Certificate of Occupancy Hold Policy

PWD implemented this policy to ensure that the project closeout process is completed for projects applicable to the Stormwater Regulations.

With the issuance of the CO, properties are occupied and ownership is often transferred, making it challenging to conduct the required inspections and survey, as well as to correct any deficiencies. It is critical that the responsible contractors and design professionals are not released from project-related obligations until all PWD regulatory requirements have been satisfied.

Compliance with the Stormwater Regulations, including completion of project closeout, is critical to the City of Philadelphia meeting State and Federal permit requirements. For more information on these requirements visit water.phila.gov/reporting.

At the conclusion of construction, the applicant is responsible for ensuring project closeout with PWD. Once the closeout process is complete, PWD will automatically release the CO hold. To complete the project closeout process, the following criteria as outlined in Appendix M of the Philadelphia Stormwater Management Guidance Manual (Manual) must be met: 

1. Resolve all construction violations (Manual Sections 5.1.3 and 5.2).
2. Pay all review fees in full (Manual Section 2.3.1). 
3. Obtain a Post-Construction Stormwater Management (PCSM) Final Inspection Report indicating all stormwater management practice (SMP) construction as complete (Manual Section 5.1.4). 
4. Execute and record an Operations and Maintenance (O&M) Agreement reflecting the constructed conditions (Manual Section 6.1). 
5. Submit a compliant Record Drawing (Manual Section 5.3.2) 

The project closeout process and associated requirements are not new and are a component of compliance with the PWD Stormwater Regulations, enacted in 2006. The only change is that, as of August 1, 2023, completion of project closeout is required as a condition to obtain a CO.

The PWD CO Hold Policy was implemented on August 1, 2023. Projects receiving PWD stormwater management review sign-off on that date or later will see a hold on permit completion for that permit. Existing permits that received sign-off prior to this date will not see a hold unless otherwise notified in writing by PWD.

Applicants who want to phase their construction and CO issuance should provide a phasing plan with their Post-Construction Stormwater Management Plan (PCSMP) submission to PWD. Information related to critical financial deadlines as well as building permit application numbers should be identified on the phasing plan, as available. The phasing plan will also be discussed during the Pre-Construction Meeting. PWD will release the CO hold on an individual permit once compliance for that permit and phase is confirmed via the project closeout process.

Applicants can submit a PCSMP Field Change to add a new or alter an existing a phasing plan. If planned phases need to be changed based on material and/or contract availability or other factors, a revised phasing plan must be submitted through the field change process.

Issuance of a Temporary CO is under L&I jurisdiction. Refer to the L&I website for more information.

The assigned PWD inspector for the project will notify the contractor and applicant team to schedule a Final Inspection. Likewise, the contractor and/or applicant team may request that a Final Inspection be scheduled. To request a Final Inspection, complete the Final Inspection Request Form. Confirmation will be provided upon receipt. After reviewing the submitted documentation, PWD will follow up with next steps.

PWD’s service level goal is to issue a Final Inspection report within 48-hours of conducting the inspection.

Record Drawings are construction drawings revised to represent the site’s as-built conditions, including, at a minimum, all locations, dimensions, elevations, and materials as constructed and installed.

Applicants must submit the Record Drawing via the Project Dashboard on the PWD Stormwater Plan Review website. Record drawings may be prepared by registered professionals, which can include Professional Engineers, Registered Architects, Landscape Architects, Professional Land Surveyors, Professional Geologists, or Licensed Contractors. To properly prepare a Record Drawing, it is recommended that the contractor keep a copy of the Approved PCSMP on-site to document changes as they occur.

Yes, the responsible contractor may submit the Record Drawing. The contractor is often best equipped to compile the as-built information and is required to track critical data throughout construction using the project-customized Construction Certification Package. The preparer of the Record Drawing plan must display prominently their signature and professional seal, or, in the case of Licensed Contractors, their signature and L&I Contractor License Number, on each Record Drawing plan sheet.

PWD’s service level goal for Record Drawing review is seven days from date of receipt.

If construction of a green roof is proposed as part of the Approved Post-Construction Stormwater Management Plan (PCSMP), then the green roof must be constructed and planted prior to the PWD Final Inspection and before PWD will release the CO hold. Similarly, bio-basins and any other surface-based vegetated SMPs must be planted for project closeout.

Projects that are awarded increased density as part of their Zoning Permit in exchange for construction of a green roof in accordance with Code Section with § 14-702(16) must construct and plant the green roof before L&I will issue the CO.

SMPs that rely on vegetation must be planted for project closeout. Planting windows should be considered early in construction planning so as not to impede project closeout. In the event these windows can’t be met, planting choices can be re-evaluated to better accommodate the season.

PWD requires that the O&M Agreement be executed prior to issuance of the PCSMP Approval and PWD sign-off on the building permit application. However, changes to the approved SMPs during construction can require a revised O&M Agreement to be executed and recorded. The applicant is required to contact PWD about any changes to the approved PCSMP and initiate a Field Change review. PWD will notify the applicant if the O&M Agreement must be revised.

If the disturbance associated with the Alteration/Addition Permit triggers the PWD Stormwater Regulations, the permit is applicable to a PWD hold.

A “master” approval is not a permit, rather, it is an approval of a standard design. The master approval will typically have a Site Permit associated with the work and the PWD hold will be placed on the Site Permit. Similarly, housing developments that are filed as a City Managed Project will be subject to a PWD CO hold on the Site Permit.