SITE INFORMATION AND CORRESPONDENCE

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%ftle 'wool City of Stockton and County of San Joaquin Page 16 NPDES Permit CAS0083470 Response to Comments Response: The detention basin study language has been revised to allow the Permittees to propose a joint study with other Central Valley MS4 permittees if certain requirements are met. 21. Comment: The City requested several revisions to the Tentative Order's reporting format (Attachment B of the MRP). Response: The MRP language has been revised to allow the Permittees to propose an alternative reporting format in their SWMP. The Permittees can propose revisions to the reporting format during the SWMP review. County of San Joaquin Comments and Regional Board Staff Response 1. Comment: "Critical Issues," County Comment Letter The County states: "The Tentative Order contains many provisions from the Los Angeles permit that may be appropriate for the Los Angeles Basin,but there is no study to show that the provisions are appropriate for the Stockton urban area. Without providing this nexus and some basis of the cost effectiveness of the permit items, the County does not believe that the inclusion of many of these items is justified." Response: Comment noted. As explained in the response to the City's Comment 2,regional boards are not required to demonstrate that the water quality benefits outweigh economic costs when issuing MS4 permits. 2. Comment: "Limited Flexibility of the Tentative Order," County Comment Letter The County states: "The Tentative Order sets time lines for activities without regard to the benefit of the activity or the need for local agencies to revise time lines, as required, to allow the best use of limited resources and provide for cost-effective program management. For example,the inability to concentrate inspection efforts on habitual offenders and limit activity on permits where compliance is not an issue is an inefficient use of finite program resources. Without the ability to adjust schedules and activities to match local conditions,the Tentative Order usurps the authority of local government to meet the requirements of the Order while balancing other local needs and accounting for local conditions." Response: This comment lacks the specificity necessary for the Regional Board to provide a detailed response. In general, however,both the Construction and Commercial/Industrial Elements of the Tentative Order set minimum requirements for conducting inspections at applicable sites and facilities. In preparing these requirements, Board staff attempted to balance the flexibility that the Permittees desire to implement their programs against the Regional Board's efforts to ensure Permittee compliance with applicable statutes, regulations, and orders. We believe the inspection requirements in the Tentative Order are the minimum necessary to meet the CWA's MEP standard. No changes will therefore be made.