Nationwide Permit 25 authorizes discharges of material such as concrete, sand, rock, or other fill into tightly sealed forms or cells where the material will be used as a structural member for standard pile-supported structures. These structures include bridge footings, transmission line footings, and various types of piers. It also covers discharges into structural members such as piling or columns, provided the activity does not result in the expansion of the structural member's footprint. The permit is designed for small-scale construction activities that require the placement of fill within a confined space to create structural stability. Its scope is limited to discharges incidental to the construction of these structural members and does not authorize general site development fills or the construction of entire large-scale facilities like dams or embankments.
The 2026 reissuance of NWP 25 maintains the same national terms and conditions as the 2021 version with no substantive changes to the authorized activities or discharge requirements. The Corps reevaluated the permit's potential impacts and determined that the existing framework remains sufficient to ensure authorized activities result in no more than minimal individual and cumulative adverse environmental effects. While the regulatory text remains consistent, the supporting decision document was updated with current environmental baseline information. This includes results from newer national-level ecological assessments, such as the 2022 National Lakes Assessment and the 2021 National Wetland Condition Assessment, to ensure the permit's re-evaluation is based on the most recent scientific data available.
Compliance managers, civil engineers, and construction contractors for utility and transportation projects typically use this permit. It is required for teams installing pile-supported infrastructure where concrete or other fill must be discharged into forms or structural members located in jurisdictional waters.
The Corps determined that reissuing NWP 25 has 'no effect' on federally-listed endangered or threatened species or their critical habitat. This finding is supported by general condition 18, which requires project-specific ESA Section 7 consultation if an activity 'might affect' listed resources; no activity is authorized until the consultation process is complete. Compliance with Section 106 of the National Historic Preservation Act is ensured through general condition 20, which triggers mandatory Pre-Construction Notification (PCN) for activities with the potential to affect historic properties. For Essential Fish Habitat (EFH), the Corps found that district engineers can apply regional or activity-specific conditions to ensure authorized structural discharges do not cause more than minimal adverse effects.
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