Comment Letter: Input on Improving Efficiency of the Nationwide Permit Program under Clean Water Act Section 404

EPIC submitted comments to the Army Corps of Engineers in response to the agency's solicitation on how to improve the efficiency of the Nationwide Permit (NWP) program (Docket COE-2026-0001). Our recommendations cover a range of topics: retaining the beneficial changes adopted in the January 2026 NWP reissuance (e.g., revised NWP 27 and new NWP 60 for fish passage), improving permit processing through technology upgrades to the Regulatory Request System, and increasing transparency on cumulative impacts at the watershed level.

Several of our recommendations focus on reducing unnecessary costs and delays for both applicants and Corps staff. These include automated PCN completeness checking, continued expansion of joint state-Corps applications, and an expedited pathway for compensatory mitigation projects. We also recommend reinstating a PCN requirement for mechanized land clearing that permanently converts forested wetlands, a provision that at least 12 regional condition documents across 15 or more Districts have independently adopted. EPIC’s 1-line recommendations are listed below. For more detail, read the full comment letter.