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%M01 Sold City of Stockton and County of San Joaquin Page 17 NPDES Permit CAS0083470 Response to Comments 3. Comment: See comment titled"Inclusion of Inappropriate Sections...," County Comment Letter The County states: "The City of Stockton—San Joaquin County Tentative Permit includes a mandate to control pollutants from fire fighting flows. San Joaquin County has not found this to be the case in any other MS4 permit in the State of California. All recent permits exempt emergency fire fighting flows and recognize that life and property protection take precedence over pollution prevention." Response: See the response to the City's Comment 11. 4. Comment: "Approval of the Storm Water Management Plan,"County Comment Letter The County states: "The Tentative Order provides for the approval of the Storm Water Management Plan (SWMP)by the Board rather than the Executive Officer, as was the case in prior permits. This requirement is burdensome and makes a simple modification of the SWMP a major effort by both the Regional Board and the permittees. Many conditions in the Tentative Order are what has previously been part of the SWMP. The SWMP is meant to be a fluid document that can readily be amended to correct unforseen problems, adjust program schedules to match field conditions, and revise requirements to fit new circumstances. This issue is directly related to increasing program flexibility to allow the program to match actual rather than perceived needs and conditions. Approval of the SWMP and any subsequent revisions by the Executive Officer would streamline the approval process and result in an improvement in the maintenance of an up to date Storm Water Management Plan." Response: See the response to the City's Comment 12. 5. Comment: "Delegation of State General Permits," County Comment Letter The County states: "The provisions of the Tentative Permit delegate[s] the State's responsibility for inspection and enforcement of the State General Permits for Industry and Construction to the permittees. The State has no authority to require the permittees to assume the State's regulatory responsibilities for these programs. NPDES Regulations for Storm Water Discharges, 55 Fed. REg. 47990,48052 (11/16/90), states that the `EPA(or the NPDES state) cannot abrogate its responsibilities under the Clean Water Act to implement the NPDES permit program by relying on pollution control programs that are outside of the NPDES program.' The tentative Permit should clearly define the powers and roles of the State and the permittees in implementation of the General Permits." Response: See response to the City's Comment 4. 6. Comment: "Financial Implications of the Tentative Permit," County Comment Letter The County states: Section D-16 of the Tentative Order states that `Each Permittee shall secure the resources necessary to meet the requirements of this Order . The Water Resources Control