Released by the Bureau for International Narcotics and Law Enforcement Affairs
Home page for project: http://www.state.gov/g/inl/rls/rpt/aeicc
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Memorandum of Justification Concerning
Determination on Health,
Environmental, and
Legal Aspects of Coca Eradication in Colombia
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The Kenneth M. Ludden Foreign Operations, Export Financing and Related Programs Appropriations Act, 2002 (P.L. 107-115) ("FOAA") lays out conditions under which assistance using funds appropriated under the FOAA may be made available for the purchase of chemicals for the aerial eradication of coca in Colombia. The legislation’s requirements and the Administration’s summarized responses are below.
Tab 1 of the report illustrates that the glyphosate formulation used to spray coca in Colombia is used in accordance with the EPA label instructions for non-agricultural use. In Tab 4 of the report, a letter from EPA Assistant Administrator Johnson EPA confirms that application rates are within the parameters listed on U.S. glyphosate labels.
Tab 6 of the report includes a letter from the Ministry of Foreign Affairs of the Government of Colombia confirming that the spraying is being carried out in accordance with each and every applicable Colombian law.
USDA’S assessment (Tab 5) opines that the spray program poses no unreasonable health or environmental risks. Upon examining the chemicals that used in Colombia, EPA notes the potential for acute eye toxicity, due to an inert ingredient in the particular glyphosate formulation used by the program. EPA’s response points out that the Department did not provide to the EPA the results of INL-commissioned toxicological tests performed on the spray mixture, as promised in a briefing (note: these tests had not been completed at the time EPA submitted its response). EPA replies that because of its inability to review such tests, it is unable to evaluate the toxicity of the spray mixture that we are using in Colombia. In the absence of these testing results, EPA recommended that the Department consider using an alternative glyphosate product with lower potential for acute toxicity.
Until a lower toxicity glyphosate formulation could be made available for use in Colombia, we have continued to spray with the higher toxicity glyphosate product. According to the EPA report, the risks of eye damage from the current formulation are limited principally to the handlers and mixers of the concentrated formulation as opposed to the general public. The concentrated glyphosate formulation is diluted when mixed with water for use in the spray program; approximately 75 percent of the end use product is water. Furthermore, several safeguards are in place to minimize human exposure to the spray mixture. Pilots are carefully selected and trained and are instructed to avoid spraying near people, homes, or occupied buildings. The permissible spray parameters of flight speed, aircraft height, and wind conditions are rigidly monitored and complied with. The Embassy is working with the GOC to warn local citizens in areas where we spray (through radio and newspaper advisory messages) to avoid the spray mist and inform them of precautions to take in case of possible incidental contact with the spray mixture.
The Department now has the results of the eye irritation test of the spray mixture that would have bolstered EPA’s analysis, but we did not receive these results in final form until after receipt of EPA’s response. This test determined that the spray mixture currently used in Colombia would be rated Category III on EPA’s scale of I-IV, with I being the most toxic. Congress is aware that this testing is underway and as we have notified in the addendum to the report, we will provide the testing results as soon as all of the testing is completed.
In addition, INL now has an alternative glyphosate product with lower potential for acute toxicity available for use in Colombia. This formulation, registered in July 2002, is less toxic to the eyes because it uses a different inert ingredient and is also known to have as low or lower toxicity ratings in all other categories, as well. Although this alternative formulation has only recently been approved in Colombia, it has been extensively tested and widely used elsewhere, and is registered for non-agricultural use in the U.S. by the EPA. Because this alternative formulation addresses EPA’s recommendation that the Department switch to a less toxic formulation, the Department plans to switch to it for use in Colombia as soon as it can be manufactured, purchased, and delivered. INL expects to place an order for the new product early in September 2002. The Department’s notification to Congress will indicate our intention to make this switch, in response to EPA’s concerns.
Based on the above information, we do not believe that EPA’s reservation about the risk of eye irritation rises to the threshold of "unreasonable risks" or "adverse effects" to humans or the environment identified in the statute.
Tab 7 of the report outlines the procedures to evaluate claims of damage to legal crops from aerial eradication and to provide fair compensation for meritorious claims. This includes an English language version of the Colombian National Drug Council’s Resolution 0017, which formalized the new process. Complaints are being received, logged, investigated, verified, and compensation is being allocated to cases with merit. Thus far only two complaints have been deemed valid; compensation in these cases is pending and will be determined through negotiation with the claimant.
Tab 8 of the report illustrates that alternative development programs are being carried out in all but one of the departments where we have sprayed in 2002. In this one department where a small amount of spraying took place in February 2002, an alternative development program agreement has been negotiated and a contract for the work signed. The GOC has agreed that no further spraying will take place in that department until an alternative development program is actually being implemented.
Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia -Report Home Page Released by the Bureau for International Narcotics and Law Enforcement Affairs September 2002
Chemicals Used for the Aerial Eradication of Illicit Coca in Colombia and Conditions of Application
Figure 1. Coca Spray Mixture
The aerial spray mixture currently used in the U.S.-supported program of aerial eradication of coca in Colombia contains three components: water, an EPA-registered formulation of the herbicide glyphosate, and a surfactant (Cosmo-Flux 411F). These components are mixed together into a spray mixture in the following percentages: 55 percent water, 44 percent glyphosate formulation, and 1 percent Cosmo-Flux 411F (see Figure 1 below). This diluted mixture is applied to coca at the rate of 2.53 gallons per acre. This application rate is within the glyphosate manufacturer's recommendations for both the amount of concentrated formulation per acre and the amount of total spray volume per acre for woody plants and hard-to-control species. Coca is a hardy, woody bush that falls into this category.
Commercial glyphosate formulation:
The commercial glyphosate formulation used in the spray mixture is registered with the U.S. Environmental Protection Agency (EPA) for sale in the United States for non-agricultural use and contains 41 percent glyphosate salt and 59 percent inert ingredients. Approximately three fourths of the inert ingredient content are water and the remainder is a surfactant blend. A surfactant is essentially a soap that enhances the ability of the herbicide to penetrate the waxy cuticle of the leaf surface. Surfactants are commonly used with herbicide formulations to improve the effectiveness of the product. This commercial glyphosate formulation used against coca is registered, produced, and sold in Colombia, where the State Department’s Bureau of International Narcotics and Law Enforcement Affairs (INL) purchases it for the Government of Colombia (GOC) for use in the GOC’s spray program. Further information on the chemical composition of this commercial formulation is proprietary and is retained by the manufacturer; it is not publicly available and the manufacturer has not provided it to the Department. Figure 2 is a breakdown of the commercial glyphosate formulation by major components.
Surfactant:
From the standpoint of coca control, properly selected surfactants make the glyphosate far more effective than if the active ingredient were applied alone. Research by the United States Department of Agriculture’s Agricultural Research Service (USDA-ARS) has demonstrated that certain surfactants enhance glyphosate penetration through the waxy cuticle on the coca leaf surface. Appropriate surfactants decrease the surface tension of the adhering spray droplet (causing them to spread further on the leaf surface). Generally, this is good, since the herbicide is less susceptible to runoff loss and greater surface coverage leads to more uptake of the herbicide. The "right" surfactant may form a chemical shield around small clusters (micelles) of the herbicide and enhance their penetration through the cuticle and into the leaf tissue.
Figure 2. Commercial Glyphosate Formulation
In order to function, glyphosate must move from the site of application (the leaf surface) toward the actively growing meristematic tissue - the new shoot tips and the new roots. Here, the herbicide glyphosate finally does its job, blocking an enzyme that is essential for plant growth but absent from humans. Surfactants are a critical component of the herbicide mixture, allowing the glyphosate to reach this actively growing tissue in the coca plant. They may also stabilize the product droplets, reducing water evaporation, and thereby reducing spray drift.
The commercial glyphosate formulation used in the spray program contains 180g/l of surfactant as part of its inert ingredients. As noted above, USDA-ARS research in the greenhouse and in the field (in Colombia, Panama, and Hawaii) showed that commercial glyphosate formulations with surfactants performed better against coca than other glyphosate without surfactants. Nevertheless, when coca ground-truth verification (see "Eradication Oversight" section below) was first done in October 1997, ratings showed mean control of coca within aircraft spray swaths to be about 70%. This was considered unacceptably low, since the goal was to eliminate the illicit crop and force the growers to abandon further coca production. To improve swath control, USDA-ARS scientists recommended two options, not mutually exclusive. One was to increase the level of glyphosate formulation in the spray mixture. The second was to add an additional surfactant to boost control without necessarily requiring a higher dose of herbicide. Previous USDA research had explored possible surfactants, not available in commercial glyphosate formulations, that might enhance phytotoxicity against coca. Several candidates that enhanced herbicide "efficacy" were selected by the GOC for further consideration.
In consultation with the GOC’s Environmental Auditor to the spray program, USDA-ARS scientists recommended that any product to be added to the herbicide tank mixture be acquired from a Colombian source, if possible. This would ensure that it was a product already registered by the appropriate GOC regulatory authority, the Colombian Farming and Livestock Institute (Instituto Colombiano Agropecuario, or ICA), and almost certainly already used in Colombian agriculture. Cosmo-Flux 411F was selected as the additional surfactant because it met the above requirements and most closely matched the most effective U.S. products that had been tested by the USDA-ARS in Beltsville and Hawaii as additives to glyphosate for use against coca.
Cosmo-Flux 411F:
Cosmo-Flux 411F is manufactured in Colombia by a private company. Its use in Colombia is not limited to the GOC’s eradication program - Cosmo-Flux 411F is often used as an additive to herbicide sprays for manual and aerial application to crops. Cosmo-Flux 411F is approved for use with herbicides and is registered with the ICA under ICA’s lowest toxicological risk category, Category IV – "lightly toxic." The Colombian Ministry of Health has also classified Cosmo-Flux 411F as "slightly toxic" (in opinion No. LP-0573/1993). The active components of Cosmo-Flux 411F are polyol fatty acid esters and polyexothylated derivatives, which are seventeen percent of the product. The remaining 83 percent is made up of inert liquid isoparaffins.
Cosmo-Flux 411F is produced, sold, and purchased for the GOC in Colombia but is not sold in the United States. The EPA Office of Pesticide Programs does not regulate Cosmo-Flux 411F - or other adjuvant products not labeled as pesticides. EPA, however, regulates the use of such adjuvant chemicals if they are purposefully formulated with and are a part of manufactured pesticide products for use in the U.S. - a common practice. INL asked the EPA’s Office of Pesticide Programs to review the complete chemical constituents of Cosmo-Flux 411F to learn what EPA knew about the ingredients so that INL could better assess safety concerns related to the use of this product in the spray program. EPA determined in September 2001 that all of the ingredients of Cosmo-Flux 411F are exempt under 40 CFR 180.1001 from the requirement of tolerances when included in pesticides applied to food, feeds, and livestock. That information reconfirmed the GOC’s conclusion that Cosmo-Flux 411F was appropriate for use against coca in Colombia. The Colombian manufacturer of Cosmo-Flux 411F recommends its use in a dose ranging from 0.5 to 1.5 percent. The illicit crop eradication program’s use of a spray mixture that is 1 percent Cosmo-Flux 411F is thus within the manufacturer’s recommendation.
Figure 3. Final Coca Spray Mixture
Figure 3 illustrates the components of the final spray mixture by percentage. Water makes up approximately three quarters of the mixture, a fact that substantially reduces the toxicity of the other ingredients. Glyphosate salt (ispropylamine salt) is the second leading ingredient at 18% of the spray mix. Finally, the surfactants (those within the commercial glyphosate formulation plus Cosmo-Flux 411F) make up approximately 8 percent of the mixture.
Spray mixing and handling:
The commercial glyphosate formulation, Cosmo-Flux 411F, and water are mixed at forward air bases by mixers/loaders who are members of the Colombian National Police (CNP). The mixers/loaders are trained by the CNP, the U.S. Embassy’s spray advisor, and by designated spray pilots. They are trained on the relevant precautions for handling the chemicals in the spray mixture, first aid, and use of personal protective equipment that applicators and other handlers of glyphosate in its concentrated formulation must wear. These include long-sleeved shirts and long pants, waterproof gloves, shoes and socks, and protective eyewear.
Storage and disposal of spray mixture:
Special care is taken in the management of the commercial glyphosate formulation, which is more concentrated than the spray mixture. Appropriate measures are taken to ensure that glyphosate is not allowed to contaminate water, foodstuffs, or natural areas through its storage or disposal. Storage is in manufacturer-approved plastic barrels in covered areas with good ventilation, away from water sources. At the main spray bases, chemical storage is in a concrete storage shelter approximately 50 centimeters high with a 10-degree incline for the collection of any residues. In addition, sawdust, sand, dirt, clay or other absorbent material is readily available for immediate use in case of glyphosate spills. A drainage system, designed to prevent water contamination via run-off or leaching into the ground, collects water storage, mixing, and loading areas in trenches that carry it to a stabilization pools, which are eventually discharged into a specially selected lot to facilitate natural degradation.
Aircraft and spray equipment:
Aviators currently spray coca with the single-engine T-65 "Thrush" aircraft built by the Ayers Corporation for agricultural spray operations and with the twin-engine OV-10D "Bronco" aircraft converted from a military observation aircraft to an aerial spray aircraft. INL is currently taking delivery of a third type of spray aircraft, the Air Tractor AT-802, which is a single-engine agricultural spray aircraft similar to the T-65.
The spray nozzles are standard, agricultural nozzles selected and adjusted to minimize the number of small droplets that can drift downwind from a sprayed coca field. These nozzles produce a volume mean diameter (VMD) between 300-1,500 microns. This droplet size was reached after considerable INL and USDA testing and is consistent with the label instructions recommending coarse sprays that are less likely to drift. The aircraft spray systems are electronically calibrated to disperse a specified quantity of gallons of spray mix per hectare, compensating for variances in ground speed. These are calibrated upon installation and are checked each day during the mechanic’s daily inspection and the pilot’s preflight inspection. In addition, during actual spray operations the pilot monitors the spray system by observing the readings of the spray pressure and the spray flow rate gauges. Onboard computer and digital global positioning systems (D/GPS)-driven equipment (SATLOC and Del Norte) automatically record each aircraft’s actual flight parameters, including differential-GPS track, airspeed, altitude (mean sea level), application rate, and precise geographic location (longitude and latitude coordinates) at the time of aspersion. This allows precise evaluation of each spray event in order to ensure that spraying is conducted within proper target areas and within specified parameters. As part of the end-of-mission check, the mission planner and pilots review the spray logs for any inconsistencies in the recorded spray data.
Spray pilots:
Eradication pilots must have approximately 3,000 total flight hours before they are considered for the spray program and can receive preliminary training in illicit crop eradication. Most of these pilots also have at least 1,500 hours of commercial aerial application (crop dusting) experience. The INL Air Wing contractor trains the spray pilots who are Colombians, third-country nationals, and U.S. citizens. Eradication training focuses extensively on the visual identification of coca fields from the air as well as the technical aspects of crop spraying.
Reconnaissance:
Detailed aerial reconnaissance of cultivation areas precedes all spray missions. Aerial reconnaissance is performed using a multispectral digital imaging system (MDIS) that identifies crop type through the reflected sunlight in the infrared portion of the electromagnetic spectrum. This airborne camera system is calibrated daily and linked to global positioning systems (GPS) equipment that enables fields to be geo-referenced and accurately plotted onto aviation maps for mission planning purposes. As explained below, this equipment is for mission planning and reconnaissance and is not in any way a substitute for positive visual identification of coca fields by the spray pilot during the actual spray mission.
Most of Colombia’s coca crop is cultivated in the lowlands east of the Andes; here, the terrain is generally flat or marked by gentle, rolling hills. The more agile T-65 is used for spraying in areas with steeper topography. Coca is often grown in monocrop fields cut out of the triple canopy rainforest of the Amazon Basin. In this context the precision of the pilots is crucial, as is the use of a herbicide mixture that allows for rapid restoration of natural vegetation once the coca has been killed. The reemergence of native vegetation occurs very quickly after glyphosate application, ensuring that soil erosion will be minimal.
Spray parameters:
Spraying is conducted in Colombia under rigid parameters laid out by the GOC’s Environmental Auditor to the spray program. Missions are cancelled if wind speed at the airport is greater than 10 m.p.h., if relative humidity is below 75 percent, or if temperature is over 32º Celsius (90º Fahrenheit) - to avoid drift that might come from a temperature inversion. Spray missions are planned so as to avoid spraying wet coca; the goal is to have no rain on the targeted fields from two hours before to four hours after the spraying. Spraying most often takes place in the morning when weather conditions are favorable in the spraying area, although spraying can take place any time of day when the above conditions are satisfied. Poor atmospheric conditions often are the cause of mission cancellations. For example, in 1998 and 1999, spraying took place on an average of 125 days out of the year. During the other 240 days, the spray planes were grounded, with the majority of cancellations due to bad weather.
While flight lines are programmed using the reconnaissance procedures outlined above, pilots are instructed and trained to activate their aircraft spray systems only when they have positively identified coca directly in their spray line. Spray planes are under continual risk from hostile ground fire, yet the pilots spray as low over the coca fields as obstacles (e.g. trees) and security conditions will permit. The altitude above spray targets while spraying is normally less than 100 feet. Under the conditions in which the aerial eradication program is carried out in Colombia, spray pilots face great risks. Over the seven years of the aerial coca eradication program in Colombia, three spray pilots have lost their lives by striking their aircraft against the ground or trees while trying to spray as close to the illicit crop as possible.
The pilot of each eradication aircraft is responsible for deciding when damage to non-target foliage is likely to occur and to take every measure to avoid such collateral damage and spray only within the boundaries of the coca field. Pilots are licensed and trained to be conscious of wind direction and speed during spray operations to avoid unintentional damage to any legal crops. According to Colombian law, food crops that are interspersed with coca are subject to spraying. Nonetheless, great care is taken to avoid spray damage to legal crops and the spraying of any area that does not contain coca. While every effort is made to minimize human and mechanical mistakes, occasional errors are unavoidable. The GOC has implemented improved procedures to investigate claims of spraying of legal crops and to compensate owners if damage is found to be credible.
Spraying and human and environmental health:
Glyphosate is one of the most widely used agricultural herbicides in the world. It has been tested extensively in the United States, Colombia, and elsewhere. EPA approved glyphosate for general use in 1974 and re-registered it in September 1993. In its latest comprehensive review of studies on glyphosate, the EPA concluded that proper use of glyphosate, as permitted in the U.S., would not cause unreasonable adverse effects in humans or the environment.
The product label advises that the concentrated formulation of the glyphosate product causes irreversible eye damage, is harmful if swallowed or inhaled, and may cause skin irritation. These precautionary statements are determined according to EPA policy and are based on the results of testing on laboratory animals. INL does not believe that the spray program exposes humans who may be present in a sprayed field to such risks. This is because the irritation and toxicity potential of the individual ingredients are reduced when diluted during mixing (the final product is approximately 75 percent water) and the mixture is dispersed when sprayed. Thus humans who may be present under the swath of the plane are not exposed to levels that approach the commercial glyphosate formulation in its concentrated, undiluted form. The symptoms of such exposure are likely to be short-term and reversible. Furthermore, any one individual field is unlikely to be sprayed more than one time in a year, lowering the levels of repeated potential human exposure.
To minimize human exposure to the spray mixture, pilots are instructed to avoid flights over towns and populated areas and, during spray missions, to avoid spraying near people, homes, or occupied buildings.
Studies on livestock (cows, goats, and chickens) show livestock absorb limited amounts of glyphosate. Permitted levels of glyphosate in/on crops and livestock for human consumption are published in the Code of Federal Regulations, Title 40 (40 CFR), Section 180.364. EPA has concluded that consumption of crops treated with glyphosate and livestock fed with forage treated with glyphosate in the U.S. does not pose a dietary concern when residues are below these published tolerances. With respect to environmental impact, EPA concluded, based on required and available scientific studies, that glyphosate is not persistent in soil, does not build up after repeated use, and is biologically degraded over time by soil microbes. Because it binds tightly with the soil, glyphosate is unlikely to leach into underground drinking water. These qualities make glyphosate a well-suited herbicide for use against coca in Colombia.
Studies have shown glyphosate itself to be "practically non-toxic" to fish, however some glyphosate end-products may contain other ingredients that may increase the toxicity to fish when they are exposed. In accordance with the instructions on the product label, pilots are instructed to avoid all bodies of water when spraying coca.
Eradication oversight:
Spray pilot oversight is carried out by several entities. Pilot performance is monitored by the GOC’s Environmental Auditor, the Colombian National Police (CNP), INL’s Office of Aviation, the Narcotics Affairs Section (NAS) of the U.S. Embassy, Department of State contractor personnel, USDA weed scientists, and the GOC’s National Directorate of Dangerous Drugs. The Environmental Auditor, the CNP, and the contractor personnel are continually on-site in the bases or airports from which the spray planes operate and in most cases accompany the spray missions themselves. All of the above-mentioned offices actively participate in the ground truth verification of randomly selected, previously sprayed fields. These verifications usually take place twice a year. During this process, one of the important elements is an assessment of potential overspray or non-target drift, essential indicators of spray pilot (and herbicide) precision. These ground truth verification missions have found very few instances of spray pilot error and have reported that pilot accuracy is excellent and overspray minimal.
Unfortunately, human and mechanical error is possible and mistakes are made on occasion. In the past, many complaints of erroneous spraying of legal crops have proven groundless after subsequent investigation. However, INL believes that the credibility of the spray program is enhanced by a speedy and fair review of all complaints and by just compensation for any legal crops that were indeed sprayed in error. With support from the United States, the GOC’s process of investigating harm to legal crops has recently been improved to provide for faster investigation and resolution of complaints.
EMBAJADA DE COLOMBIA WASHINGTON, D.C.
March 22, 2002
The Honorable RANDY BEERS Assistant Secretary for International Narcotics and Law Enforcement U. S. Department of State Washington D. C.
Dear Secretary Beers:
I hereby enclose the Verbal Note sent by the Ministry of Foreign Affairs of Colombia to the United States Embassy in Bogota, certifying that our two Governments have been conducting consultations regarding the U.S.-supported aerial coca eradication program in Colombia and that this program is being carried out in accordance with Colombian laws.
Cordially,
LUIS IS ALBERTO MORENO Ambassador
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REPUBLICA DE COLOMBIA MINISTERIO DE RELACIONES EXTERIORES
VRE.CEC No. 11355
El Ministerio de Relaciones Exteriores, saluda muy atentamente a la Honorable Embajada de los Estados Unidos de América con ocasión de informar que el Gobierno de Colombia, se encuentra desarrollando el Programa de Erradicación de Cultivos Ilicitos por Aspersión Aérea con el Herbicida Glifosato (PECIG), atendiendo las normas colombianas aplicables en la material.
Que en atención al programa PECIG, viene implementando un plan de manejo ambiental aprobado por el Ministerio del Medio Ambiente, a través de la Resolución No.1065 de 2001 y precisada mediante Resolución No. 0108 de 2002.
Que desde el comienzo del Programa de Erradicación de Cultivos Ilicitos por Aspersión Aérea con el Herbicida Glifosato (PECIG), este ha contado con una auditoria ambiental.
A la Honorable EMBAJADA DE ESTADOS UNIDOS DE AMERICA Ciudad
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REPUBLICA DE COLOMBIA MINISTERIO DE RELACIONES EXTERIORES
En este sentido de acuerdo con las consultas sostenidas entre los Gobiernos de Colombia y los Estados Unidos en asuntos relacionados con la fumigación aérea de cultivos ilegales de coca en Colombia, por este medio el gobierno de Colombia certifica que el programa de fumigación aérea apoyado por los Estados Unidos se está llevando a cabo de acuerdo con todas y cada una de las leyes colombianas aplicables en la materia.
El Ministerio de Relaciones Exteriores se vale de la oportunidad para reiterar a la Honorable Embajada de los Estados Unidos de América las seguridades de su más distinguida consideración.
Bogotá D. C., 21 de marzo de 2002
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U.S. Department of State Office of Language Services Translating Division
LS No. 07-2002-0012 KFC/JF Spanish
Republic of Colombia Ministry of Foreign Relations
VRE.CEC No. 11355
The Ministry of Foreign Relations presents its compliments to the Embassy of the United States and would like to inform it that the Government of Colombia is implementing the IProgram to Eradicate Illicit Crops by Aerial Spraying of the Herbicide Glyphosate (PECIG), in accordance with applicable Colombian regulations.
Under the PECIG program, an environmental management plan is being implemented that was approved by the Ministry of Environment, through decision No. 1065 of 2001, and outlined further in decision No. 0108 of 2002.
The PECIG program has, moreover, been subject from the outset to an environmental audit.
Embassy of the United States, Bogotá.
Therefore, in accordance with the consultations held between the Governments of Colombia and the United States on matters related to the aerial spraying of illegal coca crops in Colombia, the Government of Colombia hereby certifies that the aerial spraying program supported by the United States is being carried out in accordance with each and every applicable Colombian law on the matter.
[Complimentary close.]
Bogota, March 21, 2002 [Initialed]
Home page for project: http://www.state.gov/g/inl/rls/rpt/aeicc/
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