Philadelphia’s Stormwater Approach – Is it really green?

Philadelphia’s Consent Order and Agreement (COA) with the Pennsylvania Department of Environmental Resources (PaDEP) (link) requires Philadelphia’s “Continued Implementation of Technology-Based Nine Minimum Controls” (Attachment 1A, pg.13)

I have reproduced this section of the Philadelphia – PaDEP  COA Attachment 1A for your convenience:
This is the cover of EPA’s guidance document, available at this link.
As I read EPA’s CSO Guidance for Nine Minimum Controls (NMC) , Philadelphia is not meeting EPA’s NMC requirements 6: (Control of Solid and Floatable Materials in CSOs) and 7: Pollution Prevention Programs to Reduce Contaminants in CSOs.


Section 8 of EPA’s NMC Guidance identifies several potential control measures that Philadelphia is expected to consider in preventing CSO solids and floatables. .. From the document …

8.1 Control Measures

Pollution prevention measures such as street cleaning, public education programs, solid waste collection, and recycling can keep contaminants from entering the CSS.

8.1.1 Street Cleaning

Street litter can be removed by mechanical or manual street cleaning or by street flushing during dry weather periods. Daily street cleaning in critical areas might be necessary to significantly reduce CSO floatables. Street cleaning will not control litter from off-street areas.

Parked cars prevent the removal of litter and other materials from curbsides. Enforced parking regulations (e . g ., alternate side of street parking at different days of the week) and public awareness about the necessity of street cleaning are necessary for effective litter removal.

8.1.2 Public Education Programs

Anti-litter campaigns can reduce the amount of street litter and household items that enter CSOs and storm water outfalls. Public education programs can encourage the proper disposal of sanitary and personal hygiene items, which cause the greatest public concerns and can close beaches. Education programs can also advise the public about proper application of fertilizers, pesticides, and herbicides.

Education methods can include public service announcements, advertising, stenciling of street drain inlets, and distribution of information with water or sewer bills. In addition, these programs can also include elements that focus on commercial and industrial establishments.

8.1.3 Solid Waste Collection and Recycling

Trash receptacles along city streets should reduce the amount of litter on streets, if the receptacles are properly placed, maintained, and cleaned. Street litter in some key densely populated areas can be reduced by collecting domestic curbside garbage more frequently. Recycling programs can reduce the amount of street litter.

8.1.4 Product Ban/Substitution

Many materials that foul beaches, including polystyrene, do not degrade in the environment. Some oceanfront communities have banned the sale of certain food products packaged with these materials. In various areas nationwide, cities and environmental groups have worked with businesses to eliminate the production and sale of fast food items packaged with these materials.

(See EPA’s NMC document for remaining control measure options)

My Tookany-Tacony-Frankford Creek trash surveys have documented that too much Philadelphia’s street litter is flowing to the TTF Creek through the City’s combined sewer system and by overland flow. I have also demonstrated that many of the City’s plastic bags are passing through the City’ stormwater inlets and being discharged to TTF Creek. Some of these plastic bags are being caught on vegetation along the Creek. Theses recent photos of Frankford Creek near Castor Avenue show how City litter is trapped by vegetation in Juniata Golf Course.

The Juniata Golf Course natural trash trap by Castor Ave provide evidence that Philadelphia is not meeting the CSO Nine Minimum Controls.

My trash survey photographs (link) only show the small fraction of Philadelphia street litter that is caught by natural trash traps, they do not show the tons of Philadelphia litter flowing into our small creeks that are not snagged by natural trash traps. This major portion of Philadelphia’s litter flows on to the Delaware River, the Bay and eventually to the Atlantic Ocean.

Philadelphia’s senior administration officials need to rethink how the City views litter, it is not just a neighborhood aesthetic issue. It is a water pollution problem which needs action by the Streets, Water and L&I Departments and all City agency property owners. The City’s vision of a green city needs to be recast as a Clean & Green City.

Philadelphia can not be a green city and continue to dump tons of street litter into our creeks and rivers.

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