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The checklists below summarize the requirements for the different pesticide dischargers. However, the checklists don't take the place of reviewing the permit to ensure you understand and comply with the permit requirements.

Large entity pesticide dischargers

If you are a large entity required to submit a notice of intent (NOI), you must complete additional permit requirements. A large entity is: 

  • Public entity that serves a population of greater than 10,000


  • Private enterprise that exceeds the Small Business Administration (SBA) size standard as identified at 13 CFR 121.201. The SBA, for most industries, uses the average number of employees over the past 12 months, or average annual receipts over the past three years to determine business sizes.

To determine whether your business is considered a large entity for this permit, visit the Small Business Administration website.

Pesticide discharge management plan (PDMP)

If you must submit a NOI and are considered a large entity, you must prepare a pesticide discharge management plan (PDMP). The PDMP documents your evaluation and selection of control measures. The plan may include multiple treatment areas, but separate plans must be prepared for each type of pesticide application activity — for example, separate plans are required if you are treating for mosquitoes and forest canopy insect pests.

Section 4 of the permit details the requirement for the PDMP, but we also provide a summary:

In your PDMP, you may refer to procedures in other documents that meet the requirements of this permit. Keep a copy of relevant portions of those documents with your PDMP and make them available for review if requested.


If you know before starting pesticide applications that you will exceed a threshold, you must develop a PDMP before the first pesticide application. If you did not know until after starting pesticide applications that you would exceed a threshold, you must develop a PDMP before exceeding the threshold.

If you are applying pesticides in response to a declared pest emergency situation that will cause you to exceed a threshold, you must develop a PDMP no later than 90 days after responding to the declared pest emergency. These timelines are the same as the timelines for submitting your NOI (Step 2). 

Annual reporting

Large entities that submit a NOI must also submit an annual report by February 15 for all activities occurring during the previous year that are covered under this permit. If you do not apply pesticides under this permit for the year, you may check "No Discharge" on the annual report form.


In addition to the recordkeeping required for all operators, large entities that exceed a threshold must also retain a copy of the PDMP and annual reports. Large entities must also record action thresholds and methods used to determine them. You must document the records no later than 15 days following pesticide application, and they must be retained for 5 years.