As I mentioned before, there has not been a workup done on Philomel since level 8. She was taken through at previous levels because, unfortunately, staffers didn't bother to measure her abilities. Essentially she's been rubber stamped for the past three or four updates and this allowed her to exceed the kind of powers we permit at any level. I would encourage you to compare Phi to other characters of similar levels rather than comparing her to what was previously permitted. As I mentioned, she has ten more abilities than SirArtemis, who is a level higher. Giving a character such an arsenal of abilities is going to run up your TPL.

edit: Let me know when you're done editing and I'll re-assess again.