September 23, 2024
Letter to: Meg St. John
Waterfront Secretariat, City of Toronto
Re: Ports Toronto Request for City Consent
We are a group of volunteers who have formed Parks not Planes to advocate for conversion of the Island Airport lands to parkland.
Our members will be in attendance at the September 24 meeting the City has called.
First, we are distressed by the short notice for this important meeting. The issues are so important, that they should not be rushed, and the time necessary to address them taken.
Here’s how one community leader put it:
It is disturbing that the news of the consultation is coming so late and we are left scrambling to promote it. Its a bit like what happens to us with Ports Toronto's notices. We are all volunteers so we have to carve out time to do this sharing of information.
All of them require fulsome answers, before any consent is given.
As we noted in our letter to Councillors last January:
Parks Not Planes welcomes a serious discussion of these issues. But City Council must not be bullied or rushed. It is essential that the exploration of the public interest gets the time it needs.
Let’s contemplate where the public interest lies here. And not be stampeded into a bad decision because Port Toronto demands it.
1. Should Ports Toronto’s request for urgency be taken seriously?
Ports Toronto, which operates the Island Airport, has requested that the City consent to its filling in a portion of Toronto’s harbour, and a portion of Humber Bay, to enable it to comply with upcoming Runway End Safety Area requirements.
That consent is necessary because the City owns about 20% of the Airport lands, and, in 1983, leased those lands for a nominal amount of rent for fifty years to (then) the Toronto Harbour Commission, a City-controlled agency (by virtue of the enactment of the Canada Marine Act, the Harbour Commission’s assets were transferred to Ports Toronto). The lease is called the Tripartite Agreement, because Transport Canada also signed it.
That lease requires agreement by the City to waive these requirements in paragraph 14:
The Lessee shall:
(a) not construct or permit to be constructed additional runways or extensions to existing runways on the Toronto City Centre Airport; …
(c) not expand or permit to be expanded the lands comprising the Toronto City Centre Airport beyond the present land area contained in Parts numbered 1, 2, 3, 4, 5 and 6 shown on Schedule "A" attached hereto, excepting such expansion as may occur from natural causes, ...
At least since the Air France overshoot at Pearson in 2005, runway end safety areas (RESAs) have been advisable. The Transportation Safety Board recommended 300 m.
Transport Canada has dithered outrageously, only recently imposing 150 m RESAs by, for the Island Airport, 2027.
Ports Toronto has always known that overshoots at its Airport end up in deep water, with potential for fatalities. For commercial airports in Canada, the Island Airport is essentially alone in facing that risk.
It has ignored that risk. It has also ignored the real safety risk, again unique to its airport, of grossly inadequate emergency access in the event of a crash.
Ports Toronto cannot, at this time, credibly insist that the City must set aside proper consideration of its request and all of the issues that it raises.
2. Where’s the seventh alternative?
We recently wrote to Ports Toronto:
Missing from the six alternative scenarios Ports Toronto has advanced to meet RESA requirements is a seventh – closing the airport.
We do appreciate that that is not an inquiry that Ports Toronto wishes to allow. But this 7th scenario must be seriously and thoroughly examined. Ports Toronto’s acquisition of the Airport lands was by the simple creation of a federal statute, and another statute can as easily convert the use of those lands to parkland.
That alternative is not far fetched. Even the Globe and Mail’s highly regarded architecture critic has advanced it as a very attractive option.
You are also seeking to enter into a new lease from the City as the current one expires in 2033, it would only be prudent to examine the question of whether that should happen.
Such an examination needs to consider what the best use should be for the valuable (some would say most valuable) 210 acres in our City and include extensive and robust public engagement.
This is the time to seriously consider that alternative. It needs to be front and centre.
3. Isn’t this a wonderful opportunity?
If the City’s consent is not given, the Airport can no longer operate, and we have the wonderful opportunity to consider just what should be done with those 210 acres of, arguably, the most precious land in Toronto.
Our waterfront attracts many tourists and visitors from all over the city. But the downtown core is more deficient in parkland than any other neighbourhood in the city, states a 2019 City report. The huge line ups for the Island ferries provide strong evidence of the demand for downtown parkland.
To address that deficiency, the City has even considered spending in excess of $1.7 billion for a park of just 20 acres over the railway lands.
As the Globe & Mail recently pointed out, this is a huge opportunity to address the desperate shortage of parks in downtown Toronto, to expand the Island Park by 66%, from its current 516 acres, and to put the Island Airport tunnel and its ferry to good use improving access to the Island Park.
Now is the time to start imagining how those 210 acres should be used – is the public interest best served by allowing the Airport to continue operating, or converting them to parkland?
Edmonton, Berlin, and Chicago have converted their downtown airports to parkland, and Santa Monica will do so soon. It is time for Toronto to join them.
4. What are the environmental impacts of the Airport operation?
The Island Airport is the waterfront’s last remaining noxious vestige of its industrial past delivering noise, pollution and threats to our natural environment, our health and quality of life.
Ultra fine particles (UFP), which are extremely hazardous to human health, are emitted by jet engines, like those powering Q400 aircraft, flown by both Porter and Air Canada at the Airport. Sensors monitored by scientists from University of Toronto in the Bathurst Quay neighbourhood detected unacceptably high levels of UFP when the wind was blowing from the Airport into the neighbourhood.
This is from the scientists’ report: Short-term UFP Spikes Evident across the Neighbourhood
The airport disturbs the sleep of nearby residents: medevac planes take off and land throughout the night, the ferry begins at 4 am and runs past midnight and maintenance and upgrades are done overnight.
Unacceptable pollution and noise emanating from the Airport are incompatible with the (now) primary recreational and residential uses of our waterfront.
5. What are the Airport’s business prospects?
“The federal RESA mandate includes Billy Bishop Toronto City Airport (BBTCA) – also known as the island airport – which has seen passenger numbers increase annually from 26,000 passengers in 2006 to a recent peak of approximately about 2.8 million in 2019. Transport Canada has outlined that RESA must be in place at BBTCA by July 12, 2027.”
That’s misleading: per Ports Toronto’s 2023 Annual Report:
“Total passengers reached two million, up from 1.7 million in 2022”
The Airport’s business is in decline.
The graph below is from flightaware.com, and indicates a significant decrease in the number of flights in and out of the Island Airport in 2023 as compared with 2022. It shows 162 flights for October 16, 2023 (a typical Monday), compared with 177 in 2022.
But of those 162 landings and takeoffs, five day rolling average), 45 were medevac or private flights, not commercial aviation. Flights by Porter and Air Canada Jazz totalled 112 that day, a reduction of 46% from the peak of 202.
Porter was awarded 172 slots (landings plus takeoffs) per day by Ports Toronto, and Air Canada 30. At one point, Porter and Air Canada were using them all.
Other airlines have not demonstrated any interest in using the Airport: for a while, Nieuport, the owner of the Island Airport terminal, trumpeted a new American airline Connect. Its paltry number of destinations won’t replace the business it was doing with Porter. And its application for authority to engage in schedule passenger air transportation to the US Department of Transport was denied as it failed to provide required financial information to support a positive financial fitness finding.
The market has spoken: the Island Airport’s business has declined drastically, and, with Porter increasingly operating from Pearson, one can reasonably expect it to decline further.
6. Should the City continue to subsidize the Island Airport?
It is heavily subsidized:
The City of Toronto leases a portion of the Airport lands, a parking lot, and queuing lanes to Ports Toronto for nominal rent.
Ports Toronto obtained ownership of much of the rest of the Airport lands (originally donated by the City to its Harbour Commission for port purposes) for free and passes that benefit on to its users.
An analysis shows Ports Toronto pays property taxes at a rate far below other businesses in Toronto – over 20 years, providing a subsidy from the taxpayers of Toronto of, conservatively, $36,607,528.
Should these subsidies continue? Or should Ports Toronto pay fair market rent for its use of City land, and pay property taxes for the airport lands on the same basis as every other business?
Should consent for RESAs be given on the condition that those subsidies cease?
7. Why has Ports Toronto been so cavalier about safety?
Ports Toronto is very fortunate that a runway overshoot has not happened to date. The absence of effective RESAs means that is a real risk.
Transport Canada advises that, over a 20-year period there were 268 Runway End excursion events, 148 related to commercial passenger operations. It estimated one per 517,000 passengers would be affected by a runway excursion.
While Ports Toronto states that Transport Canada’s safety regulations are complied with, those regulations don’t address the unique safety challenges presented by an airport bounded by water.
Ports Toronto minimizes those challenges, when it comes to emergency access to a crash on airport lands. The 1993 expert report remains relevant. It is written by experts, and concludes that, for a crash of a 50-passenger plane, 64 emergency vehicles carrying 201 personnel would be expected, 54 of those vehicles arriving within 20 minutes. They indicate that the ferry would take over two hours to transport all the vehicles.
A similar problem arises for emergency response to an aircraft in the water.
Again, Ports Toronto is very fortunate that a runway overshoot has not resulted in an aircraft sinking in deep water.
We ask Ports Toronto: Why are you operating, putting passengers at risk? Close it down until you have properly dealt with the safety issues you’ve been avoiding for years.
8. Is it in Compliance with the City’s Official Plan?
“A Healthy Natural Heritage System and Waterfront: Toronto values its natural spaces, including a beautiful waterfront, which support a diverse range of plants and animals.” (page 1-3), and
“Over time, lands on the water’s edge should become a network of publicly accessible open spaces, offering a range of leisure activities connected by a continuous waterfront trail. Creating a clean and green waterfront that is safe and healthy will contribute to a better environment for the City as a whole.” (page 2-35)
And specifies that
"in the event that the airport on the City Centre Airport is closed, it is the policy to seek the immediate conversion of the lands on which the airport is located for parks, or parks and residential purposes, and uses incidental and accessory thereto designated as parkland."
Until then, the Plan requires that the Tripartite Agreement may only be revised, provided that the City is satisfied that improvements to airport facilities and operations can be made without adverse impact on the surrounding residential and recreational environment [our emphasis].”
This is a significant constraint on the proposed RESAs, and sufficient inquiry is necessary to ensure it is complied with.
9. Is the Airport financially viable?
A comprehensive examination of Ports Toronto’s finances and future is indicated. Our review indicates the Airport operations are not profitable, when the adjustments below are made.
Oddly, Ports Toronto categorizes Airport Improvement Fees ($29 per departing passenger) as income. They are required to be, per its commercial carrier agreement with Porter, spent on the Airport’s capital program. It is misleading to include them in income.
And, in calculating the profitability of the Airport, it fails to include an allocation of its head office costs.
Reviewing the latest available financial statements, for 2023:
Airport Revenue:
$52.8M (including Airport Improvement Fees), or $27.8M net of AIF.
Airport Expenses:
$22.7M. This does not appear to include capital expenses funded by the AIF.
Payments in lieu of property taxes
(calculated at $1.9M for 2023: $.94 x # of passengers) and
Head office costs
(includes salaries for management - CEO, for example, of $402K) $7.4M– prorated based on expenses ($22.7M÷$31.2M or 72%, for the Airport) =$5.4M.
Total Airport expenses are then $30M, for a net loss for the Airport of $2.2M in 2023.
10. How much of the RESA cost can Ports Toronto finance?
Cost estimates for the RESA construction vary from $50M to $130M, depending on the option chosen. Setting aside whether investing public funds into building RESA is a wise use of those funds, we note this:
According to its 2023 Financial Statements, Ports Toronto has
Cash and short-term assets | $58.3M |
Long term investments | $51.2M |
Balance of its $50M term facility available | $25.5M |
LESS Bank loan It has a borrowing ceiling of $52.1M | -$24.5M |
LESS proposed capital projects, including $7.0M for Airport | -$26M |
LESS Accounts payable net of accounts receivable | -$31.2M |
Net available | $53.3M |
Ongoing payments for the tunnel are intended to be funded by the AIF.
Note that Ports Toronto’s Capital Assets are significantly understated at $227.3M. These are the accounting policies that lead to that statement:
Land acquired since 1974 is recorded at cost. Land acquired prior to 1974 was recorded based on historical appraised values.
All other capital assets are recorded at cost less amortization and any impairment losses, net of any applicable government funding.
Ports Toronto received $19.5M from the sale of 2.95 acres of water and submerged land in the Parliament Street Slip to Waterfront Toronto in 2022 and $88.5M o the sale of its property at 30 Bay in 2017. Other assets that are not required for its operations could readily be sold.
The City paid ~$60M to Ports Toronto in settlement of a dubious lawsuit - those fund appear to have been spent.
11. Shouldn’t Ports Toronto be brought into compliance with the Tripartite Agreement first?
The Dash-8 was added as a permitted aircraft to the Tripartite Agreement in 1985. At that time, the only Dash 8 plane that could have been in the contemplation of the parties was the Series 100 – a 37 to 40 passenger plane – about half the capacity, and about 60% of the weight of the Q400, which was developed in the 1990s.
Ports Toronto allowed Porter to use the Airport for its Q400 aircraft, when it was clearly not permitted as a Dash-8.
106 metres (348ft.) of suitable terrain is available off the end of runway 08-26
The Dash-8 Series 100 requires a runway of 3280’ (1000m) and RESAs of 492’(150m) at each end could readily be accommodated by the existing 3988’(1216m) runway, and the existing land off the ends of the runway.
The Q400, the aircraft flown by Porter and Air Canada from the Airport is too noisy. Not news to anyone, but the limits in the tripartite agreement are clear.
This chart is taken from a presentation made by a consultant to Ports Toronto on February 18, 2009:
Tripartite Agreement Compliance
Q402 | Tripartite | |
Flyover | 78 | 84 |
Lateral | 84 | 83.5 |
Approach | 93.1 | 92 |
Comparison of Q400 limits in tripartite
Ports Toronto tells us that one can average the three readings to achieve compliance. However, averaging is not permitted by the Tripartite Agreement.
The problem with both of these provisions was that they were impossible to enforce by the City, until now, and Ports Toronto ignored them with apparent impunity.
12. How real is the purported economic benefit of the Island Airport?
No study on the purported economic benefit of the Island Airport has determined how much of that benefit would simply transfer to Pearson. Downtown airports have closed around the world, without significant economic impact: Chicago, Santa Monica (soon), Edmonton, Berlin, for example.
There are economies of scale to be achieved by consolidating the Island Airport’s business into Pearson. Better use of the $650M Union-Pearson Express, one set of air traffic controllers, one customs clearance facility, etc.
13. How real is the purported economic benefit of the Island Airport?
Like City Express and Air Ontario, which both failed in their efforts to profitably fly out of the Island Airport, Porter
has been losing serious money: $18,910,000 in 2017, a projected $40M in 2018, and $30M in 2019
has been significantly reducing the number of its flights out of the Island Airport,
is threatening to leave the Island Airport, and
has commenced operating jets out of Pearson – even that has had a “rough takeoff”.
Porter has found that people prefer the better choice of flights at Pearson, and the convenience of the Union-Pearson Express train to get there.
14. How real is the purported economic benefit of the Island Airport?
As this study confirms, the Island Airport is the wrong place for the ORNGE helicopter service: more than half of its emergency destinations are north of the City, and operating from the Island Airport results in deteriorated response times for majority of patients during the critical initial minutes.
ORNGE should be stationed north of the city, and it certainly doesn’t require an airport to operate its helicopters out of.
Patients requiring critical care do not arrive at the Airport. They are delivered directly to hospital heliports.
This issue was advanced as a reason to not close the Edmonton City Centre Airport but did not stop the closure. Subsequently, a 2015 study concluded that moving medevac to the Edmonton International Airport had no impact on safety or the quality of care received by critically-ill and time sensitive patients.
15. Why wasn’t EMAS considered more seriously?
Ports Toronto has refused to divulge the studies it has undertaken to evaluate the alternatives.
Ports Toronto does say an EMAS "could be physically accommodated within the existing land mass".
The US FAA lists a number of US airports in snowy climates that have EMAS, including JFK in New York.
This brochure describes the EMAS installed at Chicago Midway. A similar, if not worse, climate to ours.
Even with a 150m RESA, runway excursions can still happen, particular if all they do is extend the runway. The EMAS system would actually stop planes and would be far better than a simple runway extension at preventing planes from plunging into the water.
16. What about the climate crisis?
Short-haul flights have been targeted in Europe – they’re the worst contributors to the climate crisis and are readily replaced by high-speed rail.
Shouldn’t the City be looking at whether the short-haul flights business the Airport specializes in can be shifted to more benign modes, making the Airport lands available for more appropriate uses reflecting their choice location?
Climate change is the biggest challenge facing our planet and is leading to hotter, wetter and more extreme weather. City Council declared a climate emergency in 2019 and adopted The Net Zero Strategy in 2021 to achieve net zero greenhouse gas emissions by 2040.
The City of Toronto recognizes the importance of acknowledging the connection between housing, transportation, and addressing climate change.
Significant funding has been provided to advance High Frequency Rail, which is likely to also be high-speed, from Toronto through to Ottawa and Montreal.
Should any investment of public funds into the Island Airport be made if its primary business - flights to Ottawa and Montreal – are potentially significantly diminished – and should be, if we are to take the climate crisis seriously?
Alstom, the France-based supplier that purchased the rail division of Bombardier thinks that a HSR project would cut Toronto/Montreal travel time to three hours. Alstom prepared this graph, that shows how sensitive passengers’ travel decisions are to travel time – most chose train over air when travel time falls below three hours (the distance from Toronto to Ottawa is ~400 KM, and Toronto to Montreal is ~540km):
The HFR project: Achieving modal shift
We look forward to productive discussion on these issues.
Brian Iler
Spokesperson for Parks not Planes
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