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City of Stockton and County of San Joaquin Page 20 NPDES Permit CAS0083470 Response to Comments permits to the site-specific nature of MS4 discharges. (132 Cong. Rec. S16,424 (Oct. 16, 1986), reprinted in 2 Environment and Natural Resources Policy Division, Library of Congress,A Legislative History of the Water Quality Act of 1987 646 (1988);House Committee on Public Works and Transportation, Section-by-Section Analysis (100th Sess. 1987), reprinted in 1987 U.S.C.C.A.N. (101 Stat. 7) 5, 38-39;see also 55 Fed. Reg. 47990, 48038 (Nov. 16, 1990)). The flexibility includes the ability to direct permit requirements at the sources of pollution and not simply to direct MS4 discharge points. California Water Code sections 13263 and 13377 provide the Regional Board with the authority to regulate discharges to preserve the highest reasonable water quality and the water quality necessary to protect beneficial uses. NPDES regulations mandate the reduction of pollutants in storm water that cause or contribute to pollution to the MEP. While the CWA does not require municipalities regulated through MS4 permits to satisfy receiving water standards, CWC Sections 13263 and 13377 require that waste discharge requirements functioning as NPDES permits implement water quality objectives (i.e.,water quality standards) contained within basin plans and within provisions of the Clean Water Act and NPDES regulations necessary to protect beneficial uses and to prevent nuisance. Water Code Section 13377 states: "Notwithstanding any other provision of this division, the state board or the regional boards shall, as required or authorized by the Federhl Water Pollution Control Act, as amended, issue waste discharge requirements . . . which apply and ensure compliance with all applicable provisions of the act and acts amendatory thereof or supplementary thereto, together with any more stringent limitations necessary to implement water quality control plans, or for the protection of beneficial uses, or to prevent nuisance. See also the response to the City's comment No.1. 10. Comment: "Phase I Storm Water Regulations" When enacting section 402(p)(3)(B)(iii), Congress was aware"of the difficulties in regulating discharges from MS4s solely through traditional end-of-pipe treatment, and intended for EPA and NPDES States to develop permit requirements that were much broader in nature than requirements that are traditionally found in NPDES permits for industrial process discharges or POTWs. 55 Fed. Reg. 47990, 48037-38 (Nov. 16, 1990). Congress intended MS4 permits to reflect"a comprehensive municipal storm sewer program." 132 Cong.Rec. S32381 (daily ed. Oct. 16, 1986) (statement of Sen. Stafford). These [MS4] permits will not necessarily be like industrial discharge permits. Often, an end-of. the-pipe treatment technology is not appropriate for this type of discharge. As an EPA official explained in a meeting of the conferees: These are not permits in the normal sense we expect them to be. These are actual programs. These are permits that go far beyond the normal permits we would issue for an industry because they in effect are programs for storm water management that we would be writing into these permits.