USACE Directs Growing Role of Mitigation Banking for Navigation Projects

A new memorandum from the Department of the Army signals stronger federal support for the use of mitigation banking in navigation and dredging projects across the United States. The February 23, 2026 directive from the Office of the Assistant Secretary of the Army for Civil Works instructs the U.S. Army Corps of Engineers (USACE) to more fully utilize mitigation banks to improve the efficiency and environmental outcomes of navigation projects. See memo

The memo explains that traditional project-specific mitigation often slowed the delivery of navigation projects and increased costs. These approaches frequently require extensive planning, long timelines, and long-term management commitments that can delay construction without necessarily producing optimal ecological outcomes. In contrast, mitigation banking provides a proven, market-based alternative that consolidates restoration efforts into larger, professionally managed projects.

Under the new policy direction, the Corps is encouraged to treat mitigation banks as the preferred option for meeting mitigation requirements whenever feasible. The memorandum also directs the agency to explore ways to streamline the permitting of mitigation banks, noting that lengthy approval timelines have historically discouraged their development.

Importantly, the guidance highlights how mitigation banks can help expand dredged material placement capacity and improve planning for major navigation projects. Incorporating mitigation banks into dredged material management strategies can also enable non-federal sponsors to plan restoration efforts in advance of future federal investments.

For the mitigation industry, the directive represents a significant reaffirmation of the federal government’s long-standing preference for mitigation banking as the most effective tool for delivering environmental restoration at scale. Read the full Memorandum from USACE