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Recently the US Army Corps of Engineers (the Corps) has increased the level of compensatory mitigation requirements for streams impacted by surface coal mining in the Appalachian coalfields. Through new permitting requirements (Nationwide Permit 21) the Corps is requiring that applicants submit a compensatory mitigation plan that will offset permanent and temporary losses of aquatic functions and values from fill of intermittent and ephemeral streams. These changes have led to concern by the regulated community over the cost of meeting mitigation requirements. In this study a cost analysis is conducted of projects that could be considered as compensatory mitigation The study estimates total costs for fourteen projects in the areas of channel and riparian zone restoration, abandoned mine land reclamation and acid mine drainage treatment. We conclude that costs are sensitive to project types and size, and a number of regulatory design issues including the regulatory criteria for acceptable mitigation.