows monitoring and tracking the
areas of operation. Annex No 1 has a more detailed description of this project and

the methodology used.

2.7. PROGRAM FOR THE ERADICATION OF ILLICIT CROPS

2.7.1. General Aspects

By authority of the National Narcotics Council, the Anti-Narcotics Police runs the

operations of the Program for Illicit Crop Eradication in the context of national
policy to combat drugs called the “ National Plan to Combat Drugs, Colombia
1998 - 2002,” which is the basic framework in which state agencies should

implement their action to tackle the drug problem in the country.

The purpose of the program is the eradication of illicit crops, taking into
consideration aspects of social, political, economic, legal, environmental and health

nature in order for it to be executed in a controlled manner from an operational and
environmental standpoint.

The program is developed in regions wher e the presence of illicit crops is

identified, taking into account their differential character, according to their nature
and purpose, that is, their type or category, extensive or industrial crops and
potential risks.

274 Annex 33

The Illicit Crop Eradication Program does not operate in environmentally sensitive

areas: populated areas, parks and natural reserves, watercourses and water
bodies

2.7.2. PECIG Structure and organization

Chart 2.7 shows the structure and organization adopted for the development of the

program.

Within this framework, it is the responsibility of the National Narcotics Directorate to

coordinate the development of the eradication plans, as well as the environmental
management plan and all the programs contained herein. At the province level it
works through the Regional Technical Drug Units, which are specialized structures

in drug issues at the province level created by initiative of the National Directorate
of Narcotics and backed by the political will of governor offices, using as a criterion

the magnitude of the drug problem, including its various manifestations, and the
awareness and sensitizing of it.

The Regional Technical Units are multi- agency teams of technical support to the
Sectional Council of Narcotics, comprising members of all entities that have some
responsibility for the execution of the Province Drug Plan, consistent with the

manifestations of the problem in each locality: production, trafficking and/or
consumption and consistent with the policies and goals of the National Plan to
Combat Drugs.

Its purpose is to manage the plans, pr ograms and projects for comprehensive
assistance to the drug problem, reach inter-sectoral agreements to define priorities

for intervention, to manage resources in the Province Development Plan and
assess compliance with the defined Province Plan. 6

2.7.3. Inter-institutional coordination activities

                                                            
6 LAW 30 OF 1986 “ADOPTING THE NATIONAL DRUG STATUTE AND OTHER PROVISIONS,” deputy DNE office 

275Annex 33

The different entities involved in the Program To Eradicate Illicit Crops With

Glyphosate-PECIG should guide their activities in accordance with common goals,
adjusting their actions and involving communities in the management. To reach
agreements is the fundamental element in the unification and optimization of

actions. The program has three major processes: crop detection, spraying and
verification.

2.7.3.1. Detection group coordinating activity

The objective is to identify and establish areas of illicit crops, taking into account
area, exact location of the plot by coordinates, topography and surrounding
vegetation, among others. Similarly, hi gh-risk areas are located, productive

projects and voluntary agreements being dev eloped by responsible institutions,
and buffer strips are established for the Eradication Program not to operate in
these areas.

Chart 2.8 shows the organization and re sponsibilities of those involved in
detection.

CHART 2.7

STRUCTURE AND ORGANIZATION FOR THE DEVELOPMENT OF THE
PROGRAM

ACTION RESPONSIBLE ACTIVITY

Policy National Narcotics Authorize the DIRAN to develop PECIG
Leadership Council (CNE)

National National Narcotics Coordinate with all entities involved in
Program Directorate (DNE) PECIG its implementation and

276 Annex 33

Coordination enforcement of technical and legal
actions established for the Program.

Operational Anti-Narcotics Police Based on the guidelines given by the
execution (DIRAN) National Narcotics Council, develop the
Program which will operate under the

technical parameters of reference and/or
operational procedures to ensure its
development with low procedural and

environmental risk.

Monitoring and National Narcotics Supervise the proper implementation of
control Directorate (DNE), the program.

directly and through Control, tracking and monitoring to allow
environmental audit
services * assessment of the environmental,
agronomic and health impact generated
by this Program. This monitoring should

be conducted in accordance with
programs of Inspection, Evaluation and
Control, and of Environmental

Monitoring of the Environmental
Monitoring Plan.

* When reporting about environmental auditing in this document, it refers to the

ongoing mandatory activity of environmental audit and/or environmental inspection
to the program, whether it is international or by services provided by national firms.

2.7.3.2. Coordinating action of the spraying group

The aim is to develop glyphosate spraying operations under technical application
parameters in accordance with operational and environmental standards set in the

established legislation, Environmental Audit and Environmental Management Plan.
Chart 2.9 shows the organization and re sponsibilities of participants in the
spraying.

2.7.4. Program Goals

277Annex 33

The annual aerial spraying goals at the national level and at each nucleus level will

depend on national and international resources available for this purpose. By 2000
the sprayed area in coca cultivation was 58,073 hectares and 9,254 in poppy. A
conservative estimate of the goals for 2001 includes the spraying of 50,000

hectares of coca and 10,000 hectares of poppy.

As was explained in the description of theprogram (Section 2.1), the eradication
activities of illicit crops by aerial spraying are an ongoing activity of the Anti-

Narcotics Police.

CHART 2.8
COORDINATION OF DETECTION ACTIVITIES
UNITS, INSTITUTIONS AND
GROUP ACTION
AGENCIES INVOLVED

There is a report of illicit crop
detection and the tentative
National Drug Council, Anti-Narcotics
annual spraying schedule for Police, SIMCI Project and DNE.
submission to the National
Narcotics Council for approval.
D

E Identification, characterizationAnti-Narcotics Police

T and spatialization of the areas DNE
affected by illicit crops and
identifying exclusion zones of COMPREHENSIVE SYSTEM OF
E MONITORING OF ILLICIT CROPS
the Program.
C Project

T In accordance with the provisions of
• With satellite images Resolution 0005 of 2000, a request
I • With mapping
• Overflights for base information and cartography
O is made to the following institutions:
• Aerial photography and
N filming • Ministry of Interior
• Recognition of industrial • Ministry of Agriculture
clusters and subsistence
farmers • National Alternative
Development Plan
• Social Solidarity Network.
• Ministry of Health
Characterization of areas to be • Colombia’s National Parks

278 Annex 33

sprayed • Governors
• Mayors
Evaluation of the information
• Autonomous Regional
collected. Corporations
• ICA Branches
Submission of the • Municipal Departments
characterizations to the inter •Province and city Health
institutional technical committee
Departments
for its recommendations • Universities
• Institute of Hydrology,
Meteorology and
Environmental Studies -

lDEAM
• IGAC
• National Bureau of Statistics
Anti-Narcotics Police, DNE, Attorney

General’s Office, Environmental Audit,
National Plan for Alternative
Development and SIMCI Project
Scheduling of activities and
aerial reconnaissance officials.

Eventually involved are the Ministry of
Environment and the Solidarity
Network.

Identify and spatialize buffer National Drug Council, Anti-Narcotics
strips Police, SIMCI Project and DNE

Approval or not by the CNE of

the development of the National Drug Council
Program.

Source: DNE

279Annex 33

CHART 2.9

COORDINATION OF THE SPRAYING ACTIVITIES

GROUP ACTION UNITS, INSTITUTIONS AND
AGENCIES INVOLVED

Preparation of operational
Anti-Narcotics Police
planning

Anti-Narcotics Police
Planning and control

• Meetings for planning of
the operation Police and Military Forces
• Coordination of

intelligence operations,
A • Coordination with Local authorities, Environmental
organizations at the
S national and local level Audit, Delegate Attorney’s Office for
Environmental Affairs and National
authorities identified by the CNE.
P

E Evaluation and control of Anti-Narcotics Police, DNE,
operating parameters
R established in the EnvironmentalEnvironmental Audit and the Attorney
General of the Republic
S Management Plan

I Adjust the Satellite Tracking
System SATLOC or any other
Anti-Narcotics Police
O monitoring tool, to perform the
operation in a precise manner Environmental Audit
N according to the geographical

location of the sites

Anti-Narcotics Police, DNE,
Environmental Audit, Attorney
Illicit crop spraying operations
under the operating parameters General’s Office.

established in the EnvironmentalEventually, the Ministry for the
Management Plan. Environment, Ombudsman, Ministry
of Health and Health Departments,

local authorities, Colombian

280 Annex 33

Agricultural and Livestock Institute
and other determined by the CNE

Systematization, statistical
analysis, preparation of recordsti-Narcotics Police and
Environmental Auditing.
and archives.

Source: DNE

2.7.5. PECIG’s Schedule

The following is a tentative schedule, based on hectares sprayed in 2000. The
actual distribution will depend on weather and safety conditions of each operation
site.

CHART 2.10

GENERAL SPRAYING SCHEDULE BY GOALS (HA)

MONT J F M A M J J A S O N D

H

AREA* 673 673 673 403 403 404 404 404 673 673 673 673
3 3 3 9 9 0 0 0 2 2 3 3

% 10 10 10 6 6 6 6 6 10 10 10 10

* These percentages were assumed because the months of April to August are the
rainiest in the eastern area

281Annex 33

2.7.6. PECIG’s costs

The costs of spraying illicit coca crops with glyphosate are estimated at US

$471.51 per hectare for OV-10 aircraft and US $463.30 per hectare with T-65
aircraft, for an average of US $467.405/ha. For poppy, costs are US $429.89/ha
with T-65 aircraft.

If the 2000 spraying goals continue for the coming years, that is, 58,073 hectares
of coca and 9,254 has of poppy per year, the total project cost would be US
$27,143,610 dollars for cocaine and US$3,978,202 for poppy per year. In pesos,

that would mean figures of $63,787.5 mill ion pesos for coca and $9,348.8 million
pesos for poppy, for $73,136.3 million pesos in total.

Chart 2.11 shows the discrimination of the cost of spraying

The above calculations were estimated using fixed-wing aircraft and rotary wing,
staff and supplies.

According to estimates by the National Police, this investment is preventing drug
dealers from earning at least:

• US $144,000 ha/year of coca

• US $140,000 ha/year in poppy

The cost of spraying includes:

• The cost of the human resources in cludes employed civilians, civilian
and police pilots and logistical staff

• The aircraft operating cost includes cost of flight/ha in OV-10 and T-65.
• The cost of glyphosate refers to the value of the herbicide
• The cost of adjuvants
• The cost of water used in the program

282 Annex 33

• The cost of fuel used by aircraft

CHART 2.11
COST OF AERIAL SPRAYING WITH GLYPHOSATE PROGRAM
(Dollars per hectare)

DESCRIPTION COCA POPPY

OV-10 T-65 Average

1. Human resource 94.42 60.47 77.44 60.47

2. Aircraft operation 255.92 283.64 269.78 308.84

3. Glyphosate 84.85 84.85 84.85 20.71

4. Water 0.02 0.02 0.02 0.05

5. Adjuvants 2.23 2.23 2.23 5.46

6. Fuel 34.06 32.08 33.07 34.36

TOTAL/HA 471.51 463.30 467.41 429.89

Alkaloid Sale/ha 36,000 36,000 36,000 70,000

Total sales/year 144,000 144,000 144,000 140,000

Source: DIRAN, 2001

[CHAPTER 3]

3. ENVIRONMENTAL BASELINE

This chapter consists of two main sections:

283Annex 33

• The first is dedicated to presenting and discussing the influence area of the
program to eradicate illicit crops through aerial spraying of glyphosate
(PECIG).

• The second is dedicated to presenting the main elements of the baseline in
the areas of program implementation, taking into account that the potential
area is across the country, except the paramos, the semi-deserts and
wetlands. Part of this baseline is a brief description of the environmental
impacts of the drug industry in Colombia, since they are one of the key

elements in order to assess more clearly the impact of PECIG, which is the
subject of Chapter 4.

The baseline is not presented in detail throughout the country, 1:25,000 scale
mapping, as would be required for infrastructure projects, for the following reasons:

• Although the surface of the plots with illicit crops is 163,289 hectares, they
are divided into 24 provinces and 183 municipalities, in such a way that the
area of indirect influence to cover would be, in practice, extremely great and
its social and environmental characterization at a detailed scale could easily

take several years.

• On the other hand, for the same marginal conditions for agriculture in areas
where most of illicit crops are cultivated (areas of tropical humid and very
humid forest) and due to the criminal activity underlying drug trafficking, the
regional dynamics of illicit crops is very fast in such a way that the areas that

are now coca zones will no longer be such tomorrow and vice versa. This
implies that any social and environmental characterization of the current
areas of crops would be quickly outdated.

• Each of the glyphosate spraying operations requires careful planning in the

days before execution, as is dem onstrated in Chapter 2, “Program
Description”, not only in the technical aspects of air navigation and the
spraying method to use, but regarding public safety issues, prevention of
attacks by armed groups, previous definition of exclusion zones and buffer
strips, among others.

• Consequently, the DNE considers that at this stage–the conducting of the
spraying–is when the detailed characterization of the area to spray should
be available, in order to organize the activities of prevention, correction,
mitigation and compensation for possible environmental and social impacts.

284 Annex 33

This approach means that this management plan is considered a master plan

which should be embraced by all activities of PECIG both in the counter-narcotics
bases and in the spraying operations them selves, anywhere in the country, either
in current areas of illicit crops or where they would develop in the future.

This approach also means that at this stage of environmental planning it is not
necessary to have detailed environmental characterization of all areas to spray, as
this should be a requirement for the planning of each spraying operation, when and

where needed, that is, in real time.

Nevertheless, for the purposes of the framework of the environmental management
plan it was considered necessary to devel op a national characterization of each of

the nuclei included in PECIG, to appreciate the basic environmental constraints of
each of them and especially, the definition of the fragile, delicate, critical, strategic
and/or socially relevant ecosystems, according to the provisions of Decree Law

2811 of 1974 and Law 99 of 1993 and its implementing regulations.

3.1. IDENTIFICATION OF THE AREA OF INFLUENCE

3.1.1. Criteria for selection of areas for aerial spraying

The criteria for selecting areas to be sprayed are established by resolutions 001/94
and 005 of 2000 of the National Narcotics Council.

3.1.2. Areas of influence for the PECIG

Currently, illicit crops are distributed in 24 provinces and l83 municipalities.
According to the August 2000 census, a total of 163,289 hectares have been
cultivated with coca and 6,200 in poppy. Chart No 3.1 displays the distribution of

these crops by province.

285Annex 33

It is noted that the province of Putumayo alone represents 40.4% of coca crops.

Next in importance with 16.3% is Caquetá, Guaviare with 10.8% and Meta with
6.8%. In total, the jungles of the Colombian Amazon area (including the Guaviare)
concentrate 68.9% of coca crops in the country (including those in Guanía and

Vaupés). The savannas of the Orinoco area (Arauca, Meta and Vichada) gather
10.4% of the crop. In total, the Ori noco-Amazon region accounts for 79.3%, i.e.
four-fifths of the national area planted in coca. Among the Andean provinces, the

largest coca areas are Nariño with 5.7% and North Santander with 3.8%, while the
crops are mainly in the humid lowlands of these provinces, in the foothills of the
Eastern (in the Amazon and Orinoco basin) and Western Mountain range (Pacific

plain) and in the Catatumbo (North Santander).

In poppy, the most important province is Cauca with 32.2%, Nariño and Huila trail
with 24.2 and 16.1% respectively, of the cultivated area.

Considering the distribution of coca by nuc lei (Chart No 3.2), the most important is
the Putumayo-Caquetá 59.2%, followed by Meta-Guaviare-Vaupés with 21.4%,
South of Bolivar-Antioquia-Cordoba 7.3% and Cauca-Nariño with 6.7%.

Accordingly, it is possible to distinguish two types of areas in which the program
may manifest its effects: the area of direct influence and the indirect area of
influence.

• The area of direct influence is one in which the impacts directly caused by
the spraying of glyphosate could be manifested, such as the destruction of
the coca plants, the affectation of other types of natural vegetation and
crops, soil and water pollution and the effect on wildlife. In this case, this
area is strictly limited to industrial crops susceptible to spray, plus a buffer

strip bordering them, to a distance of 5 meters, which is the permissible drift
according to the spraying parameters.

286 Annex 33

CHART 3.1

AREAS OF ILLICIT CROPS IN COLOMBIA

PROVINCE AREA OF % AREA OF %
COCA POPPY
CULTIVATION CULTIVATION

YEAR 2000 YEAR 2000
(Ha)
(Ha)

Antioquia 2,547 1.6

Arauca 978 0.6

Bolívar 5,960 3.6

Boyacá 322 0.2

Caquetá 26,603 16.3

Cauca 4,576 2.8 2,000 32.2

Cesar 779 0.5 700 11.3

Cundinamarca 66 0.04

Córdoba 117 0.07

Guainía 853 0.5

Guajira 321 0.2 200 3.2

Guaviare 17,619 10.8

Huila 1,000 16.1

Magdalena 200 0.1

Meta 11,123 6.8

Nariño 9,343 5.7 1,500 24.2

Norte de 6,280 3.8
Santander

287Annex 33

Putumayo 66,022 40.4

Santander 2,826 1.7

Tolima 800 12.9

Valle del Cauca 76 0.05

Vaupés 1,493 0.9

Vichada 4,935 3.0

Chocó 250 0.2

Total 163,289 100 6,200 100

Source: Anti-Narcotics Police, DNE, SIMCI Project. Institutional
Censuses of illicit crops

288 Annex 33

• The area of indirect influence is one which could exhibit the indirect
impacts of the program. For the purpos es of this program, this area
corresponds to areas of the municipalit ies where illicit crops are found, and
therefore, where there will be the need to interact with communities through
the social management plan. The following diagram illustrates the concepts

of direct and indirect area of influence.

Coca crops direct impact zone 

Municipal Center 

Area of direct influence 

Municipal Boundary 

289Annex 33

CHART 3.2

AREAS COVERED BY COCA CROPS IN THE 2000 CENSUS
RESULTS BY NUCLEUS

NUCLEUS Total Nation Program Nuc Municipali

Area al % Object leus ties
(ha) Area % affected

Putumayo-Caquetá 96,694 59.2 57,174 64.4 27

Meta-Guaviare-Vaupés 34,878 21.4 16,859 48.2 24

South Bolívar-Antioquia- 11,959 7.3 4,989 42.0 49
Córdoba

Cauca-Nariño 10,906 6.7 3,899 66.5 21

La Gabarra 6,103 3.7 1,472 24.1 15

Arauca 1,234 0.8 636 51.6 5

Boyacá-Santander 743 0.4 257 34.6 31

Sierra Nevada Sta. Marta 522 0.3 133 25.5 5

Chocó 250 0.2 --- --- 2

TOTAL 163,28 100.0 85,419 56.3 183
9

Source: SIMCI, August 2000 Census

While the area of direct influence can be readil y identified, as it is the area of illicit
crops and the licit area sprayed, the boundaries of the area of indirect influence is
more diffuse, so it is usually demarcated by a line drawn at a certain distance of

the project or work under study, forming a rectangle or a circle. In the case of
PECIG, this distance would not be greater than 1 km from the edge of the sprayed
plots (in the case of roads up to 2 - 2.5 km from the axis are considered, but in this

case alterations to the drainage must be considered). Some projects may have
areas of broad socioeconomic influence that may cut across local or even national

290 Annex 33

boundaries, as is the case of coca whose product, cocaine, is sold in the cities of
many countries around the world.

Taking into account Chart No 3.2, the area of direct influence of the coca crops
would be about 85,419 ha for industrial crops, plus the 5-meter perimeter buffer
strip to allow for the drift. The area of indirect influence would be related to the

coca fields of the 183 municipalities involved. It must be noted that in these
regions, the size of the municipalities is often very large, sometimes greater than in
some provinces in the interior of the country.

Annex No 2 shows in detail the illicit crop area by municipality, province and
nucleus, according to the census of August 2000. Map 1.1 in Chapter 1 shows the
general location of coca crops in the country and the maps in figures 3.4 to 3.11

show the distribution of the coca crops per nucleus.

3.2. GENERAL CONDITIONS OF THE ILLICIT CROP AREAS IN COLOMBIA

Illicit crops are distributed in much of the country, but because of its illicit nature

and ecology, they have chosen certain types of areas characterized, on the one
hand, by their marginal ecological conditions, with high rainfall and temperatures in
the case of coca, and high rainfall and cold weather in the case of poppy. On the

other hand, they correspond to areas with an established process of colonization,
but with a very low coverage of roads and utilities. They are not, then, as can
sometimes occur, areas of primeval fores t; illicit crops come in after the clearing

and the use of the land. This can be very well illustrated in the coca-growing areas
of southern Bolívar and Caquetá-Putumayo (see photos 2 and 3, etc.).

3.2.1. Physical component

As announced and substantiated at the beginning of this chapter, this is a general
characterization of the areas of illicit crops (Program Nuclei). The detailed
environmental characterization, in those aspects that should interest the PECIG

(vegetation cover, land use, human settlements present, nearby national parks)
should be the object of the stages of detection, characterization of illicit crops and
assessment of information collected that take place at the very process of selecting

291Annex 33

areas for spraying (see Chapter 2, Sections 2.1.1, 2.1.2 and 2.13 and tab No 2 on
the protocol of the spraying process).

Chart No 3.3 shows the general physical condition of each of the nucleus purpose
of the Program. Upon observation of the Chart the following conditions can be
highlighted:

• In general, the areas chosen for the cultivation of coca (and marijuana) are
warm, humid to very humid, with rainfall generally above 2,000 mm per year
and, in some nuclei, exceeding 5,000 mm, as are Cauca-Nariño and Chocó.

• Flat to rolling topography (hills), because they correspond mostly to the
plains of the Amazon, the Orinoco, the Pacific and the low Catatumbo.
However, in the land cleared for cultivation of poppy, the topography can
range from ravine to steep lands, with serious risks for the generation of
erosive phenomena (see photos 1, 4 and 5)

• Soils with low to very low potential for traditional farming activities as a result
of high humidity, which makes soil nutrients to leach rapidly, which requires
the use of chemical fertilizers at hi gher rates than in other climates. In
addition, high rainfall, coupled with high temperatures favor the growth of
insects of all kinds, which requires al so the intensive use of pesticides at
doses and frequencies much higher than in sub-humid and semi-dry

climates. In the rugged areas of the Andean forest, the slope of the land is
an additional constraint for agricultural use.

• High drainage density, with numerous rivers and streams flowing
permanently as a consequence of the high precipitation. These rivers are

very important from a water biodiversity point of view, and they can
therefore be seriously affected by intensive and uncontrolled pesticide use.
In areas of Andean and high Andean forest used for poppy cultivation,
deforestation can drastically affect the water systems of its watercourses,
largely used to supply the water systems of the towns located downstream.

Photos 1.3 and 4 show the physical condition of some areas of illicit crops.

292 Annex 33

3.2.2. Biotic conditions

Chart 3.4 shows the general biotic condi tions in each of the nuclei under the

program. Upon observation of the box the following conditions can be highlighted:

• In general, the areas chosen for the cultivation of coca correspond to
potential areas of humid to very humid tropical forest (equatorial evergreen
forest or ombrophilous forest), intervened to very intervened and in some
cases, cut for the most part, as is the case, among others, in southern

Bolivar (see photo No. 3).

• In its original state, these forests have a great flora and fauna diversity with
many endemic and endangered species. In some sectors, coca cultivation is
performed in areas with anthropic savannas and gallery forests of the

Orinoco.

• Poppy crops, however, take place in areas of potential Andean and high-
Andean forest, also very intervened, and in many cases, completely
replaced by pastures and crops. In its natural state, these forests are also of
great importance for their biodiversity and the interest for the conservation of

water, whose sources are used, as noted, for rural and urban water supply
downstream.

• There are protected areas, affectable or affected by illicit crops in most of
the nuclei, except the South of Bolivar, Antioquia, Córdoba and Boyaca-
Santander, which, however, are excluded from the PECIG spraying

operations.

Figures No 3.12, 3.13, 3.14 and 3.15 show satellite images (in color composition),
where the existing vegetation can be seen in some areas of the nuclei of Guaviare,

Putumayo and southern Bolivar. It is noted that although the dominant vegetation
is secondary forest or primary forest, coca crops are in or near areas already
cleared and occupied by grasslands. Of particular interest is the alluvial complex

observed in La Hormiga sector in Putumayo (Figure No 3.14), where it can be
observed that many of the coca crops are on the banks of the Guamuez River.

293Annex 33

3.2.3. Social, economic and cultural components

Chart No 3.5 reveals the outstanding so cioeconomic and cultural conditions of

each of the areas of illicit crops object of PECIG (crop nuclei). Observation of the
Chart allows highlighting the following conditions:

• Coca cultivation is done in general, in areas of low population density,

although the trend is growing because of migration generated by illicit crops,
characterized by extreme poverty levels and lack of public services,
economy based on extractive activities and with no economic infrastructure
for the development of traditional economic activities or with low coverage
(roads, energy, etc.).

• Poppy crops are cultivated usually in areas of relatively higher population
density, but in all cases low compared to average levels in the country,
characterized by extreme poverty levels and lack of utilities, traditional
smallholder economy, with a low coverage of economic infrastructure for the
development of traditional economic activities (roads, energy, etc.).

• In some areas, illicit crops are in areas close to population centers, as seen
for example in the satellite image of the figure 14, in Putumayo.

• In almost all areas of illicit crop s, indigenous communities are present,

particularly in the areas of the nuclei Meta-Guaviare-Vaupés, Choco,
Putumayo-Caquetá, and Córdoba, although the majority of the indigenous
population is located in the area of influence of the poppy nucleus
(Chaparral-Iquira-Páez-Teruel).

• A very important feature from an environmental point of view is that coca

cultivation, for the most part, is not located within the forest but in open
areas previously occupied by pastures and traditional crops, indicating that
the coca crops are more typical of areas of established settlement or in the
process of consolidation.

294 Annex 33

CHART 3.3

OUTSTANDING PHYSICAL CHARACTERISTICS OF THE AREAS OF ILLICIT

CULTIVATION

NUCL WEATHER GEOMORPHOLOG SOIL HYDROLO
EUS Y GY

Warm (T>24° C) Putumayo: plain Haplorthox and Basins of
and humid to with low hills in Dystropepts of the the
very humid Lower Tertiary humid and very Putumayo

(P>25000 mm marine sediments. humid high plains and
per year). of the Amazon Caqueta
Caquetá: high plain area. rivers,
Prevailing winds with relief in Higher
Putum tributary of
from the SE, of Tertiary sediments. Tropaquents, the Amazon.
ayo - low power (<2 Fluvaquents, Abundant
Caquet m/s) and heavy Alluvial fans in Tropaquepts and
á foothills and recent rivers with
incidence of the alluvial beds along Plinthaquepts in numerous
calm. recent alluvial tributaries
rivers. plains. Suitable
permanent
forests and flowing and
extensive cattle partly
growing
navigable.

Meta- Warm (T>24° C). Meta: high flat and Meta: Petroferric Basins of
Guavia Very humid for dissected and tropeptic the Meta

re- Guaviare and Quaternary terraces. Haplustox. River and its
Vaupé Vaupés (p>3000 Plains and low hills Haplorthox, tributaries,
s mm) and humid with ferralitic Dystropepts and Guaviare

to very humid in shields. Haplustox on and its
Meta (p>2500 terraces and tributaries,
mm). Prevailing Guaviare: high plain piedmont cones. Vaupés and
with relief on upper
winds from the Guaviare: its
SE, of low power Tertiary sediments Haplorthox and tributaries,
(<2 m/s) and and flattening Dystropepts of the Apaporis
surfaces currently
heavy influence high humid and and its
of the calm. dissected. Vaupés: very humid plains tributaries,
idem Guaviare + with Ultisols in the all flowing

295Annex 33

peneplain in savannas of Yari. and partly
crystalline navigable.
Vaupés: idem
Precambrian rocks
of the Guiana Guaviare +
Shield. Troporthents,
Haplorthox and

Alluvial fans in Quartzipsamments
foothills and recent in relief of the
alluvial beds shield. Suitable

forests and
extensive cattle
growing.

Antioquia and Troporthents in the Córdoba:
South Warm (T>24° C)
of to mild (18-24° Cordoba: hills of Serrania de San Basins of
Bolívar C). Subhumid in Tertiary sedimentary Lucas. the Sinu and
San Jorge
- the north cover, folded and Fluvaquents,
Antioq (P>1500 mm) to dissected. Tropaquepts, rivers.
uia- very humid Dystropepts and Antioquia:
Bolivar and part of
Córdob (p>2500 mm) to Antioquia: Haplorthox in the basins of the
a the south. fans of the foothills Cauca and
Predominant NE metamorphic of the mountains San Jorge
igneous massif of
winds, low power San Lucas, and floodplain. rivers.
(<2 m/s) and Haplorthox and Bolivar:
heavy influence sedimentary cover Dystropepts in the basins of the
of the base in the
of the calm. eastern foothills of sedimentary rivers Cauca
mountains and
San Lucas and dissected and Magdalena.
fluvial lake plain of
Magdalena-Cauca- folded. Suitable Alluvial lake
forests and plain of the
San Jorge. extensive cattle Lower
Landslides in humid
clay areas. growing, partly for Magdalena-
mechanized Cauca-San
agriculture. Jorge.

Cauca- Warm (T>24° C) Piedmont hills of Dystropepts, Basins of
Nariño and very humid Cenozoic and Troporthents and the Micay,

to perhumid (P Pleistocene age in Tropodults in the Pati,
between 3000 volcano- hills. Tropofluvents, Iscuandé,
and over 6000 sedimentary detrital Eutropepts and Tapaje,

mm). Prevailing materials. Dystropepts in Patia and

296 Annex 33

winds from W Quaternary detrital dams and terraces Mira rivers,
and NW, low deposit plain on of the floodplain. characterize

power (<2 m/s) tertiary materials. Trpoquents, d by being
and heavy Fluvaquents and bountiful.
incidence of the Trpaqueps in poorly

calm. drained areas.
Suitable for forestry
because of the high

humidity climate.

La Warm (T>24° C) Low and medium Haplorthox and Cataumbo
Gabarr and humid hills on clay and Dystropepts in the and Tarra

a (P>2000 mm). sandy sediments of humid hills. Rivers,
Prevailing winds the Higher to Lower Suroeste
from the NE and Tertiary. Lower Tropaquents, and their
fluvaquents and
N of low power slopes of the tributaries,
(<2 m/s) and Serrania de Los Tropaquepts in all
heavy influence Motilones in recent floodplains. constantly

of the calm. sediments of the Suitable for forest flowing.
Cretaceous. Alluvial and extensive cattle
valleys with recent
growing
detritus material

NUCLEU WEATHER GEOMORPHOLO SOIL HYDROLOG
S GY Y

Arauca Warm (T>24° C), Overflow Tropaquents, San Miguel,
subhumid floodplain, Tropaquepts Ele, Cravo

(P>2000 mm) in dejection cones and Dystropepts Norte and
the plains to very and torrential in plains and Casanare
humid (p>3000 piedmont fans. alluvial fans. rivers and

mm) in the Lower hills and Tropofluvents, their
foothills and lower mountains of the Eutropepts and tributaries in
slopes. Prevailing Cordillera Oriental Dystropepts in the foothills,

winds from the NE are folded and well-drained all flow
and SE, of low dissected in varied alluvial plain. permanently.
power (<2 m/s) Tertiary and Fluvaquents, They are part

297Annex 33

and heavy Mesozoic Tropaquepts, of the Orinoco
influence of the sediments. Dystropepts and basin.

calm. Landslides in Haplorthox in
humid clay areas. very humid
areas of the

foothills.

Boyacá- Warm (T>24° C) Moderately steep Haplorthox, Quebradas,
Santande and humid to very lower slopes of Trpaquepts and Dosquebrada

r humid (P between the Cordillera Dystropepts in s, La Fiebre,
2000 and 4000 Oriental in the damp hills. La Ceiba, Las
mm). Prevailing Cretaceous Tropaquents, Pavas and La

winds from the E sediments. High Fluvaquents, Muerta,
and SE, of low and low hills in and tributaries of
power (<2 m/s) clay and sandy Tropaquepts in the

and heavy Tertiary recent alluvial Magdalena
influence of the sediments. plains. Suitable River, all flow
calm. Landslides in clay forest and permanently.

slopes. extensive cattle
growing.

Sierra Warm (T>24° C) Massif in broken Troporthents, North Slope:

Nevada to cool (18-24° C). relief, in Quartzipsamme basins of the
Sta. Semi-dry (p>1200 metamorphic nts, Agua Clara,
Marta mm) to wet igneous rocks of Psammaquents, Don Diego,

(p>2000 mm) on different ages. Tropaquods and Palomino,
the north side. Erosion by intense Haplorthox in San Miguel
Eastern and diffuse runoff with the massif, and Tapias

western slopes gullies located in generally of low rivers.
are relatively lower areas of the to no farming Eastern slope,
dryer. eastern and suitability. basins of the

Prevailing winds northwestern Fluvaquents, Rancheria
slopes. Landslides Tropaquepts, and Cesar
from the NE and in humid clay Dystropepts and rivers.
N of low power
(<2 m/s), with zones of Haplorthox in Western
metamorphic humid alluvial Slope:
occasional rocks. valleys of the Córdoba,
moderate winds
and heavy piedmont, with Manzanares,
agricultural Frio,
influence of the potential. Tucurinca,
calm.
Sevilla,

298 Annex 33

Aracataca
and Piedras

rivers.

Chocó Warm (T>24° C), Low hills in sinkingTropofluvents, Basins of the
very humid pit and semi-pit in Eutropepts and Atrato and

(p>3000 mm) to Tertiary Dystropepts in San Juan
perhumid (p>5000 sediments. Atrato well-drained rivers, both
mm). Prevailing river floodplain alluvial soils, ranked among

winds from W and with detrital suitable for the most
NW, low power deposits agriculture and abundant
(<2 m/s) and originating in the cattle growing. rivers in

heavy influence of recent torrential Tropoquents, Colombia and
the calm. alluvium Fluvaquents and the world
Quaternary and Tropoquepts in (flow per unit

Holocene. poorly drained area).
Mountain chains alluvial soils,
in sedimentary suitable for

and volcanic rocks extensive cattle
(Serrania de growing.
Baudo) and Dystropepts,

metamorphic Troporthents,
(Cordillera Tropodults and
Occidental). Tropoaquents

Landslides in locally, in areas
mountain clay of hills and
areas. foothills, suitable

for forest.
Troporthents
and Dystropepts

in the hills and
mountains
suitable for

forestry and
conservation.

(Huila Cool (T <18° C) to Moderate to very Troporlhents, Upper basins

and south cold (T 10-18° C) steep slopes of Quartzipsamme of the rivers
western humid to very the igneous- nts, Blanco, Iquira,
Tolima) humid (P 2000 to metamorphic Psammaquents, Pacamí,

(Chaparra 4000 mm). Massif of the Tropaquods and Baché, Ata

299Annex 33

l-Iquira- Prevailing winds Cordillera Central Haplorthox on and Saldaña.
Páez- from the SE, of (Nevado del Huila the massif. All with

Teruel)* low power (<2 and Paramo de Soils, in general, permanent
m/s) and high Las Hermosas). low to no flow.
influence of calm. Mass wasting agricultural

processes on clay suitability.
slopes. Intense Fluvaquents,
diffuse runoff Tropaquepts,

erosion under Dystropepts and
clean cultivation. Haplorthox in
humid alluvial

valleys, with
better
agricultural

potential.

Source: This study, based on data from Igac Regional Atlas, soil surveys,
geological plates and other sources.

* Included for its importance to the cultivation of poppy

CHART 3.4

OUTSTANDING BIOTIC CHARACTERISTICS OF ILLICIT CROP AREAS

NUCLEU VEGETATION FAUNA IMPORTANT

S ECOSYSTEMS
AND NATIONAL
NATURE

PARKS

Putumayo Evergreen equatorial forest (or Fauna is very The entire
- Caqueta tropical humid forest according biodiverse. 210 equatorial

to Holridge) multilayered, high, mammal species, evergreen forest
with dense lower layer, high 147 species of (humid forest).
biodiversity of species. This reptiles, 95 The national

forest has been replaced amphibians and parks are:
mostly by grasslands in the 868 species of
foothills between the Caquetá birds have been * Chiribiquete
National Nature

300 Annex 33

and Guaviare rivers. Sparse calculated. Park (Caquetá)
floodable forests, with palm Endangered
* La Paya
trees in the flood plains of the species: 23
rivers. 5400 species of higher mammals, 9 National Nature
plants have been reported for birds, 1 reptile. Park (Putumayo)

the Amazon area.

Meta- Guaviare: Evergreen equatorial Idem Amazon The entire
forest, multilayer, low, with area (Caquetá- equatorial
Guaviare- sparse lower level, with palms Putumayo), plus evergreen forest
Vaupés
in poorly drained areas, with fauna of the (humid forest).
high biodiversity of species, Orinoco area, The national
where 28 species parks are:
intervened. Vaupés: evergreen
equatorial forest (or tropical of amphibians,
humid forest according to 644 birds, 119 * Nukak National
Nature Park
Holdridge), multilayered, high, reptiles, 65 (Guaviare)
with dense lower level, high arachnids and
biodiversity of species, 359 hymenoptera
* Macarena
intervened. have been National Nature
reported. Park (Meta)
Meta: grassland savanna, Endangered
partially evergreen equatorial
forest to the southeast. Sparse species: 25
species of
floodplain forests, with palm mammals, 1
trees in the flood plains of
rivers, intervened. For the reptile and 5
birds.
Orinoco, 2047 species of
higher plants have been
reported.

South of Evergreen equatorial forest, Fauna is very The entire
Bolívar- multilayer, high, with dense biodiverse. 32 equatorial
Antioquia- understory, high biodiversity of species of evergreen forest

Córdoba species. Sparse forest amphibians, 951 (humid forest).
floodplain, with Palm trees in birds, 101 The system of
the river flood plains. Forests reptiles, 133 marshes in

have been interfered and arachnids and southern Bolivar
replaced by pastures. For the 434 hymenoptera and the lagoon
Caribbean plains 3429 species have been area of Bajo

of higher plants have been reported. No Magdalena-
reported. Forests moderate to information on Cauca-San

301Annex 33

high intervention. endangered Jorge.
species.

Cauca- Ombrophilous tropical forest or Fauna is very The entire
Nariño Hylaea of the Pacific, with 3 biodiverse. ombrophilous
layers, 35 m high and closed Although there tropical forest,

canopy. Predominates in the has been no including native
foothills of the Cordillera inventory of the and guandal
Occidental. In the central area fauna of the forests. The

of the Pacific plain the Hylaea region, 127 national parks
is in mosaic with flooded native species of are:
and/or guandal forests. The amphibians, 577
* Munchique
guandal is swamp forest rich in birds, 104 National Nature
palms. The native is a forest in reptiles, 101
transition between mangrove arachnids and Park

and Hylaea, so it has the 649 hymenoptera * Sanquianga
influence of brackish water. In have been National Nature
some areas these forests have reported.
Park
been taken over by logging, Because of its
gold exploitation and cattle high moisture, the
growing. For the Pacific 5474 existence of many

species of higher plants have endemic and
been reported. endangered
species is

assumed.

La Evergreen equatorial forest, Fauna is very Evergreen
Gabarra multilayer, high, with dense biodiverse. for the equatorial forest.

lower layer, high biodiversity of area 70 species National parks
species. Sub-Andean forest on of fish, 73 are:
the eastern foothills of the amphibians and
* Catatumbo-Bari
Serrania de Perija. Sparse reptiles, 99
floodable forests, with palm mammals and National Nature
trees, in the flood plains of 120 birds have Park

rivers. Forests have been been reported.
moderately to highly Endangered
intervened. species: 26

species of fish, 6
species of

302 Annex 33

reptiles, 6 species
of mammals.

NUCLEUS VEGETATION FAUNA IMPORTANT

ECOSYSTEMS
AND NATIONAL
NATURE PARKS

Arauca In the foothills, relictsIt is part of the OrinocoRelicts of the

of the equatorial area (Orinoquia), equatorial
evergreen forest, where 28 species of evergreen forest.
multilayer, very amphibians, 644 birds, The areas of the

intervened, with 119 reptiles, 65 National Nature
pastures and arachnids and of 359 Parks are:
agricultural areas. On hymenoptera have
*Flora and Fauna
the plains, grassy been reported.
savannah on poorly Endangered species: Sanctuary of
drained surfaces. 25 species of Arauca

Floodable forests and mammals, 1 reptile
Moriche palms along and 5 birds.
rivers and streams. For

the Orinoco area 2,047
species of higher

plants have been
reported.

Boyacá- The potential Since it is in the Relicts of the
Santander vegetation consists of transition between the equatorial

evergreen equatorial medium and lower evergreen forest
forest, multilayer, high Magdalena river basin, (or humid and very
with dense understory, it shares its humid tropical

high biodiversity of composition of flora rainforest)
species. Sub-Andean and fauna with the
forest remnants in the Caribbean region,

foothills of the where 32 species of
Cordillera Oriental. amphibians, 951 birds,
Sparse floodable 101 reptiles, 133

303Annex 33

forests, with palm trees arachnids and 434
in the flood plains of hymenoptera have

rivers. Forests have been reported. No
been moderately to information on
highly intervened and endangered species

replaced by grasslands has been provided.
and crops.

Sierra Since the crops are Being a mountain Relicts of

Nevada Sta. mainly on the humid range to the sea, its equatorial
Marta north side, the fauna is very diverse. evergreen forest,
potential vegetation For this area 195 deciduous forest

consists of evergreen species of birds, 46 and sub-Andean
equatorial forest (or reptiles, 18 amphibians forest of great
tropical humid forest) and l00 mammals have interest for

and sub-Andean been reported. biodiversity and
forests in the mountain Endangered species: 4 water production.
ridges. To the east and species of reptiles and The National

west, on the floor 14 endemic Nature park areas
between 1,000 and amphibians, 9 endemic are:
2,000 m, deciduous mammals and 7
* Sierra Nevada de
forest or tropical dry endangered species,
forest predominates. 34 endemic bird Santa Marta
All forests have been species (or from a very
* Tayrona
intervened and low range) and 17
replaced by grasslands endangered species.
and crops. For the

Sierra Nevada de
Santa Marta 1800
species of higher

plants have been
reported.

Chocó Ombrophilous tropical Biodiverse fauna. The entire Pacific

forest or Pacific Although there has Hylaca with native
Hylaea, with 3 layers, been no inventory of and guandal
35 m high and closed the fauna of the Pacific forests. The

canopy. The Hylaea is region, have been wetlands of Atrato-
in mosaic with flooded reported 127 species San Juan. The
native and/or guandal of amphibians, 577 National Nature

forests. The guandal is birds, 104 reptiles, 101

304 Annex 33

swamp forest rich in arachnids and 649 Parks are:
palms. The native is a hymenoptera. Because
* Las Orquideas
transition forest of its high moisture, the
between mangrove existence of many (partially)
and Hylaea, so it has endemic and

some brackish water. endangered species is
Along the Atrato river assumed.
there are areas of bog

vegetation. In some
sectors these forests
have been taken over

by forestry, gold
exploitation and cattle
growing. For the

Pacific 5474 species of
higher plants have
been reported.

(Huila and High Andean humid to Biodiverse fauna. For Andean fog forest
southwester very humid forests (fog this sector of the and humid
n Tolima) forest). Humid to very Cordillera Central 62 paramos. The

(Chaparral- humid Andean Forest. species of reptiles, 52 national parks are:
Iquira-Paez- Humid subparamos amphibians, 103 birds
Teruel) and paramos of the and 191 mammals * Paramo de las
Hermosas
Nevado del Huila and have been reported.
Paramo de Las Endangered species: * Nevado del Huila
Hermosas. For this 22 species of

area 1200 species of amphibians, 2 snakes,
higher plants have 13 mammals and 21
been reported. birds.

Source: 1) This study, based on data from Igac Regional Atlas, soil surveys,
geological plates and other sources

2) Rangel, J.O, 1995, Colombia, Diversidad Biotica I y II. *Included because of its
importance to poppy cultivation

305Annex 33

CHART 3.5

MAJOR SOCIOECONOMIC CHARACTERISTICS

NUCLEUS SOCIAL ASPECTS ECONOMIC CULTURAL

ASPECTS ASPECTS

Putumayo- Areas bordering zones The traditional Indigenous
Caquetá of recent colonization, economy is population:
jungle or semi jungle, fundamentally Putumayo: 9

density of population extractive, except in ethnic groups,
under 5 hab/km2 and perimeter areas of 2146 families and

less than 1 hab/km2 recent settlement, 15,311 people, 13
High poverty levels where it is mainly for reservations (Inga,
and lack of public cattle. Coca is the Kamsá, Witoto,

services. main speculative crop. Cofán, Siona)
Lack of economic
infrastructure for Caquetá 10 ethnic
groups, 482
production. families, 2698

people, 14
reservations
(Witoto, Inga,

Coreguje).

Meta- Guaviare: areas Guaviare and Vaupés: Indigenous
Guaviare- bordering zones of the traditional economy population:

Vaupés recent colonization, is fundamentally Guaviare: 4 ethnic
jungle or semi jungle extractive, except in groups, 588
with population density perimeter zones of families, 4340

of less than 5 hab/km2 recent settlement, persons, 6
and less than 1 which is primarily for reservations
hab/km2. Vaupés: cattle. Meta: the (Sikuani,

jungle areas with economy revolves Carripaco,
population density around cattle and Guayabero).
lower than 1 hab/km2 crops such as rice and Vaupés: 19 ethnic

except around Mitu (<5 palm. Coca is the main groups, 2669
hab/km2). Meta: speculative crop. Lack families, 16,569
natural and of economic persons, 1

anthropogenic infrastructure for reservation
savannas with (Cubeo). Meta: 4

306 Annex 33

population densities production. ethnic groups, 963
between 1 and 5 families, 5793

hab/km2 in peripheral people, 13
areas and 5-20 reservations
hab/km2 to the foothills (Sikuai, Piapoko,

(municipality of Vista Guayabero,
Hermosa, Puerto Achagua).
Lleras, San Juan de

Arama, and others).
High poverty levels
and lack of public

services in general,
although slightly better
in the municipalities of

the foothills.

Sur de Rural population Extensive cattle Indigenous
Bolivar- density less than 10 growing (<1 head/ha), population in area

Antioquia - hab/km2. High poverty especially in the of influence:
Córdoba levels and lack of terraces and flats of Antioquia: 7
public services, but Cauca, San Jorge and reservations in

slightly better in the Magdalena rivers. area of influence
municipality centers. Localized agriculture. (Embera, Embera-
Extractive forestry and catío and Cuna);

fisheries economy. population is
Mining in some unknown
enclaves (gold and
Córdoba: 2 ethnic
ferronickel). Coca is
the speculative crop. groups (embera),
Lack of economic 3147 families,
17,385 persons, 3
infrastructure for
production. reservations.

Cauca- Rural population Traditional economy is Indigenous

Nariño density is generally fundamentally population in the
less than 5 inhabitants extractive (wood), Pacific:
per km2, although in except in perimeter
Cauca: 3
some sectors it may be zones of recent reservations
between 5 and 10 settlement, where it is
hab/km2. High poverty mainly cattle. In some (Embera);
population is not
levels and lack of sectors alluvial gold

307Annex 33

public services, but mining is developing. known.
slightly better in the Coca is the main
Nariño: 54
municipality centers. speculative crop. Lack
of economic families, 278
infrastructure for inhabitants, 2
reservations of
production.
Cuaiker ethnicity.

The Andean
region is excluded.

La Gabarra Rural population Traditional economy is Indigenous

density is generally fundamentally population in the
less than 5 hab/km2 extractive (wood), area of influence:
although some sectors except in perimeter
Norte de
may be between 5 and zones of recent
10 hab/km2. High settlement, where it is Santander: 1
poverty levels and lack mainly cattle. In some reservation of the
Barí ethnicity;
of public services, but sectors coal and oil is
slightly better in the developing. Coca is population is
municipality centers. the main speculative unknown.

crop. Lack of economic
infrastructure for
production.

NUCLEUS SOCIAL ASPECTS ECONOMIC CULTURAL

ASPECTS ASPECTS

Arauca Population density The traditional Indigenous
between 1 and 5 economy is based on population in area
hab/km2 on the plain extensive cattle of influence:

and 5-20 hab/km2 growing and wood
toward the foothills. extraction activities Arauca: 6 ethnic
High poverty levels (the latter in the groups; 350
families 1880
and deficit of public foothills). In the last
services, although decades oil exploration persons, 12
slightly better in the has been the most reservations
(Sikuani, Tunebo,

308 Annex 33

municipality centers. significant. Coca is the Betoye,
main speculative crop. Macaguaje,

Cuiba).

Boyacá- Rural population Extensive cattle No reservations
Santander density is generally growing (<1 head/ha), have been

less than 10 hab/km2, especially towards the declared in the
although in some lowlands of the area.
sectors it may be Magdalena Valley.

between 10 and 20 Localized agriculture.
hab/km2. High poverty Extractive forestry and
levels and lack of fishing economy.

public services, but Mining in some
slightly better in the enclaves (emeralds).
municipality centers. Coca is the main

speculative crop.
Economic
infrastructure for

production has low
coverage.

Sierra In the Guajira sector Extensive cattle Indigenous

Nevada Sta. the population density growing in the Guajira population of the
Marta is less than 10 sector, on the northern Sierra:
hab/km2, and in the slopes of the
Magdalena -
Magdalena sector it is mountains, where the Cesar - Guajira: 3
between 10 and 20 most part of the coca
hab/km2. High poverty cultivation occurs. ethnic groups,
3214 families,
levels and lack of Extensive cattle 17,032 persons, 2
public services, but growing interspersed
slightly better in the with forest patches and major reservations
(Arhuaco, Kogui,
municipality centers. a few crops on the Arzaro).
lower slopes of the
mountains, in the

Magdalena. Alluvial
gold mining in some
areas. Tourist spots in

some areas on the
coast. Low coverage of
economic

infrastructure for

309Annex 33

production.

Chocó· The density of the rural Traditional economy is Indigenous

population is generally based on extractive population:
less than 5 hab/km2. activities (wood),
High poverty levels except for parts of the Chocó: 5 ethnic
groups, 4946
and lack of public valleys of the Atrato families 25510
services, but slightly and San Juan rivers
better in the which are primarily for people, 39
reservations
municipality centers. cattle growing. In some (Embera, Embera
sectors alluvial gold
mining is developed. - Catío, Cuna)

Coca is the main
speculative crop. Low
coverage of economic

infrastructure for
production.

(Huila and Areas with substantial Cold and cool weather Indigenous

southwest indigenous people and traditional agriculture, Population of area
of Tolima) subsistence farmers. extensive cattle of influence:
(Chaparral- The rural population growing. Low coverage
Cauca-Huila:
Iquira-Páez- density is generally of economic 15634 families,
Teruel)* more than 20 hab/km2 infrastructure for
in occupied areas. production. 94,608 persons,
41 reservations
High poverty levels (Paez Yanacona,
and lack of public
services, but slightly Coconuco
Guambiano,
better in the Totoro)
municipality centers.

Tolima: 326
families, l758
people 1

reservation
(Coyaima,
Natagaima).

Source: 1) This study, based on data from Igac Regional Atlas, soil surveys,
geological plates and other sources.

2) DNP, 1989. Los pueblos indigenas de Colombia.

310 Annex 33

* Included for its importance to the cultivation of poppy

3.2.4. Social degradation induced by illicit crops: social frame of the PECIG

3.2.4.1. Trends in coca and poppy crops

Coca

Until 1970 Colombia had a limited coca production tradition. The industry as such

started in the mid-seventies, given that the high profits surpassed those of
marijuana. The original coca plantations were developed in colonized areas of the

eastern plains and the Amazon basin, including regions of Guaviare and Caguán.

The boom that started in the mid to late seventies which lasted until 1981 brought
with it a wave of immigration that ups et the development of various regions. The

illicit crop boom had distorting effects on the social, economic, and environmental
makeup of the area and in the traditional living patterns: it generated the
7
phenomenon called the “Dutch disease,” that is, the illicit industry profits were not
invested in productive projects or infrastructure works in the same areas, but were

accessible for the emergence of conflict and violence.

In the mid-eighties, after a period of depressed market, the production of coca leaf
reactivated. The rise in production to the increasing demand consolidated the

organizational structure centered on dominant cartels, which set the production
areas, prices, and the markets were settled in partnerships.

Several conditions favored the development of illicit crops : the poverty generated

in the field because of the low yields of the land, lack of infrastructure,
technological lag and the shortage of facilities for credit, trade and marketing of

products, the marginalization of indigenous groups; the crisis of the agricultural
sector, which in recent years has worsened the poverty levels, migration and

violence; and the competition brought about by the economic opening that was not
coupled with competitive strategies for agricultural production. Rural poverty has
worsened in the nineties: between 1991 and 1995, the percentage of poor people

7                                                           
 Thoumi, F. Economía Política y Narcotráfico. TM Editores, Bogotá 
8 Plan Nacional de Lucha contra las Drogas: 1998‐2002 

311Annex 33

in rural areas increased from 65 % to 72%, that is, it increased by 7% (Lopez,
1998).

There is no doubt that the origin of th is conflict is decades old. Santiago Perry
mentioned that the level of land use in a country and the way it used reflect the
level of development of this country and in particular of its agriculture sector 9. The

productivity crisis in the countryside has bee n related to the inefficient use of land,
as it has not been used intensively or te chnically; the use for extensive cattle

growing; the degree of concentration of land ownership; and, in addition to the
above factors, the effect of the armed conflict in the country. This was further
exacerbated by the lack of roads, rail, credit and social investment, among others.

The presence of illicit crops in the r egions gave rise to a phenomenon that would
be of great concern to regional national and international governments: the

migration dynamics. In Colombia, migration flows have changed the demographic
map of the territories with increased pres ence of illicit crops. Thus, the population
10
of the Colombian Amazon soared from 50,700 in 1983 to 502,876 in 1993 . In the
last three years, the phenomenon of forced displacement of persons has increased

dramatically in the Orinoco and Amazon area in Colombia and, in particular, in
Meta, Caquetá, Putumayo and Guaviare.

The provinces of Caquetá, Guaviare and Putumayo are growing at rates above the
national average. It is worth mentioning that these regions have been the stage of
the greatest social, environmental, economic and territorial conflicts derived from

inequality levels created by the migration process, the problem of drug trafficking,
armed conflict, weak presence of the state and the absence of economic

alternatives, among others. Of the 45,000 cultivated hectares in 1994, 53.3% were
concentrated in Guaviare, 20.7% in Caqueta, and only 9.2% in Putumayo. The
three provinces accounted for 83.2% of the national total.

The beginning of the decade of the nineties was characterized by the expansion of
illicit crops in the country (s ee Chart No 3.6), which have centered in recent years

in the south, mainly in the provinces of Putumayo, Caquetá, Guaviare, Nariño,

                                                            
9 La Crisis Agraria en Colombia: 1959‐1980, Santiago Perry 
1 DANE 

312 Annex 33

Cauca, Huila and Tolima, which are part of the geographical regions of the
Colombian Massif, in the southeast, which includes part of the Amazon area. This

problem is linked to the factors described before and a systematic drop in coca
production in Peru and Bolivia, which facilitated the development of the illicit
activities.

CHART 3.6

RATIO BETWEEN CULTIVATED AREA AND

COCA LEAF PRODUCTION

Years Cultivated Coca Leaf Production

(metric tons)
Hectares

1991 37,500 30,000

1992 37,100 29,600

1993 39,700 31,700

1994 45,000 35,800

1995 50,900 229,300

1996 67,200 302,900

1997 79,500 347,000

1998* 101,800 414,000

Source: United States Department of State. Bureau for
International Narcotics and Law Enforcement Affairs.
Colombian Anti-Narcotics Police. Note the large increase in

productivity between 1991 and 1998.

The province of Guaviare was the largest producer of coca leaf. The crops
development in this region marked an upward trend from 1992 to 1996, starting

from 22,900 hectares to 38,600 hectares, to begin to decline starting from 1997,
which was the year the spraying process intensified. This had the immediate effect
of a rapid expansion in the provinces of Caquetá and Putumayo, which became the

two major domestic producers in 1998.

313Annex 33

The province of Putumayo presents a significant increase in areas planted with

coca mainly in the last two years. From 5,000 hectares in 1995 it increased to
19,000 in 1997, 30,100 in 1998, 58,297 in 1999 and 66,022 in 2000. The
percentage change between 1999 and 2000 was 13.25% and in the last year it

represented 40.4% of the total planted area in the country (Figure No 3.2).

Figure No 3.1

Major provinces of coca cultivation (year 2000)

Production potential:

The Anti-Narcotics Police, based on fieldwor k, calculated that the national yield of
coca leaf is estimated at 2,876 lbs. per hectare per harvest. The potential cocaine
production is estimated at 5.8 kilograms per hectare with 4 crops a year.

Program to eradicate coca crops

314 Annex 33

Since 1984, aerial spraying has been used intermittently to destroy illicit crops. The
Colombian government, therefore, through the National Narcotics Council (CNE) , 11

issued Resolution 0001 of 1994 for the implementation of the Program for the
Eradication of Illicit Crops.

The CNE, as of January 1992, authorized the Antinarcotics Police to conduct the

eradication by aerial spraying with glyphosate, given its role in controlling and
suppressing the production, trade and unlawful use of drugs. Additionally, it

ordered the hiring of an Environmental Audit in order to ensure the spraying in
compliance with environmental and safety standards to protect human health.

                                                            
11 The  National  Drug  Council  was  established  by  Decree  1188  of  1974  as  an  advisory  body  to  the 

Government in formulating policies that must be carried to combat the production, trade and use of drugs 
or  substances  that  cause  physical  or  psychological  dependence.  Among  its  functions  are  ordering  the 
destruction of illicit crops by means considered most appropriate, after approval of the agencies responsible 

for ensuring the health of the population and the preservation of the country’s ecosystems. 

 

According to Article 35 of Decree 2159 of 1992, the National Narcotics Council is made up of: The Minister of 

Justice and Law, who chairs, the Minister of National Defense, the Minister of National Education, the 
Minister of Health, the Minister of Foreign Affairs, the Environment Minister, the Attorney General’s Office, 
the Attorney General’s Office, the Director of the Administrative Security Department, the Director General 
of Police, the Director of the Presidential Program to address Drugs consumption and the National Director 
of Narcotics (with voice but no vote). 

315Annex 33

ESTIMATES OF THE COCA CROPS BY MAIN CROP AREAS

Source: Anti Narcotics Police

Figure No 3.2

Main areas of coca cultivation

Spraying processes have generated protes ts and mobilizations by settlers,
growers, indigenous groups and floating population, demanding the cessation of
spraying, or come to agreements on conditions for crop substitution, in addition to

claims to the national government for investments in health, housing, electrification,
schools, among others, given the socioeconomic reality of these regions.

Thus, Colombian state policy adopted a differential nature toward illicit crops,

according to their nature and purpose, that is, type or category. For industrial

316 Annex 33

crops, it arranged for forced eradication through aerial spraying of glyphosate, and
for crops in marginal rural and indi genous economy, manual eradication and the

alternative development strategy (PNDA) was decided. (see Chart No 3.7).

Given that the Program for the Eradication of Illicit Crops has been seriously
questioned by some sectors of the national and international community,

Resolution 005 of 2000 was issued, amending Resolution 001 of 1994, defining
more precisely the areas of exclusion and hiring a Technical Audit to evaluate not
only the technical and operational aspects of the Program but also the

environmental impacts on human health and agricultural activities.

CHART 3.7

ESTIMATE OF ERADICATION OF ILLICIT CROPS BY METHOD

NATIONAL TOTAL (1999-2000)

YEAR COCA (HA) POPPY (HA)

AERIAL MANUAL AERIAL MANUAL

1999 43,111.95 1,045 8,247.61 174

2000 58,073.10 3,500.28 9,254.4 74.61

According to the Verification Protocol, the actual death rate calculated based on
the aerial spraying conducted by the CNP antinarcotics is 95% for poppy crops and

90% for coca.

Source: Anti-Narcotics Police, Armed Forces, Administrative Security Department
and CTI of the Attorney General’s Office. The Armed Forces completed eradication

efforts using manual methods.

317Annex 33

3.2.4.2. Poppy

The subsistence farmers took to illicit crops because they considered them a form
of profitable productivity for the marginal agricultural regions, such as the regions

of Tolima, southwest and eastern Cauca.

The vast majority of poppy crops are located between 2,200 and 2,800 meters
above sea level in rugged areas within the fog forest belt near the paramos,

occupied largely by subsistence crops and pastures, where institutional presence
is not active. The areas where these crops have been recorded are characterized

by a lack of access roads and low coverage of state services (colonization fronts).
They have generally been isolated regions, often sparsely populated, located on
subsistence farmer or indigenous settlements belts.

In 1989 the first seizures of poppy derivatives with 130,000 grams of heroin were
recorded, a figure that established a change in the trend of illicit crops in the
country. What was initially perceived as a replacement of coca by poppy was

subsequently confirmed as a diversification of illicit crops.

In 1991, 2,900 hectares of poppy were identified, with the highest concentrations in
the provinces of Cauca, Huila, Tolima and Santander, which meant 83% of the

total; by 1992 the increase of the cultivated area was noteworthy and estimating
20,000 hectares were estimated; of these, 12,864 hectares were eradicated,
12
representing about 64%.

In recent years poppy crop hectares have decreased. Between 1998 and 1999,
poppy cultivation remained on average close to the 6,900 hectares planted, with a

potential production of opium paste of 66 tons and 6.6 tons of heroin. The
concentration areas of the crops were in the provinces of Huila, Cauca, Tolima and

the Serrania del Perija (Cesar, La Guajira) (see Figure No 3.3)

In 1999 a total of 8,249 hectares were sprayed, 67.3% took place in the province of
Tolima, 17% in Huila, and 10% in Cauca. In 2000, 9,254 acres of poppy were

sprayed, especially in the provinces of Tolima and Huila.

                                                            
1 The figures for illicit crop spraying correspond to those recorded by the Anti‐Narcotics Police. 

318 Annex 33

POPPY CROP ESTIMATES

Source: Anti-Narcotics Police

Figure No 3.3

Major areas of poppy cultivation

3.2.5. Environmental deterioration due to illicit crops: environmental
framework of the PECIG

3.2.5.1. The conditions of Colombia

319Annex 33

13
According to a recent study , Colombia is considered one of the least known
American countries in matters of flora. It has been estimated that it possesses
between 45,000 and 55,000 species of plants, representing about 16% of the

plants found on the planet. This wealth is evidenced, for example, if compared to
the 55,000 species that Brazil has in an area 6.5 times greater. Only in the

Reserva Planada (Nariño) Orejuela (1987) described 227 different orchid species
in an area spanning merely five square miles. The country has about 3,500 species
of orchids representing about 15% of world total. Other groups in Colombia that are

representative worldwide for their divers ity are the palms, anthuriums, ferns and
bromeliads. In the animal kingdom, the country’s diversity is world-renowned. The

27 species of primates described represen t a third of the primates in tropical
America. Another group well represented is that of the tapirs, because only

Colombia and Ecuador possess the three American species. In birds, 1721 species
have been reported which means about 20% of the world total. In reptiles 205
species of lizards have been reported and it is believed that there are still species

to be described. As for amphibians, the inventory is far from finished; in 1985 it was
estimated that frogs and toads in the country amounted to 430 species. The total

number of reptiles, birds, amphibians and mammals yiel14 a total diversity of 3,389
species, of which about 1,570 are endemic (42%) , In relation to fish still very little
is known about the national inventory. It would be endless to describe the

biological wealth of the country, in particular when taking into account the
arthropods and lower species, which today more than ever have become important

from a biotechnology standpoint.

On the other hand, in Colombia two hotspots (Priority Land Eco-regions) are the

world’s center stage, namely, the Tropical Andes and Chocó. Therefore it is not
exaggerated to say that on average one in ten species of plants and animals exist
within the boundaries of the Republic of Colombia, in an area not exceeding 0.77%

of the world’s land (McNeely et al., 1990).

In assessing the wealth described above, we can say that Colombian society still

does not perceive the ecological damage caused by the cultivation of illicit crops
and related activities. These activities directly affect the ecosystems considered

“humanity’s genetic offer.” The purpose of this process is to induce change from
passive to active attitudes, to allow expansion of the knowledge on the subject and

                                                            
1 Cultivos ilícitos e impacto ambiental, DNE, 2000. En Inventario Florístico de los Países Tropicales. DG. 
Campbell and H. D. HAMMOND. 1985. 
1 Cortes, L.M., Biodiversity at Risk. Weather‐Sunday Readings. October 1, 2000. 

320 Annex 33

engage institutions and the general population, since it is an issue that involves

and engages all Colombians, in particular, and the international community, in
general.

3.2.5.2. The impact of illicit crops as a component of the PECIG baselines

A conversation piece has always been the environmental problem caused by the

eradication of illicit crops through aerial spraying with the herbicide glyphosate
conducted by the Antinarcotics Police. Usually the negative effects caused by the
other activities related to illicit drug indus try are not mentioned. It is possible that

the above is a result of defense mechanisms used by the organized groups
engaged in this activity .5

It has been known for long that any human activity within these ecosystems
significantly affects the environment negatively, including, obviously, aerial

eradication. However, if an environmental cost-benefit analysis is conducted, the
conclusion is that, within the activities related to the total process of production-
traffic, the effect of the spraying is minimal.

For nearly three decades activities related to illicit cultivation of marijuana, coca
and poppy crops have been developed, and thus has been established the

processing and trafficking of narcotic subst ances from these plants. Therefore, in
order to evaluate the environmental impact of the illicit drug production on the
environment, it is necessary to identify the sequential stages of the process. First

comes the selection of the areas in which the crops are intended to be established;
then these areas should be made suitable for planting, later comes the

construction of facilities for processing the leaf and the extraction of the drug, the
adapting of the “warehouses” to store chemicals and, in some cases, the
construction of runways for traffic.

In addition to the stages mentioned related to the production processes, it is
important not to forget that the first impact on the environment is caused by the

                                                            
1 From a purely biological perspective, it is clear that the damage on forests and was caused from the time 
they are done logging, burning and disposal of substances into water sources. 

321Annex 33

strong population migration to these areas that do not satisfy their basic needs,
considering that they are forest reserve regions. The first to arrive are the primary

settlers (itinerant, in charge of trailblazing). Then come the secondary settlers, who
buy land from the primary and start developing the crops, either with their own
resources or financed by large investors. In times of harvest, hosts of coca leaf

pickers (raspachines) arrive, with the consequent emergence of informal traders,
prostitutes, processors and buyers of the base, sellers of chemicals, etc. These
immigration processes, rather than becoming factors of development for the

regions, have had harmful effects to the deterioration of the ecosystems. This
stage is where the PECIG must act.

Illicit crops in Colombia are located in strategically selected areas that meet certain

requirements essential for them, namely:

• Geographical areas isolated from urban centers, where state presence is
hampered by the lack of access roads and the presence of extensive forest
areas, especially in the provinces of Caquetá, Guaviare, Meta, Vichada,
Putumayo, Santander and Guainía.

• Presence of abundant water bodies that allow its use in processing, waste
disposal and food preparation. On the other hand, the presence of navigable
rivers facilitates the introduction of chemicals through open smuggling from
neighboring countries and the output of large volumes of finished product.

• In Colombia, some of the areas of coca and cocaine production are located
in the upper valleys of Apaporis and Caqueta, which is known as Japurá in
Brazil, and also in the valleys of the upper Vaupes and Putumayo, known as
Iça in Brazil.

• Although less frequent, ecosystems with abundant plant biomass, which
obstruct the location of the crops, jungle crops (chagras), laboratories and
warehouses for chemicals

• Ecosystems that are adapted to the climatic requirements of the varieties of

plants that they wish to grow. In this sense, Colombia has thermal floors that
ensure excellent development of the species used for the extraction of
psychotropic substances.

322 Annex 33

• Areas with the presence of armed groups, which impede the action of the
authorities and which, it seems, offer security services to the crops and
processing complexes.

In evaluating the selected areas, traffickers have basically selected

environmentally sensitive ecosystems as well as environmental important , such as
the Andean and high Andean forests for poppy and the plains and jungles of the

Orinoco area and Amazon area for the cultivation of coca.

According to IDEAM, Andean forests occupy only 8% of the national territory 16.

This low percentage is explained by the strong human pressure to which they have
been exposed since the days of the colony, to establish pastures and different

types of crops. The most important of which is still, coffee.

On the other hand, the Amazon basin, chosen to introduce the cultivation of coca,

has a vital ecological importance for its ability to regulate CO2 and to keep the
balance of emissions into the atmosphere. In addition, the Orinoco-Amazon area

represents for humanity, and especially for Colombia, an environmental supply
17
bank characterized by high biodiversity.

Overall, illicit cultivation of both coca and poppy have been implanted in

ecosystems of incalculable environmental value characterized as being the largest
germplasm banks in the world, that is, wi th the presence of biotic communities
18
(fauna and flora) which in many cases are unique and exclusive to these regions .

                                                            
1 The main feature of Andean and high Andean forests is the “water production”, the rising air, saturated 
with water vapor, which comes from lower regions, humid and warm condenses to produce clouds regularly 

17d enveloping fog, and a high rain rate. 
 Biological diversity or biodiversity refers to the variety within the living world. As multifaceted expression 
of life, it presents different levels of complexity, from genetic variability of populations, the multiplicity of 
species, to the diversity of ecosystems and landscapes. These levels are closely related so that the 
interactions between these are both spatially and functionally dependent. (Research Institute of Biological 

Resources Alexander van Humboldt). A simpler definition is provided by Solbrig (1991): a property 
demonstrated by living things to be varied, in each of the hierarchical levels of organization of biological 
nature, from molecules to ecosystems. 
The stifling and humid tropical regions are those with the highest rates of successful mutations and 
recombinations; a much more dynamic evolutionary process resulting in a higher rate of biodiversity than 

other regions in the world. (Urruela, undated). 
RAFI (International Environmental NGO) estimates that medicinal plants and microorganisms from the South 
contribute at least 30 billion dollars a year to the pharmaceutical industry of industrialized countries. 
1 Colombia has a continental area of 114,174,800 ha, representing approximately 0.7% of the global land 
surface. In this area is 10% of the world’s biodiversity, making Colombia a “mega‐diverse” country. 

323Annex 33

Growing areas that are not in areas of high environmental value are located in
19
biomes that can be classified as focus areas, where a policy to prevent the
destruction of ecosystems and control over exploitation of species in critical state

or very vulnerable should be promoted.

Most Amazon area soils are suitable for forestry, which is why usual traditional
agricultural practices fail, thus contributing to the deterioration of the dynamics of

the region.

Finally, with the population immigration, a second migration of higher wildlife flocks
to deeper areas of the forests, with the resulting imbalance in food chains and

ecological niches. In the case of the A ndean forests, the effect is more serious
because of the specificity of the ecosystems and the high concentration of endemic

species. In this regard it is important to note that the tropical Andes contains
between 30,000 and 40,000 plant species, a figure greater than estimated for the
Amazon Basin, which is why this biogeographic area is considered to have the

greatest diversity of species in the Neotropics.

3.2.5.3. Site preparation

The first and most obvious action for the cultivation of a crop is the clearing of

native vegetation, which in most cases consists of primary forests, where human
activity had never existed, or secondary forests in different successional stages.

The most common method to eradicate forests is by logging and/or burning,
actions that exert drastic effects on ecosystems, among which are the following:

• Destruction of ecological niches and food chains
• Destruction of unknown genetic potential
• Soil erosion

• Destruction of native vegetation cover
• Changes in rainfall patterns and local climate
• Significant increase in CO e2issions
• Disappearance of scenic beauty and landscape

• Extinction of endemic species
• Deterioration of water sources

                                                            
1 Zones located in the interior of the Colombian Amazon area between the Caquetá, Putumayo, Vaupés 
rivers and portions of Guainia and Vichada and part of the Andean and sub‐Andean forests of the cordillera 
Occidental. 

324 Annex 33

According to studies conducted in recent years it has been established that to
implement one hectare of coca, growers have to destroy four (4) hectares of forest
16
and for one of poppy two and a half (2.5) of Andean forest (Chart No 3.8 and
3.9), in cases where cultivation starts on forest area. Photo 1 shows a recent
deforestation in the Andean forest to im plement poppy crops. Th is is because, in

addition to land needed for the illicit cultivation, the farmer or settler fells for the
planting of staple crops and for the preparation of pasture for some animals. Here,

the farmer makes no investment in fertilizer and pesticides, as he does in the illicit
cultivation, so those crops and pastures have very low yields, which is

compensated by deforesting a larger area. Moreover, in cases of illicit crops
developed in colonization fronts of the Amazon area and Cauca-Nariño where high
rainfall makes the soil’s natural nutrients and those added to leach rapidly, farmers

cut down yet more forest to increasingly take advantage of the nutrients that are
released in the soil after burning, which provides a first crop with high yields.

On the other hand, the burning of forests and jungles means the destruction of 380
tons of biomass per hectare, which entails a cumulative total of 152 million tons of
biomass which turn to ashes, CO and sediments . 20
2

The destruction of these ecosystems severe ly alters the ecological homeostasis,
which in the case of the Amazon area is defined by the unique floristic diversity on

the planet–between 96 and 120 tree species per hectare–, an unknown number of
minor species, and the microflora and microfauna with incalculable genetic

potential (Parra, 1998)

CHART 3.8
ESTIMATES OF FOREST AREA DESTROYED BY
THE ACTION OF ILLICIT POPPY CROP

(Period 1990-2000)

YEAR ESTIMATED CROP ESTIMATED AREA
1
AREA (ha) OF DESTROYED
FOREST (ha) 2

1990 1,500 3,750

20                                                          
  This  number  is  based  on  the  studies  performed  by  the  Environmental  Audit,  National  Narcotics 
Directorate. 

325Annex 33

1991 2,900 7,250

1992 20,000 50,000

1993 7,500 59,375

1994 6,800 3 67,875

3
1995 2,180 70,600
3
1996 2,100 73,225

1997 2,2003 75,975

3
1998 2,033 78,516

1999 6,500 3 86,641

3
2000 6,200 94,391

Source: U.S. State Department, Antinarcotics Police,
Environmental Audit, Epam Ltda.- Ltda Edema

1
An estimated 2.5 ha of forest destroyed to establish 1 ha of
poppy crop

2
The figures for estimated area of forest destroyed are
presented in aggregate form.

3 It is estimated that 50% of the cultivated area are new crops.

CHART 3.9

ESTIMATES FOR DESTROYED FOREST AREA BY

THE ACTION OF ILLICIT COCA CROPS

(PERIOD 1987-2000)

YEAR ESTIMATED CROP ESTIMATED AREA
AREA (ha) 1 OF DESTROYED
FOREST (ha) 2

1987 25,600 102,400

326 Annex 33

1988 34,000 136,000

1989 42,400 169,600

1990 40,100 178 ,800

1991 37,500 178,800

1992 37,100 178,800

1993 39,700 178,800

1994 45,000 198,400

1995 50,900

1996 67,200 287,200

1997 79,500 336,400

1998 101,800 425 ,600

1999 160,119 658,876

2000 163,289 671,556

Source: U.S. State Department, CIA/CNC, Policia
AntmarcotlcüS, Environmental Audit, Epam Ltda.- Ltda
Edema

1
An estimated 4 ha of forest destroyed to establish 1 ha of
poppy crop

2 The figures for estimated area of forest destroyed are

presented in aggregate form. This effect of border and
collateral damage occurred in 1994.

It is estimated that burning one hectare of forest destroys 140 m3 of wood, of
which 30% is potentially commercial and 80% of these tree species only exist in
21
the Amazon ecosystem.

                                                            
2 PARRA, L.E., Impacto Ambiental de los Cultivos Ilícitos en Colombia. COLOQUIO, issue 3, March 1977. 

327Annex 33

The above means that there is a scenario prio r to the cultivation of coca or poppy,
formed by colonization of areas of the humid and very humid tropical forest and
high Andean forest. This colonization in some cases is already well established

and which is usually characterized by socioeconomic conditions of poverty and
depression. After this comes another scenario, comprised by the entry of illicit

crops, which, supported on the low levels of income of the population, become an
option for survival for many colonists, farmers and indigenous peoples. It is in this
latter scenario, then, where it is the responsibility of PECIG to act, as noted above,

because it is where the illicit crops are.

Effects related to the suitability of land fo r crops not only determine the irreversible

loss of native flora and genetic resources, but they also generate side effects such
as fragmentation, displacement of wildlife and the severe disruption of food chains.

Erosion is another serious effect produced by the adapting of the land for planting
of coca and poppy, because in both cases the soils of selected ecosystems are

characterized by high susceptibility to erosion, either by high rainfall or the steep
slope, or both factors at once, etc. 22As a result of deforestation, especially on the

slopes of the Andes, it is common for huge landslides to occur including runoff
causing siltation of stream beds (a proc ess known as sedimentation), leading to
flooding in times of rain and severe drought in the summertime. Photos 2, 4 and 5

show examples of the eros ion caused by deforestation due to the implantation of
illicit crops.

Given that Colombia ranks fifth worldwide in water resources, which in the case of
the Andean forest are represented by about 720,000 watersheds, it can de noted

that the effects of logging and burning are exerting undue pressure on this
resource.

3.2.5.4. Cultivation of the crops

                                                            
22 The wider community has the idea that the soils in the south of the country’s forests are highly 
productive, however they are highly fragile soils with large concentrations of aluminum and easily washed 
when the native vegetation cover is removed. 

328 Annex 33

After completing the logging and burning of forests, following is the cultivation of
the crop, that is, agricultural processes inherent in the planting, tending and

harvesting of the crops. It is at this stage that chemicals gain23ntry to the
environment, not only to industrial crops, but also to small plots.

Photo No. 1

Forest clearing for the planting of illicit crops.

Note the steep slopes and the onset of localized
phenomena of erosion by superficial landslides.
These soils, due to the slope, are not suitable for

farming,

The poppy and coca crops are characterized by demand for space and nutrients,

which means they are not easily joinable, making it necessary to eliminate the
competition. Coca growers, whether they are farmers or middlemen, aim to get the

most production possible from the leaf (biomass). For this and due to the low soil
fertility, it is common to introduce bio-stimulants, fertilizers and pesticides to control

pests and weeds.

23                                                          
 According to the SIMCI Project (DNE‐ANTI‐NARCOTICS POLICE‐UNDP), in Colombia 40% of cultivated coca 
plots are classified as subsistence farmers and the remaining 60% are classified as industrial. 

329Annex 33

The containers of pesticides (herbicides , fungicides, etc.) and fertilizers used on

crops are disposed of anywhere in the ecosystem. In many cases, producers use
substances that are prohibited, as is the case of the insecticide Parathion and
24
organochlorine substances. The containers and waste of a wide range of
biocides introduced to the environment and used at the highest possible

concentrations and amounts inevitably end up in waterways, adsorbed on soil
particles and, at worst, assimilated into food chains. At this point the pressure on

the environment is not only confined to the area of cultivation, but it is exported to
the entire ecosystem.

The introduction of agro-chemicals on the crops of farmers or of the industrialist

extends invariably into the total cultivated plots.

A report prepared for the National Drugs and Narcotics Affairs Section of the
25
Embassy of United States found that 98.7% of growers uses insecticides and
fungicides to control pests and diseases, 92.5% uses chemical fertilizers, and

95.5% controls the competition from other plants with herbicides. On the other
hand, a SINCHI Institute research 26 shows that farmers, contrary to what they used

to do with their own staple crops production, strive to do cultural work on their coca
and poppy crops, and they habitually weed, and chemically control insects and

pests.

SINCHI notes that the economic logic of these dissimilar behaviors is that while in
the staple crops the aim is to maximize the natural fertility of the soil, in the

cultivation of coca, due to revenue expectations, the producer is forced to
incorporate chemical technology.

Two methods are commonly used to keep the coca crops clean and thus obtain a
high biomass production. The first is the use of hoe, which requires an average of

ten days’ work and the second is the ap plication of Gramoxone every 2 or 3
months. Since coca is a crop that relies intensely on chemical technology, the

purchase of these products takes over more than two-fifths of the total costs of
inputs.

24                                                          
 Some of the agrochemicals reported to the DNE by authorities are: Gramoxone, Crecifol, Furadan, 
Tamaron, Tordon, Roundup (this is Glyphosate proper), Faena 323, Desarrollo, Babistem, Agrotin, 
Malathion, Parathion, Benlate, Manzate, Nutrifolia, etc. 
25 URIBE, S., Proyecto sobre rendimientos de las plantaciones de coca en Colombia. Informe de Progreso # 5. 
October 25, 1999 
26
 ARCILA, N.O., RODRIGUEZ, S. A. Estudio de Caso de la Producción de Coca en el Departamento del 
Guaviare. INSTITUTO AMAZONICO DE INVESTIGACIONES CIENTÍFICAS SINCHI. Area de Asentamientos 
Humanos, Santa Fe de Bogotá, September 1997 

330 Annex 33

There are no significant differences among the producers of the coca-growing
regions regarding the intensity of the use of agro chemicals, regardless of whether
it is the case of small farmers or industri al type crops. In this sense, URIBE (1999)

establishes the use of at least 75 differe nt brands of agrochemicals (see the most
common in Charts 3.10 and 3.11). The regional difference in the type of substance

used is determined by its availability in the market, since many of these come in
through open smuggling directly to the farmland.

CHART 3.10

HERBICIDES USED IN COCA PLANTATIONS

Trade name Active % of Toxicity

Ingredient use Classification
27
Gramoxone Paraquat 61,3 II DL Oral: 150 mg/kg

Faena Glyphosate 10,7 IV DL Oral: 4300

mg/kg

Anikilamina 2,4D 9,7 I DL Oral: 699 mg/kg

Round up Glyphosate 8,4 IV DL Oral: 4300

mg/kg

Atrazina Atrazine 4,8 III DL Oral: 1780
mg/kg

Karmex Diuron 2,6 III DL Oral: 5000
mg/kg

Otros n.a 2,6

URIBE, S., Proyecto sobre rendimientos de las plantaciones de
coca en Colombia. Informe de Progreso # 5. October 25, 1999

                                                            
2 It is among the pesticides considered worldwide as the “Dirty Dozen” whose use is banned in some 

industrialized countries, but is widely used in agricultural countries in the developing world. In addition to 
Paraquat, the use of Lindano is common for control of lice and scabies; pentachlorophenol is used as a 
fungicide in wood and powerful biocide Parathion’s action ranges from pest control in staple crops, to the 
extermination of insects. 

331Annex 33

Interestingly, among the substances most commonly used by growers of illicit

crops is glyphosate (about 20%). And ye t, when this substance is used by the
authorities to eradicate the crops, these farmers and producers who use it often
feel they are being harmed due to the product’s dangerousness.

The number and variety of pesticides (ins ecticides and fungicides) is greater than
the herbicide offer and the use of substances with high toxicity is notorious, which
is increased if considered that many farmers still follow the assumption that “the

more quantity and concentration of the agrochemical, greater its effectiveness,”
which is why it is common that the dosag es used are not consistent with those
recommended by the manufacturers. In addition, the substances most frequently

used are classified with a high degree of toxicity, so it is expected that the effect on
these special ecosystems and communities is quite negative.

On the other hand, the soils of the Andean forest, characterized by their great
capacity to suppress pathogens are losing th is feature, since the chemicals used

are broad spectrum.

Agrochemical substances that illicit grow ers introduce daily to ecosystems, cause
among others, the following effects on the ecosystems:

332 Annex 33

Photo No. 2

Area of clean crops and pastures on the Andean

floor.

Note the presence of small patches of forest in
the valleys and low stubble. Illicit crops are

located and rotated in any of the open plots.

333Annex 33

Photo No. 3

Foothills of the Serrania de San Lucas in
southern Bolivar. Note that the original forest
vegetation has practically disappeared and it is

only visible along some streams. Under these
conditions, illicit crops grow in areas with a high
degree of established colonization.

• Pollution of resources: pesticides are capable of contaminating drinking
water sources for humans and animals, water sources, rivers and seas. The
agrochemicals can reach water sources by some of the following means:

• Percolation or leaching of pesticides applied on the soil surface

• Discharge of remaining application liquids and waste of empty
containers
• Flood or overflow of rivers that reach the storage sites

CHART 3.11

INSECTICIDES AND FUNGICIDES USED IN ILLICIT CROPS

PRODUCT # OF ACTIVE CONCENTR TOXICIT ACTION
PRODUCE ATION Y
NAME INGREDIENT
RS USING CATEGO
IT/244 RY

(in %)

Manzate 87 Mancozeb 80% III Fungicide

334 Annex 33

Tamaron 73 Methamidophos 600/lt I Insecticid
e

Sevin 59 Carbaryl 80% II Insecticid
e

Metavin 29 Methomyl 90% I Insecticid

e

Furadan 28 Carbofuran 330 g/lt I Insecticid
Liquid e
Granulated Carbofuran

Curacron 20 Profenofos 500 g/lt II Insecticid
e

Thionil 20 Endosulfan 350 g/lt I Insecticid

e

Oxocloruro 19 Copper oxide 35% III Fungicide
de cobre

Parathion 19 Methyl Parathion 48% I Insecticid

e

Matador 10 Lambda 50 g/lt III Insecticid
Cyhalothrin e

Thiodan 10 Endosulfan 350 g/lt I Insecticid

e

Bavistin 7 Carbendazim 50% III Fungicide

Malathion 6 Malathion 604 g/lt III Insecticid

e

Nuvacron 6 Monocrotophos 600 g/lt I Insecticid
e

Lorsband 5 Chlorpyrifos and 500 g/lt II Insecticid

Liquido Cypermethrin e
Granulado 50 g/lt
Chlorpyrifos
50/kg

335Annex 33

Comboy 5 Cypermethrin 25 g/lt III Insecticid
and Diazinon e
200 g/lt

Politrin 5 Cypermethrin 200 g/lt II Insecticid

e

Others 61

URIBE, S., Proyecto sobre rendimientos de las plantaciones de coca en Colombia.
Informe de Progreso # 5. October 25, 1999

The consequences of this pollution are associated with loss of aquatic fauna and
flora, loss of water and food sources and human and animal poisoning . 28

• Soil Pollution: Some pesticides are applied directly on the ground
(herbicides such as 2,4 D and insecticides such as methomyl). There are
others that achieve this indirectly through dripping from the plant, poured

from the application equipment, dragged by raindrops (in the case of
Chlordane, Parathion), washing of application equipment, waste of
containers, etc.

• According to the chemical composition, once in the soil they can be
adsorbed on clay particles or organic matter (Methomyl). Others, however,
are easily flushed by the water flow. While the first seriously affect the soil,
its fauna and flora, the latter contaminate water sources.

• The soil microfauna and microflora, responsible for recycling organic matter,
are severely affected by pesticides applied directly to soil, thereby

decreasing the supply of soil nutrients, making it dependent on nutri29ts, so
that it becomes even more vulnerable to insects and pathogens .

• Persistence in food chains. Insecticides with chemical structure of the

chlorinated types (DDT, chlordane, Heptachlor), which are banned in
                                                            
28
 Many of the complaints that growers associate with the aerial spraying with glyphosate conducted by the 
DIRAN are due to the use of chemicals such as Paraquat and Parathion, which farmers use on crops without 
any technical standard and unprotected. Many of these chemicals are fat soluble, allowing them to be 
absorbed through the tissues and then accumulate in the body, with the consequent intoxication, which in 
many cases and depending on the toxicological classification of the product may be fatal. 
2 Casadinho, J.S., Plaguicidas y Salud: una relación poco conocida. CETAAR ‐ Faculty of Agronomy ‐ UBA. 

336 Annex 33

Colombia, have the ability to bind to animal fat. This feature is hazardous for

the following reasons: a) accumulation in food chains from herbivores to
carnivores of second and third order, reaching concentrations that cause
physiological damage. When people living in regions where these
substances are used in large numbers feed on the fauna of the region, the
pesticide molecule concentration levels increase within the body, as they

are not metabolized, to reach poisoni ng levels (a phenomenon known as
biological magnification).

• Action on beneficial insects and vegetation. Within the ecosystems a large

number of insects, mites and vegetation plays a fundamental role in the
balance of biomes and food chains. Among their functions are:

• Predators parasites of insect-pests: many mites and insects act as

micro-parasites of other insects that could become pests of established
crops or even of primary forests
• Incorporators of nitrogen
• Soil fasteners (reducing the potential for erosion)

• Soil coverers (wide-leaved plants)
• Decomposers of organic matter: multi-layer forests are characterized by
high activity of decomposition of organic matter when the soils are
agriculturally poor.

• Plants that act as insect traps

It is possible that in regions where illic it crops are currently being developed the

beneficial effects of these organisms may be detected only when they have
disappeared and their natural enemies are free to act, with greater reproduction
rates (causing plague effect) with t he consequent need to introduce stronger
30
pesticides

                                                            
3 It is logical that once the natural balance of ecosystems is destabilized with the introduction of pesticides, 
effects of tolerance and resistance are generated which determine, therefore, the introduction of stronger 
and more harmful substances to the ecosystems. Vicious circle effect. 

337Annex 33

Photo No. 4 A

Burning and felling for planting illicit crops. Note the
original forest and the stream receiving the sediment
from erosion of the removed slopes.

Photo No. 4 B

Coca crops in the river banks. Erosion and the pesticides
used on crops affect the water quality of these

ecosystems.

338 Annex 33

Photo No. 5 A

Plot recently cleared for illicit crops. Note the onset of
the erosion phenomena due to terrain gradient.

Photo No. 5 B

Coca cultivation in Caquetá. Along the river there is a
processing laboratory. The final destination of many
chemicals substances will be the river.

• Waste containers and residual products . In areas of illicit crops, farmers
usually discard pesticide containers, surplus product, remnants of spraying
processes, and the remnants left in the spraying equipment after washing,
into the environment (soil and water sources, incineration, etc.). This

339Annex 33

process is most used when the plots are near rivers or streams, as
illustrated in photo No. 4 A, 4 B and 5 B.

Each of these cases represents a specific problem, but in general they can
potentially grow to contaminate directly or indirectly the environment,

including in the communities that inhabit it:

• Disposal of packaging: Many containers are recycled for use as tools for
31
daily chores and food preparation.

• Accumulation in wells: the population in rural areas of the country is

accustomed to digging wells near homes where they deposit the waste
generated. Unfortunately, the wastes are not classified and all types of
materials are deposited in wells, whether they are biodegradable, toxic or
otherwise.

• Open burning: it can cause greater harm that the mere accumulation.
Some products, when exposed to heat, emit dioxins and furans, whose

toxic power is vaster than the initial product.

Taking into account that in the cultivation of a coca crop producers generally use 6

gallons of Paraquat (Gramoxone) for the first harvest and one gallon over the next
two harvests; 2 liters of dinitroaniline (Waxal) in each harvest; 240 cm3 of

carbamates (Furadan) in each of the three crops the first year, 12 kg urea and 12
kg triple 15 (chemical fertilizer), one can infer that in coca cultivation surveyed
between 1999 and 2000 the quantities of agrochemicals referred to in Chart 3.12

were used.

Because the area established in 1998 is not taken into account by the difference in
methodologies used to determine the areas, the amount of chemicals calculated

for both years and especially for 1999 is lower than what was actually used.

                                                            
3If glass containers are generally used for the collection of fluid (in some regions it was found that farmers use the
Gramoxone containers to carry their fermented juice), kerosene or water; if they are metal, they are used for heating and
storing water and if they are aluminum they are used as pots in the base a d refining laboratories.

340 Annex 33

These calculations were estimated on t he basis of focused studies that have been

made in the crop areas (SINCHI). However, there are no estimates made with
previously established statistical models.

CHART 3.12

ESTIMATES OF THE USE OF AGROCHEMICALS

(between 1999 and 2000)

AGROCHEMICAL 1999 2000 Total

Paraquat 32 640,476 653,156 1,293,632

(gallons)

Dinitroaniline* lt 1280,952 1,306,312 2,587,264

Carbamate*lt 153,714 156,757 310,47l

Urea kg 1,280,952 1,306,312 2,587,264

Triple 15 kg 2,561,904 2,612,624 5,174,528

DNE III-2000

3.3. ENVIRONMENTAL ZONING

3.3.1. General conclusion

Based on the above we can conclude the following:

                                                            
3 According to Uribe, 1999, SINCHI 1997 and state security agencies, the most used are Paraquat, Wax up 
and Furadan, in that  rder.

341Annex 33

• PECIG scenario. The real scenario of the Program for the Eradication of
Illicit Crops by Aerial Spraying with Glyphosate-PECIG is a highly involved

ecosystem by the historical and current action of man. Even in some areas it
is a totally transformed ecosystem c haracterized by grasslands and crops,
as in much of southern Bolivar, Caqueta foothills, the Serrania del Perija, or
the cold areas of Huila and Tolima cultivated in poppy, where it is grown
intercropped with other lawful clean crops. The primary forest in the Amazon
area, the Pacific plain or the high Andes belt are therefore not PECIG

scenario.

• Impact of illicit crops . Illicit crops, upon entering an area, destroy native
forests and generate serious environmental impact, expressed in biomass
and biodiversity loss, erosion, water pollution, intensive use of pesticides,
population migration and the change of cultural patterns of the native

population, indigenous or subsistence farmer. The environmental and social
impact generated by illicit crops, already existing, is the other side of the
PECIG scenario of action, that is, its baseline.

• Control of existing impact. In this context, upon pursuing the elimination of

illicit crops, the aim of PECIG is the elimination of one of the most
important–if not the worst–factors of environmental and social degradation
suffered by the country today. It is in this dimension that the program should
be seen. It follows the impacts generated by drug trafficking; it does not go
ahead, as has been the intent to portray.

3.3.2. Criteria of environmental zoning for spraying

Since this is a management plan framewor k at the national level, designed so it
can be applied anywhere in the country where it is necessary to eradicate current

or future illicit crops by aerial spraying with glyphosate, it is not possible at this
level of the management plan to adopt an environmental zoning plan for the
development of PECIG in each of the sector s, properties or plots where they are,

as would be the case for a development project or work, because, by political
decision of the National Government, eradication by aerial spraying with
glyphosate should be done where industrial crops are located.

342 Annex 33

However, it is important to have criteria to guide the commander of the base and
the personnel involved in the planning stages of each spraying operation (detection

and operational planning phases described in C hapter 2) to select the areas to try
and establish the exclusion zones. These crit eria, in principle, should be given in
Chart No 3.13. For this purpose, the following definitions are adopted:

• Ecologically fragile areas. For the purposes of the Program, these are the
areas that contain flora or fauna val ues of national importance, such as
endemic species of native flora and fauna. This applies, in particular, to
areas of the National Parks System.

• Culturally fragile areas. These are the areas with presence of indigenous
peoples or communities with their current language, customs and traditions,
which have not experienced the total impact of acculturation by colonization,
whereby the intervention could lead to the extinction of the people or
community as a nation. They include also indigenous cemeteries and other

areas with remnants of extinct cult ures, archaeological or historical
monuments or otherwise. In the PECIG area of action it is only possible to
identify indigenous settlements.

• Environmentally sensitive areas. These are the areas that contain
particularly valuable vegetation and native fauna, water bodies, special

geomorphological values, soils of high agricultural potential or the like,
whose intervention could lead to their deterioration, so it is necessary to
adopt appropriate control measures. Th is wealth, however, can be found in
other parts of the country or region. The PECIG area works especially with
areas of native forest and water bodies.

• Socially sensitive areas. These are the areas that contain special richness of
social or cultural nature, such as agglomerated settlements (villages, towns,
cities), high-density rural settlements or the like, whose intervention could
lead to a deterioration of living conditions of its population. This wealth,
however, may be found in other parts of the country or region.

• Economically sensitive areas. These are the areas that contain special
significance of an economic nature, such as roads, airports, river or
maritime ports, regulation reservoirs for different uses of water, watering and
drainage districts, industrial areas, mines, rural commercial or institutional
centers and the like, which intervention could lead to a deterioration of the

343Annex 33

same. This wealth, however, can be found in other parts of the country or
region.

In detail, different categories of sensitivity could be established, depending on the
significance of the resource. All fragileeas are sensitive, but not all sensitive
areas are fragile.

Consistent with this, in the detection and characterization stages before each

spraying operation, it is necessary thathe technical team of the base, with the
help of satellite images, maps or aeriaphotographs, identify the presence of the
above types of areas or elements, georeference them and integrate them into

SATLOC system, so that in the course of the operation, the system alerts the pilot
of the proximity of such areas, to avoid spraying and thus respect their buffer
strips.

CHART 3.13

CRITERIA FOR DETAILED ENVIRONMENTAL ZONING IN AREAS OF
SPRAYING ILLICIT CROPS WITH GLYPHOSATE

ZONE TYPE ZONING FOR PECIG

ECOLOGICALLYFRAGILE Areas of the National Nature Parks
System

Indigenous reservations

CULTURALLY FRAGILE Archaeological parks

Historical monuments

ENVIRONMENTALL SENSITIVE Water bodies (rivers, streams,
wetlands)

Native forests

SOCIALS LENSITIVE Human settlement agglomerates
(villages, towns, cities)

Infrastructure works: roads, airports,

river and sea ports, dams and power

344 Annex 33

plants

Areas of Manual Eradication Pacts

PNDA Productive Project Areas

ECONOMICALLY SENSITIVE Irrigation and/or drainage districts

Industrial zones

Open pit mines in operation

Rural tourism and commercial
complexes

Rural institutional complexes

3.3.3. General zoning

Consistent with the above and taking into account the characteristics of the PECIG

areas of action, the aim is the zonal planning as indicated in Chart No 3.14, as a
framework for planning the spraying operations.

The goal is to standardize the buffer strips to 100 meters from the border of the

zone, according to the provisions of Decree 1843 of 1991 and adopt an alert strip
of 1,000 meters around the exclusion zone, within which SATLOC aircraft system
should notify the pilot of the presence of the same, in order to avoid spraying.

CHART 3.14
ENVIRONMENTAL ZONING FOR ERADICATION BY
AERIAL SPRAYING WITH GLYPHOSATE

ZONE TYPE DEFINITION MANAGEMENT
FEATURES

Areas of the National Nature Parks

System (PNN)

Human settlements (towns, villages

345Annex 33

and the like) Must not spray on them or
on the security zone of
Bodies of Water
100 meters.
Exclusion zones
Areas of socioeconomic interest

Areas with vegetation cover other Must not spray on them.
than illicit crops Pilot must open and close
the latch in illicit crop plot.

Illicit farmer crops Manual eradication. Must
not spray on them.

Restriction Strip around PNN 1,000 meter Alert strip

zones

Strip around Human settlements 1,000 meter Alert strip

Strip around perimeter of water 1,000 meter Alert strip
bodies

Strip around the areas of 1,000 meter Alert strip
socioeconomic interest

Intervention Areas occupied by industrial Illicit Spray with glyphosate
zones crops

Source: this study, DNE

346 Annex 33

Figure No. 3.4

IMAGES OF THE CAUCA-NARIÑO NUCLEUS

LEGEND SIMCI PROJECT

Coca crop

Landsat 7 Image

SPOT Image

347Annex 33

Figure No. 3.5

IMAGES OF THE SOUTH OF BOLIVAR NUCLEUS

LEGEND SIMCI PROJECT

Coca crop

Landsat 7 Image

SPOT Image

348 Annex 33

Figure No. 3.6

IMAGES OF THE BOYACA NUCLEUS

LEGEND SIMCI PROJECT

Coca crop

Landsat 7 Image

SPOT Image

349Annex 33

Figure No. 3.7

IMAGES OF THE CAUCA-NARIÑO NUCLEUS

LEGEND SIMCI PROJECT

Coca crop

Landsat 7 Image

SPOT Image

350 Annex 33

IMAGES GABARRA NUCLEUS

SIMCI PROJECT
FIGURE NO. 3.8

LEGEND

Coca crop

Landsat 7 Image

SPOT Image

351Annex 33

IMAGES GUAVIARE NUCLEUS

SIROIJECT
FIGURE NO. 3.9

LEGEND

Coca crop

Landsat 7 Image

SPOT Image

352 Annex 33

IMAGES SIERRA NEVADA NUCLEUS

SIMCI PROJECT

FIGURE NO. 3.10

LEGEND

Coca crop

Landsat 7 Image

SPOT Image

353Annex 33

IMAGES PUTUMAYO NUCLEUS

LEGEND SIMCI PROJECT FIGURE NO. 3.11

Coca crop

Landsat 7 Image

SPOT Image

354 Annex 33

[CHAPTER 4]

4. ENVIRONMENTAL IMPACT- RISK ASSESSMENT

4.1. GENERAL ASPECTS

4.1.1. Assessment Criteria

The concept of impact/risk

This part of the study is aimed at identifying, predicting and assessing the

importance of the program’s potential im pacts and to select the measures of
prevention, correction and compensation that are required in order to make it
environmentally viable.

However, given the nature of the program, which consists of the eradication of illicit
crops by aerial spraying of a herbicide which might affect, in addition to unlawful
crops, other types of natural or cultivated vegetation, and the health of humans and

animals who may be accidentally sprayed with the product, the task necessarily
and in fact includes an evaluation of risk, understood as being the probability that
the impact or adverse effect that might occur.

Therefore, for all purposes of this evaluation, the impact/risk of aerial spraying with
the herbicide glyphosate will be considered.

In Chapter 3, there was a synthetic presentation of the environmental impact

355Annex 33

generated by drug trafficking activities on ecosystems, which begin with the felling
of jungle on the Equator, in the Andes and in the high Andes, and ending with the

contamination of bodies of water and soils with residues and containers of
pesticides and herbicides disposed of without control, and the social and cultural
impact found in migration, the decomposition of society, adverse effects on

indigenous communities, and an increase in indicators of violence.

Therefore, the control of illicit crops which is one of the most important links in the
chain, will allow the impact generated by t he drug-trafficking industry as a whole to

be controlled and reduced. Evidently, the control of illicit crops by spraying with
glyphosate also has an environmental im pact, and its evaluation and control are
the main objectives of this Management Plan

Method of evaluation

Based on the knowledge the knowledge of environmental conditions and
characteristics of the program, this phase of evaluation seeks to answer four basic

questions:

• What changes occurred will occur as a result of the program? This is the
identification of impact/risk, or the determination of possible interactions
between the program and the environmental conditions of the area.

[Page 111]

• What will be the scope of the changes? This is the prediction of the
expected magnitude of impact/risk, or a quantification in physical, biological,
economic, social or other terms, depending on their nature.

• Are the changes important? This is the evaluation in essence, or the
determination of the real importance of each impact/risk on the current
situation, and to the expectations of the local inhabitants, or existing
legislation or other reference parameters

• What must be done to manage or control changes? This is the
determination of measures of prevention, correction, mitigation or
compensation required for those impact/risks which appear to be significant

356 Annex 33

from evaluation

This process is iterative, until measures are found which will make the program

viable from an environmental point of view. In the Chapter of Impact Evaluation,
the four previous stages, although fully considered in the analysis, are presented in
a unified and synthetic manner, seeking to place emphasis on the really significant

impact of the program.

For operational purposes, the impact/risk evaluation has been organized
depending on the type of medium affected, as follows: impact on physical medium,

impact on biotic medium, and impact on socio-economic-cultural medium.

Each impact is classified by the following criteria:

• Character: direct, indirect

• Type of event: negative, positive
• Probability of occurrence: certain, probable, improbable
• Duration: long-term residual, medium-term, short-term
• Reversibility, that is, whether the medium oral resource affected can be
recovered

• Real importance: insignificant or not appreciable (0), very low (1), low (2),
moderate (3), high (4), very high (5).

The impact summarizing trends is pr esented in the reduced matrix for

environmental impact of the program (Figure 4.3).

Scenario of evaluation

Although this is not the most frequent scenario, or even an average one, for the

evaluation of impact/risk, the starting point has been a critical scenario, in which
the environment around the crop area to be sprayed is in its best possible
condition, as follows:

• In the case of coca-leaf, the scenario consists of occurrence of primary
woodland around the crop area, specifically felled to make way for the crop.

357Annex 33

• In the case of opium-poppy, the scenario is the presence of high-Andes
misty woodland, specifically felled to make way for the crop, or around
indigenous or smallholder areas, with occasional human presence in the

crop areas.

4.1.2. Effects of Glyphosate.

4.1.2.1. Mode of action of glyphosate

Herbicides are lethal to plants, by inte rfering with photosynthesis, nucleic acid
synthesis, respiration, formation of ATP, membranes and proteins, division and
growth of cells, root formation, and germination.

The current level of knowledge allows it to be said with certainty that:

Glyphosate is absorbed by leaves, and removed through the phloem

The action is slow, and may need 5-7 days for the first symptoms to appear

There are various technical items of evidence which shows the inhibitory effect of

chlorophyll synthesis, as a consequence of the inhibition of the Delta amino-
levolimic acid, which further is an important component in the formation of
porphirine (Monsanto, Bol. 0573-2139)

It inhibits the production of chorismic mutase and/or prephenic deshydratase which

are interacting active t enzymes in the proc ess of synthesis of shikimic acid, which
in turn is the precursor of the synthesis of aromatics Phenylalanine, Tyrosine and
Tryptophan, which are also basic to the process of synthesis of the proteins

required by the plant.

In addition to the amino acids mentioned above, Leusine, Lysine, Isoleusine,
Methionine and Valine are exclusive to plant species and from the point of view of

animal nutrition, essential because their only source of supply is vegetation, which,
further are the only living organisms abl e to produce them through biosynthesis.
Glyphosate does not act on seeds already lying under the surface of the soil, and

is not absorbed by roots (CIAT, 1997; Meister R. T., Farm Chemicals Handbook
1999, and others).

358 Annex 33

Glyphosate is lethal for plants and bacteria by inhibition of the activity of the

enzyme enolpyruvylshikimate-phosphate synthase (EPSPS), which is a constituent
element in vegetation and bacteria.

4.1.2.2. Characteristics and magnitude of systemic capacity

Glyphosate is characterised as a systemic-type herbicide, and is non-selective
except in the very few special cases of artificially-induced selectivity (certain plant
varieties of transgenic origin). The magnitude of systemic capacity is very wide,

even though it is almost exclusive through foliage, preferably making use of the
tubular system of the phloem, in a large number of the chemical species.

Root absorption, through the xylene, is almost nil, due to rapid deactivation and

fixing of the compound as soon as it comes into contact with soil particles.

4.1.2.3. Processes of absorption and translocation

One of the most important characteristics of glyphosate is its systemic action which

is almost exclusively through the leaf. The absorption of the active ingredient,
however, seems to be a passive kind of process, because it takes place without
the intervention of any energy in the plant. The isopropyl amine salt in glyphosate

is very quickly assimilated, and usually accumulates in the plant growth points.

4.1.2.4. Most important mechanisms of action (enzyme inhibition)

Technical literature allows the deduction that it is probable that was more than just

one process of action, although all the signs are that the most common mode of
action is inhibition of chlorophyll synthe sis, as a consequence of the inhibition of
Delta amino-levolimic acid, which is an important component in the formation of

porphyrin. At the same time, it is estimated that aromatic aminoacids can be
inhibited (mainly Phenylanalin, Tyrosin and Tryptophan), due to the blocking of the
synthesis of shikimic acid.

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Inhibition or interference in the process of synthesis of the aminoacids mentioned,
in addition to others, is critical to plants, because unlike other living beings, plants

cannot substitute them by taking them from sources other than biosynthesis.

4.1.2.5. Average residuality of glyphosate.

All chemical products have a process of degradation or of total or partial changes

of their molecular constitution, and their physical and chemical properties, as soon
as they come into contact with components of the surrounding medium (water,
temperature, microorganisms, light, solar radiation, etc).

In order to offer opinion on the average residuality of glyphosate, which can only

last 4 days or so in average tropical conditions, the following considerations need
to be applied from:

The physical-chemicals comportment of chemical herbicides is very broad and

complex, since more than one of the inductive, residents, inductive medic,
electronic and field electronic effects act favourably or unfavourably (with respect
to the stability of the molecule, for example), environmental conditions in which any

pesticide, including glyphosate, is used. It is sufficient to say simply that in addition
to polarity and apolarity, molecular threatening, solubility, the rate of hydrolization,
surface tension, the capacity for penetration through membranes, affinity and

molecular stability, residuality and the rate of metabolization, and others, are
effects governed by the flow of electrons, and this flow is in turn governed by the
direct or indirect action of factors and living organisms in the surroundings.

The influence of biochemical reactions on pes ticide formulations is real. It may be
said that the formulations use in pesti cides may be acid, or of a week basic
reaction, which facilitates the process of hyhdrolizatio n of in aqueous solutions.

The degree of ionization or protonation (a process which can take place when
adding water to formulations used), however, is governed by the dissociative
constant (pKA) and by the pH of the solution. The use of this symbolism may

become very complex when involving all the effects of the dissociative constant,
but interpretation is easier when, for example, the terms protonated form for acid
reaction compounds are used, and deprotonated forms for basic reaction

compounds.

It is a known fact that protonated and deprotonated formulations differ greatly in
polarity, and therefore, in their permeability and partitioning properties. Also, it
cannot be ignored that electronic interpretations are, today, of great importance

when speaking of properties such as polarit y, acidity, basidity and proportion and

360 Annex 33

direction of all chemical reactions, to mention only a few effects in the area of
biochemical reactions.

4.1.2.6. Toxemic action of chemical pesticides

In principle, all chemical pesticides, with very few exceptions, should be considered
more or less toxic for any living being, including humans. What may be surprising,
is the fact that many of them, and other chemical compounds usually considered to

be non-toxic, may become biocides if the conditions for developing that capacity
are present.

From a biological point of view, it is easy to show that the ingestion of certain

compounds in similar doses may be fatal for some living forms, and at the same
time, inoffensive for others, because to xic capacity is a consequence of the
quantity of product, of the response of physiological systems of organisms to be

subjected to their effects, and several conditions and circumstances prevalent in
each of the ecological systems, which may have the capacity to modify the
magnitude of toxicity in each pesticide.

Parental products and metabolites

Pesticides form a very heterogeneous group of toxic substances from a chemical
point of view. Further, there are certain products which are able to turn themselves
into other chemical substances of greater or lesser toxicity, once they enter the

organism and react with the biochemical constituents of it. Some of these
metabolites, as the substances are usually called, may be the result of oxidative or

reductive enzymatic reactions, in some cases, or the product of the fracturing of
the parental molecule, through a more or less complicated process of
detoxification. Later, we will refer to the most important metabolites of glyphosate.

Dimensioning of toxicology of pesticides

The most important concern is the toxicity of chemical pesticides. For a doctor, the
most important thing is human health, and fo r him, any pesticide is or could be a

poison, and any benefit that might generate would be of very secondary
importance. For another section of the public, including plant health specialists,
pesticides are very useful substances, although in all cases, their use is matched

by the need to follow certain very strict standards.

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Acute and sublethal intoxications in humans and animals, the problems of the

resistance to the action of pesticides, and international restrictions imposed on the
agricultural chemicals market from against contamination with toxic residues, were
the decisive causes for several states to issue restrictive regulations, including the

ban on some pesticides.

The dangers of the toxic effects of pesticides referred to the acute risk to health
(that is, the risk that simple or multiple exposure, for a more or less short period),

which may occur accidentally to any person who manipulates a pesticide, even if
he follows the manufacturers instructions or those of agencies responsible for their
storage and transport. Nonetheless, in the case of activities proper to our

operations bases, the possibilities of intoxication by some of a mixer with
glyphosate are in practice non-existent.

In order to place a limit on the scope of the term acute risk, the term "toxic" is used,

as a synonym of poison, and toxicology as the science of poisons, with respect to
their effects and the problems which are related to poisons, including those of a
clinical, industrial or legal nature.

Non-observable effects limit (NOEL)

Several studies with laboratory animals determine the existence of a close
relationship between dose and response. This relationship allowed a calculation

and determination of a dose able to cause observable effects (effects limit), and
the dose at a level at which effects are not observed (non-observable effects limit -
NOEL)

The toxemic capacity of any pesticide depends on a number of factors, as with
which a given quantity (threshold), which may be "the point at which a given
stimulus is sufficiently strong to be perceived, to cause a response, to secure

access to a given point, or to cause a moment of something". With this starting
point, it may be deduced that each pesti cide has dosage levels which have no
action on a living organism which, further, may be taken into account in calculating

362 Annex 33

the magnitude of certain regulatory norms, including the acceptable daily ingestion
for humans.

The safety and uncertainty factor

The safety and uncertainty factor is a precautionary procedure to safeguard human
and animal health, as practised in the United States and other countries.

When the effects limit has been determined for a given product, US-EPA divides
the lowest NOEL value in the study by an uncertainty factor (of 100 or higher), to
determine the reference dose (RfD), that is, the level below which the “aggregate

daily exposure” to the pesticide, in terms equivalent to one life, will not cause
appreciable risks. They spun it an uncertainty factor or safety factor of 100, is the
commonest in toxicology, because it is normally assumed that human beings are

10 times more sensitive to pesticides than animals.

Further, US EPA may take account of potentia l risk factors for infants, and on that
basis, decide whether it is relevant to apply the additional uncertainty factor or not.

For short-term risks, the EPA calculates a margin of exposure (MOE), dividing the
estimated human exposure by the value of the NOEL, making use of appropriate

animal studies. In general, the EPA and many organizations in other countries do
not accept MOEs of less than 100. This value, which is 100 times greater than the
MOE, is based on the same criterion adopted to estimate the value 100 times

greater than the “uncertainty factor”.

The concept and scope of DL 50s

The degree of hazardousness of each compound is measured in accordance with

average lethal doses values (DL 50), which is "the minimum dosage required to kill
50% of a homogeneous group of animals after six hours, under special
experimental conditions". DL 50 may also be "the minimum quantity required in a

single dosage, to kill half the individuals of a group of at least 10, in specific
experimental conditions, and subject to observation over 6 hours-15 days after the

363Annex 33

administration of the toxin". The dose is expressed in milligrams of the toxic
substance per kilogram of live animal weight, specifying the species, sex and age

of the animals used. It is applied orally, through the skin, through the eyes, through
the mucus and by inhalation.

Toxicological categories

Despite the limitations of deals 50 values, in terms of chronic and acute oral
absorption, lethal in inhalatory dose and lethal dermal dose, Colombia and other
countries have adopted several toxicological categories for the sale and use of

agricultural chemical compounds, although some are included in the following
current categories in the USA.

TOXICOLOGICAL CATEGORIES USED IN THE USA AND COLOMBIA

Characteristics classification

Less than 10 mg per kilogram of live animal weight extremely toxic

10 - 50 mg per kilogram of live animal weight highly toxic

51-500 mg per kilogram of live animal weight moderately toxic

501-2000 mg per kilogram of live animal weight slightly toxic

over 2000 mg per kilogram of live animal weight almost non-toxic

source: EPA, Ministry of health, farm chemicals 2001, USA

The Colombian Health Ministry has established for categories, separating solid

from liquid pesticides, and assigned glyphosate into Category IV (slightly toxic),
and the mixture of glyphosate + POEA+Cosmoflux 411F into category III (see the
opinion of October 4, 2001, Schedule 4). It should nonetheless be explained that

POEA forms part of the commercial formulation, that is to say, it is not that it is not
added, says it already comes with the glyphosate acquired by PECIG.

364 Annex 33

Residues and tolerances

In order to avoid the damage caused by ingestion and the accumulation of lethal

quantities of pesticides, FAO and WHO have recommended a number of measures
to reduce the hazards of ingestion of agricultural chemicals.

The maximum quantities of residues permissible in the daily consumption of food

are specified and quantified for each animal or plant food source. These quantities
are expressed in terms of parts per million (ppm) of the permissible quantities of
post-harvest residues, if plants, or post-sacrifice in the case of animals. These

values may differ from country to country, depending on the crops, or the
processing system, or food habits.

In addition to the tolerances suggest ed by the standards organisations, account is

also taken of the time in acting between the last the most recent application and
the harvest (this being a period of degradation of the parental molecule of the
compound), and environmental factors and even the influence of biochemical

systems on living organisms. In the case of glyphosate, the Ministry of Health
classifies it as toxicological category IV (slightly toxic), which means that even in
the case of ingestion, there would have to be a considerable dose to cause any

damage to the human organism.

In subsequent sections of this Chapter, where referring to the impact on human
health and ecosystems, there will be a transcription of tolerances to glyphosate
accepted by several international agencies.

Factors able to influence the toxicity of glyphosate.

The overall toxicity of glyphosate depends on a number of factors in the ecosystem
and in the physiological conditions of each living organism. For the case of the use

of this herbicide on the programs for the erad ication of illicit crops, the possibilities
of contamination with significant doses are minimal, since in practice each crop of
the illegal species is treated only once, and the degradation of the parental

molecule is very rapid in high-temperature and humidity tropical ecosystems. The
following are the most important factors.

365Annex 33

• Physical-chemical characteristics of the formulation for use
• Toxic quantity per patient

• Time of exposure time of the receptor organism to the pesticide
• Route(s) of entry to the organism (mouth, nose, eyes, etc)
• Class and type of inert materials in the formulation
• Degree of susceptibility of the receptor organism
• State of health of the organism

• Importance of the physiological system affected
• Efficiency of the organism´s detoxification system
• Chemical stability in the formulation employed

4.2. IMPACTS ON THE PHYSICAL ENVIRONMENT

4.2.1. Impact on soil

4.2.1.1. Impact on the quality of the soil

Identification

The spraying of glyphosate on illicit crops may affect soils in which those crops lie,
and legal crops nearby, which may be affected by drift. This is a matter of direct,

negative, certain impact, in the short term, and reversible.

Prediction

a) Processes old metabolization and degradation of glyphosate in the soil

Glyphosate is not a prolonged residual action herbicide, and its effect is of very
short duration in tropical soils. The molecules biodegrade principally by the action
of microorganisms in the soil, and since it is a representative of the type of

compound known as phosphoric acid, which c ontains a direct link of carbon to
phosphorus (C-P), and although the C-P link is chemically very stable, many

366 Annex 33

bacteria including those in the enteric group such as Escherichia coli, have an
enzymatic ability to break this link in order to release the organic phosphate.

Glyphosate degrades through photochemical, chemical and biological processes,
due to the effect of UV light, but not from chemical hydrolysis, although in practice
that of the greatest magnitude is the enzym atic decomposition due to the effect of

microorganisms in the soil, which originates the formation of biologically inactive
metabolites, such as a minor methyl phosphoric amino acid (AMPA).

In almost all studies on the metabolism of glyphosate, this was the only source of

obtaining phosphorus, because the organisms subjected to investigation were not
able to use the glyphosate as an additional source of carbon and nitrogen.

If we note that the common route of degradation for AMPA has been found in

microorganisms prior to the introduction of defrosted, this fact has allowed for the
proposal that the procedure for degradation of this herbicide is something which
occurs naturally in the environment, although the prevalence of sarcosine in the

intermediate route of degradation, in isolation obtained from glyphosate-enriched
sources, also suggests that this route is a process of selection in certain
environments, possibly due to the greater favourability for organisms involved in

the process.

CO2, water, nitrogen and some phosphates are the general product of degradation

of glyphosate. In laboratory conditions, it is possible to estimate and measure the
resulting quantities of these compounds as a product of degradation of glyphosate.
However, in field conditions, in which processes of adsorption and bacterial

degradation play a dominant role, in addition to processes of interception of
herbicide from the aerial apparatus of plants and elaboration, it is very difficult to
calculate the balances of these masses. Further, they may be valid only at one

moment in time, since the action of degradation is continuous.

The process of adsorption is responsible for the greatest loss of herbicide action of
the chemical compound in the soil. The particles which fall on the ground may be

fixed by absorption, in clays, in organic matter, in metal oxides, and in some humic

367Annex 33

constituents, through the action of phosphoric acid, which competes for fixing sites
with organic phosphates. The pH of the soil has little effect on adsorption, and,

since this is a case of a processor of equilibrium, the fixing (adsorption) may be
classed as irreversible process.

b) Average life of the parental product in the soil

Glyphosate is not a pesticide with a prolonged residual action, but due to the
multiplicity of factors related to the degradation process, the degree of persistence
in the soil varies greatly, and it is not easy to provide an appropriate answer to the

question "How long is the persistence of glyphosate in the soil?". The average life,
that is, the time required for half of the quantity of the product applied to metabolize
or disappear, may vary from 3 to 141 days, depending on information from a

number of authors, although there are also those who say that the biocide effect is
normally of very short duration in tropical soils, because the molecule may degrade
rapidly, and is able to be fragmented, and give rise to compounds such as CO2,

water, some nitrogenated fractions and certain phosphates - all of this, due to the
principal action of microorganisms.

The high values of the systems of the parental molecule which some authors note,

only occurs in ecosystems subject to temperatures bel ow freezing point, such as
some parts of Canada, where in addition to low temperatures, there is also an
almost total reduction of activity of the microorganisms responsible for the

metabolization of the parental molecule. This never occurs in Colombian criticisms,
and therefore, the average life of the molecule of lesser fate is so short.

Herbicide molecules, as explained earlier, normally fixed in the soil as a result of a
process of adsorption in clays, in organic materials, in metallic in metal oxides, and
in certain humic constituents, but, because this is a process of equilibrium in

electron charges, the fixing (adsorption) may be, and in effect is, a process which
can be reversed (desorption). The influenc e of pH in the soil in the rate of
degradation of glyphosate seems to be very small. Nonetheless, although in theory

it may be logical, under conditions of tropical soils desorption may be very limited,
and at all events, the glyphosate molecules will be quickly metabolised by bacterial
action.

368 Annex 33

The degradation of the glyphosate molecule is certainly a rapid or slow process,
depending on several environmental conditions, and various circumstances in

which it acts. In most cases, the rate of degradation of the parental molecule
determines that the average life will be le ss than one week in tropical conditions,

while in other conditions and environments, degradation and metabolization may
take several months, and up to one year, as may be the case of certain

applications made in Canadian crops.

c) The range of metabolites, and their relative importance

The metabolization of glyphosate is caused dominantly by microflora, although the
resulting metabolites are not used by t he microorganisms which originate them.

Despite the aerobic and anaerobic degradation of the parental molecule, giving
origin to at least six metabolites of which the majority in production and importance

are AMPA, and structural formula is CH 6NO P3 and sarcosine (N-methylglycine,
hydrochloric sargosine or 2-methylaminoethanoic acid), whose structural formula is

C 3 7O . 2MPA is detectable in the soil and in plant tissues, and respect with to
toxemic capacity, it can be classed as harmless.

For some time, there was concern that t he metabolic process of glyphosate could
cause the formation of nitrosamines substances known to induce mutagenic,
carcinogenic and teratogenic effects, or certain acute intoxications. These

concerns have been found to be baseles s so far, and no research has shown or
found evidence of the formation of these metabolites. Something similar also

occurs with reports published since 1990, that among the products of
decomposition of the parental molecule of glyphosate, there should also be

formaldehyde, a compound which currently appears on the list of potentially
carcinogenic substances. Although this possibility exists, the quantities produced
as a consequence of the nor mal use in weed control may perhaps be classed as

"trace", and of very low risk to users.

d) Bioconcentration and effects on soil microorganisms

369Annex 33

Given the toxicity implants, and the persistence of the compact being considered
so small, the use of the compound should be understood, in terms of the

comportment of glyphosate, physically and microbiologically in soils.

The first comportment refers to the adsorption of the glyphosate molecule in active

sites in the soil, generally composed of available phosphates. There are specific
Peons which reduce the capacity of abs orption of the molecule, such as Fe +2and
+3 +3
Fe , and Al . This may occasionally cause a highly constant of absorption of this
compound in sandy-clay-chalky and sandy-chalky soils.

Bioconcentration in the soil can be determined is determined by the analysis of the
solubility constant (1200/L), and the octanol water constant (Pow) (-2.8). These
factors allow the determination of the possibility of bioconcentration of the

molecule. Comparing these values with leve ls considered as critical for these two
parameters, it can be said that the risk of bioconcentration of the molecule in soils

is not feasible.

PARAMETER CRITICAL VALUE FOR
VALUE GLYPHOSATE

MOLECULE

Solubility constant < 30 mg/L 1200 mg/ L

Octanol – Water constant > 3 -2.8

Source: DNE 2000

e) Study of Transformation 33

Several bacterial strains are able to decompose and degrade glyphosate. In most
of the laboratory experiments, the rate of degradation of glyphosate in soils seems

to be rapid. The speed of transformation can be established by a first-order non-
linear model, which describes results observed best (PTRL East Inc, 1991)

                                                            
3 Environmental Management Plan for Illicit Crop Eradication, 1999 

370 Annex 33

α
C=Co (1+ β t)

where C is a concentration of glyphosate at time t C O is the initial concentration,
and α and β are constants which reflect spatial variability.

The principal metabolite of glyphosate, produce by the transformation in aerobic
conditions, is a metabolit e known as AMPA. In laboratory experiments, the

maximum quantities found of this metabolite in sandy-chalky and alluvial chalk
soils were 27% and 29% respectively, of the radioactivity applied (PTRL East Inc,
1991). Values of TD50 for AMPA can be found from this study, at approximately 50

days, for the types of soil mentioned.

In another laboratory experiment (Monsanto Inc, 1972b), it was found that AMPA

may be more persistent than the original molecule, given that after 111 days,
between 10% and 17% of the radioactivity initially applied for this metabolite could
be recovered.

The mineralization of glyphosate in t he soil occurs in aerobic and anaerobic
conditions in the laboratory, and although rates are appreciably different, the

results are mainly dependent on the soil respiration rate, and on temperature.

In the soil, glyphosate seems to be degradable by microorganisms in two ways
(Jacob at al, 1988). One route, via the formation of AMPA, a fragment of CO2 and

probably glyoxylate. This scheme of degradation was proposed by several
researchers (Monsanto, 1972b, PTRL East Inc, 1991). In this route, the cleavage

of the C-N union is the first stage. However, there is another degradation route
through sarcosine (N-methyl glycine) and orthophosphate, after which the
sarcosine is degraded to glycine, and one unit of a carbon, which eventually forms

CO2, probably via formaldehyde (Kishore and Jacob, 1987, Jacob at al, 1988). In
this route, the first step is the rupture of the C-P link.

371Annex 33

14
In experiments with C-glyphosate, isolated crops of pseudomonas SB, LBr strain,
were able to degrade glyphosate through both routes (Jacob at al, 1988).
Approximately 5% of the glyphosate applied was not degraded by AMPA, but was
34
degraded by Sarcosine

Evaluation

The low residual energy of glyphosate in the soil, due to bacterial degradation
processes and to adsorption and transformation of the molecule into metanbolites

allows the conclusion that persistence in tropical conditions would be 3-4 days. If to
this we add that it does not act on plant roots, the conclusion may be that the

impact on the soil is low to very low.

Mitigation

Given that the impact on sprayed areas is normally considered to be low-very low,
for the reasons given in preceding par agraphs, no mitigation measures are

proposed for the plots of land sprayed. In cases where, due to attacks on the
aircraft or an accident in the air, it becomes necessary to dump the entire product
somewhere; this work will depend on the location of the place of dumping. If it is

possible to arrive at that point quickly, the recommendation would be to apply the
inactivation measures recommended in the spraying operations management

program (Record 1), at all events applying the terms of the Contingency Plan
(Record 13). If this is not possible, then compensation measures provided for in the

Social Management and Compensation program would have to be applied (Record
9).

In the case of an accidental spillage of glyphosate on the ground at the operations
base, the measures recommended by the Comprehensive Security Program
(Record 4) should be applied, seeking to deactivated by covering it with an

absorbent material, such as earth, and/or apply line to prevent unpleasant odours.

                                                            
3 WHO/IPCS Environmental Health criteria No. 159 Glyphosate. 1994 in Environmental Management Plan 
for the eradication of illicit crops, 1999  

372 Annex 33

Despite the foregoing, it is considered that a research program should be

conducted on demonstration plots representat ive of the various nuclei of illicit
crops, in order to prove these conclusions , based on existing scientific literature
(see bibliography). This Plot Research Program is designed on Record 7, and

seeks to measure the residual energy of glyphosate in the soil and water in the
conditions of the Colombian tropics, and the ecological dynamics of biological
communities in the soil subsequent to the application of glyphosate.

4.2.1.2. Impact on morphodynamic processes

Identification

The planting of illicit crops in foot hills which had previously been stripped
generates processes of erosion of different kinds, depending on climate and the

nature of the terrain. In many places which had been recently cleared, surface
water erosion processes and landslips can be observed.

Once an illicit crop is established, the sp raying with glyphosate to destroy the

herbaceous cover (only in the case of pastureland, since both coca leaf and opium
poppy are clean crops), this may generate new processes of erosion or increase

existing ones. This is an indirect, negative, probable, short-term and reversible
impact.

Nonetheless, we should stress the terms of the Baseline Chapter, which states that

the principal effect on erosion is caused by the initial clearing by the coca leaf or
opium poppy grower. Further, both are clean crops, and therefore they generate
erosion processes regardless of whether t hey are sprayed or not. In fact, among

the farming practices employed by the coca leaf and opium-poppy growers, there
is the intensive use of herbicides, whic h leaves the soil uncovered and exposed to
erosion agents (rainwater and run-off). At all events, the additional impact of

spraying of aerial spraying would be for a short time (one vegetative cycle).

Prediction, evaluation and mitigation

373Annex 33

In general, the climate in which the illicit crops are grown varies from humid to very

humid (in general, with more than 2000 mm of annual rainfall), for which reason the
process of scarring or regeneration of the vegetation is rapid, and this holds up the
advance of processes of erosion, provided that the land involved has not been the

object of farming practices again.

For these reasons, which is considered that the impact caused by glyphosate
spraying on processes of erosion is low and short-term (see photos 4 and 5,

chapter 3).

Therefore, it is not considered necessary to pursue specific measures of mitigation
designed to control processes of erosion originated by the application of

glyphosate

4.2.2. Impact on water

Identification

Glyphosate spraying may affect the quality of surface water sources, deteriorating
the water habitat. This is a direct, negative, very unlikely, short-term and reversible
impact.

Further, the operation of bases generates domestic wastewater, and its discharge
may contaminate local water sources. In this case, the impact is direct, negative,
probable, mid-term and reversible.

Prediction and evaluation

a) Effects of glyphosate on water

374 Annex 33

A general overview of the large amount of technical information allows an opinion
on the regulated use of glyphosate that of fers little likelihood of contaminating

water currents, as a consequence of run-off or the percolation of residues from the
application of the glyphosate in the soil or on foliage.

When the glyphosate comes into contact with bodies of surface water, it

immediately becomes soluble and absorbs to the sediments where it biodegrades.
The period of persistence of the molecule in the sediments of surface water varies
from 4 to 171 days, but its detection occurs several days after the pesticide is

exposed to the medium, and the concentration tends to diminish over time.

The solubility of glyphosate in water is in excess of 30 mg/litre (1200 mg/litre), and
the octanal-water partition coefficient is less than three (-2.8), and we can therefore

conclude that there is no possibility that the pesticide forms bioconcentrations in
fish, or transfers itself to organic ma tter suspended in water or sediments.
Therefore, glyphosate can be considered as non-recalcitrant (Log Kow < 5), unlike

aldrin, heptachlorin, chlordane and DDT.

The presence of residues is evident in significant quantities if the compound is
used as an aquatic herbicide, and further, in static water sources the quantity of

residues declines even faster, due to the process of adsorption of particles of
matter in suspension, or at the bottom of deposits. In conditions of running water,
the process is the same but the particles of the compound can be detected a good

distance away downstream from the original site of treatment or contamination.

The adverse effect on groundwater depends on the mobility of the herbicide in the

soil, and this is analyzed with the adsorption constants, the standardized
adsorption constant and solubility of the molecule, and we describe these criteria
below.

Glyphosate is adsorbed and rapidly fixed by the soil. The adsorption of glyphosate
is correlated with the number of avail able phosphate binder sites, and seems to

375Annex 33

35
occur due to the binding of the phosphoric acid fraction .

In laboratory experiments in which glyphosate is added to aqueous suspensions in
the soil, the K S/Labsorption coefficient was 18-377 dm /kilogram in nine soils which

varied from sandy-chalky to turbid (Hance, 1976), and from 33 to 76 dm3 /kilogram
in three soils from sandy chalky to clay-chalky (Glass, 1987). In both experiments,

the process of adsorption may be described by the Freundlich equation. Glass
(1997) found adsorption values for montmorillonite clay, illite and kaolinite, of 138,
36
115 and 8 dm3 /kilogram, respectively . The values of K D correspond to 324 for
sandy-clay-chalky soils, and 600 for sandy-chalky soils.

Given the high affinity of the components of the soil, as already noted, glyphosate
is almost immobile, with a minimum probabi lity of transport through lixiviation or

being dragged by run-off.

In a fine-layer chromatography of sandy-chalky soils, alluvial-sandy-chalky, it was
found that glyphosate has an Rf value (mobility in the fixed phase) of between 0.14
and 0.2 (Sprankle et al, 1975), and in another study with the same types of soil, the

values obtained were less than 0.2 (Monsanto Inc 1972c).

In a study of lixiviation in columns 30 cm high, with a strong flow of water of 51 cm
in two days, less than 0.1 to 6.6% of the radioactivity applied lixiviated. This

experiment was conducted in each types of soil which varied between sandy and
chalky, with an organic matter content of 0. 7%, to volcanic ash with organic matter

content of 9.5%. More than 90% of the radioactivity applied was recovered from
the surface layer of 0-14 cm.

The process of translocation of herbici des can take place through a number of
routes, including the dragging of particles on air currents, evaporation, and to some

extent in running water. However, it is known that the low vapour pressure of
glyphosate means that the compound has minimal or no volatility, that percolation

                                                            
35
 Weed Science Society of America, Herbicide Handbook, 7th Edition 1994. In Environmental Management 
36an for the Eradication of Illicit Crops., 1999 
 WHO/IPCS op cit. 

376 Annex 33

of residues in the soil will be negligible, and that due to the great magnitude of the
adsorption process and the remaining evidence available, it should be catalogued

as of very low radicular absorption and nil mobility in the soil.

The great majority of specialists agree that the rapid process of adsorption of
glyphosate particles in the soil is a com portment proper to the group of pesticides

which do not have the chemical characteristics that allow them to percolate, and to
eventually contaminate surface or groundwater sources, unless there is some
process of de-sorption, which is very unlikely in natural circumstances.

Although the rate of degradation of glyphosate residues in water depends on pH,
temperature, and the presence of microorganisms, most tropical aquatic
environments that may be accidentally contaminated by the herbicide from normal

dosage in plant health applications, have t he ideal conditions to facilitate the
process of rapid degradation and metabolized, without staying there for long
enough for residues to accumulate in the tissues of fish.

Further, the effect of adsorption of glyphos ate in the soil is so accentuated, and
takes place in such a short time, that all tests continue to show that there is no time
for lixiviation, and therefore we can state that there is very little possibility of

contamination of groundwater, based on the contamination of soil.

In the case of dumping or forcible discharge of the herbicide tank from the aircraft,

in a short space of time the processes of ad sorption will also act rapidly, such that
there will be no place for lixiviation of the product. The only difference with regard
to normal spraying would be that the area and thickness of the soil affected would

be slightly greater, of the order of a few centimetres, but at all events, there would
be very small possibilities of contaminating water below the water table. At all
events too, in the case of dumping, the contingency plan is mandatorily activated,

to make a quick evaluation of the possible damage produced, and to apply
deactivation measures if necessary.

Dumping on surface water is very unlikely to occur, since the pilot should, once the

decision has been taken to dump the produc t, choose a place for dumping with a

377Annex 33

set of pre-established priorities, namely,: a plot with coca leaf, area with no
vegetation, pasture, or scrub. In no circ umstances should he dump the product on

native forest or bodies of water. If there is an attack by an armed group, and the
pilot is seriously wounded or the aircraft might be damaged and four on a body of
water and the herbicide might be spilled entirely, it would rapidly be diluted in

water, and the impact would depend on the flow or volume of the flow of the body
of the water. In this case, the activation of the program would indicate the
measures recovery measures to be taken

b) contamination due to domestic wastewater

Sewage generated by the personnel of the operations bases totals some 38
m³/day (90% of consumption). These waters are collected in the sewerage system,

and treated and disposed of as follows (see Record 5).

Since the antinarcotics operations bases are in principle mobile (they must move to
wherever the illicit crops are), the wate r from the sewerage system will be treated

in a compact and equally mobile plant, with an organic load removal efficiency of
95%, and removal of suspended solids of 95%. This type of mobile plant is formed
of tanks of PVC, aluminium and other metal materials, and may be assembled,

disassembled and transferred from one place to another as and when needed. The
effluent from the plant will be used for irrigation, or it will be discharged into the
nearest surface water current with a flow of at least 10 times that of the discharge.

For these reasons, the impact of the operations base on the local water surface
water system has been classified as very low.

Mitigation

The operating parameters for aerial spraying of glyphosate require that bodies of
water should not be sprayed at a distance of less than 100 m, in order to avoid any

direct impact on water sources. If a body of water or a fish breeding tank is
accidentally sprayed, the Social Management and Compensation program

378 Annex 33

provides for indemnity in the form of the compensation which the a environmental
authority determines, in accordance with current law, in particular CNE Resolution

17/2001 (see Measures of Compensation, Record 9). Likewise, if the spraying
takes place upstream of the intake of a water supply or tanks, the municipal
authorities should immediately be advised, so that the service can be suspended

until the emergency has been overcome.

In cases of dumping, as noted above, the activation of the contingency plan should
in each case determine actions taken to deactivate or recover.

In order to avoid the impact on wastewat er from operations bases, measures for
the collection of domestic wastewater should be applied (see Record 5), along with
measures to collect and handle oils and greases used in machinery maintenance

(see Record 3).

4.2.3. Impact on atmospheric resources

4.2.3.1. Impact on air quality.

Identification, prediction, evaluation and mitigation

The volatility of glyphosate is not a significant process, if it is noted that glyphosate

is a molecule with very low vapour pressure, and therefore does not vaporise, and
this means that there is no possibility of it being inhaled by animals or redistributed
by the air, and there is very little danger of toxicological problems in respiratory

systems.

In relation to the impact caused by spraying, it should be noted that in general
when an aerosol substance is released in to the atmosphere, the particles may

cause dispersion of visible light, and therefore interfere with the processes of light
transmission (particles with sizes particles smaller than 100 µ); this process
depends solely on the particle size of the substance, since the larger the size, the

379Annex 33

more rapidly the force of gravity tends to attract it.

In the case of the illicit crops eradication program, the effect which a glyphosate

molecule may cause in the air is negligible, since precisely, one of the objectives of
the program is to ensure that drops for e ffectively on the target (coca leaf crops),
for which purpose they use drop si zes of 300-1500 µ, which guarantees

effectiveness of application, avoids loss of the product, and so, avoid economic
loss. The drop size employed in the eradication program was endorsed by ICA in
August 2000.

It is also important to note that the herbicide glyphosate has low vapour pressure,
and therefore does not vaporise, which means that there is no possibility that it will
be inhaled by animals or redistributed by the air.

Therefore, the impact on air quality, which at all events would be limited to mixing
sites, would be very low to negligible, and therefore measures for mitigation other
than those of industrial safety described in Record 11 have not been provided for.

4.2.3.2. Impact generated by noise

Identification, prediction, evaluation and mitigation

Since the operations bases ar e close to or inside airport perimeters, they will be
subject to relatively high noise levels generated by air operations. Further, the
noise generated by the spray aircraft (OV-10 and T-65), is considered to be low

and within regulatory limits, since these are small modern aircraft, which take off
from the main runway and therefore do not create noise levels higher than 70-75
dB(A) on average in the base area, since they take off along the airport runways,

which are generally some distance from the airport installations

Helicopters, on the other hand, can generate peak noise levels of 90-100 dB(A) in
the base, this requires the use of ear muffs by ground personnel. The average by

380 Annex 33

day or night is with within industrial zone norms (75dB(A)), i.e., classified as
airports (Epam Ltda, 2000, based on the experience of measurements of Bogotá

International airport over four years, and other airports in Colombia).

Therefore, the related impact has been classed as low to moderate

4.3. BIOTIC IMPACT

4.3.1. Impact on vegetation

Identification

During spraying operations, part of the glyphosate may be dragged by the wind

(drift effect) over forests or other types of vegetation adjoining the areas of illicit
crops sprayed, with a greater or lesser effect upon them, depending on the quantity
of herbicide which falls on them.

This section makes an evaluation of the effects on forest areas. Crop areas are
discussed in as part of the socio-economic impact.

Prediction

Glyphosate is suitable to control many annual and perennial grass species, several
broad-leaved weeds, and many shrubs and woody species in crop and non-crop
areas. In many countries, application with aircraft is strongly restricted or not

allowed, where there are sensitive crops in the area.

In the United States, and in many other countries, glyphosate is permitted has
permits for application as a general herbicide for w eed control in industrial and

recreational areas, along the banks of canals, along rights of way, on golf courses,
in dry channels, and with certain restrictions, and prescriptions and technical

381Annex 33

management, on many farm crops including several leguminous species (soya), to
which a transgenic herbicide-resistant gene has been incorporated. In Colombia,

and in all countries which produce oil palm, the use of glyphosate has been
generalized since the 1980s. There are also r egistrations authorized for its use in
several species of fruit trees, and in sugarcane as an accelerator on maturity.

a) Symptoms of the effects caused by the glyphosate in coca leaf crops

We present a synthesis of the effects caused on the coca-leaf crop, to provide
easier understanding of the impact of herbicide on other types of vegetation.

Two weeks after the spraying, it will be possible to see the occurrence of the
following symptoms. It should be noted that in the presence of new shoots can only
occur in plants which have been treated by cutting within 24 hours, or in plants

which due to failures of application or some other reason, were not covered by the
glyphosate spray. The symptoms of damage are slower to appear in woody plants
more than two years old.

• Foliar chlorosis
• Defoliation
• Necrosis of secondary branches

• Necrosis of main stems
• Necrosis of the roots
• Resprouting of leaves
• Resprouting of buds

• Effect on weeds
• Drift effect on the nearby vegetation.

Two weeks after the applications, there will be strong symptoms of damage to
plants not subjected to cutting. After 8-12 weeks, the entire the effect must be total,

and plants will show evidence of total necrosis, including their root systems.

It is possible that defoliation, as the first visible symptom of the effects, will be seen
before two weeks after treatment. The initial symptoms of necrosis may also be

382 Annex 33

present within 8-10 days of the treatment.

The weeds present in the soil of coca-plants are also affected by glyphosate

spraying, but unlike coca-leaved plants, the population of gramineous weeds
begin to show significant recovery after one or two months.

The damage attributable to drift, affecting trees close to the coca plants, is

identifiable after 2-3 weeks, but has no lethal effect on most tree species. In some
observations, it was possible to determine that defoliation was greater and more
pronounced in a single species of Guarumo, whose leaves have a silvery colour,

from the Cecropia genus, but after one or two months the trees recovered their
foliage (Environmental Audit, 2001.

b) Natural succession

When there is an event in original piece of woodland, whether caused by man
(felling) or nature (landslip, falling trees), there is a process of vegetal recuperation,
a phenomenon known as succession. The fi rst species to appear may be fungi,

moss and lichen, but to the naked eye, it is the herbaceous species that count. So,
Gramineae or Poaceae and the compounds of Asteraceae will be the first to cover

the soil, and they have therefore been called the "Pioneer species". In a short time
(2-3 months), the effect can already be seen, although some herbaceous species
may come out in a few weeks.

If there are seedling trees nearby, such as guarumo (ceiba asculifolia), balsa,
guamo or puntelanzas (inga spectabilis), zurrumbos (Tournefortia longiloba), tuno
(opuntia rubescens) etc., the wind or some animals (birds, bats) start to scatter the

fruit or seeds; the germination of the seed is quick, and the growth of the plants as
well, and the average size of leaves is very large, and this produces a secondary
succession. With the guarumo, there is the belief that if the seeds are scattered in

the jungle, in a latent state, awaiting the arrival of considerable amounts of sunlight
for germination; at all events, coverage may be produced from a single species
(pure association), or several at the same at once (mixed association); in an

overflight, or in aerial photographs, asso ciations can be seen on continuous and

383Annex 33

flat treetops. In the guarumo, the whitish foliage can be detected, in the balsa
(Ochroma), they are there are a large red leaves, in the guamo or puntelanza (inga

spectabilis) there are medium sized reddi sh leaves. Photograph 6 shows a pure
guarumo association, characterized by uniform flattened treetops, developed on a
small plot of abandoned land, next to a plot which has recently been burned off,

with remnants of patches of woodland.

It should be noted that some shrubs, creepers and palms also appear, depending
on the climate. The time they take the form is also very short, growing three or ore

metres per year, given the warm and humid climate prevailing.

When the smallholding, hearing or felled area is not large (1-3 ha), animals begin
to scatter fruit and seeds of the original forest, under the secondary forest, and this
is the longest stage of recovery of woodland, because many years must pass for

the woodland to return to its primitive state (100-200 years).

Processes of plant succession in cold climates are similar to those mentioned
earlier, but with other species, and in citing more difficult ways due to the terrain,

which does not allow seeds to be retained for germination. In cold climates, kikuyu,
ferns, (Pteridium Dicranopteris) and wild fuchsia start to provide cover, followed by
croton spp, paramo bamboo, indian fig and cecropia peltata afterwards they form

almost pure associations of oak, weinemannia tomentosa, melastomaceae and
myrica pubescens.

In the cordillera, when the ridge or hilltop is bare of vegetation, the hillsides have
no possibility of fully returning to their former state.

In practice, the appearance of vegetation depends on the situation in which the
surface soil has been left after the crops. Generally, they are burnt off in order to
make sowing easier and this causes many problems, such as the removal of

nitrogen, the burning off of plantules, fruit and seeds already there, eliminating the
composers (fungii, bacteria, and microorganisms) exposing the soil to direct
sunlight and rain, the destruction of raw humus, etc. During the Environmental

Audit visit, it was noted that after spraying, very small plantules appear of some
herbaceous species, whose seeds have resisted burning, and the action of
glyphosate (glyphosate does not affect se eds); further, it has been observed that

when the crop has been covered in weeds, the effect on the surface of the soil is
not acceptable; however, if the soil is burned and not turned over, the buds of the
plantules and creepers sprout again, as do graminoids (grass for hay, rushes).

Fertiliser practices help abundance in the appearance of weeds, due to the
nutrients that remain.

384 Annex 33

Many mammals (bats, monkeys, and others) and birds that depend on the food
provided by vegetation repay this service by scattering food or seeds; some work

with grassland (graminea), others with secondary woodland, and others again with
primary woodland, distributed by levels or floors, since there are flowers or fruit in
the layers or trunks, mainly berries, drupes or capsules.

The other element which scatters this materi al is the wind, for which fruit and sees
seeds have wings and hairs The very small seeds are ingested and scattered
directly, while medium-sized and large seeds are covered with other meaty

material ingested by animals, and subsequently regurgitated or deposited without
that covering.

In general, observing crops already sprayed with glyphosate and with woodland
and vegetation around them, there is no marked effect on them. This means that

even in the case of temporarily losing their leaves, there is no total or partial death
of woodland, while this fate does occur in the foliage of graminoids (see
Photographs 7 and 8).

Therefore, if a smallholder has deforested a hectare of land, it is logical to think
that spraying may also affect a very small part of vegetation. 15 days after spraying
a coca-leaf crop, a large number of germinated herbaceous seeds have appeared.

Evaluation

In view of the above, and following the observations of one of the forestry
consultants in environmental audit (G. Mahecha, a forestry engineer), the impact of

spraying with glyphosate on woodland vegetation can be considered to be low-very
low, and if there is no drift, non-existent.

In worst case, with which there would be maximum drift, with the aircraft arriving at

the frontier between the coca leaf crop and the woodland, the strip of wood land
affected by temporary defoliation would be some 5m wide, which with a swathe of
50 m for an OV10 and a length of the plot sprayed of 100 m, (that is, a maximum

area affected of 750 m², or 15% of the area treated). If it is considered that illicit
crops in general are to be found in areas already cleared and occupied mainly with
pasture, with patches of original woodland, in which the woodland does not by now

account for even 20% of the total (see photos 2, 3, 4 and 5), the possible impact on
woodland vegetation would not be greater than 3% of the total area sprayed. This
impact at all events would not mean the destruction of woodland, but a temporary

deterioration of foliage, as noted.

385Annex 33

Mitigation and compensation

In principle, if spraying operations are conducted within the parameters of the

Spraying Operations Management Program (see Record 1), in relation to aircraft
height, airspeed dosage and drop size, hours of spraying and favourable weather
conditions, the impact would be very low or negligible. Therefore, no special

mitigation measures have been provided for.

For cases in which damage is caused to native vegetation, the environmental plan
social management program has provided a measure of compensation, consisting

of the planting of one hectare with native species for each hectare of woodland
affected by the PECIG, in places indica ted by the regional environmental authority
with jurisdiction over the area, or payment to that authority of expenses incurred in

the recovery of woodland.

Photo 6

To the left, land recently cleared to sow coca-leaf in Guaviare. In the middle, note
the homogeneous Guarumo woodland, devel oped after the property was

abandoned. On the edge of the two zones, the remains of secondary woodland
can be seen.

Photo 7

Coca-leaf crop, in rectangular shapes around the remains of secondary woodland.
Note that after spraying, woody vegetation shows no apparent signs of
physiological damage.

Photo 8

Deforested area in the region of Guaviare. The coca crops have been
indiscriminately sown in many of the smallholdings. Note the helicopter descending

to inspect and verify the effects of spraying on illicit crops. The greenish colour of
the land evidences the rapid recovery of herbaceous vegetation.

386 Annex 33

4.3.2. Impact on fauna and migrating birds

Identification

The deterioration of native land fauna habitat due to glyphosate spraying on their
bodies, and the possible defoliation of some trees. This is an indirect, very
improbable, negative, short-term and reversible impact.

As in the case of impact on vegetation, the true impact on wildlife has been caused
prior to the glyphosate spraying on illicit crops, since in addition to the destruction
of their habitats by slash-and-burn practices of the coca-leaf growers, one of their

forms of sustenance is the hunting of wildlife. Further, the intensive use of all kinds
of pesticide (not only herbicides), affects populations of insects, which occupy a
very important place in the trophic chains (see Baseline)

Prediction

a) Land fauna

Chart 4.1 shows some environmental indicators for several groups of fauna. It can

be seen that all values for average lethal doses by weight of the species is well
above critical values, and this indicates that glyphosate cannot come to affect
domestic species (mammals, earthworms, birds). However, for bees, it can be

seen that the lethal dose in its higher limit is equal to its critical value, and therefore
an analysis should be made of the exposure of this type of species to the dosage
applied by the program. However, it should be noted that given that the crops

which are the object of regulation (coca-leaf) are clean, and permanently fumigated
to avoid attacks by pests, and the presence of insects is low.

387Annex 33

Chart 4.1

ENVIRONMENTAL INDICATORS FOR LAND ECOSYSTEMS
(Concentrations of glyphosate in mg/kg of body weight)

SPECIES PARAMETER VALUE OF CRITICAL LEVEL

DL 50 **
Mammals DL 50,ral 4900- 5000 100-500 mg/Kg live
mg/kg live weight weight
Earthworms 158-500

* mg/kg suelo seco
Bees DL 50 100 μg of activbe 50-100 μg bee
ingredient/bee
Birds CL 5620 mg/kg of feed 500-1000 mg/kg of
50
feed
Source: 1) Wildlife Intl. Ltd, 1978, in Estudio de impacto ambiental
erradicación de cultivos ilícitos, 1998. 2) HRC, 1972, same study.

*Depends on the soil in which the earthworm lives. **Critical level: value
above which there are symptoms

For the analysis of toxicity in birds, values are similar to those observed for
mammals, and therefore it is considered t hat the application of the herbicide does
not represent a risk to birds. Further, if it is noted that the full application of the

herbicide, through aerial spraying, put the wild birds to flight, thus avoiding any
contact with the product.

It should be noted that the values of D50and CL 50for fauna are obtained through
laboratory tests of acute and chronic toxicity, which would not be comparable with
the probable intake of herbicides into the natural medium to eradicate illicit crops,

since the dose would be minimal, and would be affected at most on two occasions
for a single spraying site, over an interval of more than six months. At the same

time, the compound does not present transfer into ecosystems, due to the
molecule´s capacity to absorb itself into soil, water and foliage, nor is there any
bioaccumulation.

If we can imagine a spraying activity which impregnates the entire body of a
mammal of 12.5 kg and a bird of 50 g weight, the dose received would be of the

order of 10 and 22 mg/kilogram of body weight, and the dose absorbed (2%)

388 Annex 33

between 0.2 and 0.44 mg/kg respectively. These values are lower by 25,000 and

12,488 times the lethal deals 50 doses transcribed. The same analysis can be
made for other types of animals, of different heights and weights, to arrive at
similar conclusions

b) Aquatic fauna

The toxicity of glyphosate for aquatic organisms corresponds to moderate-low
intervals, as established by a range of Colombian and international agencies, both

for acute and chronic exposure, to this herbicide.

According to the low coefficient of octanol-water partition (very soluble in water), it
is very unlikely that glyphosate will bioaccumulate in aquatic animal and vegetal l

tissues.

Aquatic ecosystems, like land ecosystems, are not susceptible to bioconcentration
in fish and algae, due to the constant values of solubility and the octanol-water

coefficient of the glyphosate molecule.

The transfer capacity of water to soil is very low, due to the high solubility of the
compound in water. Transfer of water to air may be very large, due to the high

vapour pressure of the pesticide, although the solubility of the molecule in water
will be dominant, since it is greater, and does not allow for volatilization of the
herbicide.

If we consider the total spraying of a body of water under PECIG conditions, the
maximum concentration produced will be of the order of 3.74 mg/litre, which are
values lower than lethal concentrations CL , and the critical levels indicated in
50
Chart 4.2.

Chart 4.3 shows the comparison of toxicity data for glyphosate, according to
several Colombian and international agencies. It can be seen that the toxicity

levels for birds (>2.500 mg/kg) are very much higher than the levels potentially
caused by maximum exposure to spraying with glyphosate (0.45 mg/kilogram). The
same can be said for fish (15-26 versus 3.74 mg/litre, respectively).

389Annex 33

Chart 4.2

ENVIRONMENTAL INDICATORS IN AQUATIC ECOSYSTEMS
(Concentrations of glyphosate in mg/l in water)

SPECIES ÁRAMETER VALUES CRITICAL

(MG/L) LEVEL
(MG/L)
Fish CL 50(96hours) 2,4 – 34 5-10
Algae EC (48 hours) 2,4 5-10
50
Dapnia EC 506 hours) 19
pulex
Dapnia EC 506 hours) 24-37
magna

Source WHO, 1994, Environmental Health Criteria No 159.
Geneve.

These data can be extrapolated to fish-breeding pools, since in commercial

breeding, which does not exist in the PECIG zone, and in any case, they form part
of activities excluded from spraying; and the water will be permanently renewed in
flows which depend on each species. The trout, for example, which is common in

the opium-poppy growing zones, is a fish which has a high demand for oxygen,
and this means that the water in the pools needs to be constantly renewed.

Evaluation and mitigation

This means that exposure of land fauna and aquatic fauna to aerial spraying with

glyphosate, using the volumes employed in the PECIG, will be much lower than
any dosage which could cause any damage or discomfort.

Similar results have been found in a number of items of research on subchronic
and chronic toxicity, and in studies of carcinogen factors, with experiments on mice
and dogs, given high-glyphosate diets (between 20,000 and 50,000 mg/kg for

rodents, and 500 mg/kg of body weight for dogs). No effects were detected in
relation to these doses applied for several weeks. The same situation was

observed with very high AMPA dosage, AMPA being the principal metabolite of
deficit (Williams G. M., Kroes R and Munro I. C., 1999)

390 Annex 33

The US- EPA, in a rating of A-E, classified the carcinogenic risk of glyphosate in

humans and animals as Category E "evidence of non-carcinogenicity in humans".

Therefore, the impact of glyphosate and its metabolites on land and aquatic fauna
can be said to be low, especially at the levels of exposure involved with PECIG,

which are far lower than the doses employed in laboratory experiments. There has
therefore been no consideration of specia l measures of mitigation for land and
aquatic fauna in glyphosate spraying areas.

Chart 4.3

COMPARISON BETWEEN DATA OF GLYPHOSATE TOXICITY ACCEPTED BY
SEVERAL INTERNATIONAL AGENCIES FOR RISK EVALUATION

. FAO IPCS EPA WSSA Health
Ministry

Acute toxicity

DL50 oral mg/kg >5000 >5000 >5000 5600 >5600

DL50 cutaneous >17600 >5000 >5000 >5000 >5000
mg/kg

DL50 inhalation >3.18 >3.5 >3.5 >3.2 >5.48
mg/kg (1)

Skin irritation Nine None None None None

Eye irritation Moderate/se Slight/mode Slightly Slightly Irritating
vere irritatiorate irritating irritating

irritation formulas

Sensitization of No No No No No
skin

Subacute toxicity 1267mg/kg 1267mg/kg 4320mg/ >1400mg >1400

391Annex 33

NOEL (2) kg /kg mg/kg

Chronic toxicity 310mg/kg 410mg/kg 410mg/k 400mg/k 362mg/

NOEL (3) g g kg

Carcinogenicity (4)No No No No No

Teratogenicity (5) No No No No No

Genotixicity/Mutag Not Not Not Not Not
enicity (6) mutagenic mutagenic mutageni mutageni mutage
c c nic

Toxicity in birds >2500mg/kg >2500mg/k >2500mg 960mg/k 960mg/
g /kg g kg

Toxicity in fish 12-26mg/L 14-33mg/L 15- 86mg/L
26mg/L

Toxicological NA NA III NA IV
category

(1) Applicable to glyphosate and commercial formulations as salts, corresponds
to that used in PECIG
(2) Without observable adverse effect
(3) Without observable adverse effect
(4) Capacity to produce cancer
(5) Production of congenital malformation

(6)Toxicity in the genome in the form of mutations and malformation of
chromosomes

NOTES

1. The spraying mixture used in PECIG contains 10.4/ha Roundup Ultra,

0.24/ha Cosmoflux 411F and 13.2/ha of water. Roundup Ultra is called
Fuerte in Colombia (Licence ICA 2475) and contains 360g/of glyphosate as
acid equivalent and 180g/ of POEA
2.POEA: ethoxylated seboamines, This analysis takes the greatest
concentration existing in Roundup formulations

3. Dose received by a human of 65-70kg weight with a bodthsurface of
1.73sq.m. (Harrison´s Principles of Internal Medicine, 13 1991) as if
totally impregnated with spraying mixture.
4. Of one dose of glyphosate administered on the skin, the average maximum
absorption is 2% (Talbot et al 1991 in Williams Kros and Munro, December

392 Annex 33

1999) For a dose of POEA administered on the skin, average absorption is
10% (Martin 1999 and Lundhila et al 1992 in Williams Kros and Munro,
December 1999). For Cosmoflux 411F and the spraying mixture, it is

assumed that the entire dose is absorbed through the skin.
5. Calculations suppose that water is still or stagnant (tanks, pools etc.)
6. It is assumed that the dose is sprayed onto a Record of water of 1 sq.m.
10cm deep equal to 100/water
7. Internal dose. Amount of the dose ingested which is absorbed. For
glyphosate and Roundup formulations, this is 36% of the dose administered
(Talbot et al 1991 in Williams Kros and Munro, December 1999)

8. Oral DL50 for Roundup formulas is 184ml (Talbot et al 1991 in Williams
Kros and Munro, December 1999) DL50 for glyphosate as acid equivalent
and POEA are calculated on the basis of the composition of the commercial
formula used
9. Not all the dose applied reaches the bare earth, only 10% reaches the
ground in a coca-leaf plantation, the other 90% is retained by the coca

foliage.
10.NOEC: No Observable Effect Concentration for earthworms over 14 days
exposure (IPCS Environment Health Criteria No. 159 Glyphosate, 1994

ACRONYMS

FAO United Nations Food and Agriculture Organization

LPCS International Program for Chemical Safety (FAO/WHO/UNEP/ILO)

EPA: US Environmental Protection Agency

WSSA: Weed Science Society of America

MAXIMUM RISK OF DOSES USED IN PECIG Reference levels

Adult weighing 9.95 mg/kg LD50>5000mg/kg
average 65kg live weight

Water surfaces 4.74mg/L 100mg/L Fish
(lakes, rivers,

streams)

. 8mg/L Algae

. 780mg/L Dapnia

393Annex 33

4.4. SOCIO-ECONOMIC IMPACT

4.4.1. Impact on public health

Identification

During spraying operations, it is possible that part of the herbicide may fall on
people who are accidentally working on illicit crops, or who are close to flight

swathes, and this may eventually affect health. This is a direct, very improbable,
negative, short-term and reversible impact

Prediction

The effect which contact with pesticides may have a human being is based on the
analysis of the capacity of the compound for:

• Carcinogenic consequences;
• Effects generated by ingestion; and

• Effects generated by exposure through the skin, determined by sensitization
to the product

These effects are determined by compar ison of lethal dosage or concentration

LD50/LC 50, which are classified depending on the effects of a herbicide dispersed
in the environment, and tested through exposure on animals.

a) Carcinogenic effect, teratogenesis, oncogenic effect and delayed neurotoxicity

The value of LD50/LD LC 50 is the quantit y of the substance which causes death

in 50% of our test animals after a given period of exposure. The smaller the
LD50/LC 50 number, the more toxic the compound. As stated earlier, US- EPA
classifies pesticides acute toxicity in four categories, in descending order (A-most

toxic and E-least toxic). Glyphosate is categorized E in the EPA scale for acute oral
toxicity based on controlled tests on rats. The results of other types of crops
toxicology confirm the result obtained for rats, and support the categorization of the

herbicide as non-carcinogenic in humans.

394 Annex 33

Chart 4.4

CLASSIFICATION OF US EPA

CATEGORY DESCRIPTION
A Human carcinogen
B Probable human carcinogen
C Posible human carcinogen

D Not classifiable as a human carcinogen
E Evidence of non-carcinogenicity for humans
** Glyphosate is classed “E”

The analysis of the various studies on the adverse effects of acute and chronic

intoxication made by a large number of official and private agencies was the
technical basis for US-EPA to classify glyphosate in a category which includes
pesticides for which no substantial evi dence has yet been found of carcinogenic

effects on human beings. Further, there are also technical reports in relation to the
lack of occurrence of birth defects in rats and rabbits subjected to oral
administration during pregnancy, using doses which were sufficient to cause

certain adverse effects on pregnant females.

There are reports on studies related to t he supply of contaminated food over three
generations, in male and female rats, with subacute dosage of deposit. The results

of these tests did not show any effect on the reproductive capacity of either sex.
Other studies, and standard tests designed to identify eventual genetic changes in
animals and animal cells, and in certain bacteria, were also negative.

To cite only a few case studies, it can be said that one of the most recent

glyphosate toxicity tests, lasting 13 week s, in which oral doses were administered
to between 5.6 56 mg/kg of glyphosate, carbon-14 marked, to 344/N male rats, to
evaluate the process of the elimination of biocide and any symptom of

mutagenesis, the results of radioactivity tests on blood, urine, fecal material and
tissue samples indicated that before 72 hours after treatment, 20%-30% of marked
glyphosate was eliminated in urine, and 70%-80% in feces. Only about 1% of

radioactivity remained in the tissues. Subsequent studies after oral demonstration
oral, intravenous and intraperitoneal administration shows that radioactivity
measured in the urinary tract represented the quantity of glyphosate absorbed, and

that average fecal radioactivity measured the fraction not absorbed in the intestinal

395Annex 33

tract.

In a 13-week study, groups of 10 males and 10 male and female rats 344/N, and

B6C3F mice were organized, and administered dosages of zero, 3125, 6250,
12,500, 25,000 and 50,000 ppm of glyphosate in their food. The administration of
the toxic substance induced increased acidit y in bile serum, and increases in

alkaline phosphatase, and in the activity of a alanine aminotransferase in rats, and
all this was interpreted as a consequence of slight toxicity in the hepatobiliar
system.

No histopathological lesions were observed in rat or mouse livers, and was no

evidence of the adverse effects on their reproductive systems, though it is possible
to detect certain cytoplasmic alterations in their submandibular salivary glands in
rats, and in the parotid salivary glands of mice. The effects of glyphosate on

salivary glands could be shown to be rela ted to an adrenergic mechanism, but this
could be blocked by the use of propranolol androgenic antagonist.

Other studies related to do the same purpose accumulated evidence that

glyphosate did not cause mutagenic effe cts in Salmonella, and did not induce
micro-nucleation effects on rats or mice. Further, the "non-observable adverse
effects level" (NOAEL) for salivary glands was 31.127 ppm in mice diets. In this

study, however, it was not possible to determine whether NOAEL was the same for
rats.

* *

The above studies, and several up-to-date publications on the matter, in confirm

the information held, to the effect that despite the existence of certain contradictory
results (explainable in some cases), the great majority of experimental evidence

shows little possibility that contact, inhalation or ingestion of glyphosate residues in
normal conditions of phytosanitary treat ment, could be the precursors of
teratogenic or carcinogenic effects, or that it would accumulate in adipose tissues.

Although for some time there was concern that the metabolization of glyphosate
could cause the formation of nitros amides, which are known between induce
mutagenic, carcinogenic and teratogenic effects, or sudden acute intoxications,

these concerns have been groundless so far, if we note that no research has
proved the formation of any metabolite of the nitrosamide group.

396 Annex 33

b) Ingestion

Symptoms and effects which ingestion of the herbicide may generate vary

depending on the quantity of pure herbicide ingested.

• No symptom, with ingestion of 5-50 mL
• Slight symptoms with nausea, with ingestion of 50-150 mL
• Moderate symptoms, with erosion of the gastrointestinal tract, 200-500 mL

• Serious symptoms, with difficulties in swallowing and gastrointestinal
hemorrhage and may be presented with intoxication is, that is, consumption
of more than 500 mL.

Ingestion of large amounts of glyphosate for purposes of suicide may produced

serious effects, such as severe hypertension, kidney failure, and in some cases,
death (Sawada et al 1988; measures et al 1999; Tominak et al 1991; Temple and
Smith, 1992). According to the studies, death supervened in some cases with

ingestion of 206 and 263 mL. Nonetheless, the voluntary ingestion of glyphosate
for the purposes of suicide would not be an impact attributable to PECIG. Nor is it
to be expected that there will be cases of accidental ingestion, because the product

is transported and stored in 55 gallon drums. Within that, a person cannot fall or
drown, for example. These data indicate that acute toxicity by glyphosate is low in
humans, and is in accordance with the results obtained with rats.

In the volume of Attachments, there are the opinions of the Ministry of Health in the
toxicological classification of glyphosate.

c) Contact

According to the study made by Shelansky (1973), exposure to glyphosate in the

normal spraying solution (0.9% of glyphosate as an IPA salt, IPAG) or higher (4.1%
IPAG), did not produce skin irritation. Ma ilbach (1986) evaluated glyphosate along
with other products currently used in the home, and found that the glyphosate

herbicide and Johnson & Johnson baby shampoo had a lower potential irritation
than dishwashing liquid or detergent. Glyphosate produces a slight irritation in
some individuals after the application of concentrated product directly on the skin

over 24 hours.

d) Occupational exposure

397Annex 33

Jauhiainen et al (1991), when comparing the data of morbidity among farmworkers

exposed and not exposed to glyphosate in California, found no effect on
hematology, clinical chemistry, ECG, pulmonary functions, blood pressure or
heartbeat, one week after application. With the data from California, Pease et al

(1993) found that glyphosate products were the third commonest cause of skin and
eye irritation among farmworkers, and ranked 15th for systemic and respiratory
symptoms, although the use of glyphosate ranked 12th in the list of irritation

symptoms reported. Nonetheless, it is cl arified and number of cases reported is
only a reflection of the greater use of the product compared to other herbicides.
Despite the widespread use of herbicides in California among workers and

housewives, 25% of conditions reported due to exposure of glyphosate, only 13
are considered to be definite or probable, and of those, 11 showed only slight and
reversible and irritation of the eyes; the other two were for headaches, and an

exposure to a solvent hydrocarbon.

Acquavella et al (1999) in a study of 1513 cases of herbicide exposure reported by
the American Association of Poison Control Centers (AAPCC), found that 21%

presented no lesions, and 70% had only transitory ones, and no exposure reported
affected the structure or functions of the eye.

e) The situation in Colombia

According to a recent study by Clinica Tpox icologica Uribe Cualla S.A. in the town

of El Tablon (Nariño 2001), is based on 29 cases examined at the Aponte health
post between July 2000 and February 2001, of which 21 and had a clinical history.

It was found that the great majority of cases showed no causal nexus between
public health problems reported and the aer ial eradication of glyphosate. He
clinical reports were made either before or substantially after each spraying (12

cases). Of the few cases which occurred during or shortly after spraying (7) almost
half (3) reflect common endemic and conditions in this area which lives in
conditions of poverty, and were not caused by exposure to herbicide (they were

bacterial or parasite infections), and only 4 cases did symptoms begin during or
after spraying, although none serious, and evolution treatment followed the origins
given to infections and other causes. The other clinical histories and religion

glyphosate at all levels of exposure at all, and reflect completely different
diagnoses.

398 Annex 33

Evaluation

Chart .4.5 shows a summary of the valuation risks due to glyphosate exposure in
PECIG. The following should be noted:

The absorption from the skin is 25,000 times less than that required for DL 50, in
the case of an individual and 60 to 65 kg, impregnated with glyphosate
concentrations employed in PECIG. For POEA the ratio is 2,530 times less, and for

Cosmoflux, it is of the order of several million times lower.

• In the case of all ingestion through sprayed water, ingestion is 49,067 times
less than CL50 for glyphosate, 17,711 ti mes less for POEA and 10 million
times less for Cosmoflux.

• In the soil, the concentrations on the upper layer at 10 cm depth are 112

times less than those established by the NOEC standard.

Chart 4.5

SUMMARY OF THE PANORAMA OF HEALTH RISKS DUE TO AERIAL

SPRAYING WITH GLYPHOSATE.

TOXON DOSE DOSE PER DOSE PER DOSE DL 50 PECIG vs DL 50

APPLIED SURFACE BODY ABSORB (mg/kg (P=65 kg)
UNIT WEIGHT ED (mg/kg
(mg/ ) (mg/m ) (mg/kg). live) )

P=65 kg
P=65 kg

EXPOSURE THROUGH SKIN

Glyphosate 158,26 374 9,95 0,2 5.000 25.000 times less

POEA 79,13 187 4,98 0,498 1.260 2.530 times less

399Annex 33

Cosmoflux 0,00845 0,02 0,000532 0,000532 2.000 3.579.398 times

411 less

EXPOSURE THROUGH ORAL DOSE

TOXON CONCENTRATION IN INTERNAL DOSE (mg) CL50 PECIG VS CL50
SPRAYED WATER

(mg/l) (mg)

Glyphosate 3,74 1,35 66.240 49.067 times less

POEA 1,87 1,87 33.120 17.711 times less

Cosmoflux 0,0002 0,0002 2.000 10.000.000 v.

411 menor

EXPOSURE IN SOIL

TOXON DOSE QUANTITY DOSE DOSE NOEC PECIG VS

APPLIED ON BARE RECEIVED RECEIVE (mg/kg NOEC
2 GROUND IN SOIL AT D IN SOIL )
(mg/m ) (mg/m2) 10 CM AT 5 CM (10 CM PROF.)

(mg/kg). (mg/kg)

Glyphosate 374 37,4 1,41 2,82 158 112 times less

POEA NC NC NC NC NC NC

Cosmoflux NC NC NC NC NC NC
411

Source: DNE, 2001, NAS-PECI. The basis of estimates is the same as for Chart 4.3

above

The values and comparison shown above another conclusion that the impact on

human health for persons accidentally sprayed with glyphosate is low.

Mitigation

nonetheless, it is thought necessarypursue a set of preventive measures

400 Annex 33

designed to inform people inhabiting the ar eas under an illicit crops, about PECIG
and about the measures to be taken in the event of aerial spraying (see

Educational Communications program, Record 10). At the same time, the intention
is to pursue a program of follow-up and epidemiological research of conditions
possibly linked to glyphosate in spraying zones, in accordance with the terms

indicated in the Social Management and Compensation program (see Record
nine), and to take actions to pay compensation where it can be shown that there
was a causal relationship between the spraying and health.

Further, it is recommended that immediately prior to spraying operations, a
helicopter make a warning pass over the plot to be sprayed, in order to ensure that
people are warned to leave the illicit crop area, and therefore reduce the number of

persons exposed (see Spraying Operations Management Program), Record 1)

In the public environmental education workshops in the education program
communications program, people should be taught to take emergency measures if

they are sprayed with glyphosate, such as washing their bodies and heads with
plenty of soap, changing their clothes, and so on. Similarly, in relation to tame
animals such as horses, cows and dogs. Also, people should be taught ways to

deactivate glyphosate in the soil or water, (with absorbent material, urea, etc, as
described in impact on soil and water in this chapter, and in the Records on
Glyphosate Handling at Bases (see Record 2), and the Handling of Wastewater

(see Record 5).

4.4.2. Impact on agricultural production and livestock

Identification

During spraying operations, part of the glyphosate may be dragged by the wind
(drift effect) over cultivated areas adjacent to the illicit crops sprayed areas, having

a greater or lesser effect on production, depending on the quantity of herbicide
which falls there.

401Annex 33

Prediction

The impact of spraying with glyphosate on legal crops in plots adjacent to those

sprayed varies depending on the type of crop. On an herbaceous and crops and
pasture, the effect is similar to that on the illicit crop, that is death of the plant.
However, on shrub or tree-type crops, the effect may vary as a function of the dose

received.

Spraying operations contemplate a series of parameters, designed to reduce or
eliminate the drift effect, particularly, altitude of flight, airspeed, and safety strps

around the plant cover other than the illicit crops themselves (see Chapter 2:
"Description of the Program").

At all events, although the plant or crop may survive spraying by glyphosate, there

is damage due to possible effects on the crop, however slight.

In effect, commercial and subsistence crops in representative areas were illicit
crops are to be found have particles of herbicide which are transferred through the

phloem and cannot begin eliminated. Further, it is considered that the impact on
people who ingest leaves, roots, and grains of these crops will have no effect on

health.

In order to discover or evaluate the impact, account should be taken of the
following:

• Residual energy of the herbicide components (see impact on soil)

• Degradation (see impact on soil)

Photo 9

Cold climate clean crop area. The opium-poppy is sown in between potato, peas

and other crops.

402 Annex 33

Photo 10

Crops intercalated with opium poppy and other crops proper to cold climates. The

integrated crops are a way of preventing the authorities from detecting and
eradicating the illicit crop with glyphosate.

• Toxicity

• Tolerance to toxicity (permitted levels)
• Average and lethal doses (see impact on fauna and health))
• Accumulation in plants, soils and man (see impact on soils, water, fauna
and health)

In relation to toxicity, the establishment of tolerances of residues in materials used
for food may be standardised, following general parameters suggested by WHO
and the FAO Codex Alimentarius, but in the last instance, it is the authorities of

each country that will adopt certain "variati ons" on values suggested, for different
reasons, including the feeding habits of the country, and agreements or demands
of the market for export products.

As an example of the foregoing, we could mention US-EPA, which on its own
initiative and in concordance with FFDCA standards has set a number of combined
tolerances of residues in the parental product and in the glyphosate metabolites

(N-[phosphonomethyl]Glycone) in dried peas , shelled peas, hay, grass in silos,
lentils and kidneys (of cows, goats, horses or sheep), in the magnitude of 5, 60,
200, 90, 5 and 4 ppm respectively. These tolerances, however, EPA itself has said,

will be reviewed, and will subsequently expire.

The value of the EPA tolerances is the "legal limit permitted for the presence of
residue of a chemical pesticide in or on a given food", and only if this Federal

agency establishes that this value is "safe", meaning t hat "there is a reasonable
certainty that there will be no resulting damage due to the aggregate exposure to
the residues of a chemical pesticide, incl uding in advance, all dietetic exposures

and all other exposures on which reliable information is available". This condition
includes exposures coming from drinking water in residential estates, but excludes
those corresponding to occupational exposure.

403Annex 33

In the US regulations related to the allocation of tolerances to the various biocides,
it is also stated that the EPA must afford special considerations to the exposure of

babies and children to residues of chemical pesticides, and that it "the sure that
there is reasonable certainty that babies and children will not suffer damaging
damage due to exposure to the residues of a chemical pesticide".

In summary, it can therefore be said th at glyphosate has several tolerances for
different food substrates for a defined period of time, and subjects depending on
the circumstances, the constant review.

Further, the experience in areas visited during the Environmental Audit showed
that the re-installation of new crops on plots treated in a few weeks before with a
dose of 4.8-5 kg/ha (10-10.6 L) is successful, which is a decisive evidence that the

herbicide does not disable the land from bei ng used for new crops. It is calculated
that after 9-18 months, depending on manner and timing of the sowing, the
harvesting process can begin. If the new crops, have been subjected to pruning

immediately after the application of the herbicide, the recovery period may be less
than six months.

One way of avoiding the control of illicit crops by glyphosate spraying, common

among subsistence farmers, is to sow them intercalated with legal crops (plantain,
in the case of coca-leaf; potatoes, peas and others in the case of the opium-
poppy). In these cases, there is no control of glyphosate spraying, and therefore no

impact (see Photos 9 and 10).

Evaluation

As a consequence of the foregoing, and fo llowing the observations of Forestry
Engineer G Mahecha (this study), the impact of glyphosate spraying on crop
vegetation can be considered low, and if there is no drift, non-existent.

In worst case, in which there was maximum drift, with the aircraft reaching right to
the line between the coca leaf and the illicit crop, the stripof crops affected would

404 Annex 33

be 5 m wide, and this, with a swathe of 50 m and a spraying length of 100m, would
represent an affected area of a maximum of 750 m², that is, 15% of the area

treated.

Mitigation

In Record 9 (Social Management Program), there is provision for means of

measurement of compensation, consisting of an estimate and payment of all
damage or loss caused to legal crops affected, and indeed, this measure has
already been regulated in CNE Resolution 017/2001.

4.4.3. Impact on human settlements and migration

Identification

It has been frequently noted that aerial spraying with glyphosate generates
displacement of growers to increasingly remote areas, thus adding to the

deforested area in tropical and high Andean forests. This is an indirect impact,
which is very unlikely, negative, and medium-term.

Prediction and evaluation

Chart 4.6 and Figures 4.1 and 4.2 show se veral aspects which contradict the
theory that glyphosate spraying encourages the growth of illicit crops.

• It can clearly be seen that the spraying comes after the crops, that is, that

the greater the area of illicit crops that are, the greater the effort in
glyphosate spraying

• Nonetheless, as in 1998, although the area sprayed was smaller, the area
under cultivation had its greatest increase.

• In consequence, the fact that up to 1998 there was a linear relationship
between the area under cultivation in the area sprayed, this does not mean
that the area sprayed makes the area under cultivation increase, but the

405Annex 33

opposite.

• The correlation is shown in Figure 4.2 corroborates this, and allows the

appreciation that although the two variables are related, spraying does not
necessarily explain the growth in the area under cultivation.

Further, the important migrations which have taken place towards the areas of illicit
crop growing, especially in the Amazon basin, are prior to the time at which

spraying began, as explained in the Baseline chapter. The illicit crops are in
general not to be found in the middle of the jungle, but mostly where there was
already some settler activity which was more or less consolidated.

Mitigation.

The control over illicit crops may rather be a way to reduce the attractions of the

zones of the Amazon and Orin oco basins for poor settlers from the rest of the
country

Nonetheless, it would be necessary to act in parallel with the repressive work of the

State, to pursue programs from alternative development and infrastructure work
and public services that could give different economic options to the local
population.

This is the reason for the emphasis placed in the Social Management and
Compensation Program, in relation to this Environmental Management Program
(EMP), that the action of the eradicati on should be coordinated with interventions

designed to improve the socio-economic conditions of the local population, and to
create alternative sources of income.

The social management program in this EMP establishes a series of activities to

promote this type of support for alternative development

406 Annex 33

4.4.4. Cultural impact

4.4.4.1. Impact on indigenous communities

PECIG does not generate negative impacts on indigenous communities. On the
contrary, by combating illicit crops that have been shown to have a major impact in
deforestation and destruction of the cultur al values of these communities, what

PECIG does is to try and preserve systems from which they depend, and to reduce
the processes of territorial occupation.

4.4.5. Other impacts

PECIG will generate other additional are other impacts in addition to those
analyzed, particularly on employment, infr astructure and transport, and long-term
farming production. In all cases, these are positive forms of impact, although due to

the dimensions of the bases and their activities, they will low to very low.
Nonetheless, the operational planning activities for spraying, and above all, the
coordination with development agencies purs uing activities of promotion in the

PECIG target areas will have positive long-term effects.

Chart 4.6

EVOLUTION OF AREAS CULTIVATED UIT ILLICIT CROPS

AND SPRAYED

COCA OPIUM-POPPY MARIHUANA

Area Area Area Area
Area sprayed
Year cultivated sprayed cultivat sprayed (ha)
(ha) (ha) ed (ha) (ha)

1990 40.100 760 1.500 0 36

1991 37.500 459 2.900 1.497 7

1992 37.100 944 20.000 12.864 100

407Annex 33

1993 39.700 846 7.500 9.821 138

1994 45.000 4.904 6.800 5.314 14

1995 50.900 25.402 2.180 5.074 36

1996 67.200 23.025 2.100 7.411 37

1997 79.500 44.123 2.200 7.333 261

1998 101.800 69.155 2.033 3.077 18

1999 160.119 44.195 6.500 8.434 9

2000 163.289 61.573 6.200 9.329 122

Source: CNE, DNE, DIRAN, 2001

* * *

4.5. General Summary

figure 4.3 shows a reduced matrix of environmental impact..5.1 in chapter 5 shows
a summary of impacts, as being analysed in this chapter.

Following the above, PECIG in general has a low environmental impact, and to a

great extent, a positive one.

This situation is intimately related to the following facts.

PECIG seeks to detain the process of deforestation of humid and very humid

forests in Colombia, and high Andean woodland, by discouraging and persecuting
the most important factor in this environmental problem, which is illicit crops.

In this process, the spraying of illicit crops may generate some impacts on forests
adjacent to those crops, but that impact will be of very small and unimportant, as is

408 Annex 33

shown in this EMP. Further, where these impacts occur, they will be properly
compensated by the environmental authorities.

International scientific literature and Colombian experience in the use of glyphosate
in legal plantations shows that the herbici de degrades rapidly in soils and water, it
is not bio-accumulative, and the concentrations which it may reach in trophic

chains as a result of spraying are well below the limits established by Colombian
and international authorities as being levels at which some type of significant
damage can be caused to land and aquat ic fauna and human health. US-EPA has

accepted, based on available research, t hat glyphosate is not carcinogenic or
teratogenic, and is not a cause of delayed neurotoxicity in humans or animals.

The environmental management which will be given to the Program, which

provides for the exclusion of zones in t he Nature Parks system, bodies of water,
human settlements and areas of economic interest, as well as buffer areas with
respect to the same elements and areas of vegetation other than illicit crops.

Likewise, the program provides a set of operating procedures to reduce impact due
to spraying procedures to a minimum, along with activities for herbicide the
management of the herbicide at operational bases, and other elements or activities

which might generate environmental impact.

In this general context, the most important and numerous environmental impacts of

the project are caused by two activities: glyphosate spraying on illicit crops, and
handling at operations bases (storage, mixing, equipment maintenance, and
aircraft)

The main negative impacts of falls on legal crops which might be sprayed by
because they are very close to the illi cit crops, and on woodland in the same
situation. Nonetheless, given the techni cal and operational specifications and

security measures taken at antinarcotics bases, the importance of this impact is
considered to be low. It is also important to note the possibility of attacks on bases
and aircraft by the armed groups.

Further, the Program will have an undoubtedl y positive impact, in particular in

409Annex 33

discouraging deforestation to make way fo r illicit crops; and the contamination
generated by the drug trafficking industry in those areas is responsible for

contamination by pesticides which have not yet been sufficiently evaluated.

If we analyze the problem of illicit crops as a whole, in the light of current
Colombian regulations which catalogues them as a crime, in the light of

Colombia´s international commitments, in the area of control and production and
trafficking in drugs, and of the environmental impact environmental and
sociocultural impact of the same – of the size that drug-trafficking has caused and

continues to cause, particularly in Colombia's most fragile ecosystems, such as the
humid and very humid tropical forests and Andean woodland, we can conclude
that, without a doubt, the eradication of the illicit crops by aerial spraying with

glyphosate is a measure for mitigation of the environmental impact of drug
trafficking.

The matrix presented in Figure 4.3 summarizes the situation described in visual

terms. The total of 43 identified impacts, 23 are negative and 20 are positive. Of
the 23 negative impacts, 15 have very low importance, 6 have low importance, and
only 2 have moderate importance -and thes e two are both linked to the noise

generated by aircraft and helicopters used at the operations bases.

Of the 20 positive impacts, 8 had insignificant importance, 9 have very low

importance, and only 3 low importance.

Of all the impacts, 27 are medium and long-term (green), although they basically
refer to socio-economic impacts. The others are short-term, that is, they the action

is visible only for a few days, or weeks, or in worst case, months.

410 Annex 33

SUMMARY MATRIX OF

ENVIRONMENTAL IMPACT

PECIG
of glyphosate

. Storage and mixing
1. Detec.onpeorflcitclEpning.tiopneropasstoDrIt.Nqbuasment and aircraft

Soils -1

EartMorphodynamic processes -2

Water availability

Water Water quality -1 -1 -1

Physical mediuAir quality -1 -1 -1

Air Noise -3 -3

Vegetation -2

mdium Land fauna -2

Biotic Aquatic fauna -2

Public health + 2 -2

Employment +1 +1 +1 +1 +1 +1 +1 +1
Environmental resources and media
Human settlements, -1 -1 -1 -1 -1 -1 -1 -1
migrations
Infrastructure, traffic +2 +1

Agricultural +2 -2
Economicductionagropecuaria

Socioeconomic medium
Cultural values 0 0 0 0 0 0 0 0

Culture
.

Medium/long term impact Importance of impact 0 = Negligible
Short-term impact 1 = Very low
Negative impact - 2 = Low

Positive impact + 3 = Moderate
4 = High
5 = Very high

411Annex 33

Note: When the text speaks of very low, low, moderate, high or very high impact, it refers
to the importance of the impact, the term "negligible" means "insignificant".

412 Annex 33

[CHAPTER 5]

5. ENVIRONMENTAL MANAGEMENT PLAN

5.1. Objectives

The Environmental Management Plan (EMP) is designed to integrate the
conservation and defence of the natural and social environment into the various

activities involved in planning, operations and follow-up of PECIG.

The objective is to be reached through three types of complementary mechanisms.

• Through the integration of specifications of environmental management into

the execution of each and every activi ty proper to the program (operations
management). Integration of these environmental specifications implies no
additional costs to the Program, but considerable savings in the cost of
possible impacts. In this case, the Program seeks to respect the buffer
strips, and adopt operational parameters which will reduce the possibilities
of drift affecting third parties, and ensure that that aerial spraying take place

at certain times, when convective currents are not at their maximum, etc.

• Through activities complementary or additional to those of the program,
designed to mitigate or reduce the intensity of environmental impact which is
impossible to avoid, or with which there would be no Program at all
(mitigation or correction).

• With compensatory action, designed to compensate residual impact, in
order to make the project socially viable. This type of action is directed to
areas which suffer from the problem of illicit crops, and which such, receive
some form of impact from PECIG.

Chart 5.1 gives a summary of the environmental impact of PECIG, as analyzing the
documents, with the measures for the management and follow-up recommended.

5.2. STRUCTURE OF THE ENVIRONMENTAL MANAGEMENT PLAN (EMP)

413Annex 33

As a consequence of the foregoing, the EMP-PECIG covers three types of activity,

all complementary to each other; measures for environmental management
inherent in the course of the program operations (preventive) and measures to
mitigate inevitable environmental impact, and measures related to making the

program socially viable (compensation) (Figure 5.1)

5.2.1. Operations management: prevention measures

Aerial spraying of glyphosate on illicit crops and operations to handle herbicide at

the operations base involves a series of specific operations , each employing a
well-defining technology in the field of aerial navigation, aerial spraying, storage
and transport of the herbicide, and the preparation of mixtures, amongst others.

The activities which generate the greatest physical, biotic and socio-economic
impacts of those which relate to the spra ying of deficit on unlawful on illicit crops,
and the handling of deficit and its containers or residues at operations bases.

The following general strategies are recommended to minimize these impacts

Aerial spraying of glyphosate

In order to prevent the aerial spraying of glyphosate from affecting areas of special

ecological, social or cultural value, exclusion zones have been set up, and no
spraying operations can be conducted over them, and they are surrounded by
adequate buffer strps so that the herbicide will not reach them by wind action. The

zones in particular involve the official Nature Parks, bodies of water, human
settlements, production infrastructure, and areas of economic interest.

Further, a series of operating parameters have been set in terms of flight altitude,

airspeed, weather conditions for spraying (weak winds), doses and volumes of

414 Annex 33

discharge per hectare, and others, in order to reduce the possibilities of drift or
diversion of the herbicide to a minimum.

The environmental and operational specif ications are contained in the following
Program Records in detail for the management of spraying

Record 1. Spraying operations management program

Management of glyphosate at operations bases

The storage of glyphosate at operations bases, the preparation of mixtures, and
loading onto aircraft may generate impacts on the base personnel themselves. In

order to reduce this, a series of m easures have been set up designed to avoid
spillage or other events which would imply the loss of herbicide, and, should that
loss occur, measures have been designed to deactivate and subsequently control

the areas affected. In addition, other measures have been provided for the
handling of fuel, machinery, equipment and transport systems for glyphosate.

These measures have been organized into a set of programs or Program Records,
in particular:

2. Program for the handling of glyphosate and its co-adjuvants and operations
bases

3. Program for the handling of fuel, vehicles, equipment and transport of
glyphosate.

4. Management of solid waste.

5.2.2 Measures for mitigation and correction

The greater part of the mitigation measures have been already included in
strategies for environmental management of spraying operations, particularly for

415Annex 33

key impacts (effect of adverse effects on native vegetation, effects on adjacent
legal crops, bodies of water, National Parks, human settlements, etc).

Nonetheless, some activities require the application of special mitigation measures

Handling of domestic wastewater

Domestic wastewater is generated at each base, as water coming from workshops

and maintenance area, and the water from the washing of aircraft tanks. Proposals
are made for each type of wastewater, with a system of collection and treatment
and disposal, which appear on Record:

• 5. "Program for wastewater management"

Environmental monitoring

In order to measure the real impact of PECIG, and to take additional control

measures, there must be environmental monitoring and follow-up throughout the
period of spraying of illicit crops. For this purpose, a series of activities have been
designed, intended to measure the residuality of glyphosate in soil and water and

the effect on the ecological dynamics of vegetal and fauna communities and
microorganisms in the soil in spraying areas, with demonstration plots representing
the various zones of the program.

Further, there are proposals for instruments and procedures to measure the
operational and environmental efficacy and efficiency of spraying. In social terms, it
is proposed that there should be a follow-up of community complaints about

damage to non-illicit crops, and ongoing epidemi ological research, concurrently
with regional and local health organizations. The description of these instruments
appears in the following programs:

6. Program for inspection, verification and control of spraying operations

7. Research program for demonstration plots

8. Environmental monitoring program

416 Annex 33

9. Social management program

5.2.3. Making the program socially viable: measures of compensation

In order to make the program socially viable, in particular, in order to manage
conflict with the neighbouring communities, account must be taken of a set of
measures for compensation for damage caused, together with campaigns for

training, ecological education and attention to the health of the population exposed
to glyphosate spraying, and for base personnel required to work with the herbicide.
The description of these measures is to be seen on Records:

9. Social Management Program

10. Educational Communication Program

11. Integral Security Program for Operations Bases

12. Environmental Management and Institutional Coordination

13. Contingency Plan.

Social management and educational communication

The success of the Program, and above all, of community relations, depends on an

appropriate supply of information to the community on the scope, methods,
timetables, results and needs of local re sources for each activity involved. This
information should be given to the local population directly, and also through the

authorities and representatives of the organized community.

In parallel, the local community must be provided throughout the execution of the
program with environmental education, particularly related to resources affected by

illicit crops and their recovery, and environmental training and industrial safety for
program personnel, for the correct application of the management plan. There
should also be appropriate signposting to avoid accidents, and to report on the

project. The problem of control over the health of the local population exposed to

417Annex 33

spraying must also receive special attention by the authorities responsible for
PECIG.

Industrial safety and contingency control

PECIG must have a policy for industrial safety and contingency control as an
integral part of its environmental policy. Therefore, there Records 11 and 13 have

been prepared to give basic guidelines on industrial safety and contingency
planning which may affect spraying activities.

Environmental management

The agencies responsible for PECIG must have a system for environmental
management which will allow them to plan, execute, follow-up and control each
and every EMP program on a permanent basis, such that the application of

measures for in socio-environmental ma nagement recommended in this Plan will
be applied.

5.3. TIMETABLE

PECIG has an indefinite duration. Therefore, the EMP must also have an indefinite
duration. For detailed execution, the Commanding Officer of each operations base

is planning and executing spraying programs as described in Record 1 of the EMP.
The dates and times of each operation are set by conditions of weather, safety,
and availability report local resources, amongst others, as explained in Records 1

and 2.

5.4. COST ESTIMATES

Chart 5.2 shows the general timetable by stages, and gives general estimate of the

extra the exclusively owned and environmenta l costs of each of the construction

418 Annex 33

activities and project activities, referring to the objectives of the studies
(environmental matters).

The analysis of these charts allow allows the following conclusions:

The annual total cost of environmental activities is COP603, 942, 000 per base,
and COP4.227,594,000 for the seven bases of greatest importance, that is, COP

62,792 per hectare/year (or USD 27/hectare/year), on the basis of the 67,327 ha
sprayed in 2000.

The cost of environmental activities (mitigation and compensation) represents

5.8% of the cost of spraying per hectare of coca-leaf, and 6.3% of the cost for
opium-poppy areas (considering the PECIG costs reported in Chapter 2:
US$467.41/hectare average for coca-leaf, and US$ 429.89/hectare for opium

poppy.

Account must nonetheless be taken of the fact that most spraying operations, and
activities in the bases, imply a series of environmental specifications whose cost

forms part of the cost of each activity. It may happen that the application of these
environmental specifications will reduce the total cost of a given activity,

particularly if account is taken of the possibility of replacement for damage caused
by not applying those specifications.

The measures provided for in the EMP seek to ensure acceptable levels of

environmental quality in relation to the exclusion of the various program activities.
The estimated cost is related to the techniques recommended in the EMP Records.
Nonetheless, DNE and DIRAN are free to apply technologies which will reduce the

cost, on condition that they guarantee the same objectives of environmental quality
provided for in each of the EMP activities. At all events, changes must be
consulted and approved by the Program´s Environmental Management.

419Annex 33

CosmteofsuPr01s0107),(288)6(1) 113,1712) 128,286 (3)

Followup Con incsnitatigokgo)fRgeordos7a)te Conincsneroareo7g)roofdwhaotseart)e Abiunnaaaectr(RoRcicdibiederversitypsd(iceecsord

Compensati Poadmaen)atgfeo(rRecord Paydma9e)atgfeo(rRecord PaycomfoprResaaadn9f)opRescaadn9)

MitigationDes apcll)(Ra(tinrdsdc,y3)nts StafoirtantorhTasasnhcil,rRoecoorfds Wassphraayd als

EMP measures
Chart 5.1

PreventionResdpiseschtdgysatil,dsesscardoestol,s(Ressandhtdg.suteiur(RescindsscselgurRcocsnrictg/asentsy(RRpecdtr)feR)ysprictsafe)ty strips

SUMMARY OF PECIG IMPACT

Rating Lowlo/very Low Very low Vernyeligible Lowairaretwsihtinmwits) Lowreittitnllernlcse

Cause Glyspphrssneual) Glyspphoaisee:gsicaafphoeysrtanatg Aircrpaeftrations Glysohyrtetonl)lhoysnteh(ecrobnictiadcet)

Impact Soidlqtueatr:tioGnlyehlofvntceoaceo)Qsuatltretofsnshwbore,reilicrsnoksn Noise Affected byD drielcphfosabitrtscrtainegct on

ComponenS toil Mopprroccdrsrs:ediearesostnerin Atmreossopcrisc . Native VegeLtaanfdnannad water

420 Annex 33

CosmteofsuPr0s0,042)(4) 54,286 (5) 36,714 (6) 138,057 (7) 603,942

Followup EpiN doe.ao8eobg)eidlmfrsyttor)ede.rmedteecn(nuhn)llsointcoati(e%iroilsec)IrdoeIs)asccuIpieroject)

CompensaEtipoimdneonoforrRicclarya9yc)foprRescaagdn9I)norneaECdrt,cinennta(onrePrtrot,mininntaIneoorrPaEmon10ect (eRnInfrornEaEmon10ect (eRnofrd

MitigationWaasn hpeeCesfotiRgacScddrtea)tfoftr(lgecic.dlt3r)vltnv.mSeSNtaAtlterevltnv/mSeSnt NaA tlterevltnv/mSeSnt

PreventionResapnedmctnaiumreasgsaifase(Rtdiisehe1sr),fsase(Rtdlsrdh1sr),gfeotsyesstrip

Rating LowreittitnllervnlcseLow Very low Posvitivelolig/ible Posvitirvyel,ow Posvitioel,ow/

Cause Glyspphofioenalactann)lyspohyaretiin)l Glyspphoysiaetg Glyspphoysiaetg SpraanyinralrtadchuaidiC,n,srritiogeRScmiMsnnNistrie,s)

Impact Direlcythoesatteofspayfnfcgtodbuycdtin,DloispeccopseareaoifgPreoferabridatntiense,IivrieooisnrylacplovymeIsnnceravsies ofaasatrnudcture

$98$,2080$,02e3c0toongiplYlnoon$8lr090ld0snantata$ifj,l6nc5as,o0n8sem

(1)(2)(3)(4)(5)(6)(7)(8)The cost of the of Contingency Plan has been divided between components of soil, water, native vegetation, health and farming production

ComponenHtep alohuolfexonosed Farm production Husm etnleiraentsn/s Indcgmnmouusnities Employment InfrTastnrsturtre, TOTAL

421Annex 33

Chart 5.2

ENVIRONMENTAL SCHEDULE, EXCLUSIVELY ENVIRONMENTAL COSTS(1)

PROGRAM 1

J F M A M J J A S O N D cosrt
base

(COP000)

1. Management of
spraying ops

2. Handling of
glyphosate at
operations bases

3. Handling of fuels, 1590)0
equipment, transport

4. Handling of solid 15,000

waste

5. Handling of 79,385
wastewater

6. Inspection, 79,200
verification and control

7.Researchin 150,000

representative plots

8. Environmental -
monitoring

9.Social management, 159,714

compensation

10. Educational 36,714(3)
communications

Ints.rcaulrity 9,000

12. Environmental 52,000
management

C1on,tinplacny 21,429

bpetral 603,942

basestal 4,227,594

(1) Cost in year 1, cost per operations base/nucleus
(2) Includes only laboratory analysis for follow-up and monitoring
(3) $31,000,000 per base and $40,000 distributed between all bases

422 Chart 5.2

ENVIRONMENTAL SCHEDULE, EXCLUSIVELY ENVIRONMENTAL COSTS(1)

PROGRAM 1

J F M A M J J A S O N D cosrt
base

(COP000)

1. Management of
spraying ops

2. Handling of

glyphosate at
operations bases

3. Handling of fuels, 1(50)0

equipment, transport

4. Handling of solid 15,000
waste

5. Handling of 79,385
wastewater

6. Inspection, 79,200
verification and control

7.Researchin 150,000
representative plots

8. Environmental -

monitoring

9.Social management, 159,714
compensation

10. Educational 36,714(3)

communications

Ints.rcaulrity 9,000

12. Environmental 52,000

management

C1on,tinplacny 21,429

bpetral 603,942

baseostal 4,227,594

(1) Cost in year 1, cost per operations base/nucleus
(2) Includes only laboratory analysis for follow-up and monitoring
(3) $31,000,000 per base and $40,000 distributed between all basesAnnex 33

SPRAYING OPERATION MANAGEMENT PROGRAM RECORD 11

1. DESCRIPTION OF THE ACTIVITY

In the course of aerial spraying operations with glyphosate some very specific
conditions may arise which may potentially generate environmental and social

impact from the time that the aircraft takes off to the time it lands. During this time,
it may even be necessary to dump herbicide in full flight, either to guarantee the
lives of the crew, due to terrorist attack, or due to bad weather conditions, or

aircraft failure.

The Antinarcotics Division is responsible for assisting the safety and tranquillity of
all, through effective actions in prevention, interdiction and investigation required to

combat the many manifestations of drug-trafficking in Colombia directly, and to
ensure that these actions do not gener ate undesirable environmental and social
impacts.

The loss of vegetation cover in the forests of Casanare, Meta, Vaupes, Guaviare
and Putumayo, and of the mist forests in the departments of Cauca, Tolima, Huila
and IN the Serranía de Perijá, Motil ones and San Lucas has caused strong

imbalances in hydrographic basins and a reduction of minimum flows. These
factors are caused by a set of associated elements, such as deforestation,
spontaneous settlement, indiscriminate felling of trees, burning off, and

deterioration of water sources due to the spread of the agricultural frontier for
entirely illegal purposes, and this causes serious imbalances in water resources.

Associated with these factors, there are social problems in those areas, since

these activities generate disturbances to public order, due to the presence of illegal
groups engaged in associated illegal crimes, all to the detriment of tranquility and

public security.

424 Annex 33

In this context, the eradication of coca-leaf and other illicit crops is a general
concern in all countries where this botanical species may be grown. The

elimination of coca-leaf in the longer is justified, as a check on the negative effects
related to the production and trafficking in drugs, the damage done by the
deforestation process, and the introduction of new subspecies of coca-leaf into the

cultivation process. There are several systems available, but due to their ecological
characteristics, the location of the crops, and the systems of opposition mounted
by coca growers, the most efficient and least dangerous strategy is glyphosate

spraying from the air, taking advantage of the fact that the negative impact on the
environment is very insignificant, and very localized.

The eradication of illicit crops with herbicides applied from aircraft may be a

relatively easy task and efficient, if the conditions are right. This is not the case
here, and treatment must be conducted in abnormal conditions. In Colombia,
where in addition to technical problems, there is the opposition of the coca

growers, from seeking all possible means to counter the effect of the herbicide,
intentionally obstruct the flight of aircraft leaving tall trees in the middle of the crop,
or pruning as soon as possible after treatment with glyphosate, to prevent the

herbicide from affecting the root tissues, and ensuring that plants grow back again,
and produce harvestable leaves after 3-6 months.

Glyphosate is a herbicide used solely for agricultural purposes, and is registered

with Colombian Agriculture and Livestock Institute - ICA Licence 0756 in Colombia.
It is produced by Monsanto Company, and has been in Colombia since 1977.
Today, the company Agricola Colombiana S.A. distributes the product under the

commercial name Roundup. It has non-selective characteristics, and is used in
applications or post-emergent leaf struct ures, and is not, nor acts as, a soil-

sterilizing herbicide.

Physically, glyphosate is an amber-coloured soluble liquid, and chemically it is
composed of a concentrated polar formula of N(phosphonmethyl) glycine

isopropanoloamine salt. It is a highly biodegradable substance, and therefore does
not affect animals or the environment. It has been classified by the Ministry of
Health as “mildly toxic”, Category IV.

It has no carcinogenic, teratogenic or mutagenic characteristics, and does not

425Annex 33

accumulate in adipose tissue. However, it may cause irritation - temporary but
reversible - of the eye. Oral ingestion in quantities of more than 100 mL may cause

pulmonary oedema and hypertension.

2. OBJECTIVE

The purpose of this program is:

• To establish procedures and assign responsibilities for complying with
technical and environmental parameters for aerial spraying, which entailed
effective spraying on illicit crops sown in Colombia, in order to protect and
conserve the ecosystem.

• To establish procedures which s eek to avoid accidents, where for
emergency reasons, the pilot must fly by instruments.

• To set procedures and assign responsibilities for dumping in-flight, in order
not to exceed the maximum landing weight.

• To increase industrial safety for pilots, when for diverse reasons, the product
cannot be applied over the area allocated.

3. ACTIVITIES TO BE PERFORMED

3.1. Preventive measures

The following procedures are necessary in order to prevent accidents attributable
to equipment:

• Calibration of aircraft equipment
• Follow the technical and operational parameters for the application of the
herbicide, such as navigation procedures and this Management plan.

Calibration

426 Annex 33

Prior to each deposit spraying operation, technical personnel attached to the

operations base of the Antinarcotics Police (DIRAN) must check the operating
conditions of spraying equipment, and if ap propriate, recalibrate it. This process
must be followed in accordance with procedures established in Record to

"Handling of glyphosate and its co-adjuvants at the operations base".

3.2. Technical and environmental specifications in the different phases of
PECIG

The spraying process involves three stages (see Figure 1)

• Detection of illicit crops to be sprayed
• Spraying
• Verification

3.2.1. Measures of detection

In Chapter 2 of this EMP, there is a detailed description of each of the processes of

steps in the detection process, whose purpos e is to identify, characterize and give
a special context to areas affected by illicit crops, and to determine exclusion
zones for the program.

From an environmental point of view, the aspect of most interest in this stage is the
identification and the location of exclusion zones and alert zones. The
characterization is performed on the bas is of satellite images, aerial photographs

and available maps, with the support of fieldwork performed by operations base
personnel or ARECI personnel. The principal objective is to determine the
limitations of each operating area with regard to soil use, the presence of human

settlements, and specific environmental conditions. In particular, fragile systems
and systems sensitive to the spraying program, following criteria given in Chart 1.

427Annex 33

Chart 1

CRITERIA FOR DETAILS ENVIRONMENTAL ZONING OF CROP SPRAYING

AREAS FOR ILLICIT CROPS, WITH GLYPHOSATE

Zone type PECIG zoning

Ecologically fragile Nature park areas

Culturally fragile Indigenous reservation

. Archaeological Parks

. Historic monuments

Environmentally sensitive Bodies of water (rivers, streams,
wetlands)

. Native forest

Economically sensitive Infrastructure works: highways, airports,
reports, seaports, dams and power
stations

. Areas of manual eradication pact

. Productive project areas (PNDA)

. Irrigation or drainage systems

. Industrial zones

. Opencast mining operations

. Commercial complexes and rural tourist
areas

. Rural institutional complexes

Based on this identification and geolocation, the basic environmental zoning for
each operation must then be defined. This must take account of the categories
established in Chart 2. In addition to the exclusion zones established in Resolution

5, and those of this Program), and the securing the buffer strips (established by
Decree 1843/1991), R spraying may take place, and alert strip has been provided
for around and along each of them, within which the SATLOC system installed in

428 Annex 33

the aircraft must advise the pilot that he is close to them, and should take
precautions to avoid spraying them.

3.2.2. Measures in spraying

For safety reasons, and for the particularly special conditions of crop smallholdings
in Colombia, spraying must be performed by the fixed-wing aircraft, applying

discharges by hectare in the form of aqueous solutions, so that the spray particles
will have a defined size in accordance wi th parameters established here, in order
to reduce loss due to evaporation, and to attenuate drift.

The herbicide to be used in spraying will be glyphosate.

3.2.2.1. Reference comments on evaporation and drift

Evaporation and drift are of primary importance as problems in the application of
pesticides from aircraft. Evaporation causes "losses" of the product which will be

greater or smaller depending on the altitude of spraying, the initial size of the
particles, and environmental conditions at the time of treatment. The higher the
flight, the lower the relative humidity and the higher the ambient temperature, the

evaporation rate may reach 80% or more. Spraying from 10 m altitude has little
likelihood of reaching the surface of the crop if the initial particle size is less than

200 µ in diameter.

The problem of "drift", or lateral displacement of part of the pesticide spraying, is a
serious inconvenience, due to the effects which may have on the ecological

context of which the crops sprayed form part.

Drift depends on this be displacement of sidewinds, the height of the flight, the
initial size of the particles, the density of the chemical compound, ambient

temperature, and the experience of the pilot. It may be said that the higher the
aircraft the smaller the final size of particles, with a windspeed of over 8 kph, and
eventual presence of the phenomenon known as "inversion", the greater the drift.

429Annex 33

Chart 2

BUFFER STRIPS AND ALERT AREAS FOR ENVIRONMENTAL POLLUTANTS

APPLIED DURING PROGRAM OPERATIONS

ZONE DEFINITION HANDLING

Exclusion zones National parks

Human settlements Do not spray, buffer strip
(villages etc) of 100m

. Bodies of water

. Areas of areas of socio-
economic interest

. Areas with vegetation, Do not spray. Open and

other than illicit crops close tap inside the illicit
crop plot

. Smallholder illt rops Manual eradication. Do

not spray

Restriction zones Nature parks 1000m alert strip

. Fringe around human 1000m alert strip
settlement

. Perimeters around bodies 1000m alert strip

of water

Zones around areas of
socio-economic interest 1000m alter strip

Intervention areas ´ Areas occupied by Spray with glyphosate.
industrial illicit crops

Source: DNE

430 Annex 33

3.2.2.2 Operating parameters

During spraying it is therefore necessary to comply with a series of technical
navigation requirements and spraying requirements, in order to reduce the
potential impact on vegetation cover or neighbouring crops other the crops to be

sprayed. These parameter range from flying height, speed, size of droplets or
particles of herbicide, nozzle type, pressure of the spray pump, and through to the
time of application, wind speed, relative humidity and other favourable atmospheric

conditions.

Chart 3 shows the operating parameters to be met during spraying operations.
These predators have been calculated taking account of Colombian Agriculture

and Livestock Institute - ICA recommendations, so that coca-leaf crops of less than
one year old should use 8 L of glyphosate diluted into 15,413 L of water and full
crops more than one year old, the maximum of 10 L of glyphosate (commercial

formula) diluted into 13,423 L of water.

Chart 4 is the composition of the mix and lived in the aircraft for different types of
slope on the ground.

The following are some comments in relation to glyphosate and its effects, based
on direct experience, by Dr Miguel Revelo Ph.D. in phytopathology, who is
collaborating in the activities of Environmental Audit for PECIG, and they are to be

taken as the basis for suggestions and later to improve the effectiveness of
spraying.

Chart 3

PARAMETERS OF OPERATION IN PROGRAM FOR ILLICIT CROPS
ERADICATION, BY AERIAL SPRAYING, T65 AND OV10

PARAMETER UNIT/ VALUE/RANGE VALUE/RANGE

MEASUREMENT OPIUM
(i) POPPY
COCA

431Annex 33

HEIGHT OF FLIGHT M Less than 25 Less than 12

Airspeed mph (T65) 120 - 150 120 – 150

Flight speed knots (OV-10) 180 - 200 OV-10 (No aplica)

Aircraft load gals 350 – 500 - 800 200 - 350

Discharge planned L/ha 23,65 50

Glyphosate discharge Mm3 /cm.2 0,0384- 0,0480* 0,0096- 0,012*

Commercial L/ha 8 – 10 2,5
glyphosate

Droplet size Micras 300 – 1000 300 - 1000

Optimum time for Day/night 5:30 a 10:0 5:30 a 10:0 A.M.

spraying A.M. 4:00 P.M. a
3:00 A.M

Magnitude of % of area 75 % - 80 % 75 % - 80 %

recovery sprayed

Pump pressure Lb/ r cm.2 (psi) 20 - 25 20 - 25

Width of swathe M 25 - 30 25- - 30

Drift projected M < 5 - 7 < 5 - 7

T.V.B nozzles. Mm orifice 2 2

Ambient temperature °C > 30 C. > 20 C.

Relative humidity % 75 - 90 % 75 - 85 %

Windspeed m/s 0 - 2,0 0 - 2,0

*Due to the magnitude of recovery, the effective doses calculated as 20% less than
that discharged

for coca-leaf crops in less than a year old, use 8 L of glyphosate diluted in 15, 413

L of water

Full coca-leaf crops more than one year old, use 10 L of glyphosate, diluted in

432 Annex 33

13,423l of water

In both formulation, add 236 cm³ of Cosmoflux

Source: this study

Chart 4

COMPOSITION OF THE MIX IN LITRES AND GALLONS

The load depends on the type of aircraft available for operations

CROP

DOSE MIX AIRCRAFT % SLOPE
LOAD/GALS
L/HA L/HA

COCA 8 - 10,0 23,65 250 > 30 %

COCA 8 - 10,0 23,65 350 10 - 30 %

COCA 8 - 10,0 23,65 800 < 10 %

OPIUM POPPY 2,5 51,09 200 > 30 %

OPIUM POPPY 2,5 51,09 250 20 - 30 %

Source: Antinarcotics Police.

3.2.2.3. Opinions, and proposal to improve spraying operations

Residuality

The concept of residuality is very broad. If the idea is to assess the persistence of
molecules and the biocide activity of the herbicide, it is easy to state that
glyphosate is not residual, because the parental molecule deactivates itself and

433Annex 33

metabolizes in a few days in tropical soils.

The presence of renewed populations of weeds in coca-leaf products in plots

treated a few weeks before is also reliable testimony that the molecules of the
herbicide deactivate themselves in a short time and they do not leave residues
which hamper plant growth.

The persistence of the effects of glyphosate must be understood as the time
necessary for crops treated to recover after pruning, during the 24 hours following
treatment. If the plant is pruned, the process of recovery may take 4-6 months.

Reinstallation of new crops

The installation of new crops in some plots treated a few weeks before with doses
of 4.8-5 kg/ha (10-10.6 L), is successful, and this is definitive evidence that the

herbicide does not disable the land for new crops. It is calculated that after 4-18
months, depending on the manner and timing of sowing, the harvesting process
may begin. If the crops come from crops which have been pruned immediately

after the application of herbicide, the recovery period may be less than six months.

Symptoms of ill effects caused by glyphosate on coca-leaf crops

Two weeks after the treatment date the following symptomatic manifestations
should be evident. It should be noted that the presence of new shoots may occur in
the plants treated and pruned within 12 hours, or in plants which due to failures of

application or some other reason, are not reached by the glyphosate spray.
Symptoms of damage are slower to appear in woody plants more than two years
old.

− Foliar chlorosis

− Defoliation
− Necrosis of secondary branches
− Necrosis of main stems
− Necrosis of roots

434 Annex 33

− New shoots
− New buds

− Effect on weeds
− Effect of drift on surrounding vegetation.

Two weeks after the application, there should be strong symptoms of damage to
un-pruned plants. After 8-12 weeks, the degree of effect should be total, and

necrosis should be complete, including their root systems.

It is possible that defoliation, as the first visible symptom of the effect, meaning
becoming visible two weeks after treatment. Initial symptoms of necrosis may also

be present 8-10 days after treatment.

The application of a dose equivalent to 4 kg of active ingredient per hectare, may

produce some degree of control of use of 5-6kg of active ingredient, if conditions of
application comply with at least 80% of each of the parameters given above.

If conditions of application are not lower than 90% of compliance with the

parameters indicated in Chart 3, the percentage of control will come close to 80%,
with treatment of 3-4 kg of active ingredient per hectare after 12-16 weeks in un-
pruned plants.

Weeds present in the soil of coca-leaf plots are also affected by glyphosate
spraying, but, unlike the coca-plants themselves, the gramineous weeds begin to
show significant recovery after 1-2 mont hs. But if environmental conditions are

favourable (rain), a sprayed area will again contain vegetation a few weeks later.

The damage attributable to drift over surrounding trees around the coca-leaf
plantations is identifiable after 2-3 weeks, but does not seem to have lethal effect

on the majority of species. In several observations, it was evident that the
defoliation was greater and more pronounced in the single species of "Guarumo", a
silver-leafed plant of the Cecropia genus. After 12 months between the trees

recover their foliage.

435Annex 33

Procedures to improve operating capacity of aerial spraying.

There are many reasons for designing procedures which will increase the
operational efficiency of aerial spraying, and with aircraft available for aerial
eradication with glyphosate, without exceeding technical or economic thresholds.

Taking advantage of the fact that there is no technical problem in reducing the
volume of the application in the final mix, without affecting the efficiency or the
parameter to deposit 25 - 50 drops of 300-1,000 micra diameter per square

centimetre of foliage, spraying equipment can be adjusted to reduce the discharge
of the mixture to no more than 7-8 gallons (26-30 L), to take advantage of the
capacity of the operating aircraft, about 450 gallons.

The average diameter of most spraying particles and should be 30-1000 micra.
This is a good strategy to reduce the magnitude of drift.

Treatment and estimated time for recovery of plants pruned after application of the

herbicide allows the calculation that it will not be necessary to re-spray for the three
months, or before 6-12 months in the case of pruned plants.

Basis for a specific alternative

There is increasing evidence that the "growers" proceeded to install new crops
when the effect of glyphosate has caused the death of rather more than half of the
plants, and this allows consideration of t he idea that it would not be necessary to

make efforts to kill around 100%, so that the growers would be forced to
replacement, investing in new costs and time. In theory, it is possible to expect that
company crops spraye d six months before will include some of the following

categories

• The magnitude of damage was high, and forced the growers to abandon
• The damage was small and partial, and crops are in a recovery process

436 Annex 33

• Crops are in production with new branches, emerging from pruned stems
• There are new crops in the initial stage of development. This suggests that
the coca-leaf growers have started new crops, using the same ground

All of the foregoing is certain, and allows the advantage to be taken of a specific
situation in order to set a target of the destruction of no more than 70-80%, thus
reducing cost, without forcing the growers to abandon them or to renew them with

new crops.

There are several alternatives to achieve this, including the use of spraying

operations arranged to leave areas with small discharges of the mix, by plugging
some of the nozzles, and this would also reduce the expense of the herbicide, and
increase the capacity for coverage over t he area in each flight. The following data

to estimate of the percentage magnitude of the increase

Aircraft with a 54 nozzle boom

• Use 40 nozzles, treat 10% more than hectares calculated

• Use 43 nozzles, treat 20% more than hectares calculated
• Use 38 nozzles, treat 30% more than hectares calculated

3.2.3 Verification

The purpose of this stage is to evaluate the efficiency and effectiveness of spraying
operations. The procedure is explained in Chapter 2, and in Record 6 "Programs
for inspection, verification and control" of this EMP.

Figure 1 also shows the decision tree for development of each activity in detection,
spraying and verification.

3.3. Compliance with their safety standards

437Annex 33

Using intelligence reports received, the Base Commander will coordinate with the
illicit crops eradication area for the movements of fixed wing aircraft with FLIR

intelligence equipment, so that during the morning hours, they can go to the
spraying area in order to detect the presence of guerrilla groups.

3.3.1. Air safety standards for pilots

For this type of operation, pilots must have taken and passed the spraying course
normally given by Colombian Agriculture and Livestock Institute - ICA.

Crews must have their flying -time record for this equipment up-to-date, as well as

the medical licence, and be entirely clear about their functions for each operation.

3.3.2. Safety standards for aircraft operations

Bases must have manuals for spraying equipment published by the manufacturer,
and manuals for the aircraft used for spraying and escort duties.

Personnel engaged in operations must be aware of the effect of the products used

in spraying, on plants, animals and humans, and rules to be observed for
permanent and safe application

The fumigating pilot must be aware of flying techniques and application product for

safe operations and on the yield and limitations of operation of the aircraft used.

• At the end of the day's operations, the aircraft flight log will be completed,
detailing hectares sprayed, place of application, and number of flights made,
and any contingencies arising. At the same time, maintenance personnel

should be allowed to correct any failures reported, and to wash the spraying
equipment in general.

438 Annex 33

• Auxiliary personnel assigned to spraying work (those working tanks, mixers,
etc), should be trained, in order to avoid accidents and damaged equipment.

• There should be an anticorrosion and decontamination program for the
equipment used on the aircraft.

• Each base must have a spray aircraft inspector or technician, specific to the
aircraft type.

• Spray aircraft must be operated on landing strips which comply with
technical conditions

• Once the aircraft has finished spraying, it must go for refuelling, and remain

permanently on standby

• All aircraft must have the SATLOC analysis system installed and
functioning, both in spraying and reconnaissance. This is a legal
requirement, and more exacting that the PECIG for geo-referencing the
areas sprayed.

• The method to be used by fumigation airc raft will either be "racecourse" or
parallel lines. Depending on this method, safety measures should be applied
is established for escort aircraft, determining altitudes independently
depending on the nature of each type of aircraft and specific mission

missions.

3.3.3. Operating safety standards for helicopters

• The Police Aviation Division helicopt ers will provide support and security,
search and rescue in the program, and must have the equipment required

for this mission.

• Each helicopter will carry binoculars, bullet-proof vests, machetes, a
chainsaw, first aid equipment, smoke grenades, air-ground radios, and other
equipment considered necessary for this type of operation.

439Annex 33

• The Head of Zone or the Company Commanders will be responsible for
conducting and arranging the operation, maintaining permanent
communications with the Illicit Crops Eradication area of DIRAN.

• Three helicopters in the first securi ty ring of the operation will provide
firepower in support, and search and rescue during spraying operations.
The must be a minimum basic package of helicopters to be able to conduct
spraying operations under the expected standards of protection and
effectiveness.

• Helicopters should not land on crop areas unless there is at least one other
escort aircraft providing security.

• Helicopters engaged in spraying areas must at all times keep their doors

open and secure, and the gunnery officer and the technical officer in
position and ready with minigun and M-16 machine guns.

• Artillery officers will have complete set of implements for the work (bullet-
proof vests, helmet, communication with the crew)

• Helicopters must install additional earphones for the exclusive use of the
Company Commander commanding the operation.

3.4. General recommendations

• There should be a paramedic or combat medic in all spraying operations

• Always leave reinforcement personnel available to attend to any
requirement whenever a spraying flight departs.

• All aircraft will receive daily maintenance

• Instructions given to ground personnel in the Antinarcotics Group with
regards to helicopter operations, leading, safety measures, etc

440 Annex 33

• When a flight begins, the anti-collisi on light should be switched off after
leaving the terminal

• If possible, spraying should not be combined with any other type of
operation

• Full availability must be maintained for aircraft and crew for the execution of
this plan

• Spraying equipment must be calibrated daily, and aerial spraying monitoring
equipment must be calibrated once a month.

• Bullet-proof vests must be used by all personal taking part in the aerial

spraying program.

• If weather conditions are adverse at the base, but favourable in the illicit
crop area, an aircraft should be sent to make reconnaissance and report
whether it is feasible to spray that area, or definitely cancel or postpone
spraying.

• ARAVI standards require that a flight order be prepared for all aircraft.

• The mixer (water and glyphosate) must be used to facilitate the refuelling of
fumigating aircraft, complying with environmental health and hygiene

regulations.

• Account will be taken of the Environmental Audit, Colombian Agriculture and
Livestock Institute - ICA and other environmental authorities, following
parameters established in the environmental model.

3.5. Communications

DIRAN contact points

Phones Bogota

441Annex 33

Antinarcotics Division 368 7164

Antinarcotics SubDivision 221 4005

Aviation Area 276 7995

Illicit Crops Eradication Area 413 5173

4 SCHEDULING

The spraying of illicit crops is permanent, because the crops are a crime, and this

is the chosen method for the authorities to eradicate them

5. FOLLOW-UP AND MONITORING

Follow-up is the responsibility of the DNE Social Management and Environment

Department and DIRAN, including coordinat ion with the control bodies, who will
make regular inspections of installations, operations and working areas, as
established in the Program Records for inspection, verification, control and

monitoring and environmental follow-up.

6. ACCOUNTABILITY

The illicit crops eradication work will at al l times be coordinated by the Head of the

Illicit Crops Eradication area.

The appropriate development of the integral security of the program is the
responsibility of the Commanding Officer of the operations base, accountable to

DIRAN.

7. COSTS

442 Annex 33

Costs correspond to the costs of the program. There is no additional environmental

cost, because the above specifications ca n and will be applied in the execution of
spraying operations.

END OF PROGRAM RECORD

443Annex 33

LOCATION OF
FLOW CHART 
PECIG 1  ILLICIT CROPS


 
 
 

THERE IS INTELIGENCE    THERE ARE SATELLITE 
INFORMATION    IMAGES 
 

YES  NO  YES  NO 


FIELD   FIELD  
CORROBORATION  CORROBORATION

SCHEDULING OF OVER  SCHEDULING OF OVER 
FLIGHTS  FLIGHTS
D
E

THERE ARE  THERE ARE NOT  T
E
C
THEY ARE CROPS BIGGER  SCHEDULE OVER 
T
THAN 2 HA  FLIGHTS  I
O
N
YES  NO

GATHERING OF FIELD  
INFORMATION OR BASIC INFORMATION 

DETERMINING BASIC OPERATION AREAS 

THERE ARE AREAS OF HUMAN SETTLEMENTS 

YES  NO 

CONTINUE

APPLY WITH BUFFER ZONES 

444 Annex 33

2
FLOW CHART 

PECIG 2   
 

 
THERE ARE AREAS PROTECTED BY THE   
NATIONAL NATURAL PARKS SYSTEM  

 
YES 
NO 

D
E
APPLY WITH BUFFER ZONES  CONTINUE T
E

C
CONTINUE  T
I

O
THERE ARE BODIES OF WATER NEARBY  N

MOVING AND/OR STATIONARY 

NO
YES 

APPLY WITH BUFFER ZONES 

SELECTING DEFINITE TARGET AREAS 

OPERATIONAL PLANNING  4

HUMAN RESOURCES AND EQUIPMENT  INFORMING NATIONAL ENTITIES  S
ARE AVAILABLE  P

OPERATIONAL INFORMATION   R
NO REQUEST THEM WAIT PRESENCE OF ARMED GROUPS  A
YES  Y
I

THERE ARE AREAS OF HUMAN  YES NO  N 
SETTLEMENTS  G

REQUEST FURTHER  CONTINUE
YES  INFORMATION 
NO  ASK FOR GROUND BACKUP 

APPLY WITH BUFFER ZONES  5 
CONTINUE
WAIT UNTIL CONDITIONS 

4  4  ARE FAVORABLE 

445Annex 33

FLOW CHART  5
PECIG 3 

OPERATION 
 
   DEVELOPMENT 

 
IT WAS VERIFIED THAT THE AREAS ARE BIGGER 
  THAN 2 HA AND THAT BUFFER ZONES WERE 

APPLIED

YES 
NO 

CONTINUE 

DEVELOPMENT OF SPRAYING PHASE

S
MEETING WITH OPERATING PERSONNEL P
R

A
Y
FLAT OR ONDULATING LANDSCAPE  WAVY TO MOUNTANOUS LNDSCAPE  I


LINES METHOD HORSE TRACK METHOD  G

AREAS PLANNING IS MADE 

DATA ON COORDINATES ARE FED INTO THE SATLOC 
SYSTEM 

INTELLIGENCE INFORMATION IS VERIFIED 

IT IS FAVORABLE IT IS UNFAVORABLE 

INITIAL RECCONAISSANCE   IT IS POSTPONED 
OVER FLIGHT 

446 Annex 33

FLOW CHART  6
PECIG 4 

 
  WEATHER CONDITIONS ARE 
FAVORABLE 
 
 
YES   NO

 
CONTINUE IT IS POSTPONED

S
EXECUTION OF ACTION PLAN P

R
THERE IS HOSTILE FIRE  THERE IS NO HOSTILE FIRE A
Y

CONTIGENCY PLAN SPRAYING IS CONDUCTED I
N
G
IT IS POSTPONED AIRCRAFT ARE PUT AWAY

REPORTS, MINUTES, POLYGRAMS, 
SATLOC RECORDS

END OF OPERATION

PROGRAM VERIFICATION

SELECTION OF PLOTS

OPERATIONAL PLANNING THERE ARE  V
SAFETY CONDITIONS E

R
YES NO I
F

FIELD TRIP GATHERING OF  IT IS POSTPONED I
INFORMATION C
A

‐ ENVIRONMENTAL VERIFICATION  T
‐PECIG EFFICACY VERIFICATION I
O
N
YES  NO

END OF OPERATION RESCHEDULE SPRAYING  INSPECTION, VERIFICATION, AND 
CHECK CAUSES CONTROL 

Figure No. 1 
FLOW CHARTS PROGRAM FOR ERADICATION OF ILLCIT CROPS BY SPRAYING WITH GLYPHOSATE ‐ PECIG

447Annex 33

 

D
I

S
T
A
N
C
E
S




e  
 

o.  

 
2   

 

 

 

448
  Annex 33
 





e  
 

o.  

 

LEGEND 
   CA: Bodies of Water 

  ZU: Urban Areas 
Crops located at less than 100 meters from bodies of water 

  Crops located between 100 and 1000 meters from bodies of water 
Crops located over 1000 meters from bodies of water

 

449Annex 33
 





e  
 

o.  

 

PUTUMAYO PROVINCE 

LOCATION OF PRODUCTIVE PROJECTS – PLANTE 
 
MUNICIPALITY CAPITAL 

AREA OF 2 Km ON EACH SIDE OF THE RAOD 
AGREEMENTS AREAS 

AREA OF ONGOING PROJECTS – BUFFER ZONE 
PROCESSES WITH INDIGENOUS COMMUNITIES TO BE STRENGTHENED OR IMPLEMENTED
 

 

 
450 Annex 33

 





e  
 


o.  

 

BUFFER ZONES FOR PRODUCTIVE PROJECTS ‐PLANTE 

MUNICPALITY OF PUERTO ASIS – PUTUMAYO PROVINCE 

 

 
451Annex 33

PROGRAM FOR THE MANAGEMENT OF GLYPHOSATE AND RECORD 2
COADJUVANTS IN OPERATION BASES

1. DESCRIPTION OF THE ACTIVITY

The degradation of environmental condi tions in and around the operations bases

and neighbouring areas originates in residues caused by cleaning work on
spraying equipment after each daily run, and the continuous accumulation of empty
containers and packing materials for the glyphosate and other substances used in

the formulas in the illicit crops cont rol program. These processes may cause
contamination of water and soils 3, principally, and may affect the health of base

operators.

The possible contamination by formulations for the use of glyphosate may originate

in defective functioning of spraying equipment, or in the way in which the spraying
is conducted. This is a preventive operation, designed to avoid the consequences
of defective spraying, and although the degrading impact on the environment is

evident on the area of influence of the illicit crops, the task of equipment calibration
must be conducted within the area of each operations base.

Within the base, a series of tasks related to the handling of glyphosate take place -
such as storage, the preparation of the mix, the loading of aircraft, the unloading of
excess materials, and the handling of residues of contaminating products. The

standardized handling methods must include all procedures required to prevent
contamination of the operations base area, and avoid the occurrence of any

environmental impact which would damage the health and welfare of human
populations working there, or living in the geographical area of influence.

A second factor of importance is related to the work of the maintenance of spraying
equipment, and the process of calibration before spraying operations. The
personnel directly involved in these tasks are the ground operations group, under

                                                            
37 Decree 2811/1974 states that “contamination is understood to be …..” 

452 Annex 33

the direction of the expert responsible for the process of calibration, and the pilots
responsible for operating the aircraft selected. It should be noted that the aircraft

pilots must have attended one or more talks and technical workshops related solely
and specifically to the pesticide spraying process in phytosanitary work.

2. OBJECTIVES.

There are two very specific objective s for operations conducted in operations
bases for glyphosate spray aircraft.

• Prevention and mitigation of impact in the base operations area, and in the
health and welfare of personnel responsible for making the mixing and
maintenance of the spraying equipment, due to mishandling of glyphosate
and coadjuvants used in the formulation for its use, including Cosmoflux.

• Guarantee of the correct calibration of equipment or spraying equipment, so

that discharges of the herbicide will match the technical parameters
required, and that the dose of glyphosate and its coadjuvants will be the
smallest required to guarantee the destruction of the illicit crops, in
quantities and magnitudes sufficient to disable the production of the illegal
plantation completely. This objective, however, maintains the unchanging
condition that herbicide spraying may not go outside the safety margins

provided for in each phase or action of the spraying process, and that the
magnitude of drift or any other damaging impact will not contaminate
stillwater bodies or currents of water, and will not cause degradation of other
components of the ecological system lin ked to the illicit crops, and niches
inhabited by human populations.

3. ACTIVITIES

3.1. Handling of glyphosate

3.1.1. Storage

453Annex 33

The following general measures are recommended for application in each base for
the storage of the herbicide and its coadjuvants

• A well-ventilated covered space should be made available, with a hard
surface (concrete floor) to store drums and packages of all kinds. Metal
platforms can also be used, with two mobile leaves placed at an angle to
each other, in order to facilitate drainage of possible spills. The storage site
should be protected appropriately to prevent and hamper the entry of

unauthorized personnel

• The raw materials storage area should have shelving and divisions to
ensure that products are appropriately se parated with sufficient currents of
air, ventilation and lighting.

• For the process of preparation of the mix, there must be a platform with a
concrete floor, easy to wash, located outside away from the landing strip. A
concrete channel 30 cm wide should be constructive around the area to
collect up possible spills.

• The preparation area for agricultural chemicals must be well ventilated and
easily washed

• At the end of the channel, at the lowest part, et al will be built to collect up
product, with sufficient capacity to store in volume of glyphosate normally

stored on the base (for security and safety reasons, only one week´s supply
of herbicide is stored at a time) they should also have independent spaces
for the following purposes:

o Space for administration and attention to officers and visitors, away from
the areas used for the management, handling, preparation and storage

of pesticides.

o There should also be an area for the storage and consolation of
equipment, spares and protective devices.

o Room with two-door wardrobes, for operators´ use.

454 Annex 33

o Showers and toilets.

o Area for washing machinery, equipment and contaminated clothing, and

some treatment of waste and residues. These areas should be equipped
with separate installations.

o Area for first aid supplies and implements.

o Other requirements of the competent authorities, justifiable due to the

particular nature of the phytosanitary activities, or the kind of products
handled.

o It would be desirable for storage spaces and compartments to be
separated by galvanized chain link fencing, with 3-inch pipe or section
structures, except where special conditions of humidity and temperature

other than those prevailing in the surrounding environment prevail.

• It would be advisable to set up signposting for areas in order to
prevent accidents and to restrict mobilization to the areas mentioned
(see Educational Communication Program-Record 10)

• In order to minimize accidents, the supply of herbicides should be
effected taking account of all safety measures (see Integral Safety at
Bases Record).

• A ditch should be constructed to collect up rainwater, discharging into

the base rainwater systems discharge system (see Wastewater
Management Record).

• It is recommended that some firefighting equipment be available, with
sufficient capacity to attend to possible risks in the operation.

• It would also be appropriate to maintain sufficient equipment to attend
to the needs of collecting up spinet herbicide spillages on the soil and
in water.

Figure 1 shows the general scheme of an operations base, without taking account

455Annex 33

of the wastewater treatment plant, which would be built outside it.

3.1.2. Preparation of the mix

The process of preparation of the mix of glyphosate in the illicit crops control
program should be developed exclusively in installations controlled by the Police.
The following specifications and rules should be observed when preparing the mix,

• The operation follows standard, mandatory regulations contained in Ministry
of Health Decree 1843/1991, and add certain Colombian Agriculture and
Livestock Institute - ICA regulations, although the Colombian Agriculture and
Livestock Institute - ICA regulations apply especially in the case of
registered by discharge operations on agricultural crops (Resolution

3079/1995)
.

• Equipment must be in perfect working order, to avoid any kind of hazard to
the operator, or damage in the community or the environment, and must be
permanently maintained, in accordance with technical specifications

supplied by the manufacturer or its representative in Colombia.

• Washing equipment should take pl ace in specially-assigned places,
avoiding risks to operators and contamination of water sources. Wastewater
should also be discharged into the treatment system (see Wastewater
Management Program-Record 5).

The mixture should be prepared following the doses established for an optimum
effect on illicit crops, without causing damage to the environment. The date of
application, the characteristics of the mix with water and the coadjuvant and total

volume of discharge are shown in Chart 1. The volume of mix applied or
discharged with reference to the type of cr op, that is, the effective mix discharge is

23.65 L/ha for coca-leaf, calculating for a 28-nozzle room with holes 2 mm, 1.6 mm
and 1.2 mm in diameter.

3.1.3. Herbicide load on aircraft

456 Annex 33

Although police operations in the illicit cr ops control program are regulated by an
exceptional provision of law, some of the proposed provisions of Decree

1843/1991 continue to be applicable. For t he main operations base, two special
conditions will apply. First, the need to have an operating platform for the
preparation of formulations of the pesticide used, which must be located outside

away from the landing strip, and built of compacted materials and paved concrete,
in "a total area in accordance with the operating capacity, and with drainage
effective drainage range slopes towards the waste treatment system". Further, this

platform may not be accessed by unauthorized personnel.

For the loading system of the pesticide, the installations of the operations base
should have a closed-circuit system which allow the transfer of the product from

the mixing tags to the spraying equipment fitted to the aircraft, without causing
spillage or environmental contamination.

Chart 1

DOSE OF APPLICATION AND COMPOSITION OF THE MIX USED, BY TYPE
OF CROP

MATERIAL COCA l/ha) OPIUM POPPY

(l/ha)

Commercial glyphosate formulation 8-10 2.5

Coadjuvant Cosmoflux 411 F 0,23 0,5

Water 15,42 - 13,42 47

MIX RATIOS (%)

Commercial glyphosate formulation 34 - 42 5

Coadjuvant Cosmoflux 411 F 1 1

Water 65 - 57 94

DISCHARGE OF MIX PER HECTARE (L/ha)

DISCHARGE OF MIX per hectare 23,65 * 50

Source: Antinarcotics Police Directorate 2001*Calculation in accordance with the

457Annex 33

recommendation of Colombian Agriculture and Livestock Institute - ICA, 10 L/ha of
commercial formulation diluted in 13.423 L per hectare, and 8 L/ha of commercial

formulation diluted into 15.42 L.

3.1.4. Personal equipment

Following Articles 176-181 of Decr ee 1843/1991, environmental and personal

protection protective measures must be applied, and compliance will be supervised
by the Ministry of Health or it is delegate, which will have powers to determine the
existence of risks, and give mandatory instructions on specific measures or

devices to be applied in order to elimin ate or control the risk of sickness or
accident. They may also prohibit any act or omission which reduces the
effectiveness of the means of control of risk control for human and environmental

health.

The basic equipment required for operations of those is that indicated in the
Integral Safety Program (see Record 11)

Colombian law also requires the availability of toilet facilities, medical control and
care services, and other sundry obligations to be met by operating personnel, as

detailed in the Integral Safety Program (see Record 11)

3.1.5. Deactivation, elimination, destruction, disposal of wastewater, non-

usable pesticide residues, and empty packaging and containers.

The elimination of glyphosate-contaminat ed liquid and solid residues is shown in
the Wastewater Management Program (see Record 5), and the Solid Waste

Management Program (see Record 4) of this EMP.

458 Annex 33

3.1.6. Training courses and processes

Following current regulations, operating personnel must have access to theoretical

and practical training courses or processes, for a total of minimum of 60 hours
accumulated over one year. Content and form are detailed in the Educational
Communication and Training Program. This ta sk is the responsibility of the entity

contracting the services of the personnel, and if they have met this requirement,
this requirement is more of an informative nature.

3.1.7. Technical manual for aerial spraying

Operating personnel, including pilots, must be fully aware of the reasons and
technical basis of each phase of glyphosate spraying, and the importance of
margins of drift and evaporation - simply as examples - because these procedures

give a better understanding of the validity of thresholds permissible for each task.
Experience in other phytosanitary work is very positive with regard to the value of
some reference publications.

3.1.8. Other general recommendations

The following additional measures ar e recommended in order to enhance the

efficiency of spraying operations:

• Do not combine nozzles of different diameters, because this will not give
uniform spraying

• Clean nozzle filters after each operation, because they fill up with dust from
takeoff and landing.

• In principle, nozzles should be inclined at 180° to guarantee droplet size.

3.2. Calibration of spraying equipment

459Annex 33

One of the objectives of PECIG is to prevent negative impact on components of

ecological systems intervened with illi cit crops of coca-leaf, opium-poppy or
marijuana. One good measure to assist comp liance with this purpose is to effect
spraying within the guidelines in the reference parameters designed for this (see

Spraying Operations Management Program, Record 1), and to minimize in
advance a good part of the dangers of the adverse effects due to the employment
of badly-calibrated equipment, or equipment in poor working order. The greater

magnitude of drift is due, in a large number of cases, to spraying effected with
winds which are beyond limits.

Although the illicit crops eradication program has a long history in Colombia, there

have always been (and possibly, there always will be) doubts about the
convenience or otherwise of spraying. There is a wide range of arguments, but
principally, there are allegations of damage to flora surrounding the crop as a result

of the partial drift of some of the herbicide sprayed.

3.2.1. Characteristics and aircraft for glyphosate spraying

The aircraft selected for this glyphosate spraying operations are TurboThrush T-65,
OV-10 and Air Tractor which can be fitted with spraying equipment and which can
be directly calibrated from the aircraft and control system, as is the case of the

procedure recommended for some new versions (Del Norte Calibration
Procedures). In this particular case, the procedures used are summarized in the
description below, showing that it is an activity which is almost entirely conducted

by the pilot in command of the aircraft.

3.2.1.1. Parameters selected for Del Norte test

Width of swathe 170 feet (51 m) OV 10)

Discharge flow 2.5 gallons per acre (6.17 gallons per hectare,

460 Annex 33

23.38 L//hectare)

Calibration No. The pilot uses the value in the flow metric sensor

Pump pressure: 55 psi

Airspeed 208 mph

Procedure for electronic calibration (T-65 and OV-10)

1. Check the inside of the mix-tank, to ensure that the recirculation system is

working correctly.

2. Drain liquid from the tank and booms

3. Fill tank with 300 gallons of water, and mark with a sticky tape where the surface
of the 300 gallons of water reaches

4. Measure and mark the position of extension of the strut

5. Spray with water in a straight line until the panel spraying meter in the cabin
shows 200 gallons, at a height of 30 m for coca-leaf and 15 for opium poppy

6. Land and park aircraft in the same spot on the ramp

7. Ensure that the extension of the strut is the same as before taking off.

8. Refill the tank with water up to the mark previously placed

9. Measure and note the number of gallons of water added to the tank

10. If a difference detected, adjust the calibration numbers on the device to
compensate the difference

11. Make test flights as required, until achieving the correct calibration. DIRAN will

demarcate or set zones for this activity to be conducted

12. After calibration with a long spraying passes, the aircraft should be calibrated
for short spraying passes, simulating real conditions. More calibration passes may

be required until the correct mark is achieved.

During calibration process, anti-foam material must be used possible.

461Annex 33

After the calibration process it may be necessary to recalibrate, using glyphosate.

A log should be kept of all the information obtained in the calibration process,
including the name of the person performing it, the pressure, pump pressure,
spraying time, and gallons sprayed.

It should be noted that the volume of gallons sprayed is indicated by measures
measurements made at the time of reloading the tank, and during the calibration
process. The flow rate for spraying appears in the Del Norte or SATLOC device on

the cockpit panel.

3.2.1.2. Traditional calibration processes

The aircraft. T-65 and OV-10, fitted with appropriate spraying equipment and high-

precision systems to identify treatment plots.

Calibration

The process of calibration of calibration of spraying equipment should be a routine

task, conducted as frequently as necessary to obtain relative security that any
abnormal occurrences during spraying are not due to malfunctioning or deficient
calibration of spraying equipment.

PECIG is an operation of great importance to Colombia. This fact, and the need for
preparation and tests before each operation were decisive in the preparation of a
summary of technical and operating reference parameters, although they do not

include the explanations of the scientific basis for the parameters selected.

Before each spraying cycle, it would be advisable for technical personnel working
with DIRAN to check the operational condition of spraying equipment, and to

proceed to effect calibrations as necessary.

462 Annex 33

The calibration or recalibration of equipment can be conducted in the installations
of the operations base itself, on the ground, with an overflight at 30 m altitude for

coca-leaf and 15 m for opium poppy, so that over time, calibrations can be
achieved for different environmental conditions (wind, relative humidity, time of
day, etc), using the aircraft selected for routine spraying with glyphosate. It is

essential that the calibration process should be under the personal direction of a
specialist, whose special training enables him to interpret the numerical results,
and to pass judgment on the comportment of one or another reference parameter.

The work includes the collection of data related to the number, size and
arrangement of marks left by particles when deposited on sensitive paper cards or
Kromekote paper, approximately 7.0 x 10 cm wide and long, placed in a straight

line some 70-100 m long, at intervals of 1 m. The line must be transverse to the
direction of the aircraft flight. Contrast-dyed water should be used (methylene blue
or red), to identify the droplets sprayed on the paper. Subsequently, the result

should be evaluated and the width of the spraying swathe is defined, with the
number of drops per square centimetre and the estimated deposit of the
formulation, with respect to 1 ha of surface. It is possible the process of

recalibration may be necessary, again requesting the collaboration of specialists.

For the purposes of calibration, account should be taken of operating parameters
for spraying, as described in the Aerial Spraying Management Program (Record 1).

5. FOLLOW-UP AND MONITORING

• Weekly inspection of storage and pumping installations to detect possible
herbicide leaks
• Verification of the collection of residues and materials used in spill control

6. ACCOUNTABILITY

Antinarcotics Police, Head of the Illicit Crops Eradication area, Base Commander.

7. COSTS

The cost of this program is included as part of the normal operating cost of PECIG

. Environmental specifications not in principle generate any additional cost

END OF THE PROGRAM RECORD FOR THE HANDLING OF GLYPHOSATE
AND COADJUVANTS IN OPERATIONS BASES

463Annex 33

 

 

 

 

 

 
RUNWAY
SAN JOSE DEL 
  GUAVIARE 
AIRFIELD 
CONTROL 
TOWER 
 

 

OTHERS 
 

PLATFORM  HANGAR 
  ELEVATED 
WATER 
TANK 
  Pumping zone

EQUIPME  WE OTHER  OFFICES
NT  SUPPLIES 
  OIL 
GLYPHOSATE  PUMPS 
WAREHOUSE 
 

CONTAINERS 
HANGAR
 

WATER 
 FEUL  PUMP 
  WAREHOUSE  CONTROL 
ROOM 

 

  HELIPORT HELIPORT HELIPORT
HELIPORT HELIPORT

 

 

 

 

 

 
October 2001 Figure  
TYPICAL LAYOUT OF AN ANTINARCOTICS No. 1 
DNE  National Narcotics Directorate  AIR BASE  No Scale 
 

 

 
464 Annex 33

PROGRAM FOR THE MANAGEMENT OF FUEL, VEHICLES, RECORD 3

EQUIPMENT AND TRANSPORT

1. DESCRIPTION OF THE ACTIVITY GENERATING IMPACT

Aerial spraying operations require the transport, storage and loading of fuel and
lubricants for aircraft and land vehicles in PECIG at each operations base, and
regular maintenance for aircraft, vehicland machinery. Also, the transport of

glyphosate from port to operated operationsbases is usually effected by truck.
DNE and DIRAN have supplied information that requires the following equipment:

EQUIPMENT USED IN OPERATING PRAISE

EQUIPMENT

OV-10 or T-65 aircraft (spraying)

Caravan aircraft to transport personnel or as an
ambulance service

SAR helicopter on standby

Support helicopter on standby

Jeeps for local movements

Trucks to transport materials locally

Pumps

Minor tools

Articulated trucks to transport glyphosate(rented).

465Annex 33

The operation and maintenance of aircra ft, vehicles, machinery and equipment
may cause a negative impact on two components, namely:

• During operations and in transits inside the base, there will be atmosphere-
contaminating substances emitted such as nitrogen oxides (NOx), sulphur
oxides (SOx), carbon oxides (COx), and hydrocarbons (HC), and there may
be an increase in levels of sound pressure.

• Further, maintenance may cause contamination of the soil from used
greases and oils, changing amount of parts such as filters, bushings,
condensers, cables and fuel supplies. Fuel supplies are also associated with
possible contingencies

Additionally, vehicles in bad condition increase the risk of accidents and endanger
the safety of personnel working in operations.

The possible problems which may be caused by misuse of fuels would arise from

storage and spills. Nonetheless, these might also be caused by accident, or by
terrorist action. The elements affected would be the soil, flora, water and fauna.

2. OBJECTIVES

The objective of the management plan program for fuel, equipment and transport is
to prevent and mitigate impact associated with the storage of fuels and the
operation and maintenance of machinery and vehicles used to transport

glyphosate and fuel.

3. ACTIVITIES

3.1. Measures for the general transport of equipment, materials and individuals,

and the maintenance of equipment

466 Annex 33

The activities in this objective are:

• Proper selection of vehicles. For the transport of personnel, materials and

equipment, recent-model vehicles, machinery and equipment should be
used, in order to reduce the probability of accidents, and to comply with
quality standards (Decree 948/1995, and regulatory resolutions on mobile
sources).

• The maintenance of spray aircraft and helicopters working in the program
will be regularly conducted in PECIG and hangars at each base. For
security reasons, each antinarcotics base will have a system of fuel storage
for aircraft and helicopters. The regularity of aircraft maintenance will be that
necessary to secure optimum working order, and to avoid accidents, in
accordance with current aeronautical regulations.

• The maintenance of vehicles , machinery and equipment working in each
base will be conducted regularly as recognized and specialized mechanical
centres, or at workshops or service stations in municipalities or cities near
each base. The regularity of maintenance of vehicles will be necessary to
guarantee permanent and proper synchronization. Preventive checks will be

made on vehicles every 5000 km, and they will be tuned every 20,000 km.

• Daily check on equipment at the base, to detect possible leaks or spillage of
fuels and lubricants in vehicles.

• External maintenance . Supplies of raw materials and the transporters of
herbicide and its guidance will be required to comply with the same
standards of maintenance and operation as the PECIG´own machinery, in
accordance with Ministry of Health regulations.

• Parking of aircraft and vehicles. Spray aircraft and helicopters will be parked

at places specially indicated inside the operating bases, adopting
appropriate security measures with police personnel. Land vehicles will also
be parked in the covered spaces, and will be under guard inside each base.
The parking areas will be paved, with appropriate rainwater drainage, and
grease traps prior to discharge into the local sewerage or rainwater
collecting network

3.2. Specific measures for the storage and handling of fuels

467Annex 33

As noted, the fuels required for aircra ft and land vehicles will be stored and

supplied directly to each base, for security reasons. It may also be acquired in
commercial aerodromes. For this purpose, the will have to be a system storage
and temporary supply system available inside the base, with the following meeting

the following requirements.

• Preparation of a covered area with a hard zone (concrete floor). The supply
of fuels. Around this hard zone, a 30 cm concrete channel will be
constructed at one side to connect possible fuel spillages. At the end of this
channel, at the lowest point, there will be an oil and grease separator for

separation from fuel (see Figures 1 and 2). This place will also act as a
provisional storage site for used oil.

• Construction of a concrete perimeter wall, with capacity to retain 120% of
the volume of fuels in store.

• There may be alternatives for the storage structure, which may vary as a
function of the local topography and security conditions in relation to
possible terrorist attack. The only condition is that there should be sufficient
additional volume to store the fuel stored in the event of attack or accident,
such that fuel can be collected, and will not flow out of the hard

compartment.

• Signposting areas to prevent accidents and restrict mobilization in these
areas.

• Supplies of fuels must be effected in observance of also safety measures, in
order to minimize accidents.

• Construction of a ditch to collect rainwater with the oil and grease trap.

• Maintain sufficient firefighting equipment for any eventuality.

• Maintain sufficient equipment to correct collect possible fuel spills (pumps
and barrels).

468 Annex 33

3.1. Special measures for the transport of glyphosate

Normally, glyphosate can be carried by land or in critical areas by air. Generally, it

is taken to the antinarcotics bases in articulated trucks or other large trucks
depending on the volume transported. The following should be the minimum
requirements taken into account for contracting transport:

General requirements:

• The carrier must have a haulage licence

• The vehicle must have a health licence for transport, issued by the regional
transport health authority where the vehicle is registered

• Preparation of a duplicate manifest is delivered by the seller or distributor
and received by the person driving the vehicle

• Content of the manifest: date, place of delivery, data of the carrier,
identification of the vehicle, date information on the material to be
transported, destination of the material

• Instructions on the material to be transported delivered to by the seller of the

material and received by the driver, together with the manifest.

• Contents of the instructions: identification of the product, precautions of the
product, emergency measures, addresses of those institutions close to the
route.

• Log. The purpose of the log is to record the delivery of material to be
transported, delivery of the manifest, and instructions regarding the material,
with the signature of receipt to satisfaction by the carrier

• Policy. The contractor must have an insurance policy for a value of not less
than 1% of the value of the goods to be carried

469Annex 33

Requirements of the vehicle

• Physical separation of the cargo area and the cabin

• The cargo area must be in corrugated metal sheet, or smooth wood free of
obstacles

• The cargo area must have a canvas cover or metal cover. The tank may be
high-density polyethylene plastic.

• The cabin must be equipped with the following items: first aid kit,
medicaments related to the therapy of the product, portable international

warning signs. The vehicle must carry the "danger" symbol on visible parts,
sized 20 x 50 cm, with reflective paint.

Prohibitions during transport

• The vehicle may not carry products or goods other than pesticides at the

same time.

• The pesticide may not be transported with any individual located in the
unloading or loading zone

• Pesticides may not be carried in the cabin

Loading and unloading operations

The unloading of the 55-gallon drums from the trucks will be effected by forklift, in

order to avoid possible accidents.

Likewise, to prevent problems due to deterioration of the drums, or breakage or

470 Annex 33

contamination, there must be a stainless steels or high-density polyethylene plastic
tank.

Steel-coated tanks or galvanized tanks or galvanized tanks may not be used for
transport

Trucks may not be parked close to restaurants, schools, crops, animals,

watercourses or lakes.

4. SCHEDULE

The Program will commence when operations begin and continue throughout the

duration of operations

5. FOLLOW-UP AND MONITORING

Daily inspections of equipment, characterization of the effluent to the grease trap,

every time there is a spill; the paramet ers to the measured are oils and greases,
and DQO.

6. ACCOUNTABILITY

The Antinarcotics Division of the National Police DIRAN

7. COSTS

COP 1.5,000,000 a year for characterization of the water. The construction of the
storage and supply system, and the maintenance hangars, are activities proper to

PECIG in each base, and their costs form part of the normal investment of the
project, that is, they are not costs attributable to the EMP.

END OF THE PROGRAM FOR THE MANAGEMENT OF FUEL, VEHICLES,

EQUIPMENT AND TRANSPORT.

471Annex 33

 

FOR SOLID WASTES 

SAFETY ALTERNATIVE  
USED IN SOME BASES 

Date: 
MANAGEMENT OF FEUL October 2001 Figure  
DNE  National Narcotics Directorate  No. 1 
Deck for management of fuel in mobile operations bases  No Scale 
 

 
472 Annex 33

 

SEPARATION 
INFLOW   AREA  
AREA  

WATER LEVEL

1. Inflow Chamber  
2. Flow  distributor 
3. Separating Channel 
4. Foam Dissipater  

5. Oil Retaining Device 
6. Outflow Section  
7. Pouring of the flow  

Date: 
DNE  National  Narcotics MANAGEMENT OF  FEUL AND October 2001 Figure  
 Directorate  No. 2 
OILY WATER
 

 

 

473
 Annex 33

PROGRAM FOR THE HANDLING OF SOLID WASTE RECORD 4

1. DESCRIPTION OF THE ACTIVITY

Activities proper to the antinarcotics operations base of the Police, and glyphosate

spraying operations generally three types of solid waste: domestic, special, and
glyphosate-related.

The domestic solid waste is generated in quantities, quality, nature, composition

and volume by the activities of personal, accommodation or any similar
establishment, and are formed by organic matter (food residue), mainly paper,
cardboard, glass, plastic, etc.

According to the normal population of operations base with a per capita production
of an average of 0.4 kg/individual/day of domestic solid waste, the production
would be 48 kg/day and 336 kg/week

Special solid waste is formed by empty packaging, oil, grease, used lubricants,
epoxy paint containers and polyurethane-based paint containers, vinyl paint,
solvents, accelerants, sealants, materials contaminated with used oil, fuel, or oil

derivatives, metal shavings, rubber packing, packaging and crating materials used,
and lead acid batteries, in general. The production of 60 kg/day and 40 and 20

kg/week is estimated for these this form of waste (Chart 1)

Glyphosate-linked solid waste is composed of empty plastic drums and other types
of glyphosate containers and those of the coadjuvants. For all bases, a total

generation of 2850 plastic 55 gallon drums an d 3619 5-gallon plastic containers is
estimated. The distribution by bases is shown in Chart 2. The average daily

474 Annex 33

production of all bases is therefore 8 x 55-gallon drums and 10 x 5-gallon plastic
containers. Nonetheless, as the spraying does not take place every day because of

weather factors, public order, and so on, daily production may vary considerably.

The following toxins and contaminating items require special handling:

• Lubricating oils and greases. Lubric ating oils and greases are 85% by

volume composed of organic compounds, mostly aromatic, polynuclear, and
present in raw materials, and 15% are additives containing sulphur, nitrogen
and trace metals which are introduced during use as lubricants of metal
parts.

• Residues from the handling of glyphosate, being impregnated with the
herbicide and all its coadjuvants.

Inadequate disposal of this waste may cause contamination of the soil, water and
air, the appearance of disease-carrying vectors, and problems of odour and

unsightliness.

3. ACTIVITIES

3.1. General specifications

The following are some of the general measures to be followed in handling,
collecting, carrying and disposing of solid waste. Subsequently, we will give some
specific measures for each of the categories of solid waste.

475Annex 33

Chart 1

TOTAL SOLID WASTE GENERATED

Type Phases of process Waste matter quantity

Domestic operations bases organic matter, 336 kg/week
paper, cardboard,

glass, plastic,
rubber, wood,
other

Special Construction operation: Construction 420 g/week
waste
Stores operation:
Packaging waste
Sundry resources
Mixes and other

forms of waste oils
and greases,

Metal shavings
from maintenance

Laboratory
analysis

Special Glyphosate packaging 55-gallon plastic 2850 drums
glyphosate drums

. Cosmoflux 411F containers 5-gallon plastic 3619 containers.
containers

Source: This study

The production of each of these types of waste per base is very different, since it

depends on the number of individuals living there, the number of vehicles, the

476 Annex 33

number of aircraft and flights undertaken.

• Refuse, particularly in offices, camps, restaurants and maintenance
workshops, should be kept in an appropriate manner, separating domestic

waste from special waste.

• Provisional containers for domestic and special waste should be covered
with a lid

• Waste material should never be allowed to be burnt

• Refuse may not be accumulated in public places, nor at places of work, or in
ditches, etc.

• No kind of waste which is environment should be located in an
environmentally sensitive place for partial or permanent disposal. A site
should be chosen as protected from the action of the wind, at a distance
from water sources or currents, where there is no interruption to natural
drainage or watercourses, and if there is, to design control measures such
as external channels and locate them at prudent distances from places

where there are groups of human populations.

• The number of sterile dumps and in gener al places for disposal and storage
of solid waste should be kept to a minimum.

• In general, all receptacles containi ng some kind of special or hazardous
waste should be marked, showing the characteristics of the product and the
danger involved if the receptacle is opened.
• A recycling plan should be implemented, in which put materials such as
paper, metal and glass (recyclable) should be separated from other waste.
Appropriate receptacles will be provided for recyclable material, to create a

suitable environmental awareness.

• Warehouses will be used for the temporary storage of waste separately from
the special solid waste (drums and containers of the herbicide), and for
recoverable and recyclable solid waste (see Figure 1). The conventional
non-recyclable or re-usable solid waste will be placed in plastic bags for

adequate handling and the control of vectors, and kept temporarily in
covered containers, until taken to the place of final disposal. Each
compartment for special residues will have 55 gallon drums not

477Annex 33

contaminated with glyphosate for temporary disposal of the classified waste.
Non-recoverable waste will be taken directly to the dump, or to the sanitary
infill.

3.2. Handling of domestic solid waste

This classification includes waste produced in offices, camps, cafeterias or
restaurants, or any toilet or washing washroom facilities, and will receive the

treatment described below. The classification covers:

• Food
• Prepacked food cans
• Paper and cardboard

• Used textiles
• Glass
• Plastic and glass receptacles

Depending on distribution of the working areas in the operations base, receptacles

will be located in each case for collection and classification in situ of domestic
waste. In addition, personnel working at the base, security personnel and visitors
will be given instructions with regard to classification at the places of origin, in order

to facilitate handling. The receptacles will be emptied as follows: organic
nonrecyclable waste, comprising food scraps , will be disposed of in the sanitary

infill in the nearest town. Other waste will be taken every day to the temporary
disposal site, and subsequently to the dump.

Waste temporarily stored will be disposed of in drums or plastic containers, in an

enclosed, tiled space, (zinc, asbestos or all cement tiles), with grill type ventilation
or chain-link fencing. There will be pl ans and mechanisms for supervision and
control of hygiene, in order to avoid unpleasant odours or the proliferation of

insects or rodents (see Figure 1).

The final disposal of this waste will be achieved as shown in Chart 2.

Recyclable solid waste (Glass, paper, cardboard, wood, etc) will be delivered to the

recycling cooperatives of the town and/or surrounding area. The recyclable

478 Annex 33

material should be placed in a collect and collection site set aside for the purpose,
meeting the following conditions:

• Dry plastic, free of organic material, organized in bags
• Paper, free of organic material, in blocks
• Broken or whole glass, without extraneous objects, in bags
• Metal and scrap without extraneous material, washed and in bags

• Cardboard free of grease, in blocks

3.3. Handling of special solid waste

The handling of this type of waste includes the program for withholding at source,
involving classification, recycling, re-use and final disposal.

Special solid waste must have separate and careful treatment due to the high

potential for contamination. Used oils, lubricants, acids and batteries, amongst
others, are hazardous waste. The following measures should be taken to evacuate
this waste in an appropriate manner, without causing damage or contamination to

the environment.

Chart 2

CATEGORY DESICCATION OF DOMESTIC WASTE AND MEANS OF

DISPOSAL

TYPE OF MATERIAL DISPOSAL AND FINAL TREATMENT

Paper and cardboard Transport in drums, recycling

Plastic Transport in drums and recycling

Wood Transport in drums and recycling

479Annex 33

Rubber Transport in drums and recycling

Metals Transport and recycling

Glass Transport and recycling

Leather Transport and recycling

Food waste To the community, for animal
husbandry, or sanitary infill

Used greases and oils

Burned or used oils from machinery, vehicles, plant or workshops must be stored
in metal or plastic 55 gallon metal or plastic drums in good condition, with

anticorrosive paint, which can be sealed.

Empty oil cans must be packed in plastic bags, which will be sealed when full,
deposited in metal drums for sealing, and taken to the special waste section in the

domestic waste dump.

Sanitary infill

The solid waste management program will be complemented with workshops on

environmental education, addressed to operators and employees on the base (see
Environmental Education Program).

Separation

The classification and separation of this waste will be effected at the point of origin,
so that subsequent work will not be completed or require more time than

necessary. For this, there will be specific receptacles in different areas, with
standard colours: recyclable (green), special (red), oily (black), and for infill or

480 Annex 33

incineration (yellow).

Used metal equipment or parts will be classified as follows:

Type A: New

Type B. Used, in good condition for reuse

Type C. Used, in a fair state for less demanding use

Type D. Used, in poor condition, to be used as supports, accessories, etc, for
sale in lots, or

disposal.

Materials such as filters and batteries will have a special collection point within the
fuel stores, so that they are not mixed with other waste for subsequent recycling.

Disposal

Once waste has been classified, quantified and stored, it can be sent for final
disposal. The alternatives for this ar e recycling, depending on the type of waste

produced. Disposal of waste is not need not be effected in a secure sanitary infill,
nor will incineration be required, given the characteristics of the products and the
quantities to be produced

For recycling action, the following procedures and activities will apply:

• Metal, plastic and rubber waste will be reused, if possible in other program
activities, or stored until sufficient quantities obtained for disposal.

• For containers and other materials that have had contact with chemicals or
hydrocarbons, there must be decontamination or treatment prior to sale,
taking account of the manufacturer's recommendations for each product.

481Annex 33

• Acid from laboratory tests must be bottled in acid-resistant receptacles, and
properly marked, showing the corrosive potential of the product, deposited
in metal drums and taken to the special waste point in the domestic waste

sanitary infill.

• Used batteries have considerable quantit ies of heavy metals, such as lead,
which has a high potential for contamination. Batteries must be handled in
accordance with their composition. Where possible, they should be sold to
local recycling cooperatives. The production of batteries is likely to be very

low, being limited to vehicles and engines on the base. If the product cannot
be sold to recyclers, it should be disposed of in corrosion-resistant metal
drums, firmly sealed and disposed of at the special waste point in the
domestic waste infill.

Waste which cannot be recycled will be disposed of as follows:

• Oil, grease and hazardous waste: oils use oils and greases will be
eliminated by specialized companies , authorized to do so. The containers
for hazardous substances will be returned to the supplier

• Wood and metal waste. Each material will be selected and separated, and

sold for recycling or use.

• Where possible, the use of hazardous substances will be avoided, since
they may become toxic elements upon disposal.

• In particular, the use of substances or products which c ontain the following
will be avoided:
¾ Asbestos
¾ Chlorated substances
¾ Lithium-based batteries
¾ PCBs

¾ Mercury.
If it is unavoidable to use these substances, use will be the responsibility of the
contractor, and with the prior authorization of the environmental authority

• Accidental spills of special chemical s will be reported to the contractor
responsible for this activity, who will be responsible for the control and
handling and restoration of the areas affected.

482 Annex 33

3.4. Glyphosate-linked solid waste

As indicated, glyphosate is to be handled in 55-gallon plastic drums in which the

glyphosate comes, and Cosmoflux 411F in its 5-gallon plastic receptacles.

From a technical point of view, there are several recommendable procedures for
deactivating pesticide waste, though some of them may not be applicable due to

problems of an economic or functional na ture, or because the nature of risks
involved does not merit such demanding procedures. The following are the
commonest methods:

Disposal in natural or artificial depressions in the soil. This is a system of storage in

places which do not facilitate dragging from water currents, but which allowed solar
radiation and evaporation to accelerate deactivation of pesticide wastes. It is
difficult to find an appropriate place inside an operations base, but in some cases

there may be somewhere close by where it would be feasible

Burial. If there is space available, and the use of sanitary infill is can be facilitated,
this is an applicable system but, as in th e previous case, water run-off must be

avoided

Incineration. Incinerators are useful to eliminate solid and combustible waste, but
account must be taken of the problem of emissions of gas and unpleasant odours.

Chemical deactivation. In cases where the quality of toxic wastes permits,

oxygenating agents can be used, with the addition of chlorine, and the use of
caustic substances, coagulants, or ion-exchange substances

Use of volcanic craters . There have been some positive experiences with the use

of volcanic craters as a place to eliminate pesticide waste. The main problem is the
cost of transporting materials to be deposited into the crater centre.

The elimination of containers for glypho sate, the emulsion, and any other product
added to the formulation is one of the probl ems of greatest concern. Article 153 of

Law 1843/1991 specifically indicates that empty packaging and containers for
pesticides may not be reused, and that any treatment given to them must be
approved in advance by the health authorities.

Although the plastic containers used in th e sale and transport of glyphosate may
be used for other purposes, government regulat ions are firmly opposed to this, in
order to avoid any risk of contamination. As a suggestion, and taking account of

483Annex 33

the glyphosate is not a highly toxic pesticide, it would be possible to justify some
use as such as receptacles in which to collect refuse, provided that they are

thoroughly washed, deactivated with a caustic soda solution, with multiple
perforation of the base and sides (in order to avoid their use to carry water or other
liquids).

There is always the possibility of recycling, either as raw materials or as containers
for reuse by the same company that produces the glyphosate. This is the
alternative selected by DIRAN, and there is an agreement with Monsanto

(Compania Agricola Colombiana), the importer, and they regularly collect up
containers and take them to their the following specifications must be met for this
to occur:

• Storage in one of the warehouse compartment for the temporary disposal of
recyclable waste

• When there is a sufficient quantity of containers, the glyphosate distributor

Monsanto will be advised, so that it c an collect them and take them to its
specialized deposits

• The water used in washing the containers at the base will be reused in the
aircraft tanks

• It is not recommended that drums be sold or given away to the local
inhabitants, for the reasons given above, and because in general,
smallholders wash the pesticide receptacles in streams and rivers, thus
contaminating surface waters.

4. SCHEDULE

This is a normal and permanent activity in each operations base

Environmental education workshops will be held regularly, as indicated in the
Educational Communications Program Record.

484 Annex 33

5. FOLLOW-UP AND MONITORING

• Daily inspections of the temporary storage facility for waste

• Weekly inspections of all base installations to check compliance in activities
• Weekly follow-up of the recovery and recycling program

6. ACCOUNTABILITY

The Commanding Officer of each DIRAN operations base

7. COSTS

COP15,000,000. This includes the construction of the warehouse and the supply,
painting and installation of classification drums in each base. If there is already a

warehouse there, or part of a hangar can be set up for the storage of this kind of
waste, the cost will be much lower, or non-existent.

END OF THE PROGRAM RECORD FOR THE HANDLING OF SOLID WASTE.

WASTEWATER MANAGEMENT PROGRAM RECORD 5

1. DESCRIPTION OF ACTIVITIES

Wastewater generated at the Antinarcotics Police operations base is of three main

types:


Domestic wastewater, generated by base personnel during operating time
(10 working hours), which may be of the order of 38.8 m³/day during

485Annex 33

operations (90% of consumption)

• Water from watching the installations, part of which will filter or evaporate

off, and the rest will go to the rainwater network

• The rainwater will go to a collection system independent of sewage, and is
evacuated away from the operations base

• Water from washing the aircraft tanks contaminated with glyphosate.

The typical composition of domestic wastewater appears in Chart 1. The
composition of wastewater from washing and general maintenance of the

installations will have a higher content of solids in suspension, detergents, and
perhaps oils and greases. Rainwater carrying sediment from the soil will have high
concentration of total solids and solids in suspension. Water from washing on

aircraft tanks will have the remains of glyphosate and detergents.

Each type of water has different impact. The high level of organic and bacterial
contamination from domestic wastewater may affect the health of workers

exposed, or increase problems of contamination of water currents close to the
area, if discharged into them. Water from washing and general maintenance of the
installations will have moderate DQO, and greater turbidity, and its principal effect

will be aesthetic. Rainwater carrying sediment, when reaching the local run-off
network will cause an increased in turbidity of water, and slight sedimentation. The
water from washing on aircraft tanks may affect operators´ health, even though the

high degree of dilutions can mean t hat its expected high impact will be
insignificant.

Given that the greater part of operating bases are located close to existing airports,

equipped with their own sewage systems, or which form part of a municipal
sewage system, the measures for the collection and treatment of domestic
wastewater shown below only applied to new bases constructing in places which

do not have a public sewerage system in which to be discharged.

2. OBJECTIVES

486 Annex 33

The general objective of the wastewater management system is to mitigate

impacts associated with production and base operation. The actions in particular
are:

• To provide a proper form of management of liquid waste, in order not to
cause additional contamination in local and regional water source

resources.

• To avoid the discharge of wastewater and to maintain the natural conditions
of water quality in the water currents located in the area of influence of the
operations base

3. ACTIVITIES

The objectives of quality in respect of wastewater in the operations base are those
indicated in Chart 2.

Chart 1

TYPICAL COMPOSITION OF DOMESTIC WASTEWATER

PARAMETER CONCENTRATION

HIGH MÉDIUM LOW

Total solids (mg/l) 1200 700 350

Total dissolved 850 500 250

Fixed 525 300 145

Volatile 325 200+ 105

In suspension 350 200- 100

Fixed 75 50 30

Volatile 275 150+ 70

487Annex 33

PARAMETER CONCENTRATION

HIGH MÉDIUM LOW

Sedimentable solids (mg/l) 20 10 5

DBO (5 días, 20 °C) 300 200 100

DQO 600 400 200

Total nitrogenNitrógeno total 85 40 20

(como N) (mg/l)
35 15 8
Organic
50 25 12
Ammoniac

Total phosphorus (as P) 20 10 6

(mg/l)

Chlorides (mg/l) 100 50 30

Alkalinity (as Ca3O ) (mg/l) 200 100 50

Grease (mg/l) 150 100 50

Calcium (as Ca) (mg/l) 110** - 10*

Magnesium (as Mg) (mg/l) 8** - 10*

Sodium (as Na) (mg/l) 100** - 23*

Chart 2

CONDITIONS OF EFFLUENT

REFERENCE VALUE

PH 6,5 – 9

DBO (mg/l) 16

DQO (mg/l) 30

488 Annex 33

Total solids (mg/l) 300

Suspended solids (mg/l) 100

Oils and greases (mg/l) None

Tensoactives (mg/l) 0,5

Total coliforms (NMP/100 ml) 1.000

Fecal coliforms (NMP/100 ml) 5.000

Source: CAR, 2000.

3.1. Design parameters for wastewater treatment systems, for domestic
wastewater.

An operations base has average permanent daytime population of employees in all
areas of 120. Working hours are 10 hours a day

Demand and design flow

The typical consumption of water and various activities and contaminating loads
are shown in the chart 3.

Estimating the demand and flow for the group mentioned, and taking account of

the warm climate in the area, the situation is as follows:

Equivalent demand per employee 150 L/inhabitants/day

Return coefficient 0.9

Design flow 38.8 m³/day or 0.45 m/second

489Annex 33

Chart 3

TYPICAL CONSUMPTION OF WATER AND LOAD CONTAMINANTS

TYPICAL CONSUMPTION

Accommodation Consumption per resident 200 L/inhabitant/day

Camp Consumption per resident 150 L/habit and/day

Office Consumption per user 70 L/inhabitants/day

Restaurant consumption per plate 11 L/plate

served

Health centre consumption per person 200 L/person/day

CONTAMINATION LOAD

DBO 54

DQO 91

Suspended solids 105

Total nitrogen 4.8

Total phosphorus 1.4

Detergents 0.32

Location of the residual waste water treatment system

The wastewater treatment system shoul d be located where it will not cause
damage that could cause contamination in any well, spraying or other source of

water supplies. Further, it should be located in a place where the slope specified
for the evacuation of the effluent treated can be achieved. The location should be

such that it has an adequate land area, and is easy to access.

3.2. Wastewater management

490 Annex 33

The management of liquid waste will be focused on the following components:

• Segregation of currents
• Treatment of effluent

• Final disposal
3.2.1. Segregation of currents

The segregation of currents inside the operations base is intended to separate the

various drainage systems, such that rainwater will not be contaminated, and will be
returned directly to the natural medium

Therefore, the operations base must have the following water management

systems:

• Domestic wastewater
• Rainwater
• Special liquid waste from washing aircraft tanks

3.2.2. Treatment of effluent

Rainwater

Rainwater (roofs, parking areas, etc) will be drained straight into natural drainage.

The system proposed collector rainwater from the following areas.

• Platforms, gardens and sporting facilities
• Internal roadways, roofs of buildings, administration, hangars, workshops

and parking area

In general, the system for collecting rainwater will be formed by rectangular and
trapezoidal ditches, as indicated in Figure 2

The water collected in the workshops and stores, and amongst other areas, is

491Annex 33

prone to contamination, and will be carried away in a ditch system to the final
treatment system, after passing through grease traps in accordance with the

scheme of Figure 1.

The entire rainwater system will contain the following structures

• Box ditches

• Km-type grid ditches
• Perimeter ditches all round the working area

Liquid waste from aircraft tank washing

The wastewater use for the washing of spraying equipment and aircraft used in the

application of glyphosate is in always the most important concern at the operations
base. The applicable provisions of Decree 1843/1991 of the Ministry of Health do
not give details of the procedure of the most efficient procedure, but suggest that

waste be subjected to treatment prior to the exhibition "so the effluent will not pass
permissible officially permissible limits", and these limits vary depending on the
type of use of the receiving body of water, established in Decree 1541/1974.

Among the possible systems that can be used, the following:

Biological systems. This is a suggestion suited to in stallations in which liquid and

solid pesticides are handled (solid pesticides do not apply to the operations bases).
It involves the use of filters, sedimentation tanks and aerobic and anaerobic
digestion, four times which are for which exceed one or two weeks

Deep burial. This maybe an appropriate procedure if deep wells of use. It is
possible to find an appropriate place, taking care not to contaminate underwater
aquifers

Chemical deactivation . In cases in which the quality of toxic waste allows,
oxygenating agents can be used, with the addition of chlorine, and the use of
caustic substances, aquariums, or ion-exchange substances.

492 Annex 33

The most appropriate method in the case of the bases, is to collect up the water
which runs off the leading, washing and maintenance platforms for the spray

aircraft through channels or ditches which discharge their content into pools
stabilization pools, and then after some time, discharge them into an area of land
specially selected to act as the place of degradation due to the effect of

environmental factors. Figure 3 shows a scheme of stabilization pools. It is
estimated that two pools in a chain, of 6 m³ each, communicated through a
spillway and duct or channel, may meet t he needs of deactivation 2 GB deactivate

the rest of glyphosate-contaminated waste.

Treatment system for domestic wastewater.

Given the characteristics of climate, and temperature in anaerobic processes which

improve the rate of biodegradation, and principally, the time over which the bit of
the operations base will be used, and the cost s implied in constructing a treatment
system each time in rules is made to another site, the proposal is that a mobile

compact mobile treatment system should be implemented. Such a system requires
permanent maintenance, but at a low-cost, because it only requires a small
number of low-qualified personnel, and can be dismantled and set up again

somewhere else. Therefore, the recommendation is that this system of treatment of
domestic wastewater should be implemented in all operations bases.

It is to be understood, however, that adequate and constant maintenance must be

guaranteed in order to avoid biological destabilization of the process, and
consequently, the proliferation of unpleasant odors as a result of hydrogen sulfide

release.

The operations sites are not of the same size or permanence over time. In some
cases, most workers live in neighboring cities or police barracks. In others, sites

have duration of few months while the illicit crops problem is controlled. In these
conditions, it will not be necessary to bu ild permanent systems of sanitation and
waste water systems. Based on the daily population volume of the site, the Anti-

Narcotics Police (DIRAN) may equip each site with portable toilets connected to a
septic tank with biological filter and a discharge system in the filtration field. In this
case, the septic tanks should be located not less than 50 meters away from a body

water or accommodation.

493Annex 33

As an alternative to implementing a compact treatment system, there are

commercial plants that meet the above requirements. Such is the case of the
ACUASEG-A-40 treatment plant, whose tec hnical characteristics appear after the
technical and financial offer of ACUATECNICA LTDA.

Description of the system:

The proposed system is comprised of the following items:

INLET MANIFOLD: is a by-pass for plant feeding

INLET BOX: built in carbon steel, dimensions 0,5 x 0,7 x 1,0 m

AIR REACTOR: cylindrical, horizontal position, mounted on Ski profiles,
dimensions: 2,0 diameter and 8.0 m long. This shape allows transfer to other sites.
Capacity: 41 m3.

SETTLER: rectangular, pyramid background, dimensions: 2.5 m long, 1.0 m wide
and 3.0 m high (includes 1.0 m of pyramid trunk). Capacity: 9 m3.

CHLORINATION CHAMBER: rectangular, 0.5 m3 capacity, located at effluent
outlet. Dimensions: 1.0 m long x 0.7 side x 0.5 m high.

AIR PIPE: galvanized tubing main network, 2” diameter.

AIRLIFT PUMP: allows mud recirculation

BLOWER: capacity of up to 2500 cubic feet of air/m3 water/day; must be coupled
to a three-phase power motor of 220/440 V.

DIFFUSERS: have a capacity of 10 cubic feet/minute, made in high resistance

ABS plastic and implemented with a non-clog isolation membrane.

SKIMMER: in form of adjustable funnel, made of carbon steel and mounted on the
settler, leads water to drain and shut-off valve through a tube.

Other elements:

Platform and access staircase for inspection and monitoring.

494 Annex 33

Control board.

The Annex shows in detail the technical characteristics of each component of the

treatment system.

This system is designed for a design capacity of 40 m3/day and a maximum
capacity of 50 m3/day.

The following are the expected load and main features:

• DBO load: 13 kg/day
• SS load: 15 kg/day
• Average retention time: 20 hours
Maximum airflow: 2.500 cubic feet of air/m3-day

• Recirculation between 50% and 120%
• Total efficiency of the system: 95% DBO and SS removal

The overall system is built in rated steel.

3.2.3 Final disposal

Once the effluent meets the conditions required in the dumping site, the discharge
can be effected, depending on the use of the receiving water flow, as provided for

in Decree 1541/1978 and 1594/1984.

4. TIME SCHEDULE

The wastewater treatment and tank wash systems must be constructed before

starting operations in the site.

5. FOLLOW-UP AND MONITORING

495Annex 33

• Verification of the treatment system construction and compliance with
sanitary regulations and efficiency specifications.

• Verification of the correct construction of home residual waters collection,
treatment and disposal, taking washing and rain waters to be generated
during the time of permanence of the operation activities in the site.

• Quarterly sampling of basic sanitation parameters (DBO, DQO), total and
suspended solids, pH, total and fecal coliforms), to test the efficiency of the
treatment system and compliance of dumping regulations

6. ACCOUNTABILITY

DIRAN (Anti-Narcotics Police) will be responsible for the execution of the above.

7. COSTS

The cost of the domestic wastewater treatment system will be COP 61.220.000.

The cost of the stabilization wells for tank wash waters will be COP 500.000. Plant
maintenance is estimated in COP 7.665.00 and COP 10.000.000 in monitoring per
year. In total, the operating and maintenance cost for the first year of treatment will

be COP 70.385.000

END OF WASTEWATER MANAGEMENT PROGRAM

496 Annex 33

497Annex 33

RECTANGULAR DITCH

TRAPEZOID DITCH

498 Annex 33

PLANT

UNTREATED by-pass
TREATED

EFFLUENTstructure EFFLUENT

499Annex 33

500 Annex 33

INSPECTION, VERIFICATION AND CONTROL PROGRAM RECORD 6
OF SPRAYING OPERATIONS

1. DESCRIPTION OF THE IMPACT GENERATING ACTIVITY

One of the objectives of the Program for the Eradication of Illicit Crops by Aerial
Spraying with Glyphosate –PECIG- is to eradicate illicit coca, poppy and marijuana

crops by aerial spraying same with glyphosate herbicide.

The irregular performance of this activity may cause undesired impact on the
biological conditions and communities located in the glyphosate spraying, areas,

as well as their economic activities.

2. OBJECTIVE

The Program for the Eradication of Illicit Crops by Aerial Spraying with Glyphosate

–PECIG- must complete an inspection, verification and control program for each
aerial spraying operation of glyphosate in order to:

• Verify on site, the effectiveness of the application of environmental

management measures during the PECIG operation.
• Evaluate, based on design, by efficiency and effectiveness indicators, the
application of PECIG´s environmental measures.
• Evaluate the efficiency in the adoption of corrective measures, in case
damages derived from eradication activities occur.

501Annex 33

3. ACTIVITIES TO BE PERFORMED

3.1 PECIG´S VERIFICATION MEASURES

Aerial spraying must be verified in order to prove its efficiency and effectiveness,
that is, whether it meets its primary objective of destroying illicit crops, and if not, or
if its effectiveness is too low, it would not be worth causing the inherent social and

environmental impact, however small it may be.

The specific objectives of these measures are:

• To proof the biocide action of the her bicide (glyphosate), on illicit crops, and
therefore, their effective death.
• To evaluate compliance of technical parameters of the operation, specifically
those related to the compliance of buffer and exclusion zones.

The above technical verification includes the following activities:

2. Selection of areas to be recognized
3. Selection of the sample
4. Assessment of operation efficiency
5. Selection and call of participants
6. Final report.

3.1.1 Selection of areas to be surveyed

The Verification Program must be conducted on coca, poppy or marijuana plots

sprayed in each operation. For logistical reasons, the PECIG has arranged the
project zones in 9 nuclei, as shown in Chart No. 1

502 Annex 33

CHART. 1

SURFACES COVERED WITH COCA CROPS ACCORDING TO 2000 CENSUS

RESULTS PER NUCLEUS

NUCLEUS Total % national Area of % Municipalities
area (ha) industrial nucleus affected
crops

Putumayo-Caquetá 96.694 59,2 57.174 64,4 27

Meta-Guaviare- 34.878 21,4 16.859 48,2 24
Vaupés

Sur de Bolívar- 11.959 7,3 4.859 42,0 49

Antioquia-Córdoba

Cauca-Nariño 10.906 6,7 3.899 66,5 21

La Gabarra 6.103 3,7 1.472 24,1 15

Arauca 1.234 0,8 636 51,6 5

Boyacá-Santander 743 0,4 257 34,6 31

Sierra nevada Sta. 522 0,3 133 25,5 5
Marta

Chocó 250 0,2 --- --- 2

TOTAL 163.289 100,0 85.419 56,3 183

Source: SIMCI, Census, August 2000

3.1.2 Selection of the sample

The size of the sample to be verified shall be determined by statistical methods
according to the safety factor of the zones to be sampled, operating costs and
variability of the sample universe; it is recommended to apply a statistical error of

0,05% and a confidence level of 90%. The sampling unit shall be the plot selected

503Annex 33

based on SATLOC and/or DELNORTE records selected randomly, in order to
guarantee the greatest impartiality in the verification process.

3.1.3 Eradication efficiency

To determine the effective death of the illicit coca crops, the following methodology
is observed:

• In the first phase, an overflight is made of the sector based on the flight track
selected and the percentage of effective or eradicated death is determined
for the plots involved, based on the in-situ sample and over flight.
• This assessment is made by three experts who qualify the spraying quality

and effectiveness: one from DIRAN-CNC, other from DNE and one of
Technical Audit.
• To check qualification, an “in-situ” or plot verification is made (on the plots
that form part of the selected sector). The verified plots are taken from
previously selected “Satloc” flights.

• Inside lots, experts are distributed and each makes a count of a given
number of plants, determining the quantity of death and alive plants. The
qualification is expressed in perc entage. This sampling is made in 3
different sites in each plot.
• Based on the sampling, the sample is statistically evaluated and the
percentage of effective death of the is determined (subsample). The sum of

all plots is the basis to qualify the sector.
• When flying over the selected sectors, evaluators determine which area still
has illicit crops and, based on the sample, the area remaining with illicit
crops is projected and determine (estimates per nucleus or department)
• Finally, growth or reduction trends of illicit crops are recorded for each

sector.

The preparatory work in space-maps is done 1 month in advance of the operation,
between Anti-Narcotics Directorate, Illicit Crops Eradication Area and

environmental Audit.

3.1.4 Selection and call of participants to the verification process

504 Annex 33

In order to determine a reliable and consensual estimate of the area effectively
eradicated, each participant entity must appoint and designate its delegates. The

entities invited to participate in the verification process of eradication of illicit crops
are the following:

• Anti-Narcotics Police

• National Narcotics Directorate (DNE)
• Likewise, the Ministry of Environment, the Ministry of Health, the Colombian
Agriculture and Livestock Institute, the Procurator´s Office, the Attorney
General’s Office, and the Alternative Development Plan are invited to
participate as observers.

Invitations are made by the National Narcotics Directorate (DNE), in coordination
with the Anti-Narcotics Police (DIRAN).

3.1.5 Equipment and materials

Air equipment:

• Twin Otter aircraft for transportation of the commission staff
• S.AR. UH – IN helicopters
• Huey II helicopters

• Black Hawk helicopters for V.I.P. transportation /Protection
• PNC Huey II helicopters
• PNC Bell 2123 helicopters
• Turbo Thrush aircraft with GP.P.S

• OV-10D with FLIR.

Materials and elements

• Bulletproof vests
• Binoculars

• GPS
• Video recorders
• Photographic cameras
• MP8 videos
• Super HGV400 Photographic rolls

• Cartography
• Forms

505Annex 33

3.2 ENVIRONMENTAL VERIFICATION MEASURES

In parallel with the verification activities directly related with the spraying efficacy

on illicit crops, an environmental assessment must be made in order to determine
the real environmental impacts caused by the spraying, in particularly, damage of
the herbicide on human settlements and other types of adjacent areas, taking field

data to be used as success indicators of the operation.

The environmental verification will be made on the same areas to be recognized
and on the same samples determined for self-verification of PECIG (see sections

3.1.1 and 3.1.2 above). In all other aspects, the following methodology will be
observed:

3.2.1 Verification of effectiveness of application of environmental

management measures

The environmental management measures during aerial spraying can be
summarized as follows (see Development plan of spraying operations – Record2)

•Flight operational measures aimed at preventing and reducing
environmental impacts: flight altitude, flight speed and wind speed.
• Respect for exclusion areas: natural parks, human settlements (small
villages, rural districts ¸ reservations, towns) water currents used for water

supply of urban aqueducts.
• Regarding isolation strips of bodies of water, Nature Parks System areas,
human settlements, vegetation other than illicit crops and areas of socio-
economic interest. The dimension of the buffer strips may be redefined by
DNE based on proposed indicators for PECIG. Otherwise, those indicated in

Record 2 of this EMP will be used.
• When verification shows the generation of impact or failure in procedures,
measures established in the various programs of this EMP will be adopted.

The operating data can be taken from the flight recordings of each operation.

Information regarding exclusion and buffer strips can be taken from the same
records and from the field verification described in the following section. Other

506 Annex 33

verification tool will be exchange of information of flight records originated in the
SATLOC system and satellite information of the SIMCI project, which will serve as

basis to determine whether there has been aerial spraying in exclusion areas, and
to make information feedback and take the corrective measures as necessary.

The above data must be entered in a from similar to annex (IVC-01) where the

indicators to be used in the assessment are shown.

3.2.2 Efficiency and effectiveness assessment of environmental
management measures

To evaluate the efficiency or damage level of spraying operations on human
settlements and other types of vegetation, the following methodology will be
observed:

• As with technical verification, environmental assessment must be made by
other three experts of the Technical Audit team.

• Contrary to the experts responsible for verifying the percentage of death coca
plants, environmental experts must focus their attention to the border areas of
the sprayed lot, where they will make the following observations:

a) Assessment of natural vegetation adjacent to the sprayed site, to determine
where there was damage caused (such as overspray). Make an inventory of
the type of damaged vegetation and the damage see by the expert. The types
of wild vegetation could be:

*Types of coverage: Evergreen euatorial forest, sub-Andean forest, Andean
forest, high-Andean forest, tropical semi-deciduous or deciduous forest, natural
plains, moors and sub-moors.

*Successional stadium: Intervened and non-intervened primary forest, late
secondary forest, medium secondary forest, early secondary forest, plains or
grazed páramos, etc.

*Observable damage: Wilted leaves, defoliation, necrosis, rosetting, terminal
bud burning.
*Approximate area damaged (in hectares)

507Annex 33

b) Assessment of lawful crops next to illicit crops. Inventory of crops
damaged and damages observed, as provided in Resolution No. 017/2001 of
CNE as follows:

*Type of crop: permanent, transitory (including pastures), others
*Crop density: number of plants per square meter (estimate an average, except
for pastures).

* Stadium of the vegetation cycle: newly planted, half cycle, read to be cropped,
in production (in the case of permanent or semi-permanent crops and
pastures).

*Damage observed: plant death, wilted leaves, defoliation, necrosis, rosetting,
terminal bud burning.
*Approximate damaged area of each crop (in hectares). However, contrary to

the count method used for coca, in these cases, the damaged area must be
estimated in different grades (% of death or wilting).

c) Assessment of recovery level (regeneration or restoration) of vegetation after
plot spraying, by count and determination of species starting colonization. This
count must be made in sample areas of 10 square meters or less, at expert´s
option. Also, a qualitative presence of insects and birds in the area and the
presence of insects in the soil.

d) Identification of the number of housing units in the plot affected by the spraying
operation, for their location under or near the aircraft track and estimation of the
number of persons living in each unit.

e) Identification of lentic water bodies (lakes, water holes and the like) located in
the aircraft track, as well as ravines or rivers which might have received
herbicide.

The corresponding information must be completed in a form similar to IVC-01

attached.

The Operation Global Efficiency Index € consisting of the relationship between the
damaged surface not subject to PECIG and the surface with illicit crops effectively

sprayed. The result, expressed in percentage, is an indicator of the external
factors generated by the spraying:

• If E <10%, the efficiency can be considered high, since it means that the
damaged area not covered by illicit crops is very low or, in other terms, that
the herbicide has fallen almost completely on the illicit crop.

• If E is between 10 and 30%, it can be considered that the efficiency is
moderate.

• If E is between 30 and 50% it can be considered that efficiency is low.

508 Annex 33

• If E > 50% it means that efficiency is very low, or, in other terms, that the
damaged area not covered by illicit crops is higher than the sprayed area
with illicit crops.

3.2.3 Efficiency of the corrective action

If the existence of damages caused by the eradication activities is established,

PECIG must adopt the corresponding correction measures, such as mitigation or
compensation, based on CNE Resolution No. 017/2001. and in accordance with
the procedure set out in this Resolution and summarized in the Social

management Program of this EMP.

The information contained in the ICV-01 form will apply only to inspection visits and
samples, verification and environmental control, to evaluate the environmental
efficiency of the program as a whole, but in no case it will be used to accept or

acknowledge any third party damage which must follow the procedure of
Resolution 017/2001 as said above.

The National Narcotics Directorate (DNE) and the Anti-Narcotics Police (DIRAN)

shall submit an annual report to the Ministry of Environment, with copy to the
Environmental Authorities of the corresponding nucleus, on the outcome of the
assessment of environmental efficiency, and the complaints made by individuals

and Environmental Authorities, as well as of the damages actually remedied as per
Resolution 017/2001 of CNE.

Along with the information on technical verification, the environmental assessment

will also form part of a database to be integrated into the Geographical Information
System, which will allow to establish the recovery dynamics of sprayed areas, and
the dynamics of the illicit crops.

3.3 FINAL REPORT

The results of the verification program must be presented in a document
containing:

• Participants in the verification activities

• Verification records (see form attached)

• Methodology of the process

• Results
• Recommendations

• Photographic or video record of sampled plots and sectors.

509Annex 33

3.4 MULTI-TEMPORAL ANALYSIS

As a complement to the verification process described above, a multi-temporal
analysis of the sprayed areas and of the dynamics of the illicit crops is

recommended. This analysis must be supported with the following instruments:

a) Annual censuses of illicit crops areas per town, department and nucleus
(region), based on satellite images, aer ial photographs and field testing,
using the same system used at pres ent by SIMCI (see attached document:
Metodología para el monitoreo de cultivos ilícitos en Colombia mediante
interpretación de imágenes satelitales, SIMCI, 2001).

b) Results of the control program, verification and control of spraying activities
as described in this RECORD.

This analysis must yield the following results as minimum:

• Variation over space and time of illicit crops areas in Colombia, by

municipality, department and nucleus.

• Variation over space and time of areas under aerial spray with glyphosate,
by municipality, department and nucleus, based on DIRAN´s annual
reports.

• Effect of the aerial spraying program of glyphosate on the expansion of illicit
crops areas, by municipality, department and nucleus.

• Consolidation of the environmental ef fects of the program of illicit crops
eradication by aerial spraying with glyphosate, particularly in the following
aspects:

*Damage to lawful crops area

*Damage to pastures area
*Damage to forests and other forms of vegetation
*Number of households and rural subsistence farmers damaged (including

settlers and the indigenous population)

510 Annex 33

• Number of proven cases of health damages reported by sanitation posts
and hospitals located in the spraying areas, attributable to the aerial
spraying operations.

The above must be included in the Annual Inspection, Verification and Control
Report of the Program for the Eradication of Illicit Crops by Aerial Spraying with

Glyphosate –PECIG.

4. SCHEDULE

The Inspection, Certification and Control Program will be conducted throughout the

year, after the spraying operations, in the zones and plots established according to
the above methodology. Spraying and verification time must not be less than one
month nor more than two.

5. FOLLOW-UP AND MONITORING

Follow-up and monitoring of this activity will be given by report verification per
operation and the multi-temporal annual reports.

6. ACCOUNTABILITY

The following will be accountable for the operations:

• National Narcotics Directorate (DNE)

• Anti-Narcotics Police (DIRAN)
• SIMCI PROJECT (UNDP-DNE-DIRAN)

7. COSTS

Environmental costs will consist of salaries and administration expenses of an

environmental expert team and a project manager, estimated at COP237,000.000
per annum. All other operating costs of the Program (transport, aircraft, technical

verification experts, etc.) are PECIG´s ordinary expenses and therefore, are not
considered EMP costs.

END OF INSPECTION, VERIFICATION AND CONTROL SPRAYING
OPERATIONS PROGRAM

511Annex 33

SAMPLE VERIFICATION REPORT FORM FOR ILLICIT CROP SPRAYING

ANTI-NARCOTICS POLICE

MINUTES No.____/ ON SPRAYING VERIFICATION ON COCA CROPS BY
AERIAL SPRAYING IN THE DEPARTMENT OF ______________

=================================================

In ________ on ___ of ____, 201__, there met at the Anti-Narcotics Base of
_____, the Joint Verification Commission comprised by the following persons:

Head of the Eradication of Illicit Crops Area

Coordinator of the Verification Group

Environmental Auditor

National Narcotics Directorate (DNE)

Member of the Verification team

Member of the Verification team

Member of the Verification team

1. OBJECTIVE

To make field verification and to verify the effective death and present condition of
coca shrubs aerial sprayed with Glyphosate, between ________and _______ in
the Department of _______________

512 Annex 33

2. GENERAL

To meet the above, the commission proceeded with activities in the following

conditions:

• Day_____ Month _____ Year_____.

• Travel of the joint commission from Bogotá, D.C. to the Anti-Narcotics Base
of ________.
• Introduction of the Commission to the Base Commander and installment of

the Commission.
• Meeting of Police officers and Environmental Audit for setting up the
Verification Program of sprayed crops between the months of _______ and

_____ in the Department of _______.
• Submission of the pre-selected statistical sample

• Analysis of system files of the Satloc flight selecting sprayed crops
coordinates as per system, as shown in Chart No. 1

513Annex 33

CHART. 1: Plot selection per date and coordinates

PLO SPRAYI VERIFICATI SATLOC G.P.S. AREA LOCATI PHOTOGRA

T NG ON DATE COORDINAT FIELD S ON PH
N O. DATE ES COORDINAT (has

ES )

• Coordination with Air Service staff for displacement of fixed-wing and
rotatory-wing aircraft selected for the study.

• Coordination with the base Commander for displacement of operating

staff to support ground staff.
3. RESULTS

• All security measures required for helicopter displacement of the Joint
Verification Commission to the surveyed area, taking the corresponding

security measures.

• Number of descents of the Joint Verification Commission made to the
previously selected plots for the survey, thus establishing the results of the

aerial spraying done.

Chart No. 2 shows the possible criteria for assessment of the Verification Program

in the coca shrubs.

RESULTS OF FIELD VERIFICATION

PLOT FIELD GPS AREA RESULTS OF EFFECTIVE% COMMENTS
NO. COORDINATES OF ILLICIT CROPS DEATH
YES OR NO

Density: _____ plants/ha Pruning:
_________
Defoliation _____ %
plant Death

Chlorosis _____% plant Descending _______

Rossetting _____% Ascending _______

514 Annex 33

Necrosis: Crop:

Terminal buds _____ Alternate ______

Branches ______ Related _____

Stems _____ Regenerated

Plantation_____

• The verification process was conducting following the procedure of the joint
verification of illicit crops control endorsed by the Anti-Narcotics Directorate,

Environmental Audit and the Anti-Narcotics Police.

4. CONCLUSIONS

Efficacy of aerial spraying: Effective death of coca shrubs located in the ______
region varies between ___ and ___% for plots sprayed between _______ and

____, considered as.

Evidence of pruning: _________________________________________________

Evidence of plot abandonment: _______________________________________

Crop behavior in present conditions: ___________________________________

Topography: ______________________________________________________

Presence of obstacles (trees) hampering efficacy of illicit crops spraying: ___

_________________________________________________________________

Regeneration of natural species: _______________________________________

Evidence of damage to flora and fauna caused by spraying:__________________

Types of predominant soils in the surveyed area:___________________________

In communication No. _____ of (date) _______ Environmental Auditor was

requested to attend to the verification of the spraying of illicit crops.

515Annex 33

In communication No. _____ of (date) _______ National Narcotics Directorate was
requested to attend to the verification of the spraying of illicit crops.

There being nothing further to report, this verification is closed. This document is
signed by the parties once they read and approve same.

________________________

ENVIRONMENTAL AUDITOR

________________________

D.N.E.

________________________

INVITED OFFICER

________________________ __________________________

HEEFDI VERIFICATCONORDINATOR

516 Annex 33

INSPECTION, VERIFICATION AND ENVIRONMENTAL CONTROL FROM OF

AERIAL SPRAYING WITH GLYPHOSATE

FORM IVC-01

1. APPLICATION EFFECTIVENESS OF ENVIRONMENTAL MANAGEMENT MEASURES
TYPE OF MEASURE Regulation Real Complies

(Y / N)

Coca Puppy Coca Puppy

Operational Flight altitude <30 <15
(meters)

Aircraft speed 120-150 130-

(miles/hr) 150

Wind speed (m/s) <2,05 <2,05

Water bodies Yes

Exclusion Nature Parks Yes

areas
Human settlings Yes

Aqueduct supply Yes
basins

Lentic water bodies 100

(m)

Lotic water bodies
Security (m)
strips

(Alert Nature National No
Parks areas (m)
system)
Human settlings;

small villages, rural 1000
districts¸
reservations, towns

(m)

517Annex 33

Plantations other 5-10
than illicit crops (m)

Socio-economic
areas (productive
projects, social pact 1000

zones) (m)

518 Annex 33

2. EFFICIENCY ASSESSMENT OF ENVIRONMENTAL MANAGEMENT MEASURES
Affected Type of Successional Damage Affected Owner *
element coverage stadium or observed area (ha)

or crop crops cycle

Natural
vegetation

(CNV)

Crops or
pastures
(CP)

Extent of Biological Number/m2 Extent of recovery (high,
natural type medium, low)

recovery

Human Housing Persons (#) Extent of damage (high, medium,
settlings units (#) low)

Efficiency Natural vegetation area affected + crops
and pastures affected divided by area of E =
sprayed illicit crop and multiplied by 100 E =

(ACVN + ACP/A CI100

* Indicate whether it is the same (M) or different (D) than the illicit crop
** Aci: sprayed illicit crops area

519Annex 33

RESEARCH PROGRAM FOR REPRESENTATIVE AND
DEMONSTRATIVE PLOTS RECORD 7

1. DESCRIPTION OF PROGRAM ACTIVITIES

Although available theory (see environmental impact chapter in this document) on

glyphosate effects concludes that glyphosate does not act on seeds in the subsoil
nor is absorbed by roots, nor it has prolonged residual action to sterilize soil, some
stress that the herbicide generates considerable damage on soil and on its

biological communities. This is notwithstanding that glyphosate is one of the
herbicides with higher use in Colombia for controlling clean crops weed, as well as
in crops such as sugar cane and oil palm, and that Colombian Agriculture and

Livestock Institute - ICA has approved its use in Colombia.

For this reason, Article 7 of resolution 0341/2001 of the Ministry of Environment
provides for the investigation on demonstrative and representative plots to enable

to solve doubts of the scientific community on the real effect of glyphosate on soil,
on plant succession processes and soil microorganisms.

2. OBJECTIVES

• To study the regeneration and ecological dynamics of sprayed zones by
demonstrative and representative plots of nuclei of higher concentration
of illicit crops obtained in censuses.

• To determine residues of glyphosate in soil and its affectation in physical-
chemical-biological properties of same, using the same demonstrative plots.

In this sense, the investigation is aimed to raise, on a sample of sprayed zones

with PECIG glyphosate and non-sprayed zones, an inventory of biological
communities of soil and their vegetation, at different times lapsed since its
application. On the other hand, the residue survey of the herbicide aims to

establish the adsorption level by soil solution and its compounds, as well as on
groundwater.

520 Annex 33

3. ACTIVITIES

The activities proposed for the development of an investigation methodology are

the following:

3.1 Sampling strategy

According to requirements of the Ministry of Environment, the investigation must

meet two requirements: to be representative and demonstrative.

Representative values

To achieve a representative value for national coverage or PECIG, and regional
level or of each nucleus or coca plantation area. Also, to consider the number and
size of plots.

Station is the area where investigation plots are to be located. No permanent
premises are necessary, but conveniently distributed plots and barbed-wire fenced
where periodical samples can be taken.

In each station, the following criteria will be taken into account:

* that soils correspond to soil types common in the region or nucleus,

* that climate corresponds to the predominant climate in the nucleus,

*that proposed measurements and inventories are possible to make
(access)

* that security issues do not prevent making measurements and inventories.

For security reasons, it is suggested that areas where plots are to be located are in

or near operations or in institutional State´s areas. In order to guarantee security
and permanence in the investigation, it is necessary to make tests in State owned
areas such as Autonomous Regional Corporation (environmental), CORPOICA,

Universities, Research institutes, Armed Forces, etc. Some possible places to
conduct these tests are:

521Annex 33

* Macagual Research Centre, owned by CORPOICA, Department of
Caquetá

* Acacías Prison (Colonia Penal de Acacías), owned by INPEC, department
of Meta,

* Research Centre of Universidad de la Amazonía, owned by Universidad
de la Amazonia, Department of Caquetá.

The definition of the sample site requires visits and agreement by entity owners.

• Size. To establish the plot size, the “m inimum area” criterion is proposed to
be used, that is, the area in which the number of species becomes constant

or increases mildly (aerial curv e vr. number of species becomes
asymptotic). In tropical zones, the minimum area may vary between some
tenths to hundredths of meters, depending on the type of medium. However,
it is suggested that the plot area is not less than 100 nor more than 200 m2.
The entity to conduct the research ma y propose alternatives to allow the
reasonable assessment of the ecological dynamics of sprayed plots.

• Number. Regarding number of plots, a total of 10 is recommended, which
will be subject the treatment described below under 3.2

Plots will be rectangular in form, compass surveyed, wired-barbed fenced and

georeferenced (Figures 1 and 2)

3.2 Treatment

The 10 plots must be initially in pastures or temporal crops. No forest area must be

logged.

• One of the 10 plots will be left for evolution of natural succession, with no
application of glyphosate.

• The remaining 9 plots will be subject to the following treatment:

* Six months old, 3 coca crop plots sprayed with glyphosate, with twice the

dosage used in spraying operations.
* Six months old, 3 coca crops sprayed with glyphosate, with the same
dosage used in spraying operations,

522 Annex 33

* Six months old, 3 coca crops sprayed with glyphosate, with half the
dosage used in spraying operations,

*In the witness plot and in one of each of the other tress groups, a 5 m
deep phreatimeter, 2” diam PBC tube will be installed to take samples of
ground water samples for analysis.

The same treatment must be replicated in poppy nuclei stations. Each plot will be
wire-barbed fenced to avoid entry of animals. After glyphosate application, all plots
will be left to natural evolution, that is, will not be subject of cultural measures, in

order not to alter the evolution conditions post-spraying. This type of treatment is
proposed, since, while it is true that applied dosages in spraying of illicit crops are
more or less constant, it may happen that, in the case of dumpling, for example,

higher glyphosate amounts be discharged on the soil.

3.3 Soil samples and analysis groundwater

A compound sampling in each plot (in 10m grids in side) will be made before

spraying and one quarterly in the rest of the year, at 10 and 30 cm deep, taking
into account the following parameters. Physical determinations will be taken from
upper 10cm.

3.3.1 Chemical determinations:

The basic objective is to establish glyphosate concentrations and AMPA, its main
metabolite, in soil and water. The laboratory methods to be used might be different

according to the available technological developments. However, the following are
some proposals on the matter:

Measurement of glyphosate with high performance liquid chromatography (HPLC)
or gases/masses.

HPLC methodology is applicable for water samples and determination in soil

samples expressed in a liquid matrix, from saturation extract. The analytical
method consists in detecting the presence of glyphosate and its main metabolite,
amino-methylphosphonic acid (AMPA). The analysis is based on EPA 547

methodology, using HPLC equipment.

Determination of the adsorption of glyphosate and AMPA in soils

Each soil sample from the study area is added three levels of glyphosate

concentrate (proportional to those applied in field), and the same three levels of
soil sample form AMPA. Each soil sample corresponds to 1 g and is allowed to

523Annex 33

incubate for two weeks, stirring periodically. Subsequently, it is centrifuged and the
supernatant is removed.

The soil is washed with distilled water, then re-centrifuged and the supernatant is
removed again. This procedure is repeated until a given volume us reached. To
remove the excess, soil is washed twice with ethyl alcohol. The concentration of

glyphosate and AMPA adsorbed is equal to the difference between the two
components sorbed in the treated sample and in the untreated sample.

Determination of glyphosate and AMPA retention level after washing

In each of the representative samples, the soil is prepared in such a way as to
obtain, in addition to the original level (N0-without the addition of glyphosate and
AMPA), three levels of initial concentration (N1, N2 and N3) of glyphosate and

AMPA adsorbed.

For concentration levels 1 to 3, soil samples are taken from 120 g and incubated at
room temperature for 24 hours with 100 ml of glyphosate and AMPA in different

concentrations to be established.

Determination of lixiviation level of glyphosate and AMPA in soils

The field experiment is based on a lysimeter study that involves collecting
percolating water extracted under low voltage (0 to 5.4 kPa) with the help of
sensors for glass fiber strands installed in undisturbed soil.

In two subplots for treatment with and without application of glyphosate, two
catchers are installed in fiberglass strands placed at the center of each subplot at
depths of 30 and 100 m. The catcher located at 30 cm allows collection of

gravitational water and the other catcher collects water that drains groundwater.

524 Annex 33

The process is made comparing plots not affected by the application of glyphosate
with plots affected with application. With the exception of organic matter, this part

is made based on the study of ion movement in ground with the use of
microlysimeters, and installing a battery of same in permanent study plots for soil
extraction. Contents are then analyzed with HPLC technique.

3.3.2 Physical determinations

In order to understand the dynamics of glyphosate and its effect on physical and
chemical properties of soil, it is recommended to study the degree of impact on

nine soil physical parameters. It is intended to assess the impact of the application
by comparing affected plots and unaffected plots by the presence of glyphosate.

Laboratory tests for this type of determinations are:

Textural analysis. Procedure performed by granulometric analysis using the Lowy
Pipette technique.

Structural analysis. Soil structural stability is evaluated by determining the degree

of aggregation, aggregate stability and the nature of empty pore space. The
technique corresponds to the Yoder screening method.

Consistency analysis. The consistency limits, also called Atteberg limits are

working rates which are affected by water content in soil. The limits correspond to
the plastic limit, liquid limit and plasticity index.

Total porosity. Is an index of the relative volume of soil pores. A procedure
originated from derivative formulas.

Apparent density. Is the relationship between the soil mass and the apparent
volume of the unit itself. The apparent volume includes the volume of solid particles
of soil and pore space. The procedure corresponds to the cylinder methods.

Retention of soil moisture. Is the amount of water that soil can store and is known

as moisture holding capacity. The action of adhesion, cohesion and capillary
voltage forces generate the soil moisture. The procedure is to use dishes and

525Annex 33

pressure cookers to generate different pressures that generate moisture retention
curves.

3.3.3 Groundwater

Each quarter, until 12 months after spraying, a sampling an analysis of
groundwater extracted from each of the 4 wells in each station is done. The
parameters to determine are:

Measurement of residual glyphosate by the high performance liquid
chromatography (HPLC) technique.

3.4 Sampling and analysis of vegetation

It is necessary to know the behavior of vegetation over time when glyphosate is
applied, determining the successional process. To this effect, a quarterly inventory
of all existing vegetation in each plot will be made, including the control plot,

determining abundance-dominance levels.

The information collected from each subplot will be the following:

Species, which if field is not identified, a sample should be collected for botanical

identification in herbarium.

Number of individuals per species (in herbaceous, it will estimated by direct
counting in small areas and extrapolating to the entire area, if not uniformly

distributed.

Height and DBH when greater than 10 cm.

With the information obtained, diversity, frequency, abundance and dominance
levels of each species are calculated, as well as its spatial distribution through

idealized profiles.

3.5 Biodiversity sampling and analysis of microorganisms

526 Annex 33

As for soils, a compound sample is taken in 10cm grids in side, 10cm deep, every

three months. An analysis of the number of cells per gram of soil of the following
microorganisms is made for each sample:

Bacteria

Mycelial fungi (Hyphae meters)

Yeast

Algae and cyanobacteria

Protozoa

The number of cells per gram of soil of nitrogen-fixing bacteria will be established.

The number of viable microorganisms per gram of soil analysis will be established.

For the total count of cells present in each sample of soil the counting method by
direct microscopic observation will be used.

For the total recount of viable cells, the plate counting methodology or the most
probable number (MPN), as appropriate.

As for soil and water, a vegetation and microorganism sample and inventory will be

done for each plot (in 10 m grids per side) before spraying and one quarterly for
the rest of the year.

3.6 Analysis of the information

527Annex 33

Based on the quarterly analyses, a comparative analysis of the situation of soil,
water and plant and microbial communities in each plot will be made, in order to

detect, by statistical methods, significant variations between the various
treatments. At the end of three years, a final report comparing all plots and nuclei
and their results will be prepared and forwarded to the Ministry of Environment, re

respective CAR and agencies.

4. SCHEDULE

Basic research will take place over one year. In the first quarter the station site is

selected, plot design is made and plots are installed. Then, in each quarter,
information will be taken and analyzed. The first sampling will be made before
spraying. The second sampling will be made 5 days after spraying, and

subsequently, every three months.

5. FOLLOW-UP AND MONITORING

• Plots selection and assembly
• Sampling and quarterly analysis (5)

• Analysis reports of quarterly data (5)
• Final report at national level

6. ACCOUNTABILITY

The research contractor of the permanent monitoring of the Anti-Narcotics
Directorate (DNE), Anti-Narcotics Police (DIRAN) and Environmental Audit will be
the person responsible for this program.

7. COSTS

The cost per station will be COP 150.000.000 distributed as follows:

Plot establishment: $ 2.000.000

4.000P0r0e0atimeters: $

528 Annex 33

Soil analysis: $ 48.000.000

W4a0ery.0:0 $

Vegetation inventory: $ 24.000.000

Microbial analysis: $ 48.000.000

To1t5l.000.000

END OF PLOT RESEARCH PROGRAM

529Annex 33

BASIC ENVIRONMENTAL MONITORING RECORD 8
PROGRAM

1. DESCRIPTION OF THE ACTIVITY

Aerial spraying of illicit crops with glyphosate generates potential environmental
and social impacts, and its magnitude and importance depend to a large extent on
the spraying technique used and the conditions of the area, particularly soil use,

topography and weather conditions.

For each of these activities under the Program for the Eradication of Illicit Crops by
Aerial Spraying with Glyphosate –PECIG, those performed in the operation sites of
the Anti-Narcotics Police and those of spraying as such, the specification Records

of the EMP include a set of technical and environmental specifications intended to
prevent, mitigate, correct and compensate potential impact. The reason for this is
that a program of this nature generates, necessarily, environmental and social

impacts needed to know in order to take decisions on changes in methods, areas
or operating parameters. Only monitoring and follow-up may provide the
information to feedback the program.

2. OBJECTIVE

The purpose of this activity is to monitor the various activities of the Program for
the Eradication of Illicit Crops by Aerial Spraying with Glyphosate –PECIG- in order

to measure the real impact caused by them on the environment, especially on soil,
water, vegetation, land uses and on the health of the population in the sprayed
areas, and take appropriate control measures.

3. ACTIVITIES TO BE PERFORMED

According to the results of the Environmental Impact Assessment (EIA), the main
impacts of the project may be on soil, vegetation, wildlife, water quality and health

530 Annex 33

of the exposed population in sprayed areas. Consequently, the monitoring
program should emphasize these variables.

3.1 Soil monitoring

a) Soil quality

The best to determine the actual impact on the ground is by conducting research in

experimental and representative plots of various PECIG areas where it is possible
to measure the residual herbicide in the soil at different times after application. For
this purpose, a special research program in representative and demonstrative plots

have been designed, which, by its nature, is included in a separate Record of this
EMP (see Record7). Based on each quarter results, a contamination level of
glyphosate resulting from the division of the mean level found in each plot by the

maximum tolerable level for worms in soil, I addition of other indicators foreseen in
the research design will be determined. Also monitoring will be conducted to
determine residual herbicide in soil, following parameters of Record7 - Research

program for representative and demonstrative plots.

b) Soil microorganisms

Within the same research in plots, biomass of microorganisms and/or worms in soil
will be determined at different times after application. The measurement indicators

and the corresponding methodology is shown in Record7 - Research program for
representative and demonstrative plots. Based on the results of each quarter, a

contamination level with glyphosate will be determined, resulting from the division
of the mean level found in each plot, by the level found in the control plot.

3.2. Water quality monitoring

PECIG contemplates the exclusion of water bodies and a security zone around

them, where no glyphosate spraying should be done. However, given the speed
with which glyphosate is dissolved in water and is adsorbed by sediments and
degraded by microbial action, the sample of a stream that has been accidentally

reached by the spraying, several hours or days later would not yield positive results
to a possible contamination with glyphosate.

531Annex 33

For the above reasons, water monitoring has been approached from two
perspectives:

• Identification of possible bodies or water currents that might have been hit
by sprayed glyphosate, by running ef fect, performed during the inspection,
verification and control process following sprayings, as provided for in
Record6.

• Installation of a phreatimeter battery in each research station in
experimental and demonstrative plots, where migration of the herbicide to
the groundwater layer is measured.

Based on the results of each quarter, a contamination level of glyphosate will be
determined, resulting from the division of the mean level found in each plot by the
maximum tolerable level for fish. It also contemplates other indicators of Record7,

Plot Research.

3.3 Monitoring of natural vegetation

The aim is to measure the real impact of spraying the remaining native forests and
other vegetation in sprayed areas. To this effect, as in the case of water, the

procedure will include three complementary approaches:

• Identification and determination of forest areas affected, measured in terms
of area and number of trees and the degree of damage (death, temporary

defoliation, other), according to the methodology established in: Inspection,
Verification and Control spraying Operatio ns (Record6). This will make it
possible to establish the area (n ha) and biomass (in # of trees) actually
affected by the spraying operations.

• Determination of the spraying effect on plant succession of recovery of the
areas occupied with illicit crops, starting with the pioneer herbaceous
vegetation that grows immediately after spraying. As in the case of soil, the
best way to determine this effect is through research in demonstrative and
representative plots of the conditions of each nucleus, making an inventory
of vegetation that grows at different times after spraying, and comparing this

evolution with what happens in control plots that have not been sprayed.
This will make it possible to establis h the effect of glyphosate on natural
vegetation succession, that is, on the possibilities to regenerate natural

532 Annex 33

forest, based on the floristic composition compared between the various
plots with different horizons over ti me. Record7 describes the methodology
of the proposed research.

• Determination of allowable residues in plant tissues, according to the
provisions of FAO standards.

Based on the results of each quarter, a contamination level with glyphosate will be

determined, resulting from the division of the level found in each plot by the level of
the control plot.

3.4 Land use

Although land use depends mainly on many factors other than spraying with
glyphosate (see Chapter on impact assessment), the National Narcotics
Directorate with the support of the United Nations, have set up the Integrated Illicit

Crop Monitoring Program – SIMCI – based on the interpretation of satellite
images,, whose objective is to map the annual evolution of land use in illicit crop
areas. The methodology of this project, included in annex No. 1, should produce

the following results by year:

• Digital mapping in space-maps based on satellite images of the industrial
and rural plots of illicit crops in each of the nuclei or zones plots under the
eradication program with glyphosate.

• Quantification of areas occupied by illicit crops of industrial and rural nature,
at municipality, departmental and nucleus level.

• Comparison of change in land use (in hectares and percentage) produced in
the year under monitoring with respect to the previous year, also at the
municipal, departmental and nucleus le vel, considering the following
categories of which SIMCI is mapping:

Primary forest

* Secondary forest

* Stubble

* Pastures

533Annex 33

* Illicit crops

* Other crops

* Economic infrastructure (road, airports, etc.)

* Surface water

* Areas of human settlements

• Consolidated charts at national level, of illicit crops area and their annual
variation.

3.5 Rural economy

Drift can cause lawful crops near illicit crops to be hit by glyphosate, with the
consequent losses in agricultural production. The monitoring of this impact is done

in two complementary ways:

• Identification and determination of areas in affected lawful crops, measured
in terms of area or number of plants, whether temporary or permanent crops
and the degree of damage (death, defoliation, other), according to the
methodology established in “Inspection, verification and control of spraying

operations” (Record6). This will make it possible to establish the area (in ha)
and biomass (in # of plants) actually affected by the spraying operations.
The same procedure applies to forests and other types of vegetation.

• Annual inventory of the number of complaints for damage to crops in each
municipality where the PECIG operates, and complaints actually recorded
and paid for, according to statistics maintained by DIRAN and DNE, as per
resolution No. 017/2001 of the Anti-Narcotics Council (CNE).

As a result of the inspection data and field verification, an index of overall efficiency

of the spraying operation will be estimated, by the ratio of the affected area by
lawful crops in forests by the sprayed area in illicit crops. The higher the ratio is,
the lower the efficiency. Based on the above information, annual consolidates

nationwide will be made.

534 Annex 33

3.6 Health of the local population

The monitoring of the effect on the health of the population exposed in the sprayed

zones must be closely related to the epidemiological monitoring provided in the
Social Management Program (Record 9). According to this Program, monitoring
should refer basically to verify that epide miological monitoring objectives of the

social management program were met in the following aspects:

[Page 234]

• Number of epidemiological monitoring campaigns established jointly with
departmental health authorities and in effective operation, every year.

• Number of training seminars for hospital and health centre staff in
physiological and sanitary aspects linked to the possible effects of
glyphosate and number of staff attending same.

• Number of suspicious events due to spraying activities, reported by the
health authorities (or number of cases of diseases reported and audited).

• Treatment expenses (in current pesos) paid by the DNE or DIRAN
effectively proven of diseases caused by glyphosate.

At the same time, a morbidity chart and total number of consultations per month
will be made. By dividing the number of inquiries for proven diseases caused by

glyphosate over the total number of co nsultations, the frequency of diseases
caused by glyphosate will result, and will be a global indicator of its relevance.

3.9 Educational communication

Follow-up will be made on the following indicators, amongst others, based on the
goals set in the Educational Communication Program (Record10):

• Number of seminars, workshops and training courses for pilots, operation

site staff, medical and paramedical staff of hospital and health centers.

• Number of press reports on eradication activities with glyphosate and its
complementary or compensatory activities.

535Annex 33

• Number of the DNE magazine volumes.

• Permanent operation of the DNE website.

• Appropriate signage for each operating site.

3.10 Management plan

It is also important that monitoring provides follow-up of the overall PECIG
environmental management, in order to determine compliance level with the

Management Plan. According to the environmental management program, this
monitoring should relate, especially to the following aspects:

• Creation and operation of the Environmental Sub-Directorate and Social

Management of DNE for PECIG.

• Percentage or level of performance for all programs of the Environmental
Management Plan.

• Level of compliance with coordination activities established by DIRAN, the
social support organizations (PLANTE, Solidarity Network, Ministry of
Health) and the Interinstitutional Technical Committee and territorial bodies.

• Level of compliance with environmental management functions and social
management established in the EMP.

4. SCHEDULE

The monitoring activity should be permanent during the eradication with

glyphosate. The Environmental Sub-Directorate and social management of PECIG
will prepare a detailed monitoring system for each year which will be submitted …

[Page 235]

… to the Ministry of Environment. According to this program, it will send quarterly

reports to the Ministry and to the CAR offices in each nucleus.

536 Annex 33

5. FOLLOW-UP AND MONITORING

Follow-up and monitoring will consist in the regular verification by the program

audit team and environmental management of compliance with the specifications
defined in this EMP.

Chart No. 1 shows a summary of the indicators to be obtained by PECIG´s

environmental monitoring program.

6. ACCOUNTABILITY

The DNE, through the Environmental Sub-Directorate and Social Management or
its delegate will be the entity responsible for this activity. However, DNE may sign

agreements with AGUSTIN CODAZZI GEOGRAPHIC INSTITUTE OF COLOMBIA
- IGAC, INSTITUTE OF HYDROLOGY, METEOROLOGY AND ENVIRONMENTAL
STUDIES - IDEAM, the Ministry of Environment, the CAR offices, universities and

other research entities to execute same, or subscribe it with private entities.

7. COSTS

The cost of environmental monitoring is already included in the corresponding

programs, as follows:

• Soil: Considered in the plot research program
• Water: Considered in the plot research program
• Vegetation: Considered in the plot research program and inspection,

verification and control.
• Use of soil: Considered in the ordinary SIMCI Project budget.
• Rural economy: Considered in the inspection, verification and control
program.
• Health and sanitation: Considered in the social management program

(health care activity)
• Management plan: Considered in the environmental and social management

END OF THE BASIC ENVIRONMENTAL MONITORING PROGRAM

[Page 236]

537Annex 33

CHART. 1

MAJOR ENVIRONMENTAL INDICATORS FOR PECIG ENVIRONMENTAL

MONITORING PROGRAM

SOIL
NATUR MICRO HEALTH
8 AL RURAL
SOILS WATER VEGETA SOIL USE ECONOMY POPULATI
ORGANIS ON
TION MS

MAJOR INDICATORS

Residual Concen # Bacteria*** Digital maps crop Licit crop Epidemiolo
1 1 2
glyphosate tra-tion species areas area (ha) gical
concentrati residual affected formonitoring
on and glyphos temporary campaigns
1 4
AMPA ate and crops (#)
AMPA 1 according

to damage
level

Adsorption # Mycelial Industrial and ruralNumber of Training
level of individualfungi*** illicit crop areas pplants seminars

glyphosate s/ 1 municipality, affected (#)(#) and
and specie department and for number of
AMPA 1 nucleus (ha) permanent attendees 4

crops
according

to damage
level

1 1
Retention Height** Yeast*** Forest, stubble, # of claims # of
level of pastures, illicit filed suspected

glyphosate crops, other crops cases 4
and per municipality, reported
AMPA 1 department and
2
nucleus (ha)

Retention DAP** 1 Algae and Changes in # of proven Treatment

level of cyanobact vegetation every and paid forexpenses
glyphosate eria *** year, regarding claims4 paid for by
4
and previous year (in % DIRAN ($)

538 Annex 33

AMPA 1 and ha).

Lixiviation Protozoa**
index *

glyphosate
and
1
AMPA

i. SECONDARY INDICATORS

Texture1 Biomasa

lombrices
(g/kg de

suelo)

Structure1

Consistenc
y1

1
Porosity

Density1

Humidity
retention

GLOBAL AND MANAGEMENT INDICATORS

N = N N=Np/Nt N IEG = (SCL+ABA) / SCI 5 F=Cgr/Ctot7
6 6 6
Np/Nmx =Np/Nm es =Np/Ntes
x 6 SCL = Licit crops area. ABA =
Affected forest area. ACI = Illicit

crops area spayed

Environmental Subdirectorate and Social Management in operation

Compliance % of EMP programs

Number of interinstitutional coordination meetings

Number of seminars, workshops and training courses

Number of press reports

539Annex 33

Number of DNE publication volumes

Permanent DNE´s web page in operation

Adequate signage of each operation site

* Glyphosate metabolite (aminomethylphosphonic acid). ** For shrubby and tree-
like species. *** Number of cells/g
1: Measured in plots. 2: Satellite determined (SIMCI). 3: Determined in program´s
inspection, verification and control visits.
4 5
: Determined in social management program. : IEG = Global efficiency index6of
spraying operation, as per results of inspection, verification and control visits. : N =
Contamination level. Np = Level in each plot. Nmx = Maximum tolerable level for

worms in soil7or fish in water. Ntes = Control plot level (for all parameters
measured). : Fg = Morbidity frequency due to glyphosate. Cr = Glyphosate visits.
Ctot = Total consultations in hospital or health center. 8: Texture, structure,
consistency, porosity, density and humidity retention will be determined and used

once to establish differences that explain soil behavior for glyphosate
contamination.

540 Annex 33

COMMENTS LANLaIPor(tclgrivitstittnd- ICA)

METHODOLOGY Anamletamlslssilcaxrpn.guigistfs Anametcolds

REGULATION 10/03r.9398, U.S. EPA

ILLICIT CROPS AX Decree 475

M
IN
RANGES 0,1 <700

M

UNIT Mg/Ltr µ g/L

VALUE 0,01 700

/NDEX

INDICATOTERM connce(tryihosate Macx. tvegn(fntsG)lyphosate 0,1 µ g/L <0,1

ENVIRONMENTACOMNENTATORS WATERNPlaguicideICABLE TO THE PROGRAM FOR THE ERADICATION OF

541Annex 33

PEhCaIvHmronteeecftzo,aiereibtayinttainuorte.d Samhpuisplifetrion

AnmletcoldsAinmiettors. Anamletcoos.olntmotoaweeiohttme

Union methU.S. EPA 10/03rt/998. Dec1re0rt2918f2.

100

0,001 400

µ g/L g/m3

0,0011 6,5-9 ph 9 6,5 Decree 475 100

conceExpmectnpirfcralproeential suspdeilyehosat

AIR Particles

542 Annex 33

Detseudcnasioncolf Appcliverareenst to iittsdcnsstoncolf

uniitsfairwihereabunFdielces.ampField sampling Field sampling

units units/h

# of saenties indiviperela unit #sfpecinetferoifgivieacnrdnvesntorie

of individuDensity # of Mixqturoetient

VEGETA TuIN ber

543Annex 33

COMMENTS RefberfocrststtluiCpIoicetioRefearfornstcntl ieseaefornstcntl ries

yarumo, balso,
METHODOLOGY FieDetpergieession. Pla(t pioneeFresd,sa(.)omrsitlsField samples,r aerial

REGULATION

AX

M
RANGES IN Bioindicators

M

UNIT # osfpscetere # osfpscetere # osfpsceiere

VALUE Bioirdicat Bioirdicat Bioird(cnnesict7) Days 90 30
/NDEX

INDICATOTERM onadlynamics onadlynamics ic biotdyiversi (typical

COMEPOTN Successi SOIL Successi Bioedaph TD50

544 Annex 33

monitoring mosnioriln,mfelioriln,gfield StatisiesrliefsHealtExpappliratorrs

EPA

Satellite

S0a,ellite Acute

r Numr be # ocfases mgb/odwyeghyt/

0,063 Coveµg/ge HDe/yeaa/dprrea # UpSrsxp#ssedrsffnsted 0,125

melife) mean in soilof ion rates -mosratltics entextovsulftor

ExpecteC dhange Degradat HUMAN HEorLiHity Assessm

545Annex 33

ExpappulircorrsoExpcohidrenforxchsuderio(Mmtl nstiee.tgldthoesadaaluthphtmallfttavent.

CodAelmentarius

Multiply

Chrnoic Acute Chrnoic 23,oradu slt

mgb/odwyegaht/ mgb/odyeight/ mgb/ogwyeight/ µ/kgodyeight/

0,0323 0,097 0,052 23,8

entextlosulftor entextosdulftor entexptosulftor al mamxidualk(TMDI)

Assessm Assessm Assessm Theoretic

546 Annex 33

COMMENTS Chillren 1-6 yrs10 mixtsre/olor.i4ieath/dad1rrtiseAssessment hours of

METHODOLOGY

REGULATION

AX

M
IN
RANGES 51,orchildr 12 6,2

M

UNIT µ/kgodyeight/d bodwyeght/d body

VALUE 51,9 6,2 µ/kg
/NDEX

INDICATOTERM al mamximualk(TMDI) n

COMENTN Theoretic Dermic 12 µ/kg Inhalatio

547Annex 33

applicaAdult worker Adult assessmentasscehsrennt fordt,assfrplhtporakuAdult assessment

Re-entry

US EPA 1997US EPA 1997

3,9-10

Acute 2,6 55,2 4,4 USEPA19907,64

weight/d bodwyegyht/dµ/gowyeighrt/hµgodwyeghrt/h bodwyegyht/d µ/kgodwyeight

56,2 µ/kg 0,52 55,2 4,4 µ/kg 0,64

peak to trateaent to treateent forspectator rectrntted

Exposure Re-enter Re-enter Exposure Swim in

548 Annex 33

Child assessment

con1sumguttanffo3dhildren

US EPA, 1997

Estimated 3370

2,3 45 175 5420

µ/godwyeght/dµ/godwyeight µ/kgowyegyht/d µ/kgodyeight

2,3 45 175 33754-20

waters rectrnladters forrutdotinmp ObdservdEefLet(NlOAELe)xpMsure)

Swim inxposure No Margin of

549Annex 33

COMMENTS ValuyeCgolio-urdcEnsdtivluial.olio-uaAcaAIdriivuial.

METHODOLOGY Addgiiamoisltcidndnic Tecappililtpnss–aeidtls.98

REGULATION Ali19entarius EMP EMP

AX
300

M
RANGES IN <0,3 Codex 3000

M

UNIT bodwyeight micra

VALU0,3 µ/kg 3002-500 10 - 30
/NDEX

INDICATOTERM e dini(ADI) volcmdeirmfetpraredsDM) theoldtiposit

COMEPTN Admissibl AERIAMLeAanPLICATIONS Real

550 Annex 33

EMP comforeruiacoforeruiatlion

epiphytes,

Bio(inscaholcciaField,sessment Mixture control EMP. Glyphosate

EMP specie

<4(2,05)0 140E –8P ator 1M,P L/ha 1,54,5 EMLP/ha M3ixurtrEMlyp. hostMP

speed ure speappncratio for coca for poppy

Wind TemperaAtircraft Drift BioiDDirtges Do <5ages Meters 5 EMP

551Annex 33

Inctrd(tmatntearerretinra,its.)mtent

Fiealdsesmelltit.ringsessmplint.s.FiealdsesSmpliltei.toring

Dec1ree3rc.891, protocol

0,75

100 1

M/ha hecstare

23,5 L/ha 5503,5EML/ha 50 1 400 EMPunrtrol >at 80 Eradicartsapared0% Verification

volcmoca volpmopepy areresntic(ticurty) of app nicatio efficiency

Mixture Mixture Exclusion Efficiency PECI

552 Annex 33

CLAIM FORM FOR DAMAGES OF LICIT CROPS

Name and surnames of
applicant

Identification No

Damaged property

Location of damaged Rural Municipality
property district

Dept Plane N: E:

coordinates

Type of property*

Other type of property or
tenure*

Economic activity of
property

Damage Crop 1: Area M2 # of Quality*
caused plants

Crop 2: Area M2 # of Quality*
plants

Crop 3 Area M2 # of Quality*

plants

Spraying Day MONTH YEAR TIME
date

Date of Day MONTH YEAR TIME

claim

Purpose of Repair Estimated Other
petition value

Which?

553Annex 33

Address for
correspondence:

Documents and 1)
evidence attached
2)

3)

4)

5)

6)

Signature of
applicant

Receiving Name: Title:
officer

Signature of officer

• M: total death. D: temporary defoliation (crop loss in permanent crops)

554 Annex 33

CLAIM FORM FOR ENVIRONMENTAL DAMAGES

Name and surnames of

applicant

Identification No

Title:

Entity

Name of park affected

Location of damaged Rural Municipality
property district

Dept Plane N: E:

coordinates

Type of property*

Other type of property or

tenure*

Present vegetation of site

Damage Forest Area M2 # of Quality*
caused 1: plants

Forest Area M2 # of Quality*
2: plants

Other: Area M2 # of Quality*

plants

Spraying Day MONTH YEAR TIME
date

Date of Day MONTH YEAR TIME

claim

Purpose of Repair Estimated $ Other
petition value

555Annex 33

Which?

Paid value damages recovery of water bodies (if $

applicable)

Address for
correspondence:

Documents and 1)
evidence attached
2)

3)

4)

5)

6)

Signature of
applicant

Receiving Name: Title:

officer

Entity

Signature of officer

• Páramos, sabanas, morichales, low and medium stubble, others in the

area

556 Annex 33

ALERTSIGNS

557Annex 33

558 Annex 33

559Annex 33

SOCIAL MANAGEMENT PROGRAM RECORD 9

1. DESCRIPTION OF ACTIVITY GENERATING IMPACT

The development of a program of the characteristics of eradication of illicit crops by
aerial spraying of a herbicide involves a series of interactions with the communities
of the affected areas, either to inform them about the characteristics of the spraying

or to resolve complaints or conflict that may arise.

Indeed, it is possible that the aerial spraying of glyphosate affects third parties
crops located around the area sprayed on their pets, or accidentally, the product

falls on people, and as a result, their health may be affected. It is also possible that
spraying affects accidentally water bodies used for human consumption, watering
troughs, aquaculture and fisheries, so that it may be necessary to engage in

immediate decontamination programs.

2. OBJECTIVES

The objective of this activity is to achieve a good level of relations with the

population living around the areas of illicit crops spraying areas with glyphosate
and to support it with complementary actions aimed at improving their living
conditions as a mechanism for social viability of the PECIG. The objective also

includes training on the Program for the Eradication of Illicit Crops by Aerial
Spraying with Glyphosate –PECIG and on environmental protection measures
included in EMP. These actions must be complementary to the information and

environmental education provided for in the educational communication Program.

560 Annex 33

3. ACTIVITIES

Indeed, the above objective can only be achieved through the application of socio-

environmental management criteria recommended for the various activities of
PECIG.

Besides these activities, which are basic for the development of the Program, it is

recommended to execute some actions leading to obtain acceptance and
cooperation of the local population and to improve their living conditions. These
actions include five, in particular: interinstitutional support, alternative development

promotion, compensation for damages caused, environmental recovery and
improvement and health attention. Information, education, training, civilian
monitoring, and signage also form part of social management, which by its nature,

have been included in a separate program (Record).

3.2 Interinstitutional support

The Program for the Eradication of Illicit Crops by Aerial Spraying with Glyphosate
–PECIG is a strategy the Government uses to control drug issues. I includes:

• Alternative Development Plan - PNDA. El The Alternative Development Plan

– PNDA aims to promote socio-economic ac tivities to substitute illicit crops,
and which constitute a real alternative for peasants who grow coca, poppy
or marijuana.

DNE will coordinate with PNDA the development of alternative projects in

areas covered by the eradication program. It is assumed PNDA will execute
its projects autonomously and own coverage areas and subject to regional
sceneries where its mission is applied, whose strategic purpose is to reduce

the participation of the target population in illicit crops and to articulate it in
building legal social and economic alternatives, playing a positive role as a
tool for adapting to the conditions to support the peace process.

561Annex 33

Likewise, it must be acknowledged that PNDA´s management model is
supported on the need to engage in actions leading to offer economic and

social development alternatives to the population affected by illicit crops. In
this sense, PNDA has opted to strengthen voluntary eradication based on
Social Agreements for Alternative Development, whose objective is to set

forth agreements with communities affected by the illicit crops who express
their will to eradicate them.

Consequently, the PNDA´s work is defined by the implementation of

regional development processes aimed to discourage population related to
coca and poppy crops.

• Social Solidarity Network. The purpose of this network is to support
communities in areas affected by illici t crops with programs and projects for
health care.

• Investment Fond for Peace. Supports communities and organizations in the
financing of infrastructure projects and social projects.

• Illicit Crops Integrated Monitoring System – SIMCI. The National Narcotics
Directorate (DNE) and the Anti-Narcotics Police, with the support of the
United Nations International Control Programme (UNDCP), designed and
implemented the SIMCI project which developed a methodology aimed to
the permanent and exhaustive monitoring of illicit crops, not only quantifying

them but locating them in the different regions in the country with the use of
satellite images. The monitoring and environmental Record of this EMP and
its annexes shows a more detailed description of this project.

• National and regional coordination. It is of great importance that DNE should

closely coordinate its actions with agencies assigned to the National
Narcotics Council and to the Regional Narcotics Council; also, with
agricultural technical assistance agencies such as Autonomous Regional
Corporation (environmental) (CARs) and Agricultural Technical Assistance
Municipal Units (UMATAs), in order to design and to promote joint programs
on environmental education and community development.

562 Annex 33

• The approach process with departments and, simultaneously with
municipalities is achieved with the adequacy and implementation by the
Regional Council, of the following activities:

• The National Narcotics Directorate will call a meeting of the Regional
Narcotics Council, Majors and representatives of entities potentially involved
with this entity, where PECIG´s formulation principles, EPM´s Social
management Program and its articulation with the Departmental Plan to
Fight Drugs, the Departmental Development Plan, development plans and

municipal POTs.

• The purpose is to include in these plans, specific actions to mitigate,
compensate, prevent and take the corrective measures inherent to
displacement and attention to the floating population, incentives to legal

crop growers, and to obtain information on settlers, subsistence farmers,
coca–leaf harvesters (raspachines), training on the illicit crops issues and
the impact on the environmental component, amongst others.

• The responsibility for the above is under the Regional Narcotics Council,
which seeks articulation of the Social Management Plan with departments

and municipalities, such that, in the context of the Departmental Plan of
Fight Against Narcotics, provision is made of departmental and municipal
development plans and municipal land regulations (POT) specific actions for
the mitigation, compensation, prevention and adopting of corrective
measures inherent to the displacement and attention to the floating
population, incentives to legal crop growers and strengthening of these

activities.

• Administrative agreements. DNE will establish integration agreements with
State technical agencies to support and provide the required information,
according to its competencies for the sound development of measures
adopted in the EMP. In general, support from the following entities is

required:

a. Agustín Codazzi Geographic Institute of Colombia (AGUSTIN CODAZZI
GEOGRAPHIC INSTITUTE OF COLOMB IA - IGAC) for the generation
of basic cartography.

b. National Health Institute of Colombia (INS), for epidemiologic follow-up in
eradication areas.
c. Statistics Administrative Department (DANE) for production of socio-
economic statistics in the program area.

563Annex 33

d. Colombian Agriculture and Livestock Institute (Colombian Agriculture
and Livestock Institute - ICA) for follow-up of phytosanitary aspects of
the program and promotion of agriculture production.

e.Autonomous Regional Corporation (environmental) (CARs) for
environmental follow-up aspects.

• At the same time, PECIG must seek involvement with other institutions for
the management of social issues, as a support strategy to local
communities. The most concerned entities are the following:

a. SENA for support in training processes and technical assistance.
b. Departmental Education Divisions, for development and inclusion in
academic programs or institutional e ducation projects of preventive and
information strategies against drug issues.
c. Departmental Health Divisions for the establishment of epidemiologic

windows and relevant studies on health impact due to spraying.

3.2 Financial compensation actions

Compensation is defined as the payment which DNE and the Anti-Narcotics Police

will make to the owners of lawful crops accidentally sprayed or due to adverse
weather factors. The payment of these compensations will be subject to the
provisions of Resolution 0017 of October 4, 2001, as follows:

Procedure

Accountableentities: National Narcotics Directorate (DNE) and the Anti-
Narcotics Police (DIRAN)

Reception of claim: Claims must be submitted by person affected
before the Municipal Ombudsman, in form similar to
the attached.

564 Annex 33

Preliminary verification: The Municipal Ombudsman will request Colombian
Agriculture and Livestock Institute - ICA and/or

UMATA a visual inspection of the facts which will
be recorded and attached to the claim, in a format
designed for that purpose.

Remission to DIRAN: Two days following the Colombian Agriculture and
Livestock Institute - ICA and/or UMATA report, the
Municipal Ombudsman will send report to DIRAN

with copy to the DNE.

Background information: Within 5 days following receipt of the claim, DIRAN
will certify whether there was aerial spraying on that

date, according to the Satellite Tracking Flight
reports (SATLOC) and all other documentation and
spraying polygrams.

Field visit: If DIRAN´s certification is positive regarding site
spraying and date indicated in the claim, the
Complaints Team will make a field visit within the

following 10 days in order to verify the basis for the
claim, determine damages and their relationship

with aerial spraying of glyphosate.

Record of If, after the field visit, the Complaints Team
Acknowledgement: concludes that damage was caused and spraying

was effected, the Team will estimate the amount of
the damage and will sign a record of
Acknowledgment. On the contrary, if it concludes

that no damage was caused, it will inform this
decision to the Municipal Ombudsman within 2
days of the visit, explaining the reasons for non-

acknowledgment.

565Annex 33

No visit: No visit will be made when public order conditions
so avoid it.

Bases for crop replacement

Crop replacement will apply only in the following cases and in the following
manner:

Object of replacement: Licit crops affected by spraying.

Opportunity: Complaint will be processed provided it is filed within
60 days of spraying.

Classification: Permanent and transitory crops, as defined in the
Resolution.

Permanent crops: Replacement will include the following: a) investment

in installation; b) value of damaged crop at market
prices as per CORABASTOS Chart; c) reinstallation
value of the crop; d) value of future crops calculated

until production of the new plantation.

Transitory crops: Replacement will include value of the damaged crop
at per CORABASTOS Chart.

Calculation of The Complaint Team will calculate replacement value
replacement: according to the number of damaged plants,
calculating on this base the maximum possible

production, as per Charts provided by Colombian

566 Annex 33

Agriculture and Livestock Institute - ICA.

Requirements: a) DIRAN certification on spraying on site and date

denounced: b) copy of SATLOC reports; c) copies of
spraying record and spraying polygram; d) copy of
detection report of illicit cr ops and PECI´s monitoring

systems of the municipality or area of the complaint;
e) copy of the field visit report; and f) all other
documents as appropriate.

Payment: A Damage Recognition record will be signed between
the coordinator of the Complaint Team and the
beneficiary and payment will proceed. If beneficiary is

not to be found at the time of these proceedings, the
document will be left in the Ombudsman´s Office who
will obtain signature of beneficiary and send it to

DIRAN. To proceed with payment, this Damage
Recognition record must be sent to the DNE.

3.3 Environmental compensation actions

If damages are caused on State-owned forests or on the Nature Parks
Compensation system, the procedure will be the following:

Accountable entities: Anti-Narcotics Police (DIRAN)

Reception of claim: Claims must be submitted by the Environmental
Authority (CAR) or by the Special Administrative Unit

of Nature Parks (UAESPNN) before DIRAN, in a form
similar to the attached.

567Annex 33

Background information: Within 5 days following receipt of the claim, DIRAN

will certify whether there was aerial spraying on that
date, according to the Satellite Tracking Flight reports
(SATLOC) and all other documentation and spraying

polygrams. If this report concludes that no spraying
was made on the date and site indicated, the result
will be communicated to the CAR or to the UAESPNN,

as applicable.

Field visit: If DIRAN´s certification is positive regarding site
spraying and date indicated in the claim, the

Complaint Team will make a field visit within the
following 10 days in order to verify the basis for the
claim, determine damages and their relationship with

aerial spraying of glyphosate.

Record of If, after the field visit, the Complaints Team concludes
Acknowledgement: that damage was caused and spraying was effected,

the Team will estimate the amount of the damage and
will sign a record of Acknowledgment. On the
contrary, if it concludes that no damage was caused, it

will inform this decision to the Municipal Ombudsman
within 2 days of the visit, explaining the reasons for
non-acknowledgment.

No visit: No visit will be made when public order conditions
prevent it.

Basis for crop replacement

Crop replacement will apply only in the following cases and in the following
manner:

568 Annex 33

Object of replacement: Natural forest and water bodies affected by spraying.

Opportunity: Complaint will be processed provided same is filed
within 60 days of spraying.

Natural forests: Replacement will include the following: a) area of

affected forest, in square meters or hectares; b)
reforestation value per hectare with plantation density
not less than 1000 plants/ha, at market prices as per

the corresponding CAR Charts.

Water bodies: Replacement will include the cost of cleaning work by
the corresponding CAR or municipality, as per

contracts or minutes.

Calculation for The Complaint Team will calculate the replacement
Replacement value according to the number of hectares damaged,

multiplied by the value of the plantation per hectare
affected times 2 for maintenance and replacement
purposes. In the case of water bodies, calculation will

be made according to effectively payment or expense
caused to the CAR or to the municipality.

Classification: Permanent and transitory crops, as defined in the

Resolution.

Requirements: a) DIRAN certification on spraying on site and date
denounced: b) copy of SATLOC reports; c) copies of

spraying record and poligram; d) copy of detection
report of illicit crops and PECI´s monitoring systems of
the municipality or area of the complaint; e) copy of

569Annex 33

the field visit report; and f) all other documents as
appropriate.

Payment: a) A Damage Recognition minutes will be signed
between the coordinator of the Complaint Team and
the authorized CAR or UAESPNN officer, or the

Municipality and payment will proceed. The minutes
will be sent to the DNE to make the corresponding
payment; b) DNE will process before the Anti-

Narcotics Council payment on the denounce, if any,
with Peace Fund resources; c) if no relationship
between program´s operati on and damage caused is

found, no payment will proceed.

3.4 Health Care

Health attention should be given at two levels: occupational health and health of

population exposed to aerial spraying with glyphosate.

This Record will only refer to health measures of population exposed to aerial

spraying with glyphosate, since occupational health will be processed in the
industrial safety sheet. The recommended measures on this respect are the
following:

a) Epidemiologic monitoring

Surveillance of spraying effects of a chemical agent on the health of persons living
in the regions subjected to the treatment should be appropriate as to its planning

and methods, in order to obtain a result which at the same time is reliable, cost-
benefit, cost effective and far from economic extravagance and generation of
unnecessary public panic.

570 Annex 33

The risk derived from spraying is conditioned by both the intrinsic toxicity of
glyphosate and the magnitude and exposure time to its effect, biological efficiency

of the exposure route and environmental conditions where this happens.

In the case of the use of glyphosate formulation, the greatest intensity and
magnitude of exposure in the development of Program activities will fall on persons

exposed to substances used in aerial spra ying, that is, to those responsible for
formulation handling, preparation and application of mixtures.

Regarding populations of treated areas, it should be considered that they will be

exposed to a diluted intrinsic low toxicity agent, of the minimum absorption capacity
of exposed living beings, and therefore, of a minimum exposure to its systemic
effects, of general and on the spot applications, of populations far from cultivate

areas with a very low potential of direct exposure and with a low exposure level
exclusively through environment.

Epidemiological monitoring by persons and entities responsible for the health of

communities can be done in two optional ways:

• Regular monitoring according to usual assistance practice, or

• Epidemiological monitoring enhanced for possible effects

The first option involves comparing dis eases of unknown origin against case
definitions of exposure or toxic effects of glyphosate, and testing of suspected

diagnosis through laboratory tests.

Given that the margins of human exposure through environment are not sufficient
to produce detectable concentrations or amounts of the agent (glyphosate) in

samples of biological fluids, direct measurements of glyphosate in these
concentrations are discarded. This also applies to personnel exposed to
concentrated preparations of glyphosate.

571Annex 33

As for the population of treated areas, it is more appropriate to establish a
communication system between those responsible for public health and a central

level on possible effects, on what does and what does not constitute glyphosate
exposure effects, and an immediate reaction system for the field research as
required.

According to current legislation, the monitoring of potential effects on the
population living in areas of illicit crops, thterritorial entities, through the Health
Promotion Agencies (EPS) or to the Subs idized Regime Health entities (ARS,

SISBEN) contracted by the regional directorates for the purpose (Acts 9/1979,
100/1993, regulatory decrees 1891/1994 and Accord 29 of the National Council for
Health Security).

In compliance with the functions established by law, above entities must select the
monitoring option of their election, and report uncertain or highly suspect cases
associated with Program´s activities, through their information systems and

channels established at central level of the National Health Security System.

Notwithstanding the foregoing, for DNE to be able to make a closer follow-up of the
possible effects on health of population exposed in spraying areas, the following

are some measures recommended by the DNE:

• To establish direct contact with regional health authorities in the

departments with illicit crops, to inform the Program and its potential effects,
and to propose the joint execution of an epidemiological monitoring plan on
such effects.

• To design a format on epidemiological monitoring, jointly with the Ministry
of Health, and to promote its use in hospitals in the municipalities of
influence of the eradication program.

• To promote and conduct seminars at national level on the matter
designed to train local hospital officers in the physiological and sanitary

572 Annex 33

aspects linked to possible affectati ons by glyphosate, and train them on
epidemiological monitoring, jointly with the Ministry of Health, and to show

the how to complete the form previously agreed with the Ministry.

• To establish mechanisms such that the form be completed by local
hospitals and sent to the Ministry of Health, every month.

• Based on the monitoring results in the first six months, the Environmental
Sub-Directorate and Social management of DNE will design and propose

CNE an immediate notification system of suspicious events caused by
spraying activities, and of acknowledgement for treatment expenses due to
health affections of the exposed populations, in cases previously proven, in

similar form to the design provided for the acknowledgment of damages on
lawful crops (Resolution 017/2001). Toxicology sheets of the Ministry of
Health will be taken into account for this purpose.

• Establishment of a training program for health assistance and
administrative staff, as provided for in the educational communication
program.

4. SCHEDULE

The monitoring activity is to be performed throughout the life of the eradication
program of illicit crops by aerial spraying with glyphosate.

5. FOLLOW-UP AND MONITORING

This will consist of:

• Monthly verification of compliance with activities of interinstitutional support.

• Monthly verification of activities in coordination with PNDA

573Annex 33

• Monthly verification of coordination activities by regional entities and on
execution of proposed events.

• Monthly verification of financial compensation processes for crop damages.
• Monthly verification of compensation processes to Environmental Authorities
and the Nature Parks Unit UAESPNN for environmental damage.
• Monthly verification of epidemiological monitoring activities as provided for in

this program.

6. ACCOUNTABILITY

The DNE and DIRAN, through the Environmental Sub-Directorate and Social
Management of PECIG.

7. COSTS

The total cost is estimated in $1,118.000 per year, broken down as follows:

• Interinstitutional support $ 16,000.000

• Liason with PNDA $ 16,000.000

• Coordination with regional entities $ 16,000.000

• Financial compensation for crop damage $ 350,000.000*

• Financial compensation for environmental damage $ 700,000.00**
st
• Health care (Preparatory phase, 1 year) $ 20,000.000

TOTAL $1,118,000.00

END OF SOCIAL MANAGEMENT PROGRAM

574 Annex 33

EDUCATIONAL COMMUNICATION PROGRAM RECORD 10

1. DESCRIPTION OF THE ACTIVITY GENERATING IMPACT

In the course of the illicit crops eradication program by aerial spraying with

glyphosate herbicide (PECIG), the social and economic nature and connotations of
the process require permanent communication with the community, at national,
regional and local levels, for the program to be understood and accepted by

society as a whole.

2. OBJECTIVES

The objective of this program is to develop a set of activities designed to inform the

public, at national, regional and local levels, of the nature and scope of PECIG, its
results and its problems. In parallel, it seeks to train all personnel who take some
part in the glyphosate spraying, so that there will be permanent improvement in

their skills in handling the products under their care, and avoid potential accidents
which would endanger the health of persons and the environment. Similarly, there
will be mass educational communication campaigns in ecological matters, in the

PECIG target areas.

This program should be developed in coordination with the Social Management
program of PECIG (see Record 9).

3. ACTIVITIES

The Educational Communications Program has four basic components:
information, training, environmental education and signposting, through which the

575Annex 33

intention is to win the acceptance and collaboration of the local population, and
improve their conditions of life. Five of these actions are particularly important:

information, education, training, signposting and health care.

3.1. Information

The public should be constantly informed at national, regional and local levels,

particularly among the communities located in the areas of influence of the centres
of glyphosate spraying, on matters such as:

• Objectives of PECIG

• Importance of the program
• Characteristics of PECIG
• Social and environmental measures applied
• Results of the Technical Environmental Audit
• System of attention to complaints.

This information should be channelled through the following media:

• Operation of an Internet webpage, placing permanent information on the
results of the environmental management plan and PECIG, with summary
reports of the Environmental Audit, results of environmental monitoring

conducted under the EMP, monthly summary charts of spraying by
municipality, department and nucleus, number of plots and hectares
sprayed, and other matters which DNE and DIRAN consider should be the
object of public knowledge.

• Monthly PECIG information bulletin, in the context of other activities of the

programs of the fight against drugs

• Regular press communiqués, with PECIG results and results of the
environmental management plan

• Holding of an annual national seminar, attended by experts and
researchers, NGOs, government agencie s and the police, to disseminate
environmental and social aspects, and results obtained.

• Information campaigns through the media.

576 Annex 33

3.2. Training

Training should be addressed to a range of actors, including technical and
operational personnel in PECIG, health authorities, and others involved in the
implementation of the program.

3.2.1. Training operational personnel

In accordance with Decree 1843/1991, operating personnel should have access to
training courses or processes and instruction, offering theoretical and practical

nature, with a minimum intensity of 60 hours accumulated over a year, the content
being in accordance with the type of activities which in which they engage, and it is
anticipated that the training will include the following issues:

Base personnel

a) Information on pesticides, types formulation, precautions in handling and
general matters of toxicology and environmental pollution;
b) Different forms of intoxication;
c) Instructions on the proper care, handling and safety of equipment in each

activity;
d) Measures and processes to avoid c ontamination of products for human or
animal consumption;
e) Instructions on waste disposal;
f) Initial signs of intoxication and general measures in the first aid;
g) General information on the scope of legislation on pesticides and their
management;

h)Basics of registration control, with an emphasis on the handling of
herbicides and environmental impact;
i) Environmental Management Plan, with an emphasis on programs managed
at the base, that is, measures fo r the handling of glyphosate (storage,
mixing), transport of the herbicide; handling of solid waste and wastewater,
social management, and integral safety;

j) Attention to and referral of complaints about damage to crops and other;
and
k) Contingency planning, with drills for accidents.

577Annex 33

Pilots and spraying crew

a) Information on pesticides, types of formulation, precautions and handling,

and general matters of toxicology and environmental pollution;
b) Different forms of intoxication;
c) Instructions for the proper and safe handling of spraying equipment;
d) Instructions for the calibration of spraying equipment;
e) Initial signs of intoxication and general first aid measures;
f) General information on the scope of the law on pesticides and handling;

g) Base phytosanitary control, with an emphasis on the handling of herbicides
and environmental impact;
h) Environmental Management Plan, with emphasis on the program of interest,
that is, handling and management of spraying operations, social
management and integral security; and
i) Contingency plan, with drills for response to attacks on a loaded aircraft.

3.2.2. Regional and local personnel in medical and central services

a) Effects of glyphosate on human health;
b) Mechanisms of the transfer of glyphosate in trophic chains;
c) Methods of epidemiological research;
d) Training for research in symptomatology, and effects potentially linked to

glyphosate;
e) First aid measures to be taken in the event of intoxication, skin exposure, or
inhalation of glyphosate;
f) Completion of forms to record attention given in cases of potential
glyphosate effects;
g) Procedure for the dispatch of forms to departmental and national health

authorities, DNE and DIRAN;
h) Procedure in the system of attention to complaints of persons affected by
damage allegedly attributable to PECIG.

3.3. Environmental education

3.2.1. Education for local communities

During spraying operations, a campaign of ecological education will be conducted,
and it will be designed to create awar eness among the population on the natural

values of their region, and ways of protecting them. This education will play at

578 Annex 33

particular attention to the following issues:

a) Introduction on the environment, and its relationships with human activities,
b) Local flora and fauna, and the economic importance,

c) Obligations of PECIG with regard to the environment,
d) Detailed explanation of the environmental management plan,
e) Forms of community participation in the program, and
f) Preventive measures to combat exposure to glyphosate.

The campaign will be conducted through workshops in each of the municipalities

affected object of the PECIG, and will be addressed to local communities. The
workshops will be held on the issues proposed above, and those issues will be
condensed into leaflets.

Invitations to the workshops will be made through mayors, the regional
development authority CAR, and the agricultural advisory offices UMATA, amongst
others. They will preferably be held on a Saturday or Sunday, following detailed

programming to be set up by DIRAN, and implemented by a consultant specializing
in environmental matters.

3.2.2. Environmental training for tech nical and operational personnel in the

program

Workshops will also be held in each bas e for program personnel, organized into
groups of 30 (4 per base), giving em phasis to environmental management,

depending on the speciality or activity (mixers, workshop personnel, equipment
operations, police, etc).

Given the volume of personnel (about 120 per base), about four workshops per
base will have to be held, for a tota l of 36 workshops nationwide (30 per
workshop).

These workshops will be held in the first two months of each year, with the content
proposed in Record 9, Social Management Program. This training will be in the
hands of experts. Leaflets will be prepared on environmental management in the

579Annex 33

project, and distributed to all those attending.

The Program Records to be used are those for the Environmental Management

Plan. Further, two leaflets need to be prepared as basic material for the
workshops, one for the training of local communities, in which there is information
on the project and management plan, as basic element, and another for workers,

with an emphasis on environmental management measures to be applied by
workers in the course of their work.

3.4. Signposting

The purpose of signposting is to make the local population (those living in the
neighbourhood, and those passing through each base), aware of security and
safety measures to be taken into account in order to prevent risks associated with

the program inside the bases. Among the measures to be applied, the following are
recommended (see Figures 1 and 2 as an example).

• Preventive signs , warning the user or the existence of a hazard and its
nature, and providing safe passage for vehicles, equipment and program
personnel (applies only inside the base).

Preventive signs should be placed at sites where glyphosate is stored in a

mixed, where fuel

is stored, and at other places where there are special risks.

• Regulatory signs indicate limitations, prohibitions and restrictions on use,
and will be placed at points where an order must be obeyed.

• Informative signs indicate temporary directions to take to reach a certain
place, or in the form of the presence of obstacles at a given point.

Therefore, portable notices and hoardings must be made up out of sheet steel, with

metal braces, with giving signs visible to pedestrians and drivers, and directly

580 Annex 33

related to safety measures, including:

• Identification of entry and exit points to the base
• “No Litter” signs

• “No parking” signs 100 m before and after the main gate of the base (if the
base is on a public highway)
• Recovery and recycling: plastics, glass, cardboard, etc (inside the base).

Other signs should be installed at barricades, with metal hoardings or reflective

tape, with appropriate support, light cones, bins, light paths and luminous lines, to
provide temporary isolation to the perimeters.

4. SCHEDULE

This activity will take place while the aerial spraying activities are in progress, with
annual programs to be established by DIRAN.

5. FOLLOW-UP AND MONITORING

This will consist of the following:

• Monthly check of compliance with information campaigns and the
preparation and distribution of leaflets

• Weekly inspections of the condition and presence of notices and holdings
• Monthly check on the arrangements for training workshops and
environmental education
• Daily check on the environmental comportment of base personnel

6. ACCOUNTABILITY

DIRAN and DNE

581Annex 33

7. COST

The annual cost per base is estimated as COP 31,000,000, is distributed as follows

Workshops COP20,000,000

Meetings with agencies COP1,000,000

Signposting COP10,000,000

Total COP31,000,000

The following global costs must also be taken into account for the whole program:

Webpage COP 30,000,000

Monthly bulletin COP 5,000,000

Leaflets COP 5,000,000

Mass communication campaigns COP 60,000,000

Total COP 100,000,000

END OF THE EDUCATIONAL COMMUNICATION PROGRAM

582 Annex 33

PROGRAM FOR INTEGRAL SAFETY AND SECURITY AND RECORD 11

OPERATIONS BASES

1. DESCRIPTION OF THE ACTIVITY

During glyphosate aerial spraying operations a set of activities take place at the

operations base and in the air, which, if executed inappropriately, could lead to
accidents or and damage to the health of persons, loss of assets and other events.

An appropriate working procedure and efficient use of the various types of tools

and machinery during operations at the base will reduce the risk of accidents and
impacts on employee health.

This management program is based on the concept that accidents be significantly

affect the normal functioning and activities of the program in any of its phrases,
generating income disadvantages such as increased production costs,
supplementary cost (in damage, repairs, materials, etc), and this will also be

associated with a poor image of the program, and a consequent negative impact
on the social component.

Difficult atmospheric conditions, togetherwith the stress caused by the risks

involved in these operations, makes it nec essary to create and develop activities
which will encourage the entire human group, and create a harmonious, health and
healthy environment, for employee welfare.

Among the risks which may arise in the various antinarcotics bases due to
operations with herbicides (handling and us e), fuels and other chemicals, there

might be the following:

Contamination of the atmosphere. This is originates from gases generated from in

583Annex 33

vehicle transport, and vapours which may be emitted from operations in storage,
transport, mixing, spillage of the herbicide, and most especially due to the

evaporation from badly-closed containers. In one way or another, this will
contaminate the environment, and produce irritation and produce unpleasant
effects on personnel remain in permanent contact with chemical substances

Contamination of water. This is linked to a spillage of herbicide, and its possible
discharge into local water sources.

Contamination of the soil. Spillage may also take place inside the base, and of the

physical, chemical and biological conditions of soil.

Intoxication of mixing personnel . The herbicide may enter the human organism
through the mouth, or may be inhaled, or enter through the skin or eyes, during

activities such as eating or drinking while in contact with the herbicide. Entry
through the respiratory system occurs when mixing takes place in conditions of
wind, or by inhaling of smoke or vapours from fires, and, at storage sites, coming

from badly-closed, broken or leaky receptac les, or when spillage is not promptly
cleaned up, or the wrong kind of respirator is used, or filters are contaminated.

Spills. These basically may occur during the storage and transport of the herbicide,
and involve the risk of intoxication to the mixer, or damage to vegetation and soil.

Fire. The causes of fire are many. Smoke and gas is generated, some of which are

toxic (in particular, those in the burning of fossil fuels) are an immediate risk to
employee health, and offer the danger of burns, by their nature.

There are also other activities and phenomena derived from them, that cause
impact during spraying operations, and that must be handled from the point of view

of industrial safety, in particular the following:

• Handling of land machinery and equipment, including fumigation aircraft and
support

• Handling of fuels and lubricants used in general equipment and machinery

584 Annex 33

• Noise of aircraft and helicopters of the program, creating sound
contamination

This program is based on the integral security and safety plan at operations bases,
drawn up by the Antinarcotics Police, and established by the National Police.

2. OBJECTIVES

The program aims to avoid risks to personnel taking part in spraying or in
environmental hazards which may be derived from the operation and mixing of the
herbicide, the process of loading aircraft, and inappropriate use of dosers, spraying

equipment, pumps, hoses, and equipment in general, and the handling of fuel,
machinery and equipment in routine base work.

Continuous supervision by supervisory per sonnel will be a primary objective in

guaranteeing that operations are conducted correctly.

This program will be an instrument for ordering responses from personnel in the
event of an accident.

3. ACTIVITIES

3.1. Safety measures to be adopted

3.1.1. Risk control measures

Poor storage of glyphosate and its collections, and of fuels and lubricants, spillages
of liquids, badly-closed receptacles and other events may produce odours and

other environmental problems.

585Annex 33

The control to avoid this risk is based on c onstant supervision. In order to prevent

these effects, there must be additional work areas separated from the site of
accommodation, dormitory areas and places where food is prepared under cover,
with good ventilation, away from water sources and plastic containers, for

appropriate storage; further, there must also always be sawdust, earth, clay or
some other absorbent material to hand, for immediate application in the event of a
spillage

Should a nearby water source be contaminated, this must be immediately
corrected, improving the drainage system to avoid contamination of groundwater,
by constructing the ditch with earth around it, sending the mixture to a water

treatment plant.

Herbicide spillages and hard areas can be countered by covering them with earth,
and subsequently cleaning the spillage area with abundant water, in order to

prevent it from spreading and contaminating soil.

In some cases, where the spill is abundant, it should be retained and absorbed.
The material used in this activity should be eliminated at strategic places, such as

the sanitary infill in the nearest human settlement, where it can be used as
coverage material, given the relatively rapid degradation of glyphosate in the soil

3.1.2. Measures for handling

The following precautions and should be followed when using the product:.

• There should be no contact with eyes or clothing;
• Avoid breathing vapour or mist from spraying;
• Wash your hands before eating, drinking, chewing gum, using tobacco,

going to the toilet;
• Remove clothing at once if it comes into contact with herbicide. Then clean
thoroughly, and change into fresh clothing;
• Do not contaminate water when eliminating wastewater from washing
equipment.

586 Annex 33

3.1.3. First aid measures

If glyphosate enters the eye, keep the eye open, and wash with abundant water. If
ingested, this may cause irritation to the gastrointestinal tract, and it necessary to
dilute it by ingesting water or milk. If inhaled, take the person out into the fresh air.

If he is not breathing, apply artificial respiration, preferably mouth-to-mouth. At all
events, the best course is to obtain medical help.

If there is intoxication due to the action of glyphosate, the following measures

should be taken:

• Keep the patient breathing
• Wash his eyes with abundant water
• If contamination is through the skin, personal intoxication should be

removed from the working area, and his clothes and shoes, and clothing
should be thoroughly washed bef ore reuse. The patient should be promptly
washed all over with water and soap, and his scalp and should be washed,
and wash underneath his nails. In this process, avoid rubbing or washing
the skin violently. Finally, he should be dried and dressed in clean clothes.

• If there is contamination through the eyes, and I should be washed with
water 10-15 min, with the patient lying on his side so the water does not fall
into his mouth or into the other eye. After washing has been completed, the
eye should be covered with gauze and a clean handkerchief.
• If contamination is through inhalation, the person intoxicated should be
taken away from the working area and placed out in with fresh air, and his

clothes should be loosened to ease breathing.

3.1.4. Measures to combat spills

Spills generally occur during storage and tr ansport, and should be attended to at

once, in order to avoid the risk of intoxication, contamination of the environment,
and fire.

A person who is going to be exposed to th is risk must wear full protective

equipment, including boots, gloves, respirator, etc. and have personal knowledge

587Annex 33

of the degree of toxicity and flammability of the product.

Water should not be thrown onto spilled herbicide. Rather, the spilled liquid should

be covered with absorbent material such as earth, or, failing that, apply lime to
prevent odour that would irritate workers. It should be expected that the matter will
completely absorbed the spill.

Any product which can be recovered should be should have absorbent material
scattered over it, which should be turned several times in different directions with a
broom, until completely clean.

Next, use a broom and a spade to pick up th is material, place it in a plastic bag,
and then give it some appropriate final dis posal preferably in a sanitary infill.
Subsequently, a solution containing caus tic soda, water and detergent should be

applied to the floor, to decontaminate it.

To prepare the solution for one square metre, use quantities of water, 250g of
caustic soda and 300g of detergent. Places the quantity required in a container,

then add the caustic soda in spoonfuls, and stir with a stick; finally, add the
detergent. Use gloves and goggles for this.

Warning. Do not throw water on to caustic soda, it may explode.

To apply a decontaminating solution, do the following:

• Surround the stained area with absorbent material (atapulgite, bentonite or
other absorbent clays);

• Apply the solution to the centre of stain;
• Cover the entire area with absorbent material and leave for several hours,
preferably until the next day;
• Effect final disposal, placing the material in a metal drum and eliminating it

in a sanitary infill. If there is no such facility nearby, an area should be

588 Annex 33

constructed manually at the base.

When cleaning is completed, wash protective items used, applying the solution of

sodium fluoride in water at 5% (50 cc per litre of solution), for decontamination.

3 1.5. Firefighting measures

The flamepoint of glyphosate is over 200°C, but the temperature at which self-

ignition would take place has not been deter mined. In the event of a fire involving
herbicide, this would be a cause of smok e, gases or even toxic vapours, which
may create environmental health problems.

In order to avoid this kind of accident, it is essential to keep the installations
completely clean and tidy, not smoke at work sites, store items correctly, and keep
electrical installations in perfect order.

If a Class B fire break out, that is, when the fuel is liquid or gas, proceed as follows:

• Give the alert immediately
• Use extinguishers to see whether the fire can be put out

• Apply foam, dry chemicals, CO2
• Evacuate personal not taking part in the extinguishing exercise
• If the fire cannot be controlled, leave the area upwind, since smoke may be
toxic
• The water used for extinguishing should be used in moderation, to avoid

spreading, and generate less waste
• Where possible, build a sand barrier to prevent the dispersion of water used
in extinguishing, or cleaning liquids

Once the fire is put out, take the following precautions:

• Cordon off the area and place sounds, to prevent unauthorized entry
• Personnel taking part in cleaning work must wear protective equipment
• No smoking, eating or drinking in the contaminated area
• Carefully decontaminate protective items and tools used in the cleaning
exercise when the exercise is completed

• In very special cases, and if available nearby, it would be advisable to adopt

589Annex 33

measures of prevention and control, taking water samples for analysis, and
determining whether it is or is not suitable for consumption or any other
activity in contemplation

3.1.6. Rules for location extinguishers

Extinguishers should be conveniently signposted, depending on the classification
of fires, in the following manner.

Class A. The combustible item is solid (paper, cardboard, wood, cloth, etc

Class B. Whether combustible substances liquid or gas

Class C. Combustible items are electrical installations or equipment

ClassD. Where metals present which react to air, and further generate their

own oxygen,

such as aluminium and titanium.

Extinguishers should be located in visible and accessible places, and be inspected

monthly and be charged every six months if not used. Personnel should be
instructed on proper operation of the extinguisher. There must be extinguishers at
different points of each base, where ther e is the possibility of a high (offices,

restaurants, kitchens, cafeterias, stores and fuel pump, herbicide store, handles,
parking aircraft in areas, and helicopters, camping sites for herbicide, etc.

3.1.7. Personal protection equipment

Personal protection is of vital importance to the proper execution of work, without
restriction, and with regard to personal safety, and further, to avoid accidents which
will bring serious consequenc es to the institution. All employees must use

elements required for personal protection, including:

• 2 overalls, which can be easily was hed and dried, to secure a change of
clothing every day or more, where circumstances required

590 Annex 33

• 1 pr trousers, with rubber sheeting
• 1 pr nitryl gloves

• 1 pr leather gloves (depending on risk of handling)
• 1 pr safety boots
• 1 Helmet or head covering
• Protective equipment for respiration, ears or skin, where the risk requires
• Each employee must have double-door, independent and individual locker

at the entrance to the operations side, to keep his street clothing and work
clothing
• Keep towels and soap for each worker.

The glyphosate storage warehouse must have visible signposting and areas

marked out, with hazard warnings and emergency exits, and sufficient space for
personal to move around and transport containers with this liquid. Once the
chemical substances have been used, t he empty containers must be plugged and

kept away from perishable products and wa ter sources, since these will retain
vapours and residues of the product

3.1.8. Measures to be taken in the event of an attack, involving glyphosate

Bases are constantly exposed to attack, and the material used for spraying and
eradication of illicit crops is the principal target, that is, glyphosate.

In order to prevent attacks against glyphosate, the storage system is to be

constructed in a concrete store some 50-100 cm high, with a mechanism for the
evacuation of residues if necessary (see Record 2, Program for the handling of

glyphosate and its coadjuvants at operati ons bases). During combat, a container
or bin will be placed on the discharge pipe, to collect up any liquid spill. The bypass
Valve will be kept open for this activity

A given number of empty drums must be kept on site, with lids, so that they can be
replaced, and continue with the process until the liquid is entirely drained.

If there is a spill due to inappropriate location of plastic containers that contain

glyphosate, action should be taken after combat is finished, implementing the

591Annex 33

measures described above, consisting of the application and absorbent material
available nearby, and taking the right precautions.

3.1.9. Washing of aircraft

The washing of aircraft after spraying operations will be effected taking account of
recommendations such as the following:

• Work away from the water sources.
• Set up a single place for this activity.
• Design and implement a special and appropriate system for the discharge of
wastewater.

• Give regular maintenance to the system, adopted for the proper functioning
and operation of the same.
• Make a complete check of the inside of aircraft prior to washing, to ensure
that there is no liquid, in order to avoid greater contamination of the
receiving body of water.

3.1.10. Maintenance of mixing equipment

The doser, the mixing tank, the couplings, the hoses and the nozzle used in the
mixing process to supply aircraft with herbicide must always be in good condition,

avoiding any leaks of pure and mixed substances.

3.1.11. Storage

The chemicals must be stored under cover, in place with good ventilation away

from water sources, food, forage or seeds. Storage must be effected in containers
or tanks made of stainless steel, alumin ium and glass, plastic, or plastic-lined
containers, since some materials such as steel, galvanized metal or unlined

containers react with glyphosate, forming hydrogen gas, which because a highly
flammable gas mixture (see Storage and handling of glyphosate at the base).

592 Annex 33

3.1.12. Other safety measures

General

Follow appropriate techniques and use of all kinds of equipment and materials

• Do no more than four hours operation in spraying activities, and relieve
spraying personnel every week.
• Do not allow unauthorized personnel to remain in working areas, particularly
in areas used to store herbicides and coadjuvants.

• Do not allow access to aircraft and helicopters or to maintenance workshops
or parking areas by unauthorized personnel.
• All electrical installations must be explosion-proof.
• Restrict smoking in working areas.
• Restrict the use of drugs etc in working areas.

• Firearms will not be allowed in working areas by civilian workers.
• Traffic regulations must be respected in the Program vehicles platform.
• No horseplay or fighting in working areas.
• No business may be done with the materials or assets of the Program.

• Regulations described in industrial health and safety manuals of the Police.

Preventive measures

• All personal participating in the Program should be aware of the principles
and content of this Program Record, with instructions regarding the

elementary procedures to be used in pr oject activities, and possible danger
situations. This measure must be implemented by each worker who comes
into the program, and also through the education program.

• There must be at least one person engaged as responsible for supervising
compliance with industrial safety regulations during program activities,

appointed by the Commanding Officer of the base.

• Vehicles, aircraft, equipment and materials must all be frequently checked,
and processes and systems in general, and a complete check made of
installations.

• Defects in materials and equipment, and damage caused by accidents,
must be repaired.

593Annex 33

• A safe place must be found in advance to store fuels, handling them in safe
containers.

• Careful evaluation (efficacy, safety and protection), of technologies and
procedures used in each, on the ground or in the air, following the aviation
authorities regulations.

• Elimination and substitution of unsafe products.

• Protection systems for machinery and employees.

• Selection of the most suitable personnel to work in program, and personnel
must made aware of areas with the risk of explosion, fire, or attack, and

equipment allowed to be used in the various areas of work.

• Written instructions and application of procedures for working in welding,
electrical work, work at height, excavations, load lifting, and materials
storage

• Supervision and control of employees; work to be performed with discipline
and authority

• All areas such as access roads and working areas within the base, must be
signposted and marked out, particularly areas for workshops, fuel supplies,

herbicide stores and coadjuvants stor es, mixing areas and areas for the
circulation of personnel and machinery. There must also be warning signs or
prohibitions, such as the mandatory use of helmets, no smoking, and
restricted transit.

594 Annex 33

• Emergency procedures must be clearly and visibly posted, with rules for the
handling of hazardous substances and materials. Exits designed for

personnel evacuation should be clearly marked.

Figures 1 and 2 show some of the safety items to be used by workers, and some of
the preventive signposting

3.2. Execution

3.2.1. Specific functions

Anti-narcotics Division

• DIRAN will be responsible for the over all security of the safety of all
personal taking part in the illicit crop spraying activities, by implementing
effective actions to prevent and investigate operations, as required to
reduce accidents at spraying bases to zero.

• All regulations indicated in Decree 1843/1991 for the use and handling of
pesticides must be followed in the training of personnel working in
operational phases to avoid accidents in manouevres.

• Complete forms for the control of measures established.

Eradication of illicit crops area.:

• Develop control and prevention programs against risks to personnel working
as mixers or loading aircraft for spraying illicit crops for their safety and
welfare

• Transmit orders and check and these regulations are understood and
observed by Base Commanding Officers

595Annex 33

• Coordinate personnel medical examinations for those permanently engaged
in mixing or discharging or other platform operations, with the health
function.-

• Supervise visits to bases in the source of spraying-related activities-

• Provide support for the achievement of objectives.

Base Commanding Officers

• Provide herbicide mixers with knowledge of regulations and orders, and
check compliance.

• Disseminate orders, regulations and manuals for the use and handling of
chemicals used in the mix and in spraying operations, training technical
personnel-

• Ensure that technical and environmental guidelines suggested by the
Environmental Authority are observed in eradication spraying, given the

specific conditions of spraying of coca-leaf and opium-poppy, within set
operating parameters (see Program for Glyphosate Spraying Operations).

• Supervise mixing activities and the calibration of equipment used in spraying
to ensure that the comprehensive safety and environment regulations are

observed.

• Check spraying equipment calibration and ensure that dosage and volume
of discharge per hectare as in accordance with the Program (Record 1).

• Coordinate the sending of spraying polygrams with the Antinarcotics
Division, reporting developments (return of aircraft with No. of gallons in
Hooper)

Herbicide mixing technician

596 Annex 33

• Use personal protection equipment during mixing operations and loading of
aircraft.

• Dose for coca-leaf as provided in Sheep 1 and handling of glyphosate at
operations bases Record 2 .

• Report any deficiencies in the workings, maintenance or leaks arising during
work will be reported.

• Keep accounts of mixing operations, with the safety regulations and
precautions indicated for the handling of the herbicides

• Be responsible for the herbicide remaining in good storage conditions, within

established parameters

• Adapt the storage area, with the necessary signposting, with informative
notices and communication of areas

3.3. Administration

Funds

Funds required to transport and maintain installations, and for personnel welfare

and other expenses caused by the illicit crop eradication operations will be
managed by the service areas and with service and support areas of directly in
with the competent authorities and agencies

Uniforms

Uniforms as required by the special nature of activities, with additional sets of for
personal protection in the event in the individual contact with chemical substances

597Annex 33

Physical plant safety

Adaptation of installations, preventive and informative notices as necessary for

safety, to be supplied by the Head of the zone or Base Commander.

3.4. Command and communication

Command

• Antinarcotics Division
• Antinarcotics Department
• Aviation area

• Interdiction area
• Service and support area.

Communications

DIRAN media

4. SCHEDULE

The industrial safety program must be applied permanently inside the base and

during aerial operations.

5. FOLLOW-UP AND MONITORING

Follow-up is the responsibility of DIRAN, in coordination with the safety and

security supervisor, and they will make regular inspections of the installations and
operations, in accordance with regulations for protection, safety, security and

598 Annex 33

hygiene of the program area

6. ACCOUNTABILITY

The Base Commander of the operations base, accountable to DIRAN, responsible
for the appropriate management of industrial and environmental security and safety
in the program.

7. COSTS

Costs refer to the implementation of the industrial safety and security regulations of
the program. The application of these measures forms part of the execution of
each program activity. Signposting has been provided for in the Educational

Communications program. The costs of the fuel storage systems, and of herbicide
and other storage, and security and safety systems are included within the normal
costs of construction and operation of each base, and may not be charged

environmental costs.

Activity Unit Quantity Unit cost Item cost

Industrial safety

regulation

Personal costs* hours/month 2 COP3.5,000,000 COP
7,000,000

Equipment of Global 15 COP 50,000 COP
security personnel 750,000

Direct costs Global COP1,250,000 COP1,250,000
(stationary,

publications,
reports)*

Total

COP9,000,000

END OF THE INTEGRAL SECURITY AND SAFETY RECORD.

599Annex 33

PROGRAM FOR ENVIRONMENTAL MANAGEMENT AND RECORD 12
INTER- INSTITUTIONAL COORDINATION

1. DESCRIPTION OF THE PROGRAM

The implementation of environmental management measures in the various stages
of the illicit crops eradication program by glyphosate by aerial spraying glyphosate
(PECIG) requires administrative responsibilities for planning, execution, follow-up

and control.

Therefore, it is necessary at this point to make a redefinition of strategies
established to achieve the purposes of t he PECIG is part of the national policy for

the fight against drugs, and this is THE fr amework established by the government
in which State agencies must perform the actions to confront the problem of drugs
in Colombia.

The program in itself brings together certain social, political, economic, legal,
environmental and health priorities and, amongst other things, but in turn, is also
conditioned by the presence and action of a number of administrative agencies and

organizations for promotion and control and national and regional levels, in whose
jurisdiction of the PECIG must be implemented.

Therefore, it is essential to the successful implementation of the EMP, that plans
be made for the actions of the various agencies in PECIG exclusion areas, and to
coordinate execution particularly with reference to environmental and social

management. It is the work of the Narcotics Council CNE, in the current
institutional framework, to bring together all activities and adapt them to the
achievement of a common objective, that is, the struggle against illicit drugs.

600 Annex 33

This Environmental Management and Interinstitutional Coordination program is
designed for the entities involved to be able to bring together the best efforts in

pursuit of environmental performance which, according to their policies,
corresponds to them, and is of interest to them.

2. OBJECTIVES

In order to secure compliance with envi ronmental specifications of the various
stages of PECIG, and the execution of activities in prevention, correction,
mitigation and environmental compensation established in this EMP, through direct

action by the entities responsible for the program, and in coordination with the
various agencies and sectors involved in the struggle against drugs, and
specifically, in eradication through aerial spraying of illicit crops by the herbicide

glyphosate.

3. ACTIVITIES

3.1. The institutional context

PECIG is part of the institutional structure principal components for the CNE,
created by the Government in 1973 as the senior authority in national drugs policy;

the narcotics directorate DNE, as national coordinating agency, and the
Antinarcotics Division of the National Police (DIRAN), responsible for eradication
operations.

As instruments of coordination which can be set up in the course of the program,
there is provision for the making of agreements, collaboration agreements, and
other tools of bilateral negotiations between agencies. However, it is essential that

there be reflection on the part of all the interested organizations all the
organizations interested in correct execution of PECIG, and implementation of the
EMP, in relation to all types of coordination to the type of coordination which can

be most effective.

601Annex 33

Only synergistic action between all entities will secure the efficacy of EMP and the

efficiency of PECIG, performing functions given for each of them.

CNE

This organization was created by Decree 1206 of June 26, 1973, and is an organ
that provides advisory services to the Government, to formulate policies, plans and

programs for adoption, which public and private entities should pursue in the
struggle against the production, trade and us e of drugs or substances producing
physical or psychic dependence. It would also act in the area of control of the legal

use of such drugs or substances.

The composition of CNE under Article 90 of Law 30/96, amended by Article 35 of
Decree 2159/1993, is as follows:

• Minister of Justice or his delegate, as Chair
• Minister of Defence or his delegate
• Minister of Education or his delegates

• Minister of Health or his delegate
• Minister of Finance or his delegate
• Minister of Environment or his delegate
• Director of CNE, who may speak but not vote

• Public Service Procurator or his delegate
• Director of the Security Police DAS or his delegate
• Director of the Police or his delegates
• Attorney General or his delegate
• The Presidential Program

The principal functions of CNE, under Article 91 of Law 30/1986 are following

• To formulate, for adoption by the Government, policies plans and programs
which public and private entities should pursue in the struggle against the

production, trade and use of addictive drugs. Likewise, the Council
proposed measures for the control of the legal use of those drugs.

602 Annex 33

• To indicate the specific campaigns an d actions to be taken by each official
organization.

• To order the destruction of illicit cr ops be such means as it considers
appropriate, subject to the favourable opinion of agencies responsible for
public health, and for the preservation of the country´s ecosystems

• To issue regulations as necessary for the performance of its functions, and

to propose the issue of those which are within the government´s
competency.

• To guide and coordinate the acti vity of State and private agencies engaged
in prevention, scientific research and judicial police, control and
rehabilitation in the area of addictive drugs and substances

• To maintain contact with foreign governments and international
organizations in matters of its competency, and to pursue action with them
in order to coordinate the action of the Colombian government with that of
other States.

• To have available, in accordance with any serious indications obtained from
intelligence organizations, information on activities of persons, aircraft,
docks or ocean, river or land terminals, engaged in drug-trafficking, the
suspension of licences for aviation, ri ver and land transport personnel, and
permits or certificates for operations . It will give instructions to the

appropriate authorities to this effect.

DNE

DNE was created to coordinate the development and execution of policy in the

area of control and prevention and repression of drugs. Article 93 of Law 30/96
states that the narcotics office of the Ministry of Justice will act as the Executive
Secretariat of the CNE. Its functions include:

• To execute CNE decisions.
• To conduct studies assigned by CNE.
• To oversee compliance with CNE decisions, and reports as appropriate.

603Annex 33

• To update the inventory of assets occupied or seized due to their direct links
with drug trafficking. and related crimes, and oversight of correct use.
• To form part of processes which attempt to indemnify damages due to the

seizure of property.
• To coordinate the functioning of the Technical Advisory Committee and of
the Regional Narcotics Councils, and simila rly to oversee the activities of
State and private agencies responsible for prevention and scientific
investigation and judicial police activi ties in control and rehabilitation, and

maintain contact with foreign governments and international organizations.
• To implement and coordinate actions provided for in National Drugs Plans,
ensuring that public entities in the decentralized sector and organizations
which have some responsibility in execution, should design programs within
the context of policies provided, and ensure that the use of funds set aside
for such actions, whether from the national budget or international

cooperation, are efficiently and rationally allocated;
• To present plans and projects considered necessary to comply with its
responsibilities for the consideration of the Council.
• To evaluate the execution of policie s, plans and programs pursuant under
Article 93, suggesting amendments or adjustments as necessary.

DNE, as the coordinating agency in the planning and development of PECIG
policies, is responsible for coordinati ng the execution of the various actions
provided for in this EMP.

In complement to the competences of the institutional structure, in relation to the
PECIG all the divisions which dealers coordinate in the EMP, subject to verification
of activities, are the following:

• To develop the elements of administration for stages of the PECIG.
• To coordinate the implementation of the stages of PECIG.
• To set criteria and proposed solutions for the handling of emergencies.

• To organize the implementation and execution of the EMP in PECIG.
• To pursue actions as necessary to c ontract studies, lines of research and
other matters in relation to environmental management.
• To propose strategies and mechanisms of control
• To set up communications about the program with internal and external

parties interested in its environmental management..
• To supervise and evaluate compliance with the EMP in its various
components
• To check compliance with current environmental regulations (Figure 1)

604 Annex 33

DIRAN

Decree 43/97, Article 2 states that "The Antinarcotics Division of the National

Police will be responsible for the planning and direction of Police operations
designed to prevent, and repress major or minor criminal conduct within Colombia,
related to the production, manufacture, exports, imports, the distribution, sale, use

and possession of narcotics, and the growing of plants which are used to make
them", in accordance with the terms of Law 30/96 and further provisions of law
which supplement or amend it. This Article was adopted as permanent legislation

by Legislative Decree 2253/1991, Article 1.

Since DIRAN is directly responsible for the execution of eradication operations, it is
therefore responsible for the applicati on of a range of measures and actions

designed to prevent, correct, mitigate and compensate for environmental impact
generated by those operations, both at ant inarcotics bases, and in application
zones.

3.2. The scheme of administration

It is a fact that the environment must be managed, to the extent that man

transforms it to meet his needs and requirements, because environmental matters
are sustained by a complex interrelationship between biotic and abiotic
components, and by the extent to which one of these components can be

manipulated volumes, others will be affected to a greater or lesser extent.

In this context, in the course of the er adication activities by aerial spraying with
glyphosate, the agencies involved must ma intain a high level of performance in

standards of cognition and environmental management. Executing and follow-up
agencies and support elements must firmly believe that this high level of
performance in inter-institution action and environmental management is a

synonym of quality and effectiveness in the PECIG operations and the EMP.

The mechanisms of development of the scheme will be established on the basis of

605Annex 33

the concept of evaluation of environmental management and of compliance with
current legal regulations and standards (Figure 2).

3.2.1. Scheme of coordination

The following will be the scheme of coor dination and inter-institutional relations
established for this program (Chart 1):

a) Institutions responsible for the EMP

1. CNE, as the organ of decision for the formulation of drugs policy. In particular,
for the execution of the aerial spraying strategy, Law 30, Article 91 projects of the

functions of "ordering the destruction of crops of marihuana, coca-leaf and other
plantations from which substances producing dependence can be extracted, using
the most appropriate methods, and subjec t to the favourable opinion of agencies

responsible for public health and preservation and equilibrium of ecosystems in
Colombia". Further, Article 92 makes the exercise of the functions of Article 90
mandatory.

1. DNE. DNE is the Executive Secret ariat of CNE, and is responsible for
coordinating the preparation and execution of the EMP (under Article 93 of 30/96)

3. The Antinarcotics Police, under Legislative Decree 423/97, is responsible for the
planning and operational execution of PECIG.

b Agencies involved in EMP follow-up

1. Technical Environmental Audit, responsible for following and monitoring
measures adopted in the EMP

606 Annex 33

2. Ministry of Environment

The Ministry is responsible for follow-up to the coordination and implementation of

the EMP and its effects on the environment, as the body responsible for
environmental management and for renewable natural resources in Colombia. It is
mandated to secure the recovery, conservation and protection of renewable

resources and the environment, and to regulate general conditions for a healthy
environment, amongst other things, in order to prevent, eliminate or mitigate the
impact of activities which contaminate, deteriorate or destroy the environment or

natural heritage.

3. Ministry of Health. Responsible for the design and implementation of an
epidemiological monitoring system of the impacts on human health which

appreciated much cause.

4. INSTITUTE OF HYDROLOGY, METEOROLOGY AND ENVIRONMENTAL
STUDIES - IDEAM.. Responsible for follow -up and supervision of the environment

and possible contamination and degradati on caused by PECI G and ecosystems,
as the Institute responsible for surveying and handling scientific and technical
information and ecosystems, and setting the technical basis for classifying

concerning the use of land for purposes of planning and regulating territory, under
Article 17 of Law 99/1993.

5. Autonomous Regional Corporations (CAR ), responsible for the development of
projects and programs defined in the Co mpensation Plan for decontamination and
recovery of environment and renewable natural resources, and impacts which

might have been caused by PECIG, as the regional environmental authority, and in
accordance with the terms of article 31.20 of Law 99/1993. Resources for the
implementation product, financed with funds from the FIS, and the struggle against

organized crime, subject to CNE approval.

c) Support institutions

607Annex 33

1. National Alternative Development Plan (PNDA). Uses coordinates to demarcate
zones for alternative development projects will be located and voluntary eradication

agreements, so that they will not be affected by PECIG.

2. Social solidarity network (RSS). Us es coordinates to dem arcate zones where
productive development projects will be dict ated, in order to avoid them being

affected by PECIG.

3. The Colombian Agriculture and Livestock Institute – ICA - approves technical
and operational parameters for aerial spraying of illicit crops with glyphosate, as in

Resolution five, Article 7 CNE.

4. AGUSTIN CODAZZI GEOGRAPHIC INSTITUTE OF COLOMBIA - IGAC,
supplies basic and thematic maps showing soils and agroecological capacity.

5. The Interinstitutional Technical Committee. Advises DNE on the development of
PECIG.

6. Departmental and municipal authorities.

7. The national office for attention to and prevention of disasters.

8. Local committees for attention to and prevention of disasters.

3.2.2. Interinstitutional relations

a) Between executing agencies

608 Annex 33

1. The CNE approves areas to be sprayed, following a plan drawn up jointly by
DNE and the Antinarcotics Police, based on measurements made by the SIMCI

monitoring Project

2. DNE, coordinating the with the Antinarcotics Police DIRAN, for environmental,
social and economic information required for spraying operations to be conducted

within safe parameters

3. DIRAN, based on guidelines provided by CNE and information supplied by DNE,
proceeds to effect spraying operations

b) Between executing agencies and evaluation agencies

1. The Technical Environmental Audit, based on plans made by DIRAN prior to
each operation, and after spraying in each zone, proceeds to monitor and evaluate

impact on the environment, human health, and agricultural activities, following the
approved methodology. It has one month to presents its report to DNE, but if it
detects negative impact, the report must be made immediately.

DNE immediately reports to DIRAN on the results of the audit process. If there is
negative impact, the Social Management and Compensation plan of the EMP is

activated, to include and there is coordination with the entities defined in it.

3. The Ministry of Health. Once the monitoring system is set up, the Ministry will
make a monthly report to DNE on health cases identified through it. The

Environment and Social Management office of DNE, after each spraying operation,
will contact the references in the zones centre of this system, to review information
reported in it.

4. The environmental authority INSTITUTE OF HYDROLOGY, METEOROLOGY
AND ENVIRONMENTAL STUDIES - IDEAM will implement a mechanism for
follow-up of biophysical resources in operations zones, particularly, it with regard to

609Annex 33

possible contamination or degradation c aused by PECIG, and make a quarterly
report to DNE of results obtained

5. DNE will follow-up programs of inspection, verification and control, mitigation
programs, and where appropriate, social management and compensation. In each
case, there will be a process of coordination with the entities defined in the plans.

c) Between entities of coordination, execution and support

1. The alternative development plan PNDA and the social solidarity network will
report every three months and before each spraying operation to the DNE and the

Antinarcotics Police, giving the location of productive projects, in order to take
these into the these locations into account when planning fumigation operations.

2. The Antinarcotics Police will inform RSS of spraying operations to be initiated, in

order to activate the Humanitarian Attention Program for those affected by the
eradication program

3. Colombian Agriculture and Livestock Institute - ICA, at the request of DNE and
the Antinarcotics Police, will approve technical and operational parameters of
PECIG

4. AGUSTIN CODAZZI GEOGRAPHIC INSTITUTE OF COLOMBIA - IGAC
supplies DNE with basic and thematic maps with regard to soils and agroecological
capacity

5. The Inter-institutional Technical Committee is an instance of support for DNE in
the PECIG

610 Annex 33

3.3. Operational organization for implementation of the EMP.

• DNE, as the national coordinator of PECIG, will secure the implementation

of the EMP through the various participating agencies. For this purpose, it is
proposed to create an Environmental and Social Management office within
DNE, with the following functions:

• Coordination and follow-up of the execution of the PECIG

• Environmental and socio-economic characterization, in coordination with the
Antinarcotics Police, of nuclear areas of the illicit crops, to guarantee
protection for the environment and social context.

• Measurements of census and statistics to identify and locate the extension
of illicit crops in various PECIG zones.

• Follow-up the monitoring of input of implementation of the EMP.

• Development and enforcement of measures of mitigation, compensation

and environmental control with the operating agencies of PECIG.

• Implementation of the Educational Communication Program addressed the
communities.

• Design and operation of information system for the public on PECIG results.

• Coordination and harmonization of planning PECIG actions with social and
environmental management programs and projects developed by other
agencies in the context of the policy to combat drugs

• Chairmanship of the Interinstitutional Technical Committee, an advisory
body of the DNE for PECIG, and follow-up of compliance with functions and
responsibilities arising within it.

• Supervision of the audit and technical inspection contract for PECIG.

611Annex 33

• Attention to and processing, in coordination with the Antinarcotics Division,
of complaints made by individuals allegedly affected by PECIG, observing

the principles of celerity, effectiveness, transparency, good faith and
promptness, and all others required by current law.

• The establishment of inter-administrative agreements with State institutions
contributing to PECIG.

• Contracting and follow-up of studies and research as a function of
minimization of risks to human health and the environment.

• Definition and implementation, in coordination with national-level organs or
their bodies and entities (CNE, PNDA, RSS and FIP), and local

organizations (CSE, CARs, governor s and mayors), for alternative
measures to eradicate illicit crops (manual eradication agreements,
alternative development projects, etc).

• Research proposals to input and proj ects for CNE approval and financing

through the rehabilitation and social investment fund FIS, designed to
strengthen social, economic and environmental rehabilitation in PECIG
zones.

• Preparation of documents, position papers and other requirements of
international, national and local industries requested from the DNE.

• Other functions delegated to it in accordance with the competencies of the
Division.

Given the nature of PECIG activities, the Division proposed must have a minimum

staff of professionals can take including in agronomist, forestry engineer,
environmental engineer and a sociologist or anthropologist, amongst others, with
the logistical media required to operate in the office and in the field.

One alternative to the Division proposed is th e allocation of the above functions to
an existing office of DNE.

612 Annex 33

Cycle of environmental management

Environmental management within PECIG must be seen as the process of
continuous improvement, whose principal elements and the relationships between
them are shown in Figures 1 and 2.

a) The process starts from preliminary studi es, and is integrated into the system in
the following manner:

• The EMP will be checked and adjusted following additional requirements

made by the environmental authorities and operating conditions at the time
that that operations start.

• The plan requires resources (technical, staffing, economic, logistics,
communications), contributed by the agencies committed to the program.

• The plans must be disseminated, and participants must receive training in it.
Dissemination is technical, and includes the definition of responsibilities.

• Results of actions must be communicated to all interested parties.

• Control mechanisms must be set up to ensure that the program proceed as
planned, as a means of achieving the strategic objectives and targets
proposed.

• A system of measurement must be set up to evaluate the results of actions

taken, in terms of efficiency and effectiveness of the application of EMP
measures (see program of inspection, verification and control, Record 6).

• Actions will be aided by agile mechanisms for taking corrective or preventive
action in accordance with the results of the evaluation.

613Annex 33

• An information system must be made available to administer the information
generated by the process in because of the program.

• The process must allow regular revision review and feedback, as required to
improve to secure continuous improvement of the program and of EMP.

• The planning system brings together environmental planning functions of
the program, in particular the conceptualization and organization of the

operating development of the EMP. The product of the system is a detailed
operating program, with schedules, definitions of responsibility,
quantification and appropriation of resources required for execution.

b) The integral communications system contains the following general functions:

• Management of the information generated by the management system.

• Production of useful information for interested parties, the generation of
performance reports and feeding of the webpage.

• Dissemination of the EMP. Programs included in it, procedures, and other
management tools.

• Development of the training program, see Record 10.

• Generation of interim and final reports of the EMP for the environmental
authorities.

c) The function of environmental control will be secured through an appropriate

environmental inspection service, formed by a multidisciplinary team whose
functions and results will be interdisciplinary. This inspection function must have
measurement tools to generate the information required.

d) The evaluation of activities will be af fected with indicators supported by the

614 Annex 33

results of the systems mentioned above

4. SCHEDULE

This will be a permanent activity from the time that glyphosate spraying begins.

5. FOLLOW-UP AND MONITORING

The follow-up and monitoring of the program will be based on its performance

indicators, in particular:

• Creation and operation of the environmental and social management office
of DNE
• Compliance with all programs in the EMP
• Permanent and agile coordination with DIRAN, and social support

organizations (PNDA, RSS, Ministry of Health), and the organizations in the
Interinstitutional Technical Committee and regional agencies.
• Prompt compliance with functions environmental and social management
established in the EMP.

6. ACCOUNTABILITY

In the current institutional framework, the agents responsible for this program are:
new

• CNE

• DNE
• Antinarcotics Police

7. COST

The cost is estimated to be COP364 million per year. The cost of inspection work

should be coordinated with the cost of th e program of inspection, verification and
control in this EMP

END OF THE PROGRAM FOR ENVIRONMENTAL MANAGEMENT AND INTER

INSTITUTIONAL COORDINATION.

615Annex 33

CONTINGENCY PLAN RECORD 13

INTRODUCTION

Since the illicit crops eradication program is being conducted with glyphosate
spraying, and glyphosate is a broad-spectrum herbicide, and although the

evaluation of environmental risk reported a high degree of degradation of
glyphosate in different environmental scenarios, the program's operation as such is
subject to several risk factors (guerrilla action, mechanical failure of aircraft,

environmental considerations, etc.), which compromise human life and the natural
environment, when by the action of these factors, and amongst other risks, there
would be the need to dump the product totally and immediately.

The Contingency Plan is a document which sets out strategies of response to
attend to emergencies which may arise during the various stages of manipulation
of the site for the eradication of illicit crops (transport, storage, manipulation and

spraying). Among the possible events are dumping (total and immediate discharge
of glyphosate), which in the oil industry would be equivalent to a spill. For all events
analyzed, in the contingency plan esta blishes persons responsible, and

mechanisms for the supply of basic in formation on possible areas affected.
Likewise, procedures are established to be implemented in each situation, with
actors involved for support as requested , and equipment and materials required

for each action.

With the formulation of the Contingency Plan, the Antinarcotics Police aims not
only to respond promptly to emergencies derived from operations, but also to act

within the integral national policy full attention to emergencies, and therefore, to
engage with inter-institutional committees with existing inter-institutional
committees at local, departmental and national levels, given that the program is an

integral part of the national anti-drug policy, requires the support and concurrence
of the number of institutions and industries in government, each with its own
mission and objectives.

616 Annex 33

GLOSSARY OF TERMS

DISASTER. Serious damage or alteration to normal conditions of life in a given

geographical area, caused by natural phenomena or by catastrophic effects of the
action man, accidentally, exceeding the capacity for response of the community
affected, and requiring special attention from state organizations and other

instances of a humanitarian or social service nature.

EMERGENCY. Situation generated by the occurrence of the disaster, which
severely modifies the normal conditions of life of a community, and makes

immediate intervention necessary for its control

THREAT. This is the probable magnitude or extent of unexpected natural
phenomenon, natural, technological human phenomenon, which by its destructive

potential, is hazardous to the population, the economy, or the environment. In a
simplified form, the threat (A) may be expressed as the product of:

The potential energy (EP) of the matters involved if the phenomenon takes place

The susceptibility of that mass (SM), to activate the phenomenon

The magnitude (M) of the detonating effect, able to cause the hazardous
phenomenon to take place

The threat can be quantified through the use of the following expression:

A = EP*SM*M

THREAT ZONE. The area of coverage of occurrence of a possible threat,
regardless of the presence or absence of goods or persons.

VULNERABILITY. The susceptibility of an element or set of elements in a system
to suffer damage or failure in the presence of a phenomenon, which is potentially

617Annex 33

destructive or destabilizing, due to its magnitude.

Vulnerability (V) is a relationship existing between exposure (E) and resistance (R):

Exposure can thus be defined as the degree to which the system or its component
elements are subject to the action of a potentially hazardous phenomenon

Resistance is the capacity of the elements exposed to avoid or soften the effect of

the action of the hazardous phenomenon.

In general, vulnerability studies should take account of four fundamental
considerations

Human vulnerability,

Vulnerability of vital element and strategic elements,

General physical vulnerability, and

Social, economic and environmental vulnerability

RISK EVALUATION. Risk evaluation is intended to establish the most probable
consequences or effects, based as a basis for proposing selective, reasonable and
effective solutions to mitigate a given risk. These activities comprise:

The identification of risk factors and conditioning factors

The location of persons and it structures exposed, and the specific location within
the process

An evaluation of the most probable consequences or effects

RISK ZONE: This is the zone where there is the greatest degree of threat, and the
greatest presence of persons or assets, which might be affected.

618 Annex 33

RISK. Probable expected magnitude of damage or failure of one or more elements

in a system, within a given territory and time, caused by the materialization of the
hazardous phenomenon.

Risk (R) is therefore a function of the pr oject potential danger or threat (A), of

vulnerability (V) of the elements exposed to the threat.

Risks can be classified as follows:

AVOIDABLE. These are risks whose origins can be avoided, and consequences
can be cancelled out with technically, economically or socially feasible measures.

CONTROLLABLE. The threatening phenomenon can be predicted, along with its
consequences and consequences can only be attenuated or mitigated, because it
cannot be technically, economically or socially manageable.

UNCONTROLLABLE. Risks in which the capacity for prediction and evaluation is
incomplete, or and science and technology are not capable of providing a viable

technical, economic or social solution.

ACCEPTED. Risks arising as a consequen ce of the preceding scale, and defined
as the difference between the greatest level of risk which can be controlled

(controllable), and the maximum permissible risk (uncontrollable).

1. GENERAL CONSIDERATIONS

The Contingency Plan is a set of acti vities and operations to be planned and

undertaken in order to anticipate, prevent or correct some potential outcome, and
which can be present in the arise from operational, natural or exogenous failure,
and cause a negative impact on persons, assets or the environment.

619Annex 33

The program also seeks to do the following:

9 Minimize environmental impact in the face of occurrence of a disaster

9 Minimize the injuries which emergencies may cause to personnel acting in
the program or
9 communities located in the area of influence

9 Minimize economic loss

9 Reduce claims and costs derived from civil liability for possible for possible
damage

9 Reduce the area of influence of glyphosate spraying outside the limits of the

illicit crops

The program is designed to prevent emer gencies and to occupy a high priority
position in the general framework of crop eradication activities, and the following

premises should be taken into account

9 The analysis of risks is considered to be the baseline to establish the scope
and directions of the Plan.

9 The organizational, logistical and operati onal responsibilities of the Plan are

clearly defined and studied by personnel engaged in activities

9 A cooperation link is established between related operations areas

9 There will be coordination between the authorities and local, regional and
national authorities and communities, in order to optimize the response

capacity to emergencies

620 Annex 33

2. CONTINGENCY PLAN STRUCTURE

The contingency plan basically consists of a strategic plan, and operating plan and

a database, with the following basic components

CONTINGENCY PLAN STRUCTURE

|

|_________________________|____________________________

|| |

STRATEGIC PLAN OPERATING PLAN DATABASE OR
INFORMATION SYSTEMS

Responsibilities and Procedures and protocols Permanent and prompt

information

functions for response to losses for prevention and
response

The diagram illustrates the following:

The STRATEGIC PLAN seeks to ensure that each person or entity responsible is
clearly aware of their functions and responsibilities in the Plan, and performs the

functions assigned to him, and uses available resources efficiently to attend to
emergencies.

The OPERATING PLAN is part of the Contingency Plan which establishes

emergency procedures, and allows for rapi d mobilization of human and technical
resources to implement immediate actions in response, as foreseen.

The INFORMATION SYSTEM OR DATABASE is an instrument which provides

rapid and timely communication with personnel forming brigades and agencies

621Annex 33

engaged in external support.

2.1. Strategic plan

The coverage of the Contingency Plan is limited to spraying program operations
areas. The antinarcotics bases will have equipment, mechanisms and trained
personnel to attend to eventual incidents related to the aerial spraying processes

Within the specific PECIG implementation areas, the following have been defined
as priority for actions within the contingency plan;

9 Antinarcotics bases, and nearby areas
9 Areas of transit of spray aircraft, flight lines between bases and application

areas
9 Areas close to illicit crops

These areas were determined in accordance with the characteristics of spraying
operations, threats and risks present in the course of the same.

The structure of the Contingency Plan is fundamentally based on the formation of a
standing emergency committee (CPE) for each base, responsible for the following

activities:

9 Planning of action to be taken in any event
9 Establishment and ordering of hierarchy of reaction
9 Allocation of relevant functions
9 Direction and coordination of actions to be taken

9 Evaluation of results of applying the contingency plan

BASE STANDING EMERGENCY COMMITTEE (CPE)

Emergency group Internal support brigades External support

brigades

622 Annex 33

Chairman CPE or coordinator, Communications Brigade Fire service

Head of Emergencies Storgade C Rross

Security and Supervision Brigade Civil defence

EvacuAstiinBnrgadeArmy

eFiel,siangepetrol

Control Brigade Local Disaster
Prevention Committee

SpraymigrgenrgadeLauchlorities

2.2. OPERATING PLAN

The coordination centres for the activation of the Contingency Plan will be the
Antinarcotics Police bases, which will have the necessary communications

equipment, as part of the disaster attention equipment, and operations centre, and
the local committee or regional committees for disaster prevention and attention.

The purpose of the plan is to establish basic operating procedures of the
Contingency Plan. It defines the basis and mechanisms for notification,
organization and operations

OPERATING PLAN

9 Preventive and control measures
9 Internal support brigades communications
9 External support brigades communications
9 Activation of alarms
9 Contingency plan activation

9 Evacuation in emergency
9 Measures after evacuation
9 Overturning of tanks
9 Fire control in the storage area
9 Explosion control in the storage area
9 Spillage control in the storage area

9 Fire control in the spraying area

623Annex 33

9 Explosion control in the spraying area
9 Spillage control in the spraying area
9 Evaluation of the contingency plan

9 Training programs

The following are the procedures or protocols to be executed in each component of
the operating plan:

2.2.1. Prevention and control measures

In the operations base

9 The Standing Emergency Committee Chairman will make arrangements to
acquire materials and equipment needed to implement the contingency

plan, such as communications equipment, extinguishers and first aid, and
will order the appropriate brigades to install them in the appropriate places,
fire extinguishers to go to the areas most vulnerable to fire.
9 The Communications Brigade will install alarms and fire and explosion alert
equipment, and make regular checks on the same, with signposting in all
areas of the base: no smoking, restricted area, no unauthorized entry, use

safety equipment, emergency exit, evacuation route, high tension, though
extinguishers, etc, and will maintain coming occasions equipment
9 The Fire Brigade will be responsible for maintaining the extinguishers in all
risk areas
9 The Evacuation Brigade will be responsible for checking and maintaining the
first aid equipment

9 The Head of Emergencies at the base will arrange drills to check on
procedures to attend to spills, fire and explosion generated by fuels and
glyphosate, in the appropriate areas
9 The Committee Chairman will develop cooperation agreements with local
emergency committees to establish mechanisms of mutual cooperation.
2.2.2. Communications with Internal Support Brigades

The existing communications system s hould be used to advise all base personnel
and all brigades about emergencies for them to come into service immediately and
give relevant recommendations, and if the circumstances so merit, to advise the

Standing Emergency Committee

624 Annex 33

2.2.3. Communication with external support brigades

If the contingency cannot be attended to by internal brigades, the Head of

Emergencies will contact it existing extern al groups specializing in attention to
emergencies, to inform them of the emergency arising, and request their
immediate presence and support.

The Head of Emergencies will coordinate ac tion with internal and external support
groups to respond to the emergency.

The local emergency prevention and attention committee will be used to inform

local authorities and the community in general with regard to responsibilities in
attending to any dumping of material, and to prevent possible adverse effects.
These responsibilities will generate specific actions, such as evacuation of certain

areas where there is exposure to the greatest damage to public health, prohibitions
on fishing in certain areas, prohibitions on the sale or consumption of certain
hydrobiological products, community cooperation, etc.

Information supplied will be objective, a ccurate and concise, and refer to proven
facts

In case of a spillage produced in flight, the DIRAN will act through the Chairman of

the Emergency Committee, as operator of the product dumped, will make an initial
report to the competent authorities, which will act in accordance with their mission
(preservation and protection of the environment and health), to supply personnel or

technology to attend to this type of event, where security conditions allow, these
entities will include amongst others the Ministry of Environment, the regional
environmental authorities CAR, Ministry of Health, Colombian Agriculture and

Livestock Institute - ICA, and the Public Procurator (Attorney General) for
Environmental and Agricultural Affairs.

The Chairman of the Emergency Committee will make an initial report of the

dumping, which will contain basic information on specific circumstances (time place
and manner), in order to make a preliminary estimate of the magnitude and
severity of the event.

625Annex 33

The initial report will be made on Form I - "Initial Report" (see attachment), taken

from the National Contingency Plan and adapted to the Program´s operating
conditions.

2.2.4. Activation of alarms

In the event of emergency, the shift officer acting as Head of Emergencies at the
base will activate the emergency alarm.

If any other person is in the emergency area, he will immediately advise the Head

of Emergencies, for him to activate the alarm.

The Head of Emergencies will advise the Standing Emergency Committee, which
will define actions to be taken to attend to it.

Once corrective action has started, the Head of Emergencies may order the alarm
to be deactivated.

The levels adopted by the National Contingency Plan will be used to activate the

contingency plan.

2.2.5. Activation of the Contingency Plan

Once the emergency has been reported, the members of the Standing Emergency
Committee will proceed as follows:

9 Make an immediate plan for corrective measures for safety, and local
emergency plans

9 Immediately communicate with the internal support brigades, ordering the
immediate presence with their identification badges, and coordinate
activities

626 Annex 33

9 Combat the emergency following procedures established below

9 If required, request the presence of external support brigades

9 Order the suspension of activities which interfere with appropriate attention
to the emergency

9 Supervise the rescue work for pers onnel exposed to the emergency or who
are victims of it

Activation of the contingency plan may take place at different levels, depending on
the characteristics of the emergency:

Level I. Partial activation, Plan alert

In this type of event, the Program will take actions designed to control the situation,
activating response at its highest level. Mi litary and civilian personnel participating

in the event within a maximum of three hours after activation.

Level II. Activation of the plan requesting support from Operating Committees

This occurs in remote areas within the coverage of the Program operations, and

there is coordination with local and regional emergency prevention and attention
committees. This level is developed within 24 hours following the event.

627Annex 33

CHART 1. ACTIVATION LEVELS FOR THE CONTINGENCY PLAN TAKEN AND
EDITED FROM THE NATIONAL CONTINGENCY PLAN

LEVEL

HIGH LEVEL

Occurs over areas of N3
human settlements,
nature park areas, and

sources of water
supplies

MIDDLE LEVEL

In areas of forest, and N2
high density of
drainage.

LOW LEVEL

Developed on with

total and immediate
dumping on meadows
or lawful crops in

areas distant from
sensitive ecosystems N1

SPECIFIC LOCAL REGIONAL

Level 3. Total instant activati. Disaster-major volume and severity, within
zones covered by the local contingency plan

628 Annex 33

The event is totally beyond the control of the program operations, and exceeds the
capacity of local or regional systems to provide assistance requested. National-

order agencies must be involved, to provi de guidance in actions. This level will be
developed if the event exceeds the capacitie s of Level 2 operation within 48 hours
of occurrence, for which national-order agencies will provide support.

2.2.6. Criteria of priority in response operations

The highest priority is addressed to the protection and preservation of human life
threatened by the incidents.

Where there are limitations of resources or time, and the choice must be made to
protect resources of the greatest value and importance for the safety and welfare
of the human population of the area. Subsequently, protection will be given to high-

ecological value resources which are most sensitive, such as primary and
secondary forest with native vegetation, guaranteeing the sustainability of
ecosystems, and in the last resort, thr eatened socio-economic resources (lawful

crops such as plantain and yucca), and ecological elements catalogued as medium
or low risk, such as scrub.

If the choice has to be made between the protection of two threatened resources,
each with a different risk index, priority will be given to the most sensitive one. If
there are two resources in the same conditions of risk value, the choice will be to

protect the resource which is affected, would cause the most serious adverse
socio-economic impact on the human population in the short or medium term.

2.2.7. Operating procedures and responses

2.2.7.1. Evacuation and assistance in the event of fire or explosion at the
base, due to faults of an operational nature

Once the alarm has been activated by the Head of Emergencies, in the event of a

629Annex 33

fire or explosion due to operational failure s, or the base personnel will follow these
recommendations:

9 The Head of Emergencies will order Brigade personnel to suspend
activities, and prepare to deploy the procedure for emergency response

9 The Evacuation Brigade will direct the evacuation from the area quickly, and
in an organized and calm manner, separating out persons who have lost

control of themselves, giving guidance to so that they will avoid inhaling
smoke, making people walk as close to the ground as possible, preventing
people returning to the evacuation areas, ensuring that evacuated personnel
that personnel have been completely ev acuated, and if not, make a rapid
inspection of the area

9 The Brigade will provide first aid to personal suffering injury or who have
collapsed.

After evacuation

9 The Evacuation Brigade will check to ensure that all personnel are unhurt,

report if any person seems to have disappeared, and prevent people from
returning to the danger area except for members of the support brigades

9 The Brigade will guarantee that people will only be able to go back to their
place of work once the risk has been eliminated

2.2.7.2. Spills of fuels and glyphosate

a. Spills due to the overturning of a tanker- truck during transport

9 Check the condition of the driver and other accompanying personnel, to
protect human life, providing first aid where required, and then withdrawing
from the vehicle to avoid possible fire or explosion.

9 Isolate the area, by constructing ditc hes said that the liquid does not reach
water sources or water intakes or wildlife areas.
9 Advise local authorities to report the emergency.
9 Quantify the amount of the product spilled.

630 Annex 33

9 Isolate the area with security cordons
9 Proceed to clean up if security conditions allow.
9 Isolate existing drains or sewers, in order to prevent the area affected from

expanding.
9 If the spill takes place over a body of water, the Head of Emergencies will
advise personnel who operate intakes downstream as soon as possible.
The brigade will install observation barriers around the intake downstream,
once the emergency has been declared. A reconnaissance should be made
of the banks of the water source to identify places of impact, and proceed to
isolate and clean up, advising the local authorities and external groups with

experience, if the spillage exceeds the capacity of internal brigades or
groups.
9 If the spill occurs on land, the brigade will isolate the area with safety
cordons, and proceed to clean up and isolate existing sewers or drains, to
avoid the affected area from spreading
B. Spills of glyphosate and fuel at the base

9 The Head of Emergencies will order members of the appropriate brigades to
suspend activities and to deploy the procedures required for response to
emergencies.
9 Check the state of the mixer and other personnel contaminated by the spill,
in order to protect human rights life, providing first aid when necessary.

9 Isolate the area by building a ditch so that the liquid will not reach water
sources or wildlife areas.
9 Quantify the amount of product spilled.
9 Isolate the area with security cordons.
9 Proceed to clean up if safety conditions permit.
9 Isolate existing drains or sealers, to avoid the area affected from expanding.

9 If the spill takes place on dry ground, the brigade will isolate it with security
cordons, clean up, and isolate existing drains or sealers, to avoid an
expansion of the affected area.

2.2.7.4. Control of fire and explosions at a base due to operating failures

9 The Head of Emergencies will order the immediate presence of the Fire
Brigade and the Evacuation Brigade.
9 The Evacuation brigade will proceed to evacuate the base, following
procedures.
9 The Fire Brigade will isolate the site of the fire, evaluate the type of fire, and
select the most appropriate extinguishing equipment. Small fires can be put

out with nearby extinguishers. Once the fire has been controlled, equipment
should be recharged or replaced

631Annex 33

9 The Head of Emergencies will communicate with the Fire Service if the fire
cannot be easily controlled by internal brigades, and if explosions caused by
caused by operating activities occur.

2.2.7.5. Attacks on the base

9 The Head of Emergencies will im mediately advise a ll police personnel
forming the supervision and security brigade.
9 Civilian personnel present the base w ill be ordered to take up positions of

safety, and if safety and security conditions permit, they should be
evacuated at once.
9 The Chairman of the Emergency Committee will request help from the Army
if necessary
9 Base personnel will be ready to defend the most vulnerable areas of the
base, where an explosion or fire might affect with greater risks, such as

storage systems

2.2.7.6. Procedure for response to attend to disasters during spraying

a. Primary incident report. The pilot´s report will reflect the circumstances of the

incident.

It is possible that the pilot does not report the incident immediately after it occurs,
because aircraft communications systems have been damaged, or the pilot has not

detected the incident promptly, or the incident may have injured in pilot (aircraft
shot down). This last eventuality is particularly likely to occur with aircraft operating
coca-leaf spraying, since they operate without accompanying helicopters

INCIDENT REPORT

(diagram)

If the incident is detected and communication systems have not been affected, the

pilot should immediately report it to the base, specifically to the Emergencies
Committee Chairman, who will check that the pilot is unharmed, and make a

632 Annex 33

primary or initial evaluation of the damage.

If the aircraft has suffered any adverse effects from an incident, regardless of

whether it is of slight, medium or high importance, the decision will be taken to
return to base. Before returning to base, the pilot and the Head of Operations, after
evaluating the incident, will decide whether it is necessary to dump the product. If it

is decided that the project should be dumped (medium and high level incidents),
the pilot and Head of Operations will analyze the area, and will define the point at
which the least adverse effects woul d be caused, in accordance with

environmental parameters established in the characterization process.

The hierarchical order for dumping will be:

9 Illicit crop areas
9 Grazing land

9 Scrub or secondary forest
9 Primary forest areas

Incidents if the process of crop eradication will be classified in accordance with the
following criteria:

Slight incident. Incident in which there is no serious threat to the safety of the
aircraft, and therefore of the pilot. In this kind of incident, it is not considered
necessary to dump the product. In this case, the aircraft ceases operations and

returns immediately to base.

Medium incident . The pilot has the operating capacity and airworthiness to

evaluate the zone for dumping the produc t. Priority is given to the zones
established in advance for the process in the characterization of spraying areas.
The pilot will return to base immediately after dumping product

High incident. This is a highly hazardous event, in which the pilot no longer has
airworthiness sufficient to choose the place where he will dump the product, and
therefore must do so immediately and return to base

633Annex 33

Fatal incident. These are incidents in which the outcome is fatal, because generally

ending with a crash.

The follow-up to the particular operations undertaken in the Contingency Plan is
established depending on the specifications in the plan for supervision, inspection

and control

b. Activation of response team. This level of operations relates to all activities
undertaken to put the spraying emergency attention brigade into operation. It

includes a reconfirmation of the exact spot of the incident, the security study for the
area in which the incident occurred, transits to the area, evaluation of the need to
take corrective measures, and dumping if necessary.

c. Spraying emergency attention brigade . This brigade will take action to apply
corrective measures that in the Contingency Plan for events related to a total of
specific dumping product.

The coordination of respons e team is the responsibility of the Base Commanding
Officer (Head of Emergencies each base) , who becomes the br igade coordinator
as of the moment that the incident is reported.

d. Check on security conditions. If an aircraft is forced to dump all or part of the
product, this activity is generally related to criminal actions (hit by gunfire,

obstacles on plots, etc), technical failures in aircraft, environmental conditions or
human failures.

Since the contingency action must be undertaken in same area where the incident

takes place, it is a priority to check the security conditions in place where the
product is to be dumped, in order to avoid a transit and operations by the response
team, which might repeat the incident. The security study is obtained from

634 Annex 33

intelligence reports promptly supplied by the forces of law and order in the area,
and information from technical personnel making a technical study of the incident.

If intelligence information reports that security conditions are not suitable for the
spraying emergency attention brigade to move out, await new orders, to be given
when security conditions become optimal. Meanwhile, spraying operations will

continue in other areas.

ACTIVATION OF RESPONSE TEAM

(diagram)

e. Geographical reconfirmation of the area . SATLOC will be used by the Head

of Emergencies to provide a geographical location of place where the aircraft was
forced to dump the product, in order to dispatch the response team to that place.

f. Transfer of the spraying emergency attention brigade to the site . If security

conditions reported by the regional intelligence office of the National Police are
optimal, the brigade will be dispatched in accordance with parameters established
in the operating procedures for crop eradication by aerial spraying.

g. Evaluation of the area affected by dumping product . The spraying
emergency brigade will evaluate whether there is justification for dumping water in

the area affected. This procedure taken into account if the dumping is effected on
lawful crops, illicit crops, bodies of water, population centres, etc.

h. Application of corrective measures . Depending on the geographical

characteristics of the place, time and weather, and security, aircraft will dump 200-
300 gallons of water on the place affected.

2-4 dumping activities will be effected. This corrective action should be taken

during three hours following the incident. Dumping will be effected during this time
provided that the security evaluation allow it.

635Annex 33

i. Information report. This level of operation is activated by the Head of

Emergencies, from the moment the pilot or security team accompanying him
reports the incident. The purpose is to establish an information flow between
authorities and entities which support or accompany them or are affected by the

incident.

j. Technical report on the incident . This is a careful review of the aircraft by
technical personnel of the Antinarcotics Police Aviation Area attached to the base

involved in the area where incident occurs , and the eradication program advisers.
The purpose of evaluation is to check on possible damage caused to the aircraft,
and to certify results obtained. In the event of a contingency related to human

failure, the technical report will make the initial evaluation, for use in a preliminary
disciplinary investigation.

k. Completion of the initial report form. The Head of Emergencies, who

becomes the coordinator of the Spraying Emergency Brigade, will make an initial
report of the dumping, taking account of the technical report of the incident, which
will contain basic information of the specific circumstances of time, place and

manner, and to make a preliminary estimate of the magnitude and severity of the
event.

FLOW OF REPORTS

Diagram

l. Final technical report . The Head of Emergencies, with the support of the
Spraying Emergency Brigade, will present fi nal technical report in writing to the

Antinarcotics Division, for forwarding to DNE, within 20 days of the occurrence of
the dumping, in order to provide detailed knowledge of the circumstances of the
event, attention, and control.

The final report of the event will contain the following

636 Annex 33

9 Date and time of the incident, date and time of initial notification to the
Government agency
9 Date and time of the end of the emergency

9 Location of dumping. The map used by the Program, with the exact location
of the dumping given by the SATLOC system
9 Cause of dumping
9 Volume dumped
9 Determination of affected areas. (Land, natural resources, installations)
9 Determination of communities possibly affected
9 Operating plan developed, and response times used in control

9Description of measures for prevention, mitigation, correction and
monitoring
9 Support required (requested/obtained).

In addition to the above information, an evaluation and will be made of the

dumping, using technical criteria to evaluate the capacity for attention to the event,
and to identify immediate risks in the forthcoming spraying operations. The aspects
to be considered in the evaluation of the dumping are:

9 Origins of dumping
9Characteristics of the herbicide and principal physical-chemical
characteristics
9 Determination of possible risks to personnel engaged in the emergency, in
community and in operations.
9 Estimated potential approximate maximum volume of dumping
9 Evaluation of prevailing environmental and weather conditions

9 Expected trajectory of the discharge of the dumping
9 Identification of resources threatened
9 Available equipment. Evaluation of availability of equipment to control the
dumping
9 Maximum transit time to the place of occurrence. Establish and evaluate
maximum response times by the Contingency Plan response team.

j. Criminal denunciations. The Chairman of the Emergency Committee, and the
pilot involved in the emergency will lodge a criminal denunciations with the

appropriate authorities, for them to discover the persons responsible for the
damage caused to the aircraft as a result of the incident.

2.2.8. Evaluation of the contingency plans

Once the emergency is over, the Chairman of Emergency Committee, the

637Annex 33

Commanding Officer of the Antinarcotics Base will act to determine definitive
closing down of operations, and evaluate consequences derived from the dumping

with regard to the efficiency of actions taken, and effects on the environment.

2.2.8.1. Final emergency report

For all events involving the activation of the Contingency Plan, there will be a final

written report addressed Emergency Committee, giving an account of the events
which took place at the base and during spraying, the report also be addressed to
the various government agencies responsible for environmental matters (CAR,

Ministry of Environment), and members of the National Technical Committee of the
National Contingency Plan, within eight days of the date of the dumping, in order to
provide detailed information on circumstances of the dumping, and attention and

control deployed.

Evaluation of response to emergencies

In order to control and undertake evaluations of actions, contingency plan will keep

a log, which contains the daily report of control activities and attention to dumping,
and actions undertaken. The basis for the preparation of reports, and attention to
possible claims

After the event has ended, and based on repor t on action taken, particularly in the
effectiveness of the Plan, with reference to attention to the disaster. This evaluation
will allow determination of the most important aspects to be taken into account in

the reformulation and redesign of the Contingency Plan, based on experience
obtained from the emergency.

The evaluation will involve the following analysis:

9 Origin of the emergency
9 Speed of activation of the alarms
9 Mechanisms and times of evacuation
9 Procedures to combat the emergency
9 Sufficiency of available equipment
9 Levels of knowledge at the time of emergency

638 Annex 33

9 Response levels
9 Analysis of operational and natural risk
9 Relationships with local or regional committees for emergency prevention

and detection. Channels of information to the community
9 Communication systems
9 Structuring of the IT plan. Existence of plates, maps, plans. Information on
critical areas, inventories of control equipment, list of authorities, etc.

2.2.9. Training programs

It is a fact that a Contingency Plan, to be effective, not only requires the
organization and equipment to attend an emergency but also, as a basic element,
efficiency on the part of personnel, and this can only be obtained by training.

For training purposes, following environments and materials required and supplied
by DIRAN

9 Decision making
9 Crisis management

9 Personnel organization. Command, c ontrol and supervision of response
operations

For training purposes specific to operating matters, recommended training
directives must be prepared in accordance with recommendations in the National

Contingency Plan.

The specific training programs should include the following:

9 Contingency Plan. All personnel in nuclei must receive a course on

operating schemes and the organization of the Contingency Plan, and
conduct regular drills on events which may cause threats, gradual,
evacuation, firefighting, and first aid.

9 Other specific issues are:

Technical. Storage and handling in areas of operations of spraying equipment,

639Annex 33

and materials, and organization of working teams.

Environmental. Reconnaissance operating areas and a range of ecosystems with

different degrees of sensitivity.

Operational. Information on physical and chemical properties, and methods of
deactivating them.

The frequency of training should be as follows:

9 3 training sessions a year with practical work for all personnel

9 12 practical sessions a year for Emergency Response Brigades

9 1 course a year for Commanding Officers, in methods of prevention and
control of contingencies, and the development of basic knowledge on the
effects of dumping

2.2.10. Emergency equipment

DESCRIPTION

Safety boots

First aid kit

Folding stretcher

Rigid stretcher

Safety helmet

Resuscitation Kit

640 Annex 33

Air supply kit (mask, hose, blower)

PQS 50-LB satellite extinguisher

PQS CO2 20-lb extinguisher

First aid: portable material

2 ½” 15-m hose

1 1/2” 15m hose

½” rope

Pump for firefighting

Overalls

Fixed hose reel

Electric siren

Axes

Product recovery pump

Water tank

Aircraft

2.3. INFORMATION SYSTEM OR DATABASE

The contingency plan database will supply information required to ensure that the

strategic and operational plans are efficient. All the information required by the
Contingency Plan will be compiled and updated permanently by DIRAN, through
the Chairman of the Emergency Committee.

The Contingency Plan requires information to be presented as geographical
information, general listings, attachments, and consolidation into the following

types of information: legislation, referencing, logistics, statistics, local and industrial

641Annex 33

contingency plans and environmental considerations, amongst others.

For the purposes of handling the Contin gency Plan database, DIRAN, acting

through the Chairman of the Emergency Committee, will request relevant
information from municipal, departmental or national agencies.

When information is requested from an agency, the agency will inform the

administrator of the information that part of the information is confidential or
restricted, and state the provisions of law covering that restriction. At the same
time, it will establish the conditions in which that information may be used.

DIRAN will have a specific project for software, hardware, staff and logistical
support, to administer and process existing information.

3. SCHEDULE OF ACTIVITIES

The programming and organization of the Contingency Plan is intended to foresee

and provide against any event which might become a disaster, and the following
activities need to be undertaken:

PROGRAMMING

This component includes the formation of emergency groups and the allocation of
functions and responsibilities.

9 Standing Emergency Committee
9 Emergency group

9 Internal support groups
9 External support groups

ADAPTATION OF AREAS AND INSTALLATIONS IN EACH NUCLEUS

Certain areas may be needed for response to any eventuality, to attend to an

emergency, such as green areas, sporting facilities, first aid areas, etc.

ACQUISITION OF EQUIPMENT TO ATTEND TO EMERGENCIES

642 Annex 33

9 Control equipment
9 Safety equipment
9 Prevention and protection equipment

9 GIS and database.

FORMATION OF INTERNAL AND EXTERNAL SUPPORT BRIGADES

EXECUTION OF THE TRAINING PROGRAM

9 Workshops, talks, lectures, drills.

4. ESTIMATED COST

Personal protection equipment

Description Unit Quantity Total cost

Personal protection nucleus 12 COP 30,000,000

Emergency control equipment nucleus 12 COP 60,000,000
(extinguishers, detectors, barriers,
pumps)

First aid kits 12 COP 30,000,000

Training program nucleus 12 COP 30,000,000

Total COP 150,000,000

END OF CONTINGENCY PLAN RECORD.

GLOSSARY

Definitions of the main specific and most frequent times are given below, to

enhance understanding of this study

643Annex 33

Absorption: a process by which plants take nut ritive elements from the substrate
and incorporate them into their issues.

Aquifer. A geological layer, whose constitution favours the accumulation of
groundwater

Aerobic: organisms that cannot live without air, and which consume oxygen during

development and metabolic activity

Anaerobic. Organisms that live and develop in the absence of air, and for which
oxygen is often toxic.

Biomass. Mass per unit of surface or volume of a set of organisms or certain living
organisms living in an ecosystem (biozenosis)

Seedlings: Trees 0.30-1.30 m high

Trophic chain . The chain of molecular transfer between different organisms
composing an ecosystem (producers, consumers, decomposers).

Biogeochemical cycle. The circuits or lines from which elements required for life
circulate in plants and animals and return to the soil, water or atmosphere, from
which they are again taken in by living beings.

Environmental component. This component is used to indicate physical, biotic,
socio-economic all cultural factors which form the environment (physical, biotic
component, etc),. As such, each environmental component is an element of the

environment (see below, definition of element).

644 Annex 33

Conservation. Maintenance of the productive capacity of a resource, through
sustainable systems of use, exploitation and management. This is different from

preservation, in the sense that preserva tion does not accept uses which imply any
alteration of natural vegetation cover or of natural evolution processes.

Contamination. Alteration of the conditions of an ecosystem is caused by

discharges and emissions of liquid and gas use waste, noise, or the disposal of
solid waste on the soil.

Hydrographic basin. An area whose waters follow a given course

Decomposition. Process by which certain organisms (worms, bacteria and insects)
decompose organic matter in simple organic compounds (humus).

Dissolution. Process by which salts present in the soil are dissolved in water which

filters into it

Ecology. The study of the structure and functioning of the biosphere, or more

generally, its components known as ecosystems.

Ecosystem. A functional system which is more or less stable over time, with a
sufficient area to be characterized, and c onstituted by a set of living organisms

present in it, and the physical medium for the interchange of energy and matter
(Biotope).

Environmental element. According to Legislative Decree 2811/1974, these are all

elements of factors which form the environment or influence it, including waste,
refuse, residues, and leavings, noise, the conditions of life resulting from urban or
rural human settlements, and goods produced by man, whose production is

induced by man, in which environmental deterioration may have an influence

645Annex 33

Emissions. A discharge of gases, particles or smoke into the atmosphere from
fixed from sources such as a factory chim ney or mobile sources such as vehicle

exhaust. This may also be natural.

Run-off. Flow of water in the liquid state, may be surface or underground

Evaporation. Emission of water by a surface free of liquid water, at a temperature

lower than boiling point.

Evotranspiration. The process by which water coming from the evaporation of
liquid and the transpiration of plants is transported from the ground into the

atmosphere

Photosynthesis. A physiological mechanism by which organisms containing
chlorophyll are able to assimilate carbon gas and transform it into living matter,

using light radiation as energy.

Fragility. Vulnerability or degree of susceptibility of medium or its components to a

given action

Small trees: Tees with a DBH of more than 10 cm

Habitat. A homogeneous environment on a surface or in a given volume of an

ecosystem. A place where a man lives or inhabits, including housing and
infrastructure

Homeostasis. The faculty of self-regulation in a an ecosystem which tends to

reconstruct the initial relations between components of communities, and to
maintain the functional structure of the ecosystem constant

646 Annex 33

Saplings: Trees with a DBH of 10 cm or less, and a height of more than 1.30 m.

Environment. A set of energy, physical, chemical and chemical, biological and

social conditions dominant in the area where living organisms live. Synonym:
Biotope.

Mineralization. Process through which humus is transformed into mineral

substances under the action of bacteria and fungi.

Percolation. Rainwater or surface run-off which filters and passes through surface
formations of the earth

Persistence. Permanent over time, opposite to temporary, or short-term events

Population. A set of individuals belonging to the same species which lives in a

given ecosystem

Rainfall. Water which falls from the atmosphere and a solid or liquid form, from a
cloud or set of clouds. It may be liquid or solid.

Preservation. The maintenance of a state of affairs of an area or ecosystem in
conditions of natural evolution. In order to achieve this, in general the regulations
applicable to nature reserves and nature parks are applied.

Resilience or recoverability. The capacity of an ecosystem to absorb environmental
tension without changing to appreciably different ecological conditions. In other
words, it indicates the capacity of ecosystem to reorganize itself by itself when

under pressure.

647Annex 33

Hydraulic bed. This is the bed in which a watercourse or deposit, designed to
provide protection and environmental management of the body of water. In

watercourses, this bed corresponds to the a lluvial valley. In lakes, pools, creeks,
dams and the like, this corresponds to the flood zone.

Sensitivity (of an ecosystem). Ecological susceptibility to alteration, evaluated as a

function of the regional and global importance of the ecosystem and its resilience.

Succession. Certain populations (or micro populations), that succeed in a given
environment

Symbiosis. A mandatory synergic association between two organisms.

Synergism. Association between two organisms which is beneficial to one or both
of them. Symbiosis, mutualism and comm ensalisms are forms of synergy. By

extension, the word is used to indicate processes in which the combined action of
two elements of phenomenon generates more drastic conditions than the separate
action of them of each of them.

Soil solution. Solution in which plants take on nutritive substances

Alluvial valley. A strip or bed along a watercourse, over which the watercourse

spreads during flooding and deposit sediment . It is therefore a risk zone for urban
development

Discharge. The discharge of a liquid effluent into a body of natural water or a

sewerage system. This may be domestic wast ewater or industrial wastewater, or
mining or industrial wastewater.

648 Annex 33

CONTINGENCY PLAN

Accident. Any incident whose origin is considered to be fortuitous.

Unsafe action . Activity counter to parameters of safety already and already
stipulated or taken for granted. The human contribution to the development of an
accident.

Risk management. A set of strategies designed to minimize risks associated with
the functioning of the system, in order to minimize loss and guarantee continuity.

Adversely affected person. The individual or legal entity is suffering damage to

assets or operations as a consequence of a loss.

Threat or hazard. The possibility of a loss will occur, analyzed considering only the

type of event and the place.

Environmental threats. The condition able to generate damage in the environment.

Logistical support. The function of response to emergencies during the phases of

control and mitigation, consisting of a coordination of internal resources to support
and facilitate the operation of emergency action groups.

Sensitive area. A geographical area exposed to losses, whose characteristics have

a high degree of vulnerability.

Assumption of Risk. The strategy of risk management consisting in not performing
actions designed to control risks, acceptance of risk.

649Annex 33

Attack. A loss caused intentionally. All attacks entail loss.

Characterization. The degree of sensitivity of a system to a risk, measured with

regard to the level of adverse effects possible to its stability.

Circumstances. Risk factors external to the system, which do not depend on it or
are not controlled by it.

Conditions. Internal risk factors, depending on the system and controlled by it.

Disaster. The result of an emergency with serious consequences.

Emergency. Situation which implies a state of partial or total disturbance of a

system, due to the imminent probability of occurrence or actual occurrence of a
loss, and whose magnitude may endanger the stability of the same, or require a

response greater than that established (basic response), implying a temporary
modification of the organization of the system.

Evacuation. A planned action, in which each per son threatened by collective risks

follows pre-set procedures designed to bring him to safety by his own means, or by
other existing means, through movement, and to places of lower risk

Risk profile . Location related to a risk with regard to risk levels defined as

acceptable, as a functional combination of frequency and severity of the same
(Vulnerability).

Contingency plan. Preset response to events associated with operations, which

may affect them, without representing a threat or harm or injury.

650 Annex 33

ENVIRONMENTAL MANAGEMENT PLAN OF THE
PROGRAM FOR THE ERADICATION OF ILLICIT

CROPS BY AERIAL SPRAYING WITH
GLYPHOSATE
(PECIG)

VOLUME OF ANNEXES

Bogotá, November 2001

651Annex 33

TABLE OF CONTENTS

INTRODUCTION
EXECUTIVE SUMMARY
1. GENERAL ASPECTS
1.1 GENERAL OBJECTIVE
1.2 SPECIFIC OBJECTIVES

1.3 BACKGROUND
1.4 LOCATION AND APPROACHES
1.5 JUSTIFICATION
1.6 LEGAL FRAMEWORK
1.7 ORGANIZATIONAL STRUCTURE
2. PROGRAM DESCRIPTION AND ANALYSIS

2.1 OBJECTIVE
2.2 SCOPE
2.3 STAGES OF THE PROGRAM
2.3.1 DETECTION
2.3.2 SPRAYING
2.3.3 VERIFICATION

2.4 GLYPHOSATE CHARACTERIZATION
2.4.1 PHYSICAL-CHEMICAL COMPOSITION AND CHARACTERISTICS
2.4.2 COMMERCIAL FORMULATION TYPES
2.4.3 SURFACTANTS AND INERT INGREDIENTS OF BASIC FORMULA
2.4.4 CLASSES, MATERIALS AND CAPACITY OF THE CONTAINERS
2.5 HERBICIDE APPLICATION METHOD

2.5.1 HERBICIDE APPLICATION TECHNIQUE
2.5.2 EXCLUSION AREAS OF THE OPERATION AND BUFFER STRIPS
2.5.3 HERBICIDE TANKING SYSTEM
2.5.4 METHODS AND FREQUENCY OF CALIBRATION OF THE
SPRAYING EQUIPMENT
2.5.5 LIMITATIONS CAUSED BY ENVIRONMENTAL CONDITIONS

2.6 TECHNOLOGICAL EQUIPMENT, MATERIAL AND TOOLS OF THE
PROGRAM
2.6.1 EQUIPMENT
2.6.2 MATERIAL AND ELEMENTS USED
2.6.3 TECHNOLOGICAL TOOLS
2.7 PROGRAM FOR THE ERADICATION OF ILLEGAL CROPS
2.7.1 GENERAL ASPECTS

2.7.2 PECIG STRUCTURE AND ORGANIZATION
2.7.3 INTER-INSTITUTIONAL COORDINATION ACTIVITIES
2.7.4 PROGRAM GOALS
2.7.5 PECIG’S SCHEDULE
2.7.6 PECIG’S COSTS
3. ENVIRONMENTAL BASELINE

3.1. IDENTIFICATION OF THE AREA OF INFLUENCE
3.1.1 CRITERIA FOR THE SELECTION OF THE AREAS FOR AERIAL
SPRAYING

652 Annex 33

3.1.2 AREAS OF INFLUENCE FOR THE PECIG
3.2 GENERAL CONDITIONS OF THE ILLEGAL CROP AREAS IN
COLOMBIA

3.2.1 PHYSICAL COMPONENTS
3.2.2 BIOTIC CONDITIONS
3.2.3 SOCIAL, ECONOMIC AND CULTURAL COMPONENTS
3.2.4 SOCIAL DETERIORATION INDUCED BY ILLEGAL CROPS:
SOCIAL FRAME OF THE PECIG
3.2.5 ENVIRONMENTAL DETERIORATION DUE TO ILLEGAL CROPS:
ENVIRONMENTAL FRAMEWORK OF THE PECIG

3.3 ENVIRONMENTAL ZONING
3.3.1 GENERAL CONCLUSION
3.3.2 CRITERIA OF ENVIRONMENTAL ZONING FOR SPRAYING
3.3.3 GENERAL ZONING
4. ENVIRONMENTAL IMPACT-RISK ASSESSMENT
4.1 GENERAL ASPECTS

4.1.1 ASSESSMENT CRITERIA
4.1.2 EFFECTS OF GLYPHOSATE
4.2 IMPACT ON PHYSICAL ENVIRONMENT
4.2.1 IMPACT ON SOIL
4.2.2 IMPACT ON WATER
4.2.3 IMPACT ON ATMOSPHERIC RESOURCES

4.3 BIOTIC IMPACT
4.3.1 IMPACT ON VEGETATION
4.3.2 IMPACT ON FAUNA AND MIGRATORY BIRDS
4.4 SOCIOECONOMIC IMPACT
4.4.1 IMPACT ON PUBLIC HEALTH
4.4.2 IMPACT ON AGRICULTURAL PRODUCTION AND LIVESTOCK

4.4.3 IMPACT ON HUMAN SETTLEMENTS AND MIGRATION
4.4.4 CULTURAL IMPACT
4.4.5 OTHER IMPACTS
4.5 GENERAL SUMMARY
5. ENVIRONMENTAL MANAGEMENT PLAN (EMP)
5.1 OBJECTIVES

5.2 STRUCTURE OF THE EMP
5.2.1 OPERATIONS MANAGEMENT
5.2.2 MITIGATION MEASURES
5.2.3 SOCIAL FEASIBILITY OF THE PROGRAM
5.3 SCHEDULE
5.4 ENVIRONMENTAL MEASURES COST ESTIMATES

SPECIFICATION SHEETS ATTACHED
SHEET NO. 1: SPRAYING OPERATIONS MANAGEMENT PROGRAM
SHEET NO. 2: HANDLING OF GLYPHOSATE AND COADJUVANTS AT
OPERATIONS BASES

SHEET NO. 3: FUEL, VEHICLES, EQUIPMENT AND

653Annex 33

TRANSPORTATION OF GLYPHOSATE MANAGEMENT
PROGRAM
SHEET NO. 4: SOLID WASTE MANAGEMENT PROGRAM

SHEET NO. 5: MANAGEMENT PROGRAM FOR WASTEWATER AT
BASES
SHEET NO. 6: INSPECTION, VERIFICATION AND CONTROL
PROGRAM ON SPRAYING OPERATIONS
SHEET NO. 7: RESEARCH PROGRAM FOR REPRESENTATIVE AND
DEMONSTRATIVE PLOTS
SHEET NO. 8: BASIC ENVIRONMENTAL MONITORING PROGRAM

SHEET NO. 9: SOCIAL MEASURES AND COMPENSATION PROGRAM
SHEET NO. 10: EDUCATIONAL COMMUNICATIONS PROGRAM
SHEET NO. 11: INTEGRAL SAFETY PROGRAM AT THE OPERATIONS
BASES
SHEET NO. 12: ENVIRONMENTAL MANAGEMENT PROGRAM
SHEET NO. 13: CONTINGENCY PLAN

GLOSSARY
BIBLIOGRAPHY

VOLUMES ATTACHED
NO. 1: METHODOLOGY OF THE MONITORING OF THE INTEGRATED
PROJECT FOR ILLEGAL CROPS

NO. 2: ILLEGAL CROP AREAS, LISTING BY DEPARTMENTS,
MUNICIPALITIES AND NUCLEI. AUGUST 2000 CENSUS
NO. 3: QUOTATION FOR A COMPACT WASTEWATER TREATMENT
PLANT FOR BASES
NO. 4: OPINIONS OF THE MINISTRY OF HEALTH ON TOXICITY OF
GLYPHOSATE. POEA AND COSMOFLUX

654 Annex 33

ANNEX 1

M ETHODOLOGY OF THE LLICITCROPS

INTEGRATED MONITORING PROJECT–SIMCI

655Annex 33

METHODOLOGY OF THE ILLICIT CROPS MONITORING IN
COLOMBIA USING SATELLITE IMAGE INTERPRETATION

656 Annex 33

Content

Introduction 10 
1. Methodology of the Illicit Crops Monitoring in Colombia Using Satellite Image Interpretation 12 
1.1 images Employed 14 
1.2 Import 16 
1.3 Georeferencing 17 

1.4 Visualization 18 
1.4.1 Contrast enhancement 18 
1.4.2 Spatial enhancement 18 
1.4.3 Multispectral enhancement 23 
1.5 Legend 26 
1.6 Analysis of Secondary Information 33 

1.7 Interpretation of Images 36 
1.8 Building Coverage in Fumigated Areas 40 
1.9 Field Testing 44 
1.10 Final Editing 57 
2.  Methodology for Fieldwork 62 

2.1 First Phase: Aerial Reconnaissance 62 
2.1.1 Selection of Areas 63 
2.1.2 Flight Schedule 63 
2.1.3 Evaluation of Results 64 
2.2 Second Phase: Field verification 65 
2.2.1 Selection of Verification Areas 65 

2.2.2 Flight Schedule 66 
2.2.3 Estimation of Areas Verified. Programmed Sampling and Real Sampling 67 
2.2.4 Evaluation of Results 67 
2.3 Quality Control of the Fieldwork 68 
2.4 Quality Control of the Census 69 
2.5 The Quality of the Information 69 

2.6 Approach and Estimation of the Degree of Reliability of the Information 69 
2.6.1 Selection of the Sample 71 
2.6.2 Qualification of the Statistical Sample 72 
2.6.3 Estimation of Results 74 
3 FINAL RESULTS 74 
3.1 GIS Applications 83 

3.1.1 Categorization 87 
3.1.2 Neighborhood Analysis (Buffers) 87 
3.1.3 Plante Projects 94 
3.1.4 Multi-temporal Analysis 94 
3.1.5 Characterization 99 
3.1.6. International Vision of the Project 103 

657Annex 33

INDEX OF FIGURES

Figure 1 Methodology Scheme of the Illicit Crops Monitoring in Colombia 12
Figure 2 Satellite Images Used 14

Figure 3 Band 2 Original – Spot Image 643349 18
Figure 4 Band 3 Georeferenced and Geometrically Corrected 19
Figure 5 Window Georeferenced Image 20
Figure 6 Contrast Enhancement – Spot Image 645347 21
Figure 7 Spatial Enhancement – Spot Image 643349 23
Figure 8 Multi Channel Visualization 24

Figure 9 Approach To Color Composition 321 – SPOT Image 643349 26
Figure 10 Approach To Color Composition RGB 432 – SPOT Image 645336 27
Figure 11 Approach to Color Composition RGB 437 – LANDSAT Image 9_60 28
Figure 12 Multi Channel Visualization – IHS Transformation 29
Figure 13 IHS Transformation SPOT Images 650345, 652345, 651347 30

Figure 14 Legend SIMCI Coverage Areas 31
Figure 15 Evaluation Phase of Secondary Information 32
Figure 16 Fumigation Lines – Identification of Coca Crops 33
Figure 17 Photograph of a Coca Crop 36
Figure 18 Training and Assignment Phase – ILWIS Software 37
Figure 19 Training and Assignment Phase – PCI Software 38

Figure 20 Visual Interpretation of Coca Crops 40
Figure 21 Visual Edition by Digitization in Areas of Spectral Confusion 41
Figure 22 Preliminary Classified Map – SPOT Image 643349 42
Figure 23 Identification of Sprayed Coverage Areas 44
Figure 24 Field Verification Scheme 45

Figure 25 Field Verification Points – Specific Areas 46
Figure 26 3D Viewing – La Gabarra Image 47
Figure 27 Field Verification By Sweep Following Meridians 48
Figure 28 Aerial Photograph For Edition 50
Figure 29 Aerial Photograph For Edition 51
Figure 30 Comparison of Coverage Areas By Location of Points 52

Figure 31 Verification of Coverage Areas, Photo and Satellite Image 53
Figure 32 Field Verification Chart 54
Figure 33 Theme Map of Land Coverage 57
Figure 34 Approach To Theme Map 58
Figure 35 Preparation of Space Maps 59

Figure 36 Mapping Products 60
Figure 37 Statistical Products of an Image – Basic GIS Input 83
Figure 38 Statistical Products Generated By The Database 84
Figure 39 GIS Query 85
Figure 40 GIS Query – Range of Medium Density Areas In Coca Crops 87
Figure 41 GIS Query – Range of High Density Areas In Coca Crops 88

Figure 42 Buffer To Varying Distances of Guamuez River – Neighborhood Survey 89
Figure 43 Coca Crops Categorized By Distance To Water Bodies 90
Figure 44 Coca Plots At Variable Distances From Water Bodies 91
Figure 45 Statistics By Buffer Studied – Guamuez River – Putumayo Nucleus 92
Figure 46 Viewing of PLANTE - DEM Productive Projects Puerto Asis Municipality 94

Figure 47 PLANTE Projects Coordinates 95

658 Annex 33

Figure 48 Location PLANTE Agreements For Voluntary Eradication 96
Figure 49 Damping Area For PLANTE Productive Projects 97
Figure 50 Supplementary Information To Achieve New Theme Maps 99
Figure 51 Ecosystems Affected By Illicit Crops 100

Figure 52 Table - Ecosystems Affected By Illicit Crops 101

659Annex 33

INTRODUCTION

Remote sensing and computer-based digital imaging have

changed the study of land surface and the evaluation of the
natural resources.

One of man’s major concerns throughout history has been the exploration of the planet Earth. His
attention has been driven by a powerful need to know what lies beyond his domain.

In all his proceedings, man has used a number of elements that distinguish him not only as a

creature seeking keenly to investigate his surroundings, but also as an individual out to dominate

the environment.

In consequence, his curiosity and desire to learn about the land he dwelled first led him to climb a

tree, and later conquer a mountain to take in the sweeping view of the landscape.

Even in this summary of man’s early exploratory activities, the basic elements of today’s modern

science of remote sensing come into view: The light source, formed in this case by the sun emitting
light or solar radiation; the landscape, made up of all objects in the territory explored by man, such

as rivers, mountains, vegetation and man-made elements; the scene, that is, that section or area of

the landscape on which man centers his interest; the remote sensor , with which light emanating

from the scene is captured and which, in this case, allows a visual representation of that area of the

landscape that has been focused by the iris and the eye lens; the platform, which is where the

remote sensor is placed or mounted for an overview of the entire scene; the processing system
comprising the device to process, qualitatively and quantitatively, data provided by the remote

sensor regarding the scene, which, analyzed and interpreted by man’s brain, provide valuable

information in relation to the landscape that is useful in making any decisions about the

environment; and the field support, which consists of direct inspection at various selected points of

the scene, of the different attributes of the objects found in the field in order to evaluate the data
obtained previously from a distance.

This remote observation of the Earth’s surface is the framework for the study of spatial remote

sensing that is conceived as the technique which allows the attainment of scenes or images of the

660 Annex 33

Earth’s surface from sensors installed on space platforms, assuming that between the Earth and the

sensor there is an energy interaction, either by re flection of solar energy or an artificial energy
beam, or by its own emission which is transmitted to the land surface, where the detected signal can

be stored and interpreted for a particular application.

In December 1997, the Government of Colombia initiated in the provinces of Guaviare, Vaupés and
Vichada a pilot phase (ILICO) for the identification of illicit crops with such technology. The

current project (SIMCI) has continued and extended this work by creating a methodology for

ongoing and comprehensive monitoring of illicit crops, not only quantifying but also specializing

them in different regions of the country using satellite imagery.

Part of this project is the design and implementation of a Geographic Information System for the

analysis of information generated by satellite images. This will provide data to the UNDCP

international monitoring system in tune with the resolutions of the Space Meeting of the UN
General Assembly dedicated to the world drug problem (UNGASS, June 1998) and Resolution 42/3

of the Commission on Narcotic Drugs (CND) on “Monitoring and verification of illicit crops.”

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1. METHODOLOGY OF THE ILLICIT CROPS MONITORING IN COLOMBIA USING

SATELLITE IMAGE INTERPRETATION

The purpose of this paper is to distinctly illustrate the complete methodology that has been designed
and implemented throughout the project.

To this end we submit the methodological framework that shows all the different processes used to

obtain a theme map, which identifies and spatializes illicit crops in Colombia.

In many cases, the production of a map is the final phase of the work, its ultimate outcome. In

others, such as in the SIMCI project, it is merely another document that provides, along with other

land variables, an integrated understanding of t he space under consideration. With this approach,
the project, supported on a Geographic Information System as a tool, aims to generate new

information based on the treatment of stored data to solve more complex situations. These require

handling different information sources and layers using spatial analysis and statistical techniques to

guide the project to management and decision-making at the different levels required. (see Figure 1)

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FIGURE 1 METHODOLOGY SCHEME OF THE ILLICIT CROPS MONITORING IN

COLOMBIA

IMPORT 

DISPLAY 

CONTRAST ENHANCEMENT  SPATIAL ENHANCEMENT 

VEGETATION INDEX  COLOR COMPOSITION  IMAGE FUSION 

OPTIMAL INPUT/S FOR CLASSIFICATION

GENERAL DEFINITION OF COVERAGE 

ANALYSIS AND EVALUATION OF 
SECONDARY INFORMATION 

PRELIMINARY CLASSIFIED MAP 
GENERATION OF SPRAYED COVERAGE 
AREAS 

FIELD VERIFICATION 

VISUAL EDITION 

MAPPING PRODUCTS  GENERAL STATISTICAL PRODUCTS 

GIS PRODUCTS (POLYGONS, ATTRIBUTES, TABLES)

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1.1 IMAGES EMPLOYED

The project has used SPOT, LANDSAT IKONOS and RADAR satellite images. For the purposes

of the project, the spatial resolution is secondary to the spectral and temporal, because the

phenomenon studied is very dynamic in time and the spectral dimension is the definer, therefore it
is critical to use sensors that provide information on certain bands where the phenomenon of

interest is more evident.

The SPOT (Systeme Probatoire d’Observation de la Terre) satellite developed by the French CNES
in cooperation with Belgium and Sweden, has two sets of push scans called HRV (Haute Resolution

Visible). These two sensors allow imaging in two modalities: panchromatic and multispectral

(green, red and near infrared) with a spatial resoluti on of 10 and 20 meters respectively; the area

covered in each scene is 60 km per side which means a coverage of 360,000 hectares, with a
spectral resolution of 3 bands for Spot 3 and 4 bands for Spot 4.

Landsat is a U.S. satellite with coverage of 180 km per side, equivalent to coverage of 3.24 million

hectares, with a spatial resolution of 28 m for the spectral mode and 15 m for the panchromatic and

a spectral resolution of 7 bands. The decision to use SPOT or LANDSAT lies in the nearness of the
image for the target date of the figure and the presence of a lower percentage of clouds since either

of these two types of images allows us to discriminate at an optimum level of quality the coverage

of interest for the project. (See Figure 2)

The French satellite ERS can be used in the case where LANDSAT or SPOT do not allow gathering

information due to the effects of the clouds, since the radar wave penetrates the clouds to capture

information of the land surface.

The use of IKONOS in the project is geared towa rd the identification of poppy crops given its 4-
meter spatial resolution at the multispectral level or one meter for the panchromatic band. It is also

used for quality control processes, that is, the interpretation using IKONOS images can be

compared to that obtained with both SPOT and LA NDSAT, as appropriate. Another application is

to locate and plan for alternative development programs led by PLANTE.

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FIGURE 2 SATELLITE IMAGES USED

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1.2 IMPORT

The first part of the scheme shows the item relating to image import.

In ILWIS software version 2.2, the option to impo rt “General raster data” is selected, since this
software does not read the original image files directly and the information requested in the import

dialog box must be provided.

With the PCI software, the import process is direct, with images that are supplied in BIL and DAT
format. For those images that are provided in BSQ format, the software requests additional

information similar to that requested by the ILWIS.

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1.3 GEOREFERENCING

For the georeferencing of an image, it is important to have a series of common observations

between the image to be georeferenced and the support (georeferenced image, analog or digital

maps, lists of control points with coordinates, GPS, etc.)

That functions that enable the transfer of map coordinates to the image require locating a series of

control points between image and map. From the coordinates of these points, a function can be

estimated to relate the two documents, because the functions are estimated from the sample
coordinates. The quality of the adjustment depends on the precision with which these points are

located; otherwise, the estimate will be biased.

The experience gained during the project has indicated that the selection of points is a complex task.

In case of an image-to-image registration, the proc ess is simplified, since it is easier to identify
commonalities (eg river crossings, roads) between the two images than between image and map.

Figure 3 shows an original band 2 image corresponding to the province of Putumayo exhibiting the

municipalities of Puerto Asis and La Hormiga, and which has not undergone geometric correction
or georeferencing. (See Figure 3)

Geometric correction seeks to change the positioning of the pixels of the image in order to have

them coincide with true north, or for the geographic elements to coincide as regards the position

with the same elements represented in a map. This operation can be used both to cartographically
correct an image, and to overlay two or more images together, with the aim of conducting multi-

temporal studies of the dynamics of illicit crops in Colombia. When georeferencing, we can obtain

the exact location of a point with geographical and flat coordinates, take longitudinal or polygon

measures on the image in order to understand the area of each and feed the GIS database (see
Figures 4 and 5)

Once the image has been georeferenced and geometrically corrected, the next step of the process is

to display each of the bands of images and the contrast and spatial improvements where

appropriate.

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The aim in this process is to display better the data for their visual analysis, in order that the

features of interest appear more distinctly in the image. This includes processes of contrast

enhancement, spatial enhancement, color composition, vegetation indices and image fusion.

1.4 VISUALIZATION

The visualization of a band consists of the digital-analog conversion of the digital levels stored on
an image for their representation in the graphical monitor.

1.4.1 CONTRAST ENHANCEMENT

Figure 6 compares an original image against one on which techniques have been applied to improve

the visual quality, by enhancing contrast. The data should be better displayed for their visual

analysis, so that features appearing in the image are more noticeable.

1.4.2 SPATIAL ENHANCEMENT

Figure 7 shows the difference between an original band and one to which a spatial enhancement

was applied, through the use of filters (high pass or low pass) in order to soften or enhance the

spatial contrasts present in the DN that comprise it. In other words, the original DN should

transformed, so that they resemble or differ from those in most neighboring pixels. This results in
that the objects being observed, such as the urban areas, roads and rivers, among others, are more

easily distinguished, improving their geometry compared to the original image.

So far, the required unispectral treatments have been performed to obtain a clear image and to allow

distinguishing and identifying the different coverage areas of interest as a pre-step to the
multispectral treatment. This treatment will enable the interaction of the original bands through the

specific combination between them, facilitating the process of interpretation and discrimination of

the elements contained in it.

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FIGURE 3 BAND 2 ORIGINAL – SPOT IMAGE 643349

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FIGURE 4 BAND 3 GEOREFERENCED AND GEOMETRICALLY CORRECTED

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FIGURE 5 WINDOW GEOREFERENCED IMAGE

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FIGURE 6 CONTRAST ENHANCEMENT – SPOT IMAGE 645347

Original Image Enhanced Image

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1.4.3 MULTISPECTRAL ENHANCEMENT

The color compositions are created and displayed on screen, combining the spectral values of the

three bands selected individually. It suffices to apply each of the primary colors (red, green and
blue) to a different band of the image, selected with the criteria and in the order deemed most

appropriate. This process allows for a simultaneous display of images from different regions of the

spectrum, which facilitates visual delineation of some coverage areas. (See Figure 8)

The choice of bands for the composition and the order of the colors for each depend on the sensor

which will be worked and the specific application of the project. The most common color

composition is the so-called false color, which occurs from applying the red, green and blue colors

on the bands corresponding to near infrared, red and green respectively. This composition facilitates
the mapping of plant masses, sheets of water, cities, etc., and it has therefore been used extensively

in visual analysis studies.

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FIGURE 7 SPATIAL ENHANCEMENT – SPOT IMAGE 643349

ORIGINAL ENHANCED

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FIGURE 8 MULTI CHANNEL VISUALIZATION

Multi
channel
products

Color
composition
(additive
synthesis)

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Figures 9, 10 and 11 show three different close-up color compositions, showing illicit coca crops,

pastures, rivers, swamps and forests in different colors. The selection of a suitable color

composition depends on the selection criterion and a combination of bands to differentiate or isolate
the coverage areas to be mapped. This is different in each image, according to the inherent

characteristics of each.

Another alternative for visual discrimination of coverage is the use of vegetation indices and
quotients which, as its name suggests, implies a pixel-by-pixel division between the DN stored in

two or more bands of the same image.

Its use is justified in two situations: i) to im prove discrimination between soils and vegetation, and

ii) to reduce the effect of the relief (slope and orientation) in the spectral characterization of
different coverage areas.

When achieving an optimal color composition is not possible, the process is pursued with an

alternative way to represent color, which serves not its components, but its properties. This occurs
with the hue, saturation and intensity transformat ion recently employed in remote sensing. (See

Figure 12)

The hue originates in the wavelength, where the maximum reflectivity of the object is produced,

equivalent to the color taken in by our eyes. Saturation refers to the purity of said color, and
intensity can be identified with glow in the percentage of reflectivity received. Figure 13 displays

three different images where this technique was applied and clearly shows the discrimination of

illicit crops on the environment.

1.5 LEGEND

Once optimal input has been obtained for classification, it is necessary to define the legend with the
information that the project believes that it can obtain from the satellite images and of course based

on a working scale of the maps. (See Figure 14)

It is crucial to note that spatial remote sensing has limitations, and that it is valid to solve a number
of problems. False expectations can lead to false conclusions therefore achieving the opposite.

676 Annex 33

FIGURE 9 APPROACH TO COLOR COMPOSITION 321 – SPOT IMAGE 643349

Primary
forest

Coca crops

Secondary
forest

Pastures

Urban area

River

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FIGURE 10 APPROACH TO COLOR COMPOSITION RGB 432 – SPOT IMAGE
645336

Pastures

Coca crops

Forests

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FIGURE 11 APPROACH TO COLOR COMPOSITION RGB 437 – LANDSAT IMAGE
9_60

Flooding
areas

Pastures

Coca

Water

bodies

Forests

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FIGURE 12 MULTI CHANNEL VISUALIZATION – IHS TRANSFORMATION

Notion of color

IHS
Transformation
(Intensity,
Hue,
Saturation)

Color
composition

Intensity
Saturation
Hue

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FIGURE 13 IHS TRANSFORMATION SPOT IMAGES 650345, 652345, 651347

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FIGURE 14 LEGEND SIMCI COVERAGE AREAS

CO: Coca in all its states
BP: Primary forest

BS: Secondary forest and high
stubble
PA: Pastures, stubble pastures
and low stubble
SD: Bare soil
CA: Bodies of water

BA: Sand bank
OC: Other crops
NU: Clouds and shades
VI: Roads
ZU: City area
ZI: Flooding areas

AR: Rocky terrain
OT: Other
AF: Sprayed areas

682 Annex 33

This process should display the data better for visual analysis, so that the features of interest present

in the image are more evident; this includes the processes of contrast enhancement, spatial

improvement, color compositions, vegetation index and image fusion.

The work legend is necessary not only in terms of scale but also of complexity of the territory,

which makes it common in mapping land use to employ a particular legend for each study area,

well adapted to local needs.

1.6 ANALYSIS OF SECONDARY INFORMATION

Before starting the process of image classification, it is good to clarify that the classification method

used in the project is supervised classification, which starts from a knowledge of the study area in

its geographical-landscape, cultural and social environment supported on the secondary information
and naturally, the fieldwork. This greater familiarity with the area of study allows the interpreter to

delineate on the image some pilot areas, which are considered sufficiently representative of the

categories that make up the legend. These areas are called, in Anglo-Saxon literature, training

fields. The term indicates that such areas are used to train the computer to recognize the different

categories. In other words, from them, the computer calculates the DN that defines each class, to
then assign the rest of the pixels in the image to one of these categories. This greater familiarity

with the area of study, allows the interpreter to define some pilot areas on the image, which are

considered sufficiently representative of the categories that make up the legend according to their

DN. It is advisable to select several fields by ca tegory, in order to adequately reflect the variability
in the study area.

Figure 15 shows the framework where the different types of secondary information are recorded,

such as fumigation lines supplied by the DIRAN before and after the date of the image.

The fumigation spraying after the date of the image is used for the identification of coca fields by

matching image coordinates and spraying lines, for their overlapping on the image. (See Figure 16)

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FIGURE 15 EVALUATION PHASE OF SECONDARY INFORMATION

ANALISIS AND EVALUATION OF
SECONDARY INFORMATION

FUMIGATIONS PHOTOGRAPHIC CENSUS PLOTS PLANTE
ARCHIVES FIELD
DETECTION OF AREAS ENGINEER
OF ILLICIT CROPS

PRE…….. POST

SATLOC FILES

684 Annex 33

FIGURE 16 FUMIGATION LINES – IDENTIFICATION OF COCA CROPS

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Another important secondary information comes from the DIRAN photographic archives regarding

the areas for detection of illicit crops in the different nuclei or established zones; these photographic

archives comprise images of coca crops previously identified and located with their geographic
coordinates (latitude and longitude) and which are located on the image to identify the spectral

response of the coca crop. (See Figure 17)

Other supporting information at hand refers to the plots of the visual aerial censuses conducted
during 1999 and 2000, which are supplied by the DIRAN with their geographic coordinates related

to each of them; in addition to these information sources, there is also available the experience and

knowledge of the areas where the illicit crops are developed, of a field engineer engaged for over 5

years with reconnaissance of illicit crops.

1.7 INTERPRETATION OF IMAGES

The next stage, following the evaluation of the secondary information, corresponds to the

interpretation of the coverage by two methods: the first is a visual supervised classification oriented

toward the interpretation of coverage areas such as forests, pastures, clouds, bare soil and the

second is visual interpretation of the coverage of coca, and the digitization of water bodies, roads
and urban areas. Both methods are based on the proper relationship between the elements of land

cover and the reflectance values measured or shown in the picture. Within the supervised

classification, there are two stages as follows: the first of these stages is the training and assignment

phase (see Figure 18 and 19), in which a number of pixels is assigned to each of the classes to be
considered, after the interpreter learns about the coverage areas shown and the values indicated in

the image of each of them. These pixels are defined visually in each of the categories or classes to

be evaluated, performing a significant and consistent sampling and in line with all the values

presented in each of the coverage areas.

Upon completion of the selection and study of the categories involved in the classification, the

second stage begins; it is called allocation since it aims to ascribe each of the pixels in the image to

one of the previously selected classes.

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FIGURE 17 PHOTOGRAPH OF A COCA CROP

Coca crop

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FIGURE 18 TRAINING AND ASSIGNMENT PHASE – ILWIS SOFTWARE

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FIGURE 19 TRAINING AND ASSIGNMENT PHASE – PCI SOFTWARE

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This assignment is performed according to the DN for each of the bands involved in the process.

The result of this phase will be a new image; its DN will express the category assigned to each of

the pixels in the original image.

The third stage is the evaluation of results, so called because it involves the criteria, knowledge and

experience of the interpreter to evaluate the results shown by the computer, after the training and

assignment phase. Thus the interpreter evaluates whether the results are correct or incorrect as
shown in the image and it performs the necessary corrections to obtain a higher quality product.

Within these corrections made at this stage is ma inly the resampling of the areas, intensified in the

areas where discrepancies with those in the image are manifested. This process is performed

continuously and as often as necessary to achieve the highest quality product possible according to

the condition of the image. This product is known as the initial classified Map.

The product obtained above undergoes visual editing in order to eliminate confusion or erroneous

coverage therein due to similar spectral response conditions. Given different causes such as

atmospheric conditions, climate and quality of the image, these responses are not subject to
discrimination in the training and allocation phase, which makes visual editing necessary, using the

techniques of on-screen digitizing and pixel by pixel editing. (See Figures 20 and 21)

Once all the corrections necessary are concluded, we obtain the product known as the preliminary

map classified with its respective legend. (See Figure 22)

1.8 BUILDING COVERAGE IN FUMIGATED AREAS

According to the layout in Figure 1, the next step concerns the generation of coverage for the

sprayed areas, which consists of the setting up of fumigation lines prior to the date of the image,

with the aim to qualify the coverage in the fumigated areas according to the vegetative or natural
regeneration state in which they may be. In these cases we find the coverage of bare soils, pastures,

coca and natural secondary forest, to which are assigned the label of fumigated, if one or more

fumigation lines pass over them.

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FIGURE 20 VISUAL INTERPRETATION OF COCA CROPS

Digitized coca plots

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FIGURE 21 VISUAL EDITION BY DIGITIZATION IN AREAS OF SPECTRAL
CONFUSION

FLOODING AREAS CO: Coca in all its vegetation states

B1: Primary forest
PASTURE AREAS B2: Secondary forest and high stubble
ZU: City area
FOREST AREAS CA: Bodies of water
N: Clouds
P: Pastures
V: Roads

I: Flooding

692 Annex 33

FIGURE 22 PRELIMINARY CLASSIFIED MAP – SPOT IMAGE 643349

Coca
crop

Pastures

Forest

River

693Annex 33

For example, if they were sprayed 8 days before the date of taking the image, there will still be the

spectral response of coca and it will be assigned as fumigated; if it was sprayed 6 months before the

date of the image, there will possibly be spectral response of pastures, stubble pastures or low
stubble and even coca if there was replanting according to what occurred later. In this case the

assigned coverage corresponds to fumigated pastures. If sprayed 12 or 18 months, we will find high

bush vegetation that will be considered fumigated secondary forest if there was no replanting.

This way a discriminatory coverage is obtained from the fumigated and non- fumigated areas, as

well as the vegetative state in which they are. (See Figure 23)

1.9 FIELD TESTING

Once the preliminary classified map is obtained with its corresponding coverage areas sprayed, the
product is ready for the Verification of the results by visual aerial inspection of the consistency of

the legend with the spatial units in the field, which is prepared with three options:

• The random selection of points or coverage to be verified (specific areas)

• The manual selection of areas of confusion or conflict (specific Areas)

• A general sweep by meridians or the parallel

For the first two, points or plots are selected which are equipped with coordinates and identified on

the image to transfer them to an analog format (verification sheets on paper). The flight paths are

set out on them according to the closeness of the points. The tables with the points and their

respective coordinates are given to the DIRAN pilots conducting the field verification by
helicopters or Caravan airplanes. (See Figures 24, 25 and 26)

For the third step, the flight route is planned on an analog or digital format, which is aimed at

verifying the largest amount of land and coverage areas, following the lines according to the

parallel or meridians (see Figure 27)

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FIGURE 23 IDENTIFICATION OF SPRAYED COVERAGE AREAS

DATE: JANUARY 1993 FUMIGATIONS CO: Coca in all its vegetation states
DECEMBER 1997 CF: Sprayed coca
B1: Primary forest
B2: Secondary forest
GUAVIARE NUECLUES BSF: Secondary sprayed forest
CA: Bodies of water

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FIGURE 24 FIELD VERIFICATION SCHEME

Quality Control
Field verification

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FIGURE 25 FIELD VERIFICATION POINTS – SPECIFIC AREAS

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FIGURE 26 3D VIEWING – LA GABARRA IMAGE

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FIGURE 27 FIELD VERIFICATION BY SWEEP FOLLOWING MERIDIANS

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During verification the following are evaluated:

− Photo interpretation and assignment of coverage

− Definition of the plot forms

− Identification of new plots that do not appear in the image due to the date of the image

In each plot verified, a corresponding photographic or video record is made and general

observations are made for the area (see Figures 28 and 29)

The photographic record includes not only the plots established for verification, but also the

different areas to get the closest approach possible to the crop culture and behavior in the region

accompanied by voice and visual records of what is found in each point.

These field files and observations in analog format are transferred to digital imaging for
complementation and/or correction in two ways:

• Mapping of points with their corresponding flat and geographic coordinates (Gauss-

Krugger) and identifier (See Figure 30)

• Comparison of analog (field) image coverage or photographs with interpreted image, which
provides the accuracy or inaccuracy in the interpretation (see Figure 31)

The records of verified plots and coverage are taken to “verification tables,” where each point is

assigned its corresponding attribute with regard to verified coverage location, area, and accuracy or
inaccuracy of the coverage previously interpreted. These tables provide an estimate of the quality of

the interpretation process. (See Figure 32)

With the final editing completed by using the same techniques as the preliminary edition, a theme

map of land coverage is obtained for each of the images interpreted.

It is important to bear in mind the possible sources of error or discrepancy between coverage

interpreted and coverage identified in the field, among which are the following:

700 Annex 33

FIGURE 28 AERIAL PHOTOGRAPH FOR EDITION

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FIGURE 29 AERIAL PHOTOGRAPH FOR EDITION

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FIGURE 30 COMPARISON OF COVERAGE AREAS BY LOCATION OF POINTS

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FIGURE 31 VERIFICATION OF COVERAGE AREAS, PHOTO AND SATELLITE
IMAGE

704 Annex 33

FIGURE 32 FIELD VERIFICATION CHART

IMAGE 646350         

DATE OF TAKING:    /FIELD VERIFICATION FEBRUARY 2001   

ORIGIN 2         
           

POINT #  North  East  X  Y  COVERAGE AREA IN M SUCCESS  AREA *VERIFIED COVERAGE
001   0.052   ‐75.650  825330.000  497150.000  Coca in all its states 2800 ‐ 3949200 

002   0.055   ‐75.639  826570.000  497570.000  Pastures, stubble 270800  + 2708800 
003   0.051   ‐75.629  827690.000  497050.000  Pastures, stubble 275200  + 2708800 

004   0.078   ‐75.660  824172.500  500032.500 Coca in all its states 46400  + 3949200 
005   0.075  ‐ 75.659  824357.500  499752.500 Coca in all its states 56800  + 3949200 

006   0.074  ‐ 75.671  822937.500  499647.500 Coca in all its states 30800  + 3949200 
007   0.073  ‐ 75.666  823512.500  499477.500 Coca in all its states 78400  + 3949200 

008   0.071  ‐ 75.661  824092.500  499322.500 Coca in all its states 41200  + 3949200 
009   0.071  ‐ 75.654  824812.500  499277.500 Coca in all its states 33200  + 3949200 

010   0.070  ‐ 75.652  825137.500  499157.500 Coca in all its states 118800  + 3949200 
011   0.074  ‐ 75.650  825347.500  499657.500 Coca in all its states 15200  + 3949200 

012   0.075  ‐ 75.648  825502.500  499747.500 Coca in all its states 19600  + 3949200 
013   0.073  ‐ 75.647  825652.500  499542.500 Coca in all its states 46000  + 3949200 

014   0.075  ‐ 75.643  826117.500  499707.500  Flooding areas  88800  + 88800 
015   0.072  ‐ 75.642  826232.500  499402.500 Coca in all its states 33600  + 3949200 

016   0.072  ‐ 75.636  826902.500  499422.500 Coca in all its states 61200  + 3949200 
017   0.073  ‐ 75.644  825940.000  499530.000 Coca in all its states 57200  + 3949200 

018   0.065  ‐ 75.640  826400.000  498690.000 Coca in all its states 52800  + 3949200 
019   0.059  ‐ 75.630  827500.000  497980.000 Coca in all its states 96800  + 3949200 

020   0.059  ‐ 75.625  828080.000  497970.000 Coca in all its states 47200  + 3949200 
021   0054  ‐ 75.617  828940.000  497400.000 Coca in all its states 56800  + 3949200 

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Structure of the land: Errors related to the structur e of the territory include those confusions arising

from the spatial arrangement in the coverage areas which are objects of study. This may include

aspects such as shape, orientation and above all, the size of parcels; also the spatial contrast
between neighboring coverage areas, the degree of mixing in the different types of coverage areas.

In the case of the Guaviare nucleus, this concept is considered in terms of the more defined form of

the coca fields, size and analysis of the environment coverage in the event of a spectral confusion

between the different theme coverage areas. The effe ct of the parcel morphology is particularly
sensitive in those regions which have undergone colonization of the territory. This originates, quite

often, plots of very small size, even lower than the pixel size, which results in the sensor’s detection

of a radiometric signal averaging between two or more coverage areas, making discrimination

practically impossible, which is known as boundary error.

Level of disaggregation: In most cases, the atte mpt to establish subdivisions in a theme class

involves assignment problems, since the purpose is to discriminate spectrally similar covers. For

example, a study in southern Germany found that the combination of the “low density” urban and

“high density” classes in a regular “urban” class increased the final mapping accuracy in 83%. In
this aspect and in terms of the sensors used, it is not possible to discriminate the different vegetative

states of coca (scraped coca, newly planted coca and coca with high leaf density) and facing the

high dynamics of the crop, the decision was to classify the illicit coca crop with the theme legend of

coca in all its vegetative states, ensuring an optimu m level of reliability in identifying the coca

areas.

Taking of images: Errors related to image taking me ntion problems in the functioning of the sensor

or platform, the atmospheric influence, or to flaws in the image reception and/or recording systems.

Also included here could be the confusion arising from a possible incorrect selection of the image.

When the image has problems of cloud cover, this means that the coverage areas under them will

not be censed, affecting the procurement of figures close to reality. Also when there is high

influence of haze in the scene, the spectral respon se will be affected, which will therefore affect
interpretation.

In the case of images taken during heavy rain, it has occurred that it can generate a mistake because

the spectral response of areas of flooding or waterlogging is similar to the spectral signature of coca

crops, which means more visual editing work in order to correct this error.

706 Annex 33

1.10 FINAL EDITING

The final editing process based on field verificati on is undertaken with the same techniques as the

rough cut to achieve a theme map of land cover for each of the images interpreted.

The final theme map is the input for the obtainment of statistics per image, nucleus, province and

municipality, that is, the quantified information of areas of each of the coverage areas as well as

maps or map products. (See Figures 33 and 34)

The final theme map obtained (see Figures 35 and 36), becomes an input for the GIS, which is the

tool that will allow direct queries to the database such as: what is there in a specific area, how much

is there, what information surrounding it is there, and so on. From the information provided by the

GIS, new theme maps can be produced based on the attributes of the database, such as the range by
areas, estimation of future behaviors regarding the dynamics of change in land use by nucleus,

simulation of environmental effects before they are irreparable, monitoring of potential new areas

of illicit crops, environmental characterization of the illicit crop areas and exchange of information

with other institutions, etc. This way, the project becomes an important source of multidisciplinary
type information generation.

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FIGURE 33 THEME MAP OF LAND COVERAGE

City area

Secondary
Forest

Coca

Pastures

River

Primary
forest

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FIGURE 34 APPROACH TO THEME MAP

Pastures

Secondary
Forest

Coca
crops

River

Primary
forest

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FIGURE 35 PREPARATION OF SPACE MAPS

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FIGURE 36 MAPPING PRODUCTS

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2. METHODOLOGY FOR FIELDWORK

Fieldwork is an essential tool for improving the qua lity of interpretation. It is conducted in two

stages as follows:

First phase: Aerial reconnaissance
Phase Two: Verification of interpretation

The first phase is intended to widen the reference point of the engineer interpreter so that he

recognizes the social, economic and environmental dynamics of the area that is to be interpreted
and that he may assign coverage values, consistent with the geographical space, to the different

spectral responses of the image to be interpreted.

In the second phase, the fieldwork is directed to verify, from the aircraft, that the coverage areas
assigned to certain patterns are correct. Additionally , specific areas where there is doubt about their

interpretation are visited.

The two phases are developed through field visits, but the methodologies of planning and

preparation, as well as assessment, and the product s of each visit differ according to the phase that
is being developed.

2.1 FIRST PHASE: AERIAL RECONNAISSANCE

Aerial reconnaissance is conducted before starting the interpretation of images and its major aim is

to expand the respective interpreter’s reference on the specific area to be interpreted. The

reconnaissance can be done together with the evaluation of the reliability of the above figure, since
there are no specific restrictions on reconnaissance. Indeed, programming of routes is susceptible to

changes, since the main aim rather than visiting specific sectors, is to know the area to interpret.

The methodological process for aerial reconnaissance has three stages:

Selection of areas
Flight Schedule

Evaluation of results

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2.1.1 SELECTION OF AREAS

The field reconnaissance has no special restrictions on the selection of areas, however it is useful to

identify specific sectors covered in the image such as:

Areas of concentration of illicit crops according to the results of the census of the previous year.

This allows the identification of the spectral response of coca in the image to be interpreted.

Areas with economic dynamics of legal activities, such as consolidated agricultural, agro-industrial,
industrial and livestock areas since, in general, th e presence of these areas reduces the existence of

illicit crops.

Colonization fronts where there is high likelihood of implementation of illicit crops.

Areas where the program of eradication by aerial spraying has been developed, in order to observe

how coverage has evolved in these areas

The selection of the reconnaissance areas has as a main tool the census results of the previous year
and the team’s knowledge of the area. It is also convenient to compare the distribution of illicit

crops in accordance with the previous census and to identify areas prone to growth, and areas prone

to reducing the area with illicit crops.

2.1.2 FLIGHT SCHEDULE

Once the reconnaissance areas are identified, they are accompanied by maps, preferably on a

1:100000 scale. If the images are already available, it is ideal to bring plottings of all images in
scenes on a 1:50000 scale; otherwise images from the previous census may be used. The scenes

should include the outline of geographical coordinates at intervals of up to two (2) minutes and

expressed in degrees, minutes and seconds in the WGS84 system, since this is the system within the

managed aircraft.

Two sets of scenes should be plotted, which w ill be used to identify the coverage on each of the

sides of the aircraft. Once the scenes are plotted, rivers and towns are identified to facilitate

referencing, and the scenes are located on the image mosaic.

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The areas surveyed are identified on the images and maps, and the flight lines are traced following

two distributions in particular:

Block sweep considering aspects such as viewing angle, visibility, flight altitude, required intensity,

among others. This sweep is done following the parallels or meridians with the help of the

geographic positioning system of the aircraft and it is recommended for the reconnaissance of coca

areas.

Fly-by guided by the elements in the landscape that serve as reference points. This method is

recommended for the identification of coverage in new colonization sources.

Trips between specific points: it is recommend ed for the reconnaissance of areas with economic
dynamics of legal activities, such as consolidated agricultural, agro-industrial and livestock areas.

A mosaic is then prepared for the commander of the aircraft, which must also include the

corresponding images, scheduled routes, restricted areas for the flyby, the main names of the places
in the area, the towns present and the most outstanding geographical accidents in the terrain.

Likewise, a second plotting is prepared for the field engineer, which should include all information

necessary for navigation by the interpreters, that is, identification of images and scenes into which

they were decomposed for detailed level plots, place names, scheduled flight lines and specific
points of interest.

The plotting and mapping must contain enough information for the interpreter to identify areas of

interest, so it is recommended to include municipal boundaries, rivers and sites.

During the trips at least 10 specific plots of each of the forms of coverage present in the area should

be identified, which will serve to identify the spectral patterns of the forms of coverage.

2.1.3 EVALUATION OF RESULTS

The information obtained in the reconnaissance is marked on the maps and is compared with what
is reflected in the images for the corresponding figure. The 10 plots are identified in the images by

714 Annex 33

coverage form and the spectral signature is evaluated. With these parameters, the interpretation

begins.

2.2 SECOND PHASE: FIELD VERIFICATION

The methodological process for the development of the field verification work includes four stages,
which are described below:

Selection of verification areas

Flight programming

Estimation of verified areas
Evaluation of the results

2.2.1 SELECTION OF VERIFICATION AREAS

The selection of the areas being verified is performed by applying the following criteria:

Visit the areas where interpreters have identified the presence of illicit crops to identify possible
ways of coverage with spectral responses similar to that of coca

Visit areas where there is doubt about the presence of illicit crops according to the respective

interpreters and/or secondary information sources

Visit the areas where illicit crops have been inte rpreted, but the local social, economic and

environmental dynamics raise doubts about their presence

Visit the areas where the excessive presence of clouds renders image interpretation difficult

Visit areas with different spectral responses to coca where coverage has not been able to be

qualified

It is important to remember that at this stage, there is already a partial interpretation of the coverage
areas, therefore the trips are scheduled to specific points.

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2.2.2 FLIGHT SCHEDULE

After defining the areas to be verified, an “assembl y” of all georeferenced images present in the

nucleus is done and the plotting of the respective mosaic takes place.

The areas subject to verification are identified on this plotting and the flight lines are drawn along

two distributions in particular:

Sweeping of blocks considering aspects such as viewing angle, visibility, flight altitude, required
intensity, among others. This sweep is done following the parallels or meridians aided by the

geographic positioning system on the aircraft.

Fly-by guided by the elements of the landscape that serve as reference points

After tracing the flight lines, the images are broken down into more detailed scenes (1:30000 to

1:50000 scales), providing enough overlap to facilitate the transition from plate to plate. Likewise,

the scenes should include the outline of geographical coordinates at intervals of up to two (2)

minutes and expressed in degrees, minutes and seconds. Two sets of scenes should be plotted which
will be used in similar fashion as those in th e reconnaissance process, for the identification of

coverage on each of the sides of the aircraft. Once the scenes are plotted, the rivers, and towns are

identified to facilitate referencing and the scenes are located on the mosaic images.

Later, a mosaic is prepared for the aircraft commander which also include the corresponding
images, scheduled routes, restricted areas for the flyby, the main place names in the area, the towns

present and the most outstanding geographical accidents and which could affect the scheduled flight

altitude and the route with the specific points to visit. A list of the coordinates of specific points to

be covered is also prepared.

Finally, a second plotting is prepared for the field engineer, which should include all information

necessary for navigation by the interpreters, that is , identification of the images and scenes that

were divided for the detailed level plotting, place names, scheduled flight lines and specific points

of interest that must be verified.

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2.2.3 ESTIMATION OF AREAS VERIFIED. PROGRAMMED SAMPLING AND REAL

SAMPLING

The scheduled sampling is determined considering the flight altitude over the terrain and the
permissible angle of view and it expresses the total area intended for verification. However, upon

verification, some factors may affect the schedule (climatic conditions, law enforcement, resource

availability, among others) and cause a reduction in the area finally verified. The final area covered

becomes the actual sampling.

During the field trips, the scenes are marked with the identified forms of coverage, not only in the

specific verification points but also throughout the plane trip to reach them; this means that

coverage is verified provided the fly-by is over an area covered by the images. This is of great

importance since it allows identifying errors in the interpretation and controlling the quality of
interpretation.

Identifying the coverage of coca is done, as possible, by defining specific plots when there is

complete certainty of the plot. Otherwise it is marked as coca areas mixed with pastures, forest or
other cover as appropriate.

It is important to note that, unlike the phase of reconnaissance, field verification does not allow

modification of scheduled routes, and therefore the amount of points or areas covered satisfactorily

in field trips (real sample) must be assessed versus the number of areas or points to be covered as
scheduled (programmed sampling).

The ratio between scheduled sampling and real sampling cannot be less than 70%, and if so, it is

necessary to set up supplementary visits to the area. This decision is made jointly between the
interpreter and the field engineer, considering that although it would be ideal to cover on the field

the total polygons interpreted, the high cost of this procedure mandate a partial sampling.

2.2.4 EVALUATION OF RESULTS

Upon returning from the field trip, the information obtained is contrasted with the preliminary

interpretation that has been developed and a prior control of the quality of interpretation is
conducted. The specific plots whose coverage area was identified in the field are placed on the

717Annex 33

images, and the coverage assigned in the previous interpretation is verified, qualifying a match

between the information interpreted and that verified as a success. Later, the number of correct

interpretations regarding the number of polygons identified in the field is calculated and the quality
of interpretation is controlled.

The field verification work allows timely correction of errors of interpretation. Some spectral

responses tend to get confused and wrongly classified, and only through field verification is it
possible to identify errors of interpretation that would otherwise be systematic and would

significantly decrease the final reliability of the process.

2.3 QUALITY CONTROL OF THE FIELDWORK

Quality control is a concept that should apply to each stage of a project and in the implementation

of each. Mechanisms should be established to ensure that the stage is developing satisfactorily. For
the fieldwork, quality is controlled in the following aspects:

Control of georeferencing: the fieldwork involves 3 georeferencing models, which are the

coordinates of the image, the coordinates of the GPS (navigator) of the aircraft and the actual

coordinates of the terrain. Therefore the differences of the three models are established, so that the
location in the field is as accurate as possible. For this, control points are taken, the coordinates are

derived for each system and the error is known. It is important to note that as a result of this

difference, the location of specific plots should be made in detail and not by coordinates. However,

to have a coordinate system that is very close to reality and to know the possible error will greatly
facilitate the location.

Identification Control: the control of identification is made achieving such flight altitudes to allow a

clear identification of the coverage. As an exercise in interpretation quality control, before starting

the visit of specific points, there is a test to ascer tain that that coverage of one area is identified by
all the participating team, and this information is compared. In case of a difference between the

participants, the area is visited again and the fly-by is lower in order to clarify doubts. This way the

parameters for aerial interpretation are established, which will be replicated in the entire area.

Control of the intensity of fieldwork: Fieldwor k must have an intensity such to allow correcting

possible errors of interpretation to acceptable levels. For this an evaluation is performed of what

718 Annex 33

was scheduled compared to what was done. When the ratio between these two points indicates that

less than 70% of the proposed route was covered, a new field trip is scheduled.

2.4 QUALITY CONTROL OF THE CENSUS

The estimate of the theme accuracy achieved by the census can be prepared using various criteria
which include i) comparing the census with that obtained by other conventional sources, ii)

studying the reliability obtained by classifying th e training areas (this is for the coverage areas

different from coca) and iii) selecting verification areas for which there is actual cover present in

the soil.

2.5 THE QUALITY OF THE INFORMATION

It is not easy to establish the overall measure of quality of information gathered during the process

of identification and measurement of illicit crops in Colombia. However, it is possible to describe it

by identifying the most important sources of error and provide them, if appropriate, with

quantitative measures to express their magnitudes. To find these magnitudes, it is necessary to
know the way the data were collect and the processing methodology.

The quality of information is basically described in terms of sampling and non-sampling errors

committed in the process of obtaining the informatio n. The sampling error is simply defined as the

distortion between the estimated and the true value by the fact of having collected only a part of the
elements of the sample universe. The non-sampling error is generated by physical and material

difficulties that cannot be controlled entirely but may be minimized by improving the processes of

correction and adoption of controls. Therefore the total error is the accumulation of sampling and

non-sampling errors committed during the process of gathering information.

2.6 APPROACH AND ESTIMATION OF THE DEGREE OF RELIABILITY OF THE

INFORMATION

The purpose of data collection techniques is to obtain proven evidence that it is significant to

answer the questions asked in research. The signif icance is explained in terms of validity, accuracy
and reliability.

719Annex 33

The resulting interval between the upper and lower limits where the true value is located is called

the confidence interval with an x% of reliability. If the difference between the boundaries is small,

it means that the information will have a high accuracy with the specified reliability.

In addition to obtaining accurate information, it is important to ensure that the result remains within

this accuracy for any other process undertaken to make the same measurement, that is, that the

amount be consistent with any other measure gathered. This means in practical terms, that if the
same process were repeated many times, the x% of them would have the property that the result

would be within this range of accuracy. This is called the reliability of the information.

QUALITY OF THE RELIABILITY ANALYSIS AND

INFORMATION AND ACCURACY CONSISTENCY OF

VERIFICATION INFORMATION
OF QUALITY TOLERABLE

ERRORS

DISTRIBUTION BY NUCLEI IN THE AREAS OF COCA CROPS

Scheme 1 Distribution by nuclei in the areas of coca crops

720 Annex 33

Quality control is based on the demonstration of the existing vegetation coverage with respect to
vegetation cover interpreted of a statistically valid sample. This allows extrapolation of results

using statistical techniques on the entire census. Whether the coverage interpreted for a given

polygon is correct or not is specifically assessed.

2.6.1 SELECTION OF THE SAMPLE

Quality control was initially conducted for the nuclei with the highest incidence in the total number

of coca crops (Putumayo, Guaviare and South of Bolivar), which possess 87% of the national total,

in order to achieve the greatest representation possible. However, considering that in most cases, the

spatial distribution of the coca polygons is not homogeneous for all the nucleus, it became

necessary to define the images that shape it and within them, enclose in amoebae the areas of coca

in order to not direct the sample to non representative sectors.

Once the sectors with illicit crops were identified, polygons were classified which were interpreted

within the same according to area ranges, and identified considering that the smaller the area of the

polygon, the degree of difficulty of identification is higher, and that the smaller the area, its impact

on the figure is lower. The selected ranges are as follows:

Table l Area ranges used for defining the statistical sample size for the quality control of the 2000
figure

RANGE DEFINITION

1 Polygons between 0.25 ha and 2 ha

2 Polygons between 2 ha and 10 ha

3 Polygons greater than 10 ha

The application of this classification enables the assurance of a statistically reliable sample and

facilitates the analysis of results since the weight of each rank is established on the final result.

The series obtained by applying this classifi cation are analyzed to determine the appropriate

statistical parameters. The frequency distribution curve of the areas of polygons is defined, the

1Plots smaller than 0.25 ha are not considered given that the spatial resolution of the images used do not allow obtaining pure coverage
areas with areas smaller than 0.25 ha

721Annex 33

standard deviation, coefficient of kurtosis, the inte rquartile range and the population mean. Later,

the sample size is defined for a reliability level of the experiment of 95% with a maximum

acceptable error of 5%. With this information the next step is to select the statistical sample to be

qualified.

It is critical to remember that the basic population of the quality control are the coca crops of each

nucleus. Identification of the sample size is made by applying the following formula:

Npq
n =
(N –1) D + pq
Where:

B2
D =
4

N: indicates the size of the population from where the sample will be taken
p: Probability that the estimator is in the experiment zone of acceptance

q: (l-p)

B: Limit for the estimation error

In this case the parameters taken into account were:

p = 0.05
B = 0.05

The statistical model described allows assessment of the success rate for polygons interpreted as

illicit crop. However, it is necessary to consider whether some polygon was not interpreted as an

illicit crop when in reality it was; for this reason, 50% of the sample was established directly over
the control tools and not over the image interpreted, seeking the polygons that were coca but had

not been interpreted as such. The remaining 50% was established in the opposite way, that is,

selecting the polygons interpreted as coca on the satellite images and verifying if the interpretation

was consistent with reality; in this way polygons interpreted as coca when in fact they are not can

be identified.

2.6.2 QUALIFICATION OF THE STATISTICAL SAMPLE

Qualification as an error or a success of a given polygon represents a particular degree of difficulty
due to the dynamics of the crop. Indeed during the course of time between taking the image and the

assessment by quality control, it is very likely that new coca crops have ben established and that

722 Annex 33

these have developed enough to reach considerable heights in just four months. Conversely, the

“disappearance” or “abandonment” of coca crops, except when there is fumigation, is highly

unlikely.

Assessment of the quality of interpretation shou ld consider this aspect. The issue of temporality

inherent in the process is partially solved by establishing a decision matrix, which serves as a guide,

to qualify as a mistake or a success a specific polygon within the sample.

For quality control three tools were used:

Aerial photographs of detailed scales (greater than 1:11000)

High-resolution images (multispectral high-resolution photos and IKONOS images)

Field visits

These tools enable the extreme accuracy of identification and spatialization of coca crops, which are

considered viable tools for quality control. As an additional tool, SATLOC records for the

eradication program by aerial spraying are used; if a plot identified as coca is covered by
fumigation lines after the date of the image, it is seen as proof that the plot was interpreted

correctly. Thus spraying ensures that a plot of the sample which appears covered with spray lines

after the date of the image is actually coca. However, it cannot be assured that a plot interpreted as

coca but not covered by lines of fumigation, is not so, since spraying does not have 100% reliability

and it does not cover 100% of the plots. This means that the plots not covered by lines of
fumigation must be verified with some of the control tools.

Aerial photographs:

There are 38 rolls, with an average of 263 pictures each, which cover four nuclei in the sites with
the highest concentration of illicit crops. The photographs show detailed scales and enough

overlapping to ensure easy identification of details and geographical accidents. The following table

summarizes the general characteristics of aerial photographs available.

Table 2 Aerial photographs available per nucleus
NUCLEUS Total rolls

Putumayo Caquetá 11
Guaviare - Meta-Vichada 8
Gabarra 2
South Bolivar 17
High-resolution images:

723Annex 33

There is a mosaic of high-resolution multispectral images, which covers approximately the

southwest of the Putumayo nucleus. The images were taken in 1999. These images have a spectral

resolution of 3 bands and a spatial resolution of 4 meters, allowing the identification of coca
accurately.

Likewise there is an IKONOS image with a 4 m spat ial resolution and a 4-band spectral resolution.

This image covers an area of the center of the nucleus Putumayo - Caqueta.

Field visits:

The points not covered by any of the tools above should be verified directly in the field. For this the

coordinates of the polygons are established to be verified and the lines of flight are traced so the

plane does not pass directly over the point as this would impede visibility and enough time for an
objective qualification. Likewise, the points near rivers and roads, easily identifiable on the ground

must be preferred for field verification. Field visits should be limited to the points that are definitely

not possible to qualify with the tools available.

2.6.3 ESTIMATION OF RESULTS

To determine the reliability of the figure in each of the selected nucleus, the percentage of correct
answers over all the polygons of the statistical sample assessed should be identified.

Two main results are established: first, the reliability regarding the number of existing coca

polygons, that is, how many of each of the 100 existing polygons were interpreted accurately.
Secondly, the reliability regarding the area, considering the area ranges of the polygons interpreted,

that is, out of every 100 hectares, how many were interpreted accurately.

To estimate the area correctly, the ratio of the successful areas of polygons compared to the sum of

the areas of the polygons selected in the sample of each nucleus was considered.

Finally, the results from each nucleus are weighted and applied to the national total for the

reliability of the national figure.

3 FINAL RESULTS

724 Annex 33

The project has enabled the creation of a geographic framework where illicit crops have been

developing in Colombia. This framework consists of 8 nuclei which group domestic production of
coca leaf. The images used for the evaluation of the mentioned nuclei are listed on the

GEOGRAPHIC COVERAGE OF SATELLITE IMAGES OF THE YEAR 2000 map.

The geographic framework was defined initially with the areas identified by DIRAN as illicit crop
areas in the visual census of March 1999. These areas were clustered in nuclei. The 1999 census

results are shown in Table FINAL RESULTS BY NUCLEUS - AREAS COVERED WITH COCA

CROPS IN 1999.

It is important to note that in the 1999 figure, the area corresponding to the demilitarized zone for
peace talks was excluded from the nuclei of Putumayo-Caqueta and Meta-Guaviare-Vaupés. The

2000 figure, however, includes the demilitarized zone in the respective nuclei.

The interpreted illicit crops are clustered in clearl y differentiated nuclei, as presented in the map of
LOCATION OF AREAS WITH COCA CROPS YEAR 2000. The spatialization of these areas is an

essential tool that serves as a starting point to address the drug problem in Colombia.

Importantly, the annual development of the illicit crop censuses allows identifying the dynamics of

their growth; in this way there are valid criteria to direct efforts and assess the results of the
different strategies of eradication and control. TheLOCATION OF AREAS OF COCA CROPS

YEAR 1999 map shows the location of illicit crops in the corresponding year. Contrasting this

information, the permanence of the nuclei identified can be observed.

725Annex 33

GEOGRAPHIC COVERAGE OF SATELLITE IMAGES
SIMCI PROJECT
YEAR 2000

726 Annex 33

GEOGRAPHIC COVERAGE OF SATELLITE IMAGES
SIMCI PROJECT
YEAR 1999

727Annex 33

LOCATION OF AREAS WITH ILLICIT COCA CROPS
SIMCI PROJECT
YEAR 2000

728 Annex 33

LOCATION OF AREAS WITH ILLICIT COCA CROPS
SIMCI PROJECT
YEAR 1999

729Annex 33

FINAL RESULTS BY NUCLEUS
AREAS WITH COCA CROPS IN AUGUST 2000

Nucleus Total nucleus % Total Coca area in % Coca area % Number of
in ha Nation nucleus in ha plots smaller Nucleus in plots Nucle municipalit
(adjusted) al (interpreted) than 3 ha larger us ies affected
than 3 ha

Putumayo Caquetá 96,694 59.2 88,712 31,538 35.6 57,174 64.4 27
Meta Guaviare 34,878 21.4 34,945 18,086 51.8 16,859 48.2 24
Vaupés
South Bolívar 11,959 7.3 11,883 6,894 58.0 4,989 42.0 49

Antioquia Córdoba
Cauca Nariño 10,906 6.7 7,545 3,64633.53,86969.5 21
La Gabarra 6,103 3.7 6,103 4,63175.91,42742.1 15
Arauca 1,234 0.8 1,234 598 48.4 636 51.6 5

Boyacá Santander 743 0.4 743 48665.4245.67 31
Sierra Nevada de 522 0.3 522 38794.5153.53 5
Santa Marta
Chocó 250 0.2 --- -- -- -- -- 2

TOTALES 163,289 100 151,687 66,268 43.7 85,419 56.3 183

NOTES:

1. Adjustments to For cloudiness 10,254 ha 2. The adjustments did not take into
interpretation For seniority 2054 ha account the number of plots and their

For fumigation 956 ha percentages
Aerial census Chocó 250 ha

TOTAL 11,602 ha

730 Annex 33

FINAL RESULTS BY NUCLEUS

AREAS WITH COCA CROPS IN AUGUST 2000

Nucleus Total % Number of % Number of % Number of

nucleus Nation plots smaller Nucleus plots larger Nucleu municipalities
al than 3 ha than 3 ha s affected
Putumayo Caquetá 33,658 46.0 26,501 78.7 7,157 21.2 27
Meta Guaviare Vaupés 20,024 27.3 17,205 85.9 2,819 14.4 24

South Bolívar Antioquia 7,090 9.7 6,163 86.0 927 13.4 49
Córdoba
Cauca Nariño 5,714 7.8 5,122 89.6 592 10.4 21
La Gabarra 5,261 7.2 4,952 94.1 309 5.9 15

Arauca 512 0.7 375 73.2 137 26.8 5
Boyacá Santander 467 0.6 415 88.9 52 11.1 31
Sierra Nevada de Santa 482 0.7 452 93.8 30 6.2 5

Marta
Chocó -- -- -- -- -- -- 2
TOTALES 73,208 100 61,185 83.6 12,023 16.4 183

NOTE: The adjustments do not take into account in the number of plots

731Annex 33

FINAL RESULTS BY NUCLEUS

AREAS WITH COCA CROPS IN MARCH 1999

Nucleus Total nucleus % Number of % Number of % Number of

Nation plots smaller Nucleus plots larger Nucleu municipalities
al than 3 ha than 3 ha s affected
Putumayo Caquetá 47,865 57 41,324 86 6,541 14 25
Meta Guaviare 12,297 16 9,515 77 2,782 23 10

Vaupés
South Bolívar 4,411 5 3,209 73 1,202 27 26
Antioquia Córdoba
Cauca Nariño 8,801 13 8,361 95 440 5 15

La Gabarra 7,240 9 6,103 84 1,137 16 10
Arauca -- -- -- -- -- -- --
Boyacá Santander -- -- -- -- -- -- --

Sierra Nevada de 291 -- 243 84 48 16 4
Santa Marta
Chocó -- -- -- -- -- -- --
TOTALES 80,905 100 68,755 85 12,150 15 90

732 Annex 33

The project has developed a methodology for estimating the reliability of the reported figure, which

yielded reliability approaching 85% for the 1999 figure and above 90% for 2000

3.1 GIS APPLICATIONS

The Geographic Information System provides a consistent storage of spatial information that can be
updated or manipulated. This way, it is possible to access mapping models, from the transformation

or combination of different variables: signal buffers within a certain distance from rivers, roads,

schools, city centers; make tables of matches between maps, calculate slopes, analyze two or more

layers of information etc. Also, the GIS allows being used as simulation models for studying the
environmental processes or analysis of impacts of decisions in planning,

The Geographic Information System provides valuable information for different applications from

different disciplinary fields; the first results that can be obtained with the interpretation of satellite
images are the statistics by image, which give information on coverage area of the different kinds

interpreted. (See Figure 37)

The second results obtained from the structure of the GIS is the identification of each plot and

different coverage, with their corresponding attribut es. These are based on the needs of the project
and its users and once structured in the GIS they can be spatialized and represented in mapping

products and become input for studies, analysis, and multiplying trends. This way, information can

be obtained, for example, from the number of plots that are in a certain municipality as well as their

specific location, one by one. (See Figure 38)

Among the advantages of having a GIS is to have the information quickly and updated of the area

or point of interest since the system provides simultaneously all its attached information and that

has previously been uploaded to the database. (See Figure 39) The reference figure provides

information on said plot regarding their Gauss plane coordinates, identifier, coverage area, whether
or not it has been fumigated and the category to which it corresponds according to ranges

established by the DNE.

733Annex 33

FIGURE 37 STATISTICAL PRODUCTS OF AN IMAGE – BASIC GIS INPUT

734 Annex 33

FIGURE 38 STATISTICAL PRODUCTS GENERATED BY THE DATABASE

735Annex 33

FIGURE 39 GIS QUERY

736 Annex 33

Likewise, socio-economic information can be added. This is just one example of the versatility and

importance of information generated and the supplementary characteristic of the areas where illicit

crops are developed and that may allow rapid access and reliable information base for management
and decision-making.

3.1.1 CATEGORIZATION

Figures 40 and 41 show another application of the GIS, with information of illicit crops, referring to

the categorization of coca cultivation by areas in accordance with the parameters established by the

DNE, where clearly differentiated are the coca plots below 3 or 2 hectares, those that are in the 3-10
hectare range and so on for all ranges. This theme map is derived from information provided by the

attributes for each plot in the database; this information, coupled with socioeconomic information,

allows among other things, analyzing the environment and estimating the behavior of the areas.

3.1.2 NEIGHBORHOOD ANALYSIS (BUFFERS)

Figure 42 shows a section of the Guamuez River, which was selected as the axis, starting from
which buffers and corridors were generated at specific distances, using the neighborhood and

connectivity features characteristic of GIS and the elements that comprise it. This information is

very important because under existing rules regarding the eradication of illicit crops, they must

meet certain parameters, including special handling to those plots that are at distances less than 100

meters from bodies of water. Therefore and complementing with the categorization of crops, the
location of plots that meet the parameters required for eradication and alternative treatment in any

form can be pinpointed. (See Figures 43 and 44)

This analysis of the information also provides vital statistics for the knowledge of the area where,
among many other things, the number of plots and the corresponding area that meets specific

parameters can be specified (See Figure 45) including t he list, if it applies, of each one of the plots

required by the query, with the corresponding identifier and assigned attributes (History).

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FIGURE 40 GIS QUERY – RANGE OF MEDIUM DENSITY AREAS IN COCA CROPS

Coca crops smaller than 3 ha
Coca crops between 3-10 ha
Coca crops between 10-30 ha

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FIGURE 41 GIS QUERY – RANGE OF HIGH DENSITY AREAS IN COCA CROPS

Coca crops smaller than 3 ha Coca crops between 30-50 ha
Coca crops between 3-10 ha Coca crops between 50-100 ha
Coca crops between 10-30 ha Coca crops larger than 100 ha

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FIGURE 42 BUFFER TO VARYING DISTANCES OF GUAMUEZ RIVER –
NEIGHBORHOOD SURVEY

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FIGURE 43 COCA CROPS CATEGORIZED BY DISTANCE TO WATER BODIES

CA: Bodies of water
ZU: City area
Crops located less than 100 m from water sources
Crops located between 100 m and 1,000 m from water sources
Crops located at distances greater than 1,000 m from water sources

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FIGURE 44 COCA PLOTS AT VARIABLE DISTANCES FROM WATER BODIES

CA: Bodies of water
ZU: City area
Crops located less than 100 m from water sources
Crops located between 100 m and 1,000 m from water sources
Crops located at distances greater than 1,000 m from water sources

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FIGURE 45 STATISTICS BY BUFFER STUDIED – GUAMUEZ RIVER – PUTUMAYO
NUCLEUS

Categories No. Plots Perimeter Area
Crops located less than 100 m from water sources
Crops located between 100 m and 1,000 m from water sources

Crops located at distances greater than 1,000 m from water sources

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3.1.3 PLANTE PROJECTS

At the moment a Pilot project for the municipality of Puerto Asis is being developed, with the aim

to design and implement a georeferenced base oriented to geographically integrate the information

currently owned by Plante with additional information but vital for the efficiency of the
management in areas with problems with illicit crops. This additional information mainly originates

in the SIMCI Project results related to the generation of coverage maps and land use, as well as and

basic mapping information.

Specific project objectives are:

- Delineation of areas of eradication agreements signed (see Figure 46)

- Generation of geographic information consisting of attributes of the agreements and

projects (See Figure 47)
- Delineation of buffer areas for productive projects (Figures 48 and 49)

- Delineation of plots of illicit crops under 3 or 2 hectares

- Generation of a map of land conflict

- Monitoring the use of areas of agreements and projects with the frequency supports by the

SIMCI Project
- Determination of potential areas for alternative development and its possible uses

The project will be extended to other municipalities where PLANTE develops its activities since it

will provide important information for actions carried out on project viability and its consequent
monitoring and follow up of compliance with voluntary eradication agreements.

3.1.4 MULTI-TEMPORAL ANALYSIS

The frequency with which the Project generates information allows access to multi-temporal

analysis, providing information about changes in land use, trends, not only in the aspect of

quantification of hectares but its geographic comp onent. Multi-temporal analyses constitute basic

input for monitoring since it provides access to information on the area studied in certain historical
periods with which a history of the area is created, or individual crops that allow analysis of trends

and dynamics.

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FIGURE 46 VIEWING OF PLANTE - DEM PRODUCTIVE PROJECTS PUERTO ASIS
MUNICIPALITY

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FIGURE 47 PLANTE PROJECTS COORDINATES

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FIGURE 48 LOCATION PLANTE AGREEMENTS FOR VOLUNTARY
ERADICATION

City center
2 km area on both sides of the road
Agreement areas
Area of projects developing with damping area
Indigenous group processes to be strengthened or implemented

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FIGURE 49 DAMPING AREA FOR PLANTE PRODUCTIVE PROJECTS

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3.1.5 CHARACTERIZATION

One of the important contributions of the SIMCI pr oject for handling the problem of illicit crops in

the country is the characterizing of the environment in which they develop. Indeed, the

identification of specific sectors of illicit crops and surrounding forms of coverage are an essential
input to identify the social, economic and environ mental dynamics of the areas with illicit crops.

Issues such as land coverage, use, successional dynamics of forested areas, etc., are developed as

sub products of great importance to land planning.

The tools available to the project also allow integration of the information produced by different

entities at the national level (see Figure 50), with information produced by the project and this way

additional information can be procured on areas of interest. Among many possible aspects the

following is worth noting:

Ecosystems that are being affected by the development of illicit crops (See Figures 51 and 52)

Environmental offer of the areas where illicit crops are developing

Human settlements and population dynamics

Legitimate economic activities developed in an area with illicit crops
Alternative projects developed in the area

Areas with environmental or legal restrictions threatened by the presence of illicit crops

From this type of information, the surroundings of illicit crops can be environmentally
characterized.

The information generated by the project is updated annually enabling the evaluation of the

dynamics of each region through vital multi temporal analysis.

It is important to note that the proper characteristics of the activity have made it develop in marginal

areas with modest development, where very poor levels of information were the norm.

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FIGURE 50 SUPPLEMENTARY INFORMATION TO ACHIEVE NEW THEME MAPS

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FIGURE 51 ECOSYSTEMS AFFECTED BY ILLICIT CROPS

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FIGURE 52 TABLE - ECOSYSTEMS AFFECTED BY ILLICIT CROPS

752 Annex 33

The SIMCI project has provided for updating the information in these areas and improving the

knowledge thereof, creating theme mapping at a semi-detailed level.

Obtaining this information allows learning about the environment in which illicit crops are

developed and providing coherence in policies and strategies to combat this problem.

3.1.6. INTERNATIONAL VISION OF THE PROJECT

The problem of illicit crops brings the internat ional community together, as seen in the past

TECHNICAL COMMITTEE FOR ALTERNATIVE DEVELOPMENT OF THE ANDEAN
COUNTRIES, where each of the participating countr ies presented the current situation in each

country, showing the objectives achieved in accordance with the scope of the projects and programs

in areas with problems of illicit crops. In tis seminar Colombia was represented by the SIMCI

Project, and it showed the Group its progress in the development and methodological
implementation for the detection and monitoring of illicit crops and their environment, as well as

the applicability of this information for the formulation and feasibility of alternative development

plans. Thus, Colombia is a pioneer in Latin America in the formulation and development of a

methodology in accordance with the requirements and characteristics of the region; the

advancement in methodology and results shown by the project became an example to follow by the
other countries, tailoring the methodology develo ped to their interests and characteristics.

Representatives of the different countries re quested at the panel the technical training and

technology transfer from Colombia to their respective countries. This ended in the unanimous

appointment of Colombia as Coordinator for the group in the development of a Regional
Geographic Information System to strengthen Alternative Development.

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GLOSSARY

SPECTRAL BAND: This term refers to a selection of wavelengths with similar electromagnetic

behavior.

DATA BASE: Collection of data that can receive, store and provide data to several parties

DIGITAL CLASSIFICATION : The process whereby a pixel or pixels in a finite amount of

multispectral image is assigned to one of the categories of the legend, usually based on similarities

between the numerical values that define it.

COLOR COMPOSITIONS: They are created by combining the spectral values of three individual

bands. Each band is disassembled using one of the three primary colors.

FALSE COLOR COMPOSITION: Red is assigned to the infrared band; green goes to the band

of visible red; and blue to the green visible band.

COMPOSITION IN TRUE COLOR : Red is assigned to the visible red band; green goes to the

band of visible green; and blue to the blue visible band.

LAND COORDINATES : Set of conventional magnitudes established to determine the exact

position of a point on the surface of the earth

ELECTROMAGNETIC SPECTRUM : It is the clustering of electromagnetic radiation in

different bands, depending on the wavelength or frequency, which have a similar spectral behavior.

VISIBLE SPECTRUM: (0.4 to 0.7 μm) This is the only electromagnetic radiation that our eyes
can perceive.

LINEAR EXPANSION: It is the simplest contrast enhancement. A low value of the digital level of

the original histogram is assigned to black and a high value is assigned to white. Intermediate

values are distributed linearly.

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HISTOGRAM EQUALIZATION: A non-linear expansion. The digital levels are redistributed

based on their frequency. Different shades of gray are assigned to digital levels that occur with
greater frequency in the histogram.

FILTER: This is an enhancement operation, used to improve image display.

BSQ FORMAT: Type of storage of image data in sequential bands

BIL FORMAT: Form of storing image data in bands interleaved by line

IMAGE FUSION: The process of combining digital images. If the values of the data are modified,
the result is a new set of data.

HISTOGRAM: The graphical representation of the frequencies observed in a given image.

IMAGE: Any form of pictorial representation of the data not obtained by photographic means

VEGETATION INDEX: This is the result of an operation between image bands used to obtain a

better discrimination between soils and vegetation.

LANDSAT: A series of satellites built by NASA specifically dedicated to the remote detection of

natural resources

LATITUDE: Distance in degrees, minutes and seconds of a degree, between any point and the
parallel 0°. Measured from 0° to 90° and may be N or S.

LENGTH: Distance in degrees, minutes and seconds of a degree from any point of the prime

meridian. It is measured from 0° to 180° and may be E or W.

WAVELENGTH: Separation distance of 2 identical states of the wave at a given time

CONTRAST ENHANCEMENT: Also called global improvement, it transforms the raw image

data using statistics calculated from this.

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SPATIAL IMPROVEMENT: These are procedures that modify a pixel value in an image based

on pixel values of their closest neighbors.

DIGITAL LEVEL: Whole value which numerically translates radiometric intensity received by an

electro-optical sensor

VISUAL LEVEL: Corresponds to the intensity of color with which a pixel is displayed on the

monitor

PIXEL: The smallest pictorial element of the images that is capable of being processed

PRODUCT COMPATIBILITY : The product of 2 ERS, SAR images taken in identical

conditions, which made by interferometry techniques, give a new layer of information.

CONTROL POINTS: These are geographic elements that can be located precisely on an image
and on a map to be used in mapping correction of the image.

RADAR: active microwave system that emits energy beam on the surface and then collects its

reflection on it. The same antenna emits the radar pulse and receives the response of the land. In the

range of wavelengths characteristic of radar there is virtually no water absorption band, which
allegedly makes this system suitable for studying the tropics.

RADIANCE: Total energy radiated per unit of area and per solid angle of measurement.

IMAGE ENHANCEMENT: Digital processes that aim to improve the visual quality of the image

by increasing the internal contrast or the creation of new bands that illustrate better about the

original features.

REFLECTIVITY: Percentage of incident radiation that is reflected by a two-dimensional surface.

RESOLUTION: The resolution is a measure of the ability of a system sensor to discriminate

information within the image.

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SPATIAL RESOLUTION: The system’s ability to distinguish the smallest possible object in an

image. This will define the size of the pixel.

SPECTRAL RESOLUTION : The sensor’s ability to discriminate the radiance detected in

different wavelengths of the electromagnetic spectrum. Only the radiance extended to a certain

range of wavelengths called a band can be measured.

The spectral resolution is determined by the number of bands that the sensor can capture.

RADIOMETRIC RESOLUTION : The sensor’s ability to discriminate levels or intensities of

spectral radiance. In the optical-electronic systems, the radiance is assigned to each pixel as a value

number proportionate to the amount of electromagnetic energy received.

TEMPORARY RESOLUTION: This refers to the time at which a sensor obtains an image of a

particular area.

SAT-LOC: spatial positioning system supported on satellite records of the lines of fumigation

SENSOR: Any instrument that detects electromagnetic energy, converts it into a signal and

presents it in a form capable of being used in a studio.

SPECTRAL SIGNATURE: a peculiar way of reflecting or radiating a certain object. Since each
material has different absorption bands according to their chemical composition and certain

properties of its surface, the reflected solar energy will be complementary to the incident plus the

one virtually emitted by the surface itself.

GEOGRAPHIC INFORMATION SYSTEMS: A set of programs that allow storing, retrieving,

modifying and combining any type of georeferenced variables

REMOTE SENSING: The technique to procure information on an object, area or phenomenon
through the analysis of data acquired by an instrument that is not in contact with the object, area or

phenomenon under investigation

TEXTURE: visual interpretation criteria resulting from the ratio between the size of objects and

the sensor resolution

TONE: visual interpretation criterion resulting from the amount of energy received in a spectral

band

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Probability. The value calculated on the number of times that a given loss may
arise in a given period of time.

Basic response. The action of initial response to a loss, using means normally
available in the system, and developed without changing the initial structure of its
functioning.

Rescue. Actions undertaken by trained groups external to the loss area, to remove
a threatened person, who has not been able to leave by his own means in the
process of evacuation

Loss. Undesirable incident or event which has not been programmed, and which
may generate negative consequences on the system

Victim. Person who has suffered damage to physical damage or damage to his

health as a consequence of a loss.

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