alea-institute/kl3m-data-sample-004-shuffled huggingface dataset:
Sample Letter #1

May 15,2012

Address

City, State, Zip

Linda Irokawa-Otani, Regulations Coordinator

Department of Pesticide Regulation

10011 Street, P.O. Box 4015

Sacramento, California 95812-4015

RE: Proposed Non-Fumigant VOC Regulations

Dear Ms. Irokawa-Otani:

am writing in response to your proposed VOC regulations for Non-Fumigant products. As retailer

located in the Central Valley of California, find many problems with your proposal.

First, GoalTender and other low VOC oxyfluorfen formulations are NOT viable substitutes for Goal

2XL and other EC oxyfluorfen products. My company has over 20 years experience working with Goal

2XL and over 10 years working with GoalTender. When it comes to post emergence weed control,

GoalTender is not substitute. Our experience in the field and orchard is that Goal 2XL is the only

formulation that controls hard to control weeds like malva, and helps with glyphosate resistant weeds.

have reviewed your list of "kickers" and their cost as it pertains to making GoalTender an effective^

post emergence product. Reliable data does not exist that supports your position that these "kickers"

are the answer to using GoalTender in place of Goal 2XL. Glyphosate is not an effective tank mix

partner due to the fact that glyphosate is already the foundation of the spray mix. Adding pint of

glyphosate will do nothing for resistant weeds and hard to control weeds. Paraquat is Restricted Use

Pesticide due to acute toxicity. Human toxicity and worker exposure concerns make paraquat an

extremely poor choice. The most likely "kickers" to be added to GoalTender are Rely and Treevix.

Rely costs $46/acre and was in short supply in 2012. Treevix costs $16/acre and the label recommends

the addition of Goal to broaden the spectrum. The label also recommends an "adjuvant system" for

post emergent weed control. This "system" includes methylated seed oil (MSO) plus Ammonium

Sulfate (AMS). With the additional costs of the adjuvant system, our growers cannot afford to add $20

to $50 per acre to their weed control programs.

Lastly, please allow me to comment on the administrative burden that these regulations push upon our

business and our people. Providing written information on the VOC regulations, tracking the intended

use period, providing written recommendations and maintaining records for two years adds costs to

our business. We will in turn be forced to pass these costs on to our grower customers. This is addition

to the $20 to $50 per acre calculated above.

We need Goal 2XL in our summer post emergent weed control programs. Its elimination will result in

significant cost increases and decreased weed control in orchards and vineyards. This decreased weed

control could even result in additional trips across the field with tractor and sprayer. Have you

considered the effect of additional VOC loading from additional spray trips?

We respectfully request that you find way to keep Goal 2XL and other EC formulations available

during the post emergent market months of May through October.
Best Regards,

XXXXX YYYYYY

Name

Title

Company
#### § 779.219 Unified operation may be achieved without common control or common ownership.

The performance of related activities through “unified operation” to serve a common business purpose may be achieved without common control and without common ownership. In particular cases ownership or control of the related activities may be factors to be considered, along with all facts and circumstances, in determining whether the activities are performed through “unified operation.” It is clear from the definition that if the described activities are performed through unified operation they will be part of the enterprise whether they are performed by one company or by more than one corporate or other organizational unit. The term “unified operation” has reference particularly to enterprises composed of a number of separate companies as is clear in the quotation from the Senate Report in § 779.215. Where the related activities are performed by a single company, or under other single ownership, they will ordinarily be performed through “common control,” and the question of whether they are also performed through unified operation will not need to be decided. (*Wirtz* v. *Barnes Grocer Co.,* 398 F. 2d 718 (C.A. 8).)