Comment submitted by Dr. Premjit Halarnkar, Loveland Products, Inc.

Loveland Products, Inc. (LPI) would like to comment on the role of adjuvants containing the Leci-Tech technology. For over 20 years, LPI has marketed adjuvants that contain an unique technology that aids in spray drift reduction and LPI would like to emphasize its importance. Several of LPI’s adjuvants (LI 700, Liberate, WeatherGard Complete) are based on the Leci-Tech technology which has lecithin as the main component. Lecithin, derived from soy, is a lipid material belonging to the phospholipid class. Since phospholipids have both hydrophobic and hydrophilic elements (polar lipids), the adjuvants containing the Leci-Tech technology work well with both oil-soluble and water-soluble pesticides. Several studies have shown that Leci-Tech technology provides many benefits including increased spreadability of the active ingredient, improved adhesion to the target surface and droplet size management. Droplet management is one of the key factors in controlling drift and off-target spray. Spray nozzles produce a range of droplet sizes depending on the type of nozzle and pressure. Studies have demonstrated best spray performance if the droplets are between 150 and 500 microns. Droplets below 150 microns are considered “fines”, which can result in off-target movement call “Drift”. Droplets above 500 microns have a negative impact on coverage, ability to adhere to the plant surface and ultimately affect performance of the spray application. Several studies have demonstrated that Leci-Tech technology reduces “fines”, the volume of spray droplets below 150 microns without increasing the volume above 500 microns, resulting in more uniform droplet size and enhanced target coverage. This in turn reduces off-target spray movement and eliminates the need for re-sprays due to poor coverage. LPI believes that adjuvants based on the Leci-Tech technology could play a key role in the overall spray drift reduction scenario.