The Philadelphia Stormwater Management Guidance Manual (the Manual, or SMGM) is a comprehensive resource for the development community in complying with the Philadelphia Water Department (PWD) Stormwater Regulations (Stormwater Regulations). The Stormwater Regulations require on-site stormwater management for development projects above a certain size, helping to improve the health and vitality of Philadelphia’s waterways along with the City’s own sizable clean water investments. Other types of construction activities may also trigger portions of the Stormwater Regulations, including demolition and voluntary stormwater retrofit projects.
At its core, the Manual provides detailed guidance for the applicant on how to most quickly and efficiently comply with the Stormwater Regulations for development and other construction projects. Using this Manual, the applicant will be able to do the following:
- Determine if a project is regulated under the Stormwater Regulations and, if so, what specific requirements need to be met;
- Learn about new ways to incorporate green approaches to stormwater management that provide benefits for development projects and expedite the stormwater approval process;
- Design specific stormwater management practices (SMPs) to meet PWD’s standards;
- Prepare and submit application materials;
- Learn how to ensure proper installation and protection of SMPs during construction activity; and
- Obtain information on post-construction and operations and maintenance (O&M) requirements.
The Manual provides the development community with detailed guidance on designing stormwater management systems to meet the Stormwater Regulations, understanding PWD’s stormwater-related requirements and approval processes, and preparing submissions to PWD. The Manual also provides guidance on topics relating to the proper construction and maintenance of SMPs.
The Manual has six Chapters and a series of Appendices. Chapters 1 through 4 focus on the stormwater design, submittal, and approval process, while Chapters 5 and 6 discuss construction and post-construction topics. As design, submittal, and review processes are closely related, the applicant will find cross-referencing throughout the Manual, particularly between Chapters 2 and 3. The applicant should use each Chapter as follows:
|Chapter||How to Use|
|Chapter 1 – Regulatory Requirements||Learn about the Stormwater Regulations, determine if a project is subject to the Stormwater Regulations, and find out which requirements need to be met|
|Chapter 2 – Submission, Review, and Approval Procedures||Understand the submission and review process for a project and get detailed guidance in preparing submissions to PWD|
|Chapter 3 – Site Design and Stormwater Management Integration||Learn how to perform site assessments, including infiltration testing, and design stormwater management controls, including disconnected impervious cover and SMPs, to comply with the Stormwater Regulations|
|Chapter 4 – Stormwater Management Practice Guidance||Obtain SMP-specific guidance on use, applicability, components, design requirements, materials specifications, construction sequencing, and O&M|
|Chapter 5 – Construction Guidance||Understand PWD’s construction inspection process, identify common problems with SMP and Erosion and Sediment Control (E&S) construction, and prepare a Construction Certification Package and Record Drawings|
|Chapter 6 – Post-Construction and Operations & Maintenance Guidance||Understand PWD’s SMP maintenance requirements, learn how to inspect, operate, and maintain SMPs and other stormwater controls, get detailed guidance on O&M Agreements, and apply for stormwater billing credits|
The Appendices contain additional resources, including watershed and Flood Management District mapping, submission checklists, a sample Record Drawing, and landscape guidance. A list of Appendices is provided in the Manual table of contents.
PWD requires that many development sites in the City implement stormwater management controls. The Stormwater Regulations define the specific requirements that need to be met for various types of development in the City. PWD’s Stormwater Regulations fall into two categories, Post-Construction Stormwater Management (PCSM) Requirements and an E&S Requirement.
PCSM Requirements regulate how stormwater runoff leaves a project site in the built, or post-development, condition.
There are four components of PWD’s PCSM Requirements:
- Water Quality, to recharge the groundwater table and reduce pollution in stormwater runoff;
- Channel Protection, to minimize channel erosion resulting from stormwater runoff by controlling the peak flow rates for medium-sized storms;
- Flood Control, to prevent, through peak flow rate control, flooding caused by large storm events that could cause damage to life or property; and
- Public Health and Safety Release Rate, to minimize the impact of flooding in areas of the City with infrastructure capacity restrictions through peak flow rate control.
The E&S Requirement stipulates that practices be employed during construction to reduce any erosion and sedimentation that occur as a result of development activities.
Private Development Services is a program within the PWD Green Stormwater Infrastructure (GSI) Implementation Unit. Private Development Services is responsible for administering the Department's Stormwater Regulations through the review, construction inspection, and maintenance inspection of development sites. Within Private Development Services are two programs: Stormwater Plan Review and Stormwater Inspections. Private Development Services provides a range of services relating to the enforcement and implementation of the Stormwater Regulations, including the following:
- Reviewing development plans for compliance.
- Ensuring that SMPs are correctly designed, installed, and maintained in accordance with the Stormwater Regulations.
- Coordinating with other PWD programs involved in the development review process to establish consistency across the Department and ensure required approvals are obtained.
- Acting as PWD’s link to the larger development process in the City, most critically the Zoning and Building Permit process administered by the City of Philadelphia Department of Licenses and Inspections (L&I). The applicant must receive approvals from PWD before a Zoning or Building Permit may be issued.
- Coordinating with other reviewing entities such as the Philadelphia City Planning Commission (PCPC), Philadelphia Streets Department (Streets Department), and the Pennsylvania Department of Environmental Protection (PA DEP), to ensure that consistent information is provided by the applicant to all agencies.
- Administering inspection activities to ensure that SMPs are installed according to the approved plans.
- Conducting inspections at the close of construction to record information about the project’s as-built conditions, which the applicant must incorporate into a Record Drawing.
- Conducting post-construction inspections to ensure the property owner maintains SMPs to design function.
Contacting Private Development Services
PWD encourages the applicant to contact staff throughout the project lifecycle, from preliminary planning through O&M. If additional clarity or discussion is required, the applicant is encouraged to request in-person meetings. Staff can be reached during normal business hours (8 am to 5 pm) at (215) 685-6387 or email@example.com. The general phone line and email account are both monitored regularly by staff. Before a reviewer has been assigned to the project, the applicant should use the general email account for all inquiries to ensure an efficient response time.
The Stormwater Plan Review website (www.pwdplanreview.org) is geared toward the applicant and the development community at large and is the best place to find all applicant resources. Using the website, the applicant can access technical resources, such as process flow charts, Standard Details, the Online Technical Worksheet, and informational fact sheets. Copies of the Manual can be downloaded from the website. The applicant may use the website to submit their application for review and monitor the review status.
Unmanaged stormwater runoff—rainfall in developed areas that quickly “runs off” of impervious surfaces rather than soaking into the ground—negatively affects the aquatic and streamside habitats of streams and rivers in Philadelphia. These water bodies suffer from a variety of problems and as a result, many of Philadelphia’s streams do not support healthy aquatic communities. Similarly, pollution from unmanaged stormwater that reaches the drinking water intakes on the Schuylkill and Delaware Rivers threatens the City’s potable water supply.
In contrast, healthy streams and rivers have lower rates of erosion, plenty of flow during dry periods for fish and aquatic life, high water quality that supports both recreational uses such as swimming and fishing and potable water use, and flood less frequently and less severely. Clean, healthy rivers are a valuable community amenity that attracts residents and enhances the overall quality of life for residents. The goal of healthy, clean rivers in Philadelphia is an ambitious one, but one that PWD and its partners are aggressively working toward.
Stormwater and Land Development
Land development activities, such as the construction of new buildings, roads, driveways, and parking lots, can lead to increased stormwater runoff and pollution. As land is developed, increases in impervious areas (hard surfaces like rooftops, roads, and parking lots) limit the amount of rainfall infiltrating into the ground. Rates of evaporation are also reduced due to a lack of vegetation. Conversely, in “natural,” undeveloped conditions, the majority of rainfall either infiltrates or evaporates back into the air. As rainfall flows across the developed land surfaces, it picks up pollutants, such as sediment, fertilizers, pesticides, bacteria, metals, and oils, and flows directly into streams, rivers, or other bodies of water. Every acre of impervious cover in Philadelphia produces about 1 million gallons of polluted runoff per year, causing sewer overflows, degraded stream habitat, and water quality problems.
These problems are not unique to Philadelphia. Stormwater regulations are changing around the country to address these and similar problems. These changing regulations include new approaches to stormwater management, which often require improvements in stormwater quality prior to discharge, reductions in the volume and rate of runoff, and reductions in stormwater-related erosion and sedimentation. Through these regulations, cities and developers are working together to prevent additional pollution and damage to waterways by controlling stormwater. The updated Stormwater Regulations in Philadelphia ensure that the City has an effective, comprehensive stormwater program that meets State and Federal requirements and is adaptable to a changing regulatory context.
PWD’s Regulatory Context
The City of Philadelphia is required, by a series of State and Federal regulations and mandates, to clean up its waterways. While PWD is investing billions of dollars to implement the bulk of the required upgrades, PWD, through the Stormwater Regulations, also requires the development community to do its part to help manage stormwater. Table 2 provides an overview of the many State and Federal laws that require PWD to work toward cleaning up Philadelphia’s waterways.
Clean Water Act: The Clean Water Act (CWA) of 1972 aims to restore and maintain the chemical, physical, and biological integrity of the nation’s waterways. PWD is primarily charged with ensuring CWA compliance in Philadelphia and does so through a variety of activities, such as building and maintaining public stormwater infrastructure, regulating development, implementing municipal pollution prevention best practices, meeting pollutant discharge standards at sewage treatment plants, and monitoring industrial and commercial dischargers.
Combined Sewer Overflow (CSO) Control Policy: Published by the Environmental Protection Agency (EPA) in 1994, this policy established a national approach for controlling CSOs through the National Pollutant Discharge Elimination System (NPDES) Permit program. CSOs occur when combined sewers (sewers that convey both stormwater and sewage in the same pipe) reach capacity as a result of stormwater runoff entering the pipe network during rain and snowmelt events. When this happens, the PA DEP permits Philadelphia, as is common with other cities containing combined sewer systems, to discharge excess untreated wastewater into nearby waterbodies. Communities with combined sewer systems are required to develop a Long Term Control Plan to outline steps toward full compliance with the CWA. PWD submitted its original Long Term Control Plan in 1997. In 2006, PWD enacted Stormwater Regulations that included requirements to assist the City in addressing CSOs. Then, in June 2011, PWD and PA DEP entered into a Consent Order and Agreement (CO&A), a binding legal agreement that outlines the water quality targets the City needs to meet to reduce CSOs.
PWD prepared and submitted to PA DEP a Long Term Control Plan Update (LTCPU) known as Green City, Clean Waters, to outline specific steps needed to implement the provisions of the CO&A. Green City, Clean Waters outlines a 25-year, $2.4 billion plan to protect and enhance Philadelphia’s combined sewer watersheds by managing stormwater with innovative green stormwater infrastructure. PWD’s approach differs from the methods used by other cities to address CSOs, which typically involves building large, underground tunnels and storage tanks to temporarily hold combined sewer water so that it can eventually be treated by wastewater plants. In Philadelphia, this approach was found to be cost prohibitive for residents; it also did not meet restoration goals for the City’s waterways.
|Regulation||Objectives||How PWD Meets These Objectives|
|Clean Water Act of 1972||Restore and maintain the chemical, physical, and biological integrity of the nation’s waterways||
|The Safe Drinking Water Act of 1974||To ensure safe drinking water for the public by establishing standards for water quality||
|The Pennsylvania Stormwater Management Act of 1978||Develop county-based stormwater management plans to ensure that stormwater is managed properly, particularly with regard to flooding||
|NPDES MS4 Stormwater Regulations||Reduce and eliminate sources of pollution coming from municipally-owned separate sewer systems into the Nation’s water bodies||
|CSO Control Policy||Eliminate discharges of untreated wastewater through combined sewer overflows into the nation’s waterbodies||
PWD’s Stormwater Regulations cover a wide spectrum of development and construction projects. Under the Stormwater Regulations, not all projects are subject to the same requirements. Some projects may need to meet multiple requirements, while others may be subject to only certain portions of the Stormwater Regulations (Figure 2). The application and review process are different for different types of projects, as described below.
Stormwater Regulations applicability refers to which projects are subject to the Stormwater Regulations, which may not necessarily require on-site stormwater management. The regulatory applicability factors include the amount of earth disturbance associated with a project, its development type, and its watershed. Understanding the Stormwater Regulations' applicability to a project directly impacts the type of review PWD conducts and the subsequent submission requirements. The applicant should thoroughly review Chapter 1 to understand PWD’s definitions of these factors to determine if the Stormwater Regulations are applicable to a project, and to obtain guidance on how the Stormwater Regulations may be applicable (i.e., the requirements of the Stormwater Regulations to which a project would be subject).
Understanding the Submission and Review Process
The final piece of understanding the Stormwater Regulations focuses on preparing submissions and navigating the review process. PWD organizes the different submission procedures and review processes into four Review Paths. Review Paths are a linear series of submission and review steps (Review Phases) taken to obtain stormwater management approval or exemption. There are four Review Paths, which are discussed in greater detail in Section 2.2. Figure 3 provides additional detail on the steps in PWD’s stormwater review and approval process that occur during the design process. These steps are discussed in more detail within Section 2.3.
Review Process Timelines and Milestones
It is understandable that the applicant would be interested in how long the review process will take. As with many other aspects of PWD’s program, it depends strongly on the type of project and the associated stormwater management requirements, submissions, and reviews. Upon submission of an Existing Resources and Site Analysis (ERSA) Application and depending on the project’s Review Path, there will be different Review Phases. For the Conceptual Review Phase, PWD strives to review all complete Conceptual Review Phase Submission Packages within five calendar days. For projects undergoing a Post-Construction Stormwater Management Plan (PCSMP), E&S, PCSMP field change, or Record Drawing review, a review of complete Submission Packages within 15 calendar days is targeted. The fastest way to get a project through the review process is to provide PWD with a high-quality submission that meets all of the submission requirements. Other strategies to streamline the process are to meet with PWD prior to submissions of larger and more complicated projects and to provide as much detail as possible about the project early in the review process.
Chapter 3 and Chapter 4 provide detailed guidance to the applicant in designing stormwater management systems that comply with the Stormwater Regulations. PWD offers the designer a standardized and systematic design process that is consistent for every project. This Section provides a first look at PWD's preferred approach to stormwater management design.
SMP Design Approach
The SMPs discussed in this Manual incorporate a variety of technologies designed to manage stormwater. While non-structural options, such as reducing the amount of impervious cover and designing for disconnected impervious cover (DIC), are preferred strategies that the designer should consider before proposing SMPs, PWD recognizes that many development projects will need to use SMPs to comply with the Stormwater Regulations. In Chapter 3 and Chapter 4 of the Manual, PWD provides guidance for an array of SMPs that offer design solutions for many different types of sites.
Chapter 4 details nine SMPs, along with pretreatment, inlet control, and outlet control components. It provides SMP-specific information on applicability and uses, components, design requirements, material specifications, and construction and maintenance guidance.
When using SMPs to meet PWD’s Water Quality requirement, the applicant must use infiltrating SMPs, which allow water to soak into the ground rather than holding and releasing it. Infiltration is the main focus of the Stormwater Regulations, as these SMPs also filter out pollutants and thus are the most beneficial for improving water quality. Infiltration SMPs must be utilized unless it is demonstrated that they are not feasible due to poor soils, bedrock, soil contamination or other site constraints. PWD requires that the applicant provide documentation of these conditions and submit an infiltration waiver for review. Specific requirements for soil and infiltration testing, a waiver request form, and other related issues are discussed in Section 3.3.
Not All SMPs are Created Equal
To help developers select SMPs, PWD developed a hierarchy that uses ranking factors to prioritize acceptable SMPs. The SMP Hierarchy uses factors important to PWD’s efforts to clean up Philadelphia’s waterways as well as those of primary concern to developers such as ease of maintenance, cost, and impact on buildable area. A full discussion of the SMP Hierarchy is found in Section 3.2.4, but a brief discussion of high, medium, and low-preference SMPs is provided below.
- Highest-preference SMPs are bioinfiltration and bioretention basins, porous pavement, and green roofs. Projects using only highest-preference SMPs are eligible for an Expedited PCSMP Review (Section 2.4) and may elect to postpone infiltration testing until construction or be exempt from testing.
- Medium-preference SMPs (subsurface infiltration, cisterns, blue roofs, and ponds and wet basins) often provide fewer triple bottom line benefits and may not last as long as more highly-preferred SMPs.
- Lowest-preference SMPs include various types of subsurface detention and media filter systems that are non-infiltrating and provide little-to-no triple bottom line benefits. Lowest-preference SMPs also tend to have relatively high O&M costs and may malfunction more frequently than other SMPs.