Clean Water Act Mitigation No Net Loss Analysis

No Net Loss in Georgia – Assessing Stream and Wetland Mitigation in the Army Corps’ Savannah District

In 2017, River Basin Center staff completed a first of its kind analysis showing that the U.S. Army Corps Savannah District is failing to meet the critical national policy of “no net loss” for streams.  Fortunately, Savannah District regulatory personnel incorporated recommendations from the accompanying report into newly proposed standards for permitting that, if adopted and properly implemented, should rectify most of the major issues we identified.  In a nutshell, the no net loss policy dictates that Army Corps Districts should offset stream and wetland impacts permitted under Clean Water Act Section 404 through compensatory mitigation activities such as restoration.  At the very least, Corps Districts should be requiring compensatory mitigation at a 1:1 aerial ratio – for every foot or acre of stream or wetland impacted, a foot or acre should be mitigated.  Through a comprehensive permit and GIS analysis, RBC staff found that, in the Savannah District, for every acre of wetland impacted through a Section 404 permit, 1.8 acres are mitigated, but for every foot of stream impacted, only 0.36 feet are mitigated.

The report for this project, No Net Loss in the U.S. Army Corps Savannah District, includes a comprehensive review of applicable regulations, our technical process and results, and recommendations for the Savannah District.

This project was funded by the Georgia Environmental Restoration Association (

Stream restoration site at the Wahachee Creek mitigation bank in the Upper Savannah Watershed. (c) Mitigation Management, Inc.