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1%VV 1-... <br /> City of Stockton and County of San Joaquin Page 74 <br /> NPDES Permit CAS0083470 <br /> Response to Comments <br /> concerned,based on prior experience, that the Permittees may make little effort in securing <br /> involvement of individuals from the larger community. The advisory committee will need <br /> representatives from the environmental, educational and public relations communities, as well as <br /> interested citizens, if it is to be effective. Consequently,the Permit should require that the <br /> Permittees proactively endeavor to secure individuals from the environmental and educational <br /> communities as well as experts in public relations. The committee should be required to meet <br /> quarterly and charged to evaluate the public outreach program and make recommendations. Surely, <br /> this is a minimal MEP requirement. <br /> There is a total lack of performance measures with respect to public outreach and educational <br /> BMPs. Simply distributing brochures, developing PSAs or providing schools with educational <br /> materials or brief presentations is insufficient, especially since there is virtually no demonstrated <br /> nexus between these BMPs and identified improvements in water quality. At the very least, <br /> outreach and educational BMPs must be shown to be effective in increasing public awareness of <br /> storm water issues. Independent surveys to evaluate increased knowledge, if any, of storm water <br /> issues are essential. General public awareness surveys,before and after testing of school children <br /> and surveys targeting the construction and industrial community must be required. Without these <br /> performance evaluations, no outreach and educational program can be considered to have complied <br /> with an MEP standard. <br /> Response: The Regional Board intends for the public outreach committee to give interested parties <br /> an opportunity to provide the Permittees with feedback on implementation of the Public Outreach <br /> and Education Program. We expect the Permittees to (1)notify the public, through local <br /> newspapers or other means, of opportunities to serve on the committee; (2) hold committee <br /> meetings at least quarterly; (3)provide a meeting place; and(4) provide adequate Permittee <br /> representation. We do not expect the Permittees to hire "representatives from the environmental, <br /> educational, [or] public relations communities,"or any other type of consultant. We certainly hope <br /> that interested citizens with these skills wish to volunteer, but we will not compel the Permittees to <br /> hire such individuals. <br /> Provision D.14(i)requires the Permittees to conduct surveys to measure program effectiveness. <br /> We expect the objective of these surveys to be to show that the subject program is making progress <br /> towards increasing public awareness of storm water issues. We also expect target groups for these <br /> surveys to include school children, the general public, and members of the construction and <br /> industrial communities over the course of the permit term. We request that DeltaKeeper withholds <br /> judgment on the Permittees' committee and survey plans until the Permittees have had the <br /> opportunity to present their proposals in the S WMP. <br /> 51. Comment: (DK Comment 5(u)) SWMP Municipal Program 17,Performance and Effectiveness <br /> Evaluation: The regulations require that the Permittees report flow and the concentration and mass <br /> loads of each constituent that is discharged from each outfall. The formula used in calculating mass <br /> must be scientifically defensible and be consistent over time. Given the failure of the Permittees to <br /> report mass loads over the previous permit cycle,results from previous monitoring must be <br /> recalculated according to the same methodology. DeltaKeeper believes this requirement is <br />