Robert Deluce attended a meeting of the RCYC to discuss his jet expansion plans at the Island Airport and got a rather frosty reception. This is a description of an exchange between Ron Jenkins, an airport opponent and Deluce. It was written by Ron. Editor’s note
The Question asked of Mr. Deluce
My question challenged Robert Deluce’s assertion in his presentation that the Porter Plans proposal would not impact (and in fact be good for) development on the Toronto waterfront. I was pointing out that his statement conflicted with the following Ports Toronto statement in its Airport Master Plan:
“9.3 AIRPORT ZONING
BBTCA is located within close proximity to a number of major developments along the City of Toronto waterfront. As a result, the protection surfaces associated with the Airport’s certification and Instrument Approach Procedures are at risk of penetration, which could impact the Airport’s certification, operational usability and economic viability.
As a result, the TPA has initiated studies to work with Transport Canada, NAV CANADA and the City of Toronto to ensure that future developments located on the shores of Lake Ontario do not impact the Airport. These studies include comprehensive analysis of aeronautical protection surfaces outside of those protected under existing Federal Airport Zoning Regulations (SOR 85-515).
Once finalized, these revised aeronautical protection surfaces will be used by the TPA, NAV CANADA,
Transport Canada and the City of Toronto to identify and discourage developments that are incompatible with the current and future operation of BBTCA.” (TPA Airport Master Plan p. 48) [see reference below])
Why This Question Matters
This topic matters for two reasons: because of the economic impact of BBTCA and BBTCA expansion on the City of Toronto, and as a matter of safety.
1) Economic impact
Zoning restrictions to meet airport needs will limit high rise (and possibly medium rise) development of the City, particularly in the Central Waterfront, Lower Donlands, and Eastern Portlands. The Eastern Portlands are the largest undeveloped area of City lands in the central Toronto area. Ordinary airport operations are not the main problem (although they are not problem free); however, greater problems arise with scenarios developing from unusual or emergency flight situations particularly related to the use of jets.
Missed Approach Surfaces
Airport regulations currently in force in the Transport Canada document TP308 [see reference below] define areas that must be clear of obstacles in various flight and guidance scenarios. The current regulations define among other things a “Missed Approach Surface”, which is an area that must be kept clear should a pilot, when approaching landing, decides not to land and to instead peel away to either try again, or to divert the flight to land elsewhere. Missed approach attempts are not rare, and can happen when the airport is somewhat fogbound; in that case if the pilot cannot see their way clear when reaching a predetermined specified altitude (“decision height”), they are supposed to abort that landing attempt.
A missed approach could also arise in response to mechanical issues, the runway not being clear, or any other reason. When weather is not good BBTCA can have several missed approach attempts occur in a single day (historically, that’s why Pearson was developed as the main Toronto Airport).
Decision heights are higher for approaches when the aircraft is being flown under visual guidance (“visual flight rules”), as is the case at BBTCA. By contrast, when flying under instrument control, the plane is permitted to use a lower decision height. For this reason, decision heights differ for Missed Approach Surfaces depending on the technology being used for a particular landing.
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If a decision to abort a landing is made at a lower altitude, the aircraft will also be closer to the airport itself, and substantially closer, as landing approaches are generally made at about a 3 degree angle to the ground. In the specific case of BBTCA, an instrument controlled approach cannot be used when arriving from the west, because if the need for a missed approach arises, the aircraft would need to have clear a surface that would include some of the high rise buildings on the Central Waterfront (with more such buildings to come). A missed approach attempt from a low decision height would also be problematic for future Lower Donlands and Eastern Portlands development.
In fact, Access to Information documents recently released by Transport Canada show that Porter Airlines proposed an instrumented (ILS) approach for Runway 08 (approach from the west) at BBTCA and got Transport Canada approval for such in December 2012. For Porter, this approval would be good news as they would then have better odds of landing on foggy days. On closer inspection however, Transport Canada realized that their approval was based on out of date information, and that the approval that had been given did not allow for high rise development that had recently occurred along the Central Waterfront (ATI documents reference specific buildings). Transport Canada first suspended their approval for this approach design, and later (March 2013) revoked the previously-granted approval. Porter Airlines fought and lost a legal case relating to an earlier release of safety information [see reference below]; they have however been silent on this ATI request, which nonetheless was quite heavily redacted.
Instrumented approaches are not permitted from the east, in part because of the obstacle represented by the Hearn generating station smokestack. Newer buildings on Stadium Road and the under-construction hotel at the eastern end of the CNE grounds add to the problems for the airport. At the moment, no good alternative to deal with days with bad visibility exists for the airport, leading to expensive cancellations and diversions of flights.
The Missed Approach Surfaces discussed above, and more still the Take-off Surfaces discussed below, also have safety implications.
When looking at Takeoff Surfaces, the picture gets worse. The BBTCA is operating under, and its flight surfaces are designed to, the TP308 regulation as mentioned earlier (many other regulations apply also but are not germane to this topic). However, in the United States the Federal Aviation Administration has been reconsidering its regulations for airport design (remember in this, that “airport design” refers not just to what’s on the ground, but also to the surfaces in the airspace above).
The FAA now is looking at One Engine Inoperative (OEI) scenarios as important to consider [see reference below]. In the case of landings, OEI situations require longer runways because planes missing one engine have less stopping ability (so we see Porter fights diverting to Pearson in such a situation; BBTCA runways are too short). In the case of takeoffs, OEI situations lead to GREATLY REDUCED climb capability. New aircraft (the CS100 included) are perfect examples. When taking off, an aircraft is already at its most challenged in climb gradient because it is full of fuel. Climb gradients are about 1/15th as fast as when both engines are operational.
A video of an Airbus 350XWB testing a one engine takeoff makes the point [see reference below].
Over Toronto Harbour an aircraft losing one engine on takeoff (as might happen for example if it ingests a goose or swan into an engine) would be challenged to climb fast enough to clear obstacles — boats or buildings — that it would otherwise clear easily. If the Takeoff Surfaces being developed for the FAA are adopted in Canada (and adopting ICAO and FAA standards is typical in Canada), then Transport Canada would have reason to demand zoning regulations in the Portlands to meet this new surface. The proposed Takeoff Surface is much flatter than the Missed Approach Surface, so the constraints involved on development would be greater still.
These concerns and supporting images have been offered to the Ports Toronto Stakeholder Advisory
Committee; we will see whether they are adopted into the scope of the Environmental Assessment being
developed. [see references (2) below] (I actually prefer to call this assessment a “Proponent Study” as Ports Toronto is defining the rules of the study, hiring the consultants, and defining the scope).
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Mr. Deluce’s Answer
On Missed Approach Surfaces, Robert Deluce’s answer was largely a deflection. He responded by referring to a more precise navigational system that Porter has proposed to adopt for the airport and their planes, “Required Navigation Performance” or “RNP” [see reference below], and was suggesting that that new technology would enable a more precise missed approach surface to be defined so as to miss the buildings of the Central Waterfront. That might be, but the real issue is the enforcement of the regulatory spaces involved, and their impacts on future development. And ultimately, a missed approach surface is not very flexible as it is intended to encompass abnormal conditions. It’s not simply a matter of saying RNP will guide the plane as it weaves its way around buildings after an aborted landing.
Mr. Deluce and I never got to talk about Takeoff Surfaces, and Mr. Deluce shut me down quickly on that second question because he knew where the discussion was headed. At BBTCA, the operational problems presented by Takeoff Surfaces are worse than those presented by Missed Approach Surfaces. An advanced navigational system will not help a plane with one engine inoperative to climb any faster, and Takeoff Surfaces are also not defined with a narrow width because aircraft with one engine inoperative are not very maneuverable. When a plane has one engine only, it will lose height if it banks significantly. Witness the crash recently in Taiwan —another urban airport [see reference below]. The aircraft involved in that crash banked to avoid high buildings, and so slid into a crash. It was a choice by the pilot of which way was better to die.
The Value of Mr. Deluce’s Answer
The value of Mr. Deluce’s answer was pretty close to zero. RNP — the technology Mr. Deluce pointed to in his response — will offer some navigational benefits that might permit aircraft to take routes that better avoid noise impacts, but those are largely already in use for the areas that have already been developed. RNP will save Porter Airlines some money, as it will enable cleaner, more precise flight tracks, saving fuel. But its relevance to the discussion of Missed Approach Surfaces and Takeoff Surfaces, and to discussion of how Transport Canada can control City development zoning should they choose to, is nil. RNP is also not a safety tool really, doing nothing to increase an aircraft’s maneuverability or climb gradient, essential parameters to this discussion.
Mr. Deluce is well aware of these aviation issues and the ensuing problems. For him, the best path forward is the fastest path forward. If the airport expansion is approved and regulations become more restrictive in the future, the airport will most likely be grandfathered against them (as in fact its runway is already grandfathered into a less restrictive Code classification than that appropriate to its existing length). Grandfathering of airport surfaces will mean either that less restrictive aviation requirements will be applied when new ones are introduced (at the cost of safety); or, failing grandfathering, that more restrictive City zoning regulations will be demanded (at the cost of development potential). Either way, the airport wins and the City and boaters lose if expansion is given approval.
Transport Canada has astonishing powers under the Aeronautics Act over zoning [see reference below]. As an example, a runway modification in 1994 at Pearson led to Transport Canada requiring an already-existing hotel of seven floors to remove four floors at the runway end and three floors further away.
Moreover, Ports Toronto wants and is on record as wanting a 50 year extension to the Tripartite Agreement as a condition of advancing with BBTCA expansion. They have not agreed to include this requirement in the Master Planning Exercise they are developing, probably as that demand is perhaps quite unpalatable and in any case the City has not agreed to consider it as a part of consideration of the Porter Proposal. However, grandfathering the airport’s aeronautical surfaces and applying zoning restrictions to the Portlands could lock the City into nearly 70 years of stunted use of its Portlands.
— Ron Jenkins
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(note: you may need to cut and paste the longer hyperlinks below into your browser as this PDF may not properly create the link)
Ports Toronto Master Plan
TP 308 regulation
Decision on Access to Information
FAA One Engine Inoperative
Airbus A350 One Engine Takeoff
One engine climb to scale: Toronto Harbour
Large panoramic view, Toronto Harbour, Missed Approach & Takeoff Surface implications (13 meg jpg)
Porter RNP letter to City of Toronto
Aeronautics Act: Toronto Island Airport Zoning Regulations SOR/85-515