This dashboard shows the average annual baseline (left) and estimated change (right) in permitted freshwater wetland impacts and jobs, and changes in flood protection from the average annual acreage of impacts. It is based on EPIC analysis of USACE freshwater wetland permits from FY2016 to FY2023. The changes reflect proposed changes to the definition of Waters of the United States (WOTUS) released by the Trump Administration in November 2025 and September 2026. Choose a proposal in the dropdown on the right. For more information, see the Methods and assumptions tab.

Freshwater wetland acres

Average annual values. Freshwater wetlands only. Tidal wetlands and streams are not included.
NATIONALLY
Baseline: Pre-Sackett
Impacts needing permits 1
3,622 acres required permitting in states that rely on federal WOTUS or have limited protection
An additional 4,440 acres required permitting in states with their own broad wetland protection laws.
Decrease in acres needing permits 1
-3,046 acres (-84%) require permitting
States with their own broad wetland protection laws: no change.
AT THE STATE LEVEL
Baseline: Pre-Sackett
Proposal map
Baseline map
Drag the slider to compare. The baseline map shows all states. Proposal maps show decreases. States with broad coverage of non-WOTUS waters are gray. All maps use the same color scale.
1 EPIC analysis of USACE pre-Sackett permit data, averaged over 8 years; based on methodology of Dr. Chris Samoray, in "A Counterfactual Analysis of Sackett on Compensatory Mitigation for Wetlands in North Carolina" (unpublished).
Percent changes are from the baseline in states that rely on federal WOTUS or have limited protection.

Flood protection

Freshwater wetlands only. Tidal wetlands and streams are not included. Flood protection lost is over 25 or 50 years from one year of permitted impacts.
NATIONALLY
Baseline: Pre-Sackett
Flood protection lost 3
No flood protection lost. The baseline is the starting point for the change.
Flood protection lost 3
-$4.98M to -$16.60M
Lost over 25 years from one year of permitted impacts
Low end: NFIP-covered losses. High end: all residential losses.
Flood protection lost over 25 years. Switch to:
AT THE STATE LEVEL
Baseline: Pre-Sackett
Proposal map
Baseline map
Drag the slider to compare. The baseline has no flood protection lost. State labels show flood protection lost over the chosen horizon from one year of permitted impacts (NFIP-covered losses to all residential losses). Colors use the NFIP-covered value. The low end is the study's value, based on National Flood Insurance Program (NFIP) claims. Only 30% of expected annual flood losses are insured by the NFIP (Gourevitch et al. 2026, citing Amornsiripanitch et al. 2025), so the high end scales the low end by 1 / 0.30. AK and HI are outside the study area. Both horizons use the same color scale.
3 Based on Gourevitch et al. 2026 (non-paywall PDF available here). See Methods and assumptions for more detail.
Percent changes are from the baseline in states that rely on federal WOTUS or have limited protection.

Jobs

Average annual values. Freshwater wetlands only. Tidal wetlands and streams are not included.
NATIONALLY
Baseline: Pre-Sackett
Jobs associated with mitigation 2
4,197 jobs were associated in states that rely on federal WOTUS or have limited protection
An additional 5,212 jobs were associated in states with their own broad wetland protection laws.
Job loss associated with decreased mitigation 2
-3,406 jobs (-81%)
States with their own broad wetland protection laws: no change.
Jobs use each state's average credit price. Switch to:
AT THE STATE LEVEL
Baseline: Pre-Sackett
Proposal map
Baseline map
Drag the slider to compare. Jobs are total jobs (direct, indirect, and induced) supported per year by mitigation spending (BenDor et al. 2023). These are gross effects on the mitigation industry, not net effects on the economy. All maps use the same color scale.
2 Based on BenDor et al. 2023.
Percent changes are from the baseline in states that rely on federal WOTUS or have limited protection.

National highlights

Average annual values. Freshwater wetlands only. Tidal wetlands and streams are not included.
NATIONALLY
Baseline: Pre-Sackett
Impacts needing permits 1
3,622 acres required permitting in states that rely on federal WOTUS or have limited protection
An additional 4,440 acres required permitting in states with their own broad wetland protection laws.
Decrease in acres needing permits 1
-3,046 acres (-84%) require permitting
States with their own broad wetland protection laws: no change.
Jobs associated with mitigation 2
4,197 jobs were associated in states that rely on federal WOTUS or have limited protection
An additional 5,212 jobs were associated in states with their own broad wetland protection laws.
Job loss associated with decreased mitigation 2
-3,406 jobs (-81%)
States with their own broad wetland protection laws: no change.
Jobs use each state's average credit price. Switch to:
Flood protection lost 3
-$4.98M to -$16.60M
Lost over 25 years from one year of permitted impacts
Low end: NFIP-covered losses. High end: all residential losses.
Flood protection lost over 25 years. Switch to:
1 EPIC analysis of USACE pre-Sackett permit data, averaged over 8 years; based on methodology of Dr. Chris Samoray, in "A Counterfactual Analysis of Sackett on Compensatory Mitigation for Wetlands in North Carolina" (unpublished).
2 Based on BenDor et al. 2023.
3 Based on Gourevitch et al. 2026 (non-paywall PDF available here). See Methods and assumptions for more detail.
Percent changes are from the baseline in states that rely on federal WOTUS or have limited protection.

State table

Methods and assumptions

Key assumptions

  • Freshwater wetlands only. Tidal wetlands and streams are not included.
  • Permitted impacts no longer needing permits: the method is based on Dr. Chris Samoray, “A Counterfactual Analysis of Sackett on Compensatory Mitigation for Wetlands in North Carolina” (unpublished). It used elements of the methodology of Dr. Adam Gold. Gold’s research, “How wet must a wetland be to have federal protections in post-Sackett US?” (Science, 2024), informed the proxy for which wetlands keep protection.
  • Nov 2025 Proposal: wetlands that are at least semipermanently flooded (NWI Semipermanently Flooded and Permanently Flooded) remain WOTUS, following Gold (2024).
  • Sept 2026 Proposal: we used the NWI Permanently Flooded water regime as the proxy for wetlands that would remain WOTUS, following Gold (2024). The proposal limits “relatively permanent” waters to those that are perennial, with allowances for temporary interruptions (e.g., drought, a regular dry spell, or low tide). We did not model these allowances (e.g., using the US Drought Monitor).
  • State protection levels: we started with ELI’s 2023 categorizations, and made changes due to developments since 2023. States that rely on the federal WOTUS definition: AK, AL, AR, GA, HI, IA, ID, KS, KY, LA, MO, MS, MT, NC (NC SB 582, 2023), ND, NE, NV, OK, SC, SD, TX, UT. States with limited coverage of non-WOTUS wetlands: AZ, IL, IN, NM (NM SB 21, 2025), OH, TN (TN SB 670, Oct 2025), WV, WY. Changed to ‘states with broad non-WOTUS protection’: CO (CO HB24-1379, 2024), DE (DE SB 9, 2026).
  • Impacts in categories that would no longer be covered are removed at 100% in states that rely on WOTUS and 50% in states with limited coverage. States with broad coverage of non-WOTUS waters are not included in the changes.
  • Source data are Corps permit data (ORM) for freshwater wetland impacts from FY2016 to FY2023 (Oct 2015 to Sept 2023), divided by 8 years to get average annual values. Permits that did not require compensatory mitigation are not in the source data.
  • We assume permitted impacts occur as reported. Impacts without a permit, or beyond the permitted amount, are not included.
  • For coastal states that do not have a state wetland protection law, we did not account for freshwater coastal wetlands that may keep protection under state coastal management programs (e.g., programs approved under the Coastal Zone Management Act).
  • Dollars are in Nov 2025 dollars.

Jobs

  • Mitigation spending = credits (ORM) x the state price per credit, plus PRM acres x the PRM cost per acre. PRM cost per acre = 75% x the state price per credit x the state credits per acre (RIBITS). The 75% is a rough estimate.
  • Jobs = spending x total jobs per $1 million of direct output (BenDor et al. 2023, “Assessing the size and growth of the US wetland and stream compensatory mitigation industry”; 2019 industry data, converted to Nov 2025 dollars). These are gross effects on the mitigation industry, its suppliers, and household spending by its workers. They are not net effects on the economy.
  • The price switch changes the state credit price used (median, average, or high). It changes jobs only. Credit prices come from EPIC’s credit price data. Individual prices are confidential and not shown.

Flood protection

  • Flood values come from Gourevitch et al. 2026, “The economic value of wetlands in reducing riverine flood losses in the USA” (non-paywall PDF available here). The study estimated the value of wetlands in reducing riverine flood losses to residential properties (1-4 units) for every HUC12 subwatershed in the lower 48 states.
  • The values cover riverine flooding and residential properties (1-4 units) only.
  • 25 and 50 years: wetlands affected by permitted fill are lost permanently, so their flood protection is lost every year after the impact. We report this loss over 25 and 50 years, which reflects typical lifespans of permitted projects. A 25- to 50-year horizon is reasonable because projects like pipelines, roads, and residential housing are generally built with at least this lifespan in mind. Because the permit data indicate a permanent loss, these horizons are conservative.
  • Losses in later years are discounted at 2% per year, following the study. Values are present values in Nov 2025 dollars. The study reports values over an unlimited time horizon. The first 25 years make up 39% of that value, and the first 50 years make up 63%.
  • All values reflect one year of permitted impacts. Each additional year of permits adds a loss of similar size, assuming similar permit volume.
  • Range: the low end is NFIP-covered losses (the study’s values). The high end is all residential losses. Only 30% of expected annual flood losses are insured by the NFIP (Gourevitch et al. 2026, citing Amornsiripanitch et al. 2025), so the high end scales the low end by 1 / 0.30.
  • State values are averages of the study’s subwatershed values, weighted by the wetland area that would lose jurisdiction under each proposal. Values at the actual impact locations may differ.

Other

  • States with no reported acreage are treated as zero: AK, HI.
  • AK and HI are outside the flood study area.
  • Louisiana credits are split by Corps district. New Orleans District credits use LA prices. Vicksburg District credits use MS prices.