While there might not be one right or wrong way to manage a consent decree program, the strict regulatory deadlines and timeframes, extent of projects required to be completed, and political nature lends itself to a contractual makeup that prioritizes efficiency, cooperation among stakeholders, and effective communication. In 2012, the City of Memphis selected Black & Veatch (BV), along with their subconsultant partners, to serve as Program Manager for the Sewer Assessment and Rehabilitation Program (SARP10) to implement and manage the City’s response to their Consent Decree with the Environmental Protection Agency (EPA). The City of Memphis’s wastewater collection and transmission system (WCTS) consists of approximately 2,800 miles of gravity sewer mains, 85,000 manholes, approximately 100 lift stations, and over 300 siphons. The City’s SARP10 team is responsible for assessing the City’s assets, prioritizing rehabilitation based on consequence and likelihood of failure, and ultimately performing rehabilitation to reduce sanitary sewer overflows (SSOs). While almost all consent decree program managers employ a construction manager to oversee construction related activities on behalf of the owner, a less common arrangement is for Program Manager/Construction Manager (PMCM) team to serve as a program manager at risk (PMAR) where all construction activities, including advertisement and procurement, are the responsibility of the PMCM. In the City of Memphis’s case, having Black & Veatch’s construction subsidiary, Overland Contracting Inc. (OCI), serve in such a capacity was determined to be the best solution for SARP10. To date, nearly $200 million worth of construction has been completed as part of SARP10. The primary advantages of using PMAR to manage construction projects through a program are efficiency, flexibility, streamlined communication, and decreased risk for the owner. A few of the disadvantages include additional exposure to safety incidents for the PMCM, less control over subcontractor quality, increased responsibility for inspection staff, and the need for robust procurement staff. The program team has been able to apply lessons learned through these advantages and disadvantages for the program’s continued success. This presentation will explore the advantages, disadvantages, and lessons learned through 10 years of PMAR construction completed by the SARP10 team.