Understanding whether runoff mitigation is required is one of the most important — and often misunderstood — aspects of pesticide application under the EPA’s new ESA-driven compliance framework. The EPA provides a structured determination process through the Mitigation Menu.

Key Points Up Front

• Verify if the product label or bulletin requires runoff/erosion mitigation points
• Unless the field qualifies for a mitigation exemption under Step 3
• It is the applicator’s legal responsibility to document:
  • whether mitigation points WERE required
  • or WHY they were not required
  • if required, must document which mitigation options were used to achieve the required number of points

It's important that applicator's and consultants work closely with the growers they serve to understand what fields will require runoff mitigation and the options available for each field. ESA compliance adds addtional nuance to the challenges applicators face, given that in many cases the grower is the only individual that can answer the mitigation options. However, the applicator bears full responsibility if an application takes place without the required mitigation points.

Step 1 — Plan application needs for the growing season or year

Before the season begins, document:

• What crops will be planted
• Which pesticide products will be used
• Which of those products require runoff mitigation
• Whether the label instructs a BLT (Bulletins Live! Two) lookup for PULA status
• Whether certain uses involve aerial, ground boom, chemigation, etc.

Step 2 — Check whether the label or BLT bulletin specifies required runoff points

Products may contain statements such as:

“TWO mitigation points are required for all crops listed on this label.”

or

“As this crop use is located within a PULA, X TOTAL points of runoff/erosion mitigation must be achieved…”

If your product DOES NOT specify a runoff mitigation point requirement —
then runoff mitigation does not apply for that application.

If YES — mitigation is required → proceed to Step 3.

Step 3 — Determine whether the application is exempt from mitigation

Runoff mitigation is NOT required if ANY of the following are true:

• The field has a perimeter berm system
• The field maintains tailwater recovery or recirculation
• The field has subsurface tile drains with a controlled outlet
• The pesticide is applied as a soil injection
• The pesticide is applied as a tree-injection
• The pesticide is applied via subsurface chemigation
• The treatment area is < 1,000 sq ft
• The total treated field area is < 0.1 acre
• The required drift buffer falls entirely onto agricultural managed areas (as defined in mitigation guidance)

If ANY ONE of these conditions is true → no runoff mitigation points are required.

If NONE are true → runoff mitigation points are required.

Step 4 — If mitigation is required, select measures from the EPA Mitigation Menu

Mitigation practices are categorized into functional types and assigned point values.
Examples include:

County Runoff Relief Points

These are county level points ranging from 0 - 6.

Related: What are County Runoff Relief Points

Vegetated Filter Strips (VFS)

These are vegetated buffer strips that filter overland flow and reduce sediment/pesticide movement.
They provide points depending on width and design quality.

Cover Cropping or Continuous Ground Cover

Reduces soil erosion, improves water infiltration, and limits surface movement of residues.

Controlled Subsurface Drainage

Tile drainage with controlled outlet allows retention of storm surges and sediment.

Conservation Tillage

Reduces exposed soil and improves infiltration.

Berms and Infiltration Structures

Physical barriers that prevent water from leaving the field boundary.

Tailwater Recovery Systems

Capture runoff and allow it to re-enter irrigation systems or infiltration storage.

Each mitigation measure carries a point value, and applicators may combine them to reach the required total.

Practical Compliance Guidance

For every treated field, operators should be able to document:

This documentation should be stored along with the application record or through tools such as the Acre Blitz compliance registry.

Reminder on Legal Standing

Failure to meet mitigation requirements is a label violation —
and therefore a federal violation under FIFRA and ESA.

Applicators must be able to demonstrate:

• They checked BLT within the required timeframe
• They determined PULA status
• They determined whether runoff mitigation was required
• They selected appropriate mitigation strategies when needed

Acre Blitz Support

Acre Blitz simplifies compliance by allowing users to:

• Check PULA status automatically
• Retrieve applicable limitations
• Determine required runoff points
• Verify field-level mitigation exemptions
• Document mitigation measures and point totals
• Export compliance records for audit or inspection

👉 Integrate the PULA Check API into your platform