GAO-05-668R Asian Soybean Rust 

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 overwintered 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 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-668R Asian Soybean Rust 

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 landgrant 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 soybeanproducing 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 
Page 3 GAO-05-668R Asian Soybean Rust 

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. 
Page 4 GAO-05-668R Asian Soybean Rust 

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, 

Robert A. Robinson 

Managing Director, Natural Resources 

 and Environment 

Enclosures - 3
Enclosure I 

Page 5 GAO-05-668R Asian Soybean Rust 

USDA’s Preparation for Asian Soybean Rust 

1

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 
Enclosure I 

Page 6 GAO-05-668R Asian Soybean Rust 

2

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.
Enclosure I 

Page 7 GAO-05-668R Asian Soybean Rust 

3

Background

• 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.
Enclosure I 

Page 8 GAO-05-668R Asian Soybean Rust 

4

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.
Enclosure I 

Page 9 GAO-05-668R Asian Soybean Rust 

5

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
Enclosure I 

Page 10 GAO-05-668R Asian Soybean Rust 

6

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.
Enclosure I 

Page 11 GAO-05-668R Asian Soybean Rust 

7

Objective 1: 

USDA’s Preparation for ASR

• 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.
Enclosure I 

Page 12 GAO-05-668R Asian Soybean Rust 

8

Objective 1: 

USDA’s Preparation for ASR

• 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.
Enclosure I 

Page 13 GAO-05-668R Asian Soybean Rust 

9

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
Enclosure I 

Page 14 GAO-05-668R Asian Soybean Rust 

10

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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.
Enclosure I 

Page 15 GAO-05-668R Asian Soybean Rust 

11

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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.
Enclosure I 

Page 16 GAO-05-668R Asian Soybean Rust 

12

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

Sentinel Plots

• 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.
Enclosure I 

Page 17 GAO-05-668R Asian Soybean Rust 

13

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

Sentinel Plots

• 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.
Enclosure I 

Page 18 GAO-05-668R Asian Soybean Rust 

14

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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.
Enclosure I 

Page 19 GAO-05-668R Asian Soybean Rust 

15

Objective 2: USDA’s Efforts to 

Minimize the Effects 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.
Enclosure I 

Page 20 GAO-05-668R Asian Soybean Rust 

16

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

Source: GAO’s analysis of state survey data.

Sufficient funding? 10 7 14

Sufficient staff? 18 7 6

Uncertain

Probably 

or 

definitely 

no

Probably 

or 

definitely 

ASR Testing yes

States’ Assessments of Laboratory 

Facilities and Staff for ASR Testing
Enclosure I 

Page 21 GAO-05-668R Asian Soybean Rust 

17

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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). 
Enclosure I 

Page 22 GAO-05-668R Asian Soybean Rust 

18

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

• Estimated Percent of Soybean Growers Who 

Own Equipment to Apply Fungicide

Source: GAO’s analysis of state survey data.

Uncertain 9

100% 2

76-99% 4

51-75% 3

26-50% 7

1-25% 6

Estimated percent Number of states
Enclosure I 

Page 23 GAO-05-668R Asian Soybean Rust 

19

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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. 
Enclosure I 

Page 24 GAO-05-668R Asian Soybean Rust 

20

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

Fungicides and Application Equipment

• 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. 
Enclosure I 

Page 25 GAO-05-668R Asian Soybean Rust 

21

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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.
Enclosure I 

Page 26 GAO-05-668R Asian Soybean Rust 

22

Objective 2: USDA’s Efforts to 

Minimize the Effects of ASR

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.
Enclosure I 

Page 27 GAO-05-668R Asian Soybean Rust 

23

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.
Enclosure I 

Page 28 GAO-05-668R Asian Soybean Rust 

24

Objective 3: Licensing Fungicides and 

Developing Rust-Resistant Soybeans

• 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. 
Enclosure I 

Page 29 GAO-05-668R Asian Soybean Rust 

25

Objective 3: Licensing Fungicides and 

Developing Rust-Resistant Soybeans

• 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.
Enclosure I 

Page 30 GAO-05-668R Asian Soybean Rust 

26

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.
Enclosure II 

Page 31 GAO-05-668R Asian Soybean Rust 

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.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.

 

1

A check-off board is an industry-funded marketing and research program that promotes an 

agricultural product. 
Enclosure III 

Page 32 GAO-05-668R Asian Soybean Rust 

Survey of Soybean-Producing States: Preparations for Asian Soybean 

Rust 
Enclosure III 

Page 33 GAO-05-668R Asian Soybean Rust 
Enclosure III 

Page 34 GAO-05-668R Asian Soybean Rust 
Enclosure III 

Page 35 GAO-05-668R Asian Soybean Rust 

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. 
Enclosure III 

Page 36 GAO-05-668R Asian Soybean Rust 
Enclosure III 

Page 37 GAO-05-668R Asian Soybean Rust 
Enclosure III 

Page 38 GAO-05-668R Asian Soybean Rust 

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. 
Enclosure III 

Page 39 GAO-05-668R Asian Soybean Rust 
Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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Enclosure III 

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