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Environmental Management Plan for the Illicit Crop Eradication Program Using Aerial Spraying with the Herbicide Glyphosate (ICEPG)

Report on Issues Related to the Aerial Eradication of Illicit Coca in Colombia

Bureau of International Narcotics and Law Enforcement Affairs

December 2003

SPRAYING OPERATIONS MANAGEMENT PROGRAM
SPECIFICATION #1

1. ACTIVITY DESCRIPTION

While executing aerial spraying operations using the mixture of this herbicide, some quite specific conditions may occur that may generate potential environmental and social impacts, from the very moment the airplane takes off until it lands. During the trajectory, it may even be necessary to dump the herbicide in flight to ensure the lives of the crew, due either to attacks by terrorists or to aircraft failure.

The elimination of illicit crops in Colombia is justified because it hinders the negative impact related to the production and trafficking of narcotics and to the harm of deteriorating the environment. It also enables introducing new plant species aimed at extracting psychoactive substances. There are several available eradication methods (manual, mechanical, burning, biological, and chemical). However, taking into consideration the location of the illicit crop fields, the characteristics of the landscape, the opposition of the farmers who cultivate plants for illegal purposes, and the presence of outlawed armed groups, the most efficient and least dangerous strategy is aerial spraying with herbicides.

2. OBJECTIVES

3. ACTIVITIES TO BE CARRIED OUT

3.1. Prevention Measures

Maintenance, Checks, and Calibration

Before every mission, the technical personnel at the National Police Anti-Narcotics Division (DIRAN is the Colombian acronym) operations base must check the operational condition of the spraying equipment, and if need be, adjust the equipment.

DIRAN will keep a file of maintenance, check, and calibration reports.

3.2 Technical and Environmental Specifications in the Different ICEPG Phases

The spraying process is carried out in three phases: detecting the illicit crops to be sprayed, spraying, and verification.

3.2.1. Detection Measures

The purpose of the detection process is to identify, characterize, and locate the zones with illicit crops and the zones to be excluded from the programs, using geographical coordinates.

Such characterization will be supported by satellite imagery, aerial photography, and cartography. The ARECI-DIRAN personnel will do the field work to carry out this activity and its main objective is to identify how the soil is used, the presence of settlements, and the delimitation of National Protected Area System zones, ecologically fragile zones and environmentally, socially, and economically sensitive zones, in order to create the basic environmental zoning for each operation.

To do so, there must be strict compliance with 1991 Decree 1843 Article 87 referring to security zones and with Article 1, Paragraph 2 in National Anti-narcotics Commission Resolution 0013 dated June 27, 2003.

The environmental zoning will be delivered, in accordance with the available cartography for operations already carried out and with the frequency stipulated by the Ministry of the Environment, Housing, and Territorial Development.

3.2.2. Spraying Measures

For reasons of security and due to the location of and access to the fields with illicit crops, the spraying must be done using proper aircraft that comply with the parameters in Chart # 1.

3.2.2.1. Operational Parameters

During the spraying operations, bear in mind all technical navigation and spraying requirements, in order to mitigate the potential impact of the spraying on vegetation or on neighboring crops not covered by the ICEPG. These parameters include flying altitude, the size of the drops, dosage, wind velocity, and other favorable weather conditions.

The effect of the drift or side movement of some of the mixture being sprayed could be an inconvenience, considering the consequences that it may have on the ecological surroundings of the plants being sprayed; therefore, the ICEPG will be carried out under proper conditions (see Chart # 1).

ILLICIT CROP ERADICATION PROGRAM USING AERIAL SPRAYING

OPERATIONAL PARAMETERS

PARAMETER	UNIT OF MEASURE	VALUE OR RANGE	VALUE OR RANGE
		COCA	POPPY
Flying Altitude	Meters	The highest application altitude will be 50 meters; notwithstanding, the operation will be conditioned to the height of the obstacles present in the target spraying zones.
Maximum Dumping of Commercial Formula with Glyphosate	Liters / Hectare	10.4	2.5
Size of the Drops	Micras	300 ? 1,000
Foreseen Drift	Meters	< 5
Maximum Outside Temperature during Application	Degrees Celsius	35	20
Maximum Wind Velocity	Knots	5

3.2.2.2. Other Factors to Bear in Mind during the Spraying Operations

There are other factors that enable increasing the operational efficiency of aerial spraying using Glyphosate, without exceeding technical and economical thresholds; therefore, we recommend not spraying when:

3.2.3. Verification

The Eradication Program using aerial spraying with Glyphosate must be verified in order to evaluate the efficiency and effectiveness of the environmental management measures.

3.2.3.1. Measures to Verify Environmental Impact

1. Identification of the number of houses on the sprayed parcel, by their location in the airplane trajectory

2. Identification of still bodies of water (lagoons, lakes, and similar ones) located in the airplane trajectory, as well as streams or rivers susceptible of receiving the herbicide

3. Drift. The drift depends on the lateral wind velocity, the flying altitude, the initial size of the particles being sprayed, the density of the chemical compound, the outside temperature, and the pilot flying the aircraft?s experience. To verify the presence of drift, an Operations Precision Index will be estimated, consisting of the ratio of the quotient of the total sprayed area over the intended controlled area.
   
   If the quotient is more than 1, that is a direct indication of over-preciseness. And if the quotient is less than 1, there is not enough precision. The more the quotient approaches 1, the more the precision of the application technique reaches the optimum level.

The technical verification consists of the following activities:

1. Selecting the areas to be acknowledged
2. Selecting the sample
3. Selecting and gathering the participants
4. Evaluating the efficacy of the operation
5. Verifying the impact on the surroundings
6. Writing up the final report

Also, the Ministry of the Environment, Housing, and Territorial Development, the Ministry of Social Protection, the Colombian Farming and Livestock Institute, the National Attorney General?s Office, the National General Prosecutor?s Office, Plan Colombia, and other institutions that it is deemed relevant to summon may be invited to participate in the verification process, as observers.

3.2.3.1.4. Writing up the Final Report

The results of the verification process must be submitted in a document containing:

• The verification activity participants
• Verification acts
• Process methodology
• Results
• Recommendations
• Photographic record or video of the sampled parcels and sectors.

DIRAN will be in charge of the follow-up on the different activities herein. Therefore, it must have the records of the results achieved in the spraying operations.

5. ENTITY IN CHARGE

The National Police Anti-narcotics Division is in charge of carrying out the activities indicated herein.

END OF THE SPECIFICATION
SPRAYING OPERATIONS MANAGEMENT PROGRAM

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INDUSTRIAL SAFETY PROGRAM ON THE OPERATIONS BASES
SPECIFICATION # 2

Accidents lead to an increase of operation costs, supplementary costs (indemnities, compensations, repairs and replacements) associated with a negative program effect.

In order to carry out aerial spraying operations, it will be necessary to transport, store, load and dispose of farming chemical products, fuel, lubricants, and parts for the usage and maintenance of equipment, aircrafts and vehicles in the ICEPG on the operations bases; as well as the final disposal of debris, waste and packing materials.

Among the risks that may arise on the different operations bases, we name the following:

There are other activities that deserve industrial safety management, such as:

• Handling machinery, equipment and parts, including aircraft for spraying and for support.
• Handling fuels and lubricants used in the general equipment and machinery.
• Controlling the noise generated by the aircraft for spraying and for support.

In order to ensure a proper total safety program, it is necessary to have the training plans for the operation base personnel.

2. OBJECTIVE

To prevent, control and mitigate the adverse or undesired events related to the improper handling of farming chemicals, fuels, lubricants, equipment, aircrafts, ground vehicles and machinery.

3. ACTIVITIES TO BE CARRIED OUT

3.1. FARMING CHEMICAL PRODUCT MANAGEMENT

For the storage, handling, application, transportation and disposal of debris and residues, apply the measures embodied in the norms in force in 1986 Resolution 2309, 1991 Law 430, 1991 Decree 1843 and the regulations that modify them, add to them or substitute them, as well as in applicable environmental standards.

The specific activities are consigned in the National Police Anti-Narcotics Division instructions that address total safety measures for the operations base platforms.

3.2. RAW MATERIAL AND EQUIPMENT MANAGEMENT

3.2.1 FUEL AND LUBRICANT MANAGEMENT

For the storage, handling, application, transportation of fuels, lubricants and disposal of debris and residues, implement the measures embodied in the following Colombian technical standards 1899, 1417, 4643, 5011 and in the 2002 Regulation Decree 1609 and in the standards that modify it, add to it or substitute it and that are applicable to it, given the special characteristics of this program.

For the operation and maintenance of aircrafts, ground vehicles, equipment and machinery available on the operations bases, follow the guidelines available at the National Police Anti-Narcotics Division and especially the instructions contained in the manufacturer?s operating manuals.

3.3. OCCUPATIONAL HEALTH AND INDUSTRIAL SAFETY MEASURES

Follow the measures embodied in the National Police Occupational Health and Industrial Safety internal regulations, as well as the standards provided for in 1979 Law 9, Heading III ? Occupational Health and the decrees that regulate it.

Both the illicit crop eradication area and the police aviation area have their own instructions regarding total industrial safety and occupational health measures.

3.4 SIGNALLING

The Operation Bases will be equipped with signaling for prevention, regulations, and information purposes, following industrial safety guidelines to prevent program-associated risks.

3.5. TRAINING

3.5.1 TRAINING FOR FARMING CHEMICAL PRODUCT MANAGEMENT

Pursuant to the provisions in 1991 Decree 1843 Article 172 and following, all personnel working with pesticides must be trained once a year to ensure proper farming chemicals product management. DIRAN must keep the corresponding records of such training sessions, including topics covered, attendance sheet, duration, and training entity.

3.5.2 TRAINING ON OCCUPATIONAL HEALTH AND INDUSTRIAL SAFETY MEASURES

DIRAN will forward a training program, according to the specific activities carried out by the personnel involved in the ICEPG, including the following topics:

4. FOLLOW-UP

DIRAN will be in charge of the follow-up on the different activities included herein. To do so, DIRAN must have the records of the results of the inspections and verifications, as follows:

5. ENTITY IN CHARGE

The National Police Anti-Narcotics Division is in charge of carrying out the activities herein.

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2. OBJECTIVE

3. ACTIVITIES TO BE CARRIED OUT

3.1. Domestic Solid Waste (DSW) Management Plan

Because the program generates domestic solid waste on the bases where spraying is done, the regulation embodied in Decree 2104 dated July 26, 1983, through which solid waste management is regulated, will be applied.
In addition to the above, instructions must be given to the personnel on the operations base for them to classify solid waste in its place of origin, in order to facilitate its management.

3.2. Management of Special Solid Waste (SSW) and Solid Waste linked to Farming Chemical Management (ASW)

Because the program generates special solid waste on the bases where spraying is done, including farming chemical containers, the regulation embodied in 1991 Act 430, in Decree 2104 dated July 26, 1983, in 1986 Resolution 2309 and in 1991 Decree 1843 issued by the Ministry of Health, through which solid waste management is regulated, must be obeyed.

In addition to the above, instructions must be given to the personnel on the operations base for them to classify solid waste in its place of origin, in order to facilitate its management. An instructions booklet and environmental education workshops will complement the solid waste management program for the operators on the bases.

Due to the low toxicity of the mixture used for the ICEPG, the empty recipients of the mixture can be used to collect garbage or for building barriers (trenches) on the military bases, provided they are completely washed and perforated, to avoid their being used to transport water or other materials for human consumption.

With the above exceptions, they can be re-used by the same farming chemical manufacturing company.

4. FOLLOW-UP

DIRAN will be in charge of the follow-up on the different activities included herein. To do so, it must have the records for each one of the activities:

Follow-up will be done every six (6) months.

5. ENTITY IN CHARGE

The National Police Anti-narcotics Division will be in charge of carrying out the activates described herein.

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OPERATIONS BASE WASTEWATER MANAGEMENT PROGRAM

There are three (3) types of wastewater produced on a National Police Anti-narcotics Division operations base:

Sewage: the product of satisfying individual and group domestic needs

Industrial Wastewater: the product of washing the spraying devices of the aircraft, machinery, filling equipment, and of mixing and storing farming chemicals. This also includes water used to wash the facilities. In the wastewater from the general maintenance and washing of the facilities, we foresee a greater content of solids in suspension, detergents and, possibly, emulsified grease and oils.

Rainwater: This goes to a collecting system and is evacuated from the operations base or is infiltrated into the ground. Rainwater full of sediments that it drags on the ground may contain total solids as well as solids in suspension.

2. OBJECTIVES

2.1. General Objective

2.2. Specific Objectives

3.1. Wastewater Management

Wastewater management will be handled, taking where the wastewater is produced into account:

On the fixed bases where there is no connection to the public sewer system, connection may be made to an alternate wastewater treatment system or at least to a septic tank with a grease trap or a membrane, which meets minimum waste disposal standards.

The bases will have a fixed or mobile system for collecting and re-using industrial wastewater. See Annex.

Precipitate solids produced in sewage treatment processes will be managed as domestic solid waste (DSW) and special solid waste (SSW), pursuant to the provisions in Specification # 3 regarding solid waste management.

3.1.1. Wastewater Treatment

Sewage Treatment System

The bases that produce sewage directly related to spraying operations will have treatment systems according to need; they will obey the allowable limits set forth in the regulations in force, and will ensure proper, permanent maintenance.

Liquid Industrial Waste from Washing the Airplane Tanks (SLW)

The industrial wastewater produced from washing the aircraft used to apply the mixture will be re-used in the spraying process.

3.1.2. Final Disposal

Once the wastewater meets the conditions required at the emptying site, based on the use of the water in the receiving trench, it can be dumped, pursuant to the provisions in 1978 Decree 1541 and to 1984 Decree 1594.

3.2. Dumping Control

In order to establish basic sanitary parameters (DBO, DQO, total solids and solids in suspension, pH, total coliforms and faecal coliforms), a characterization aimed at proving the efficiency of the domestic wastewater treatment system and compliance with regulations must be made.

A wastewater dumping analysis must be made once every six (6) months or at least once during the operation on bases that operate for less than six months, in order to establish that the emptying was limited to the provisions set forth in 1984 Decree 1594 regarding the use of wastewater and liquid waste.

The wastewater treatment system will be located where it will not lead to the contamination of any well, spring or other source of water supply. In addition, it will be located in a place that has the slope specified for evacuating the treated wastewater. The location must have the proper terrain and must be easily accessible.

The bases where wastewater is emptied into systems other than municipal sewer systems will obtain permits and keep them effective.

3.3. Training

Training and educational programs will be given to those who operate the treatment system for the wastewater plants and for the re-use of industrial wastewater, in order to guarantee their proper maintenance and operation.

4. FOLLOW-UP

DIRAN will be in charge of the follow-up on the different activities included herein. To do so, it must have the records of the results achieved in each one of these activities, as follows:

Implementing the measures included in this program will be subject to the budget assignments that the National Government allots for this purpose.

5. ENTITY IN CHARGE

The National Police Anti-narcotics Division is in charge of carrying out the activities indicated herein.

END OF THE SPECIFICATION
OPERATIONS BASE WASTEWATER MANAGEMENT PROGRAM

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ENVIRONMENTAL MONITORING PROGRAM
SPECIFICATION #5

1. ACTIVITY DESCRIPTION

Although the scientific studies available show that there are is no significant impact from applying Glyphosate on the soil, water, and plant components that surround the illicit crops being sprayed, it is necessary to carry out follow-up and verification actions regarding the effectiveness of the spraying operations and the estimation of the possible impact on the environmental components.

This technical follow-up will be done on parcels that meet the following criteria:

3.1. Plant Succession Analysis

To become familiar with the plant succession process, a qualitative regeneration characterization (percentage of vegetation layers) will be done before and after each spraying, using videos, digital photography, and satellite imagery.

In zones where there is no access either due to public order problems or to topographical conditions, available images will be used in order to determine any change in the vegetation layers.

To do this analysis, the following specifications must be borne in mind:

The parcel to be evaluated will be geo-referenced and will have a minimum area of one hectare.

Number

A total of two (2) parcels will be analyzed regarding vegetation layers, for each ICEPG target nucleus:

Verification must be done before the spraying, immediately thereafter, at 60 days and, if justified, at 90 and at 180 days.

To forward the environmental monitoring of the spraying operations on poppy crops, aerial monitoring will be done, given the topographical, meteorological, public order, and typical logistic support conditions in these zones.

3.2 Glyphosate and MPAA Residue Analysis

Size

The parcel to be evaluated will be geo-referenced and will have a minimum area of one hectare.

Number

A total of two (2) parcels will be analyzed regarding vegetation layers, for each ICEPG target nucleus. For soils, a compound sample will be made up of minimum three (3) samples taken from each parcel. For bodies of water, a compound sample will be made up of minimum two (2) samples taken from each parcel.

In each parcel selected, a compound sampling will be used taken from the first 20 cm. of horizon A, before the spraying, immediately thereafter, at 60 days and, if justified, at 90 and at 180 days.

Indicators

Soil: pH, Cationic Interchange Capacity (CIC), relation of interchangeable bases, nitrification (nitrates, ammonia and nitrites), percentage of organic matter, texture, concentration of Glyphosate and AMPA, new count of bacteria, actinomycetic fungus and nitrogen fixative, phosphate solubilizers, total phosphorous and available phosphorous.

Water: Concentration of Glyphosate and AMPA, pH, electrical conductivity, temperature, dissolved oxygen, chemical oxygen demand, nitrification (nitrates, nitrites and ammonia), dissolved phosphate, magnesium, and calcium.

Vegetation Layer. The indicator will be a percentage estimate of the area with new vegetation.

4. FOLLOW-UP

In coordination with the entities involved, DIRAN will ensure compliance of the work schedule established to carry out the proposed activities and to send the samples to the Agust?n Codazzi Geographical Institute (IGAC is the Colombian acronym) Soil Laboratory and to the National Health Institute (INS is the Colombian acronym) National Referencing Laboratory .

5. ENTITIES IN CHARGE

Plant Succession Analysis

• The National Police Anti-narcotics Division will do the aerial photography and videos, as part of the environmental monitoring. The results will be sent to the Ministry of the Environment, Housing, and Territorial Development.
• The Ministry of the Interior and of Justice is in charge of the project to analyze the vegetation layer over time, which is a product of the Total Illicit Crop Monitoring System (SIMCI is the Colombian acronym). That Ministry will remit the results to the Ministry of the Environment, Housing, and Territorial Development.

1. ACTIVITY DESCRIPTION

The development of a program of the nature of the ICEPG implies a series of interactions with the communities in the program target zones, either to inform them of its characteristics, results or progress or to solve the concerns that they may have regarding said program.

2. OBJECTIVES

3. ACTIVITIES TO BE CARRIED OUT

3.1. Communication

Through a communication strategy, keep the society and the community at large informed nationally, regionally and locally, especially the communities located in the areas of influence of the Glyphosate spraying nuclei, regarding aspects, such as:

• Illicit crop problems
• Eradication policies
• ICEPG results (detection, spraying and verification)
• Complaint handling system
• Risk prevention and management

3.2. Training

The training will be aimed at institutional officials involved in the program, ICEPG technical and operational personnel, health care authorities, among others, and will be related to the Environmental Management Plan. See training aspects in Specifications # 1, 2, 3, 4, 7, and 8.

3.3. Inter-institutional Coordination

The Illicit Crop Eradication Program using Aerial Spraying with Glyphosate (ICEPG) is a strategy that the Colombian State uses to reduce the supply of illicit drugs.

To carry out the activities included in the ICEPG and in its Environmental Management Plan, we boast, at a national level, the participation and commitment of the different institutions involved in the ICEPG, which have direct responsibility, pursuant to the provisions in the National Narcotics Council Resolution 0013 dated June 27, 2003, and to the specifications in this plan.

In order to carry out these actions, we may establish inter-institutional covenants with technical, public and private organizations who can support the ICEPG.

3.4. Complaint Handling

3.4.1. Farming and Livestock Activities

Complaints of affectations that may have been caused by working with legal crops not mixed with or that are rotated with illicit crops will be handled pursuant to the provisions in Resolution 0017 dated October 4, 2001 or in any other regulation that modifies it, adds to it or substitutes it.

3.4.2. Environmental Management

Should there be possible damage to zones in the National Natural Park Systems or other forest zones or State-owned natural zones, the Environmental Authority (Regional Autonomous Corporations) or the Natural National Park Special Administrative Unit (UAESPNN is the Colombian acronym) will present the complaints to DIRAN, who must handle said complaints pursuant to the standards in force regarding administrative actions.

3.4.3. Health Care Management

The possible complaints that may arise for alleged health affectations will be handled pursuant to the mechanisms set forth in the General Health Social Security System described in Specification # 7.

4. FOLLOW-UP

On a monthly basis, DNE will verify the progress status of the scheduled activities vs. the activities carried out for each strategy defined herein.

Each entity committed to the implementation of strategies will appoint one delegate who will be in charge of all coordination with DNE.

5. ENTITY IN CHARGE

DNE is responsible for coordinating the implementation of the strategies provided for herein.

END OF THE SPECIFICATION
COMMUNICATION AND SOCIAL MANAGEMENT PROGRAM

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1. ACTIVITY DESCRIPTION

This program describes the set of activities and procedures aimed at the prevention, mitigation, correction, and compensation of risk situations for the health of the population in the ICEPG application zones.

2. OBJECTIVES

To develop risk management measures for the prevention, mitigation, correction, and compensation of the effects on health that may be associated with spraying using Glyphosate in the ICEPG operations zones.

2.2. Specific Objectives

The strategies to be developed are related to information, care, and evaluation regarding health complaints.

3.1. DETERMINING THE HUMAN HEALTH RISK PANORAMA

The Ministry of Social Protection will create the Panorama for Risks to Human Health, which may be caused by exposure to the mixture used in the ICEPG. Based on medical and scientific literature, medical histories and risk levels as well as foreseeable adverse effects can be described.

Using that panorama, the scope and development of the other activities included herein based on the occurrence of each risk will be established and specific measures to eliminate or effectively control the provoked adverse effect will be prepared.

3.2. INFORMATION FOR PREVENTING EXPOSURE AND ACCIDENTS CAUSED BY ILLICIT CROPS AND THEIR ERADICATION

The specific information actions to which this component refers are aimed at the communities in the areas of influence of the zones in which the ICEPG intervenes, in order to reduce risks of exposure to pesticides and to induce the demand for timely medical care for the diagnosis and management of possible accidents with pesticides. Such activities will be permanently carried out in all of the zones scheduled in the ICEPG, with certain priority before the spraying occurs and during the period immediately after the spraying. The activities include the following:

3.3. HEALTH CARE FOR AFFECTATIONS RELATED TO ILLICIT CROPS AND THEIR ERADICATION

The actions aimed at guaranteeing timely, proper attention to possible risk situations or affectations effects to the population?s health include:

The objective of this activity will be to encourage the participation and integration of persons and institutions to supervise and control problems related to the use and handling of and management of pesticides. Special emphasis will be given to coordination with the ICA Regional Offices, the Regional Autonomous Corporations, SENA, the UMATAS, and Municipal Ombudsmen?s Offices.

e) Training the Operational Personnel Who Work with the Mixture Being Sprayed

3.4. EVALUATION OF COMPLAINTS REGARDING AFFECTED HEALTH

All health complaints received or remitted to entities other than health care service centers or to public health supervision units will be immediately referred to the above-mentioned health agencies set up in each territorial agency, to proceed with the medical evaluation and determine possible relations between the medical situation that motivated the consultation and exposure to Glyphosate and other related substances. Along those lines, information must be given to the persons involved as well as to the authorities and officials of the distinct agencies, for said evaluation to be done in a timely manner.

At any time, both entities that receive health complaints and the population at large may demand that health organizations make an evaluation of the health condition of persons who file complaints or who accede to services for consultation when they suspect the existence of physical signs and symptoms that they believe are associated with pesticides.

4. FOLLOW-UP

5. ENTITY IN CHARGE

At the national level, the Ministry of Social Protection and the National Health Institute will be in charge of the health component; at the provincial department, district and municipal levels, the Territorial Health Divisions will be in charge.

END OF THE SPECIFICATION
PUBLIC HEALTH PROGRAM

Given the fact that the illicit crop eradication program sprays using Glyphosate, a broad spectrum herbicide, and, although the environmental risk evaluation reported the high degradability of Glyphosate in the different environmental surroundings, the operation of the program itself is subjected to several risk factors (outlawed armed groups, aircraft mechanical failures, environmental aspects, to name a few), which endanger human lives and the natural environment when, due to these facts, it is necessary to immediately dump all of spraying product.

The Contingency Plan (CP) is a document that provides response strategies to attend the emergencies that may arise during the different stages of Glyphosate handling, for the purpose of illicit crop eradication (transportation, storage, handling and spraying). Among the possible events that may occur, we include dumping (immediately dumping all of the Glyphosate from the aircraft), which action, in the oil sector, would correspond to spillage. For all events analyzed, we have established the responsible parties to be in charge of the CP operation as well as the mechanisms to supply basic information on the possibly affected areas. Likewise, we have established action procedures that must be followed when facing each type of situation, the parties to whom to request support, the equipment and production factors that would be required for each action.

By creating the illicit crop eradication program contingency plan, the Anti-Narcotics Police aims not only to respond in a timely manner to the contingencies that arise from the operation, but also to follow the National Total Emergency Attention Policy, with the support and participation of the different government entities and institutions, each one handling its portion, based on its mission and objectives.

1. GENERAL CONSIDERATIONS

The Contingency Plan (CP) is a set of activities and operations that must be planned and carried out, in order to anticipate, prevent and / or correct any eventuality that may arise due to operating, natural or exogenous failures, and that may cause some type of negative impact on people, their assets or on the environment.

The CP also seeks to:

The Contingency Plan is basically comprised of a Strategic Plan, an Operating Plan and a Database, with the following basic components:

2.1 STRATEGIC PLAN

The purpose of the strategic plan is for each responsible person or entity to clearly know its functions and responsibilities within the plan, to perform the functions assigned and to efficiently use the resources available to take care of emergencies.

The Contingency Plan covers the spraying program operations zones. Therefore, the National Police Anti-narcotics Division bases will have the equipment, mechanisms and personnel trained to handle possible incidents or accidents related to the aerial spraying processes.

Within the specific ICEPG implementation zones, the following have been defined as priority action zones within the Contingency Plan:

The CP structure is mainly based on the creation of a Permanent Emergency Committee (PCE is the Colombian acronym) for each base, responsible for the following activities:

BASE PERMANENT EMERGENCY COMMITTEE (PEC)

Emergency Groups Base Operations Commander Spraying Operations Commander Spraying Group Coordinator Environmental Management Plan Technician

Internal Support Group Spraying Mobile Group Commander Farming chemical and Fuel Blending Technicians Environmental Management Plan Technician Communications Chief

External Support Entities Fire Department National Army Red Cross Colombian Civil Defense Corresponding National Police Department DNE Ministry of the Interior Disaster Attention Office, if so required.

The Coordination Centers for activating the Contingency Plan will be the National Police Anti-Narcotics Division spraying bases, where the required equipment is available for communication between the disaster attention team and the operations center.

The purpose of this plan is to establish the basic procedures of the Contingency Plan operation. It also defines notification, organization and operation principles and mechanisms.

Below we list the procedures or protocols to be followed in each Operating Plan component:

2.2.1 Prevention and Control Measures

On the operations base:

2.2.2 Communication with the Internal Support Group

The existing communication systems must be used to inform all personnel on the base of the emergency at hand for them to immediately arrive and give the pertinent recommendations.

2.2.3 Communication with External Support Entities

When the internal groups cannot control the contingency, the Spraying Operations Commander will contact the existing external entities specialized in emergency attention to inform them of the type of emergency at hand, and to request their immediate arrival and support.

The Spraying Operations Commander will coordinate the actions with the internal and external support groups to respond to the emergency.

In the case of dumping, the Spraying Operations Commander will report and coordinate the necessary support with the different pertinent entities.

The Spraying Operations Commander will prepare an initial dumping report that will contain the basic information regarding the specific circumstances (where, when, and how), in order to preliminary estimate the magnitude and severity of the event.

For initial notification purposes, Form # 1 ?INITIAL REPORT? will be used, (see Annex), taken from the National Contingency Plan and customized to the spraying program operation conditions.

2.2.4 Alarm Activation

In case of emergency, the Spraying Operations Commander must trigger the emergency alarm.

If there is any other person in the emergency room, this person must immediately inform the Spraying Operations Commander for him / her to trigger the alarm.

Once the corrective actions are initiated, the Spraying Operations Commander may order the alarm deactivation.

To activate the CP, we will take the customized levels from the National Contingencies Plan.

2.2.5 Contingency Plan Activation

Once the emergency is reported, the Spraying Operations Commander will proceed to:

The CP activation may have different levels, according to the characteristics of the emergency:

Level 1: Partial CP Activation in Alert Mode

In this type of event, the Program will take measures aimed at controlling the situation, by activating its maximum operating response level for attending the event, maximum three (3) hours after activation.

Level 2: Program CP Activation by Requesting Support to the Operating Committees

This occurs in remote zones within the program operation coverage, and is coordinated with the internal support groups and external support entities. This level will be activated 24 hours after the event.

TABLE 1. CP ACTIVATION LEVELS, OBTAINED AND EDITED FROM THE NATIONAL CONTINGENCY PLAN

Level 3: Instantaneous Total CP Activation. Disaster ? Highest Volume and Severity, within the Local CP Coverage Area

The event is totally out of the program operation area control, and exceeds the capacity of the requested local or regional assistance systems. National level agencies are required to organize the actions. This level will be developed if the event exceeds the level 2 operations capacities 48 hours after its occurrence, for which it will have the support of national level agencies.

2.2.6 Priority Criteria in the Response Operations

The highest priority is to protect and preserve the lives of persons threatened by the incident.

When there are resource and time limitations, it will be necessary to first protect the resources that are most valuable and important for the security and welfare of the base personnel and of the population in the surrounding area. Next, we will protect resources with a high ecological value and the greatest sensitivity, such as primary and secondary woodlands with native vegetation, in order to ensure sustainability of the ecosystems. And last, we will protect socio-economically and ecologically threatened resources that have a risk indicator of medium or low, such as legal crops or brush.

If we have to select between protecting two threatened resources of high value to the community, but with different risk indicators, priority will be given to the most sensitive one. If there are two resources with equal risk value, we will opt to protect the resource that, if affected, would cause greater socioeconomic impact on the human population at a short or mid term.

If any of the above-mentioned measures cannot be applied, we will proceed to do emergency dumping at an altitude of 5,000 feet, and to do follow-up on the area if the public order conditions so permit; otherwise, we will notify the pertinent entities to do follow-up on the possible effects.

2.2.7 Operational Procedures or Response Protocols

2.2.7.1 Evacuation and Assistance in the Event of Fire or Explosion on the Base due to Failures of an Operational Nature

a. Spills for Tank Truck Turn Over during Transportation

The following procedure will be delivered to the transportation entity contracted for transporting farming chemicals.

8. When the spillage has occurred on the ground, the transportation company will isolate the area with security bands, will proceed to do the cleaning, and will isolate the existing sewers or drains so that the affected area does not expand.

2.2.7.4 Fire and Explosion Control on the Base due to Operational Failures

2.2.7.5 Attacks against the Base

a. Primary Incident Report. The aircraft pilot must report the events right after they occur.

It is possible that the pilot not report the incident immediately after the event occurs, due to damages that may affect the aircraft communication systems or to the pilot?s not detecting the incident in a timely manner or if the incident ended up in a fatality (aircraft accident).

When the aircraft has suffered an incident, no matter if the incident is of low, medium or high severity, it must return to the base. Prior to returning to the base, the pilot and the Spraying Operations Commander, after having evaluated the incident, establish the need to dump the product, based on the following order of importance:

Low Severity Incident. We include incidents where the safety of the aircraft and, therefore, the pilot?s safety are not seriously endangered. In this type of incident, no product dumping is considered. In this case, the aircraft suspends the operation and immediately returns to the base.

Medium Severity Incident. The pilot has operational and airworthiness capacity that enables him / her to evaluate the zone for product dumping. Priority is given to pre-established zones in the spraying zone characterization. The pilot immediately returns to the base after dumping the product.

High Severity Incident. This is an event of great risk, where the pilot lacks sufficient airworthiness to select the spot to dump in, thus he/she has to dump the product immediately and return to the base.

Fatal Severity Incident. These are incidents where the final result is fatal; they usually end up in the aircraft being shot down.

The follow-up on the operation as described in the CP is established within the environmental monitoring program.

b. Response Team Activation. This operating level relates to all activities carried out to activate the emergency attention group during the spraying process. Among them is the reconfirmation of the exact place of the incident, the security study of the area in which the incident occurred, going to the area, the evaluation of the need of taking corrective measures or not, and dumping, if required.

c. Emergency Attention Group. It will carry out activities aimed at taking the corrective measures specified in the Contingency Plan, in events related to the possible total or partial dumping of the product.

The Spraying Operations Commander is responsible for the Response Team coordination, who, as soon as the incident is reported, becomes the emergency attention team coordinator.

d. Verification of Security Conditions. When an aircraft has been forced to do a total or partial dumping operation, this activity usually occurs due to criminal action (the aircraft is shot at, obstacles on the parcels, etc.), aircraft technical failures, environmental conditions or human failure.

Due to the need of performing the contingency action in the same zone where the incident occurred, the priority lies in verifying the security conditions in the product dumping area, in order to avoid the incident from reoccurring before the Response Team can arrive and work. The security study is obtained from the intelligence reports supplied in due fashion by the Military in the area and from the information obtained by the technicians who do the technical study of the incident.

When the security conditions are not adequate for the Emergency Attention group to arrive, it is necessary to notify the Eradication Area in order to apply environmental monitoring measures. Meanwhile, the spraying operations will continue in other zones.

RESPONSE GROUP ACTIVATION

e. Geographical Reconfirmation of the Area. Through the Satellite Localization System, the Spraying Operations Commander proceeds to geographically locate the place in which the aircraft was forced to dump the product.

f. Arrival of the Emergency Attention Group at the Specified Site during the Spraying. If safety conditions allow, the group arrives, according to the parameters set forth in the protocols for crop eradication operations using aerial spraying.

g. Evaluation of the Area Affected by Product Dumping. The Emergency Attention Group evaluates if dumping water over the affected areas is justified or not. This procedure analyzes if the product dumping was done on legal crops, illicit crops, bodies of water, populated areas, among others.

h. Application of Corrective Measures. Depending on the physiographical characteristics, weather and security conditions, the planes will dump from 200 to 300 gallons of water on the affected site.

The dumping will be done during this period of time, provided that the evaluation of the security conditions so permits.

i. Information Report. From the moment when the pilot or the accompanying security team reports the incident, the Spraying Operations Commander activates this operational level. It is aimed at establishing the information flow for coordinating how to respond to the emergency.

j. Incident Technical Report. This is a careful revision of the aircraft done by the technical personnel in the National Police Anti-Narcotics Division Aviation Area assigned to the base where the event occurred and by the Eradication Program advisors. The evaluation is aimed at verifying the possible damages caused to the aircraft during the incident and to certify the results obtained. If the contingency is caused by human failure, the technical report must include an initial evaluation that will be used to carry out an investigation and make corrections.

k. Filling Out the Initial Report Format. The Spraying Operations Commander, who has become the Emergency Attention Group coordinator, will make an initial report of the dumping, bearing in mind the Incident Technical Report, which will contain the basic information of the specific circumstances (when, where, and how) in order to have a preliminary estimate of the magnitude and severity of the event.

l. Final Technical Report. With the support of the Emergency Attention Group, the Spraying Operations Commander will present the final written Technical Report, addressed to the Eradication Area, in order for the latter to submit it to the National Narcotics Agency maximum 20 days after the date on which the dumping occurred, in order to obtain detailed knowledge of the circumstances of the event, its attention and control.

The final written report on the event must contain the following:

2.2.8 Contingency Plan Evaluation

Once the emergency is over, the Spraying Operations Commander will carry out a series of activities in order to determine the final closing of the operation, evaluate the consequences of the dumping as concerns the efficiency of the actions performed and the impact on the environment.

Evaluation of the Response to the Emergency

In order to perform a proper control and be able to evaluate the actions taken, the Contingency Plan must keep a log that must contain the daily report of all dumping control and attention activities, as well as of all actions performed. This log will be the base for preparing official reports and for handling possible claims.

Once the event is over, based on the action reports, a detailed evaluation will be made of the effectiveness of the plan, the reference being how the event was handled. Said evaluation will enable determining the most important aspects that must be considered for recreating and redesigning the Contingency Plan, based on the experience obtained from the emergency.

To make this evaluation, the following aspects will be analyzed:

It is a fact that in order for a Contingency Plan to be effective, it not only needs the organization and equipment required to handle the emergency, but it also requires a basic element that is the personnel?s quality and efficiency, and that may only be achieved through training.

For training purposes, it will be necessary to use all environments and materials required, which DIRAN will establish and provide.

It is necessary to have specific training programs for:

Technical Aspects. Storage and handling in spraying equipment operation areas, raw material handling, and work team organization.

Environmental Aspects. Acknowledgement of the operational zones as distinct ecosystems with different sensitive levels.

Operational Aspects. Information on physiochemical properties and their inactivation methods.

2.3 INFORMATION SYSTEM OR DATABASE

This is a tool that provides, in a quick, timely manner, communication with the group personnel and with the external support entities.

The Contingency Plan database will supply the required information for the Strategic Plan and the Operating Plan to be effective. All information required by the Contingency Plan will be gathered and permanently updated by DIRAN, through its Spraying Group Coordinator.

The Contingency Plan requires information presented as geographical information, general lists, appendixes, which are consolidated into the following types of information: legislation, referencing, logistics, statistics and environmental aspects, among others.

Through a specific project, DIRAN will have software, hardware, personnel and logistic support to administer and process existing information.

3. ACTIVITY SCHEDULE

This program must be ongoing.

4. ENTITIES IN CHARGE

The National Police Anti-Narcotics Division is responsible for contingency activation and attention.

Upon the request of the National Police Anti-Narcotics Division, the National Narcotics Agency will process the support requests to national level agencies, such as the Ministry of the Environment, Housing and Territorial Development, the Ministry of Social Protection, and the Ministry of the Interior and of Justice.

 

NATIONAL POLICE
ANTI-NARCOTICS DIVISION
ILLICIT CROP ERADICATION AREA

EMERGENCY DUMPING REPORT

BASE FOR SPRAYING:

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DUMPING DATE:

TIME_________ DAY_________ MONTH_________ YEAR________

RANK AND FULL NAME OF THE PERSON WHO DETECTED THE DUMPING

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DUMPING CAUSE

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LOCATION (Provincial Department ? Municipality ? Settlement ? Other Information)

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DUMPING COORDINATES

N: __________________________ W: ________________________

DUMPING ALTITUDE

_____________________________ meters

WEATHER CONDITIONS WHILE DUMPING

Temperature: ________?C Wind Velocity: _______ Km / hr. Rain: ______

DESCRIPTION OF THE AFFECTED AREA: (Prepare a schema of the dumping site, the affected surface, and the area of influence)

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ESTIMATED DUMPING AMOUNT

_________________________ Gallons

IMPACT ON NATIONAL RESOURCES ? TERRAINS ? FACILITIES ____________________________________________________________________
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IMPACT ON COMMUNITIES

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ACTIONS CARRIED OUT

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SUPPORT REQUIRED

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COMMENTS

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