Comment submitted by MagrowTec

Subject: Comments on Draft Fungicide Strategy - Expand Appendix F to Include Non-Chemical Mitigation Technologies Submitted by: Kyle Bennett, Regional Director North America, MagrowTec Executive Summary Appendix F of the Draft Fungicide Strategy focuses exclusively on chemical adjuvants for spray drift mitigation. MagrowTec recommends EPA expand this framework to include proven non-chemical technologies that offer superior environmental and economic benefits while achieving greater drift reduction. Limitations of Chemical-Only Approach The current framework in Appendix F limits mitigation options to chemical additives, which present several challenges: • Environmental Load: Additional chemicals in spray mix increase environmental burden • Compatibility Issues: Tank mix compatibility varies across pesticide formulations • Weather Dependency: Performance varies with humidity, temperature, and water quality • Recurring Costs: Continuous purchase and handling requirements • Storage/Disposal: Chemical storage, packaging waste, and disposal considerations Physical Technology Advantages Physical spray conditioning technologies like MagrowTec's MAST offer distinct advantages: • Zero Environmental Impact: No additional chemicals introduced to environment • Universal Compatibility: Works with all pesticide formulations without tank mix concerns • Consistent Performance: Weather and water quality independent operation • One-Time Installation: 15+ year lifespan with minimal maintenance • Enhanced Efficacy: Superior drift reduction enables greater buffer reductions Economic Analysis Lifecycle cost analysis demonstrates significant economic advantages of physical technologies: Chemical Adjuvant Costs (per 1,000 acres annually): • Oil emulsion adjuvants: $750-2,250/year • Guar gum adjuvants: $500-1,500/year • 10-year cost: $5,000-22,500 MagrowTec Physical Technology: • One-time installation: $45,000-$55,000 • 15-year lifespan with no recurring costs • ROI typically achieved in 8-18 months Regulatory Framework Recommendation EPA should establish a new mitigation category in Appendix F for "Physical Spray Conditioning Technologies" with evaluation criteria including: 1. Performance Standards: Minimum drift reduction thresholds (e.g., 70%+ certified reduction) 2. Third-Party Validation: Independent testing and certification requirements 3. Installation Verification: Field verification of proper installation and function 4. Buffer Reduction Credits: Performance-based buffer reduction percentages Implementation Pathway We recommend EPA: 1. Issue guidance on evaluation criteria for physical drift reduction technologies 2. Establish certification pathways for non-chemical mitigation technologies 3. Update Mitigation Menu to include physical technology options 4. Provide technical assistance to growers on technology selection and implementation