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entitled 'Agriculture Production: USDA's Preparation for Asian Soybean 
Rust' which was released on May 23, 2005.

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United States Government Accountability Office:

Washington, DC 20548:

May 17, 2005:

The Honorable Tom Harkin:
Ranking Democratic Member:
Committee on Agriculture, Nutrition, and Forestry:
United States Senate:

Subject: Agriculture Production: USDA's Preparation for Asian Soybean 
Rust:

Dear Senator Harkin:

In November 2004, Asian Soybean Rust (ASR) was discovered in the United 
States in Louisiana. In the following weeks, it was found in eight 
additional southern states. ASR is a harmful fungal disease that has 
spread throughout many other parts of the world, including Asia, 
Australia, Africa, and South America. ASR can infect over 90 host plant 
species, including legumes, such as dry beans, peas, and kudzu, a plant 
that grows wild primarily in the southern United States. Although the 
disease has caused significant soybean crop loss and increased 
production costs in many other countries, ASR arrived in the United 
States too late in the crop year to have any effect on soybean 
production in 2004, and scientists were uncertain about how it would 
survive the winter climates in the United States. However, in February 
2005, researchers found that ASR had successfully over-wintered on 
kudzu in Florida, and it was subsequently detected in Georgia on 
soybean plants in April 2005. Since environmental factors, such as 
rainfall, humidity, and temperature, affect both the severity and 
incidence of ASR, scientists do not know how widespread or damaging the 
disease will be in the United States during the 2005 crop year. The 
U.S. Department of Agriculture (USDA) is responsible for monitoring and 
addressing the problems posed by ASR. The Environmental Protection 
Agency (EPA) is responsible for licensing fungicides to treat the 
disease.

You asked us to determine (1) USDA's efforts to develop and implement 
an ASR surveillance strategy to identify and protect against ASR's 
entry into the United States and to test and verify suspect cases; (2) 
USDA's strategy for minimizing the effects of ASR now that the fungus 
has arrived in the United States; and (3) the progress that USDA, EPA, 
and others have made in developing, testing, and licensing fungicides 
to treat ASR and in identifying and breeding ASR-resistant or -tolerant 
soybeans. We provided your staff with a formal briefing on our findings 
on April 28, 2005. In that briefing, we cited USDA's lack of funding 
for ASR oversight as an area of concern. On May 12, 2005, the Secretary 
of Agriculture announced that USDA will use about $1.2 million in 
contingency funding to help monitor, report, and manage soybean rust 
during the 2005 growing season. This report summarizes the results of 
our April 28TH briefing, and enclosure I presents our briefing slides.

To respond to your questions, we met with USDA and EPA officials and 
visited state, industry, and soybean association officials and 
university extension faculty in Georgia, Indiana, Iowa, Louisiana, and 
Minnesota. We selected these states to provide geographic 
representation of states where soybeans are grown. We also conducted a 
survey of 31 soybean-producing states in April 2005. Enclosure II 
describes our scope and methodology, and enclosure III presents our 
survey results. We performed our work from December 2004 through April 
2005 in accordance with generally accepted government auditing 
standards.

In summary, we found the following:

In May 2002, after ASR was identified in Brazil, USDA began planning 
for the introduction of ASR into the continental United States. Three 
USDA agencies--the Animal and Plant Health Inspection Service (APHIS), 
the Cooperative State Research, Education, and Extension Service 
(CSREES), and the Agricultural Research Service (ARS)--the National 
Plant Board, industry, and several land-grant universities formed an ad 
hoc Soybean Rust Committee. At about the same time, USDA established 
the National Plant Diagnostic Network to enable diagnosticians, state 
regulatory personnel, and first detectors to communicate information, 
images, and methods of detection for ASR and other diseases in a timely 
manner. In the fall of 2002, USDA began disseminating information and 
conducting training courses in an effort to educate growers about how 
to identify and manage the disease. In January 2004, APHIS issued a 
strategic plan that provided information on the protection, detection, 
response, and recovery from ASR. While generally comprehensive in its 
coverage of issues, the plan was not fully developed when ASR was first 
identified in the United States.

Since the initial discovery of ASR in the continental United States, 
USDA and others have increased efforts to inform growers about how to 
identify and minimize the effects of the disease. In April 2005, USDA 
issued A Coordinated Framework for Soybean Rust Surveillance, 
Reporting, Prediction, Management and Outreach. The framework includes 
a surveillance and monitoring network, a Web-based information 
management system, decision criteria for fungicide application, 
predictive modeling, and outreach efforts. We surveyed 31 soybean- 
producing states to obtain information about their efforts, in 
coordination with USDA, to prepare for and manage ASR. The states 
generally responded positively when discussing efforts to educate 
growers and others on ASR and in setting up sentinel plot monitoring 
programs. (Sentinel plots will be planted earlier than commercial 
plants to alert growers if ASR is present in their region.) However, 
some of the states reported that their diagnostic laboratories may have 
insufficient funding and/or staff to test suspected samples for ASR. In 
addition, most states indicated that they were either uncertain or did 
not believe they would have enough equipment available to apply 
fungicides to treat the disease. The American Soybean Association, 
representing many of the nation's largest soybean growers, has also 
expressed concerns about whether growers will have access to equipment 
as well as fungicides in a timely manner. Finally, USDA's Risk 
Management Agency has recently developed additional guidance on the 
actions growers must take to ensure that any losses due to ASR are 
covered under their insurance policies. However, growers have expressed 
concerns about what they need to do to demonstrate good farming 
practices in treating ASR and the documentation they must provide to 
demonstrate that they followed such practices. Further guidance may be 
needed because of the uncertainties associated in dealing with the 
disease.

USDA, EPA, and others have made significant progress in developing, 
testing, and licensing fungicides to treat ASR. As of April 2005, eight 
fungicides were registered with EPA for treating ASR. In addition, EPA 
had approved emergency exemptions for an additional 11 fungicides to 
treat ASR under section 18 of the Federal Insecticide, Fungicide, and 
Rodenticide Act. Section 18 exemptions provide designated states with 
an emergency exemption to temporarily use a fungicide. As of April 
2005, 32 states had applied for and been granted section 18 exemptions 
that are effective through November 10, 2007. USDA estimates that 
researchers are 5 to 9 years away from identifying or breeding ASR- 
resistant or -tolerant soybeans. In addition, on March 10, 2005, USDA 
removed ASR from the list of select agents and toxins, which removed 
certain restrictions and will aid ongoing research on the disease in 
the United States.

We met with USDA's Special Assistant for Pest Management Policy and 
APHIS, ARS, CSREES, the Economic Research Service (ERS), and RMA 
officials to discuss the facts in this report. We also discussed the 
report with officials in EPA's Office of Pesticide Programs. USDA and 
EPA generally agreed with the information in our report and provided 
some clarifying comments that we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution of it until 30 
days from the date of this letter. We will then send copies of this 
report to the Secretary of Agriculture and the Administrator of EPA. In 
addition, this report will be available at no charge on the GAO Web 
site at http://www.gao.gov.

If you have any questions about this report or need additional 
information, please contact me at (202) 512-3841. Key contributors to 
this report were James L. Dishmon, Jr., Chad M. Gorman, Ronald E. 
Maxon, Jr., Lynn M. Musser, and Deborah S. Ortega.

Sincerely yours,

Signed by: 

Robert A. Robinson:

Managing Director, Natural Resources and Environment:

Enclosures - 3:

Enclosure I: USDA's Preparation for Asian Soybean Rust:

Briefing for Senator Tom Harkin:
Ranking Democratic Member:
Committee on Agriculture, Nutrition, and Forestry:
United States Senate:

April 28, 2005:

Background:

In November 2004, Asian Soybean Rust (ASR) --Phakopsora pachyrhizi--was 
first discovered in the continental U.S. in Louisiana.

ASR is a harmful fungal disease that has caused economic losses in 
Asia, Australia, Africa, and South America because it decreases crop 
yield and increases fungicide costs.

Environmental factors, such as rainfall, humidity, and temperature, 
affect both the severity and incidence of ASR. Long periods of leaf 
wetness, high humidity, and temperatures between 60 and 85 degrees 
Fahrenheit are ideal for spore germination.

ASR can infect over 90 host plant species of legumes, such as dry beans 
and peas, and kudzu, which grows wild in the southern U.S.

There are no commercial U.S. soybean cultivars with resistance or 
tolerance to ASR.

Fungicides are currently the primary tools for managing ASR. However, 
growers must be knowledgeable about the various types of preventative 
and curative fungicides as well as when and how to apply them.

An April 2004 USDA study projected U.S. losses between $640m and $1.3b 
in the first year of ASR's arrival.

Objectives:

Provide Information on:

* USDA's surveillance strategy to identify and protect against ASR 
entry into the U.S.

* USDA's strategy and actions to minimize the effects of ASR now that 
it is in the U.S.

* USDA, EPA, and others' progress in developing, testing, and licensing 
fungicides to treat ASR and in developing rust-resistant or rust- 
tolerant soybeans.

Scope and Methodology:

Met with USDA and EPA officials and visited state, industry, and 
soybean association officials and university extension faculty in 
Georgia, Indiana, Iowa, Louisiana, and Minnesota.

Surveyed 31 soybean-producing states:

* Training and Education:

* Sentinel Plots:

* First Detectors:

* Laboratory Facilities and Staff:

* Fungicides and Application Equipment:

Objective 1: USDA's Preparation for ASR:

In May 2002, after ASR was identified in Brazil, three USDA agencies-- 
the Animal and Plant Health Inspection Service (APHIS), the Cooperative 
State Research, Education, and Extension Service (CSREES), and the 
Agricultural Research Service (ARS)--joined with the National Plant 
Board, industry, and several land grant universities to form an ad hoc 
Soybean Rust Committee.

In June 2002, USDA established the National Plant Diagnostic Network 
(NPDN) to allow diagnosticians, state regulatory personnel, and first 
detectors to communicate information, images, and methods of disease 
detection in a timely manner.

In November 2002, USDA began conducting training to educate growers and 
others about how to identify and manage ASR.

In January 2004, APHIS issued a strategic plan providing information on 
how to detect, respond to, and recover from ASR. The strategic plan 
appeared to be comprehensive in its coverage of issues, but ASR was 
identified in Louisiana before many aspects of the plan were fully 
developed.

In September 2004, USDA participated in a mock field exercise held in 
Minnesota to prepare for ASR.

In October 2004, USDA issued standard operating procedures for plant 
diagnostic laboratories to deal with ASR. The procedures included 
information about the symptoms of the disease; protocols for screening, 
examining, shipping, storing, and destroying ASR samples; and 
guidelines for who should be notified of the results.

USDA supported states' efforts to obtain EPA emergency fungicide 
approvals.

Objective 2: USDA's Efforts to Minimize the Effects of ASR:

In January 2005, USDA issued a draft copy of A Coordinated Framework 
for Soybean Rust Surveillance, Reporting, Prediction, and Management. 
The final framework was issued in April 2005.

The framework includes:

1. A surveillance and monitoring network,

2. A Web-based information system,

3. Decision criteria for fungicide application,

4. Predictive modeling,

5. Outreach for training, education, and disseminating information.

Training & Education:

Before the November 2004 discovery of ASR, land-grant universities had 
given over 300 presentations, programs, and workshops to educate 
growers about ASR detection and fungicides.

Since the discovery of ASR, they have given about 1,500 additional 
presentations, programs, and workshops.

In 30 of the 31 states we surveyed, training covered identification of 
ASR and "look-alike" diseases and available fungicides; 25 states 
covered ASR tracking and forecasting information; and 25 states covered 
application methods.

Sentinel Plots:

The sentinel plot program has three functions:

1. Serve as an early warning system.

2. Quantify the timing of spore production.

3. Provide means to collect data for research.

Sentinel plot data, along with data collected by mobile field 
monitoring teams and industry, will be entered into USDA's Soybean Rust 
Monitoring and Prediction System.

USDA has established a Web site that will use sentinel plot data to 
allow viewers to monitor the progress of the disease on a daily basis.

States reported that they plan to have 347 USDA plots, 516 university- 
sponsored plots, and 186 other plots.

Most states reported various factors for determining the number and 
distribution of sentinel plots. The most common factors were location 
of plot within the state and distribution of soybeans within the state. 
Only 15 states reported that scientific data, such as wind patterns, 
crop yield, or rainfall, were factors.

In most states, a combination of people will monitor the plots. The 
number of monitors that the states plan to train varied, ranging from 1 
to 300.

USDA has recommended that the states plant 320 plots at a projected 
cost of $800,000, but USDA has not yet provided funding.

The North Central Soybean Research Program (NCSRP) and the United 
Soybean Board (USB) have provided $389,000 for a sentinel plot program 
consisting of 20 plots to be established in each of 20 states.

The total amount of funding that the states anticipate receiving also 
varied. The states anticipate receiving over $500,000 from USDA and 
approximately $390,000 from the North Central Soybean Research Program 
and the United Soybean Board.

First Detectors:

The states reported that they have already trained over 5,000 first 
detectors to assist growers in their efforts to detect ASR and that 
they plan to train over 1,000 more this year.

First detectors include: extension personnel, crop consultants, 
agribusiness employees or consultants, state department of agriculture 
personnel, growers, USDA/APHIS personnel, and master gardeners.

30 states indicated that first detectors were being given instructions 
on how to prepare, and where to send, samples for confirmation of ASR.

Laboratory Facilities and Staff:

State labs have allocated $0 to $91,000 for testing samples for ASR in 
2005.

The amount of funding that the labs believe is needed to run the 2005 
ASR testing program varied, ranging from $0 to $150,000.

USDA estimates that each state will require $45,000 for diagnostic 
staff and equipment dedicated to diagnosing ASR.

States' Assessment of Laboratory Facilities and Staff for ASR Testing:

ASR testing: Sufficient staff?
Probably or definitely yes: 18;
Probably or definitely no: 7;
Uncertain: 6.

ASR testing: Sufficient funding?
Probably or definitely yes: 10;
Probably or definitely no: 7;
Uncertain: 14.

Source: GAO's analysis of state survey data.

[End of table]

Fungicides and Application Equipment:

Surveyed states reported that their growers and commercial applicators 
probably or definitely had a good understanding of:

* available fungicides (27 states),

* when to apply fungicides (23 states),

* the appropriate methods for applying fungicides for ASR (23 states).

Estimated Percent of Soybean Growers Who Own Equipment to Apply 
Fungicide:

Estimated percent: 1-25%;
Number of states: 6.

Estimated percent: 26-50%;
Number of states: 7.

Estimated percent: 51-75%;
Number of states: 3.

Estimated percent: 76-99%;
Number of states: 4.

Estimated percent: 100%;
Number of states: 2.

Estimated percent: Uncertain;
Number of states: 9.

Source: GAO's analysis of state survey data.

[End of table]

Fungicides and Application Equipment:

8 states believe there are enough commercial applicators to provide 
service to growers in their states who do not own equipment to apply 
ASR fungicide. 5 states do not believe there is sufficient equipment, 
and the remaining 17 states indicated that they were uncertain. 1 state 
did not respond.

Estimates for the percentage of soybean acreage that could be sprayed 
within 5 days following the confirmation of ASR in the states we 
surveyed ranged from a low of 20 to a high of 100 percent.

Chemical companies that manufacture fungicides approved by EPA for use 
on ASR declined to go on record with the quantities they had on hand or 
planned to manufacture.

A trade association representing crop protection chemical companies has 
stated that it believes the industry will be responsive to growers in 
managing the disease during the 2005 crop year.

The American Soybean Association has expressed concerns regarding the 
availability of fungicides.

ASR Disease Forecast/Predictive Models:

The Soybean Rust Aerobiology Prediction System is a collaborative 
project between Pennsylvania State and North Carolina State 
Universities and ZedX, Inc.

Iowa State University is developing forecast models using predicted 
daily weather data from an atmospheric model to make short-term 
predictions of ASR risk in different geographic areas.

The North American Disease Forecast Center at North Carolina State 
University will also provide ASR disease forecasts.

Crop Insurance Coverage:

USDA's Risk Management Agency (RMA) has stated that losses of insured 
growers will be covered if they follow "good farming practices.":

12 of the 31 soybean-producing states indicated the information 
provided by RMA is sufficient for use in extension presentations to 
growers on ASR; 18 were uncertain, while 1 said it is not.

RMA stated that it has recently provided insurers with guidance 
regarding what steps growers must take to insure that their losses will 
be covered.

Objective 3: Licensing Fungicides and Developing Rust-Resistant 
Soybeans:

As of April 25, 2005, 8 fungicide products (4 active ingredients) were 
registered with EPA for treating ASR in the U.S.

In addition, EPA has approved 11 fungicide products for treating ASR 
under section 18 of the Federal Insecticide, Fungicide, and Rodenticide 
Act (FIFRA). Section 18 quarantine exemptions grant three years of 
temporary use rights in specified states.

32 states have received section 18 emergency exemptions for 6 or more 
fungicide products.

Most of the states we surveyed reported that they did not have 
difficulties obtaining EPA section 18 emergency exemption approvals for 
ASR fungicides.

26 states have obtained information or consulted with officials from 
Brazil or other countries regarding lessons learned about applying 
fungicides to treat ASR.

27 states believe that growers and commercial applicators in their 
states have a good understanding of the types and product names of 
fungicides to treat ASR.

USDA estimates that its researchers will identify soybean germplasm 
with some level of rust resistance within 5 years and that industry 
will require an additional 2-4 years to develop commercial soybean 
lines with resistance.

On March 10, 2005, USDA removed ASR from the list of select agents and 
toxins, which will allow for additional research to be conducted in the 
U.S.

In April 2005, USDA issued its National Strategic Plan for the 
Coordination and Integration of Soybean Rust Research.

Areas of Concern:

USDA has not provided funding to the states for the sentinel plots. 
However, if the states do not monitor the plots as recommended, the 
quality of the data used in the forecasting systems and for future 
research could be jeopardized.

Fungicides and application equipment may be insufficient to meet the 
needs of growers if and when ASR occurs.

The predictive models have not yet been validated, and there are 
questions about the timely reporting of data.

RMA may need to issue additional guidance regarding what steps growers 
must take to insure that their losses will be covered.

Although USDA's framework is generally comprehensive, more information 
is needed regarding how it will be implemented.

[End of slide presentation] 

Enclosure II: Scope and Methodology:

To determine the U.S. Department of Agriculture's (USDA) efforts to 
develop and implement an Asian Soybean Rust (ASR) surveillance strategy 
to identify and protect against ASR's entry into the United States and 
to test and verify suspect cases, we interviewed officials from USDA's 
Animal and Plant Health Inspection Service (APHIS), Cooperative State 
Research, Education, and Extension Service (CSREES), and Agricultural 
Research Service (ARS) to identify actions that the department took 
before November 2004, when the first case of ASR was confirmed in the 
continental United States. In addition, we discussed these actions with 
USDA's Special Assistant for Pest Management Policy. We also reviewed 
pertinent documents regarding USDA's efforts to educate growers and 
others to identify, report, and test suspected cases of ASR.

To determine USDA's strategy for minimizing the effects of ASR now that 
the fungus has arrived in the United States, we interviewed officials 
from USDA's APHIS, CSREES, ARS, Farm Service Agency (FSA), and Risk 
Management Agency (RMA) to identify efforts that have been implemented 
since November 2004. We also surveyed the 31 soybean-producing states 
that were included in USDA's sentinel plot program to obtain 
information on their efforts to minimize the effects of ASR through 
education, training, surveillance, and testing. We pretested the 
content and format of the survey questionnaire with officials in four 
states. During these pretests, we asked the officials to assess whether 
the questions were clear and unbiased and whether the terms were 
accurate and precise. We made changes to the questionnaire based on 
pretest results. We also conducted site visits to Georgia, Indiana, 
Iowa, Louisiana, and Minnesota, where we met with officials from land- 
grant universities, field-based extension offices, state departments of 
agriculture, and state soybean associations and check-off boards to 
gain more in-depth information about their efforts to mitigate the 
effects of ASR.[Footnote 1] We also interviewed industry and trade 
representatives to discuss the adequacy of available fungicides and 
application equipment.

To determine the progress that USDA, the Environmental Protection 
Agency (EPA), and others have made in developing, testing, and 
licensing fungicides to treat ASR and in identifying and breeding ASR- 
resistant or -tolerant soybeans, we interviewed officials from USDA, 
EPA, and state departments of agriculture to obtain information about 
their efforts to license fungicides to treat ASR. We also interviewed 
ARS personnel as well as researchers from academia and industry and 
reviewed related reports and studies regarding efforts to identify and 
breed ASR-resistant or -tolerant soybeans.

We performed our work from December 2004 through April 2005 in 
accordance with generally accepted government auditing standards.

[End of section] 

Enclosure III: Survey of Soybean-Producing States: Preparations for 
Asian Soybean Rust: 

[See PDF for image]

Note: The total for question 6 does not equal the subtotals in 6a and 
6b because some sentinel plots will use both soybeans and non-soybean 
hosts.

Note: The total for question 11 does not equal the subtotals in 11a and 
11b because some sentinel plots will use both soybeans and non-soybean 
hosts.

[End of figure]

[End of section]

(360578):

FOOTNOTES

[1] A check-off board is an industry-funded marketing and research 
program that promotes an agricultural product.