A week ago, this blog predicted that PortsToronto (PosTO) would use old data in its environmental assessment (EA) to show that its planned airport expansion would have no significant effects. Another example has come to light.
The RWDI Case
To recap, the example used last week was courtesy RWDI.
In previous presentations, the PosTO consultants presented two studies spaced seven years apart to show that the airport wasn’t affecting air quality in the airport’s neighborhood, despite the 21% increase in flights and introduction of a larger, heavier aircraft capable of producing greater emissions. The studies used the same methodology and data sources.
Fast forward to 2015 and the PosTO EA. Once again, the PosTO consultant RWDI is conducting the air quality study. RWDI has made it clear that it would use emission measurements that RWDI has taken or measurements contained in software data bases. Might we expect that RWDI will repeat its previous success, success for PortsToronto that is?
There is yet another study that RWDI may rely on.
The Bombardier Commissioned Study
In November 2013 RWDI produced Billy Bishop Toronto City Airport (BBTCA) Toronto, Ontario Final Report Air Quality Review RWDI #1400311 November 15, 2013. This time the consultants were working for Bombardier. However, PosTO made it available to the city as part of the city’s review even though RWDI’s work was submitted to Chris Sowerby, Manager, Program Strategy, CSeries Aircraft Program, Bombardier Inc., Bombardier Aerospace.
The study contains a table, Table 7, that compares the annual emissions of two different scenarios at BBTCA. One scenario has emissions from only Q400s; the other has Q400s and CS100s.
The table is notable in several respects. For one thing, the study containing it was published on November 15, 2013 with engine emission data gathered before then. The CS100 FTV1 debuted on September 16, 2013. By the study’s publication date, the aircraft had logged approximately 50 out of 2,400 hours required for Transport Canada certification. It is interesting that RWDI would use preliminary figures in such an authoritative manner.
The study is also surprising with regard to the Notes. They show 65,175 LTOs (Landings and Take-Offs). This works out to a daily average of 178, well short of the current 202. Perhaps using the worst-case scenario, the current allowable 202, would increase the annual emission figures and would likely affect at least one of the study’s conclusions and not in the airport’s favour.
To add further mystery, the notes for Table 6: Comparison of Q400 and CS 100 Emissions with Other Transportation Sources near BBTCA shows the data in Table 6 use the full 202 daily allowable LTOs. The study gives no explanation for use of the two different standards or reasons for the inconsistency.
Not Quite As Advertised
In order to produce a study for a jet builder that proves jets would have no deleterious effect on air quality around the airport, it is useful to cite reports that make the case.
At least two such reports are found in Section 4.1 General Findings reproduced below.
The first bullet refers to an air quality study in and around Chicago’s O’Hare Airport. RWDI uses the quote above to build the case that the air around an airport is no worse than that at other monitoring sites. However, readers might wish to make up their own minds about that statement by examining the conclusions from the O’Hare Airport study.
Point 2 doesn’t exactly support the RWDI claim that the report that average contaminant concentrations around the airport were comparable or lower than at other sites, unless of course, breathing in acetaldehyde and formaldehyde is an average daily activity. In addition, RWDI seems to have missed the subtle implication in Point 4 – emissions from the airport have an impact on air quality on the airport’s neighbourhoods.
The second bullet in General Findings 4.1 “No significant differences between upward and downward measured air contaminant concentrations” RWDI cites McCulley, Frick & Gilman, January 1995, Air Quality Survey, Seattle-Tacoma International Airport. The study cites McCulley et al on four occasions.
Perhaps RWDI was unaware of a paper critical of the McCulley, Frick & Gilman (MFG) methodology.
“However, much of the sampling done by MFG did not follow specific criteria on location or scenario for sampling the worst case predictions. The sampling time of year, days of the week and weather were more conducive to best case scenario.”
Best Case Scenario
For PortsToronto, Porter Airlines and Transport Canada, the best case scenario would be to let their consultants RWDI run with findings their three existing studies: the two (2003, 2010) that show the air around the airport is not a problem and the one (2013) that shows the CS 100 is not a problem.
For anyone interested in balance on the waterfront, not so much.
The Greater Waterfront Coalition is an example. In November 2014, the group asked for participant funding in order to hire expertise in interpreting the various studies that will constitute the PosTO EA. The best case scenario for the Greater Waterfront Coalition would be to have the funding to allow for a thorough examination of the issues around air quality.