The Philadelphia Water Department champions the goal of cleaner, healthier rivers and streams for Philadelphians and visitors alike. We also value the advocates who care deeply about protecting our waterways for generations to come. However, some characterizations of PWD’s work in the recent PennEnvironment report “Sewage Pollution in the Philadelphia-Camden Region” and associated webinar(s) do not fully reflect the complexity of managing and upgrading an aging urban sewer system while safeguarding public health and balancing affordability for ratepayers.
Combined sewer overflows (CSOs) are a real and longstanding challenge in older cities like Philadelphia. That’s precisely why, nearly 15 years ago, the City launched one of the most ambitious urban water quality programs in the nation: Green City, Clean Waters. PWD has worked tirelessly to implement water quality investments to benefit our communities and uses an innovative approach to achieving water quality improvements, creating the programs, policies, and tools necessary to facilitate a groundbreaking investment in Philadelphia’s waterways and communities. To date, we have met or exceeded all regulatory obligations set by the Pennsylvania Department of Environmental Protection (PADEP) and United States Environmental Protection Agency (USEPA) associated with this clean water program.
Proven Progress
Since the program began, Philadelphia has:
- Reduced combined sewer overflow volumes by more than 3.08 billion gallons annually, exceeding regulatory targets
- Achieved nearly 40% of the program’s long-term CSO reduction goal
- Met or exceeded regulatory milestones established by the Pennsylvania Department of Environmental Protection and the U.S. Environmental Protection Agency
These reductions are measurable, verified, and ongoing.
Clarifying the Data
- The statistics cited in Penn Environment’s materials include inferences drawn from PWD’s own reporting and reflect real challenges with combined sewer overflows (CSOs) in wet weather.
- PWD has projects under construction that are expected to reduce another 600 million gallons of CSOs annually in the next 3 years. These projects include upgrades to regulator chambers, collections, conveyance and wastewater treatment facilities.
- The 2009 CSO Long Term Control Plan Update (LTCPU) (also known as Green City, Clean Waters, or GCCW) was formally approved by the PADEP in a 2011 Consent Order & Agreement (COA), and USEPA in 2012 through the Administrative Order for Compliance on Consent (AOCC). These agreements were not the product of enforcement actions or violations; rather, they serve as regulatory mechanisms for approving the City’s CSO program and implementation approach.
Why This Challenge Exists
- Philadelphia’s original sewer system was designed more than a century ago. It serves a 60-square-mile combined sewer area with 165 permitted outfalls across the Delaware, Schuylkill, Cobbs, and Tacony-Frankford watersheds — some of the most densely-built historic neighborhoods in the country.
- Infrastructure planning and construction at this scale requires long lead times for:
- Design
- Permitting
- Extensive engineering and environmental review
- Federal and state regulatory coordination
- Community engagement
- Significant financial investment
- Large-scale improvements, like storage tanks, tunnels, or sewer separation, cannot be implemented overnight — but they are being evaluated deliberately and responsibly.
Read the full response here.