Comment submitted by MagrowTec

Subject: Comments on Draft Fungicide Strategy - Buffer Reduction Potential for High-Performance Drift Technologies Submitted by: Kyle Bennett, Regional Director North America, MagrowTec Executive Summary EPA's proposed buffer reduction percentages in Table 1-3 should reflect the full spectrum of available drift reduction technologies. MagrowTec recommends establishing tiered buffer reduction credits that reward superior performance, potentially enabling 75%+ buffer reductions for technologies demonstrating exceptional drift control. Current Buffer Reduction Framework Table 1-3 proposes maximum buffer reductions of: • 30% for oil emulsion adjuvants (ground application, medium droplets) • 50% for guar gum adjuvants (ground application, various droplet sizes) These percentages appear calibrated to chemical adjuvant performance levels rather than maximum achievable drift reduction. Performance-Based Buffer Reduction Proposal EPA should establish tiered buffer reduction credits based on demonstrated performance: Tier 1 (Current Chemical Adjuvants): 15-50% Buffer Reduction • Oil emulsion and guar gum adjuvants as currently proposed • Performance range: 15-50% drift reduction Tier 2 (High-Performance Technologies): 50-75% Buffer Reduction • Technologies demonstrating 70%+ certified drift reduction • Consistent performance across application conditions • Third-party validation required Tier 3 (Premium Technologies): 75%+ Buffer Reduction • Technologies demonstrating 90%+ certified drift reduction • Comprehensive field validation across multiple crops/regions • Independent certification by recognized testing organizations MagrowTec Performance Data Supporting Tier 3 Classification MagrowTec's technology demonstrates performance qualifying for Tier 3 designation: • 97.5% drift reduction - Dutch TCT certified • Consistent 70%+ field performance across 350+ installations • Multi-crop validation (corn, soybeans, cotton, canola, potatoes) • Independent verification by multiple research institutions • 15+ countries deployment demonstrating broad applicability Economic Impact of Enhanced Buffer Reductions Greater buffer reductions provide significant economic benefits to growers: Current Proposed Buffer Reductions (50% maximum): • 100 ft buffer reduced to 50 ft • 10-acre field recovers ~5% additional treatable area Enhanced Buffer Reductions (75%+ for premium technologies): • 100 ft buffer reduced to 25 ft or less • 10-acre field recovers ~15% additional treatable area • Significantly improved operational flexibility Grower Adoption and Compliance Benefits Enhanced buffer reduction credits for high-performance technologies would: • Incentivize adoption of superior drift reduction technologies • Improve compliance outcomes by providing better mitigation options • Reduce implementation costs through greater operational flexibility • Advance technology development in drift reduction field Regulatory Recommendation EPA should: 1. Establish performance-based tiers for buffer reduction credits 2. Create certification pathways for technologies exceeding current performance thresholds 3. Provide maximum buffer reduction credits (75%+) for technologies demonstrating exceptional performance 4. Update Ecological Mitigation Support Document to include tiered performance framework Field Implementation Considerations Higher buffer reduction credits should include verification requirements: • Installation certification by qualified technicians • Performance monitoring protocols for ongoing compliance • Maintenance verification to ensure continued effectiveness • Field auditing capabilities for regulatory enforcement