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Don’t Let Philadelphia International Airport Use Outdated Flood Data

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RA-EPWW-SERO@pa.gov

Subject: PAD230012 A-18

Message:

The Philadelphia International Airport, located in the extremely flood-prone Eastwick neighborhood of Southwest Philadelphia, is proposing to update a stormwater discharge permit related to a small construction project and I am concerned that the airport is relying on outdated precipitation data related to this construction project. The airport has been replacing pavement and runways at the facility for years to meet Federal Aviation Administration (FAA) safety standards while also updating stormwater control measures. Unfortunately, the airport’s currently proposed amendment to its stormwater discharge permit uses outdated precipitation estimates that, in addition to being lower than Philadelphia’s actual precipitation, are even lower than previous rainfall estimates the airport has used in earlier versions of this stormwater discharge application, specifically phase 5A. The airport now claims that a 50-year flood in Philadelphia will produce 6.75 inches of rain in 24-hours while in its previously approved application for phase 5A of this project, the airport concluded that a 50-year flood in Philadelphia will produce 7.16 inches of rain in 24-hours. Additionally, the airport now claims that a 100-year flood in Philadelphia will produce 7.71 inches of rain in 24-hours, but in its previous application for phase 5A of this project, the airport concluded that a 100-year flood in Philadelphia will produce 8.43 inches of rain in 24-hours. The City of Philadelphia is currently surpassing some 2080 precipitation predictions made by the Consortium for Climate Risk in the Urban Northeast (CCRUN), specifically regarding days with over 4 inches of rain. Using the National Oceanic and Atmospheric Administration's (NOAA) National Climatic Data Center’s (NCDC) 1980-2010 baseline climate data for Philadelphia, CCRUN concluded that Philadelphia will witness .3 days a year with over 4 inches of rain by 2080. However, since 2010, six of the last 12 years have included at least one day of the year with more than 4 inches of rain. In addition, since 2010, Philadelphia’s annual 24-hour maximum precipitation event produced an average of 3.87 inches of rain. The airport currently claims that the maximum 2-year 24-hour storm will produce 3.24 inches of rain and in 2020 the airport claimed that a 2-year 24-hour storm would produce 3.4 inches of rain. Unfortunately, neither of these precipitation estimates are accurate and the airport’s estimations are becoming increasingly inaccurate. Philadelphians need updated, expanded precipitation data. DEP must not allow the Philadelphia International Airport to reduce its precipitation estimates given Philadelphia’s rapidly increasing precipitation, which will continue to increase because of climate change. It is unconscionable for the Philadelphia International Airport to reduce its precipitation estimates. The airport has an immense responsibility to not further contribute to flooding in Southwest Philadelphia.

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Don’t Let Philadelphia International Airport Use Outdated Flood Data

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