This is the eighth 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 consultant, 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.

Civil Aviation Daily Occurrence Reporting System (CADORS) is a Transport Canada website that collects information on accidents, incidents and occurrences at Canadian airports. Bird strikes are an example of the kind of information collected.

Queries on accidents, incidents and occurrences can be run through CADORS. For example, a CADORS query on information about aircraft contact with birds at Billy Bishop Toronto Centre Airport (BBTCA), using the Canadian Aerodrome ID CYTZ shows that nine bird strikes occurred so far this year with seven of the nine occurring in May alone. All nine contacts reported involved Porter Airlines Q400s.

The Toronto Islands are on a bird migration route and the world’s largest colony of ring neck gulls is on the Leslie Spit less than 20 km away. A colony of much larger cormorants has also made its home on the Spit. While BBTCA has its bird dispersal program, the 28 bird strikes in 2014 show that birds still present a safety hazard.

Although turboprops such as the Q400 are susceptible to bird strike damage, jet engines are particularly vulnerable as the bird can be sucked into the jet engine rather than bouncing off a propeller and so present a far greater risk.

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

8. Bird Hazard Zone

[Page 20] This Airport virtually abuts a major bird sanctuary, and thousands of geese and cormorants populate the Toronto waterfront.

The UK Government’s Airports Commission Document titled “Inner Thames estuary airport: summary and decision”, 2 September 2014, determined that a proposed airport development in that location should not proceed, in part because of the risk of bird strikes:

“The operational risk to the airport posed by birdstrike could increase the scale of compensatory habitat required as it would require it to be sited further away, ideally to a minimum of 20km away from the site, and certainly outside of the 13km bird safeguarding circle, increasing the uncertainty as to its suitability as replacement for the habitat lost.”

If this degree of caution is necessary in the UK, why is it not on our waterfront?