This is the third in a series of comments CommunityAIR submitted on Wednesday, May 20, on the Proposed Environmental Assessment (EA) Study Design/Scope in what has been described by people with experience in such matters as a sham EA.
The PortsToronto consultants, AECOM, proposes 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. It seems strange that PortsToronto would not consider an issue that affects the future of the planet, climate change, in its environmental study. The oversight, deliberate or not, does nothing to dispel the charge that its EA is a sham.
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
3. Climate Change
The assessment must also include consideration of the environmental challenge of climate change, which is immediate and dire, and by all informed analysis, will require significant reductions in the emission of greenhouse gases in the very near future.
The aviation industry, as a significant and, currently growing, contributor to those emissions will be obliged to do its share.
Tim Johnson, Director of the UK’s Aviation Environment Federation, put this succinctly in a letter in the Independent recently, in relation to the proposed fourth runway at Heathrow:
“With a new runway potentially locking the UK into an emissions path entirely at odds with our long-term climate commitments, politicians will very soon need to face up to the CO2 consequences of sanctioning airport growth.”
This document ignores that imperative, which is equally applicable to this proposal, and has ignored CommunityAIR’s request for climate change policy to be included, submitted to Nicole Swerhun on January 8, 2015.
That request, Island Airport Expansion & Climate Change – Learning from the UK, is attached as the Appendix Island Airport Expansion & Climate Change to this letter.