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_ - - _ _ _ _ _ 7 , _ - - - - - Iri 1999 rt is stated ' . "Continue development of a system by which all Bank related;expenses can be charged appropriately such_that.-all_costsassociated with the~Bank dre recorded and accounted for-within its fund" "Complete-the assessment-of the cost per credit and make appropriate adjustments to the creditfee. " In 2000 it was similarly stated;- "Evaluate. the cost-per, credit through.`-a jnancial gnalysfs including past years' data, future trend projections, and imidar costs for comparable credits elsewhere in the region. There is a record of five years being spent developing"a system to track costs and set credit value. The fallout from such recognized and published self-examination, compounded by_ time, is bound to have _ _ ~ ` negative unpacts ~n.more than one quarter _ - - ~ If tlris problem:was -identified as early as 1997, what possible reason- could there` be why it has nat been rectified- by-this time? 'Public ;agencies arid: ~ piograms `must be held ac_c_ountable for adhering,- to - _ agreemeirts and wise use_of public; fiords; if the public trust`is to be~preserved. - -How could.., the .City; of Eugene,: possibly explain to concerned citizens.; and .other groups why one more credit would' be sold under these circumstances? It would be reasonable and fair for one to ask how much . - - - money may have been-lost due. to: the;delay ui any remedial actionbeing taken'. It could be perceived -that . by charging, a price ,per ,credit that is fas less than its value, and of what is required, that the City has.: knowingly° aril::actively been in the business of subsidizing developmern in West Eugene-and other areas where credits Have been sold. _ _ t Mitigation Banksmust`follow their. agreements and meet the standards,to~assure the cominued success of _ - - _ _ Mitigation Banking in Oregon: _ _ It is always preferable that internally:-generated: forces first recognize the problem, then those same forces act expeditiously in correcting :them; exactly, and precisely meeting .the requiremerrts set forth in the signed MOA. The current Draft West Eugene Wetlands. Mrtagaton Bank "Budget: and Credit Fee White Paper" _ _ ~ ~ - - suggests amodest. _nce:increase,to~$45 000;00 _ p _ < , - . ~ _ per crecht ~ However, ui reviewing. the ~crrteria set forth m . . ~ - the, Paper `to determine the amount - of increase necessary; there: till _ has .been no complete "financial _ - .,,analysis" ;done.~to; determine :whether."taus- _ _ - amowrt~-v~nll be: sufficient-to'cover-aU of the"costs .incurred, - - - Under the-most cursory review; the ;"White Pape" _lacks °-.cost estimates for. administration, and -long term monitoring and maintenance: These represent substantial costs~associaxed.with,the operation of the Bank.: - It is;reasonable to expect that :at a:~minimum, the;cost for the creation of one credit could exceed $60,000. Therefore any. temporary credit;pnce increase-:should reflect that.