Revealed: Secret Toronto Port Authority Report on Island Airport runway overruns
- Parks not Planes
- 3 minutes ago
- 17 min read
Environmental Assessment fatally flawed – Decision made before public engagement had commenced
A Parks not Planes Report, May 2026
An April 2024 RESA Report, recently obtained through Freedom of Information, reveals that
Toronto Port Authority (TPA) had already made its decision on how to meet federal safety requirements for the Island Airport before public consultation occurred, and
there is a powerful case for a far cheaper, far less disruptive, and far more effective
alternative to the 150m Runway End Safety Areas (RESAs) TPA intends to build off the ends of the runway at the Island Airport [1].
The RESA Report was prepared by aviation consultants Avia NG Inc. for the TPA and is dated April 19, 2024.
Parks not Planes had requested the release of the RESA Report in August 2024, but the TPA refused, responding:
At the July 17th meeting, PortsToronto discussed six RESA options resulting from a comprehensive planning study conducted in 2023/24. The presentation delivered at the meeting, and subsequently posted to our project website, contains all of the relevant information from the study [our emphasis] and is the basis of all current and future studies.
It did not.
This report explains.
Based on our findings, Parks not Planes calls on Toronto Port Authority, the City of Toronto, the Ministry of the Environment, Climate Change and Nature and Transport Canada to reject the TPA’s RESA environmental assessment, and conduct an independent, proper and valid one.
1: Why is RESA Important?
The 300m 2005 Air France flight 358 runway overshoot at Pearson[2] illustrated the need for adequate Runway End Safety Areas and triggered consideration of longer minimum RESAs at Canadian Airports.
More recently,
On November 19, 2024 at the Vancouver International Airport, an aircraft overshot runway 08L by approximately 1250 feet (381m) beyond the paved surface[3], becoming stuck in mud.
On December 31, 2024, at Muan International Airport in South Korea an aircraft overshot, crashing into a concrete wall 250m from the end of the runway, with 179 fatalities resulting from the crash.
A New York Times analysis states:
Runway excursions – when an aircraft overruns or veers off the runway during landing or takeoff – have for years been among the most common type of aviation accident. But in the vast majority of cases, the planes come safely to a stop, saved in part by zones around runways that are supposed to contain only structures that are frangible, meaning designed to break easily upon impact.
If any of those incidents had occurred at the Island Airport, there would have been a high risk of multiple fatalities: the current Island Airport RESAs are only 106m.
The Canadian Transportation Safety Board and International Civil Aviation Organization (ICAO) recommend, and the United States’ Federal Aviation Administration requires[4] 300m RESAs[4]. Yet Transport Canada has only recently imposed 150m RESAs, requiring them to be installed by July 12, 2027[5] for the Island Airport.
Toronto Port Authority’s RESAs are, have been, and will be, wholly inadequate: even with the pending 150m requirement, the Island Airport RESAs will be too short, and overshoots could end up in deep water with potential for fatalities. No regulation addresses the unique safety challenges presented by an airport bounded by water.
For commercial airports in Canada, the Island Airport is essentially alone in facing that risk.
The Island Airport does not become unsafe in 2027, when the 150m RESA minimum requirement comes into force – it is unsafe now.
Toronto Port Authority has ignored that risk.
2: What is an EMAS?
"An EMAS installation absorbs the kinetic energy of runway excursion aircraft in less space and time than traditional turf or paved safety areas."
From the RESA Report
The EMAS is used where a 300m RESA is not feasible.
From the Transport Safety Board of Canada Report on the 2005 Air France runway overshoot at Pearson:
“An EMAS is an area of materials of closely controlled strength and density placed at the end of a runway to stop or greatly slow an aircraft that overruns the runway. When an aircraft rolls into an EMAS arrester bed, the tires sink into the material and the aircraft decelerates …
“The EMAS technology is designed to stop an aircraft where it is not possible to construct a 300 m (ICAO or FAA) overrun … ”
From the RESA Report:
“A typical EMAS will bring a runway's critical aircraft to a complete stop when it enters the EMAS at a speed of 70 knots or less. Transport Canada design standards permit the use of EMAS where an airport may lack adequate space for traditional open space safety areas.
“Given the limited landmass off both ends of Runway 08/26, another alternative available to airports under RESA design standards is the use of an EMAS. An EMAS installation absorbs the kinetic energy of runway excursion aircraft in less space and time than traditional turf or paved safety areas. The material used for EMAS effectively "crushes" under the weight of the excursion aircraft, slowing it down considerably faster than open space. A typical EMAS will bring a runway's critical aircraft to a complete stop when it enters the EMAS at a speed of 70 knots or less.
“Transport Canada design standards permit the use of EMAS where an airport may lack adequate space for traditional open space safety areas.”
3: Why is EMAS Safer?
"EMAS has proven to be a cost-effective, efficient, and successful way to protect against overrun accidents."
2010 FAA Report
Surprisingly, when RESA is stated to be all about safety, neither the TPA in its presentations, nor the RESA Report, evaluated the alternatives based on which is the safest.
As noted above, there are numerous examples of aircraft overshooting the runway by more than 150m. Transport Canada found there were 42 runway overshoots over 150m at airports in Canada over the years 1990-2010[6]. A 150m RESA would not have stopped any of those 42 overshoots.
It is particularly important to stop runway overshoots at the Island Airport, as the water off the end of the runway is deep, running the risk of damage to the aircraft, and possible fatalities. EMAS, on the other hand, is designed to stop an aircraft without damage before it reaches deep water.
Transport Canada, recognizing the lack of available land for an adequate RESA, stated, in an internal document:
“Billy Bishop [the Island airport] would be required to meet what would be the new RESA requirement by installing an Emergency Material Arresting System EMAS) at a significant cost. The balance of the busiest airports have land available for the implementation of RESA.” [7]
“Significant cost”? Contrary to Transport Canada’s opinion, the RESA Report confirms that EMAS is, by far the least expensive of all the alternatives studied.
The EMAS alternative is far more effective in preventing damage or injury from runway overruns than the proposed 150m RESA: the recommended RESA is 300m internationally, and a 150m RESA still has considerable potential for an aircraft to overshoot beyond 150m and end up in deep water.
EMAS stops it dead.
An EMAS manufacturer states it this way:
Most runways have enough area for a sufficient RESA, stopping an aircraft at 70 knots within 300 meters from the end of the runway (ICAO recommendation). If there are space limitations and reduction of the runway’s declared distances or a geographical extension is not possible, an EMAS (Engineered Material Arresting System) is the option.
This alone should have led TPA to conclude that EMAS was the sole viable alternative.
4: What the TPA told the public
"One should always be wary of any Environmental Assessment carried out by the proponent of the project..."
Where were only two opportunities for the public to have input into the proposal to extend RESAs at the Island Airport – on July 17, and October 15, 2024, as part of the non statutory Environmental Assessment conducted by the TPA. One should always be wary of any Environmental Assessment carried out by the proponent of the project instead of an independent organization such as the federal government’s arm’s length Impact Assessment Agency of Canada.
The TPA’s July 17, 2024 presentation was the only public presentation of the EMAS alternative. It contained this cursory and dismissive statement on EMAS:
Option C: EMAS
Marine environment impacts (west end) require breakwater construction
Special equipment required for snow and maintenance of EMAS
Additional ongoing airport operational costs for inspections, maintenance, and 20 year life expectancy
Would be the first and only EMAS installation in Canada; the only manufacturer based in USA
Damaged EMAS due to aircraft or equipment excursions will require repairs and notices published to aviation community. Risk of runway closure or major reduction in length if not repaired within 45 days.
With this statement in its presentation at the second public meeting on October 15, 2024:
”additional technical feasibility assessments confirmed that EMAS is a high risk option with costly operation and maintenance demands, making it technically infeasible”
the EMAS alternative was not considered further by the TPA. No such additional assessments have been disclosed.
Ultimately, the TPA reported, in its Gap Analysis, an appendix to the Environmental Assessment, that EMAS
presents certain operational and business risks, including the potential need for repairs in the event of damage from aircraft or equipment excursions. Failure to address these issues promptly could result in runway closure. In response to public feedback from the first open house, Engineered Materials Arresting System was reconsidered and reviewed again. However, due to unacceptable operational, feasibility and regulatory risks, it has been ruled out.
While the public presentation accurately listed the study’s concerns, it omitted the Report’s confirmation that EMAS is cheaper than any of the other alternatives studied and requires minimal lakefill.
The full multi-criteria analysis was not shared, depriving the public of informed participation as required by the Impact Assessment Act.
The TPA was wrong to have chosen a more expensive and less effective (and therefore less safe) alternative that involves far more filling of our harbour and lake.
5: What did the RESA Report reveal?
EMAS is far cheaper than any of the alternatives. EMAS capital cost is stated to be $39M. Conventional RESA options cost $61M to $172M.
EMAS involves minimal lake-fill – 1750 square metres [8], unlike the alternatives:
o Option 4 (selected by City Council) requires 13,950 square metres of lake-fill [9]
o Option 5 requires 23,100 square metres of lake-fill [10]
o Option 6, TPA’s preferred alternative [11] requires: 42,580 square metres of lake-fill
The RESA Report states that EMAS material and associated perimeter emergency access roads can be accommodated within the existing 108m pre-threshold areas off both runway ends. There is no need for extensive filling of the harbour or Humber Bay.
EMAS is commonly used at US airports with similar climates [12]. From the RESA Report:
“EMAS has proven performance in marine and cold climates.” (page 47)
No inquiries were made of those airports to learn from their experience.
Repairs to the EMAS can readily be made without affecting the operation of the runway if damaged by an overrun. In the US operations are permitted to continue for 45 days after damage has occurred, providing more than sufficient time to effect repairs. There is no reason to believe Transport Canada would differ.
Was Transport Canada even asked? Have any of the US airports with EMAS had to shut down because of damage to an EMAS? The RESA Report did not ask or answer that question.
6: Transport Safety Board of Canada (TSB) recommends 300m RESA or EMAS
The TSB stated, in its report of the 2005 Air France overshoot recommending a 300m RESA:
“The Board is aware that requiring a 300 m RESA may affect many existing Code 4 runways that are located where natural obstacles, local development, and/or environmental constraints make the construction of a RESA of this length impracticable. The Board believes that there exists a requirement for an alternate means of compliance, such as the use of an engineered material arresting system to provide a level of safety that is equivalent to a 300 m RESA.”
Will the 150m Runway End Safety Area planned for the Island Airport do the job as well? Clearly not.
The 2005 Air France overrun at Pearson was approximately 300 m beyond the end of the runway [13] . A 150m RESA would not have prevented the crash. An EMAS would have.
7: Comparison of TPA’s public statements with the secret RESA report
TPA July 17, 2024 Presentation: Marine environment impacts (west end) require breakwater construction
What the report states: All alternatives require breakwater construction.
“On the west end, additional landmass is required in combination with a breakwater structure to control wave overtopping and water spray to reduce ice encroachment onto the EMAS. Ice buildup on the EMAS can compromise its performance and can reduce its operational life expectancy resulting in more frequent maintenance and replacement. The height of the breakwater in this case was set to comply with airspace protection requirements off the runway and to control water spray sufficiently to mitigate ice accretion onto the EMAS. No additional landmass or breakwater was proposed at the east end due to the low probability of significant wave action and limited to no ice encroachment risks due to the protected inner harbour. (page 45)
TPA Presentation: Special equipment required for snow and maintenance of EMAS.
What the report states: “To accommodate winter conditions and routine maintenance of the surface of the EMAS, small/light snow clearing equipment, i.e., Bobcat/Kubota are required and would need to be purchased by the airport as part of this alternative and have been included in the cost projections.”
TPA Presentation: Additional ongoing airport operational costs for inspections, maintenance, and 20 year life expectancy
What the report states: “The net present value (NPV) for a 20-year life cycle cost analysis including capital and maintenance/replacement for the EMAS was project to be about $43-45 million. These cost estimates included an allowance of $500,000 for new EMAS maintenance equipment.[page 47]”
TPA Presentation: Would be the first and only EMAS installation in Canada; the only manufacturer based in USA What the report states: “It should be noted that EMAS is used extensively in the US and internationally, but there are no EMAS installation to date in Canada. Research and consultations with the supplier Runway Safe confirmed that EMAS is compatible with marine and cold climate environments similar those experienced at Billy Bishop Toronto City Airport. EMAS installations with similar winter environments can be found at airports like Boston Logan International, JFK, Minneapolis St. Paul, Rutland/Southern Vermont Regional and Kodiak, Alaska.” (page 46)
TPA Presentation: Damaged EMAS due to aircraft or equipment excursions will require repairs and notices published to aviation community. Risk of runway closure or major reduction in length if not repaired within 45 days.
What the report states: “Would be the first EMAS installation in Canada and would require Transport Canada to acknowledge acceptance of FAA AC 150/5220-22 Engineered Materials Arresting Systems (EMAS) for Aircraft Overruns (e.g. 45 days return to service FAA requirement and no runway closure due to damaged EMAS). Transport Canada’s Advisory Circular AC 300-007 defers to the United States FAA EMAS planning, design, installation and maintenance standards.
“While this offers clear direction at this time, it may introduce future unknown risks due to changes in standards by an agency outside Canada”
Neither the RESA Report, or the TPA Presentation indicate any effort to seek information on repair times from airports using EMAS.
We found this, from an EMAS manufacturer (our emphasis) [14]: Should an overrun occur, the damaged portions of the bed can easily be repaired without impacting other areas. The damaged area is removed and reconstructed with the same material used at the initial installation. Repair materials can be stored on site or shipped from Runway Safe safety stock.
The runway can be operational within hours after the aircraft has been removed with a partly functional EMAS. The final restoration needs to be done after all material is on site but no later than after 45 days.
8: Choosing the preferred alternative
The criteria set out in the Report for evaluating the alternatives were not disclosed during the EA process. If they had been, these would have been challenged:
The failure to give any emphasis to the far superior safety provided by the EMAS alternative, as noted above.
The failure to seriously consider the impact on our waterfront of massive lake-filling
The failure to seriously consider the excessive costs of the non EMAS alternatives.
The undue weight given to “community benefits” when no community input to whether they are desired or sought by the community was obtained
The Report’s failure to inquire into the actual experience with EMAS at the many US airports where it had been installed
Regulatory uncertainty: was Transport Canada even asked if they would agree to adopt US FAA rules? EMAS is used effectively in many US airports with similar climates. There is no reason for concern that Transport Canada would object or change its rules.
How real was the claim that the runway might have to be closed while EMAS is repaired? As noted above, it appears that runway operations can continue while repairs are made, and that repairs can readily be made within the 45 day period applied in the US, essentially eliminating the risk of runway closing.
Failing to reveal the criteria used to choose the preferred alternative should be fatal to the EA. And on examination, the criteria used were the wrong ones: safety, cost, and impact of extensive lake-filling on our waterfront should have been the prime considerations. They were not mentioned in the evaluation [15].
9: No meaningful or transparent public participation
The RESA Report revealed that the decision to adopt another alternative was made by the TPA board well in advance of environmental assessment conducted to assess the alternatives, and before meaningful public engagement on those alternatives occurred.
That made the entire EA process a sham.
From page 50 of the RESA Report:
“The alternatives presented in Section 4 were presented to PortsToronto for consideration. The Board of Directors together with the PortsToronto RESA Technical Committee reviewed the alternatives and considered how implementation of the project would align with their latest Strategic Plan, ESG priorities and the work conducted during the 2018 Airport Master Plan, as added factors. From this, Alternatives 5 and 6 were chosen as the preferred alternatives.”
TPA (formerly Ports Toronto) failed to advise the public that it had already decided on the preferred alternatives, and failed to meaningfully inform and engage the public in the course of its voluntary Environmental Assessment (EA) of knowledge in its possession that could have significantly impacted the method adopted for compliance with impending [16] Runway End Safety Area (RESA) requirement at the Island Airport [17] .
"The overarching approach... is a commitment "to providing Canadians with the opportunity to participate meaningfully in the process and to providing them with the information needed to participate in an informed way" The new Federal Impact Assessment Act: Implications for Canadian Energy projects, 2021 CanLIIDocs 2385.
None of the discussion of the “Preferred Alternative” set out in the RESA Report was revealed to the public.
In fact, the RESA Report discloses, at page 50, that
The alternatives presented in Section 4 were presented to PortsToronto for consideration. The Board of Directors together with the PortsToronto RESA Technical Committee reviewed the alternatives and considered how implementation of the project would align with their latest Strategic Plan, ESG priorities and the work conducted during the 2018 Airport Master Plan, as added factors. From this, Alternatives 5 and 6 were chosen as the preferred alternatives.
The Report was dated April 2024, months before the RESA issue was taken to the public for comment and input. Public engagement occurred in sessions were held in July and October, 2024.
The decision of what option is preferred was made well before any opportunity for public input.
Meaningful and transparent public consultation is a requirement under the rules applicable to environmental assessments (now, federally, Impact Assessments) [18] .
A failure to comply with the requirements can result in the EA being set aside: see, for example, Greenpeace Canada v. Canada (Attorney General), 2014 FC 463 (CanLII)
Meaningful public participation is participation that is informed. Informed participation requires that all relevant information be made available.
Here, the withholding of the Report, and the fact that the decision on the approved alternative was made well before any public engagement, destroyed any chance of fulfilling that obligation for transparent, meaningful public participation.
10: Conclusion
We know that EMAS is the only effective method of ensuring an overrun does not result in damage, injury or death at the Island airport. And it the cheapest alternative. Unlike the RESA alternatives, it requires only minimal lake-filling.
Where decisions affect major public infrastructure and publicly owned waterfront lands, decision-makers must be confident that environmental assessments fully and accurately disclose the range of feasible alternatives on which public participation depends.
We now know that EMAS is the only effective method of ensuring an overrun does not result in damage, injury or death at the Island Airport.
And it is the cheapest alternative. Unlike the RESA alternatives, it requires only minimal lake filling.
Yet TPA summarily dismissed it and chose to hide the RESA Report from the public instead.
A 150m RESA – the minimum to be required by Transport Canada is in many cases ineffective at preventing damage or injury – 300m is the international standard.
Far more effective is an EMAS, that actually does stop an overrunning aircraft BEFORE it hits the deep water off the end of the runway at the Island Airport.
TPA – and Transport Canada – need to explain why they have failed to put safety first. And why they are choosing to spend millions of public dollars on an ineffective alternative.
11: What can be done?
a. The City should not approve the RESA Environmental Assessment
An appropriate environmental assessment is a precondition for approval by the City of TPA’s Runway End Safety Area project, pursuant to the City’s January 25, 2025, agreement to extend the City’s lease to Ports Toronto for a portion of the Island Airport lands:
The Lessee shall complete an Environmental Assessment for RESA at its sole expense, prior to the commencement of construction, and to the satisfaction of the City, acting reasonably.
The work carried out to date by the TPA and its consultants is inadequate to satisfy that precondition.
The City should immediately notify TPA that the EA as conducted did not meet the required standard, and that it is rejected.
b. The Impact Assessment Agency should conduct an independent, and comprehensive impact assessment
We are asking the Minister of the Environment, Climate Change and Nature to designate the RESA Project under subsection 9(1) of the IAA.
She may do so if “the carrying out of that physical activity may cause adverse effects within federal jurisdiction or direct or incidental adverse effects”
c. Insist that the safest option be chosen
Both Transport Canada and TPA need to be told that EMAS is the only acceptable option for safety at the Island Airport.
[1] We use the common name for the Airport. It is also known as the Billy Bishop City Centre Airport.
[2] The TSB report on the overrun.
[3] The initial TSB report on this incident.
[4] Wikipedia: Runway Safety Area (RESA)
[5] Why did Transport Canada take so long (from the overrun in 2005 until the effective date of the requirement in 2027) to act on the TSB’s recommendations?
It is clear from reviewing 723 pages of FOI disclosure that the sole reason for the delay has been the dilemma of Billy Bishop Airport. It is the only airport that cannot deliver the TC recommended 150m RESA.
This is from a document found at page 62+ of that disclosure:
“The Toronto Billy Bishop Airport case is unique, the airport is on the island and runways are very close to the seaside. The runway is significantly constrained due to the land mass limitations and the surrounding marine environment. The RESA was analyzed on the basis of the minimum dimensions. The proposed land mass expansion would be capable of not only supporting the proposed RESA, but would also offer the flexibility to incorporate additional airfield infrastructure. The option could be constructed between 2.5-3 years, and the capital cost [redacted]
“However, the cost associated with this work is significant, and [redacted]
“Option to expand the runway should be explored but must respect the Tripartite Agreement and will cost would be extremely significant. The table 3 summarizes the impact of the implementation of RESA on 36 impacted Canadian airports.”
[6] From Transport Canada FOI production, at page 39
[7] ibid, at page 202
[8] “The EMAS material and associated perimeter emergency access roads can be accommodated within the existing 108m pre-threshold areas off both runway ends.” Secret RESA Report, page 47
[9] on the west end 7,850 square metres, and on the east end 6,100 square metres
[10] on the west end, 11,800 square metres, and on the east end, 11,300 square metres
[11] 12,600 square metres on the west end and 29,980 square metres on the east end Total
[12] From the Secret RESA Report, page 46: “Research and consultations with the supplier Runway Safe confirmed that EMAS is compatible with marine and cold climate environments similar those experienced at Billy Bishop Toronto City Airport. EMAS installations with similar winter environments can be found at airports like Boston Logan International, JFK, Minneapolis St. Paul, Rutland/Southern Vermont Regional and Kodiak, Alaska.”
[13] Per Wikipedia
[15] See page 51 of the Report.
[16] The RESA must be operable by July 12, 2027
[17] At least since the Air France overshoot at Pearson in 2005, RESAs have been advisable.
[18] The Impact Assessment Act, SC 2019, c 28 states, in its Preamble:
Whereas Parliament recognizes the importance of implementing the impact assessment process in a manner that fosters meaningful public participation, [and] is transparent …
Section 6(3) of that Act states
The Government of Canada, the Minister, the Agency and federal authorities must, in the administration of this Act, exercise their powers in a manner that
(a) ensures that processes … are fair, predictable and efficient; and
(b) adheres to the principles of scientific integrity, honesty, objectivity, thoroughness and accuracy.
And section 11 of that Act states
“The Agency must ensure that the public is provided with an opportunity to participate meaningfully
Comments