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City of Stockton and County of San Joaquin Pa,-e 11 NPDES Permit CAS0083470 Response to Comments feasible. These types of differences were recognized by the Regional Board last year when it adopted a Storm Water permit for the Fresno area that did not contain a Los Angeles-style SUSMP. The City of Stockton requests similar consideration. The City of Stockton currently has a program to require post-construction BMPs as part of new development and significant redevelopment. This program reflects local conditions and limitations. If changes are required in the City's current program to satisfy the goals of Order 2000-11 while taking into account the differences noted, we are more than willing to meet with Board staff to discuss ways to modify our program to meet the intent of this Order. Therefore, it is requested that the Board adopt the Tentative Permit without the requirement for a Standard Urban Storm Water Mitigation Plan (SUSMP) and direct staff to meet with City staff to determine appropriate programmatic changes to deal with post-construction pollution prevention. Once this program is finalized it can be brought back to the Board for approval and incorporation into the adopted permit. Response: The Fresno permit did not include SUSMP requirements because the Fresno Flood Control District controls almost all of the storm water discharges within the City:90 percent goes to retention ponds, eight percent goes to detention basins, and only 2 percent goes directly to surface water. Thus, SUSMP requirements were deemed inappropriate for Fresno. The detention and retention are provided on a regional level, so it would be redundant and inefficient to require individual developments to provide the same measures. The Regional Board found that this regional system is more protective of water quality because it provides mitigation measures for all existing as well as new development, not just specific categories of new development. Stockton's SUSMP requirements are consistent with the State Board Order WQ 2000-11. In preparing the Tentative Order's SUSMP requirements, Regional Board staff considered the Stockton area's environmental conditions. Although treatment options such as storm water infiltration or detention may not be feasible in some areas, there are alternative treatment options available that can be applied(e.g., vegetative swales and filter devices or other treatments). The Tentative Order will not be revised. 10. Comment: Finding#58 of the WDR notes that Retail Gasoline Outlets (RGOs) contribute high concentrations of heavy metals and hydrocarbons. There is no documented impairment in local waterways for heavy metals or hydrocarbons. This Finding is being used to justify the inclusion of RGOs in the Commercial Program. However, if no impairment exists in local waterways for the pollutants associated with RGOs, this finding serves no purpose and should be deleted. Response: The CWA's MEP standard applies to pollutants that are currently causing water quality impairment in receiving waters as well as pollutants that may cause water quality impairment in the future. Heavy metals and hydrocarbons fall into the latter category. Furthermore,the State Board's Order WQ 99-05 requires the Permittees' SWMPs to be designed to achieve compliance with water quality standards, including standards for heavy metals and hydrocarbons. Although these standards have not been exceeded in local waterways, the Regional Board believes that the MEP standard and State Board Order WQ 99-05 obligate the Permittees to take the preventive and proactive measures