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City of Stockton and County of San Joaquin Page 55 NPDES Permit CAS0083470 Response to Comments the adoption of waste discharge requirements, except requirements for new sources as defined in the Federal Water Pollution Control Act or in other acts which amend or supplement the Federal Water Pollution Control Act. In the CEB "Practice Under the California Environmental Quality Act, the authors note: "[t]his section identifies and interprets the exemption for waste discharge requirements from existing sources under the Federal Water Pollution Control Act.... This Guideline section specifies that this partial exemption applies only to the preparation of EIRs and Negative Declarations. This is not a total exemption in CEQA..." The water code regulations also support the principle that CEQA policy applies to NPDES permits. 23 Cal. Code Reg. § 3733 states that, "[e]nvironmental documents are not required for adoption of waste discharge requirements under Chapter 5.5,Division 7 of the Water Code, except requirements for new sources as defined in the Federal Water Pollution Control Act. This exemption is in accordance with Water Code Section 13389 which does not apply to the policy provisions of Chapter 1 of CEQA." 23 Cal. Code Reg. § 3780 states that: "[t]he board shall not approve a proposed activity if there are feasible alternatives or feasible mitigation measures available which would substantially lessen any significant adverse impact which the proposed activity may have on the environment." State Water Board decisions also support this view. In Order No. 2000-03, the Board stated that the "action to renew an NPDES Permit is exempt from certain provisions of CEQA, Public Resources Code Section 21100, et seq., in accordance with Section 13389 of the California Water Code." Earlier Board decisions confirm that CEQA policy applies. See Order No. WQ 84-7 ("Section 13389 does not exempt Regional Boards from the policy provisions of CEQA (Public Resources Code Sections 21000 to 21100")); Order No. WQ 75-8 (Exemption under Section 13389 does not apply to the policy provisions of Chapter 1 of CEQA. " Case law is clear that such certified programs are still subject to the general policies of CEQA. See e.g. Mountain Lion Foundation v. Fish & Game Commission, supra, 16 Cal. 4th at 114; Sierra Club v. State Board of Forestry, supra, 7 Cal. 4th at pp. 1228, 1230-1231; City of Sacramento v. State Water Resources Control Bd. (1992) 2 Cal. App. 4th 960, 976-978; EPIC v. Johnson(1985) 170 Cal. App. 3d 604, 620-621 (abbreviated procedures allowed under 21080.5 does not preclude adherence to the "broad policy goals of CEQA" and to "CEQA's substantive standards designed to fulfill the act's goal of long term preservation of a high quality environment.") This includes general CEQA directives that an agency considers the "cumulative impacts" of its project approvals (Id. at 625),provide timely and adequate responses to comments made by the public. (Id. at 622; Dunn-Edwards Corp. v. South Coast Air Quality Management District(1993) 19 Cal. App. 4th 519, 534) and consider feasible alternatives to the proposed action. Friends of Old Trees v. Dept. of Forestry and Fire Protection (1997) 52 Cal. App. 4th 1383, 1404-1405; 14 Cal. Code Reg. § 15126.6. An important CEQA principle applicable to certified programs is the requirement that the environmental impacts of a project be considered by the public and public agencies at the