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City of Stockton and County of San Joaquin Page 73 <br /> NPDES Permit CAS0083470 <br /> Response to Comments <br /> Response: In designating a street's maintenance priority,we expect the Permittees to consider <br /> things such as traffic levels, surrounding land use, and historical debris buildup. We also expect the <br /> Permittees to propose performance standards along with their street and road maintenance program. <br /> The details of the street and road maintenance requirements will be presented in the Permittees' <br /> revised SWMP. Once the SWMP is approved by the Regional Board, this maintenance program <br /> will be an enforceable part of the permit. We request that DeltaKeeper withholds judgment on this <br /> issue until the Permittees have had the opportunity to present their proposals in the SWMP. <br /> 47. Comment: (DK Comment 5(q) SWMP Municipal Program 12(b)(viii)(c), Streets and Roads <br /> Maintenance: We strongly urge that Permittees be required to ensure that green waste, including, <br /> but not limited to leaves,branches and grass clippings not be disposed of in gutters or locations <br /> where they can reach and clog storm drain inlets and lines. We also urge that Permittees be required <br /> to ensure that pet or human waste not be disposed of in gutters or locations where they can be <br /> discharged to the MS-4. <br /> Response: Provision D.6(b)(viii)requires the Permittees to effectively prohibit MS4 discharges <br /> containing pet waste and vegetation clippings. Provision D.18(b) requires the Permittees to identify <br /> sources of(including consideration of human waste), and BMPs for,pathogens as part of the <br /> preparation of the Pathogens Plan. These provisions adequately address these pollutant sources. <br /> 48. Comment: (DK Comment 5(r)) SWMP Municipal Program 12(b)(viii)(e), Streets and Roads <br /> Maintenance: Eighteen months is an unreasonably long time to complete basic training in the storm <br /> water management program requirements. How is the effectiveness of training to be measured? <br /> Response: We anticipate that development of training materials for the Municipal Operations <br /> Element will require more time than for other elements. We therefore believe the 18-month <br /> timeline is appropriate. The Permittees will demonstrate that they've complied with the requirement <br /> by including training attendance sheets in their Annual Reports, or by some other acceptable means. <br /> The Permittees' compliance with the provisions of the Municipal Operations Element will provide <br /> an indirect but adequate indication of the training program's effectiveness. We will arrange for <br /> training materials to be made available to interested parties upon request. <br /> 49. Comment: (DK Comment 5(s)) SWMP Municipal Program 13(e), Illicit Discharge Detection and <br /> Elimination Program: Please provide the rationale for extending the requirement to respond to <br /> reports of illicit discharges from within one day(in the previous tentative permit) to two days. The <br /> Permittees should immediately respond to reports of illicit discharge of paints, oils, hazardous <br /> substances, etc. It may be too late to effectively abate, contain and cleanup illicit discharges two <br /> days after they are reported. This extended delay cannot be MEP. <br /> Response: The Regional Board expects the Permittees to respond to reports of illicit discharge as <br /> soon as possible, but in no case later than two days. This deadline is intended to account for the <br /> situation when two or more illicit discharges are reported over a short period. <br /> 50. Comment: (DK Comment 5(t)) SWMP Municipal Program 14, Public Outreach and Public <br /> Education: We believe the public advisory committee requirement is a good one. We are <br />