workers Submission to the City of Toronto 2012

8/2/2019 workers Submission to the City of Toronto 2012

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________________________________________________________________________________________

TORONTO TAXIWORKERS Chapter of i TAXIWORKERS

SUBMISSION TO

THE CITY OF TORONTO 2012 TAXICAB INDUSTRY REVIEW

FEBRUARY 27, 2012

TORONTO TAXIWORKERS Chapter of i TAXIWORKERS

25 Cecil St. Toronto, ON M5T 1N1

Phone: 416-597-6838 Fax: 416-597-2195

E-mail: [email protected]

<cope 343> <SRU-SDR>




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TABLE OF CONTENTS………………………………………………………………………………………………………………………………………..

ACKNOWLEDGMENTS ..................................................................................... v

ABOUT THE iTAXIWORKERS.............................................................................1

DEMOGRAPHICS - WHO ARE TORONTO’S TAXI DRIVERS? ...............................3

INTRODUCTION - THE NEED FOR FURTHER CHANGE.......................................5

SUMMARY OF THE iTAXIWORKERS' PROPOSED REFORMS FOR TORONTO’S

TAXI INDUSTRY................................................................................................9

HEALTH & SAFETY .........................................................................................13

LICENSING ISSUES .........................................................................................19

AGENTS & SUB-LEASING................................................................................35

SHIFT & LEASE RATES ....................................................................................39

TAXI STANDS .................................................................................................41

RELATIONSHIP BETWEEN DRIVERS, MLS & POLICE........................................45

BENEFIT FUND...............................................................................................47

TAXIS AS PUBLIC TRANSIT..............................................................................51

CONCLUSION - A WAY FORWARD FOR TORONTO’S TAXI INDUSTRY .............57


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ACKNOWLEDGMENTS………………………………………………………………………………………………………………………………………..

The iTaxiworkers would like to thank all the taxi drivers of Toronto who participated in the

preparation of these proposals. Their thoughtful ideas and contributions shared throughmeetings, surveys, and various working groups are reflected in this report.

This report also reflects the invaluable contributions of numerous individuals and

organizations that provided guidance, suggestions, research and administrative support.

This report would not have been possible without the dedication and hard work of the

following:

• Caitlin Gascon, MIRHR Candidate, University of Toronto

• Michael Halder, MES (Planning)

• Stephanie Ireland, MSc (Planning) Candidate, University of Toronto

• Kaitlin Nay, MIRHR Candidate, University of Toronto

• Jackie Edwards, United Steelworkers

• Mark Janson, United Steelworkers




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ABOUT THE iTAXIWORKERS………………………………………………………………………………………………………………………………………..

The iTaxiworkers Association is the latest installment in the long history of taxi drivers in

the City of Toronto collectively advocating for justice and dignity in their profession. In

2009, taxi drivers came together to form the iTaxiworkers Association to improve the

rights and working conditions of Ontario taxi workers. The iTaxiworkers brings together

frontline taxi drivers with the aim to unite the many voices to reform the taxi industry so

that drivers can make a decent living and come home safely to their families at the end of

a shift. Support for the iTaxiworkers Association has grown steadily as members and

drivers experience the value of the organization. Today, the iTaxiworkers is on track to

represent close to 1,000 taxi drivers in Toronto and continues to provide legal defense,

political advocacy and organize Toronto taxi drivers for justice and reform. Run by and for

taxi drivers, support for the iTaxiworkers continues to grow as taxi drivers show their

resolve to be organized and united in their quest for respect, equality, and fairness.





DEMOGRAPHICS

WHO ARE TORONTO’S TAXI DRIVERS?………………………………………………………………………………………………………………………………………..

Before examining Toronto's taxi industry, it is important to understand the city’s taxi

drivers.

The 2006 Census provides the following data on “Taxi and Limousine Drivers and

Chauffeurs” in Toronto.1

• 11,055 total drivers

• 96% male, 4% female

• 63% of labour force between the ages of 35 and 54

• 81% are immigrants to Canada

• 73% are visible minorities

• 24% speak English as their mother tongue

• 44% work more than 50 hours per week

• 48.1 average hours worked in the reference week

• $11,949 is the median full year full-time employment income

These statistics clearly demonstrate that taxi drivers in Toronto work long hours for very

little compensation.

In contrast to the Toronto-wide median full-time full-year employment income of

$45,350, half of Toronto taxi and limo drivers are earning less than $11,949 for a full year’s

work. This median income implies an hourly wage of $4.782

compared to Ontario’s

current general minimum wage rate of $10.25 per hour. In other words, taxi drivers earn

less than half of the minimum wage to support their families. If we could separate the

limo drivers out of this group, the taxi-only result would indeed be smaller still. Almost

half of Toronto’s drivers are working more than 50 hours per week. In short, they are

working hard to bring home poverty wages.

1This is the smallest occupational data set available from Statistics Canada. It is worth noting that the

number of taxi drivers in this classification would greatly outnumber the limousine chauffeurs, but the

inclusion of chauffeurs would tend to increase average compensation.

2The Census classifies “full-year” as 49 to 52 weeks and reports that more than half of full-time drivers

worked more than 50 hours per week. $11,949/50 weeks/50 hours = $4.78/hour.



And “home” does indeed matter to these drivers. As the statistics show, the vast majority

of drivers are in the age bracket where they are likely to have dependent children. An

iTaxiworkers survey3

indicated that many drivers have large families who depend on their

earnings. Of surveyed drivers, an average of 4.5 people depend on a driver’s earnings.

In addition to low income, over 80% of taxi drivers in Toronto are immigrants to this

country. The challenges faced by new Canadians in their political, economic and social

lives have been well documented. Any reform of the taxi industry should take a holistic

approach and consider the various dimensions of a taxi driver’s life.

3In the summer of 2011, the iTaxiworkers conducted a survey of Toronto’s taxi drivers, both members and

non-members. Two hundred and sixty-one surveys were completed through meetings and on the street

outreach.



INTRODUCTION

THE NEED FOR FURTHER CHANGE………………………………………………………………………………………………………………………………………..

“The taxi is often the largest employer in an urban community and will

touch the lives of a significant proportion of a city’s population.”

- James Cooper, Ray Mundy, John Nelson, Taxi!: urban economies and the social and

transport impacts of the taxicab, 2010

“The more the working conditions of the taxi industry are improved, the

more chance of the industry attracting the type of driver who will give

improved service.”

- Mel Lastman, Report on the Metropolitan Toronto Taxi Cab Industry to Metro Legislation

Committee, January 22, 1975

“The taxi driver is the most important part of the taxi industry, and if he or

she works for low pay in poor conditions, the people of Toronto cannot

expect an efficient taxi industry.”

- Brief submitted to the City by the Toronto Union of Taxi Employees, November 20, 1973

“Low driver incomes attract low quality drivers into the industry and reduce

the quality of the taxi service.”

- Taxicab regulation in Metropolitan Toronto: A Background Paper Prepared for theMetropolitan Licensing Commission, by Bruce Chapman, 1994

“The ability of a driver to generate income can have a direct affect on how

a driver relates to the public and takes pride in providing safe and

comfortable transportation.”

- Report to Review the Toronto Taxi Industry, Toronto Task Force to Review the Taxi

Industry, October 1998

For decades, the City of Toronto has made genuine efforts to improve its taxi industry.

Consultations, special reports and fact-finding efforts have brought about changes that

have reshaped the industry – in many cases, for the betterment of all.

The 1998 Task Force to Review the Taxi Industry (1998 Task Force) focused on the

consumer with its main goal to improve customer service. Taxi driver groups supported

and we continue to support this goal. Our members work long hours doing dangerous



work for very little reward, yet they still manage to serve their customers with a smile. Of

the millions of taxi rides taken each year in Toronto, the City receives few customer

complaints. Managing to provide a high level of customer service despite overwhelming

challenges is proof of drivers’ commitment to serving customers well.

Despite all the positive outcomes of the 1998 Task Force, taxi drivers – an integral

stakeholder group in the industry – were largely overlooked. For example, the City

mandated the creation of a Taxicab Passenger’s Bill of Rights, but no corresponding

document for taxi drivers.

We have had 14 years to evaluate the changes arising from the 1998 Task Force. Our

experience represents 14 years of frontline, on-the-ground knowledge that should be

invaluable to this consultation. We share the desire for a taxi industry that benefits all of

its stakeholders. However, we feel that the current system disadvantages drivers in some

significant ways. And when drivers are disadvantaged, the entire system suffers.

We recognize that the City of Toronto does not employ the thousands of taxi drivers who

work within its borders. Drivers work within a complicated system of ownership, leasing

and rental arrangements, typically as self-employed drivers.

However, we do recognize that the City exerts unilateral control over the legislation and

licensing policies that are enormously influential in determining what kind of working

realities Toronto taxi drivers face.

The City of Toronto is continually striving to be recognized as a world-class city, with

efficient and modern infrastructure. A clear goal of the 1998 Task Force was to re-brand

the city’s taxi industry, so that taxis would become part of the city’s image, similar to

London’s black cabs or New York’s yellow cabs. The iTaxiworkers support this broad goal,

as the taxi industry is a key component of any modern city. Taxi drivers perform an

essential, frontline service that directly impacts the day-to-day lives of millions of

residents and visitors to the Toronto area. As taxi drivers comprise one of the city’slargest professions, we believe our industry is critically important in making our city work

well.

This submission contains 14 recommendations the iTaxiworkers have developed through a

lengthy democratic process. Our policy development process involved an extensive driver

survey, data collection from the City of Toronto’s Municipal Licensing and Standards



Division (MLS), extensive review of academic and think-tank studies, working groups with

industry stakeholders, many open-floor meetings with our members and non-member taxi

drivers, “best practices” discussions with taxi driver groups in other cities, and several

rounds of membership approval of the proposals. Our proposals have been refined,

critically examined and discussed countless times. They address such topics as: health andsafety, licensing, the role of agents, lease rates, and taxi stands.

We are confident that our proposals provide a coherent, creative and evidence-based

roadmap for a better taxi industry in Toronto.

The fundamental principles uniting these proposals are the iTaxiworkers’ position that the

industry will be of greater benefit to the city when its taxi drivers are economically,

physically and psychologically secure. The link between working conditions and customer

service is strong. Making the industry better for drivers will make it better for passengers,

which will benefit the city at large.

The announcement of this consultation process has given Toronto taxi drivers hope that

their grievances will be heard and addressed. We thank the City for beginning this process

and welcome the opportunity to participate in it.





SUMMARY OF THE iTAXIWORKERS’ PROPOSED

REFORMS FOR TORONTO’S TAXI INDUSTRY………………………………………………………………………………………………………………………………………..

HEALTH AND SAFETY

1. Establish a permanent task force including taxi drivers,

police, industry stakeholders and health practitioners to

address driver’s health and safety.

LICENSING ISSUES

2. There should be only one kind of taxicab owner’s licence.

W, Ambassador and Standard plate holders should beconverted to one standard plate. Conversion to the

standard plate will be contingent on the existing W and

Ambassador plate holders paying a $5,000 fee. The

taxicab owner’s licence should have the following

properties:

a) Each owner’s licence must be in the name of a

licensed taxicab driver,

b) A licence owner may employ an additional driver

to drive the owner’s taxicab; a second driver may

be hired in the event of sickness or injury,

c) Licence owners may not employ agents or any

other people except the additional driver,

d) By-laws describing taxicab licences are amended

so that the licences become property that banks

and other agencies are willing to finance.

3. An individual may not own more than one taxicab

owner’s licence.

4. A taxicab owner’s licence shall be transferable whether

or not it is attached to a vehicle.



5. A plate can only be sold to those on the waiting list that

have been licensed and driving a taxicab in the City of

Toronto full-time for three years.

6. Corporations that presently own taxicab licences havetwo years within which to transfer their licences to

individuals who meet all of the above requirements. If

any corporate owners fail to meet these requirements

within two years, their taxicab licences should be

revoked by the City and reissued to drivers on the list.

7. Present owners of more than one taxicab licence have

two years within which to transfer all but one of their

licences to individuals who meet all of the above

requirements. If any multi-plate owners fail to meet

these requirements within two years, their taxicab

licences should be revoked by the City and reissued to

drivers on the list.

8. Present individual owners of taxicab licences are

exempted from the requirements listed in 2 a) and b)

above.

AGENTS AND SUBLEASING

9. Abolish the use of agents and sub-leasing.

SHIFT AND LEASE RATES

10. Lower shift, lease, and brokerage rates through a

stakeholder negotiated industry standard.



TAXI STANDS

11. Increase the number of taxi stands in the city, including

establishing a taxi stand at each subway station. The City

should work in partnership with frontline taxi drivers toconduct an annual review of taxi stand issues in Toronto.

RELATIONSHIP BETWEEN DRIVERS, MLS & POLICE

12. The Municipal Licensing and Standards Division (MLS)

should establish a formal working relationship with taxi

drivers and police to address issues related to driver and

customer safety, aggressive ticketing and explore ways

to jointly improve the taxi industry in Toronto.

BENEFIT FUND

13. The Municipal Licensing and Standards Division (MLS)

should establish a working group to develop and

recommend a plan to create a benefit fund to provide

health and dental insurance and retirement protection

for drivers and their families. This working group will

include representatives from the iTaxiworkers,

brokerages and other industry stakeholders. At a

minimum, shift drivers will be automatically enrolled and

owner-operators will have the opportunity to buy-in to

the plan. Start-up costs for the fund will be derived from

the $5,000 fee collected from plate conversions

TAXIS AS PUBLIC TRANSIT

14. The City of Toronto must recognize that taxicabs are an

important component of public transportation. The role

of taxicabs must be included when the structure of

public transportation is being considered.





iTAXIWORKERS’ PROPOSAL

HEALTH & SAFETY………………………………………………………………………………………………………………………………………..

HEALTH & SAFETY

1. Establish a permanent task force including taxi drivers, police, industry stakeholders

and health practitioners to address driver’s health and safety.

BACKGROUND

Taxi drivers face the daily reality that their profession is inherently dangerous.

Last year the Ontario government implemented Bill 168 – a series of amendments to the

Occupational Health and Safety Act designed to prevent workplace violence and

workplace harassment. Employers are required to assess the risks of violence in their

particular workplaces and develop policies around them. The Ministry of Labour has

produced guidelines to assist employers in assessing these risks. These guidelines

included a list of nine risk factors. These risk factors, in the eyes of the Province, were

seen as being particularly conducive to a workplace where violence or harassment was a

threat to workers. The risk factors are as follows:

1. Direct contact with clients2. Handling cash

3. Working with unstable or volatile clients

4. Working alone or in small numbers

5. Working in a community-based setting

6. Mobile workplace

7. Working in high-crime areas

8. Securing/protecting valuable goods

9. Transporting people and/or goods

With the exception of number eight, taxi drivers in Toronto are subject to all of these risk

factors. Toronto taxi drivers face 89% of the provincial risk factors for violence and

harassment in the workplace.



Recently, Statistics Canada reported that, of all workers in Canada, taxi drivers and police

officers face the highest occupational risk of homicide.4

The homicide rate of taxi drivers

was found to be twice that of police officers and taxi drivers are most likely to be

murdered while on the job.5

Similar results have been found in the United States,

suggesting that, given the nature of the work, taxi driving is an inherently dangerous job.6

It is therefore hardly surprising that Toronto taxi drivers have faced a long history of

violence, assault and even homicide in this line of work. Assaults on taxi drivers in

Toronto are all too common. Given the high percentage of visible minorities working in

the industry, racist remarks or attacks are also widespread.

The following news stories have appeared in the past two years:

• “Taxi driver standing outside his disabled cab is killed after being rammed by SUV” – Toronto Star – February 15, 2010

• “Two men wanted after taxi driver stabbing” – 680 News – February 20, 2010

• “Three suspects sought after cab driver robbed” – Toronto Star – March 17, 2010

• “Cab driver beaten, robbed of cash, phone” – Toronto Star – May 21, 2010

• “Cab driver robbed of cash in Scarborough” – Toronto Star – May 24, 2010

• “Taxi driver swarmed and robbed” – Toronto Star – July 22, 2010

• “Taxi driver robbed, locked in trunk” – Toronto Star – August 13, 2010

• “Beck taxi driver ambushed and robbed” – Toronto Observer – October 27, 2010

• “Men wanted for taxi robbery” – Toronto Sun – December 13, 2010

• “’Drive, drive’, cabbie ordered; Taxi driver tells of wild ride with alleged baby

abductor and 1-month-old” – Toronto Star – January 3, 2011

• “Toronto cab driver stabbed repeatedly in face” – CBC News – February 15, 2011

• “Stabbed cabbie gouged by rules; Driver can’t earn living with lower-tier licence” – Toronto Star – March 5, 2011

• “Taxi driver fled after passenger pulled out gun; Cabbie tells murder trial about

two-hour ride through Toronto” – Toronto Star – April 6, 2011

4Sara Beattie and Adam Cotter, "Homicide in Canada, 2009" Juristat , Fall 2010, 85-002X, Statistics Canada.

5Sara Dunn, "Police officers murdered in the line of duty, 1961 to 2009" Juristat , Fall 2010, 85-002X,

Statistics Canada.

6http://www.bls.gov/iif/oshwc/cfar0020.pdf



• “Man 22, charged after cab driver choked, robbed” – Inside Toronto – August 16, 2011

• “Toronto cabbie robbed in carjacking before crash” – CBC News – September 26, 2011

• “Taxi driver crashes after fare dispute” – CP24 – October 12, 2011

This long list of headlines demonstrates that taxi drivers face serious risks while working in

Toronto. Of course, there are many other assaults and crimes that go unreported, and

many other more minor, but still significant incidents, that do not make headlines.

Not all assaults on Toronto taxi drivers are physical. In a recent study published in the

Canadian Journal of Public Health, Toronto taxi drivers surveyed reported having

experienced verbal abuse while on the job.7

The results from the iTaxiworkers’ survey showed similar findings:

• 70% of drivers reported having felt in physical danger while working.

• 85% of drivers reported being verbally assaulted while working.

• 51% of drivers reported being physically assaulted or attacked while working.

Compounding the problems inherent in an already dangerous job, the high level of

economic uncertainty among drivers is a strong incentive to accept risky situations.8

Drivers are more likely to accept a passenger they feel wary about if they are desperate

for the fare. If making ends meet was not such a constant struggle for these drivers, theywould be more likely to avoid potentially dangerous situations.

Similarly, given their low wages, drivers are pressured to work extremely long hours to

make ends meet. This of course increases the risk of accident to the driver, the passenger

and the public. The long hours of driving and frequent bending and twisting, also leads to

ergonomic pressures and persistent back pain for many drivers.9

Health concerns about

7Marcia E. Facey, “The health effects of taxi driving: the case of visible minority drivers in Toronto,”

Canadian Journal of Public Health (2003) Jul-Aug; 94(4):254-7.

8Ibid.

9Jiu-Chiuan Chen, Wen-Ruey Chang, Wushou Chang and David Christiani, "Occupational factors associated

with low back pain in urban taxi drivers," Occupational Medicine (2005) 55: 535–540.



sitting for extended hours in traffic in Toronto have also been noted.10

Mealtimes are

often erratic and unhealthy. Long shifts away from home also put significant strain on the

drivers’ social and family lives, in many cases, leaving them unable to enjoy social

situations.11

A common principle in labour markets is to compensate workers performing dangerous

work with higher levels of pay – i.e. “danger pay.” However, as discussed earlier, Toronto

taxi drivers do not even earn minimum wage when their long hours are factored in.

Clearly, taxi drivers do not receive nor are they likely to benefit from danger pay.

RECOMMENDATION

Among the drivers surveyed by the iTaxiworkers, health and safety concerns were

identified as their top issue. Creating real solutions will only come through a permanent

task force, partnering taxi drivers, police, health practitioners and other industry experts.

In other jurisdictions, models of joint partnerships among industry stakeholders have been

successful at proactively developing effective health and safety initiatives.

The establishment of a permanent health and safety task force for Toronto taxi drivers,

and industry stakeholders, including government officials and the public, must be initiated

by the City of Toronto. The mandate of the task force should include, but not be limited

to, gathering information and data, identifying health and safety issues, assessing the risks

faced by taxi drivers, researching and reviewing existing safety initiatives and developing

new strategies to improve the health and safety of Toronto’s taxi drivers.

Funding for the health and safety task force could come from a variety of sources, and

take many different forms. One example, in Winnipeg, Manitoba, the provincial

government commissioned an extensive independent review of safety issues in the taxi

industry. The Report on the Study of Taxicab Safety Issues outlined several

recommendations to enhance safety for taxi drivers in that province. One

10Joseph Zayeda, Mourad Mikhaila, Sylvain Lorangera, Greg Kennedy & Gilles L'Espérance, “Exposure of Taxi

Drivers and Office Workers to Total and Respirable Manganese in an Urban Environment,” American

Industrial Hygiene Association Journal 57:4 (1996).

11Sara Abraham, Aparna Sundar, Dale Whitmore Toronto, “Toronto Taxi Drivers: Ambassadors of the City: A

Report on Working Conditions,” January 2008



recommendation was that a “Taxi Health, Safety, and Prevention Trust Fund” be

established with the objective of providing the necessary equipment, tools, education and

training to improve the health and safety of frontline drivers. It was suggested that this

fund would be financed by a modest levy on fares and that these monies would then be

collected and managed by the Trust Fund. Although health and safety initiatives in other jurisdictions can provide useful examples, it is essential to develop a task force that

addresses the issues specific to Toronto drivers and the taxi industry as a whole.

Overall, taxi drivers’ health and well-being should be considered alongside the

iTaxiworkers other proposals. Increasing economic well-being would give a driver more of

an incentive to avoid taking a dangerous fare in the hopes of earning more on his/her

shift. Increasing the number of taxi stands would give drivers the opportunity to take

some strain off their bodies and stretch, avoiding long-term physical issues. Thus, while

health and safety is listed as a separate issue in this submission, it should be recognized

that all of the iTaxiworkers’ proposals relate to this key topic in some way.






LICENSING ISSUES………………………………………………………………………………………………………………………………………..

LICENSING ISSUES

2. There should be only one kind of taxicab owner’s licence. W, Ambassador

and Standard plate holders should be converted to one standard plate.

Conversion to the standard plate will be contingent on the existing W and

Ambassador plate holders paying a $5,000 fee. The taxicab owner’s licence

should have the following properties:

a. Each owner’s licence must be in the name of a licensed taxicab driver,

b. A licence owner may employ an additional driver to drive the owner’s

taxicab; a second driver may be hired in the event of sickness or

injury,

c. Licence owners may not employ agents or any other people except

the additional driver,

d. By-laws describing taxicab licences are amended so that the licences

become property that banks and other agencies are willing to finance.

3. An individual may not own more than one taxicab owner’s licence.

4. A taxicab owner’s licence shall be transferable whether or not it is attached to

a vehicle.

5. A plate can only be sold to those on the waiting list that have been licensed

and driving a taxicab in the City of Toronto full-time for three years.

6. Corporations that presently own taxicab licences have two years within which

to transfer their licences to individuals who meet all of the above

requirements. If any corporate owners fail to meet these requirements

within two years, their taxicab licences should be revoked by the City and

reissued to drivers on the list.



7. Present owners of more than one taxicab licence have two years within which

to transfer all but one of their licences to individuals who meet all of the

above requirements. If any multi-plate owners fail to meet these

requirements within two years, their taxicab licences should be revoked by

the City and reissued to drivers on the list.

8. Present individual owners of taxicab licences are exempted from the

requirements listed in 2 a) and b) above

BACKGROUND

The City of Toronto currently administers two broad classifications of taxicab owner’s

licences (plates): “Standard” and “Ambassador.” Originally, the City only issued Standard

plates. Following the 1998 Task Force, the City introduced the new Ambassador plate anddiscontinued the issuance of Standard plates. Currently, there are 3,451 Standard, 1,315

Ambassador and 85 active W plates in the city.

The plates have very different rules and properties.

StandardAmbassador

(Includes W Plates)

Transferable Non-transferable

Not tied to a single driver Tied to a single driver

Can be owned by absentee ownerCan only be held by

person driving the taxi

Very high market value No market value

Can hire many drivers Cannot hire any drivers*

“Lessee” business model “Owner-operator” business model

* Does not apply to W plates.

The iTaxiworkers’ set of proposals on licensing seeks to create a single owner’s licence

city-wide that is essentially a hybrid of these two types of plates. We have identified the

strengths and weaknesses of each type of licence. Our proposed licence capitalizes on the

strengths of each existing licence, while minimizing their weaknesses.



THE STANDARD SYSTEM

WHAT IS WRONG WITH THE STANDARD SYSTEM?

The problems with the Standard system stem from the basic fact that a standard plate is asell-able and marketable commodity that does not have to be owned by the driver of the

taxi. Given the restricted number of plates in the city, and the ever-expanding market of

customers and drivers, the plates continuously appreciate in value. According to the MLS,

the average market value of a standard plate rose from $133,750 in 2008 to $210,126 in

2011 – that’s an appreciation of over 57% in just three years. This puts plate ownership

beyond the financial reach of most drivers, and encourages an ownership model

characterized by absentee/multi-plate owners and asset-less drivers.

The City of Toronto first allowed Standard plates to be sold on the open market in 1963.

This essentially made the licence a “capital asset, with value created by a supply

controlled by the Commission.”12

As the 1998 Task Force reported, the value of plates has

been rising steadily over previous decades. The Task Force found that the return-on-

investment from the plates averaged approximately 12.6% per year: an incredibly

lucrative investment for plate owners. Not surprisingly, the 1998 Task Force noted a

“widespread agreement that absentee owners and passive investors are often an

unnecessary and detrimental link in the chain.”

The Standard system has key drawbacks:

• As the licences are incredibly expensive to buy, and only increase in price, there is

an ever-diminishing chance for drivers to purchase a licence and the phenomenon

of absentee owners will only grow.

• As the cab drivers are very rarely the owners of the cab, there is less incentive for

them to provide top-notch customer service.

• The money that ultimately funds the substantial return-on-investment forabsentee owners, passive investors and agents must come out of the pockets of

taxi drivers and their passengers. Having this extra level of middlemen who must

be compensated from a taxi ride results in less income for the drivers.

12 Sara Abraham, Aparna Sundar, Dale Whitmore Toronto, “Toronto Taxi Drivers: Ambassadors of the City:

A Report on Working Conditions,” January 2008



Data for these graphs derived from wage information from Sara Abraham, Aparna Sundar, Dale Whitmore,

“Toronto Taxi Drivers: Ambassadors of the City: A Report on Working Conditions,” January 2008

These graphs demonstrate how the owner-operator model of the Ambassador plate

provides more income for the driver. In the Standard system, with an absentee plate

owner, 23% of the fare goes to the plate owner and agent (if applicable). In an industry

where profit margins are already razor thin for drivers, this extra cost hurts drivers more.

Standard - Where Each $ of Fare Goes

CAR &

INSURANCE

COSTS, $0.27

GAS, $0.21

PLATE LEASE FEE,

$0.23

DRIVER

INCOME, $0.21 TO BROKER,

$0.09

Ambassador - Where Each $ of Fare Goes

CAR &

INSURANCE

COSTS, $0.28

GAS, $0.22

DRIVER

INCOME, $0.41

TO BROKER,

$0.09



It forces them to rush for more fares, take more risks and to sacrifice customer service –

just to pay overhead and hopefully make some income.

The owner-operator model does not increase costs for customers. It merely assures that a

significant portion of their fare will remain with the driver, instead of being used to fundwhat has been an incredibly lucrative investment for many absentee investors who do not

participate in the difficult day-to-day work of driving a taxi in Toronto.

The ownership model created by the Standard system does not serve the drivers, nor does

it serve the public.

WHAT ARE THE ADVANTAGES OF THE STANDARD SYSTEM?

The Standard system does have certain advantages. Drivers who lease a plate are

permitted to hire second drivers, called the “shift driver.” The shift driver pays a fee to

the lessee, which helps to cover the overall costs of operating the taxi. A 2008 study

found that shift drivers pay an average of $1,882 per month to the driver leasing the plate.

While there are higher insurance premiums associated with two taxi drivers on one car,

the study found that lessees with a second driver still earned more than twice that of

lessees without a second driver.

In an industry where profit margins are so thin, opportunities to share costs among drivers

should be preserved and encouraged. This will result in higher levels of earnings for

drivers without an increase in cost to the public, ultimately resulting in higher levels of

customer service.

For the few Standard plate owners who actually drive their own taxis, the appreciating

value of the plate provides an important element so often absent among this workforce:

retirement security. These drivers understand that their ownership of a plate, that will

continue to rise in value, will guarantee them a certain amount of income in retirement if

they sell their plate. The fact that the person driving the taxi benefits from this eventualreturn-on-investment is much different than when an absentee owner benefits by

cashing-out. Knowing the plate can eventually be sold provides these owner-operators

with a measure of security that most drivers lack. This security would be extremely

important in making taxi work “good work.”



CONCLUSIONS REGARDING THE STANDARD SYSTEM

The iTaxiworkers therefore make three broad conclusions about the Standard system:

• The absentee ownership model does not serve the drivers, the customers, or theoverall industry. The only people served by this model are the absentee owners

themselves, who do not perform the difficult work of driving a taxi in Toronto. The

taxi industry and the city overall would benefit if this element of the licensing

system were grandfathered out.

• Standard plate owners who drive their own taxis have a measurement of

retirement security that other drivers do not. These drivers feel less economic

pressure and are therefore more likely to provide high levels of customer service.

• The cost-sharing advantages of allowing second drivers within the Standard systemresults in higher incomes for drivers, which results in better customer service.

Cost-sharing advantages should be preserved in a new system.

These conclusions are integrated into the iTaxiworkers’ hybrid proposal on licensing.

THE AMBASSADOR SYSTEM

WHAT IS WRONG WITH THE AMBASSADOR SYSTEM?

At 8 p.m. on February 14, 2011, Toronto taxi driver Khalil Talke was stabbed several times

in the head, throat and mouth by his passenger. The taxi was on a dark stretch of a quiet

street when Talke was attacked. The assailant escaped, and Talke faced a long period of

recovery. While he convalesced, he was forced to return his Ambassador plate to the City,

as per municipal by-laws. These by-laws prevent Ambassadors from hiring second drivers.

The Toronto Star reported that Talke felt like he had been attacked twice, “once by the

attacker and now by the City.”13

Ambassador drivers, as owner-operators, exemplify the definition of “self-employed”

workers. Traditionally, our conception of a self-employed individual was the image of the

successful entrepreneur. This entrepreneur took risks by starting a business and likely

endured some difficult times in the beginning. However, through dedication and hard

13“Stabbed cabbie loses his income because of city rules,” Toronto Star , March 4, 2011.



work, the business expanded, the entrepreneur hired employees and soon began enjoying

substantial financial returns.

In Canada, being self-employed means that one is excluded from most of the legislative

and common law protections available to workers, as these protections are only availableto traditional “employees” who work for someone else. Self-employed workers,

therefore, do not have the automatic protection of laws on employment standards,

employment insurance, health and safety, workers compensation, and labour relations.

For access to the Canadian Pension Plan (CPP) taxi drivers have to contribute twice what

employed workers do to receive the same benefits upon retirement.

However, losing these protections is not so serious for financially successful

entrepreneurs. The wealthy self-employed individual described above would have less

need for this basic safety net of rights, which means so much for workers further down

the economic ladder.

However, the trade-off is not so easily made for all self-employed individuals. As labour

law scholar Judy Fudge writes, “the self-employed do not make up a homogenous

category; instead, they range from the high income professional who employs others to

the child-care provider who works out of her home and employs no one.”14

Researchers

have recently demonstrated that the traditional ideal of self-employment is slowly dying

in favour of a more precarious version of self-employment. Each year, fewer self-

employed individuals are actually hiring employees, while more self-employed individuals

are truly working on their own. The new self-employed individual tends to be older, work

longer, have less access to benefits and earns significantly less than the traditional

entrepreneur.15

Toronto taxi drivers under the Ambassador system fall into this precarious worker

category. They are not covered by the protective legislation enacted for most workers,

yet their work is very low-paying. In short, drivers desperately require the safety net that

is not extended to them. The Ambassador system forces drivers into an extremelyprecarious form of self-employment in an industry with significant barriers to economic

security.

14Judy Fudge, “Labour Protection for Self-Employed Workers,” Just Labour 3 (2003): 43.

15Judy Fudge, Eric Tucker and Leah Vosko, The Legal Concept of Employment: Marginalizing Workers.

Report for the Law Commission of Canada (Ottawa: Law Commission of Canada, 2002): 27.



However, unlike other self-employed individuals, Ambassador drivers are disadvantaged

in another important way. Not only are they denied important legislative protections,

these drivers are also prohibited by the City from partnering, leasing or temporarily

transferring their licences, even if they are unable to work. The non-transferable

Ambassador licence is tied exclusively to the owner who can be the only driver. Thisprevents the owner-operators from expanding their businesses or to partner with other

drivers to share costs. It also prevents the owner from having a replacement driver during

a time of illness or disability thereby forcing drivers to work while ill or disabled. When

surveyed, over 50% of drivers reported having worked while being seriously sick or

injured. Additionally, as Ambassador licences are not-transferable, they accrue no value

throughout the owner’s career, and therefore provide no measure of retirement security.

Taxi drivers are uniquely disadvantaged by the City in this way. The City, of course,

regulates licences for many businesses. It provides licences for stationary businesses such

as automobile body repair shops, butcher shops, drug stores, restaurants, etc. It also

provides licences for mobile businesses such as catering trucks and food vendors.

However, these licences are made available to a person, a partnership, or a corporation.

Their proprietors are then able to hire employees or partners or investors to share in the

costs, risks and working time of running the business. If successful, they are able to climb

out of precarious self-employment and become entrepreneurs, in the ideal sense of the

word.

These options for betterment are not available to Toronto Ambassador taxi drivers. To

begin, they work in an industry defined by its extremely thin profit margins. As self-

employed workers, they are then stripped of the legislative and common law protections

that other workers enjoy. Then, as Toronto Ambassadors they are prevented from

partnering to share costs, transferring their licences while unable to work and selling their

business after it has grown in value.

A recent case at the Ontario Human Rights Tribunal also challenges the fairness of the

Ambassador system on grounds of systemic discrimination, as a disproportionate numberof Ambassador drivers are visible minorities. The Tribunal’s ruling in the case has yet to be

released.

In summary, the perils of self-employment are partnered with municipal restrictions to

make this already difficult work extremely and unacceptably precarious, in a way that

many believe is systemically discriminatory.



ECONOMIC ASPECTS

As stated above, losing the floor of legislative and common law protections would not be

so detrimental to taxi drivers if they managed to earn enough money to offset these

losses. However, Ambassador drivers are not anywhere close to achieving this offset.Their earnings in fact come in below the legislated standards in Ontario.

Ambassador taxi drivers face substantial costs. First, they must own their own car which

cannot be more than 7 years old. Along with the cost of car payments are maintenance,

depreciation, insurance and gas – all of which are costly due to the nature of the work and

the kilometres traveled. The cost of gas and insurance has also been rising over recent

years, and is likely to continue becoming more expensive in the future. The taxi drivers

must then pay brokerage fees which allow them to receive dispatch calls. On top of this,

taxi drivers must pay their licensing fees to the City, which are substantial.

It is important to note that all of these costs, with the exception of gas, are fixed. These

costs will continue to add up, whether or not the driver is able to drive.

WHAT WORKS IN THE AMBASSADOR SYSTEM?

The principal rationale for moving to the owner-operator Ambassador model offered by

the 1998 Task Force was to provide a higher level of customer service, while providing an

avenue to ownership for drivers. The basic idea was that owner-operators will take

greater pride in their business, since they are the principal proprietor.

The iTaxiworkers agrees with this assertion and believes strongly that Ambassador and

W-plate drivers feel a pride of ownership.

The 1998 Task Force found that “owner-operated taxicabs are maintained at a higher

quality standard than fleet vehicles.” Vehicle inspection failure rates were much lower for

owner-operator taxis. It also concluded that “statistics show that owner-drivers, with

pride of ownership typically provide the best level of customer service.”

Since the introduction of the Ambassador program in 1998, the number of taxi complaints

received by MLS has fallen significantly. This is demonstrable proof that the owner-

operator model has been providing better customer service in Toronto’s taxi industry.



This has, in turn, pulled the level of service throughout the industry up, by setting a higher

bar for customer service in general.

# of Taxi Complaints Received by MLS

600

800

1000

1200

1400

1600

1800

2000

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

CONCLUSIONS REGARDING THE AMBASSADOR SYSTEM

The iTaxiworkers therefore make three broad conclusions about the Ambassador system:

• Ambassador licences, as they are currently regulated, force drivers to remain in a

very precarious kind of self employment where wages are low, legal and statutory

protections are minimal and the opportunities for growth or future profit are

minimal.

• The two main culprits of this precarious self-employment are:

o The inability of Ambassador drivers to hire a second driver to share costs

o The inability of Ambassador drivers to sell their plate upon retirement.

• The pride of ownership associated with the owner-operator model, however,

translates into better customer service.

These conclusions are integrated into the iTaxiworkers’ hybrid proposal on licensing.



CONCLUSIONS ABOUT THE LICENCING SYSTEM

The conclusions reached by the iTaxiworkers are summarized in the following chart.

Standard Ambassador

Strengths

Second drivers allow cost

sharing.

Some plates owned by drivers,

which allows them to work

towards value of asset used in

retirement.

Pride of ownership leads to

better customer service.

Weaknesses

Many plates property of

absentee owners.

Many plates owned by owners

with 2+ plates.

20% of fare money can go to

absentee owners, leaving lessfor drivers.

Forced to remain in

precarious self-employment

with little chance of

improvement.

Cannot hire second driver.

Plates have no value.

Creation of plates has led to

a two-tier system in the City.



RECOMMENDATION

The iTaxiworkers’ proposal on licensing has carefully sought to combine the strengths of

both types of licence, while avoiding the weaknesses. Each strength has been preserved

in our proposed system, while each weakness has been eliminated.

The resulting features of our proposed licensing system are as follows:

Characteristics of iTaxiworkers’

Proposed SystemAdvantage

One type of licence across

the entire industry Removal of current two-tier system

Owner-operator model Pride of ownership leads

to better customer service

Licences can only be

owned by drivers

Eliminates absentee owners, ensures

that all fare money stays within

the working taxi industry.

Allows drivers to work towards building the

value of their business, as self-employed

workers ideally should, which provides ameasure of retirement security.

An individual may not own

more than one licence

Eliminates multi-plate owners who do not

drive taxis and who take up to 20% of fare

money that would otherwise go to drivers.

Licences can only be sold

to drivers on the list

Ensures that individual drivers who have

many years of seniority will be rewarded

with the opportunity of plate

ownership in an equitable fashion.

Second driver permitted Allows cost sharing, will raise

owner and driver profits.



THE MECHANICS OF CONVERSION

The iTaxiworkers recognize that this proposal will result in a substantially different kind of

taxi industry in Toronto. To manage this change, our proposal provides for a two-year

transition period from the existing licensing structure to the new structure. We proposethat the transition not be managed by the City – instead, a market-based approach would

see owners and drivers making their own decisions on how best to protect their own

interests to comply with the new guidelines.

Creating a new kind of plate and ownership rules will clearly impact the value and

operating reality of existing plate ownership and lease structures. The City will certainly

encounter resistance from various groups who prefer the existing structure.

The iTaxiworkers is asking the City to recognize that resistance from interest groups is not

a reason to forego the changes in licensing that are necessary for a better taxi industry in

Toronto.

We anticipate that any resistance to changes in the licensing of taxis is likely to centre on

the idea of property rights. Absentee and multi-plate owners are likely to argue that the

City does not have the right to take away what is rightfully theirs.

The alternative view – supported by iTaxiworkers – is that part of the deal these plate

owners accepted when purchasing their plates is that the City ultimately decides what

rules will govern the taxi industry. The City’s view, of course, is likely to change over time.

This is simply part of the gamble of owning an asset whose value is largely determined by

ever-changing municipal policy. The absentee and multi-plate owners have indeed

profited very well from their investments, as the City itself recognized in the 1998 Task

Force. This does not mean that such profits and returns are guaranteed ad infinitum, or

that the betterment of the city’s taxi industry should be held back in the interests of

continuing to appease a small number of absentee owners and passive investors.



We also anticipate the criticism that Ambassador drivers are seeking conversion solely for

financial reasons: when converted, their plates, which are currently worth nothing, will

suddenly acquire a substantial value. It is also suggested that these Ambassador drivers

will sell their plates to make a one-time windfall. We thoroughly reject these suggestions

for the following reasons:

• Ambassador drivers have unanimously indicated in our survey that they would not

seek to sell their plates. Over 92% of drivers stated that they would not plan to sell

their plate immediately if it is converted.

• Many Ambassador drivers were on the City’s waiting list for newly issued Standard

plates in 1998. In many cases, these drivers had been waiting on this list for years

to have an opportunity to purchase a Standard plate for $5,000. However, after

the City’s decision to not issue more Standard plates, these years of waiting

became worthless for these drivers. Many feel they were given a false promise by

the City and forced to wait many working years for nothing. In these cases,

Ambassador drivers do feel that the City should make good on its past word and

provide them with the opportunity to invest in a plate that can accrue value.

• Ambassador drivers have strongly indicated a willingness to pay some amount for

the conversion. Of drivers surveyed, 90% would be willing to pay for conversion.

Most would be prepared to pay less than $5,000, but 27% of drivers were still

prepared to pay more.

• Ambassador drivers resent the argument that they would not deserve the new

plate value if their existing plates were converted. They feel that, having been so

disadvantaged by the system for 14 years, they are entitled to some kind of

benefit.

This willingness to pay is why the iTaxiworkers has proposed a $5,000 fee for conversion

of existing Ambassador licences. As will be discussed later, this substantial asset base will

be used directly to benefit the working drivers under the new system.

Another concern surrounding the conversion of Ambassador plates is that enabling their

owners to employ a second driver might put more taxis on the road and lead to an

oversupply of cabs in Toronto. In fact, many current Ambassador plate owners would not

choose to employ a second driver.



When the iTaxiworkers asked drivers, “If your Ambassador or W Plate is converted to a

Standard Plate this year, do you plan on hiring a shift driver?” The responses were: 46%

yes, 30% no, and 24% maybe.

Currently, there are 3,451 Standard and 1,315 active Ambassador plates in Toronto. If Standard plates are used for two shifts a day and Ambassador plates for a single shift, the

current supply of taxi shifts is 8,217. If the percentage of Ambassador plate owners who

responded “yes” and half of those who responded “maybe” added a shift driver, 763

additional taxi shifts would be driven (i.e. 58% of 1,315). In other words, supply would

increase by only 9%.

However, this estimate is excessive because not all of the shift drivers hired by current

Ambassador plate owners would be new entrants to the industry. Some would be drivers

who currently drive taxis with Standard plates. More demand for shift drivers would

create better job opportunities for them, drawing some new workers into the industry but

also drawing some existing drivers away from agents and Standard plate owners.

Another important factor is that hiring a second driver would allow current Ambassador

plate owners to drive somewhat less themselves. The iTaxiworkers’ survey found 75% of

respondents worked shifts longer than 10 hours a day and 81% doing so six or seven days

a week.

Many Ambassador drivers would undoubtedly choose to spend less time at the wheel if

they could supplement their earnings by employing a second driver. Therefore, the time

worked by additional shift drivers would not simply be added to the time now worked by

Ambassador drivers.

Given all of these factors, enabling current Ambassador plate owners to employ a second

driver would only modestly increase the total supply of taxi service. Any increase would be

offset in the context of rising demand for taxi service, as Toronto’s population grows and

ages.

Taxi reform in 1998 ushered in a new era for drivers and the public. To address the issues

of poor service and taxi driver exploitation, the owner-operator model was introduced via

the Ambassador and W plates and has led to real improvements for drivers. However, the

1998 Task Force reform stopped short of addressing the problems associated with the

Standard plate. Fourteen years later we have a two-tier system that perpetuates



inequality. One licence that provides equality for all owners and advances the single

owner-operator model will significantly improve the taxi industry for the public, drivers,

brokers and City regulators. An industry with one plate per owner and one additional

driver is fair, efficient, just and the cornerstone of the proposals contained in this

submission.




AGENTS & SUB-LEASING……………………………………………………………………………………………………………………………………

AGENTS & SUB-LEASING

9. Abolish the use of agents and sub-leasing

BACKGROUND

Agents were first introduced to assist elderly plate owners and industry widows in the

management of their taxicabs. However, the role of agents has increasingly evolved to

include representing absentee owners and passive investors.

Some standard plate owners view their ownership of a plate as a lucrative investment

opportunity. Individuals and/or corporations that own multiple plates who elect not to

operate as the driver of each of the vehicles associated with these plates, contracts to

either a single lessee, who will operate the taxi and pay a monthly fee directly to the plate

owner; or to an agent, who pays for the use of the plate and then sub-leases the plates to

individual drivers on either a daily, weekly or monthly basis.

WHO ARE AGENTS? WHAT DO AGENTS DO?

Designated agents are the middlemen between many plate owners and taxi drivers. City

by-law 545-144 permits the owner of a standard plate to designate an individual to

manage the plate for them. Individual agents must be licensed as a driver, owner, or

taxicab broker. Agents do the legwork to find drivers to lease the plate, arrange those

leases and monitor them. A close parallel in real estate would be the relationship

between when an apartment is managed and rented by a property manager on behalf of a

landlord, who may never interact directly with their tenant.



The fees that an agent charges depends on the type of lease arrangement. According to

the 1998 Task Force, there are three general types of lease arrangements:

1. Shift (or Cash-in)

a. Agent provides the driver with the taxicab and equipment on a shift basis.

b. Current rates are estimated to be $85 - $100 per day

2. Plate lease

a. Agent provides the plate. Drivers provide the taxicab and pays insurance

and brokerage fees.

b. Current rates are estimated to be $1600 - $2000 per month

3. Package

a. Agent provides the plate, insurance, and brokerage fees. Driver provides

the taxicab.

b. Current rates are estimated to be $3000 - $3500 per month

HOW MANY AGENTS ARE THERE?

As of January 1, 2011, there were 470 agents operating in the Toronto taxi industry.16

These agents represent 2,239 of Toronto’s taxi plates. Each agent controls between 1 and

111 plates, with an average of 4.8 plates per agent. As shown in the table below, a

minority of agents (11%) controls a majority (66%) of the share of agent-controlled plates.

# Plates

Controlled# of Agents

% of

Agents

Total

Plates

Controlled

% of Total

Agent

Plates

Controlled

1 plate 288 61% 288 13%

2-5 plates 109 21% 313 14%

6-9 plates 21 7% 161 7%

10+ plates 52 11% 1477 66%

16All data provided by the Toronto Municipal Licensing and Standards Division (MLS).



Despite the introduction of the Ambassador system in 1998, the number of agents in the

industry has grown significantly. In 1997, there were 401 agents, while today there are

470 agents in the industry, an increase of 17%. The concentration ratios of plate

ownership have remained relatively stable over this period.

# of Agents in Toronto Taxi Industry

350

370

390

410

430

450

470

490

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

The increase in the number of agents and the unrestricted system of sub-leasing in

Toronto effectively drives up costs for frontline drivers. This forces them to work longer

hours to cover the costs of leasing a plate that in turn generates a profit for agents,

absentee owners, and passive investors.

For example, a single plate that is leased by an agent, brokerage or garage from an owner

and then subsequently sub-leased (rented) out, often to two drivers per 24 hour day

driving under the single taxi plate, can bring in enormous profits for the owner and agent.According to the MLS, the average monthly cost to lease a plate directly from an owner is

$1,212.19 per month or $14,546.28 per year. For agents, who control on average 4.8

plates each, at a lease rate of $1,243.84 per month, and who often lease plates to 2

drivers per 24 hour period, can earn an income of over $143,000 per year.



RECOMMENDATION

The iTaxiworkers assert that the use of agents and sub-leasing is detrimental to taxi

drivers who must pay brokers, agents and owners in order to work. The added

management layer of the agent results in additional fees that are passed onto the driver,

further reducing their incomes.

Sub-leasing is a widespread problem in Toronto. It negatively impacts the entire industry

by eroding service and safety standards, prevents drivers from earning a decent living to

support their families and creates an environment where an increasing number of agents

are controlling more and more plates which enable them to derive profits and monopolize

the taxi industry at the expense of frontline taxi drivers.

As absentee owners, passive investors and agents sub-lease their plates to taxi drivers,

there is little incentive for owners to ensure a high level of safety and service as the plate

owners and agents will receive their lease fees irrespective of the challenges that the taxi

drivers face on a daily basis. The 1998 Task Force concluded, and the iTaxiworkers agree,

that “with plate leasing and the creation of the middleman or designated agent, a growing

number of plate owners have a decreased incentive to provide a high quality or type of

service since it has no direct financial impact.”

As costs for frontline drivers are pushed upwards by the practice of sub-leasing, drivers

are forced to work longer hours and take more risks on the road to earn enough money topay their agent and lease fees. The money that drivers earn serving the public goes to

support the agents, absentee owners and passive investors, leaving drivers with little to

support their families.

Sub-leasing has created an environment where a small number of multi-plate owners and

agents make tremendous profits at the expense of frontline taxi drivers and the public.

The use of agents and the practice of sub-leasing should be abolished.




SHIFT & LEASE RATES………………………………………………………………………………………………………………………………………..

SHIFT & LEASE RATES

10. Lower shift, lease and brokerage rates through a stakeholder negotiated industry

standard.

BACKGROUND

It is well known that taxi drivers face high fixed expenses which significantly impact their

economic status. Specifically, drivers are subject to high lease, shift and brokerage fees

without any protection or recourse from arbitrary and unilateral increases. In the current

regulatory framework, standard plate owners enjoy a guaranteed income from the lease

of their plates and brokerages receive a guaranteed profit from dispatch fees. In contrast,

drivers have no such guarantee. These rates are open to manipulation and drivers are

vulnerable to exploitation. Unrestricted fees are often responsible for the low incomes of

frontline taxi drivers.

In the 1998 Task Force, it was acknowledged that the current structure of the industry

impeded the ability of many drivers to earn a living wage. Recognizing that unregulated

lease rates needed to be addressed, the 1998 Task Force recommended that the City

investigate the possibility of setting a limit on lease rates. It was determined that setting

lease and other fee caps was outside the City’s legal jurisdiction and that provincial action

was required to allow the City of Toronto to institute fee caps. To date, it is unclear if any

action has been taken between the City and the Province regarding this matter.

Unlike Toronto, several comparable world class cities have been effective at protecting

drivers from unrestricted fee increases and exploitation by absentee owners, passive

investors and agents. In municipalities such as Chicago, Boston, New York, Seattle andPhiladelphia, city government has been successful in implementing lease, shift and

brokerage fee caps to ensure that lessees and shift drivers are able to make a decent living

to support their families.



RECOMMENDATION

To stabilize the industry and to ensure that drivers have an effective means to negotiate

fair rates, the iTaxiworkers propose the establishment of a permanent committee in which

a majority of industry stakeholders will participate to reach fair and flexible lease, shiftand brokerage rates.

• This committee will be established by a municipal by-law outlining its

responsibilities and authority.

• Stakeholders representing at least 60% of plate owners will work cooperatively

with drivers to negotiate a fair fee scale that includes lease, shift and brokerage

fees.

• The City will designate the iTaxiworkers Association as the official representative of

lease and shift drivers.

• This committee will have 6 months to set lease, shift and brokerage rates.

• If no agreement is made within 6 months, it will be resolved through binding

arbitration.

• Once negotiated, these rates will apply across the industry.

• Rates will remain the same for 2 years and then rise at the rate of inflation.

• These rates are maximums. Drivers can be charged less but not more.

• Rates will be all inclusive and no additional charges, fees, deposits, service fees etc.

can be added.




TAXI STANDS………………………………………………………………………………………………………………………………………..

TAXI STANDS

11. Increase the number of taxi stands in the city, including establishing a taxi stand at

each subway station. The City should work in partnership with frontline taxi drivers

to conduct an annual review of taxi stand issues in Toronto.

BACKGROUND

The iTaxiworkers submit that there are not sufficient taxi stands in the city and that more

taxi stands would benefit both drivers and customers.

As per By-law 545-147 (D), taxi drivers are not permitted to park on any road while waiting

for a fare. This is only permitted at designated taxi stands. There are strict rules around

overcrowding of taxi stands, and each stand is marked with how many taxis it permits.

There are currently only 146 designated taxi stands in the city that can accommodate a

total of 452 taxis.

With over 4,700 licensed taxis on the road and 10,000 licensed drivers in Toronto, it is

clear that there is an inadequate supply of taxi stands in the city. This negatively impacts

taxi drivers, their customers, and the public.

As taxi drivers are not permitted to wait anywhere other than taxi stands for fares, when

the stands are at capacity, drivers are forced to continually cruise for a fare.

For drivers, such fare-less driving is incredibly expensive, as it costs them in both gas and

vehicle wear-and-tear. This places additional strain on their already stretched earnings.

As gas prices rise, the true cost of this inadequate supply of taxi stands increasinglyimpacts drivers, as fares remain the same, forcing driver’s incomes even lower. In

addition, taxi stands are an important place for drivers’ physical well-being. The long

hours in a sitting position, combined with the twists and turns of interacting with

customers places serious strain on drivers’ bodies. Taxi stands allow drivers a place to get



out of their cabs and stretch, use nearby washroom facilities, and safely make phone calls

without breaking any by-laws.

For the public, the inadequate supply of taxi stands negatively impacts the quality of life

for Torontonians. First, there is the environmental impact of having thousands of carsconstantly driving that are not serving any immediate purpose. These cars needlessly

spew significant amounts of pollution into Toronto’s air. They also add to the growing

gridlock problem in the City which was recently found to have the country’s longest

commute.17

Taxi drivers seek out the busiest areas of the city, as that is where fares are

most readily available. Forcing them to continually drive around these areas without fares

only contributes to the growing traffic congestion downtown.

In other jurisdictions, municipal governments have addressed the taxi stand issue by

implementing initiatives such as the “Late Night Taxi Stand”. For example, the City of

Calgary has launched a program whereby several parking spaces are reserved for taxis

outside popular restaurants, bars and nightclubs during the peak late night hours – 10pm

to 3am - on Thursdays, Fridays and Saturdays. This is in an effort to reduce drinking and

driving and to stop inebriated individuals from running into the street to hail a taxi. This

program decreases aimless driving, improves customer access to taxis, provides a safe

place for taxi drivers to pick-up and drop-off passengers and has improved public safety.

Several other cities are establishing similar programs, including Victoria, British Columbia

and Seattle, Washington. In Victoria, the City has enhanced the program by providing

police officers to periodically “supervise” the taxi stand areas to ensure the safety of taxi

drivers and the public.

Another way to increase the number of taxi stands is to use spaces that have already been

designated for other vehicles. Fire lanes could provide spaces where drivers could park

throughout the day as long as they remained subject to the needs of the police and fire

department.

17Statistics Canada, “Commuting to work: Results of the 2010 General Social Survey,” Canadian Social

Trends, August 24, 2011, no. 11-008-X.



RECOMMENDATION

Toronto taxi drivers know which areas are lacking taxi stands, and which taxi stands are in

the greatest need of expansion. Drivers also know better than anyone where the most

non-stand pickups occur.

The iTaxiworkers propose that the City increase the number of taxi stands, including the

establishment of taxi stands at each subway station and additional taxi stands within the

borders of the old City of Toronto. Additionally, it is necessary for the City to work in

partnership with frontline taxi drivers in an annual review of taxi stands and proactively

engage drivers when the installation, relocation or removal of taxi stands is under

investigation.






RELATIONSHIP BETWEEN DRIVERS, MLS & POLICE………………………………………………………………………………………………………………………………………..

RELATIONSHIP BETWEEN DRIVERS, MLS & POLICE

12. The Municipal Licensing and Standards Division (MLS) should establish a formal

working relationship with taxi drivers and police to address issues related to driver

and customer safety, aggressive ticketing and explore ways to jointly improve the

taxi industry in Toronto.

BACKGROUND

Taxi drivers in Toronto feel strongly that they are unjustly targeted by police for violationsof the laws regarding traffic, taxi stands and pick-ups/drop-offs. According to MLS

statistics, in the last 5 years over 13,500 tickets for by-law infractions have been issued to

Toronto taxi drivers and owners. These tickets are in addition to those issued under the

Highway Traffic Act.

When surveyed, over 90% of drivers responded that “police targeting abuse” and

“traffic/parking tickets” was an “important” or “very important issue.”

A major service provided by the iTaxiworkers is paralegal representation for drivers todeal with tickets that have been issued by Toronto Police. The popularity of this service

testifies to the issues around ticketing in the city.

Paying for tickets and paralegal representation is yet another expense for drivers. As this

submission has already outlined in great detail, the income of taxi drivers is already

stretched incredibly thin. Again, the further drivers are stretched, the more customer

service will suffer.

That being said, the iTaxiworkers advocate for ticketing that is fair and necessary for

maintaining a high level of public safety on the streets of Toronto.

However, given the negative perspective of drivers around ticketing, it is clear that a

better relationship must be fostered between MLS, the drivers and the police on this

issue.



RECOMMENDATION

The iTaxiworkers propose, in an effort to improve the relationship between the MLS,

frontline taxi drivers and the police, that the MLS formally establish a permanent Taxi

Advisory Committee (TAC) with equal representation from various industry stakeholders.In addition, it would be useful to explore conducting joint workshops and roundtables

with taxi drivers and police to improve communication and help facilitate a better working

relationship. It is also proposed that the industry consider establishing a mechanism by

which drivers can assist police as “eyes on the road” and it is essential to systematically

begin to track police interaction with taxi drivers so as to be able to identify, develop and

implement concrete solutions to the issues facing Toronto’s taxi drivers.




BENEFIT FUND………………………………………………………………………………………………………………………………………..

BENEFIT FUND

13. The Municipal Licensing and Standards Division (MLS) should establish a working

group to develop and recommend a plan to create a benefit fund to provide health

and dental insurance and retirement protection for drivers and their families. This

working group will include representatives from the iTaxiworkers, brokerages and

other industry stakeholders. At a minimum, shift drivers will be automatically

enrolled and owner-operators will have the opportunity to buy-in to the plan.

Start-up costs for the fund will be derived from the $5,000 fee collected from plate

conversions.

BACKGROUND

As self-employed workers, taxi owner-operators, lessees and shift drivers do not receive

any of the health, dental or retirement benefits that many other workers receive.

Considering the inherent danger and constant exposure to physical, verbal and

psychological abuse that Toronto taxi drivers experience on a regular basis, it is imperative

that they have access to affordable and comprehensive health, dental and retirement

benefits for themselves and their families.

As previously noted, working as a taxi driver in Toronto does not provide a living wage or

economic stability. At the request of the iTaxiworkers Association, a group benefits

administrator provided an analysis of the availability and cost of a very basic benefit plan

for member taxi drivers. Assuming that most drivers, who on average support more than

4 people on their income, were to choose family coverage, the cost for benefits would be

over $200 per month. With an average income of just under $12,000 per year, this would

see nearly 20% of a driver’s earnings being spent on benefits. Clearly, this option is out of reach for most drivers. The economic, social and health consequences of ignoring the lack

of affordable benefits for Toronto’s taxi drivers and their families will lead to a decline in

health status for thousands of Torontonians and exacerbate the demands placed on our

health care system.



By developing a benefit fund for 10,000 Toronto taxi drivers, the costs per driver can be

reduced to an affordable rate. This affordability is why many professional associations

have begun to establish and/or manage their own benefit plans. Professional associations

have a history of providing benefit plans to members and have become an established

mechanism for offering security. Some examples include the Ontario Nurses Association,the Canadian Real Estate Association, the Toronto Board of Trade, and Engineers Canada.

It is within this context that examples of specific benefit plans for taxi drivers are outlined

below and may be useful models for a benefit fund for Toronto’s taxi drivers.

New York State’s Independent Livery Drivers Benefit Fund, United States

The concept of a benefit fund for drivers was inspired by New York State’s Independent

Livery Drivers Benefit Fund which was established over the past several years. The fund

was the result of state legislation that established a non-profit corporation to administer

the benefit fund for taxi drivers. The law requires that dispatch companies join the fund

and pay premiums for dispatch drivers into the fund. The fund then provides medical and

loss-of-earnings benefits for drivers who have sustained serious injuries while working.

Companies are required to participate and there are penalties for non-participation.

The National Association of Taxi Drivers (NATD), United States

The National Association of Taxi Drivers is a professional association in the United States

that covers self-employed taxi and limousine drivers. Having been established in 2011, the

group insurance is currently not offered in every state, but there are efforts to expand and

eventually encompass the entire country. Benefits cover a broad range of services

including health and life insurance, drug programs, legal representation for tickets,

discounts on immigration representation, as well as on vision and dental costs.

The City of San Francisco, United States

The City of San Francisco initiated a study on how to offer health insurance to taxi drivers.

The report seeks to demonstrate that every taxi driver can get insurance if all stakeholders

agree to contribute (City and County of San Francisco Department of Public Health, 2006).In determining the need for health insurance, over 79% of San Francisco taxi drivers

surveyed stated that the reason they did not already have insurance is because they could

not afford it (San Francisco Municipal Transportation Agency). To counter this, the Agency

suggested three main ways to offer coverage: medical savings accounts, direct health

services that would provide care through hospital networks, or a health insurance plan

under a taxi association. Some possible sources of revenue outlined include drivers, plate



owners, brokers and public sources such as increasing fares or creating a new fee or tax

(City and County of San Francisco Department of Public Health, 2006).

New York City and New York Taxi Workers Alliance (NYTWA)

Founded in 1998, the NYTWA is the largest taxi driver association in the United States. It isa membership-based organization which provides access to healthcare for its 15,000

members. A NYTWA member has access to health care services which include:

• Community health workers

• Free annual health fairs for comprehensive check ups

• Health insurance options, including free or low-cost programs (Family HealthPlus,

Child Health Plus, Medicaid, Medicare & renewals)

• Social security, retirement and disability insurance

• Discount dental programs for an annual fee of $63 for individuals and $86 for a

family which includes 1,400 dentists who offer a free exam and x-rays

• Free prescription discount card

In addition, the NYTWA and The New York City Taxi and Limousine Commission (TLC) are

collaborating on the establishment of a task force for the creation of a Taxi Driver Health

and Wellness Fund which will include healthcare (medical and dental), as well as state

disability, accidental death and dismemberment insurances. The sources of revenue for

the fund include contributions from the industry, industry-specific revenue generatingprograms (lease contributions, taxi rooftop advertising revenue and profits from taking

credit card payments), contributions from drivers, private foundation support and

subsidies from the state as well as the federal government. The NYTWA proposal outlines

a specific, realistic breakdown of sources of revenue they are using to fund the benefit

package; these sources are comparable to those that could be used for a benefit fund for

Toronto.

RECOMMENDATION

As the city’s taxi drivers are classified as self-employed, they do not receive employment-

based health insurance and other benefits. The low income levels of drivers further place

the cost of private health insurance policies out of reach. To address this issue, the

iTaxiworkers propose that the MLS establish a working group to develop a plan that

creates an affordable and comprehensive package of benefits for all of Toronto’s frontline



drivers and their families. The preliminary funding for this initiative can be provided by

converting the 1,400 Ambassador plates currently on the road, and at $5,000 per plate,

this fee would provide $7 million in startup costs for a benefit fund. It is clear that there

are benefit funds being created specifically for taxi drivers that provide access to

healthcare and basic insurance, and should be considered in any reforms of the Torontotaxi industry.




TAXIS AS PUBLIC TRANSIT………………………………………………………………………………………………………………………………………..

TAXIS AS PUBLIC TRANSIT

14. The City of Toronto must recognize taxis as an important component of public

transportation. The role of taxis must be included within the larger public

transportation policy discourse.

BACKGROUND

Taxis are an important part of the City of Toronto’s transportation infrastructure. They

complement residents’ choice to use alternative modes of transport such as public transit,walking, and cycling. For many Torontonians, taxis are an alternative to the use of private

vehicles, particularly in circumstances when other forms of transport are inconvenient or

simply not available. The ready and affordable presence of taxis in our city supports

thousands of people in choosing lifestyles that do not include owning a private

automobile. It is for this reason that the decisions around the future of our taxi industry

are critical to the development of our city.

Taxis have always been a form of public transportation. Indeed, the taxicab is the oldest

form of licensed public transportation in the world. In Toronto, they were one of the firstforms of easily available public transit.

18William Hubbard, who would go on to be the

first black Mayor of Toronto (and of any Canadian city) in 1906 and 1907, opened the

city’s first taxi business in 1836.

Today, taxis move thousands of residents, business people, and tourists around the city

taking them to business meetings, attractions, medical appointments, hotels, and airports,

among a host of other places. However, despite these facts, the role of taxis is often

overlooked by transportation planners and policymakers in their discussions on public

transportation.

18Taxi!, p. xv.



TAXIS AS A SUSTAINABLE TRANSPORTATION OPTION

Toronto’s Official Plan (OP) envisions providing Torontonians with sustainable

transportation options that are seamlessly linked, safe, convenient, affordable, and

economically competitive. Along with walking, cycling, and mass transit, taxis are asustainable transportation option. These forms of transportation stand in contrast to

privately owned vehicles that clog our roads and contribute to air pollution, both of which

diminish our quality of life.

Furthermore, taxis are a travel demand management measure as described in the OP,

especially when they travel on High Occupancy Vehicle (HOV) lanes with three or more

occupants. Travel demand management refers to strategies that make more efficient use

of the transportation system such as carpooling, the use of high occupancy vehicle lanes,

ride sharing arrangements, etc. In this regard, the OP sees a role for taxis as a supporterof an alternative transportation lifestyle by discouraging private vehicle ownership.

In his February 3, 2012 article in The Atlantic Cities, writer Eric Jaffe further demonstrates

how taxis add to public transit. Citing a study that mapped the origins and destinations of

New York City’s yellow cabs over a 24 hour period by urban planning professor, David King

of Columbia University, Jaffe reports that an individual’s travel journeys show a distinctive

multi-modal pattern. That is, people use taxicabs to complete one leg of their daily round

trip journey and likely use public transportation to complete the other leg. The pattern

reveals that New York City taxi cabs work within the existing transit network, not against

it. Jaffe writes, “… taxis act as a complement to these other modes and help discourage

auto-ownership and use,” which is a defining feature of transit-oriented cities. The

question Jaffe raises is: Why is the role of taxis as part of the transit network overlooked,

especially when car ownership is being discouraged? This question is equally applicable in

the Toronto context.



TAXIS IN TORONTO

By serving as an additional transportation option, taxis fill the gaps of Toronto’s mass

public transit system, the Toronto Transit Commission (TTC), in the following ways:

• Provide late night and early morning service when TTC service is limited

• Provide service to the geographic areas of the city that are outside of the TTC

service area19

• Provide door-to-door service

• Accommodate elderly passengers who cannot use the TTC

• Accommodate passengers with mobility issues who cannot use the TTC

• Provide service to passengers seeking to transport items that would not be

appropriate to carry on the TTC

• Transport passengers who do not feel comfortable on the TTC at certain hours• Provide accessible options for tourists who are not familiar with local public transit

• Provide door-to-door service on contract for agencies like the Workplace Safety

and Insurance Board

Studies and reports confirm the role of taxis in filling the gaps left by mass public transit,

especially in terms of their service coverage area, payment options, convenience, and

speed.20

Indeed, many people depend on taxis to complete trips that would otherwise be difficult

to undertake by other modes of public transportation. Taxis are particularly a more

suitable option when poor weather, bad connections, reduced mobility due to health, or

when transporting heavy and bulky items like groceries or some other new purchase are

factors. Many would find life difficult without the occasional taxi trip. Without a well

functioning taxi system, many more people that could afford cars, would choose to

purchase them, thereby adding to the traffic congestion and pollution in our city.

Over time, one group that will grow increasingly more reliant on taxi services is senior

citizens. According to Statistics Canada, the proportion of seniors is poised to grow

rapidly in the coming decades. Last year, the first of the baby boomers turned 65, the

19Many of Toronto’s neighbourhoods that are least accessible by transit are also its poorest

neighbourhoods. See J. David Hulchanski, The Three Cities Within Toronto: Income Polarization Among

Toronto’s Neighbourhoods, 1970-2005, University of Toronto, 2010.

20Bradgate Research. December 2010. Toronto Taxi Public Opinion Survey.



beginning of a historic demographic shift in Canada.21

By 2015, the population of seniors

will outnumber the population of children in Canada for the first time in the country’s

history. Moreover, by 2031, it is predicted that one-quarter of Canada’s population will

be senior citizens. With an aging population, mobility is sure to become a key concern for

seniors. In this regard, taxis can help meet their future mobility needs.

Another group of users who may increasingly rely on taxis are those affected by service

cutbacks to TTC bus and streetcar routes. According to the TTC’s website, there are over

50 bus and streetcar routes that are experiencing a reduction in frequency. Some of these

routes include those servicing the city’s suburbs such as McCowan Road, Finch Avenue

East, Eglinton Avenue West, Martin Grove Road, Markham Road, among many others.

Taxi service will be especially critical for passengers travelling overnight where TTC service

is either reduced or discontinued.

Despite their importance in transporting residents and tourists, as highlighted above, taxis

are largely treated as private vehicles on our roads. Apart from the taxi stands in the city,

there are few other allowances made for taxis in Toronto. Whereas the TTC benefits from

its own lanes, turning lanes, and special traffic privileges in certain parts of the city, taxis

enjoy very limited traffic privileges.22

By contrast, in England, where taxis are part of the

public transportation system, they are exempted from the application of local traffic

restrictions such as the Congestion Charge in London. They also have access to restricted

areas of town centres through gates and barriers. Furthermore, at transport interchanges

such as airports and railway stations, taxis often enjoy a degree of preference over other

modes such as bus and coach through more prominent positioning of taxi stands.23

The lack of traffic allowances for taxis in Toronto has not gone unnoticed. Allowing taxis

the same access as TTC vehicles, especially in turning lanes, will cut down not only on the

amount of travel time, but also on the amount of air pollutants released. The faster travel

time to destinations, granted by traffic allowances, can also enhance customer service.

Moreover, traffic allowances for taxis would increase the possibilities for drivers to earn

additional fares, which can go a long way towards improving their low incomes. It is awin-win situation for all.

21Statistics Canada. 2006 Canadian Census.

22In Toronto, taxis can use some bus lanes but there are other traffic restrictions like left hand turns.

23Hawthorne and Menz. 2009. Encouraging the shift from private to public transport - are taxis part of the

solution or part of the problem? European Transport Conference.



RECOMMENDATION

Aside from traffic allowances, taxi stands also belong in the wider discussion of taxis as a

form of public transit. If public transit is to be truly accessible and convenient, thencustomers should have convenient access to taxis through additional taxi stands in the

city. The current number of taxi stands does not provide the riding public with this option.

Thus, the growth and expansion of the network of taxi stands should be coordinated

and/or integrated with planning the City’s larger public transportation infrastructure.

It is abundantly clear that an inclusive transit network must recognize taxis as a part of the

public transit mix. When limited taxi use is associated with other alternative transport, it

serves as a green and affordable solution to private car ownership. A vibrant and

sustainable city is built by offering sustainable transportation options. As such, whendeveloping broader transportation policies and plans, the City should consider the

benefits that taxis deliver to both the riding public and the city as a whole.





CONCLUSION

A WAY FORWARD FOR TORONTO’S TAXI INDUSTRY………………………………………………………………………………………………………………………………………..

This document presents a coherent set of proposals that would reform Toronto’s taxi

industry for the betterment of drivers, passengers and the city as a whole.

These proposed reforms have been crafted and presented by Toronto’s taxi drivers.

However, these proposals were not driven solely by self-interest but out of a desire to

improve the taxi industry for drivers and customers. Despite working hard with little

economic or social reward, Toronto’s taxi drivers take great pride in their work and truly

want to serve their customers well. However, as drivers know better than anyone, true

customer service will only come when drivers’ basic needs are met. These needs can onlybe met by municipal regulations that encourage basic safety and fair economic gains for

hardworking drivers.

In Toronto’s current taxi industry, thousands of hardworking drivers work very long hours

doing very dangerous work, yet they still earn very little. Unlike most workers, they lack a

social safety net of any kind and have no mechanism of saving for retirement. The end

result is that drivers feel insecure, rushed and stressed on the job. Customer service

inevitably suffers. On the other hand, those who may never drive a taxi themselves - the

absentee and multi-plate owners and agents - reap the financial rewards of this system.

With razor thin profit margins divided amongst so many stakeholders, drivers are

increasingly pushed towards the edge.

Ultimately, the City is responsible for how its taxi industry functions, and, to a large

extent, for what drivers’ lives are like.

The 1998 Task Force and the introduction of a new type of licence has provided, in

essence, a unique experiment in different systems. If anything, the continuing struggles of

all taxi drivers during this period have demonstrated that neither system – the Standard or

Ambassador – is able to address driver concerns. However, each system does have clear

advantages and disadvantages. The iTaxiworkers have attempted to craft a vision of a taxi

industry that capitalizes on the strengths of each system, while sidestepping the

weaknesses. This innovative, hybrid approach would make the system better for

everyone: the drivers, the customers and the city as a whole.



If the City fails to address the need for reform now, the taxi industry in Toronto will

continue to spiral downwards, both for taxi drivers and for the public.

Taxi work is an important, frontline service. A well functioning taxi industry will benefit

the city as a whole and contribute to Toronto’s rise as a global destination. Such anindustry depends on finding innovative solutions that benefit all of the industry’s

stakeholders, drivers included. The City should complete the good work that was begun

by the 1998 Task Force and adopt the proposals put forward by the iTaxiworkers in this

document.

Again, we thank you for the opportunity to participate in this consultation and ask that

you consider our proposals carefully.

Documents

workers Submission to the City of Toronto 2012