96-485��t��(�����
ORDfNANCE
CITY OF SAINT PAUL,
Preseated By
Referred To
Date
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An ordinance to amend Chapter 37b of the Saint
Paul Legislative Code pertaining to taxicabs;
increasing the number of licenses auailable,
removing the reference to metal license tags,
changing selection criteria for newly issued licenses,
and making other minor housekeeping changes.
9 THE COUNCIL OF'PHE CITY OF SAINT PAUL DOES ORDAIN:
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Section 1
13 Section 376.05. of the Saint Paul Legislative Code is hereby amended to read as follows:
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"Sec. 376.05. Public convenience and necessity.
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Section 2
Sectian 376.08. Of the Saint Paul Legislative Code is hereby amended to read as follows:
"Sec. 376.08. App&cant--Requirements.
(a) Each applicant for license to operate for hire a public vehicle must comply with the following
conditions to the satisfaction of the inspector:
(1) Be the state license registered owner or a lessee, if the motor vehicle is the subject of a
lease having an initial term of six (6) months or longer, of the public vehicle.
(2) Be of the age of eighteen (1 S} years, or over, in the case of an individual, and in the case
of any copartnership or corporation, must be authorized to operate taxicabs and carry on
business in accordance with the laws of the State of Minnesota.
(3) Must obtain a license for each and every such vehicle to be operated.
(4) Must fill out upon a blank form to be provided by the inspector a statement covering
each vehicle to be so licensed, giving full name and address of the owner; the class and
passenger-carrying capacity of the vehicle for which a license is desired; the length of
time the vehicle has been in use; the make of car; the engine number; the serial number
and the state license number; what insurance or bond against personai injury or property
damage is carried, and in what amount. If said application is made by an individual
owner, said owner shall sign and swear to said application; if said applicarion is made by
a partnership, then by one (1) of the partners; and if by a corporation, then by one (1) of
the duly elected officers of said corporation.
(b) Said application shall also include an accurate and detailed description ofthe color scheme ofthe
public vehicle, if it is to be used as a taxicab, including inscriptions or monograms thereon,
proposed to be operated by said applicant, which sha11 be distinctly different from that of the
taxicabs of any other licensed owner or operator, so that the ownership and identity may be
readily ascertained by the deQartment of police and patrons of any taxicab, �cept that one (1) or
- � � � �T����
i more applicants who are members of the same association and who are authorized to use the
2 color scheme of taYicabs, including the inscriptions or monograms thereon, of such associations
3 may be licensed to do so when proper evidence of their right from such association to use such
4 color scheme and inscriptions or monograzns shall be filed with their application; and it shall be
5 uniawful for the owner of any such taxicab, or the operator or driver thereo� licensed under the
6 terms of this chapter to make any change whatever in the color scheme of the ta�cabs or the
7 inscriptions or monograms thereon without first obtauiing the approval of the city council.
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14 Section 3
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16 Section 376.09. pf the Saim Paul Legislative Cade is hereby amended to read as follows:
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"Sec. 3'76.09. Vehicles--Reqairements.
No public vehicle shall be licensed wrtil it has been thoroughly and carefully examined and found to
comply with the following:
(i) To he in a thoroughly safe condition for the transportation of passengers, each vehicle shall be
inspected at the city service garage, at a cost deternuned by the license inspector to be paid by
the applicant. The inspection shall include, but not be limited to, inspection of tires, brake
system, lights, electrical system, steering, wheel alignment, suspension, e�aust system, engine,
transmission, drive train and frame in accordance with standards adopted by the inspector. Any
taxicab owner failing to show proof of vehicle passage of the Minnesota Motor Vehicle
Inspection Program, pursuant to rules established under Minnesota Statutes, Section 116.62, in a
period of six (6} months prior to the September and/or April inspection date, shall be required to
submit the vehicle or vehicles to a similar emissions test gerformed at the firelpolice equipment
garage at a cost to be determined by the license inspector. If such test shows repairs to be
required, the owner shall order the repairs made by an authorized dealer or licensed repair
garage and the taxicab returned to the city garage to pass inspection. For purposes of this
subsection, "authorized dealer" shall mean an automobile dealership which deals in that
particular make of automobile.
�2)
(3)
Every public vehicle st�all have a means to raise and lower windows and to open the doors from
the inside of the reaz passenger area, if so equipped by the manufacturer.
taYicab shall be eauioned with safetv belts for all passengers in both front and rear seats.
(4) Every taxicab, ', shall be equipped with a
taximeter in good working order, having a light, and sealed, and so placed as to enabie the
passenger at all times to see the fare registered when operating on the meter basis.;�€?:-��er:�tia�
l�'�q�i�,��;�Cr;���`��;i��al`;��E�S�:: No taacicab sha11 be operated except upon the meter or
hour basis.
(5) There shall be conspicuously displayed in the compartment of the taacicab occupied by the
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�2)
(3)
Demonstration of financial ability to operate taxicab services.
Adequate level of past service, if any.
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39 (b) If there aze more license applications than available licenses, the �sr. inspcctar �.;��i`e�s�
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40 shall ���;�ti recommend and-the city council shaH ��r3�,�those applications
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(6)
passenger and on the outside right and left rear doors ofthe taxicab a printed card or sign
showing the rate of faze charged, as hereinafter provided.
Each taxicab shall be equipped with a top light on the roof of the cab which shall be lighted when
the cab is in service and available to receive passengers. Such light shall be visible from all
directions.
(7) Each taxicab shall be equipped with a radio or mobile telephone capable of two-way voice
communication with the t�icab licensee's or affiliated licensee's base station from all locations
within the ciry limits. The radio or mobile phone shall be in ogeration at all times that the vehicle
is available for service or in service for the purpose of dispatching taxicabs and receiving calls
from drivers of such taxicabs. Every taxicab licensee shall provide �;-�ii*r'.�.��.,��.tf�;t��<� twenty-
four-hour taYicab service �gari��t�a�`��vi� am� twenty-four-hour radio dispatch service
within the city.
(8) The iictnse �:��',!�e��ti�;sha11 make, or haue made, by competent inspectors, such
examination and inspection before a license is issued. A license shall be refused to any vehicls
found to be unfit or unsuited for public patronage.°'
Section 4
Section 376.10. ofthe Saint Paul Legislative Cade is hereby amended to read as follows:
"Sec. 376.10. License--Issuance.
(a) Upon satisfactory fulfillment ofthe requirements of sections 376.08, 376.04 and the following
threshold criteria enumerated below, it shall be the duty of the license inspector to issue licenses
to qualified applicants. The threshold criteria shall be:
(1) Affiliation with a capable service company providing radio dispatching, advertising,
record keeping and other common services to a group of taxicab owners and operators
using a distinctive color scheme and company name.
lvi �/�\`l�IFYtl3�l.Olil�l��l�LK�fw PlR�1111�
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b c The ci council shall act on the iiceastins ��; recommendations and
t ) tp Pect°r`s..:""_.:.:.::
7 approve by resolurion, up to the number of authorized unissued public veMcle licenses, those
8 applications that meet or exceed the requirements of this section. Once approvecl, the license
9 inspector shall then issue each public vehicle license, which shall be in such form as customary."
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Section 5
14 Section 376.11.(b) of the Saint Paui Legislative Code is hereby amended to read as follows:
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"Sec. 376.11. Reguiations.
(b) License tags. There shall be delivered to the owner of each and every licensed public vehicle a
::i�;.ir �ii� v
meta� license ta� �r;to be fastened and displayed upon the outside of each and every pub c
vehicle so licensed, so that said license "" "''°
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tag,�f�� may be plainly visible at a11 times. Said license
ta��i�.'� shall not exceed s'vc (b) inches in the longest measurement, and shall bear the license
number of the public vehicle and the proper descriptive words, including the year for which the
license was issued, and such license tag;s�� shall be of distinctly different color for a� three
3 successive ears. In case an hcensee shall lose his or her license or mctat license `�� "'
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:.,-;......
or tag��icTce�s, he or she shall forthwith and before doing any further business procure a
duplicate license or duplicate license tag<�,�ek or tag;s¥�ctC�s, as the case may be, from the
`.;:,>:;:-:
inspector, and shall pay for such duplicate license or meta� license tag�t';,u�i; to said inspector
the sum of five dollars $5.00 for each and eve du licate license or metai license '� "� ""' so
� ) rY P �;�'�
procured."
Section 6
33 Section 376.11.(w) of the Saint Paul Legislative Code is hereby added to read as follows:
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"Sec. 37611. Regulations.
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� Section 7 �1 �. � - 1 g�
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This ordinance shall be in force and take effect t}rirty (30) days following its passage, approval, and
publication.
Q�����'��
� a �(� n ��, ao � t � Requested by Department of:
• R �
_} _
: 1/�j� /. '
By:
Approved by Mayor:
Byc
Date
Form Approved by City Attorney
By: ' ��o.no�/J � Ge.1'/Yilft
Approved by Mayor for Submission to Council
B ; A" l� 1, Ey��
by Council: Date �'�.���qqL
Fa:�s
Adoption Certified by Council Secretary
OFFICE OF LIEP
on
REQUESTED:
Date: 4j29/96
GREEN SHEET
N° 35213
ordinance to amend Chapter 376 of the LC pertaining to taxicabs; to
ogressively eliminate the cap on the number of licenses available, removing
e reference to metal license tags, simplifying the applicant selection
iteria for newly issued licenses, and making other minor housekeeping
NDATIONS: APPROVE (A1 OR REJECT (R)
NING CQ'�LNISSION CIVIL SERVTCE CONP7ISSI0
COMMTTTEE A BOSINESS REVIEW COUNCIL
e —
RSCT COURR
S WHICH COUNCIL OB�7ECTIVE7
PROBLEM, ISSUE�
'ANAL SERVICB CONTRACTS D1[JST ANSWER 'fH6 FOLLOSPiNO:
Has the personJfirm ever worked under a contract for this department?
YES NO
Has this personlfinm ever b?en a City employee?
YES NO
Does this petson/firm possess a skill not notroally possessed by any
Current City employae?
YES NO
.aia all YES answers oa a aepatate sheet and aYtach.
NITY (Who, What, When, Where, Why):
City of 5aint Paul has an increasingly poor service standard, according to
number of complaints received by the City. It is felt that to increase
number of licenses available will strengthen competition in triis industry,
improving the service standard.
roved service delivery. Will increase opportunity for businesses to come
Saint Paul.
ADVANTAGES IF APPROVED:
sent 5aint Paul taxicab companies will be forced to step up quality of
vice in order to compete with one another effectively.
ty will continue to enforce unnecessary regulations.
AMOUNT OF TRAN5ACTION S COST/REVENUE BUDGETED YES NQ
FUNDING SOURCE
FINANCIAL INFORMATION: (EXPLAIN)
ACTIVITY NUMBER
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SECTiOti a�g) IT THERE ARE MORE LICENSE APPLICATIONS THAN
AVRr�ABLc LICENCE, THE CIEP DIRECTOR SHALL EVALUATE AND
RECOi7MEND CITY C�UNCIL APPROVAL OF THDSE APPLIGATi0N5 THAT
DEMONSTRATE SUPERIOR SERVICE WTTH NEWEST AND SAFEST VEHICLES
(AS DETERMINED THROU�H THE CITY INSPECTION PROCESS), THE
MOST RELIABLE DRIVERS, AND THE BEST RECORD �F PREVIpUS
SERVICE.
1'HIS Ar�ENDMENt L.EFVES FAR TO hIUCf-I DISCRETIDN FOR THE
FDLLDW1tJG REA50N5:
1) CARS WILL NOT BE PURCHASED UIV7IL A LICENSE IS GRaNTEll.
2J MAKiNG COMPARISONS BETWEEN COriPANTES(SUPERI+QR SERVICE,
SAF�ST VEHICLES MOS7' RELIABLE DR NERS AND THE BEST RECORD OF"
PAST SERVICE) IS IMPOSSIBLE. HOW DO YDU COrIPARE CDMPANIES
THqT HAVE BEEN LICENSED IN ST. PAUL FOR 18 YEAR5 TO A PARTY
THAT HRS NEVER BEEfV LICE(VSED IN ST. PAU�? �R HOW DO YOU i
COMPARE a COMPANY THAT SERVIGES ALL GF ST.PAUL AND ONE THAT v
SERVIL'ES JUST AIRPORT RCCOUNTS? YOU CAN NDT COrIPARE APpLES �
AIVD ORANGES. d
A H�TI"ER F MI6HT BE SOMETHTN6 LIKE THIS.
1) IF AN ABANDONED LICEN6E WAS ATTACHED TO A COMPAIUY, THAT
COMPANY WQllLD HAVE THE PIRST �PTION OIV THE LIC�NSE.
2) LIL'LNS'E TO BE 6iVEN OUT SY F1 LQTTERY SY5TEM qFTER ALL
APPL ICf-17lONS' HAVG MET AT t_EAST THE FOLLOWING CONDI7IpNSc
A) FINANCIA� ASILI"fY.
B) L�CA"IE 6ARAGE IN ST. PAUL,
C) NO DUAL LICENSING EXCEPT FOR THE AIRPORT.
ll) DISTINCT LOLOR SCHEMES.
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�rC�.�
��b=_r�- 5'�-� � �
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summary Response C� � — ��S
to
Ordinances 96-485, 96-486, and Resoiution 96-479
(dated May 22, 1996)
• The Green Sheets contain a variety of misstatements and distortions.
• Poor service standard: Citizen Service Office numbers don't bear this out.
• lncreasing licenses strengthens competition: There is littfe evidence for this.
• Increased apportunity to draw new businesses: There are no incentives tor
existing smal{ businesses to grow.
Unnecessary regulations: LIEP shows littie understanding of what a
"necessary" ordinance is.
• Amendments to §376.05
• Saint Paul has only been able to support 85-95 cabs in the past. An
increase of 30 per year, for the next four years is far too much too fast.
♦ Amendments to §376.09
• Cabs should be leased on a 12-hour shift basis oniy. This protects the
safety of the driver, the passengers, and other vehicles on the road.
♦ Amendments to §376.10
• The new language still fails to clearfy speli out ail the criteria for issuance.
• Amendments to §376.11(b)
• Current taxicab {icense stickers are in violation of the existing ord+nance.
� Amendments to §376.12.(h)(3}(a}
• City officials do not have the right to sei2e State of Minnesota license plates.
� Amendments to §376.16.(e} and (k)
• This proposal could violate constitutional rights to privacy and due process.
• The taxicab industry views as tainted anything coming from the BRC.
��- ��
Summary Response
to
BRC Recommendation and Enciosure
(dated Jan. 30, 1996)
• The BRC failed to do due diligence before recommending removai of the cap
• The BRC disregarded virtuafly all evidence of negative effects in two studies
and dismissed testimony from members of the industry.
• Many cities cap the number of taxicab licenses.
♦ There is no evidence to show that there are not enough cabs.
• Licenses are sitting idie.
• The Citizen Service Office receives approximately 1 complaint per 30,000
service calls with oniy 1 per 300,000 service calis relating to promptness.
� L{EP has not made an annual report to the City Council regarding the
number of available licenses for the last two years.
♦ Saint Paui does not have the same ratio of cabs to population as Minneapolis.
• With no major sports arenas or as much night life, Saint Paui doesn't have
as much demand at this time.
• The BRC took initial testimony from the author of an industry study in Minneapolis.
• This individual admitted little familiariry with the industry in Saint Paui,
• The funding for this study was provided by a Minneapolis service company.
+ Existing city ordinances regulating the number and issuance of taxicab licenses
protect Saint Paul smali businesses from unfair competition and protect the safety
of citizens and visitors.
• Arguments to the contrary rely primarily on economic theories, not on past
experience or history
• Enc4osure: Entorcement irregularities in the Saint Paul Taxicab Ordinance
• LIEP is doing a remarkably poor job of regulating existing Iicenses and
enforcing city ordinances designed to protect the public.
� � - `�8`S
1616 Lafond Avenue
Saint Paui, MN 55102
- May 22, 1996
Counciimember Dave Thune
Office of the Ciiy Council
310 City Hall
Saint Paul, MN 55102
Dear Councilmember Thune:
I am writing to note some salient points regarding Ordinances 96-485, 96-486,
and Resolution 96-479 amending Chap. 376 of the City Legislative Code. This letter is
an updated addendum to another letter, dated Jan. 30, 1996, regarding to the Mayor's
Business Review Council's recommendation (dated Dec. 8, 1995) io lift the cap on tax-
icab licenses. ft wifl be heipful to have a copy of the Jan. 30, 1996 letter, the current
proposals, the BRC recommendation, and Chap. 376 of the Ciry Gode for reference.
Re Ordinance 86-485:
•"The City... has an increasingly poor service standard..."
• This argument is wholly without merit. Of the approximately 100 com-
plaints regarding taxicabs received by the Mayor's {nformation and
Complaint Office between Jan. 1, 1992, and Oct. 15, i995, haif were
against a singie company and only 10 were related to promptness.
Anecdota{ evidence indicates there are roughly 1 miilion service calis
dispatched per year in Saint Paul, the vast maiority having response
times welf under 20 minutes.
+"... [increasing] the number of licenses... wiil strengthen competition..."
• The LIEP Director has not made a report to the City Council for the
past two years regarding the number of licenses availabie as required
by §376.05(d[3]) of the City Legislative Code. it strains credibility
that increasing the number of licenses -- � any amount -- wiil
improve service when there are currently abandoned licenses that
have not yet been formally referred to the City Council for revocation.
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♦"Will increase opportunity for businesses to come to Saint Paul."
• These proposals contain nothing in the way of incentives #or existing
Saint Paul businesses to grow. It is hardly credibie that the City
wouid seek to destroy an existing loca! business and encourage non-
locals to take its p(ace and expand into Sa+nt Paul.
•"Present._. companies will be forced to step up quality of service..."
• There is already a healthy amount of competition among existing
companies: there is only so much fare and lease revenue to go
around for the drivers and owners respeetively.
• There is ample evidence that a large number of new entrants into the
market will result in a degradation in service quality (see references to
the Price Waterhouse and Hamline University studies in the 1/30/96
letter).
♦"City will continue to enfarce unnecessary regulations."
• LIEP has not adequately demonstrated that any regulations, many ot
which are for the safery and protection of the public, are u�necessary.
LIEP also has not shown that it can appropriately enforce many of the
existing regulations (see enclosure with 1/30/96 letter).
♦ Amendments to §376.05
•¶(a): It is a widely he{d opinion in the industry that an increase of this
magnitude is a recipe for disaster. As written, the train wreck will
already be history before anyone can be bothered to check the
brakes. if past history is any guide, of the ten licenses issued in May,
1994, two have been returned to the City, and two to four more are
failing to provide consisterrt service to the city. Historicaily, Saint Pau!
has only been abfe to support approximately 85-95 cabs, as judged
by the number of idle shifts for existing ficense hofders. As yet, LIEP
has not been able to reasonably demonstrate that there is a need to
increase the number of licenses.
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•¶(b-d): This +s an example of LIEP abdicating its fegitimate authority.
Neither the pubiic nor the industry are welf-served by these changes.
. Amendments to §376_08
•¶(c): The pubiic must be guaranteed the right to comment and be
heard on the issuance of business licenses.
. Amendments to §376.�9
•¶(4): The fanguage of this amendment would be much ciearer if the
author understood that a taximeter device operates on both a dis-
tance a�d time basis, It would be more accurate to require that "No
taxicab shall be operated except on the metered-fare basis". This
would be in keeping with the spirit of the archaic reference to the pasi-
tion of the taximeter's "flag" in §376.12(d).
•¶(7); This appears to be a minor housekeeping change, but it has very
serious implications for the health and safety ot both drivers and pas-
sengers. Specificaily, the existing language has historically been
interpreted to require cabs be leased on a 12-hour shift basis. The
new language clearly alfows cabs to be leased on a 24-hour (i.e.
weekly) basis. As a result, there is no way to reguiate how iong a
given driver may operate his/her cab. A driver leasing on a weekly
basis may put in 12-, 14-, or 16-hour days as much as 7 days a week.
Granted, few drivers would work like this, but some will. A driver on
duty much more than 60 hours per week poses a serious risk to
himselflherself, his/her passengers, and other drivers.
• Amendments to §376.10
• The proposed changes stifl faiis to explicitly spell out aIl criter+a for
issuance. This matter requires much more careful consideration and
consultation to prevent ad hoc decisions such as occurred when
iicenses were issued in May, 1994. The LIEP Director has already
pubiicly admitted that the selection process at that time was flawed.
3
�C�-`
+ Amendments to §376.11(b)
• This is a belated attempt to reflect the reality on the street. Since
i992, stickers have been used in place of inetai tags, yet no pubiic
notice of this change was ever given. Since i992, the stickers have
never contained the cab license number, or even a serial number, as
required by current ordinance. in ihe past, there have been instances
of interchanging trunk fids between vehicles, thus bypassing the nor-
mal inspection and license transferal process. The stickers also do
not aliow the license inspector to impound the taxicab license(s) of
any vehicie or licensee without doing damage to the vehicle.
Re Ordinance 96-486:
♦ Amendments to §376.12.(h)(3)(a):
• It is questionable that any city official has the right to seize the State of
Minnesota {icense plates of any vehicie, taxicab or otherwise.
• Amendments to §376.16(e) and (k):
� This proposal is dangerousiy fiawed. ft does not state who may
admin+ster the breathalyser test nor under what circumstances. it faiis
to recognize that a breathalyser will only show intoxication by aicohol,
but not any other type of drug. This proposal ra+ses serious constitu-
tionai questions regarding the right to privacy and due process.
Re Resolution 96-479:
♦¶1: "The BRC has heid extensive meetings during the last s+x months..."
• The Taxicab Regulation Committee has heid oniy two public meetings
in September and October, 1996. See further commerrts in the Jan.
30, 1996 letter to the Saint Paul City Councii.
•¶2: "The BRC... has determined... that lifting the cap wiii heip increase com-
petition and improve taxicab service in the long run..."
• The BRC also chose to ignore a significant body of evidence to the
contrary -- specifically Analvsis of Taxicab Deregulation and Re-
:�
��-L�,��
Regulation (Price Waterhouse,1993) and An Ana{ysis of Derepulation
and the Taxicab industrv (Giibertson et ai, Graduate Students,
Hamline University MAPA Program, 1995). However, the BRC gave
considerable weight to arguments presented in a document titled A
Documented Discussion on Taxicab Service in Minneapolis. it should
also be noted that the author of this study received funding for his
research from a tvcicab service company based in Minneapolis and
that his research supposediy reffected the situation in Minneapolis.
�¶3: "Several [industry] representatives have suggested... a ceiling and fioor
for taxicab fares... to further promote competition."
• The actual number of industry representatives advocating this change
is questionable. Traditionaily, this industry has competed quite effec-
tively on the quality of service, not price.
•¶9-10: "Staffing for the Taxicab Rate Review Committee shall be provided by
LIEP and... appointment[s to this committeej shall be confirmed by LIEP.
• It often appears that LIEP views iaxicab licensees as adversaries
rather than clients. Due to the severely jaundiced nature of this refa-
tionship, a"bfue-ribbon" panel appointed by the City Council and con-
sisting of regulatory personnel, owners, drivers, other business lead-
ers and members of the pubiic could begin to draft more solid legisia-
tion benefiting all concerned.
The legislation before you shou4d be viewed as a threat to the livelihoods of
those in the taxicab industry and to the safeiy and weil-being of the citizens and visi-
tors of Saint Paul, i strongly urge you to vote "NO" on ali three measures.
Sincerel yours
Robert Q. Stone
Licensed �axicab Driver #95520, City of Saint Paul
c: City Councilmembers
�
��-��'-s
CITY OF SAINT PAUL
INTERDEPAR'tMENTAL MEMOF2ANDUM
May 3l, 1496
To: City Councilmembers
Licensed Taxicab Owners
Fr: Robert Kessler, LIEP Director ��
Re: Taxicab Licensing Issues(Responses
Representatives of the taxicab industry raised a number of questions at the Public Hearing on May
22nd in regard to the proposal to add 30 taxicab licenses to the cunent cap of 120 licenses and
related matters. Stafffrom the Office of License, Inspections & Environmental Protection have
prepazed information in response to many of the questions raised. That infonnation is attached to
this report. There are, however, a number of overriding questions that need to be clarified at the
outset to frame the issue for the Counci]'s deliberations. These ovemding or salient issues are:
1. There are "oniy" a 100 complaints about tasicab service in the City over the last two
years—and most of those were For one company—So why are we trying to ra something that
isn't broken? We can not assume that the only complaints about taxicab service are received by
the City's Citizen Service Office. In addition, spat inspections performed by LIEP inspectors on
May 30, 1996, revealed that approximately one third of the cabs in the City did not have the
Citizen Service Office number posted inside the cab as required. In addition, customers calling
for and not receiving adequate service wou3d not know to call the City to lodge a complaint about
taxicab service. But most importantly, and the main reason behind this proposa�, is that the
genera! consensus of LIEP personnel, the Business Review Council, and many representatives of
the hospitality industry, is that taxicab service in Saint Paul, with few exceptions, is inadequate.
The most common concerns listed include old and diriy cabs; slow response times; and the poor
demeanor and personal appearance of some drivers. Unfortunately, the system is broken, but the
City can not and should not assume the responsibility fot insuring quality service. Graduai
increased comnetition is the best wav to imnrove service in the Citv.
2. Councilmember Gaerin compared the control of the number of taxicab ticenses to
controlling the number of liquor licenses saying that the justification for control is the same
for both. He is eacactly correct. Our purpose in adding licenses is to sei the number of taxicab
licenses high enough to ailow the mazket to establish the optimum number. This is what was done
by the City Council 10 years ago to end the trading and governmenta] control of liquor licenses.
There have been substantially more liquor licenses available since 1987 than the demand for
licenses. T'he main control that the City exercises over liquor licenses is WElERE in the City they
can be located. Even in those wards where the maximum number has been attained, (Wards
three, four and five) the City Council has the authority to add licenses by creating or adding to
special liquor development districts. This procedure has been used five rimes in the last four years
to add licenses in Wards 2, 3 and 6. A summary of the status of liquor licenses is attached for
your reference and peiusal.
Taxicab Report
May 31, 1996
Page 2
!.-R
3. Severat speakers questioned the motivation of the Business Tieview Counci! (BRC) -
and the procedures fotlowed in the discussion of the issae of conirolling the number of
Tazicab Licenses. The Business Review Council was scrupu]ous in the way it handled this
matter, and all similar issues concerning business interests of inembers. SINCE TF� PURPOSE
OF TF� BRC IS TO REVIEW BiJSINESS REGULATION ISSL7ES, IT FREQUENTLY
DISCUSSES MATTERS THAT CONCERN Tf� VITAL 1NTERESTS OF MEMBERS. In
addressing such matters the BRC foilows the spirit of the City's procedure concerning ConflicYs
of Interest (Chapter 100 of the Administrative Code). Although the procedure does not apply to
advisory committees in general, the BRC nonetheless routinely requires members to identify any
potential conflicts that ihey may have regarding matters that come before the Council, and then
the BRC requires these members refrain from voting on such matters. Besides the taxicab issue,
during The BTtC's review of the proposal to increase license fees for restaurants, the restaurant
owners on the B1tC stated iheir pocentiat bias and refrained from voting on the matter. Likewise,
representatives of the taxicab industry did not vote on recommendation to eliminate the cap on the
number of licenses.
The B12C spent many hours discussing whether Yhe City should continue to control the number of
Taxicab licenses. In general the BRC found the practice of controlling free market conditions
anYi-competitive. They were unamious in their recommendation to end controi of licenses and
ihey were not swayed by the testimony received from the industry which claimed that conuols
were essential to insure quality of service.
As you know the BRC is made up of mostly smaIl to medium sized business owners and
managers. They have a decidedly free market view, or bias. But as was pointed out by Henry
Kristal, as long as the City doesn't control the number of restaurants, he is certain that we
shouldn't control the number of taxicabs either.
4. Several speakers questioned whether "new" tazicab companies receiving Saint Paul
licenses would serve a1[ neighborhoods and not simply take the more lucrative airport runs
and ignore the shorfer runs. This will not be a probiem since there is no longer an exclnsive
Saint Paui taadcab line at the airport. In addition, the City will enforce the requirement that all
license holders affiliate with a 24 hour service company, and we will also enforce the regulation
that all service companies licensed in the City of Saint Paul must provide service to alI Saint Paul
neighborhoods.
5. Breathalyser Tests. The ordinance simply makes it possible for LIEP to take adverse
action against a driver or appticant who has flunked or refused to take a standard breathalyser
tesf. It does not give license personnel authority to administer such tests. That is appropriately
the responsibility of police. As the ordinance now stands we do not have clear authority to vse
the results of these tests.
b, Annaal Report on Licenses Not issved. .4ccording to the attached report from Troy
Gilbertson, There are 13 licenses that are not being used in ]996 which should be declared
available and reissued according to the procedures contained in Legislative Code Chapter 376. 24
(b). LIEP is asking the City Attomey to commence proceedings to revoke these licenses
unmediately so they can be reissued forthwith.
In 1995, there were no licenses deemed to be available as indicated in the report to the Caty
Tax'scab Report
May 31, 1996
Page 3
��- y�'S
-. " Operations Committee on July 12, 1995. However, LIEP did recommend last year, as we have
done so since 1990, that, for reasons of convenience and necessity, addiYiona] ticenses should be
approved, or the license cap lifted entirely, to increase competition and improve service. The City
Council took that matter under consideration, resulting in the current debate.
7. The Price Waterhouse Study cautions against d�regulation and points out that
cities that deregulated ended up re-regulating a short time later. A careful reading ofthe
Price Waterhouse study reveals that the Saint Paui approach is indeed a sound one. The report
states that:
The cities which employed a minimum standardc approach to market entry, which is a
mid poinf beltiveen full deregulation and full regulation of taxi services, likewise
reported no significant issues and accordingly have maintained this shucfure These
cities incTude (]) Ka»sas City, �ssouri (2) Fresno, Californin (3} Madison, �sconsin,
(4) Portlanr� Oregon (5) Tucson, Arizona and (6)1'acksom�ille, Florida The
minimum standards (eg. 24-hour dispatch capabilify) erercised in these cities act to
ruise the cost of markd extry, thus discouraging independent owner-operators rhat are
not affiliaied with a t¢ri cooperative or company.
It is precisely for this reason that LIEP recommends that the 24 hour dispatching requirement be
maintained. We are open to negotiation on the matter of fazes, only after the market has had the
opportunity to adjust to the additional licenses. Fazes should be addressed through the
establishment of a Taxicab Rate Committee made up of industry representatives.
8. Establish a"Blue Rib6on Committee" to review taaicab regulations and recommend
further changes and improvements. The BRC stands ready to work with the industry on this
invitation and welcomes the opportunity to recommend improvements in the City's regulations,
procedures, and priorities. The BRC invites interested industry representatives to attend the June
20 BRC Genera! Legislation Subcommittee meeting, chaired by William Huestis. An agenda and
meeting notice will be provided to license holders. The meeting is held at 8:00 a.m., Thursday,
June 20, 1996, in the LIEP Conference Room, 3rd Floor Lowry Professionai Building, 350 St.
Peter Street.
Please 1et me know if you have further questions regarding this matter.
c: Mayor Norm Coleman
Mark Shields, Chief of Staff
Fred Owusu, Citizen Service Director
Robert Sandquist, Equipment Services Manager
Phil Byrne, Assistant City Attomey
Cringer Palmer, Asssistant City Attomey
William Cosgrif� Business Review Council Chair
Business Review Council Members
License Managers & Enforcement Staff
' Arralysis of Taxicab Regulation and Deregulation, Price Waterhouse, Office of
Govemment 5ervices, Washington D.C., November, 1993.
orr�ce oF ucE�se. i�sric
ev�•teo�++E�r.u. reorrcrtov
Rohrq A"es>lcr. D�ncior
THE C1TY OF SAINT PAUL
.�'Ornt L'oleman..11aJ'or
. �.
_` i�1ay 28, 1996 -
To: Bob Kessler
Fr:
Re:
Troy Gilbertson
1495 Ta.�;icab Enforcement Update
L[1HH1'PRUfESS1U.1:qL XL•7I1J/.YG
Sw�e iDU
3S0 St. Prter $trret
Sam( Pad. }firsnru+m SS10'-/SIO
q�
T.�lrphnnr: C,L'-]GG.'7U'JO
FnCm�aife: (.1_-:66J0'l')
6/?-2Gl.97?J
I have attempted to address the issues requested by Councii based on 1995 records. All vehicles w�ere inspected
at least once in 1945 in addition to the biannual garage inspection except for 2 vehicles. Vehictes are selected at
random for spot inspections and generally given t���o days notice prior to the inspection. Spot inspections are
intended to ensure compliance between full garage inspections conducted in April and September. By giving 2
days notice, LIEP hopes to obtain compliance while keeping positive contact with the industry.
PERCENT FAiLI�'G IN 1995 SPOT INSPECTIONS
LIGHTS (headlights, tail iights, turnsignals, flashers)
DOOR HANDLES (inside and outside)
1�1I�illSI-I�LD
SEATBELTS
TIRES
TAXINIETER
INTERIOR (Seats, floor)
EXTERIQR (body damage)
12.5%
0%
I .6%
0%
17.5%
6.5%*
I5.0%
I 1.7%
*NOTE: LIEP plans to verify and seal ta�cimeters during ihe inspection �+�ith a lead City seal.
1943 CITATIONS
Failure to submit vehicles for inspection: 6 issued
L'nlicensed Taxicab driver: 6 issued
Failure to maintain trip sheets: 1 issued
BA�'DIT CABS
'_IEP regularly visits taYicabs parked in cab stands and inspects for driver licenses and vehicle licenses. I�To
written warnings have been issued. Cab stand visits are generaily more beneficia] as a contact with the industry
than for enforcement purposes.
THE CITY OF SAINT PAUL
.Ynnn Cnlrman. S1ay'or
;�9ay 31, 1496
To:
Fr:
Re:
Gary Pechmann
Troy Gilbertson�
Ol'FI('F OP IICE\SF,. I�SP�C7'10\S.�\'U
E\ \'I HO\ Af ENT:ll. !'ROTECTtOv
Rnher( A�<:cder, P+rrUOr
LUHR1"PXOF£S.SIOKAL BL7I1J/.tiG
Aule i 00
35G Sc Pcrer Strcet
$aimPan1,.11rnncsola 55/�_'-I510
�tEVISED Status of Annual Taxicab vehicle renewals
�!_���
Ta•Irphotte: C,/?-2G(r-')090
FoCSmnlr.' (rl:-_'GC-90Y9
(•1?-.C+6-Y/_'4
Annuai taxicab license renewals were due on or before Aprii 30, 1996. Several of the Saint Paul
licensed tzxicabs have not renewed, or renewed late.
Saint Paui Legislative Code chapter 376.12 (h)(3)c. indicates upon failure to submit to periodic
biannual inspections, these licenses shali be fonyarded to the City Council for consideration of
revocation. Following is a list of ] 3 abandoned cabs for which I am recommending that the
licenses be declared availabie and re-issued:
#09, 10, 53, & 64 City Wide Cab - The former license holder's estate attempted to
transfer the license and lost in court. LIEP renewed #9, and #64 pending outcome of the
case; however, all -S licenses shvlald now be reis�7red by coa��cil.
■ #52 Airport Taxi - No renewal documentation has been submitted to LIEP. This license
should reveri back to the City to be reisn�ed with all deliberate .rpeed.
■ #85 St. Pau1lVletro - LIEP issued a citation to Mr. 3ohn Sweeney last fall for failing to
submit to the biannual inspection due before October 1, 1995. As Mr. Sweeney was not
available for a court appearance, and presumed out of the state, the disposition was a
deduction from state income taxes, should Sweeney ever file personal income taxes in
Minnesota again. 77�e nehicle is not on t11e sb�eet and �he license should revert back tv tlae
City io be 7•eissned with all deliberale speed.
■ #86, 88, 91, & 92 Checker - L�F issued a citation to Mr. Wayne Joyce, DBA Checker
Cab last fall for failing to submit to the biannual inspection due before October l, 1995.
On December 12, 1995, I spoke with Ralph Hendrickson who informed me that Checker
had no vehicles in their possession. He promised me vehicles would be obtained within 30
days. Vehicles have not been obtained. These vehic7es are not o�t t1�e street and the
■
licenses should revert back to ihe City fo be reissued with all deliberate speed.
#87 City Wide - The license renewal application was submitted with payment prior to the
deadline but as of 5/&/96 the vehicle has not been submitted for inspection. This lice»se
shovld renert back to the Ciry and be re-issued
■
#93 Cl�ecker -A vehicle was submitted for inspection on 4l30/96. The vehicle did not
pass the inspection and has not paid the inspection fee yet. lhrs licc��rse shor�ld rererf
back �o the City curd be re-rssriec!
_ «_ ..;: -�_�_- ;-#i94 Gedion Adeda (Ittdependent operatoc��=A1r. Adeda has not submitted his vehicle or
any renewal documentation. He has not responded to any attempts to contact him and it
is unknown if his ta.ricab is operating. 77iis license shurdd renert !01he Crty to he reis.+7rcd
�rith a!I deliherafe syeed
In addition to the abandoned iicenses, there were sereral ]ate cab renewals. Many «�ere late
because the vehides �+�ere submitied for initia] inspection on the last possible day and ���ere not
approved. Submitting a vehicle in poor mechanicai condition on the lasi day for annual inspection
does not indicate a seriovs concern for puhlic safety. As an example to illusTrate the point, one
Saint Paul Taxicab failed the annual inspection, for among other things, a broken differential bolt.
Instead of simpty replacing the bolt, the vehicie was re-submitted with a bot[ head glued
ottto the broken bolt. Needless to say, the vehicle was not approved until proper repairs were
made. Obviously some license holders are not taking seriously their responsibitity to provide safe
vehicies.
Taxicab license renewal procedures are straightforward and the requirements are very reasonable,
but LIEP's best effoR at inspections and enforcement will not always be able to correct
inTentional attempts to circumvent the rules. There is no reason for a responsible ticense
holder not to comply and citations have been issued on the fottowing.
■ #11 City Wide Cab - Approved May 1, 1996 (after April 30, 1996 deadline).
■ #4I Twin City Yetlow Cab - Insurance certificate submitted May 17, 1996
(atier Apri130, 1996 deadiine).
■ ##94, 97, 98, & t03 Airport Sc Airline Taxi - Approved May �, 199b (after April 30,
1996 deadline).
■ #109 Minnesota Taxi - Approved May 5, 1996 (afrer Apri13Q 1996 deadline).
■ � 111 Diamond Cab - Approved May I, I996 (after Aprii 30, I946 deadline).
c: Robert Kessier, LIEP Director
Kris Schweinler, Seaior License Inspector
TaYicab License Holders
U1l7CL Of I Il'L\:tili. INSI'I �C I'IUA:ti .1\U
f \1"IROK5f1"\"IAI PKU"IlZ"il���
Xohert l:ts+lrr. DvcoJOt
THE CITY OF SAINT PAUL
?'onn Co%man, .1Juyor
June 3, 1996
To:
Fr:
Re:
Robert Kessler, LIEP Director
Ted Koeppl, LIEP��
ton ev rxot�.rsro,�: it h rninvc
Snile 300
350 Si Pvrrr Svee�
Saim 1'a�d, Sfinncsoln 5510?-lSIQ
Suspension Due to State Sales Tax Default
q►t-�iss
T.dephnne: l l? 26G-9090
/"ncnnlilr. GR-_'(6-J019
G/_'-'rG-ll?-1
This memo is in response to your request that LIEP ouiline the procedures it follow•s when a
licensed establishmeni is found by the Department of Commerce to be non-compliant with the
State of Minnesota sales ta� laws. The procedure follo��•ed by LIEP is as Sollows:
� The State Department of Conmierce informs LIEP, via letter, of establishments who are
delinquent in paying die appropriate sales tax.
� LIEP initiates adverse action against tl�e licensed estab3ishment, and the City Counci]
levies a suspension against the establishment for the period until the State issues a tax
clearance letter.
� LIEP sends a 3etter informing the establishment of their suspension and any other adverse
actions per the direction of the City Council.
� Upon receipt of the State ta� clearance letter, LIEP releases the suspension and sends a
letter informina the licensee that the establishment may be reopened.
It should be noted that the licensed establishment is free to do business as soon as the licensee
receives a copy of the c3earanee letter, and this sometimes precedes LIEP's receipt of the letter.
If there aze any furcher questions or concerns, please ca11 me at 266-9123.
q � -�Ib''�
C1TY OF SAINT PAUL 390 Cit}• Xu/1 Teirphone: 612-266-SSlD
Nartn Colernars, Macor IS West Xelingg 6oulerard £ncsimi(e: 612-266-8513
Sninr Paul, A1N 55102
May 28, 1996
Mr. Robert Stone
1616 LaFond Avenue
Saint Paul, IvTinnesota 55104
Dear Mr. Stone:
You have written several ]engthy leiters and lodged a number of compiaints with the Citizen
Service Office conceming taxicab regulation in the Ciry of Saint Paul. Robert Kessler, the
director of the Office of �,icense, Inspections and Environmental Protection (LIEP), is in the
process of responding to your inquiries, and most of the matters that you mentioned will be
addressed in his report to the City Council which is due before the end of the month.
However, there is at least one difference of opinion on the interpretation of the regu]ations
regarding the abandonmeni of licenses. Mr. Kessler points out that LIEP does not consider
failure to complete the annual inspection process on time as grounds for abandorunent. The bi-
annual inspections are a very high priority for LIEP, but they handle non-compiiance through the
civil and criminal en£orcement process rather than seeking abandonment of the license.
I am confident that most of your specific concerns will be answered. Nevertheless, I recognize
that there are major changes facing the taxicab industry as the City Council debates whether to
add more licenses, eliminate the license cap entirely, or try and maintain the status quo. The
changes the industry faces are not just about the number of licenses issued, or how strictly
regulations are enforced, or even the reduction in the number of city license inspectors. They
have more to do with the fundamental change in the relationship between government and
industry.- Csovernment, especiatlg local- govemment, can no longer assume the burden of insuring
quality service for the private sector. Quality is a fundamental responsibility of the private sector
and no amount of government regulation can substitute for good customer service.
On the other hand, govemment does have the responsibility to insure basic health and safety for
citizens, and to provide essential services that can not be provided by the private sector.
Robert Stone
May 28, ]996
Page 2
__-_-=Cflnuolfing priv�t�marke� c�nditioasis�otsorriethinglhai locaf government should do. But we
---`-d��have;the.respons�biliiy-iu�rvark vvsih.�outo help al] affected adjust to tfie new set of -
" ciicumstances that govemment and bi�sinesses face in tod"ay's economy of limited resources and
globa! compeiition.
I appreciateyovr concems and ihank you for taking the time to express your views so cogently.
Sincerely,
�� � �--� � �`�L
Norm Coleman
Mayor
c: City Councitmembers
Fred Owusu, Directar of Citizen Sen�ce
Robert Kessler, LTEP D'uector
Licensed Taxicab Owners
CITY OF SAINT PAUL
1996 ON-SALE LIQUOR LICENSE AVAILABILITY (MAl7
ESTABLISHED � ADDED IN ' ALLOWASLE
MAXIM� 1M �990 WITH CLUBS
0
LICENSES
MAY 1996'
TOTAL LICENSES ISSUED IN WARDS I -�di
qC-4�
11�L•Tlr���d
� L - �G>
Chapter 100. City Committees--Conflicts of interest*
~ *Cross reference(s}--Coce of ethics, Ch. 24.
Sec. 100.01. De£initions.
The terms used in this c�apter are hereby defined as
follows:
(1) Association. Busine<s, cozporation, firm, partnership,
limited partnership, corvnittee, labor organization,
club or any other group of two (2) or more persons,
which includes more than an immediate family, acting in
concert.
(2) Business with which an individual is associated.
(a) Any associatioa doing business in Minnesota in
connection with which an individual is compensated
in excess of fzfty dollars ($50.00) er:cept for
actual and rezsonable expenses in any month as a
= director, officer, owner, member, partner,
employer or er.�ployee, or is holder of securities
worth two thousand five hundred ($2,500.00) or
• more at fair narket valve.
(b) Any associatioa doing business in Minnesota in
connection wit4 which an individual owes money
except for customary household expenses, retail
credit accounts, and mortgage contracts on the
principal place of dwelling.
(3) Financial. interest. Any interest which sha11 yield,
directly or indirectly, a monetary or other material
benefit (other than duly authorized salary or
compensation for services to the city) to the appointed
member, the spouse of the appointed member and all
minor children within the custody and control of the
appointed member.
(4) Appointed member. A pezson appointed by the mayor and
approved by the city council to any advisory body,
including, but not limited to, boards, commissions,
committees and task forces established by the city.
{Ord. No. 17503, 5 1, 10-20-87)
Sec. 100.02. Conflicts of interest.
(a) Any appointed member who in the discharge of official
duties would be required to take an action or make a decision
,-
substantially
business with
the following
af£ectinq financial interests or those of a
which the appointed member is associated shall take
actions:
-. .(3) Within forty-eiqht (48)_hours of an appointed member's
_-_ - _. -=� - � =c�iscovery, that �e has a -co-nflict of interest, he shall
-,'-- -'='�`_ �=� prepare a- writ�en statement describing the matter
,_>: _.._ -
-"�=equiring-actiori or decision and the nature of the
conflict of interest.
(2) File cooies with t}:e city clerk and the chair of the
advisory bocy.
(3) If a conflict of interest presents itself and there is
insufficient time to deliver a written statement as
required herein, the appointed member shall verbaZly
advise the advisory body of the potential conflict. A
written statement shall then be delivered to the city
clerk and the chair of the advisory body within one
ti*eek after the conflict of interest presents itself.
(b) The apgointed nember who has a conflict o£ interest, as
cefined in paragraph (a) of this section, shall refrain from
voting on or otherwise participating in the action or decision
with which there is a conflict o£ interest. An appointed member
is specifically exempted fron the prohibitions of this paragraph
when the action to be taken or �he decision to be rendered is one
hhich is solely advisory. '
(Ord. No. 17503, § 1, 10-2d-87}
Sec. 100.03. Sanction.
Any appointed member violating the provisions of Section
100.02 may be removed from the appointive position by the mayor
with the consent of the city council. Violation of this section
may render the action taken �oidable by the city council or by a
court of competent 7urisdict?on. Any monies paid as a result of
such violation may be recovered by a joint and several action
£rom the parties to the action and the appointed member
3nterested in the same.
�.. .
(Ozd. No. 17503, § 1, 10-20-87)
"The Cab Call o s�. rut,Y �
\�
JUNE 3, 1996
CITY W1DE CAB GO.
292-1616
340 Atwater St.
St. Paui, MN 55i17
llEAR COUNCILMEMBER:
'THERE ARE TWO VERY�TMPORTANT ISSUES BEFORE YOU'ABOUT
REGULATING TAXICAflS. .
! Snfcty
• Comfort
• co�.T�Ggy
. I.ow Raccs
q�.WSS
ONE THE ADDITSON OF MORE LICENSE. I FIRMLY BELIEVE TFiE
ADDING OF ANY ADDITIONAL LICENSE OVER THE�120 THE1T ARE NOW
AVAILABLR WILL NOT ONLY HURT THE INDUSTRX BUT THE QUALITY OF
SERVICE. IT IS VSRY HARD AT THIS TIME TO GET QUALIFIED
llRIVERS ADllING MORE LICENSE WILL MAKE THAT EVEN MORE
llIEBICC3LT. IT IS ALSO HARD FOR THS DRIVERS TO MAKE A AECENT
LIVING ESPECIALLY IN THE SUMMER TIME. ALSO THE COMPLAINT
CALL RftTIO DOSS NOT INDICATE THAT ST. PAUL T$ NOT RECEIVING
GOOD �ERVICE AT 2HIS TIME.
TWd THE WAY ABANDONED OR NEW LSCENSE ARE ISSUED. AN
ASANDONFSD LICENSE THAT HAD PREVIOtJSLY BEEN OPERATED WITH A
COMPANY, 'PHAT COMPANY SHOULD HAVE RIRST OPTION OF RPiEPTNG
THAT LIrENSE IF THEX MEET ALI, OTHSR QUALIFICATIONS."
AN EXAMPL�: CITY WIDE CAB CQ. HAS 4 LICENSE THAT $SLONGE.0 Tq
JAMES , JOfIANN�S WHO PASSED AWAY. LIEP WAI3TS TO TAKF. T'HE �E
LICENSF. FROM CI'I'Y WIDE. THIS WOULD LOWER THE AMOUNT' OF' CABS
IN C�UR FLEE'P CAUSING POOI2 SEkVICE. �
FOR ANY LICENSE THAT AfiS ABANDONED AND THAT ARE NOT PICKED
UP BY TEiE•AFFILIATED COMPANX OR ADDED LICENSE THERE SfiOULD
BE A LOTTERY FOR ALL THOSE WHO MEET THE QUALIFICATIONS SET
BY THE CI'TYCOUNCIL. AT LEAST ONE OF THF QUALIFICATIONS
SHQULD BE THAT THE CABS ARE GARAGED IN ST. PAUL. THIS WTLi,
HELP TU PUT ST. PAUL PEQPLE TO WORK, IT WOULD ALSO INSUR�
THAT CITY SALES TAX IS PAID. WHAT EVER @UALIFICATIONS YOU
SET SHOULD BE FIRM SO SVERYSODY KNOW5 WHAT RULES WE AKF�
PLAYING IIUY. NOT AS LIEP HAS SUGGES�ED, B�ST CARS> BEST
DRIVERS ETC.
TFiANR YOU FOR TAKING YOUR TIME TO REVIE47 THIS MAT'TER.
SINCS� Lr���
�
P. A. BURKET—JONES
GENERAL MANAGER
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