May 30, 2012 

TO: Linda Irokawa-Otani, Regulations Coordinator 

Department of Pesticide Regulation 

1001 I Street, P.O. Box 4015 

Sacramento, California 95812-4015 

RE: Proposed Non-Fumigant VOC Regulations

Dear Ms. Irokawa-Otani: 

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

located in the Central Valley of California, I find many problems with your proposal but I want to, first, 

focus on an article titled “Error in pesticide report impacts SJV” by Randy Segawa, Environmental 

Program Manager, DPR published on line in Farm Press Magazine on May 21, 2012 3:48pm (Exhibit 

“A” attached). 

It would appear from this article that DPR left the tabulation of the original numbers to rank armatures. It 

is obvious from the fact that numbers were only questioned by DPR senior staffers after the initial 

publication of the report; probably when “industry” began questioning the most blatant of errors. However, 

DPR must question the validity of the entire report at this point ... from the formulas used in calculating the 

VOC levels to the way growers were allocated to different ozone nonattainment areas. This mater is just 

too costly for agriculture to implement without the base assurance that the people deciphering the data 

actually knew what they were doing. I suggest DPR hire a disinterested, third party accounting firm to 

audit the numbers, formulas and processes DPR used in its original interpretation of PUR data to assure the 

entire integrity of the VOC numbers in the report; not just the most blatant mistakes. 

Secondly, 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 a 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 weed 

management. 

I 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 a pint of glyphosate will do 

nothing for resistant weeds and hard to control weeds. Paraquat is a 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 is 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. 

8246 South Crawford Ave • Reedley, California 93654 

Web Address: gtipros.com 

OFF: (559) 638-6311 

FAX: (559) 638-6314

TOOTELIAN

Crop Protection Ideas & Products that Save 

Growers Money... Since 1949

 Inc.
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 a tractor and sprayer. Have you considered 

the effect of additional VOC and air quality issues from the added spray trips? 

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

the post emergent market months of May through October. 

Sincerely, 

Greg Musson 

Greg Musson - President 
EXHIBIT “A” 

Error in pesticide report impacts SJV 

Randy Segawa, Environmental Program Manager, DPR

May 21, 2012 3:48pm 

In March 2012, the Department of Pesticide Regulation (DPR) released its annual report on 

volatile organic compound (VOC) emissions from pesticides. This report included information 

on VOC emissions based on 1990-2010 pesticide use data for five ozone nonattainment 

areas (NAAs) in California. The pesticide VOC emissions were compared to the goals 

described in the ozone state implementation plan (SIP). Since the report’s release, DPR 

found an error that primarily affects the pesticide VOC emissions for the San Joaquin Valley 

NAA in 2010. 

What error was found that requires a correction to the report? 

With the assistance of the Department of Food and Agriculture, DPR found an error in the 

pesticide use report data and VOC emissions for a single product containing bifenthrin. The 

error was in the data for Fanfare 2EC (registration number 66222-99-AA), first registered in 

California in 2006. This error caused overestimates in the use and VOC emissions for 

Fanfare. For this product, the pesticide use reports record the amount of pesticide applied as 

gallons of product. There was an error was in DPR's data processing which converted the 

gallons applied to pounds applied based on the product density. For Fanfare, the 

product density was incorrectly assigned as 67.739 pounds per gallon. 

The correct product density is 8.13 pounds per gallon. The amount of product and active 

ingredient of Fanfare applied was 8.33x (67.739/8.13) too high. 

How does this correction impact the VOC emissions estimates in the San Joaquin 

Valley?

For the San Joaquin Valley NAA during May-October 2010, DPR originally estimated that the 

VOC emissions from all bifenthrin products were 1.55 tons/day (#2 pesticide VOC 

contributor). DPR now estimates that the VOC emissions from bifenthrin products were 0.24 

tons/day. Bifenthrin products are no longer among the top 10 pesticide VOC contributors for 

the San Joaquin Valley. Total pesticide VOC emissions changed from 16.8 tons/day to 15.5 

tons/day. Relative to the 1990 base year, total pesticide VOC emissions for 2010 changed 

from an 18% reduction to a 24% reduction. The goal in the pesticide element of the SIP is at 

least a 12% reduction from 1990, equivalent to emissions no greater than 18.1 tons/day. 

There are also changes for other years and other NAAs tracked by DPR, but use of Fanfare 

was much lower in other years and NAAs, so the differences are minor. Similar relative 

changes apply to the amount of bifenthrin active ingredient reported. 

What steps is DPR taking to address this error?

DPR is revising its most recent VOC emission inventory report to correct the error for all 

years and all NAAs. DPR will also upload the corrected pesticide use report data to its 

California Pesticide Information Portal website, and other databases. DPR should complete 

the revised report in a few weeks, and complete the data uploads in a few days. This change 

will cause no revisions to DPR’s proposed regulations for VOC emissions from nonfumigant 

pesticides.