Farmton Mitigation Bank located in Volusia County, Florida
USACE Issues New Standards for Aquatic Resource Delineation: What It Means for Mitigation Projects
When it comes to mitigation banking, clarity and consistency in aquatic resource delineation are essential. As of July 2025, the U.S. Army Corps of Engineers (USACE) has released a new set of Recommended Minimum Standards for Aquatic Resource Delineation Reports (ARDRs)—and if you’re a landowner, consultant, or developer working in Florida, these changes matter.
At The Mitigation Banking Group, we help our clients navigate the permitting maze. So, I wanted to take a moment to translate what these standards mean in real-world terms and how they support better project planning, faster verification, and stronger compliance.
Why This Update Is a Big Deal
Wetland delineation is the starting point for many regulatory decisions under the Clean Water Act. It determines how much of a site is considered jurisdictional and, therefore, regulated. But historically, the quality and format of Aquatic Resource Delineation Reports have varied widely.
The new USACE guidance introduces a national baseline of what should be included in ARDRs. While these aren’t mandatory, following them will dramatically improve the speed and accuracy of USACE verifications, which benefits everyone involved in the mitigation process.
What’s Included in the New Standards
The document outlines what a high-quality ARDR should include. A few of the key components:
- Structured reporting: From cover letter to references, everything is now clearly laid out.
- Required mapping: Location maps, aerial photos, wetland boundaries, data point GPS locations, and even cross-sections when applicable.
- Detailed field methodology: Whether you’re using the 1987 Wetlands Delineation Manual or the appropriate regional supplement, the new format ensures consistency.
- Soil, hydrology, and vegetation descriptions: Including Cowardin classifications, hydric soil documentation, and dominant plant species.
- OHWM data: Ordinary High Water Mark delineations must be supported by clearly referenced field data.
- Antecedent precipitation and climate data: Agencies now expect weather conditions and historic rainfall patterns to be accounted for in hydrology determinations.
USACE even included a helpful template to guide report formatting.
“An accurate aquatic resource delineation is fundamental to ensuring assessment of a proposed project’s impacts and determining any required mitigation,” the report states.
How This Impacts Florida Developers and Bankers
If you’re preparing to buy or sell mitigation credits, these standards add a new layer of confidence to the process. Why? Because if your delineation follows this guidance, it’s far more likely to be verified quickly by USACE, and delays cost money.
For mitigation bankers, these standards also support better marketability of your site. A well-documented and USACE-compliant delineation reassures credit buyers, especially in a market where service area boundaries are scrutinized closely.
And for consultants? This is an opportunity to show clients you’re ahead of the curve by aligning your methods with the Corps’ evolving expectations.
My Perspective
While the standards are called “recommended,” I see them as essential for anyone serious about wetland permitting and mitigation banking.
At MBG, we work with consultants, landowners, and regulators every day. These updates give us a shared foundation—a clearer playbook—to operate from. And that means fewer surprises, smoother approvals, and stronger outcomes for both people and ecosystems.
If you have a mitigation site you’d like to bring to market, or if you’re unsure how these standards apply to your property, I’m here to help.
Contact: victoria@mitigationbankinginc.com
Download the Full Standards
You can review the full USACE Recommended Minimum Standards for Aquatic Resource Delineation Reports (July 2025) on the USACE website or view the full document here.
