On Wednesday, May 20, CommunityAIR submitted its comments on the Proposed Environmental Assessment (EA) Study Design/Scope as required in what has been described 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 first addresses the question of bias and is offered following the subject areas list.
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
11. Emergency Response and Access
Unfortunately, the bias of the primary consultant for this work, AECOM, appears clearly on the first page of this document. It states:
The Canada Marine Act … requires PortsToronto, as a GBE (Government Business Enterprise), to uphold the federally-appointed mandate to ensure the continued commercial viability of PortsToronto assets.
It does not.
There is no mention of non-marine assets (i.e. related to port operations) in that Act.
The Island Airport is certainly not a marine asset. Of the purposes for Port Authorities listed in section 4 of that Act, only these two apply to Ports Toronto’s operations generally:
(d) provide for a high level of safety and environmental protection;
(e) provide a high degree of autonomy for local or regional management of components of the system of services and facilities and be responsive to local needs and priorities;