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Commissioners debate lower 2:1 mitigation minimum for degraded ESHA
Summary
Staff proposed a 2:1 minimum mitigation ratio for degraded environmentally sensitive habitat (ESHA) areas in the Humboldt Bay Area Plan; commissioners and commenters noted the Coastal Commission often expects 3:1 or 4:1 and that some large projects have been treated more strictly. Staff said EIR and site-specific processes would refine mitigation requirements.
During review of Chapter 3 (coastal-dependent development), commissioners extensively discussed mitigation requirements for environmentally sensitive habitat areas (ESHA). Staff explained the draft allows a minimum 2:1 mitigation ratio for degraded ESHA where the existing habitat is dispersed or invaded, while higher-quality habitats may trigger higher ratios. The Coastal Commission's comments advocating 3:1 or 4:1 for wetlands were noted.
Several commissioners and participants cautioned that some large infrastructure projects have nonetheless been required to mitigate degraded ESHA at the same rate as high-quality habitat; one commissioner said that both realities exist and asked staff to clarify when a 2:1 minimum would apply versus when higher ratios would be expected. Staff acknowledged the Coastal Commission's position and said site-specific EIRs and permitting would further define mitigation levels, and that clarifying language could be added to the plan to emphasize situational dependence rather than a blanket lower ratio.
