An Environmental Assessment Submission Worth Reading

By Monday, February 9, 2015 0 No tags Permalink 0

Sarah Miller has spent most of her working life in environmental advocacy. She recently submitted her recommendations to the Swerhun Group on how to improve PortsToronto’s EA.  Below are her introduction and recommendations. The full submission is here.


Opening Quotes

“The ecosystem concept holds that economy, social issues and environment are interrelated – decisions made in one area affect all the others.”

“ We are responsible for the consequences of our own actions – to ourselves and to other people, to other generations, and to other species.”

‘The Royal Commission found no overwhelming public demand for any change in the airport’s current role.”

Quotes from Commissioner David Crombie’s REGENERATION ~ Toronto’s Waterfront and The Sustainable City: Final Report 1991 of the Federal Royal Commission on the Future of Toronto’s Waterfront.


The Process

It is misleading to call this PortsToronto undertaking an Environmental Assessment (EA). It does not offer many of the amenities usually provided by an EA. There is no provision for hearings. There is no arms length tribunal to weigh the evidence. There is no provision for the public or others to seek intervener status, receive intervener funding or call their own experts and evidence.

It is also misleading to portray this undertaking as a mere runway extension. It is a transformation of a small short take off and landing airport into a destination for jets. Such a transformation will impact the livability of Toronto and it’s waterfront.


Recommendation # 1

The report and studies resulting from this consultation should not be deemed to be the outcomes of an Environmental Assessment. They should be forwarded to the City Council as the results of a Ports Toronto public consultation.

Recommendation # 2

The Runway Extension evaluation should use the Royal Commission on the Future of Toronto’s Waterfront studies and recommendations as its base line and yardstick. Your job should be to overlay its conclusions with up to date statistics and new studies for this EA to demonstrate what has changed since then. Care will be needed to chronicle the intensification and growth of housing and other waterfront amenities and stresses since the Commission Report in 1991.

Recommendation # 3

Toronto City Council must ensure that this Ports Toronto proposal not proceed before approvals are received from the City as past developments have. Should Toronto City Council eventually ignore the advice of their Medical Officer of Health and approve runway extension for jets those approvals should be subject to the condition that a full joint Federal/Provincial Environmental Assessment be held.

Recommendation # 4

Should the runway extension be approved it should be constructed with clean soil to protect water quality in the Inner Harbour and Lake Ontario. Fill should be contained behind engineered revetments so they do not erode into these waters.

Recommendation # 5

Runway design must include pollution prevention measures to minimize runoff, and to aid in the collection of spills.

Recommendation # 6

If dredging results from Runway construction the level of sediment contamination should be assessed to determine if the sediments require confined disposal.

Recommendation # 7

The flows out the Western Gap, so important to the harbor health, should not be diminished by the proposed runway extensions.

Recommendation # 8

The runway extension into the inner harbor should not cause sediment buildup within the harbor.

Recommendation # 9

Activities at the Billy Bishop Airport should comply with the terms of the Great Lakes Water Quality Agreement and the recommendations of the Toronto Waterfront Remedial Action Plan.

Recommendation #10

The impact of the introduction of jets on the future value and enjoyment of the Toronto Island and Tommy Thompson parks for City and Island Residents as well as visitors must be weighed in this decision.

Recommendation # 11

The impact on students in the Toronto Island Natural Science School, the Waterfront School (at Bathurst Quay), and George Brown’s Waterfront Campus must be accessed. As well impacts on the summer camps at Harbourfront and on the Toronto Islands should be studied.

Recommendation #12

A variety of airplane flight accident situations need to be considered as part of this evaluation, including emergency planning for each of these scenarios. Emergency plans need to be made available to residents and to City Council for both current and future operations.

Recommendation # 13

Health and safety risks associated with the transportation, handling and storage of increased diesel volumes required in airport expansion must be evaluated. Current and future emergency plans and response capacity in case of spills should also be evaluated.

Recommendation #14

Studies must be done to determine how expansion to jets will add to the cumulative air pollution burden in Toronto. These studies should include the human and economic costs of the increased burden of illness in respiratory diseases and hospitalizations. Future operations of the airport should not add to the burden of air pollution in the City.

Recommendation #15

City of Toronto transportation priorities for the waterfront should not be altered by this proposal to intensify use of the Billy Bishop airport.


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