What the Globe Left Out: Billy Bishop, the Harbour and Toronto's Waterfront Future
How to Win an Argument Without Having It
The Globe and Mail's Saturday editorial on Billy Bishop had one job: address the biggest waterfront question in Toronto right now, in the middle of a federal public comment period. It didn't. And I don't think that's very balanced.
The Globe can't make a case for filling in Lake Ontario. So it doesn't try. It leaves the lake out of the argument entirely and endorses the expansion anyway.
Here is how the argument works. The editorial admits "many different potential impacts are being discussed," then narrows the whole debate to one line: "the key question is if the economics of the expansion work."
That's the not the whole story. Everything important, the harbour, the habitat, the water, the Great Lake, becomes background noise. The business math gets the focus while the lake gets ignored. Again.
The "Already Ruined" Loophole
Here's what the math conveniently skips over. A sad argument that justifies filling in the lake.
In 2003, the Environmental Assessment for this airport found the Western Channel habitat already so degraded that further impacts weren't considered significant. It did not say the impacts of Lake infilling were acceptable. They were not even reviewed. Just: already ruined, so it doesn't count anymore. That's the sentence that justifies ignoring the environmental impacts. It keeps returning, even twenty years later, without anyone mentioning it. Nothing about the government and community efforts to restore Toronto’s harbour and lake?
Instead, the piece narrows the opposition down to noise and traffic. Waterfront residents who "knew they would live near the airport." Road congestion a shuttle bus can fix. It's a neat move: take your weak ecological argument, ignore it and focus on a neighbourhood dispute about decibels. Once it's a neighbour dispute, it's NIMBYism. Once it's NIMBYism, nobody has to talk about restoring the integrity of the harbour, the waterfront, fish habitat, recreational water opportunities or our binational obligations to protect and restore the Great Lakes.
The editorial's entire environmental accounting is one line: jets might cause "some impact on boats." It's worth being specific about what the impact actually is. The Toronto Port Authority's own CEO has said the extension could require up to 900 metres of new landmass in Lake Ontario, most of it filled in toward Ontario Place. Nobody, not the TPA, not the province, has published a volume for that fill. No cubic metres. No truckloads. Just a length.
60,000 Truckloads Into the Lake
So I did the math myself, using their own numbers. A 900-metre extension, filled to a modest 4 metres of depth, across the width of the graded airfield strip required for runway safety, comes to roughly 700,000 cubic metres of fill. At 12 cubic metres a load, that's about 60,000 truckloads going into Lake Ontario. This is my estimate, not an official one, because there isn't one. An agency that can tell you the runway will be 900 metres longer can tell you how much lake it's filling in. It hasn't.
And this fill isn't routine. Look around the Great Lakes right now and new land creation has mostly stopped. Toronto's own Leslie Street Spit, the largest lakefill in Lake Ontario's history, is finished. Hamilton Harbour's big project isn't creating land at all; it's sealing off nearly 700,000 cubic metres of legacy industrial poison so it stops leaching into the water. Chicago just fought off an attempt to expand a lakefront disposal site. Billy Bishop may be the only place on the Great Lakes right now proposing to create new land in open water, rather than achieving its goals with what is already there.
And of course, where is the fill coming from? Who is assessing the quality of the fill? Will it be clean enough to put in the lake? Let’s talk about that.
A Project That Is Currently Illegal
Most importantly, the editorial should have started with the heart of the story. The 1983 Tripartite Agreement that governs this airport, splitting ownership between the Toronto Port Authority, the City and Transport Canada, explicitly prohibits runway and landmass extensions. Not discourages. Prohibits. This project is currently illegal under the terms of its own governing agreement.
The onus to change the law is the government's burden and the government must be held accountable.
The province's answer has been to pass legislation taking over the City's seat at that table and to talk about declaring the airport a "special economic zone" to suspend the rules that would normally apply.
But a provincial special economic zone can only waive provincial and municipal law. It cannot waive the Fisheries Act, the Species at Risk Act or the Migratory Birds Convention Act. It cannot ignore our transboundary obligations under the International Joint Commission, which treats water diversions and lake infilling as serious violations of the shared responsibility both countries, eight states and two provinces hold for protecting the Great Lakes.
Worth remembering, this spring, our provincial government gutted Ontario's own Endangered Species Act, stripping habitat protection from dozens of aquatic species and migratory birds and telling the public that federal law already had it covered. Concerned environmental experts warned that federal statutes don't sit at the permitting table the way the provincial law did. So Ontario is leaning on a federal backstop it just spent months arguing was sufficient, on the one project where that backstop is about to be tested. And the only environmental review that's actually been done on this airport, from 2017, was released to the public with sections redacted. Whether a full federal review is even required this time is still an open question and nobody in government has answered it.
That's the real story: not noise complaints, although they are legitimate; but the story is the future of Toronto’s waterfront, the governing agreements being overridden, a federal review whose scope is unclear and species protections quietly disappearing at the exact moment they're needed most. The Globe had space to ask about any of it. It asked about airfares instead.
How to Have Your Say (Before July 24)
The Globe has weighed in. I'd wager plenty of its editorial board have already sent their own views to the government that's actually deciding this. Transport Canada is taking public comment on the future of this airport right now, through July 24. This is not a symbolic exercise; the department has said feedback will directly inform the decision and will be summarized in a public report afterward. Hopefully, it will also acknowledge that the decision is not entirely theirs and that other federal authorities and jurisdictions are directly involved.
If you think the lake deserves better than a line about boat traffic, say so before July 24.
By Email: airportspolicy-politiquedesaeroports@tc.gc.ca(Use subject line: Consultation – Future of Billy Bishop Toronto City Airport)
Online: Submit via Transport Canada's anonymous online survey.
By Mail: Transport Canada, Air Policy, Place de Ville, Tower C, 330 Sparks St, Ottawa ON K1A 0N5
Say it plainly. Ask the government to follow all their environmental laws and processes before making a decision. Make your opinion known about what you want in the future from Toronto’s harbour and lake. Request that no infilling occur until they prove it makes the harbour and lake more swimmable, drinkable and fishable, not less so?
Then and only then, can we assess the market value and other benefits of an expanded second airport on Toronto’s waterfront.


You say what needs to be said so eloquently. I hope you sent this to the Globe’s Senior Editor.
That’s disappointing about the editorial…. After the July deadline, is a decision made soon after?