July 12, 2016
John Pyke, Chair
Kingston Area Taxi Commission
1201 Division St., Kingston ON
Dear Mr. Pyke,
You asked for recommendations from the Industry concerning safety measures the Commission should require in vehicles affiliated with Transportation Network Companies (TNC’s).
I propose that all vehicles affiliated with TNC’s be required to have the same safety equipment as taxis. Despite the assertions of the representative for Uber, there is no guarantee that the person who orders a cab or a TNC vehicle will be the same person as the passenger.
I can think of three circumstances in which the person who orders a cab through a company app could be a different person from the passenger:
1. If the wrong passenger is picked up, especially at a bar;
2. If “Jane” asks “John” to call her a cab, and the driver expects John to be the passenger; and
3. If the cell phone is stolen and not locked to prevent the thief from using the app.
In terms of insurance, I feel that TNC operators should be insured for the entire time the TNC app is activated, time between and en route to calls as well as the time while the passenger is in the car. The most recent news I have seen is that Intact Insurance is offering a policy covering the driver of the vehicle while the passenger is in the car, but I see this as being inadequate.
I offer some definitions for inclusion in By-Law No. 4:
• Transportation Network Company (TNC) shall mean any corporation other than a Taxi Broker which
1. provides an app to the owners of vehicles for the purpose of being connected to potential passengers for hire; and
2. provides an app to persons for the purpose of being connected to owners of vehicles for the purpose of becoming passengers for hire
• Transportation Network Plateholder (TNP) shall mean any vehicle owner who installs and uses the app provided by a TNC for the purpose of finding passengers for hire.
I feel that no TNC plates should be issued until everyone on the waiting list has been issued a plate. As this seems unrealistic, I propose that the number of TNC plates be strictly limited, perhaps to five, subject to review annually in September. Every TNP should be required to inform the Commission whenever he ceases to be affiliated with a TNC, and may only return to that affiliation if the number of TNC plates in use is fewer than five.
Thank you for considering my opinions.