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sprawl. This behavior puts at risk the <br />public investments and growth <br />management efforts cities have made <br />when planning for future development. <br />e) Permit fees and other cost -transfer <br />elements of federal and state programs <br />do not provide an incentive for <br />environmental agency efficiency, policy <br />prioritization or risk assessment. <br />Additionally, all residents of the state <br />contribute to the need for wastewater, <br />drinking water, and stormwater <br />treatment and benefit from the resulting <br />improved water quality. These factors <br />make the state general fund an <br />appropriate source for significant <br />portions of state water program funding. <br />f) Third -party environmental advocacy <br />groups create significant hardships on <br />cities by threatening litigation even <br />when hard science may not support the <br />groups' positions. <br />Cities are often required to pay the cost <br />of removing problem materials from the <br />waste stream, rather than preventing the <br />problem at the consumer product or <br />manufacturing level. <br />g) <br />Response: Alternative wastewater <br />treatment and cooperative service systems <br />should be prohibited from operating in <br />areas that can reasonably and effectively <br />be served by existing municipal systems, <br />unless: <br />a) The municipal system is proven to be <br />substantially less cost-effective and <br />substantially less beneficial to the <br />environment; and <br />b) The operation of these systems will not <br />create a stranded public investment in <br />the existing system. <br />Sufficient state and federal financial <br />assistance should be provided to local <br />governments when complying with state <br />and federal infrastructure requirements, <br />particularly with regard to wastewater, <br />stormwater, and drinking water facilities. <br />The Minnesota Pollution Control Agency <br />(MPCA) should streamline its permitting <br />and re -issuing processes to allow for <br />effluent standards and permit <br />requirements to be known earlier, <br />thereby giving communities more time to <br />defend against contested case hearings. <br />The Legislature should require the <br />MPCA to make its determination <br />regarding permit -required submittals, <br />permit modifications, and the reissuance <br />of a permit within a reasonable set time <br />period, and require the MPCA to make <br />its determinations and reissue the permit <br />within that reasonable set time frame. <br />The state should ensure townships are <br />required to meet the same environmental <br />protection and regulatory requirements <br />as cities. <br />Legislation should be passed that requires <br />state agencies to establish permit <br />requirements only when the criteria they <br />are using is developed through the rule - <br />making process. <br />State agencies need to develop science - <br />based standards and quantify new <br />effluent standards, ensuring that they are <br />scientifically and economically <br />practicable. State and federal agencies <br />should coordinate and integrate their <br />monitoring data to assure that all <br />pertinent data is available and utilized. <br />The state general fund is an appropriate <br />source for state water program funding. <br />Municipal water permit fees should only <br />be increased if new revenue is needed <br />because of increased costs of processing <br />municipal water permits or if the funds <br />would go for specific scientific research, <br />technical and financial support for cities, <br />League of Minnesota Cities <br />2015 City Policies Page 37 <br />