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4 <br /> City of Stockton and County of San Joaquin Page 79 <br /> NPDES Permit CAS0083470 <br /> Response to Comments <br /> directly, or indirectly, calculate, or estimate, the reduction in pollutants in storm water discharges as <br /> a result of implementing its source control BMPs. The studies shall be implemented upon approval <br /> by the Executive Officer." Order No. 95-035, 24 February 1995. More than seven years later,the <br /> Permittees still have not provided calculations or estimates of reductions (if any) of pollutants in <br /> storm water discharges as a result of BMP implementation. The EPA has proposed several <br /> methodologies to calculate mass loading. The Permit must require the Permittees quantify the <br /> effectiveness of its existing BMPs. <br /> Response: The MRP is approved by the Regional Board,but provides that the Executive Officer(or <br /> the Regional Board) may approve modifications thereto or may reissue the MRP. California Water <br /> Code section 13223 permits regional boards to delegate any of its powers and duties to the executive <br /> officer with the exception of certain enumerated powers and duties. The issuance of a monitoring <br /> and reporting program is not among these enumerated powers and duties and may permissibly be <br /> delegated. <br /> Pursuant to 40 CFR 122.26(d)(2)(iv)(A), the Permittees are required to provide an estimate of the <br /> expected reduction of pollutant loads for source and structural control BMPs proposed in their <br /> SWMP. The Regional Board expects the Permittees adhere to this requirement. <br /> 55. Comment: (DK Comment 8(b) [incorrectly marked as 8(a)]) Monitoring Program,Urban Discharge <br /> Monitoring, B: Despite the fact that previous monitoring has shown that water quality standards are <br /> violated at every monitored outfall during every monitored storm event,the Permit inexplicably <br /> proposes to reduce the number of monitored outfalls from five to four. Please provide a justification <br /> for this reduction in the number of monitored outfalls, especially, considering that the entire <br /> downtown area including much of the old industrial area east of downtown and the old ship yards <br /> along the Stockton Deep-Water channel (which include operating steel fabrication facilities)have <br /> never been monitored for storm water discharges. DeltaKeeper proposes that the fifth monitored <br /> location be reestablished at the head of McCloud Lake. We support moving one of the two <br /> Mosher Slough monitoring locations to Smith Canal. However,the Permit describes the Smith <br /> Canal site as in the vicinity of the Pershing Drive over-crossing. This location should be specified <br /> as the large pipe at the head of Yosemite Lake. This outfall drains a large mixed-urban/industrial <br /> area that extends east to highway 99. <br /> The Permit inexplicably proposes to reduce the number of monitored storm events from three to <br /> two. Please provide the justification for this reduction in the number of monitored events. The City <br /> of Stockton has repeatedly claimed that one of the reasons they have failed to evaluate the <br /> effectiveness of BMPs is that a large number of data points are required to establish trends. Why <br /> would Regional Board staff reduce the number of sampling events, thus making it more difficult to <br /> assess the effectiveness of BMPs. Monitoring is the only performance measure in the Permit that is <br /> connected to water quality. Reductions in the frequency of discharge monitoring cannot be claimed <br /> to be MEP. DeltaKeeper requests that the number of monitored storm events be reestablished <br /> as three storm events per year. <br /> Response: As stated in the fact sheet for the Tentative Order, "[t]wo of these residential basins, <br />