The below response from July 20 was updated July 24.

We are thrilled to see an invested advocate organization that cares so much about water quality in our region. However, the Penn Environment report’s assertions do not consider the reality of implementing the current Green City, Clean Waters plan in addition to more infrastructure projects, done at a greatly accelerated rate.

It is also the position of the City of Philadelphia, including the Health and Police Departments charged with protecting public health and safety, that there are far more barriers to swimming in urban rivers and streams than those posed by sewer overflows following storms. Even in a dry start to the summer, there have been two tragic drowning deaths in Philadelphia streams this year.

What we have done

PWD has made significant progress in reducing combined sewer overflows in the last 12 years of the Green City, Clean Waters program. As of the last required regulatory reporting period in 2021, PWD reduced the combined sewer overflows volume by 3.08 billion gallons in a typical year, exceeding the required combined sewer overflow volume reduction target of 2.044 billion gallons by more than 1 billion gallons.

We have continued to implement projects since that regulatory reporting and continue to see additional volume reduction due to project implementation. PWD has additional projects under construction that will reduce combined sewer overflows by an additional 600 million gallons annually in the next three years.  In addition to the green stormwater infrastructure projects that are being implemented throughout the city, there are several larger projects that are anticipated to be completed that will have significant impacts on reducing combined sewer overflows, including modification to regulator chambers, interceptor expansion, and an addition of a pretreatment building at the Northeast Water Pollution Control Plant that will allow more flows to be treated at that plant.  We received a $100 million, low-interest, federally backed PENNVEST loan to help finance this project and reduce impacts on our ratepayers over time.

What we still need to do

PWD has 13 years remaining in the Consent Order Agreement that created the Green City, Clean Waters initiative, with nearly five billion gallons of additional combined sewer overflow volume left to eliminate annually.  At the completion of Green City, Clean Waters, we are targeting to reduce combined sewer overflows by approximately 8 billion gallons in the typical year from the original 13 billion gallons. We continue to have benchmark performance standards every 5 years, with the next at Year 15 of the program in 2026. Throughout the implementation process, we will continue to develop approaches to meet each combined sewer program performance standard while balancing PWD’s other priorities that also need to be funded.

Background on Combined Sewers

During dry weather, the combined sewer system and wastewater treatment plants have the capacity to transport and treat all the sanitary sewage entering the system (including flow from our wholesale customer communities). However, when flow in the sewers increases as a result of rainfall or snowmelt, the sewer pipes or treatment plants may reach their capacity. When this happens, the EPA permits Philadelphia, as it does with other cities with combined sewer systems, to discharge excess wastewater into nearby waterbodies to prevent health and human safety issues that may result from localized flooding in neighborhoods and in treatment plants.

Replacing the entire combined sewer system would be prohibitively expensive. As a utility, PWD must make careful decisions about our drinking water, wastewater, and stormwater systems while balancing the cost, which is passed on to our customers through water bills. PWD’s 25-year plan to reduce CSOs is a work in progress—this is a multi-billion-dollar investment in traditional and green infrastructure. We are investing the time and money needed to address the problem of combined sewer overflows. This plan represents a robust and ambitious program that balances regulatory priorities with the pace of implementation.

The plan and its timeline are not arbitrary – it took many years of collaboration with state and federal regulators to design a solution that is feasible and that can be implemented at a pace that our customers can afford.

Regulatory context

PWD is a regional drinking water, wastewater, and stormwater management entity with wholesale customer contracts with several neighboring municipalities. As the utility managing water quality in receiving waters downstream from hundreds of miles of urban and suburban development, we are mindful of water supply protection as well as receiving water quality and the implications of lack of proper management during large-scale events.

PWD has a consent order in place requiring the reduction of combined sewer overflows through the implementation of green stormwater infrastructure, treatment plant, and collection system projects – Green City, Clean Waters. At the beginning of the program in 2011, Philadelphia experienced 13 billion gallons per year of combined sewer overflow in a typical year.

Dry weather water quality has been a priority of PWD for decades. At present, Philadelphia does not have known actively discharging sanitary sewer overflows. Over the past decades, as problems were identified, they were addressed by adding new infrastructure. PWD is committed to ensuring these discharges are remediated and continues to closely monitor locations with known capacity challenges.

CSO outfalls that discharge during dry weather conditions are very infrequent. PWD maintains a vast network of monitors in the combined sewer system that we use to make sure that there are no dry weather overflows from the CSO outfalls.

PWD has a robust commitment to reducing dry weather flows in the City’s municipal separate sewer system (MS4) through our Defective Lateral Abatement Program. It is worth noting that when comparing the scale of water quality impairments, dry weather discharges in the MS4 portions of the city are on a far smaller scale than CSO discharges during wet weather.

Balancing regulatory priorities

PWD remains committed to reducing combined sewer overflows through a multitude of asset enhancements and project implementation. However, an initiative of this scale needs time to implement. PWD heavily invests funding and resources in many other programs, including our Drinking Water Revitalization Plan, to address other regulatory requirements. We are simultaneously investing in protecting and replacing drinking water and wastewater infrastructure. We are spending a tremendous amount of money to make substantial progress in those areas as well, while also making progress in reducing CSOs.

Why acceleration is challenging

PWD has resources dedicated to the management of aging assets, compliance with multiple types of regulatory obligations, and a series of emerging issues and public health interests, as well as the occasional unpredictable emergency. Each of these focus areas necessitates dedicated staff resources and funding to establish scopes, schedules, and measurable benefits. It takes time to plan for infrastructure investments. Time is spent understanding the source or cause of an issue and to determine the best solution for addressing it. It takes time to work with our regulatory agencies to determine approval for compliance approaches and regulatory mechanisms for approving plans, projects, and permits. It takes time to site, design, and garner stakeholder approval for initiatives. Finally, it takes time to construct, operate and maintain investments. Programs that PWD is leading are complex, costly, and resource intensive.

Additional funding, especially in the form of grant funding that would not increase the burden on water bills, would certainly be valuable and PWD is advocating for this. Our ratepayers are paying for these increasing regulatory obligations. However, there seems to be a misconception that additional funding might lend itself to either project acceleration or additional project implementation. While this may be possible in some instances, the challenges with acceleration are both temporal and financial. PWD must remain focused on planning for known regulatory obligations while being mindful of potential changes to ensure that projects planned for today are not incompatible with future needs while remaining agile in addressing emergencies and other pressing priorities as they emerge. With this balancing of priorities, it is not often prudent to have “extra” projects identified, planned, designed, and ready for construction prior to the planned implementation. Projects are planned based on program priorities, regulatory obligations, and their relationship to future projects as many are interrelated in their function and benefit.

It is simply not realistic to move the goalposts on a massive, 25-year initiative at the halfway point to dramatically increase the implementation pace or add new projects. Even if funds were unlimited, the resources to support acceleration are not. It would likely take more than a decade to plan, design and implement the drastic changes to Green City, Clean Waters that are being alluded to.

The entire $70 million that Penn Environment cites in Pennsylvania’s allocation for Clean Water State Revolving Funds could be used for a single large project in Philadelphia, leaving no funds for any other part of the Commonwealth. Additionally, these funds are overwhelmingly available as loans that must be repaid.