Chapter 2 Submission, Review, and Approval Procedures

2.6 PWD’s Role in Philadelphia’s Development Process

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Philadelphia Water Department (PWD) approvals are only one part of the full set of approvals required for development within Philadelphia. PWD approvals are often prerequisites for other approvals or permits. For example, the PWD Post‑Construction Stormwater Management Plan (PCSMP) approval is required before the applicant may obtain a Building Permit from the City of Philadelphia Department of Licenses and Inspections (L&I). Less formally, PWD also coordinates reviews with other City agencies to promote continuity between department reviews and expedite the applicant through the City’s development review process when feasible. This Section provides a brief description of the City departments with which PWD interacts and overlaps as part of the City’s development review process. It does not describe the full extent of each department’s work, but rather a perspective of their work as it relates to PWD’s review.

Licenses and Inspections

Projects that apply for permits through the L&I Electronic Commercial Licensing, Inspection, and Permit Services Enterprise (eCLIPSE) system will require separate sign-offs from each applicable PWD unit. The applicant is referred to the L&I eCLIPSE FAQs website for more guidance on eCLIPSE.

A summary of required PWD approvals by L&I permit type is provided in Table 2.6‑1.

Table 2.6‑1: Summary of Required PWD Approval by L&I Permit Type
L&I PermitRequired PWD Approval
Zoning Permit
  • PWD Conceptual Approval is required for projects that propose more than 5,000 square feet of earth disturbance or applying for a stormwater management height or density bonus.
Building Permit – Demolition
  • PWD Conceptual Approval is required for projects that propose more than 5,000 square feet of earth disturbance.
  • Projects that propose more than one acre also require a NPDES Permit from PA DEP (Section 2.7).
  • Discontinuance Permits are required to terminate existing water services prior to demolition.
Building Permit – Foundation Only, New Construction, and Site/Utility
  • PWD Conceptual Approval is required for projects that propose more than 5,000 square feet of earth disturbance.
  • If more than 15,000 square feet of earth disturbance (5,000 square feet in the Darby and Cobbs Creeks Watershed) is proposed, PCSMP Approval will be required.
  • A NPDES Permit is required from PA DEP for projects that propose more than one acre of disturbance (Section 2.7).
  • Approvals are also required from Utility Plan Review and Sewage Facilities Planning (Act 537).
  • Private Cost Approval and approval from Green Stormwater Operations may be required if the project will impact PWD infrastructure.
Plumbing Permit
Enforcement

PWD Development Services staff coordinate with L&I staff in the enforcement of development projects that are not in compliance with Stormwater Regulations or the Pennsylvania Department of Environmental Protection (PA DEP) Erosion and Sediment Pollution Control Program Manual (2012 or latest). When deemed necessary, PWD will request L&I enforcement support on non-compliant properties.

The City of Philadelphia Plumbing Code
Floodplain Construction Approval

L&I requires flood protection documents and flood protection scoping meetings for projects that are proposing construction, additions, renovations, and/or alterations in the floodplain over a project cost minimum. Floodplain scoping meetings should be held before zoning and/or Building Permit applications in order to receive a required Project Summary to submit with the application. PWD will refer the applicant to L&I for specific questions regarding applicability and requirements for work in the floodplain.

Streets Department

The Streets Department is involved in the review of most development projects, particularly if a street opening or closing permit is required, there is bollard installation, new driveway or curb cuts are to be constructed, there are changes to ROWs or curb line widths, Americans with Disabilities Act (ADA) improvements are needed, or other ROW improvements are involved. As part of their plan review process, the Streets Department solicits comments from PWD Stormwater Plan Review and PWD Engineering Design Review to incorporate in their review letters. The comments provided by PWD will often direct the applicant to make a formal submission to the appropriate PWD unit for review.

If the applicant is proposing to make changes to PWD infrastructure located within the public ROW to accommodate a development, this work must be reviewed by the Streets Department. This includes minor improvements, such as relocation of an inlet, as well as major improvements, such as the complete striking of an existing drainage ROW. As part of their review, PWD Engineering Design Review will clarify for the applicant when and how the Streets Department should be notified.

Department of Planning and Development

The Department of Planning and Development facilitates the Division of Development Services, which helps large real estate projects connect to key City departments through Developer Services Committee Meetings. The applicant can contact the Department of Planning and Development to convene a meeting of the committee. A representative from PWD Development Services will attend these meetings.

Philadelphia City Planning Commission

The Philadelphia City Planning Commission (PCPC) reviews development projects for various reasons, including the relocation of lot lines, location in Neighborhood Conservation Districts, Façade Control Districts, the construction of parking garages or surface parking lots, parking lot stripe modifications, and location within floodplains. As part of PCPC review, PWD’s Conceptual Approval (Section 2.3) may be required. If the project involves relocation or striking of a public or drainage right-of-way (ROW), approval from PWD may be required. These prerequisite PWD approvals may also be requested by the Civic Design Review Committee for projects that trigger this requirement.

While PWD and PCPC generally conduct their reviews independently, these agencies work directly with each other to administer §14-510 Wissahickon Watershed Overlay of the Philadelphia Code.

Wissahickon Watershed Overlay

To help reduce flooding, erosion, siltation, and channel enlargement resulting from development within the Wissahickon Creek Watershed, additional stormwater management requirements and impervious coverage limits may apply to projects within this watershed.

Projects located in the Wissahickon Creek Watershed are subject to the Philadelphia City Code §14-510 / Wissahickon Watershed Overlay (WWO) District. A map of the overlay is provided within the Code; however, the applicant can determine whether the project lies within the overlay by using the City’s Atlas map tool.

If the project is in the WWO, the applicant is advised to meet with PCPC prior to submitting the project’s Existing Resources and Site Analysis (ERSA) Application. Depending on the project’s location within the WWO, lot size, and net change in impervious area, PCPC may restrict new impervious cover, or impose additional stormwater management requirements (beyond PWD’s Stormwater Regulations), which must be noted by the applicant in the project’s ERSA Application (Section 2.1.1). Should the project be applicable to additional requirements as determined by PCPC, PWD Stormwater Plan Review will be responsible for review of the PCSMP.

PCPC does not use an earth disturbance threshold when determining whether stormwater management is required. Therefore, it is possible for development projects to trigger Post‑Construction Stomwater Management Requirements under the WWO without triggering the Stormwater Regulations. Projects that fall under this category must follow the Development Compliance Review Path as defined in Section 2.2.1. These projects must also abide by all PWD design standards when designing systems to meet the WWO stormwater requirement.

Office of Property Assessment

For projects that trigger the Stormwater Regulations, PWD uses the Office of Property Assessment (OPA) address records to track projects and determine the appropriate address used in recording the Operations and Maintenance (O&M) Agreements (Section 6.1). The applicant is encouraged to refer to the OPA website to confirm the legal address prior to submitting an ERSA Application to PWD. If an applicant disagrees with the address being used by PWD in the preparation of the O&M Agreement, the applicant should contact OPA for resolution.

PWD also uses OPA records to determine property classification (residential, non-residential, or condominium), which factor heavily into determining a monthly stormwater bill. If, over the course of a development, these features change, the applicant is advised to contact PWD Stormwater Billing and Incentives so that the appropriate changes are reflected in subsequent stormwater bills.

Department of Records

O&M Agreements are recorded against the property for all projects that trigger the Stormwater Regulations or Stormwater Retrofit projects that receive Stormwater Grant funding. The owner is responsible for the recording of the O&M Agreement with the Department of Records (DOR); however, PWD may record this Agreement on the owner’s behalf. The DOR charges a fee for all recordings and the DOR fee schedule is used to determine O&M Agreement recording fees. To obtain a copy of the recorded O&M Agreement, the applicant must contact DOR. PWD also uses DOR deed records to determine parcel boundaries.

Historical Commission

Properties on the Philadelphia Register of Historic Places may need approval from the Philadelphia Historical Commission before starting any development or Stormwater Retrofit work. The applicant is referred to the Philadelphia Historical Commission website for more information on design reviews. Stormwater Billing and Incentives can assist with coordination with this commission for Stormwater Retrofit projects.

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