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November 30 report to Licensing Committee does not contain accurate comment from stakeholders, David Reti writes Councillors

On November 29th, 2021, Toronto Taxi plate holder David Reti wrote Councillors and members of the General Government and Licensing Committee to express his frustration with the contents of the staff report they will be considering on November 30.

The full content of Reti’s letter to Councillors is below; it is followed by his October 6th submission to the online survey which accepted submissions from the public. Some individuals, groups and businesses do not feel their submissions were accurately reflected in the new report. Taxi News published several in full, including those submitted by Baird MacGregor Insurance; ATOOL; and Neil Shorey of City Taxi.

Re: 2019 VFH By-Law Review

Dear Councillors,

In my previous letter to you from about a month ago, I said:

“I have submitted the attached feedback showing just how unfair and discriminatory some of these by-laws are, but Idoubt any of it will make it to the report shown to you.”

Sure enough, there is no mention of any of this, and parts of the report are going to be kept from you and from the public as MLS has requested it be kept confidential. This report is failing our industry.

We have insisted that the regulations are unfair for many years now and no one seems able to do anything about it. I urge you to read or re-read the original submission I made, which you can find attached. The extraordinary unfairness against the taxi industry, largely made up of immigrants is astounding. Please raise these issues! Please ask why a public review of by-law changes must be kept confidential! We have no voice without you, despite being told that we can provide comments and input. We cannot!

I also find it frustrating that the MLS is now recommending a reduction in fees for PTCs to “prevent the appearance of cross-funding.” The same MLS has no compunction about collecting fees from one class of business to support another in the form of the Accessibility Fund. This Fund literally forces people like me to pay into it, even when my own business is inoperable. It then allegedly distributes that money to support another class of license. I say “allegedly” because according to the by-laws adopted, MLS is NOT required to distribute ANY of the monies collected and has full control over what, how much and when these funds are used.

I MUST pay into this fund, even though the monies are not used for ANY administrative or enforcement costs related to my business. Why is Toronto so absolutely determined to destroy our industry? Many of our members are immigrants, doing their best to make ends meet but face this kind of extraordinary discrimination again and again.

Why can’t we EVER get our concerns addressed? Why is it so difficult to treat us fairly?

Sincerely Frustrated,

David Réti

The letter below was submitted to Toronto’s Vehicle for Hire By-law Review’s online submission portal:

October 6, 2021

Re: 2019 Vehicle-for-Hire Bylaw Review 

For Distribution to: Chairman and Members of the General Government and Licensing Committee

I would like to start by pointing out that many of the topics being reviewed as well as many of the current demands from VFH drivers around the world, all form the basis of the regulatory system THAT ALREADY EXISTED before PTCs were “legalized.” This includes improving public, passenger and driver safety and fairness, which were largely removed to “accommodate” PTCs entering the market.  

“Report after report shows congestion increasing,” Reti writes. Photo: Unsplash

Many of the demands of the international PTC community now, however, are to reduce oversupply to allow operators to make a living. It is infuriating that the taxi industry had to be decimated to come full circle back to the regulatory system we had in place before PTCs were “legalized.” We are literally moving closer and closer to the system that already existed!

Issues

1.  Licensing Renewal Fees Are Ridiculously Discriminatory.

a.  There is significant disparity in annual licensing renewal fees. A Taxi Driver’s license costs $132.60. A Taxi Operator’s license costs $306.00. A Taxi Owner’s license costs $1,003.84.  For a PTC driver, it costs $15.30. Total.

b.  Taxis are separated into 3 distinct categories: driver, operator, owner. To own and drive your own vehicle requires you to pay 2 separate licensing fees. There is only 1 fee for PTC drivers, which includes operating and owning their business. 

c.  According to published documentation, over approximately $34,000,000 in VFH licensing fees was collected in 2019. The law requires these monies to be collected on a cost recovery basis within each license category. The revenues are to cover the expense of administration and enforcement. With over 80% of taxis not even operating, how can administrative and enforcement expenses remain unchanged? How is this money being spent and why must I keep paying for regulatory services that no longer apply to me? 

d.  Revenues from VFH licensing has more than tripled since 2015. If licensing revenues are to be used to administer and enforce the by-law from which they are collected, how can it take over $34 million to enforce one by-law??? Where is all this money going?  

e.  With my business sitting idle, there should be no enforcement costs and near-zero administrative costs. Yet I am still required to pay $1,003.84 in annual licensing fees. There should be no renewal fees applied to any Taxi Owner’s licensed plates while the business remains inoperable due to circumstances beyond their control.  

2.  The Accessibility Fund is Illegal, Unfair and Discriminatory. 

a.  There is a significant disparity in Accessibility Fund Fees. 

A Taxi Owner/Operator must annually pay $125.32 to the Reserve Fund. A Taxi Driver must pay $62.66 annually. ($187.98 total for owner/drivers).

For a PTC driver, it is only $7.23. Total.

b.  Despite my taxi being inoperable for several years now, I am STILL required to financially support TTL drivers. If I don’t, my plate will be expropriated from me. That’s the law!

c.  The “$5 million” a year accessibility fund collected over $8 million in 2019 – approximately 1/3 of all VFH licensing revenues that year.

d.  Only about 25% of these funds are disbursed to eligible TTL drivers. And not all Toronto Taxi Licence drivers and owners are even eligible for this financial assistance. How is this not a slush fund for MLS? 

e.  There is no oversight on this fund. It’s entirely at the discretion of the Executive Director of Municipal Licensing and Standards – including how much is collected, used and disbursed. Fees can be increased at will. Disbursements can be denied at will.

f.  The MLS is illegally collecting millions of dollars per year to financially sustain a Fund, from people who can’t work, without any oversight or even any requirement to disburse the funds meant to support this failed class of licensees. 

g.  I am required to pay this fee to support OTHER people’s businesses, even though I cannot even meet my own expenditures. Failure to do so, means my business gets expropriated.

 3.  Unlimited PTC Vehicles Are Bad for Everybody. 

a.  Report after report shows congestion increasing, emissions increasing and almost 50% of riders being pulled from public transit into private vehicles. This is literally the opposite of the City’s stated goals.

b.  With over 90,000 PTCs, the market is flooded. Nobody can make a living with such unrestrained oversupply.  

c.  The original 5,000+ licensed taxis can’t possibly compete with almost 20x more vehicles for hire on the road, who have a fraction of the operating costs, but do the exact same work.  

d.  The purpose of a regulated system was to ensure public health and safety while allowing operators the ability to make a living from their work. Flooding the market with unlimited new operators negates all of that. The City has not enacted a system that comes close to being able to administer or enforce the governing by-law for such a huge amount of licensees. There is currently no good way to ensure public safety and no ability to earn a livable wage for any operator. 

e.  We have literally replaced a small group of trained professionals adhering to strict safety protocols, with a massive fleet of amateurs that have minimal or no safety requirements.  

My submission before the 2019 by-law changes were approved, warned that the City was moving itself into a position that would force me to shutter my business, after which they would be able to expropriate it from me. With over 80% of cabs idle and unable to work, we are now seeing exactly this happen. The laws require that the fees be paid no matter what. And if they are not…the plate is seized.  

I am extremely distraught at the notion that I followed the rules, obeyed the laws and in return am about to lose everything my family has worked for in the last 5 decades. How does the destruction of my family business serve the greater good?

Sincerely,

David Réti