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I/ EUGENE <br /> Parks and <br /> Open Space <br /> C M <br /> CELEBRATING E B R A T I N G Y a 15, 2007 <br /> - <br /> 1 (� 0 (� Years of Parks <br /> 11 V 1906.2006 David Jampolsky <br /> 1263 Oak Street #304 <br /> Eugene, OR 97401 (‘) J <br /> A DIVISION OF PUBLIC WORKS <br /> RE: <br /> 1820 ROOSEVELT 8EV0 West Eugene Wetlands Mitigation Bank <br /> EUGENE, OREGON 91402 <br /> (541) 682-4800 <br /> FAX (541) 682 -4882 <br /> WWW. EUGENE-OR .GOV /PARKS Dear Mr. Jampolsky: <br /> I am writing in response to your recent letter to Kurt Corey in which you <br /> expressed several concerns regarding the West Eugene Wetlands Mitigation <br /> Bank. Inasmuch as you and I have worked to resolve related issues in the <br /> past, Kurt has asked me to respond to your concerns. <br /> In your letter, you mentioned that you are concerned with certain practices of <br /> the Bank that potentially serve to dissuade the use of other mitigation banks. <br /> The West Eugene Bank provides developers with one option for satisfying <br /> their mitigation requirements; however, developers within the West Eugene <br /> PARKS AND OPEN SPACE PLANNING Wetlands Plan area are not required to mitigate impacts by using the West <br /> Eugene Bank. Developers may employ other means of mitigating their <br /> wetland impacts, including mitigating on -site or purchasing credits from <br /> PARKS MAINTENANCE other authorized mitigation banks. As you know, the Oregon Department of <br /> State Lands has a web site that lists all the authorized mitigation banks in <br /> Oregon; this same web site describes the approved service area boundaries of <br /> URBAN FORESTRY each bank. The Oregon Department of State Lands and the U.S. Army Corps <br /> of Engineers are the entities responsible for approving mitigation plans <br /> NATURAL RESOURCES associated with fill- removal permits, not the City of Eugene. The City of <br /> Eugene does not impose any additional permit requirements, delays, or any <br /> other adverse action on developers who satisfy their wetland mitigation <br /> requirements by using another mitigation bank. If, as you suggest, there are <br /> applicants who do not believe this to be the case, I would be very interested <br /> in visiting with them. <br /> In your letter, you also suggest the City of Eugene enjoys an unfair advantage <br /> by virtue of its authority to calculate mitigation replacement ratios for <br /> projects within the Plan boundary. Since state and federal approval of <br /> mitigation banks requires that the majority of mitigation projects be <br /> constructed prior to selling credit, this policy provides a lower replacement <br /> ratio for mitigation purchased from a mitigation bank compared to mitigation <br /> performed privately. While this incentive encourages the use of a mitigation <br /> bank, the policy does not specify that credits need to be purchased from a <br /> particular bank. A developer would have the choice to opt for the higher <br /> replacement ratio and mitigate impacts privately, or to purchase credits from <br /> any authorized mitigation bank. <br /> EUGENE I<� <br />