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City of Stockton and County of San Joaquin Page 26 NPDES Permit CAS0083470 Response to Comments In today's fiscal climate with a projected $23 billion State deficit, the County is expecting severe cuts in State funding of existing programs.Depending on the State's final budget, the County is estimating a 15% to 18% across the board spending reduction, which may include layoffs. To ask for additional funding from the general fund is against County policy for special districts. Based on recent State projections the RWQCB and all other state agencies will likely be impacted. by the State deficit and may need to delay or revise work programs to account for funding deficiencies (estimated 20%reduction). The County's situation is worse in that, in lean years the State has historically enhanced its revenues by reducing subventions and other funding of County programs. The County's limited taxing authority further impairs the ability to replace or increase needed revenues. Response: Federal NPDES regulation 40 CFR 122.26(d)(2)(vi)provides that: "[The Copermittee must submit] for each fiscal year to be covered by the permit, a fiscal analysis of the necessary capital and operation and maintenance expenditures necessary to accomplish the activities of the programs under paragraphs (d)(2)(iii) and(iv) of this section. Such analysis shall include a description of the source of funds that are proposed to meet the necessary expenditures, including legal restrictions on the use of such funds. Further, California Water Code section 13377 provides that the Regional Boards shall issue waste discharge requirements which apply and ensure compliance with all applicable provisions of the Federal Water Pollution Control Act (33 U.S.C. § 1251 et seq.), as amended, also known as the federal Clean Water Act(CWA). Section 402(p)(3)(B)(iii) of the CWA requires municipalities to implement "controls to reduce the discharge of pollutants to the maximum extent practicable, including management practices, control techniques and system, design and engineering methods, and such other provisions as the Administrator or the State determines appropriate for the control of such poluutants." The Regional Board's responsibility is to translate this section of the CWA into the form of waste discharge requirements. Therefore, the Regional Board has the authority to require specified programs to be implemented by the municipalities to carry out CWA requirements. DeltaKeeper Comments and Regional Board Response 1. Comment: Receiving Waters Are Already Seriously Degraded, Have Little Or No Dilution Capacity And Experience Multiple-Dosings. Stockton storm water discharges pose a substantially greater threat to the environment than storm water discharges from upstream cities. Local urban waterways lie within the tidal prism and are subject to frequent periods of reverse flows that provide little or no dilution. Furthermore,the State and Federal Project pumps can cause reverse flows in the San Joaquin River when the Old River barriers are not installed. Regional Board staff have analyzed these tidal effects and found that below a net San Joaquin River flow of 3000 cfs, flow reversals can cause multiple-dosings of discharged pollutants (i.e.,pollutants flow downstream from the discharge point and subsequently flow upstream past the point of discharge and then back downstream and again upstream). Fact Sheet, City of Stockton NPDES Permit, 8.5, April 2002. These multiple dosings can occur many times over extended periods of