National Experts Weigh in on Vision for a Swimmable Delaware (Part 2)


National Experts Weigh in on Vision for a Swimmable Delaware (Part 2)

As we close out a summer that served up some of the hottest days on record, we’re revisiting our conversations with national experts on how Philadelphia’s waterways, specifically the Delaware and Schuylkill rivers, can be accessible, safe places for in-water recreational activity like swimming. In July, we published a blog featuring the viewpoints of Tim Dillingham, executive director of the American Littoral Society, and Nancy Stoner, president, Potomac Riverkeeper Network, on this matter. In this blog, we’re sharing a conversation we had with Andy Kricun, senior fellow at the U.S. Water Alliance and former head of Camden County’s water utility.

About a year ago, Tim, Nancy, and Andy along with Layla Bibi of the Eastern Atlantic States Regional Council of Carpenters; Maggie Flanagan, Chair of the education subcommittee of the Harbor Operations Safety and Navigation Committee of the Port of New York and New Jersey; and Lawrence Jones, CEO, Richard Allen Preparatory School, testified before City Council’s Committee on Commerce and Economic Development, chaired by Councilmember Mark Squilla, on how the region’s waterways are faring, how the city could be taking advantage of federal infrastructure funding to improve the water quality of the Delaware and Schuylkill rivers for public recreational use, and what we can learn from the experience of other urban waterways.

At issue is the fact that of the Delaware River’s 330 miles, only 27 miles are not designated for primary contact or full recreational use because of the presence of harmful bacteria from combined sewer overflow (CSO). Those 27 miles of river run through Philadelphia, Chester, and Camden – communities near the waterways where average household incomes hover around $28,000, “which means the areas with lesser means have less usable water,” Councilmember Squilla said. Every year billions of gallons of stormwater mixed with raw sewage are collected by the region’s antiquated infrastructure and funneled, untreated, directly into creeks, streams, and rivers.

Read Andy’s perspective on how Philadelphia could address this problem.


Andy Kricun, Senior Fellow at the U.S. Water Alliance

WPF: Your testimony emphasized that more can be done to accelerate Philadelphia’s Green City, Clean Waters CSO plan. You encouraged the city to pursue greater federal funding, given the unique opportunity of the Bipartisan Infrastructure Law (BIL) and Inflation Reduction Act (IRA), and state funds allocated for water infrastructure through the State Revolving Fund (SRF). How can these funds help utilities go above and beyond their permit requirements?

AK: When I worked in Camden at the wastewater utility, we used the State Revolving Fund, the New Jersey version of it, to upgrade our wastewater treatment plant, to repair Camden's combined sewer system with green infrastructure, and put in netting systems. The benefit of the SRF, at the time, was that it was a low-interest loan, much lower interest than conventional funding, and it was spread out over 30 years. Because of that, we were able to do all that in Camden without having to raise rates.

Camden has a combined sewer system like Philadelphia, but significantly smaller, so there are different considerations in Philadelphia. But the good news is that when I was doing that work in Camden, the only way to access those funds was through the low-interest loan; now, the BIL has opportunity for grant funding or principal forgiveness, and there are additional funds available that weren’t there previously.  So my hope is for the city to be more aggressive in seeking federal funding with a multi-pronged approach:

  • Right now, the city is barred from getting grant funding from PENNVEST, which is the Pennsylvania State Revolving Fund. That works against [federal initiatives] like Justice40; in implementing Justice40 at the Environmental Protection Agency (EPA), the EPA envisioned cities like Philadelphia getting a portion of that grant funding. So PENNVEST’s policy is defeating that, if you will. If I were in the position of the Philadelphia Water Department, I'd be speaking to my federal, state and local policymakers and elected officials to try to get the PENNVEST decision reversed or waived. I worked with the city of Jackson, Mississippi successfully to get a waiver in a similar situation.
  • There are also other kinds of federal funding available, like FEMA grant funding. There are BRIC [Building Resilient Infrastructure and Communities] grants that Philadelphia could qualify for, as well as Camden and Chester, to make their CSO systems more resilient.
  • There's stormwater grant funding, and while that’s not as fully funded as one would want for the whole country yet, I would try to get that funding, as well.
  • Thinking again about my experience with Jackson, there is also the possibility of getting congressionally directed spending or an earmark. Jackson got a $600 million earmark last December for its water infrastructure.


So there are incremental funding opportunities to help address the problem. In Philadelphia, you have raw sewage coming out of the sewer system into the river or backing up into people's homes dozens of times a year. That's a lot of raw sewage spills. It's a public health issue.

And here’s the thing: Cities are mandated to do this work. It's not voluntary. But there is a pretty big lane between what’s required and what’s possible. The argument that the City of Philadelphia has made is that to avoid significant rate increases they’ve got to spread the work out over a longer period of time so as not to adversely affect Philadelphia ratepayers. But if they could be more aggressive in getting the funding that’s available now, then the total cost of the required work would be reduced, and they could do it in a shorter period of time, and they could further improve water quality, and they could lower the rate and public health impacts.


WPF: Why is accelerating the plan so important? Are there other things the plan should accommodate now?

AK:  The Philadelphia Water Department (PWD)’s Green City, Clean Waters plan was groundbreaking when it was approved in 2010. It was so smart and so right, and the work we did in Camden while I was there was borrowed directly from it. The issue now is that while the plan has accomplished a lot, it doesn’t go far enough. In hindsight, with 13 years behind us, we know that climate change is playing a much bigger role today. Storms are much more severe than they were, they’re going to get worse, and the river level is rising. So one reason to accelerate and relook at some aspects of the plan is to determine whether the green infrastructure planned for in 2010 can accomplish what’s needed now and in the future knowing what we know now about climate conditions.

A second thing is that the Green City, Clean Waters plan, when it was conceived, did not consider equity, and PWD has acknowledged that. The plan looks at the city for 10,000 greened acres, and it doesn't matter where you get them from. But some communities are more hard hit than others, and there is an opportunity to help the communities that need it. For example, it is more valuable to put a rain garden in a community where combined sewage flooding is backing up into basements as opposed to putting one on a corporate mall or a business center. Knowing what we know now, we have to prioritize the areas where there are overflows or flooding.

The third thing that could be done is to allow for optimal screening of overflows. Even if the Green City, Clean Waters plan works exactly as planned with an 85% capture, it still calls for 40 overflows a year, which would render the river unusable 40 times or more each year. So one thing I recommend is to put netting and screening at the end of the outfalls. This way, if it does overflow, at least you're capturing the solids. Then, you take the net out and put a new net in. This way, while you’re working on reducing the number of overflows, if an overflow happens, the netting can catch 80 to 90% of the solids, and then the public health and environmental impact will be lower even though the frequency [of the overflows] is the same. The Green City, Clean Waters plan does not call for netting, but they could do it, and they could do it affordably with the funding that’s out there.


WPF: Water quality testing shows evidence of human sewage contamination in local waterways during long stretches without any rainfall. What are some possible reasons for these dry weather contamination events? Your testimony mentions the need for a track-back study; how would this help Philadelphia better understand and address these contaminants? Are there other potential non-CSO sources that we should be paying attention to?

AK: PWD’s annual CSO report states that five overflow instances were observed in dry weather. That may be true. A gate may have been stuck and then fixed. Or sewage may have been seen going out for some other reason. But the thing is, the leaks aren’t easily observed because they’re located underwater. So unless you're looking for that, you are only going to report the overflows you happen to observe. The fact that the water quality has a significant amount of fecal coliform even on dry weather days suggests that sewage is getting out into the river. That’s illegal. It doesn't matter whether you caught it or not. You have to find the sources, track back where they are, and eliminate them, and that will likely require coordination between the water department, the streets department, public works, etc.

And this is important. The water quality data is showing that there are a lot of sewage discharges during dry weather days when there shouldn’t be any. The only sewage discharges coming out on a dry weather day should be from Philadelphia's three sewage treatment plants, and they meet the standard, there’s no argument about that. So we should not be seeing pockets of fecal coliform, bacterial matter on a dry weather day, but yet we are. PWD has acknowledged that there are illegal connections they're trying to track down. On some occasions, when contractors are connecting the sewer into a sewer lateral from the home, they’re connecting it illegally into the storm pipe instead, and so [the sewage] goes out [to the riverways] through the storm pipe.  And if these illegal connections are the problem, and they’re taking sewage from toilets into the river, then raw sewage overflows are happening continuously with every flush. So it is really imperative, both from a public health and an environmental standpoint, that an aggressive “find and fix” approach be taken until dry weather sewage overflows are eliminated altogether.

So my position is that the lowest hanging fruit is eliminating dry weather sewage overflow. There is a legal and moral obligation to address this in order to protect the public health and the environment. When I was in Camden, there was a dry weather overflow problem, and we were able to eliminate it pretty quickly by tracking it back to where it came from. Of course, Camden’s system is much smaller than Philadelphia’s, but Philadelphia also has more resources than Camden.


WPF:  So connect the dots for us on how this dry overflow issue relates to whether our waters can be fishable and swimmable.

AK: If what PWD says is true, and there isn't a lot of dry weather overflow, then they shouldn’t have an objection to allowing primary contact [for activities like fishing and swimming] in the rivers on dry weather days. But they do object to it. To the extent dry weather sewage overflows are a significant problem in Philadelphia, then these overflows are illegal and standing in the way of our waters being fishable and swimmable on most days during the year.  Accordingly, PWD should make it a matter of top priority, from a public health, social justice, and environmental standpoint, to find the sources and eliminate them as soon as possible. If they are able to do this, then there shouldn’t be any water quality barriers to primary contact in our rivers, except after rain events.


WPF: What accounts for this discrepancy?

AK: It could be a couple of things. Possibility #1 is that it's anomalous or unlikely. If that’s true and it’s not a problem, let’s allow for primary contact in the waterways.

Possibility #2 is it's coming from the CSO system, and the sewage is getting out because there are openings in the CSO system. They're supposed to be closed during dry weather, but they might be stuck in an open position, which is what I found in Camden. But when we fixed it, the dry weather overflow went away immediately. PWD doesn’t believe this is the case.

Possibility #3 is “death by a thousand cuts,” which is what PWD believes is the case. They say it's coming in through illegal, illicit connections. I don't doubt that there could be the odd contractor that is working in this way, but the fact that it would be happening to such a high degree doesn’t seem to add up.

Another thing I've heard is that it's fecal matter from animal waste. But why would that be true only in Philadelphia? Why don't other cities have a dry weather problem? It doesn't seem likely.

I’ve also heard more recently that old fecal matter is being re-suspended, which means that discharges that happened from years ago are somehow getting stirred back up and going back into the river. Now, I've always heard that fecal coliform dies after 48 to 60 hours. It doesn't have a lifespan of days, months, or years that it can come back. This would also mean that there's nothing that any CSO community in the world can do because even if you clean something up, it doesn’t matter because it can somehow come back to life. If that's true, then we would have a worldwide problem. So I find this possibility unlikely.

The bottom line is that if Philadelphia can eliminate dry weather sewage overflows, then the water quality barrier to fishing and swimming on the Delaware during dry weather days would also be eliminated.  So, from a public health, social justice, and environmental standpoint, I believe that Philadelphia ought to be implementing a very aggressive find and fix initiative to eliminate illegal and harmful dry weather sewage overflows from their sewer systems.


WPF: The final item you mentioned in your testimony was better control on the sewage solids, the fecal matter, litter, and debris that accompanies CSO. How big an issue is sewage solids? How does the performance of the skimming boats that Philadelphia is using to manage solids compare to the netting systems and inlet controls used in other cities like Camden and Chester?

AK: In Camden, we were capturing about 180 tons of solids per year through our netting systems. In Philadelphia, it's probably at least 10 times greater, since the dry weather sewage flow is much greater and, of course, the area is much bigger, as well. It would be a pretty substantial number.  

And, yes, skimming boats are directionally positive. However, Philadelphia has 164 outfalls and two skimming boats. In addition, the two skimming boats are likely not catching overflows in real time; some of the matter may stay on the surface, but a lot of it sinks to the bottom. When nets are installed, they are there full time. They're capturing the sewage matter and debris instantaneously.

The bottom line is that there is some urgency around the availability of the extra federal funding that’s out there. We’re already a few years into a five-year window, and when those dollars are gone, they’re gone. The Delaware River Watershed is 330 miles long. All of it except for 27 miles, between Philadelphia and Wilmington, is designated for primary contact. The residents of Philadelphia, Camden, Chester, and Wilmington deserve the same kind of water quality as everyone else.

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