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City of Stockton and County of San Joaquin Page 67 NPDES Permit CAS0083470 Response to Comments loading; Irrigation water is an identified source of pesticide,nutrient and pathogen loading; Individual Residential Car Washing is an identified source of cumulative loading of detergents and oil,without specific enforceable BMPs; Lawn Watering is an identified source of pesticide,nutrient and pathogen loading; Street Wash Water is a source of many pollutants (The LA Regional Board prohibited discharge of street wash water to storm drains because they found them to be sources of pollutants. Response: The word"significant'has been removed from applicable texts to comport with 40 CFR 122.26(d)(2)(iv)(B)(1). 29. Comment: (DK Comment 4(c))Discharge Prohibitions B(3) for Non-Storm water Discharges. The word significant is not in the regulations and must be eliminated. The word significant only applies to firefighting discharges. B(3)(b) should be eliminated because non-storm water discharges must be eliminated. The MEP standard does not apply to non-storm water discharges. For such discharges the CWA establishes a flat prohibition. Section 402(p)(3)(B)(ii)mandates that "[p]ermits for discharge from the municipal storm sewers shall include a requirement to effectively prohibit non-storm water discharges into the storm sewers..." 33 U.S.C. § 1342�p)(3)(B). Response: The proposed language is consistent with 402(p)(3)(B)(iii). Prohibition B.3(b)provides the opportunity for the Permittees to install structural BMPs to eliminate or reduce the discharge of pollutants. In addition, Prohibition B.1 addresses the need for a de minimus permit if any of the referenced discharges are identified by the Permittees as a source of pollutants. 30. Comment: (DK Comment 4(d))Receiving Water Limitation C(1)(a) should be corrected to acknowledge that the Basin Plan contains a warm water spawning dissolved oxygen limit of 7 mg/l. Response: The warm water-spawning limit for dissolved oxygen of seven mg/1 only applies to certain stretches of the Delta. It is therefore inappropriate to cite this limit in C.1(a).. 31. Comment: (DK Comment 5(a)) SWMP Legal Authority, 6(d): states that"[t]he legal authority must, at a minimum, authorize the Permittees to: Control the discharge of spills, dumping, or disposal of material other than storm water to its MS4s." For such discharges the CWA establishes a flat prohibition. Section 402(p)(3)(B)(ii)mandates that"[p]errnits for discharge from the municipal storm sewers shall include a requirement to effectively prohibit non-storm water discharges into the storm sewers..." 33 U.S.C. § 1342(p)(3)(B). The language should be changed from control to prohibit. Response: "Control'has been changed to "Prohibit' in Provision D.6(d). 32. Comment: (DK Comment 5(b)) SWMP Legal Authority 7 should have the following sentence added: "Failure to follow the progressive enforcement schedule or, otherwise, effectively enforce the ordinance will be considered a violation of this permit." Stockton has frequently failed to escalate enforcement.