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<br />I . Regulatory bodies impose new permit requirements without going through rulemaking. . <br />2 Instead, the agencies rely on internal documents, program strategies, and "best professional <br />3 judgment of staff' when setting permit criteria. <br /> <br />4 . Regulatory bodies approve permits and programs that compete with traditional municipal <br />5 services and encourage urban sprawl. This behavior puts at risk the public investments and <br />6 growth management efforts cities have made when planning for future development. <br /> <br />7 . Permit fees and other cost transfer elements of federal and state programs do not provide an <br />8 incentive for environmental agency efficiency, policy prioritization or risk assessment. <br /> <br />9 . Third party environmental advocacy groups create significant hardships on cities by <br />10 threatening litigation even when hard science may not support the groups' positions. <br />11 <br />12 Response: <br />13 <br /> <br />14 · Alternative wastewater treatment and cooperative service systems should be prohibited <br />15 from operating in areas that can reasonably and effectively be served by existing <br />16 municipal systems unless: <br />17 -. The municipal system is proven to be substantially less cost-effective and <br />18 substantially less beneficial to the environment; and <br />19 --The operation of these systems will not create a stranded public investment in the <br />20 existing system. <br /> <br />21 . Sufficient state and federal financial assistance should be provided to assist local <br />22 governments when complying with state and federal infrastructure requirements, a <br />23 particularly with regard to wastewater, stormwater, and drinking water facilities. .. <br /> <br />24 · The Minnesota Pollution Control Agency (MPCA) should streamline its permitting and <br />25 reissuing processes to allow for effluent standards and permit requirements to be <br />26 known earlier, thereby giving communities more time to defend against contested case <br />27 hearings. <br /> <br />28 . The Legislature should require the MPCA to make its determination regarding the <br />29 reissuance of a permit within a reasonable set time period and require the MPCA to <br />30 reissue the permit within a reasonable set time frame. <br /> <br />31 . Legislation should be passed that requires state agencies to establish permit <br />32 requirements only when the criteria they are using is developed- through the rule- <br />33 making process. <br /> <br />34 . The League should join with other like-minded organizations to contest through <br />35 judicial means various regulatory activities of state agencies and advocacy groups. <br />36 <br /> <br />37 SD-15. Creating a Minnesota GIS (AH) <br />38 <br />39 Issue: Local governments are finding geographic information systems (GIS) an essential <br />40 tool for comprehensive land use, real estate, environmental, and other land management <br />41 information. In many counties, maintenance of official land records has not been automated, <br />42 creating a barrier to GIS development. In addition, the start-up costs of GIS implementation can <br />~ be prohibitive. e <br /> <br />28 <br />