Comment submitted by MagrowTec

Subject: Comments on Draft Fungicide Strategy - Include Physical Spray Conditioning Technologies in Section 2.6.1 Executive Summary- EPA's Draft Fungicide Strategy appropriately recognizes drift-reducing adjuvants as mitigation measures in Section 2.6.1, but should expand this framework to include physical spray conditioning technologies that provide superior performance. MagrowTec respectfully submits these comments to highlight a proven technology that achieves 97.5% certified drift reduction - significantly exceeding the 15-50% reductions proposed for chemical adjuvants. Background on Physical Spray Conditioning Technology MagrowTec's Magnetic Assist Spray Technology (MAST) represents a fundamentally different approach to drift reduction. Rather than adding chemicals to modify spray properties in the tank, MAST uses rare earth magnetic arrays to condition spray fluid before it exits the nozzle. This physical conditioning process: • Realigns nano-particles in spray fluid to create optimized droplet behavior • Achieves consistent 70%+ drift reduction across all application conditions • Maintains or improves target coverage while reducing off-target movement • Functions independently of tank mix chemistry or water quality Performance Comparison to Proposed Adjuvants Table 1-3 in the Draft Strategy proposes buffer reductions of: • Oil emulsion adjuvants: 15-30% reduction • Guar gum adjuvants: 50% reduction MagrowTec's certified performance data demonstrates: • 97.5% drift reduction validated by Dutch TCT certification • 70% drift reduction in real-world field conditions • 20%+ coverage improvement enabling potential rate reductions Regulatory Precedent and Validation MagrowTec technology has been validated by multiple independent research institutions: • Trinity College Dublin (AMBER Research Centre) • Wageningen University & Research • ILVO (Belgium) The technology has received formal drift reduction certification and is deployed on over 350 farms globally, providing extensive real-world performance data. Specific Regulatory Request EPA should expand Section 2.6.1 to include "Physical Spray Conditioning Technologies" as a distinct mitigation category alongside chemical adjuvants. We request EPA: 1. Add new subsection 2.6.1.2 titled "Physical Spray Conditioning Technologies for Buffer Reduction" 2. Include evaluation criteria for physical drift reduction technologies in the Ecological Mitigation Support Document 3. Establish buffer reduction credits commensurate with demonstrated performance (50-75% reduction for certified technologies) Supporting Documentation Provided See attached technical dossier including third-party validation studies, certification documents, and field trial data demonstrating superior drift reduction performance.