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REGIONAL BOARD RESPO)79E (SWRCB/OCC FILE A-1524(A)) `'� -8- <br /> PETTTION FOR REVIEW OF WASTE DISCHARGt REQUIREMENTS <br /> ORDER NO. R5-2002-0181 <br /> CITY OF STOCKTON AND SAN JOAQUIN COUNTY PHASE I MUNICIPAL SEPARATE STORM <br /> SEWER SYSTEM <br /> 2. MEP means to the maximum extent feasible, taking into account considerations of synergistic, <br /> additive, and competing factors, including but not limited to, gravity of the problem, technical <br /> feasibility, fiscal feasibility,public health risks, societal concerns, and social benefits. (Order R8- <br /> 2001-10 Orange County MS4 Permit) <br /> 3. MEP is the technology-based standard established by Congress in CWA Section 402(p)(3)(B)(iii) <br /> that municipal dischargers of storm water(MS4s)must meet. Technology-based standards <br /> establish the level of pollutant reductions that dischargers must achieve typically by treatment or <br /> by a combination of treatment and BMPs. MEP generally emphasizes pollution prevention and <br /> source control BMPs,primarily(as the first line of defense)in combination with treatment <br /> methods serving as a backup (additional line of defense). MEP considers economics and is <br /> generally,but not necessarily, less stringent than BAT. A definition for MEP is not provided <br /> either in the statute or in the regulations. Instead the definition of MEP is dynamic and will be <br /> defined by the following process over time: municipalities propose their definition of MEP by <br /> way of their Storm Water Management Plan (SWMP). Their total collective and individual <br /> activities conducted pursuant to the SWAP becomes their proposal for MEP as it applies both to <br /> their overall effort, as well as to specific activities (e.g.,MEP for street sweeping, or MEP for <br /> municipal separate storm sewer system maintenance) <br /> 4. Ina memo dated February 11, 1993, entitled 'Definition of Maximum Extent Practicable," <br /> Elizabeth Jennings, Senior Staff Counsel, the State Board addressed the achievement of the MEP <br /> standard as follows: <br /> "To achieve the MEP standard, municipalities must employ whatever Best Management <br /> Practices (BMPs) are technically feasible (i.e., are likely to be effective) and are not cost <br /> prohibitive.The major emphasis is on technical feasibility. Reducing pollutants to the MEP <br /> means choosing effective BMPs, and rejecting applicable BMPs only where other effective <br /> BMPs will serve the same purpose, or the BMPs would not be technically feasible,or the <br /> cost would be prohibitive. In selecting BMPs to achieve the MEP standard, the following <br /> factors may be useful to consider: <br /> a. Effectiveness: Will the BMPs address a pollutant (or pollutant source)of concern? <br /> b. Regulatory Compliance: Is the BMP in compliance with storm water regulations as <br /> well as other environmental regulations? <br /> c. Public Acceptance: Does the BMP have public support? <br /> d. Cost: Will the cost of implementing the BMP have a reasonable relationship to the <br /> pollution control benefits to be achieved? <br /> e. Technical Feasibility: Is the BMP technically feasible considering soils, geography, <br /> water resources, etc?" <br /> The WDRs specify that the Permittees' revised SWMP will contain BMPs that each Permittee will <br /> implement to reduce the discharge of pollutants from their respective MS4s to the MEP. The Permittees <br /> are required to establish performance standards for each proposed BMP. Pursuant to 40 CFR <br />