-
Jul 23, 2025Endangered Species Act Considerations for the Coming Season
As you plan for the season, it’s important to know how EPA’s new Endangered Species Act risk mitigations might impact pesticide planning and use.
As EPA registers new pesticides or reviews registrations of existing ones, they evaluate expected impacts on federally listed threatened and endangered species. When a pesticide is predicted to adversely affect a listed plant or animal species or their critical habit, one or both of two outcomes are possible:
- Broad label requirements to reduce potential impacts of pesticides on listed species and other non-target organisms by reducing runoff and/or spray drift.
- Geographic-specific use limitations communicated through
As you plan your pesticide program, be sure to review current product labels to anticipate any endangered species requirements.
Runoff Mitigation Points
• Does the pesticide require runoff / soil erosion mitigation points? Check the pesticide label. (Tip: Look for a header such as “Mandatory Runoff Mitigation” or search for the word “points.”)
• Exemptions. No points are needed for fields with systems that capture runoff and discharge, certain application methods such as soil injection, spot treatment < 1,000 sq. ft., or chemigation applied under non-permeable plastic mulch.
• Yuma County applications qualify for 6 mitigation relief points.
• If more points are required, consult EPA’s Mitigation Menu website and consider using their Worksheet to ensure adequate points can be attained to use the pesticide. Mitigation points are based on several factors, field characteristics, participation in conservation programs, application parameters, and more.
Endangered Species Bulletins
• Is an Endangered Species Protection Bulletin required? Check the label under “Directions for Use.” If required, access the Bulletins Live! Two website. Enter or navigate to the application site using the map; select month and year of application; enter the product EPA Registration Number.
• Print bulletin. If a Pesticide Use Limitation Area (PULA) appears in the map view, click the colored area of the PULA to turn the red “Printable Bulletin” button green. Click the green button to download or print the bulletin.
• If your field(s) are located inside a Pesticide Use Limitation Area (PULA), follow the bulletin guidelines for limitations on pesticide use. If your fields are outside the PULA, follow label requirements and keep a copy of the bulletin for your records.
• PULAs in Yuma are found along the Colorado and Gila Rivers in production areas for certain Dicamba products. These require both a 310-foot in-field wind-directional spray drift buffer and a 57-foot omnidirectional in-field buffer for fields found within the PULA.
• Plan ahead. You can access and print Bulletins up to 6 months prior to an application. Consider entering registration numbers for the main pesticides in your program, then generate a bulletin for each month and year you expect to apply the pesticide. Keep these with your records in case an application is needed.
Want a Deep Dive on This?
There will be a Laws & Regulations CEU opportunity on September 3 in Yuma, where this topic will be covered in detail.
- 4 CA DPR L&Rs CEUs and 4 AZ CEUs (pending approval)
- This is a great chance to learn how to stay compliant and ask questions directly.
To contact John Palumbo go to: jpalumbo@ag.Arizona.edu