EPA Seeks Public Comment on Qualifying Process for Conservation Programs and Experts to Aid Growers Using EPA’s Mitigation Point System to Manage Pesticide Runoff and Erosion
U.S. Environmental Protection Agency (EPA) is seeking public comment on a proposed process to review and qualify conservation programs and experts that have technical expertise in runoff and erosion measures. Establishing a list of qualified conservation programs and experts will help growers find trusted guidance to help them control pesticide runoff and erosion on their fields. This effort will support EPA’s mission to keep pesticides out of America’s rivers, streams, and communities, by making it easier for growers to use proven practices that protect soil, water, wildlife, and human health at the same time.
Every program and expert will need to meet clear, science‑based standards that show they can reduce runoff and erosion in a real and measurable way. Programs or experts that do not sufficiently enhance environmental protections will not qualify.
This proposal is also designed to reduce confusion and paperwork for growers without weakening protections. By giving credit for strong conservation practices that many farmers already use, EPA is rewarding good actors who are already using good stewardship practices to reduce pesticide exposures.
In its final Insecticide Strategy, EPA made one qualified conservation plan available to farmers to ease compliance. This proposed process is the first step to making more plans available that meet runoff and erosion mitigation requirements. EPA will explain how plans and practices are scored and will update them as new science becomes available, so that the system stays protective over time.
EPA’s Mitigation Point System
EPA has developed several strategies to improve protection for listed species and meet its Endangered Species Act obligations. As part of these strategies, EPA adopted a mitigation point system that clearly sets the level of runoff and erosion mitigation required for a pesticide to reduce exposure to non-target organisms, including threatened and endangered species. A point in this system stands for a specific level of expected risk reduction, based on current science. When protection is needed, EPA will assign each pesticide product points to reduce the level of exposure from runoff and erosion. These mitigation requirements appear on product labels and bulletins for the pesticide product in the Bulletins Live! Two System. Before applying a pesticide product, growers would need to adopt the mitigation measures selected from EPA’s Mitigation Menu that meet or exceed the number required on the label or bulletins.
Growers can achieve points based on:
- The number and type of runoff or erosion mitigation measures implemented on a treated field.
- Field characteristics or application parameters (for example, being in a county with low runoff vulnerability, having a flat field slope, using micro-sprinklers, or treating only a small portion of the field).
- Participation in a qualified conservation program.
If finalized, this proposal would give landowners and growers credit for measures they may have already taken, such as cover crops or grassed waterways, instead of making them start from scratch. This helps farmers who are already investing in soil health and environmental stewardship.
What EPA is Proposing
- Provide growers credit for implementing mitigation practices (such as vegetative filter strips or field terracing) under a qualified conservation program if that program helps growers to achieve at least nine points on their fields.
- Recognize that experts, who are well-versed in advising growers on runoff mitigation, erosion reduction measures and EPA’s Strategies, can assess existing field conditions for characteristics that may lead to reduced runoff or erosion. A technical expert could assess a field for anywhere from zero to nine or more points so that a grower would have some form of documentation that could be provided to commercial applicators to know what points are already on the field to ensure a pesticide product is applied in compliance with its labeling (including the designated point value).
- Conservation programs and technical experts would be able to apply to become “EPA Qualified” through EPA’s website. Qualifying conservation programs and technical experts represent an additional step the agency is taking to increase protections for endangered species and habitats while also reducing burdens to growers.
Comments can be submitted to docket ID EPA-HQ-OPP-2025-1906 at www.regulations.gov. Upon publication of a Federal Register notice, the agency will extend the current comment period for 30 days until April 6, 2026.