CommunityAIR’s Letter to Marc Garneau

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                                              Sent by Email to

February 8, 2016

Hon. Marc Garneau
Minister of Transport
Ottawa, Ontario

Dear Minister:

We were surprised by a media report yesterday that you are encouraging the United States government to provide US Customs pre-clearance at Toronto’s Island Airport (sometimes referred to as BBTCA).

While Porter Airlines may wish you to do so, there are a number of reasons why it not in the public interest to take initiatives such as this to accommodate Porter’s wishes.

1. Pearson is Toronto’s Airport

As anyone who has attempted to fly to the United States from Toronto’s Pearson Airport can attest, insufficient staffing at Pearson’s US Customs pre-clearance service results in unacceptable delays that directly assist Mister Deluce’s business at the Island Airport.

With the speedy Union – Pearson Express now operating, and the excessive traffic congestion around the Island Airport access, the only remaining disincentive travellers have to usingPearson is the under‑staffed US Customs pre-clearance.

Pearson is Toronto’s airport, and should be assured the resources it needs to provide the best service it can now to travellers.

Any additional resources that can be provided to Pearson’s US Customs pre-clearance service have a far higher priority than the Porter operation at the Island Airport, in our view.

2. Regional Transportation Planning

We do know that Pearson has ample capacity to handle anticipated volumes of business for some years to come, even with the optimistic straight-line projections common in the industry, as illustrated in this chart:

Total US Passenger Traffic

To our knowledge, there has never been any comprehensive plan for southern Ontario’s transportation needs and how the Island Airport might fit into such a plan.

Transport Canada’s 2010 Needs Assessment Study – Pickering Lands anticipates that a new major airport will be needed in the GTHA by either 2027 or 2037.To meet the region’s capacity needs in the meantime, Transport Canada is promoting the expansion of Toronto Pearson International Airport and the strategic use of Hamilton International Airport and possibly Waterloo International Airport as “reliever airports”. Transport Canada anticipates that these three international airports can expand to capacities of 54, 7and 4.6 million passengers per year, respectively.

The Toronto Island Airport is not mentioned as a possible regional “reliever airport.”

As Urban Strategies notes, in their November 2013, BBTCA Expansion Review Summary Report, in relation to the Island Airport,

Other airport sites are better suited to meet growing regional air transport demands, given their potential to expand and incorporate complementary employment land uses, and their relative distance from residential areas and other sensitive uses.

Any initiative to facilitate further expansion of the Island Airport, such as providing US Customs pre-clearance, must be justified on solid planning grounds. Those grounds have not as yet been formulated.

3. Island Airport is Severely Challenged with Current Volumes

You would also be aware that the Island Airport is, physically, severely constrained in its capacity to handle its existing volume of business: Ports Toronto, the operator of the Island Airport, released its 2012 draft Master Plan, after pressure from the City of Toronto, that set out a host of essentially unsolvable problems with the current operation.

These are some excerpts from that Master Plan [our emphasis]:

1. “The provision of public parking is significantly undersized given the level of passenger activity. Industry planning guidelines suggest a provision of approximately 1,000 – 3,000 parking stalls per 1 million enplaned passengers.”  “With approximately 1.5 million passengers, the unrestrained demand for parking at BBTCA would be approximately 750 – 2,000 parking stalls.”

2. “The terminal was designed to support a planning peak hour passenger (PPHP) capacity of 336 in either the domestic or transborder sector.”

“…Given that the existing terminal is designed to accommodate a peak hour demand of approximately 336 passengers, it is likely that areas of the terminal building already exceed demand during peak periods.”

3. “The area of the combined services building allocated for airport maintenance is comprised of four equipment bays and support areas. This facility is not sufficient to accommodate the full needs of the Airport.”

4. “Given the tight physical constraints of the Airport, particularly in the vicinity of the terminal building, there is no opportunity to provide a centralized de-icing facility.”

5. “With the rapid increase in air carrier activity over the past two years and the allocation of all of the 202 slots available for scheduled air carriers, it is very likely that BBTCA has reached its theoretical capacity of 140,703 movements.”

“Even with modest (1-2%) growth in the other general aviation sectors, the TPA may have to implement measures next year to manage aviation activities.”

6. “At a length of approximately 60m, the drop-off/pick-up curb at the ferry terminus is significantly undersized as compared to airports with comparable passenger activity.”
“ As comparison, the following is a list of similar Canadian Airports, including the number of annual passengers and the length of their terminal curb-side:

? Kelowna Airport: 1.3 million annual passengers, curb length of 122m,
? Saskatoon Airport: 1.3 million annual passengers, curb length of 150m, and
? Victoria Airport: 1.4 million annual passengers, curb length of 200m.”

7. “The current capacity of the two taxi queuing lanes is approximately thirty-four vehicles, which during peak periods is at over-capacity.”

“As a result, taxis often stand on the northbound curb lane of Eireann Quay, which presents a significant congestion and safety concern. …As a result, the TPA is left with an overall taxi system that has far more demand than capacity, and is without any realistic short-term and cost effective mitigating solutions.”

There have been no answers from PortsToronto or its consultants on any of these issues in any of the public meetings recently held, and no indication that any of them are being seriously addressed.
Given those obvious physical constraints on its existing business, why would your government opt to support a growth in that business by seeking US Customs pre-clearance for the Island Airport?

4. Climate Change Impact

We would also suggest that any decision your government makes must be made in the context of its commitments made at the recent Paris climate change conference to significantly reduce greenhouse gas emissions.

A climate change screen of all decisions of your government is essential if those commitments have a hope of being met.

Your government recently signed an agreement to add US Customs preclearance at Union Station for train passengers to the United States.

Rail travel is, this agreement recognizes, vastly preferable, for short and medium haul travel, from a carbon emissions perspective.

Securing train travel is your government’s second Customs preclearance priority in the Toronto area, not the Island Airport.

Any decision that encourages increased use of carbon-intensive modes of travel, such as aviation, should be avoided, we submit.


Yours truly,

Brian Iler, Chair
416-835-4384 (cell)
416‑598‑0544 (work direct)

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