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1*� 1.10� City of Stockton and County of San Joaquin Page 15 NPDES Permit CAS0083470 Response to Comments that are being monitored for the first time as a result of this Order, an analysis will be conducted during the last year of the Permit." Response: 40 CFR 122.42(c)(7) requires annual reports to identify water quality improvements or degradation. Section I.B.7 has been revised to comport with this requirement. 17. Comment: The City requested clarification of where urban discharge monitoring stations are to be located, as identified in MRP Section U.B. The statement in question read as follows: "Samples shall be taken at the following stations: MS-14 (Residential)—Vicinity of Mariners Drive at Mosher Slough; SC-I Smith Canal—Vicinity of Pershing Drive Over-crossing; CR-46 (Commercial)—Vicinity of El Dorado Street Overpass; and DC-65 (Industrial)—Vicinity of El Dorado Street Over-crossing at Duck Creek. Attachment A also shows the approximate locations of the urban discharge sampling stations." Response: This issue has been addressed by modifying this text as follows: "Samples shall be taken from representative outfalls for the following drainage basins: CR-46, discharging to the Calaveras River;DC-65, discharging to Duck Creek; and MS-14, discharging to Mosher Slough. The locations of these basins are shown in Attachment A. Samples shall also be taken at a representative outfall for the urban area surrounding Smith Canal, and near the receiving water sampling location designated as SC-1R in Attachment A. The proposed locations of these urban discharge monitoring stations shall be presented in the revised SWMP." 18. Comment: The City requested a reduction in dry weather monitoring of urban discharges and receiving water from two storm events per year to one. Response: The level of monitoring in the Tentative Order is the minimum level deemed adequate by Board staff to demonstrate compliance with receiving water limitations. We will therefore not reduce any monitoring. 19. Comment: The City requested the removal of the water column toxicity monitoring requirement for Fathead Minnow based on its assertion that, "[t]here is already a significant amount of data in the delta waterways concerning the toxicity to Fathead Minnows. Additional testing will [add] to the expense of the program without providing additional knowledge" Response: One of the goals of the City's SWMP is to reduce impairment, including toxicity,in Stockton area waterways. Tracking toxicity trends for Fathead Minnows during the permit term is a valuable means of measuring the City's progress towards that goal. Consequently,the requested deletion will not be made. 20. Comment: The City requested that the requirement to conduct detention basin monitoring be deleted because they claim to have few detention basins and other Central Valley MS4 permittees (i.e.,Modesto and Sacramento area's)will be conducting these studies anyway.