Comment submitted by Brad DeBels

I wanted to first thank you for your time to discuss the new product registration opportunity from Corteva Agriscience, which I know you are well aware of. I am the current Vice President of Operations at Weed Man Lawn Care, leading approximately $100 million in lawn care services across 35 offices nationwide. While lawn care has been my devotion for the previous 12 years, I conducted product research at the University of Wisconsin and have also served as President of the Wisconsin Turfgrass Association. I hope those experiences offer some credence to my thoughts below. The current political and economic environment, considering ESA and forever chemicals, has created bottlenecks in product approval within the green industry. While I agree that all considerations need review, it is important we maintain an open lane for scientific product advancement. In the last decade, we have seen a trend of offering products that reduce risks to human and environmental safety, while more specifically targeting pests. Things like reduced odor, lower active ingredient application rates, more specific pest targeting and reduced risk. Truly great innovation that has helped us as lawn care operators. Corteva Agriscience currently has two products in its Rinskor line, including the tradename herbicides CenterCourt and KurtainCall. Both products continue the trend of improved targeted invasive weed control for some of the most common weeds, offering reduced risk benefits. This line of chemistry already received recognition from the EPA for its reduced-risk attributes, along with other manufacturing and research and development groups. I believe both of these products will benefit the green industry and warrant review and approval for use. We continue to see products being taken off of the market, we must continue creating a space for reduced risk products, like the Rinskor line, to ensure green industry operators like myself have the tools necessary to provide clients with spaces safe of invasive species. I appreciate your commitment to the industry and look forward to hearing back from you regarding the opportunity to move forward with the Rinskor line.