workers submission to the city of toronto 2012
TRANSCRIPT
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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.
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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.
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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.
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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
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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
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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.
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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.
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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.
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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.
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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.
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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
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• “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.
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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
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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.
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iTAXIWORKERS’ PROPOSAL
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.
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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.
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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
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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
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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.”
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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iTAXIWORKERS’ PROPOSAL
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.
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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).
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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.
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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.
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iTAXIWORKERS’ PROPOSAL
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.
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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.
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iTAXIWORKERS’ PROPOSAL
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
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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.
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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.
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iTAXIWORKERS’ PROPOSAL
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.
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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.
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iTAXIWORKERS’ PROPOSAL
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.
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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
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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
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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.
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iTAXIWORKERS’ PROPOSAL
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.
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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.
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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.
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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.
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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.
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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.
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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.