SITE INFORMATION AND CORRESPONDENCE

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11%.. SVO, City of Stockton and County of San Joaquin Page 4 NPDES Permit CAS0083470 Response to Comments The Regional Board must make findings that it considered costs when preparing the permit. The Regional Board also must point to evidence in the record to support those findings. (Topanga Assn. for a Scenic Community v. County of Los Angeles, 11 Cal.3d 506, 515.) Cost information must be evaluated on a case-by-case basis to determine whether the costs associated with the permit are reasonable. (Water Code, § 13000.) Thus,the Regional Board must consider the specific costs Stockton will incur to implement the permit. The Regional Board should evaluate the estimated cost of compliance with permit provisions and the benefits that can be expected to result from implementing those provisions. To determine whether compliance costs are appropriate, the Regional Board should do a costibenefit analysis, and may consider the relative rates and fees of Stockton as compared to other municipalities,the costs typically incurred by similarly situated permittees, and economic conditions specific to Stockton. In considering cost, the Regional Board should also take into account the economic hardship it will place on the Permittees and their ability to fund these requirements. Just as different areas of California have different water quality problems, storm water programs with similar costs may result in different economic hardships. According to the most recent Census Bureau estimates, the median household annual income in San Joaquin County is $35,629, which is over 10 percent less than that of the rest of the state, at $39,595. Per capita income has historically been lower in Stockton(and areas immediately surrounding Stockton)than the rest of the state and nation for several reasons: • A large proportion of employment in the City and surrounding areas has historically been in the agribusiness industry, e.g., agriculture and food processing. Because most of the rest of California residents live in urbanized areas (i.e.,the greater Bay Area, the Los Angeles basin and the greater San Diego metropolitan area), the Stockton area has a higher proportion of agricultural jobs than the state as a whole. Employment compensation in agribusiness is generally low-paying relative to employment in other business sectors. The seasonal nature of some agribusiness employment contributes to lower per capita income in the Stockton area. • Because of the area's proximity to major transportation facilities (major highways, such as Interstate 5 and Highway 99,railroads, seaport and airport), a higher proportion of jobs in the City and surrounding areas has also been in logistics, e.g.,product distribution and trucking. Compensation in logistics is also lower-paying, relative to that in most other business sectors. • The Stockton area has had chronic high unemployment, which brings down per capita income. The Stockton area has also had chronic high under-employment, in part because of the existence of a higher proportion of jobs in industries offering lower-paying jobs. Based on data from the California Employment Development Department, the annual unemployment rates for the City of Stockton for the years 2000, 2001 and January 2002 (the most recent month for which data is available)were 10.4 percent, 10.3 percent, and 13.4 percent,