BBTCA and Environmental Assessment Comments – Public Interest and Policy

As mentioned in a previous post, on May 20, CommunityAIR submitted its comments on the Proposed Environmental Assessment (EA) Study Design/Scope as required in what has been described by well-regarded people with experience in such matters as a sham EA.

The PortsToronto consultants, AECOM, proposed to consider public comments in deciding the final study components that AECOM will use to serve PortsToronto’s purpose in conducting the sham EA.

CommunityAIR’s comments cover 11 subject areas, are extensive and pointed, and are best digested slowly. They are listed below and will be presented individually over the next few weeks. The second addresses the question of public interest and policy and is offered after the list.

Subject Areas

1.   Bias
2.   Public Interest and Policy
3.   Climate Change
4.   Flawed EA Design
5.   Runway End Safety Areas
6.   Permitted and Proposed Growth Scenarios
7.   Compliance with Tripartite Agreement
8.   Bird Hazard Zone
9.   Immense Existing Subsidies from City and Federal Government
10. Transportation
11.  Emergency Response and Access

2. Public Interest and Policy

Although the Canada Marine Act is silent on the matter, as a public agency, PortsToronto is by necessary implication, obliged to pursue the public interest. Surely any assessment of the Porter proposal must start with an assessment of the public interest, evaluating the need for the proposal, in relation to the other competing needs and desires our City and its citizens have for their Waterfront, and considering alternatives to the proposal, including expansion at Pearson.

Further, consideration of alternatives to air travel, such as improved passenger rail service, which is far more environmentally friendly, are absent entirely.

Certainly the scope of this work should, as a matter of public interest, include possible harm to other public assets and activities.

  • Island Airport expansion threatens WaterfrontToronto’s redevelopment plans. These involve multi-billion dollar investments.

Will an expanded Island Airport threaten these plans by discouraging that investment?

  • The viability of the Union Pearson Express. It has been built at a cost of at least $456 million by the provincial government.  This is a public investment made by the people of Ontario.

Will the expansion of the Island Airport threaten the economic viability of the UP Express?

  • Recreational facilities in the Island Park, Ontario Place and boating in Toronto Harbour and Lake Ontario.
    Increasing number of people are settling in the downtown core of the city. They will need recreational facilities.

This work should examine whether it is in the public interest to have Porter operate its jets out of Pearson instead, given the expense and possible environmental and economic disruptions of lengthening the runways, and filling Toronto Harbour and Lake Ontario that the expansion will require. Pearson has the capacity and facilities that can handle jets without the need for any additional capital investments.

All of these matters are in the public interest and require assessment.

This document is silent on any public interest and policy considerations.

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