U B ER. November 23, 2016 Q^f ^ WINDSOR COUNCIL SERVICES RE: TAXI STUDY REPORT & TRANSPORTATION NETWORK COMPANIES / UBER

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1 U B ER November 23, 2016 Q^f ^ WINDSOR COUNCIL SERVICES City of Windsor ^ g^ 9^ 350 City Hall Square W. ny N9A'6si"" RECEIVED Dear ETPS Standing Committee Member, RE: TAXI STUDY REPORT & TRANSPORTATION NETWORK COMPANIES / UBER In response to the Vets Cab submission, I provide the attached response (also sent yesterday via ). With respect to the Taxi Study Report by staff scheduled for consideration at the ETPS Standing Committee meeting today, I reiterate: On behalf of Uber Canada, I support the staff recommendations made to regulate Transportation Network Companies (TNCs) like Uber. Councillors will have another opportunity to review the staff recommendations in the form of a draft bylaw. Staff will prepare the draft bylaw based on input by Committee and Council. The draft bylaw will come before Committee and Council again I understand early in I would be happy to meet with you in person in Windsor this week (Nov ) at your convenience or speak with you by phone about this correspondence in advance of Committee at 430pm on Nov. 23rd. I can be reached by phone at or at chris. schafer.uber.com. Sincerely, Chris Schafer Public Policy Manager chris. schafer(a)uber.com Uber Canada

2 Vet Cabs Submission 1. All Drivers should apply for licence in person with City of Windsor Uber Response Online licence application processes have been adopted by all other Ontario cities that have recently passed bylaws recognizing ridesharing/uber (Toronto, Ottawa, Waterloo Region, Niagara Region) that allow for Transportation Network Companies (TNCs/Uber) to be licensed. Windsor city staff are supportive of this model. Under the model, the TNC/Uber is licensed and prospective drivers apply to drive with Uber through Uber by confirming identity through credit check type processes, and supplying a range of documentation (driver's licence, etc.). Uber can only permit drivers to drive on the Uber platform that meet the strict requirements of the proposed Windsor bylaw. The City of Windsor supports this model and ensures compliance under it through data sharing obligations and audits. A TNC that fails to fulfil compliance related bylaw requirements risks substantial fines and loss of its TNC licence to operate. The ridesharing business model is different from taxi. Most Uber drivers drive less than 10 hours a week. For many, Uber is an income supplement and not a full-time job. As such, requiring prospective Uber drivers to come down to City Hall is both challenging for them (they have other jobs) when modern online processes facilitate the same outcome as more traditional application methods. 2. Vulnerable Sector Criminal Record Check should be a requirement for all drivers and submitted to the City. Cities that have passed bylaws recently to address ridesharing have allowed for third party record checks completed by an Ontario police service. Windsor city staff are supportive. The process ridesharing companies use as supported by Windsor city staff: Uber has a zero tolerance threshold for criminal convictions on the Uber platform. Check initiated online by prospective driver and check done of local police databases by Ontario Cobourg police with result delivered to Uber through 3rd party intermediary (background check vendor). Cobourg Police Service searches the National Repository of Criminal Records and the Police Information Portal (PIP) and Firearms Interest Police

3 (FIP) databases which contains local police information. If there is no criminal history, the prospective Uber driver-partner passes this stage. If there is a criminal history, they are ineligible to drive with Uber. If there is a "concern", perhaps from a Date of Birth and Name match in a police database, Uber requires that prospective driver to go in-person to a local Windsor police station to be fingerprinted. 3. A Photo!D Card should be issued by the city for all classes of drivers. A photo ID card is unnecessary in The Uber driver-partner smartphone app (that bylaw enforcement has access to) contains a photo of the driver, name, driver's licence, car make and model, etc., in addition to pertinent documentation: ridesharing insurance "pink slip". Note: When an Uber passenger requests a ride, they get the driver's name, photo, licence plate, and vehicle make and model, before getting into the Uber vehicle. Uber passengers can anonymously contact the driver by phone or text prior to entering the vehicle. Uber's technology scrambles numbers for privacy. Uber passengers can share above details in real-time, including live GPS route mapping, with friends/family at the touch of a button while on an Uber trip. Historical trip information above is stored in the driver and passenger apps. 4. Plate Holder Fees for all Classes Taxi, Livery and X-Class should be the same at $250. An annual fee + per trip fee model for Transportation Network Companies (TNCs) has been adopted in recent bylaws across Canada including Toronto, Ottawa, Niagara Region, and Waterloo Region. Uber supports the Windsor staff recommendation that provides an additional way for the City to collect fees beyond the traditional manner of fee collection. Windsor is recommending the following: $30,000 annual fee + $0.11 per trip fee Windsor city staff have indicated that this fee structure will ensure the City recoups the costs of regulatory compliance. Uber agrees based on its current and future trip projections. 8. The taxi training and english language assessment should be Windsor city staff are recommending TNCs/Uber and taxi brokers provide training to drivers without an English assessment requirement. This is consistent with recent bylaws

4 replaced with the successful completion of the TLPA driver coarse administered by the broker. 12. Security Cameras should be selected by car owner, removing restriction for who can view and utilize the information recorded but still making it available to City bylaw and Law Enforcement. passed to date in cities across Ontario including Toronto, Ottawa, Waterloo Region, Niagara Region that allow TNCs/Uber/brokers to train drivers. Beyond the driver related training Uber already provides: Uber Driver ratings provided by Uber passengers and real-time written feedback on customer service in app allows customers and Uber to apply effective customer service "discipline" in real-time around the clock on every day of the year. Windsor city staff have recommended that cameras not be required in Uber vehicles: No city globally including Canadian cities have required cameras in private for hire vehicles (Uber) in their bylaws. Cities like Toronto, Ottawa, and Waterloo Region have included the issue of cameras in a report back one year after new by-law in full force and effect to enable time for further study post bylaw implementation. In most old taxi bylaws, cities have required taxis to have cameras because taxi drivers carry cash, and taxi passengers are anonymous. Most old taxi bylaws have not required limos to have cameras as trips are pre-arranged. Reasons why other cities in Canada have decided private for hire vehicles (Uber) do not require cameras: Uber trips pre-arranged. No anonymity in Uber vehicles. GPS monitoring. "Share Location" from Uber app with contact: Ride can share trip details + live GPS routing with loved ones. Driver ratings & real-time feedback in app, responded to by Uber24 hours. Uber has 24/7 support + Emergency Response Team + Law Enforcement Response Team. Uber works with law enforcement to support production orders and data sharing (GPS trip data, etc.) to facilitate police investigations/prosecutions. 15. All X-class vehicle applications should be made in person to the City of Windsor by an individual vehicle owner. X-class vehicle applications should be restricted to individual Online licence application processes have been adopted by all other Ontario cities that have recently passed bylaws recognizing ridesharing/uber (Toronto, Ottawa, Waterloo Region, Niagara Region) that allow for Transportation Network Companies (TNCs/Uber) to be licensed. Windsor city staff are supportive of this model.

5 car owners not allowing for corporation or partnership applications. Under the model, the TNC/Uber is licensed and prospective drivers apply to drive with Uber through Uber by confirming identity through credit check type processes, and supplying a range of documentation (driver's licence, etc.). Uber can only permit drivers to drive on the Uber platform that meet the strict requirements of the proposed Windsor bylaw. The City of Windsor supports this model and ensures compliance under it through data sharing obligations and audits. A TNC that fails to fulfil compliance related bylaw requirements risks substantial fines and loss of its TNC licence to operate. The ridesharing business model is different from taxi. Most Uber drivers drive less than 10 hours a week. For many, Uber is an income supplement and not a full-time job. As such, requiring prospective Uber drivers to come down to City Hall is both challenging for them (they have other jobs) when modern online processes facilitate the same outcome as more traditions! application methods, 16. A X-class vehicle should be supplied with a City of Windsor Decal identifying it the vehicle as an X-Class vehicle "This vehicle is ONLY available by pre-booking and MAY NOT accept cash payment" with completed vehicle application similar to that of a taxi with same submissions (Ownership, insurance, Safety Certificate) etc. and inspected by City of Windsor By-law officer. Where cities (i.e. Toronto and Waterloo Region) have required vehicle identification/decal, they have opted to harmonize and require the same vehicle identification of broker specific removable signage (see below). Windsor city staff support the decal below: 0^<? The Windsor city staff recommendations already provide for Uber requirements to retain and remit various documents related to insurance, safety standard certificate, etc, in addition

6 to vehicle spot inspections by by-law officers who can use specially created Uber "ghost" accounts provided by Uber to the City to request trips on the Uber platform for the purposes of bylaw enforcement. 17. X-Class vehicle should be not older than 8 Model Years. Most cities that have recently passed a bylaw that addresses ridesharing and Uber, have a maximum vehicle age of 10 years. Like Windsor city staff that support vehicle age limits of 10 or more years, modern vehicle manufacturing have established safer vehicles than in decades past. Recall all vehicles are already subject to an annual Ontario Ministry of Transportation Safety Standard Certificate vehicle inspection + random spot vehicle inspections by bylaw enforcement under proposed Windsor city staff recommendations.

Public Vehicle Pilot Program Committee

Public Vehicle Pilot Program Committee Date 2016/08/18 Time 9:00 AM Location Civic Centre, Council Chamber, 300 City Centre Drive, Mississauga, Ontario, L5B 3C1 Ontario Members Bonnie Crombie Karen Ras