Authors: Christopher Hassinger, Exposure Modeling Scientist, BASF and Corey Lacey Environmental Policy Manager, ISA 

The U.S. Environmental Protection Agency (EPA) developed its Herbicide Strategy to protect endangered and threatened species and their habitats from potential impacts of herbicides. Based on the properties of the pesticide, target crops and directions for use, the Herbicide Strategy determines the necessary spray drift and runoff/erosion mitigations for product use. Spray drift mitigations include drift buffers, which are influenced by nozzle selection, release (boom) height and adjuvants (DRAs). To address off-target movement via runoff/erosion, EPA established a mitigation point system in which the number of points required is based on the pesticide’s potential for moving off-target to areas of potential endangered species habitat. Eventually, all herbicide products will be assessed using the Herbicide Strategy and will be assigned mitigation point requirements. 

Source – U.S. Environmental Protection Agency

Pesticide products that have been assessed using the Herbicide Strategy will generally have between three to nine runoff mitigation points. For example, Liberty® ULTRA Herbicide requires three points, indicating it has a low runoff vulnerability. There are multiple ways to obtain points, starting with “baseline” points (as described below) and then assessing points in a sequential manner. The information and approach outlined in this article demonstrates that most Illinois soybean growers should be able to obtain nine points. 

To assist growers in achieving points, EPA developed a “reduced runoff vulnerability map,” which groups counties into the following categories based on runoff vulnerability categories of high, medium, low or very low (the number in parenthesis indicates the number of Illinois counties): 

• High: Counties receive zero mitigation points (11) 

• Medium: Counties receive two mitigation points (89) 

• Low: Counties receive three mitigation points (2) 

• Very low: Counties receive six mitigation points (0) 

These points are available for all agricultural fields within a given county with no action needed from the grower. In addition, one mitigation point is available for documenting that the mitigation point requirement has been met for the field. For example, for a low runoff vulnerability county (e.g., Piatt County), three points are given based on the runoff classification of the county and, provided that proper documentation of mitigation points is maintained, four total points are available. 

After identifying baseline mitigation points, additional points are available for field characteristics, cropping practices and active participation in runoff reduction and soil conservation programs. These points give credit for inherent properties of the fields and practices that growers have already implemented or can implement. Figure 1 shows a recommended process that growers could adopt to check for all available field points. First, the county map of Illinois, which reflects the runoff vulnerability classification from EPA, should be used to identify the county in which the application is being made. Then, for this color category and beginning with “Baseline Mitigation Points,” work down the table and begin adding up points for relevant point categories. The table provides a partial list of the most common mitigation measures for Illinois growers. Figure 1 also provides an example of a low, medium and high runoff vulnerability county and potential points based on common practices in these counties. Please note that these are provided as examples and do not necessarily apply for your fields. To track points on a field-by-field basis, EPA’s mitigation calculator should be used. Once completed, the calculator can be printed or stored electronically for documentation. 

The process outlined in Figure 1 must be done on a field-by-field basis. Only after all mitigation points have been counted for existing processes and documented should the grower consider adopting new mitigation practices (using the picklist) if additional points are needed for a specific field. If the number of points for a specific field does not meet the required points for product use, EPA’s mitigation option picklist should be consulted. 

If you have additional questions regarding how to obtain mitigation points contact Illinois Soybean Association (corey.lacey@ilsoy.org). 

Online Resources: 
EPA Mitigation Menu: https://www.epa.gov/pesticides/mitigation-menu 
EPA Mitigation Calculator: https://www.epa.gov/system/files/documents/2024-10/runoff-mitigation-calculator-tool.xlsm 
EPA Mitigation calculator user guide: https://www.epa.gov/system/files/documents/2024-10/mitigation-calculator-user-guide.pdf 
USDA Web Soil Survey: https://websoilsurvey.nrcs.usda.gov/app/