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STAFF REPORT

January 4, 2000

To: Budget Advisory Committee

From: City Auditor

Subject: Review of Parking Enforcement Unit, Toronto Police Service

Purpose:

To report on the review of the Parking Enforcement Unit of the Toronto Police Service, completed in accordance with Audit Services 1999 Work Plan, and as requested by the

Budget Committee.

Financial Implications and Impact Statement:

Implementation of certain recommendations in this report may result in adjustments to the operating budgets of the Parking Enforcement Unit, Toronto Police Service and the Parking Tags Operation Unit, City Finance in 2000 and subsequent years, as well as the City's parking tag revenue.

Recommendations:

It is recommended that:

(1) the Chief of Police report to the Policy and Finance Committee by September 30, 2000 on the results of the parking enforcement consolidation. The report should provide:

(a) a detailed analysis of the Parking Enforcement Unit's annual operating cost increase resulting from the consolidation;

(b) a comparison of the Parking Enforcement Unit's actual results with the projected financial and operational benefits included in the report which recommended the consolidation;

(c) any initiatives planned by the Parking Enforcement Unit to improve its operations and thereby reduce the annual cost of enforcement and optimize revenue to the City;

(2) the Chief of Police review the current organizational structure of the Parking Enforcement Unit with a view to eliminating at least one level of management and the associated positions, reassess the number of area supervisors required, and report to the Policy and Finance Committee by September 30, 2000;

(3) The Chief of Police report to the Policy and Finance Committee by September 30, 2000 on the progress of the civilianization of the Parking Enforcement Unit; and

(4) the Chief of Police review the administrative and support functions in the Parking Enforcement Unit with a view to rationalizing these services by re-deploying parking enforcement officers to direct enforcement duties and eliminating certain functions that could be more cost-effectively provided by the Toronto Police Service or the City, and report to the Policy and Finance Committee by September 30, 2000;

(5) the Chief of Police report to the Policy and Finance Committee by September 30, 2000 on whether the current number of parking enforcement officers are sufficient to meet the enforcement requirements in the City, and the costs and benefits of any proposed changes in the unit's establishment, including the effect on total tag issuance;

(6) the Parking Enforcement Unit review the level of enforcement activity during off-peak periods with a view to reducing the number of officers assigned during these periods and re-deploying the officers to other times when there is greater demand for enforcement;

(7) the Parking Enforcement Unit consider assigning certain officers in each platoon with the responsibility of handling service calls and complaints, on a rotating basis, and having the remaining officers dedicated to tag issuance;

(8) the Parking Enforcement Unit review the level of tag issuance by platoon supervisors and confirm the platoon supervisors' responsibilities in this regard; and

(9) the Chief of Police review the requirement for parking enforcement officers to report to their respective office at the start of each shift, and report to the Policy and Finance Committee by September 30, 2000 on the need for this procedure and the costs and benefits of other alternatives.

(10) the Chief of Police, in consultation with the City's Executive Director, Facilities and Real Estate, assess and develop an action plan with respect to the office space requirements of the Parking Enforcement Unit and report to the Policy and Finance Committee by September 30, 2000 on the cost of terminating the current leases and the options available to the unit, including the costs and benefits of operating out of one location. The office space assessment should be completed in the context of the City's space rationalization plan, taking into account the unit's operational requirements, optimal location and the estimated cost of other locations, including City-owned properties;

(11) the Parking Enforcement Unit charge City Finance the annual rental cost of the First Appearance Facilities, and the 2000 budgets of both the Parking Enforcement Unit and Parking Tag Operations Unit of City Finance be adjusted accordingly;

(12) the Parking Enforcement Unit enhance the performance review process, currently being developed for implementation in 2000, to include other performance indicators and benchmarking with other comparable organizations, that would further assist in measuring the benefits and effectiveness of the unit;

(13) the Parking Enforcement Unit include the number of tags that are withdrawn upon officer request or replaced by another tag in calculating the non-processible rate, in order to better measure officer performance;

(14) the Parking Enforcement Unit, in consultation with the appropriate City officials, expedite the drafting of a uniform by-law that consolidates all existing parking-related by-laws of the former area municipalities;

(15) the City's Chief Financial Officer and Treasurer enhance the current quarterly parking tag report submitted to the Administration Committee to include information on the average number of parking enforcement officers deployed each month, average issuance per officer, non-processible rate (broken down between officer controllable and non-controllable) and the absenteeism rate for the Parking Enforcement Unit; and that the unit provide the necessary information to City Finance in this regard;

(16) the Parking Enforcement Unit establish an acceptable absenteeism rate and continue to monitor absenteeism in order to determine the effectiveness of the unit's absenteeism reduction initiatives and take any additional action required. In addition, the absenteeism rate should be compared periodically to other comparable organizations and jurisdictions;

(17) the City's Executive Director, Human Resources, report to the Administration Committee by September 30, 2000 on a framework for reporting absenteeism across the corporation, which should include the development of appropriate definitions and reporting guidelines, to enable a meaningful comparison of absenteeism among the various departments, agencies, boards and commissions;

(18) the Parking Enforcement Unit investigate the reasons for unmatched data between the City Parking Tag Management System and the Toronto Police Service Data Entry Control System and take appropriate action to ensure that the unit's Parking Information System contains a more accurate and complete record of parking tag information;

(19) the Parking Enforcement Unit implement procedures to ensure that the parking tag information received from the City Parking Tag Management system is complete;

(20) the Parking Enforcement Unit, in consultation with appropriate Toronto Police Service personnel, review the current overhead charges in detail and determine whether a more reasonable basis of allocation can be used to fairly reflect the actual costs of the services provided to the unit. Support for the basis of allocation should be documented in writing and reviewed annually, making appropriate changes as required;

(21) Parking Enforcement and City Parking Tag Operations staff meet with potential hand-held ticket issuing equipment suppliers to explore possible solutions that would enable the paper used by hand-held ticket issuing equipment to be processed through the banking system;

(22) the Chief of Police, in consultation with the City's Chief Financial Officer and Treasurer, prepare a complete cost benefit analysis and identify any issues with respect to the use of hand-held ticket issuing equipment by parking enforcement officers, and report to the Policy and Finance Committee by September 30, 2000;

(23) the Parking Enforcement Unit develop a strategy to promote the use of certified municipal law enforcement agencies by property owners and develop appropriate policies and procedures to monitor the performance of these agencies;

(24) the Parking Enforcement Unit expedite the finalization of the by-laws with respect to unifying parking enforcement activities on private property and defining the role and responsibilities of the Chief of Police in the Municipal Law Enforcement Officer Program, so that these by-laws are submitted to City Council for approval by September 30, 2000;

(25) the Parking Enforcement Unit enhance the performance standards used by the unit to include the level of non-processible tags issued by municipal law enforcement officers;

(26) the Parking Enforcement Unit develop an implementation plan with specific timelines to address the recommendations contained in this report, such that the resulting budgetary adjustments are incorporated and considered in the 2001 budget; and

(27) this report be forwarded to the Toronto Police Services Board and that the board be requested to report back to the Policy and Finance Committee, by March 30, 2000, on its response to each of the recommendations contained in this report.

Background:

The Parking Enforcement Unit of the Toronto Police Service is responsible for the enforcement of the City of Toronto's parking by-laws to facilitate traffic and transit flow. In addition to issuing parking tags, the unit handles complaints from the public and is responsible for administering the Municipal Law Enforcement Officer (MLEO) Program, which includes the training, supervision and certification of MLEOs.

In 1993, the former Metro Council approved the consolidation of all parking enforcement related activities under one centralized command. Parking enforcement activities were previously decentralized and operated out of the various police divisions.

The cost of the Parking Enforcement Unit is provided for in the City's corporate sundry at large budget and is recovered by the police from the City, on a fee-for-service basis. The unit's approved 1999 operating budget was $21.5 million. The unit is responsible for the issuance of approximately 90 percent of the total parking tags issued in the City, which translates to approximately $43 million in revenue. This level of revenue is based on the unit's total tag issuance of approximately 2.3 million tags, a 78 percent collection rate and a per tag value of about $24. Overall revenue generated from the issuance of parking tags, including those issued by police officers and MLEOs is approximately $48 million annually.

The 1999 Audit Work Plan approved by Council included a review of the Parking Enforcement Unit. Further, the Budget Committee requested that the City Auditor review the Parking Enforcement Unit's operations prior to the year 2000 budget deliberations, as well as the unit's absenteeism rate in comparison to other agencies, boards and commissions.

It should also be noted that in October 1998, Council requested the Chief Administrative Officer to report on the feasibility of incorporating parking enforcement and other related parking functions into an authority or department. The Chief Administrator's Office is in the process of finalizing this review and will be reporting to the appropriate standing committee accordingly.

The overall objective of our review was to determine how effectively and efficiently the Parking Enforcement Unit is carrying out its mandate and whether any budgetary efficiencies can be effected for the unit's 2000 and subsequent years' budgets. Specifically, our review included an assessment of:

- whether the policies, systems and procedures of the Parking Enforcement Unit are appropriate toward achieving efficient, effective and economical operations;

- the effectiveness of the unit's organizational structure and staff deployment to ensure maximum productivity at minimal cost;

- the effectiveness of the unit's management information system in providing accurate, complete and timely information to assist the unit in managing its operations and performance; and

- the reasonableness of the unit's performance indicators and how well the unit is achieving these performance standards.

The results of our review, including observations, conclusions and recommendations are provided below. A "one page report", summarizing significant observations, is provided as Appendix A to this report.

Comments:

Consolidation of the Parking Enforcement Function

In April 1993, Metro Council approved the consolidation of the parking enforcement function. Prior to consolidation, the parking enforcement function was operated from 24 sites, with 193 parking enforcement officers (a mix of uniform and civilian officers) assigned to police divisions. In addition, 56 officers and 45 cadets were assigned to Traffic Support Services to perform solely parking enforcement activities. Policy and direction were provided through each of these units. As a result, the enforcement function was often seen as slow and disjointed in its reaction to parking-related issues.

When approving the consolidation, Metro Council requested that:

- the consolidated operation be reviewed after a year and a half;

- a three-year budget and operating plan be submitted; and

- a performance review and an economic analysis of the consolidated unit be submitted annually.

In December 1995, the Toronto Police Service submitted a preliminary report on the status of the consolidation and a restructuring plan. However, because it was difficult to measure operational results of several new initiatives that were in the midst of implementation at the time, Metro Council approved the deferral of the post consolidation review for one year. To date, Council has yet to receive a full report on whether the consolidated function has delivered the operational and financial benefits expected.

Since the consolidation, the annual budget of the parking enforcement function has grown from $15.5 million in 1993 to $21.5 million in 1999, an increase of $6 million. During the same period, tag issuance by parking enforcement officers increased from 2 million to 2.3 million. However, this increase was offset by a corresponding decline in tag issuance by both the police and municipal law enforcement officers. Consequently, total tag issuance has remained relatively constant at about 2.5 million, as illustrated in the graph above.

The consolidation of the parking enforcement has resulted in a more cohesive unit, which now provides a more consistent and focused approach to parking enforcement and has allowed uniform police officers to concentrate their efforts on policing functions.

However, notwithstanding the aforementioned benefits, the level of issuance is significantly lower than the 2.9 million tags projected by Toronto Police Service at the time of consolidation. As such, the additional cost of consolidation has not been offset by a corresponding increase in revenue, resulting in a significant reduction in net revenue to the City.

It is recommended that:

1. the Chief of Police report to the Policy and Finance Committee by September 30, 2000 on the results of the parking enforcement consolidation. The report should provide:

(a) a detailed analysis of the Parking Enforcement Unit's annual operating cost increase resulting from the consolidation;

(b) a comparison of the Parking Enforcement Unit's actual results with the projected financial and operational benefits included in the report which recommended the consolidation; and

(c) any initiatives planned by the Parking Enforcement Unit to improve its operations and thereby reduce the annual cost of enforcement and optimize revenue to the City.

Organizational Structure

The Parking Enforcement Unit consists of 341 personnel. Five senior positions in the unit are held by uniform police officers, while the rest of the workforce consists of civilian employees, 297 of whom are parking enforcement and towing officers (PETs).

The Parking Enforcement Unit is divided into two districts, East and West, and also has a support services section. Each district has a staff sergeant, sergeant, operations area supervisor and a number of area supervisors and platoon supervisors. The need for the current number of management and supervisory layers is questionable. In our view, there is an opportunity to streamline the operation by eliminating at least one level of management.

There are currently 12 area supervisors who liaise with the community and elected officials and assess enforcement requirements, consistent with the police's community-based policing strategy. While we agree that these positions are required, there is a need to reassess the actual number of area supervisors currently deployed to perform this function. Area supervisors no longer required could be re-deployed to direct enforcement activities as PETs.

Currently, the unit has five uniform police personnel. In a report to the Budget Committee, dated August 28, 1998, the Toronto Police Service indicated that it would achieve full civilianization of the unit in 1998. This has yet to occur and while the unit has planned to reduce the number of uniform personnel, it has been unable to do so mainly due to the fact that the unit's senior management has changed several times over the six-year period following the consolidation. In addition to civilianizing the unit, it would be appropriate that key senior positions are staffed on a longer-term basis, in order to ensure the continuity of operations and that initiatives undertaken are fully implemented.

Approximately 25 percent of the unit's complement, or 85 employees, are involved in functions other than direct enforcement. These employees include management personnel, clerical staff, area supervisors and PETs assigned to non-patrol functions such as administrative and support, MLEO program, customer service, training, graphics, etc. In our view, certain of these functions and positions can be eliminated or re-assigned, and the PETs re-deployed to direct enforcement duties. In addition, the unit could alternatively utilize administrative and support services provided by the police or the City, where cost-effective.

It is recommended that:

2. the Chief of Police review the current organizational structure of the Parking Enforcement Unit with a view to eliminating at least one level of management and the associated positions, reassess the number of area supervisors required, and report to the Policy and Finance Committee by September 30, 2000;

3. The Chief of Police report to the Policy and Finance Committee by September 30, 2000 on the progress of the civilianization of the Parking Enforcement Unit; and

4. the Chief of Police review the administrative and support functions in the Parking Enforcement Unit with a view to rationalizing these services by re-deploying parking enforcement officers to direct enforcement duties and eliminating certain functions that could be more cost-effectively provided by the Toronto Police Service or the City, and report to the Policy and Finance Committee by September 30, 2000.

Operations

The Parking Enforcement Unit is responsible for the issuance of parking tags for infractions under Part II of the Provincial Offences Act, as well as the handling of complaints and responding to service calls. The unit provides 24-hour enforcement throughout the City through the deployment of parking enforcement and towing officers (PETs).

The Parking Enforcement Unit's total workforce consists of 297 PETs, deployed as follows:

No. of PETs % Total

Patrol duties:

Platoon supervisors 28 9.4

Regular patrol 215 72.4

Light patrol 11 3.7

254 85.5

Non-patrol duties:

Area supervisors 14 4.7

Administration and support 14 4.7

Light duties - administration and support 15 5.1

43 14.5

Total PETs 297 100.0

Although the number of officers assigned to direct enforcement duties varied from year to year, the total number of parking enforcement officers in the unit has remained relatively the same since the consolidation. At the time of consolidation, it was expected that a significant number of additional officers would be hired. It is unclear whether the unit has the optimal number of officers required to ensure proper and effective enforcement throughout the city.

Parking enforcement officers who are assigned to patrol duty are grouped into six platoons, each reporting to a platoon supervisor. Of the six platoons, one platoon of 70 officers is dedicated to the issuance of tags in high enforcement demand areas during weekdays, working in three 8-hour shifts. The other five platoons are responsible for tag issuance as well as for service call responses and complaint follow-up throughout the week. These platoons, each consisting of 26 to 29 officers, are scheduled based on a compressed work week cycle, covering 24 hours daily in three shifts.

At the beginning and end of each shift, parking enforcement officers are required to report to the office to collect and return tag books, radios and vehicles and meet for a "parade" during which officers are briefed on policy procedure updates, special assignments or other matters. Having the officers report to the office also ensures that they are in proper uniform at the start of their shift. We recognize that this procedure is standard practice in other areas of police. However, the applicability of this requirement in a parking enforcement environment should be reviewed, since it reduces the time available for enforcement duties.

Currently, 254 officers or 75 percent of the unit's workforce are deployed in direct enforcement activities, including tag issuance. In our view, there are opportunities for management to re-deploy existing officers in order to more effectively utilize its resources, as follows.

Firstly, the number of officers deployed during off peak periods, such as between 2:00 a.m. and 6:00 a.m. when the need for parking enforcement is generally lower, could be reduced and the officers reassigned to other times when there is greater demand for enforcement.

Secondly, it may be more efficient, operationally, to assign certain officers in each platoon the responsibility of handling service calls and complaints, on a rotating basis, and having the remaining officers dedicated to tag issuance. This would also facilitate the measurement of officer performance as well as assist in monitoring the amount of time spent responding to service calls and complaints.

Finally, there is a need to monitor the platoon supervisors' performance with respect to tag issuance and confirm their responsibility in this regard, since very few of these supervisors actually issue tags, even though it is a part of their responsibility.

It is recommended that:

5. the Chief of Police report to the Policy and Finance Committee by September 30, 2000 on whether the current number of parking enforcement officers are sufficient to meet the enforcement requirements in the City, and the costs and benefits of any proposed changes in the unit's establishment, including the effect on total tag issuance;

6. the Parking Enforcement Unit review the level of enforcement activity during off-peak periods with a view to reducing the number of officers assigned during these periods and re-deploying the officers to other times when there is greater demand for enforcement;

7. the Parking Enforcement Unit consider assigning certain officers in each platoon with the responsibility of handling service calls and complaints, on a rotating basis, and having the remaining officers dedicated to tag issuance;

8. the Parking Enforcement Unit review the level of tag issuance by platoon supervisors and confirm the platoon supervisors' responsibilities in this regard; and

9. the Chief of Police review the requirement for parking enforcement officers to report to their respective office at the start of each shift, and report to the Policy and Finance Committee by September 30, 2000 on the need for this procedure and the costs and benefits of other alternatives.

Office Location

The Parking Enforcement Unit operates from leased premises at 1500 Don Mills Road and 970 Lawrence Avenue West. The headquarters at 1500 Don Mills Road consist of 36,500 square feet of office space, storage and change-room facilities. Total office space at 970 Lawrence Avenue is about 11,000 square feet. The total rental cost of the two sites is approximately $1.1 million per year. Both rental agreements, approved by the former Metro Council, are 10-year leases expiring in June 2004 and December 2005, respectively.

A portion of office space at 1500 Don Mills Road is currently vacant. The space requirement analysis completed in 1993 included approximately 7,500 square feet of additional space to accommodate a planned staff size of 671 in the year 2003. Management has now indicated that the current staff complement of 341 will likely remain constant and therefore any current excess space is not required.

Approximately 77 percent of the tags currently issued are within the geographic boundaries of the former City of Toronto, and about 50 percent of the officers are assigned to patrol this area. However, since the two offices are both situated outside of this core, officers must travel to and from their respective headquarters and assigned patrol routes at the beginning and end of their shifts, reducing the amount of time they actually spend on enforcement. Relocating the offices closer to the high volume enforcement area would reduce travel time and therefore increase productivity. The potential also exists to consolidate the two offices into one central office, which could result in administrative efficiencies and cost savings.

While Parking Enforcement staff acknowledge the benefits of relocating the offices, the long term leases entered into by management at the time of the consolidation make it difficult to take any corrective action until the leases expire in 2004 and 2005. A preliminary review by the City's Facilities and Real Estate Division indicated that terminating the leases at this time would result in significant penalty costs. Nonetheless, the Parking Enforcement Unit should confirm its actual space requirements and start the search for potential office location(s) which would best serve the needs of the unit.

It should also be noted that both Parking Enforcement district offices provide space for First Appearance Facilities. The responsibility for operating these First Appearance Facilities was transferred from the Parking Enforcement Unit to City Finance in mid-1996. However, the annual rental cost for these facilities, estimated at $130,000, is still borne by the unit. In order to reflect the actual annual cost of both the Parking Enforcement Unit and Parking Tag Operations Unit, City Finance, the rental cost for the First Appearance Facilities should be charged back to City Finance.

It is recommended that:

10. the Chief of Police, in consultation with the City's Executive Director, Facilities and Real Estate, assess and develop an action plan with respect to the office space requirements of the Parking Enforcement Unit and report to the Policy and Finance Committee by September 30, 2000 on the cost of terminating the current leases and the options available to the unit, including the costs and benefits of operating out of one location. The office space assessment should be completed in the context of the City's space rationalization plan, taking into account the unit's operational requirements, optimal location and the estimated cost of other locations, including City-owned properties; and

11. the Parking Enforcement Unit charge City Finance the annual rental cost of the First Appearance Facilities, and the 2000 budgets of both the Parking Enforcement Unit and Parking Tag Operations Unit of City Finance be adjusted accordingly.

Performance Indicators

In the 1993 report recommending the consolidation, parking enforcement staff indicated that a consolidated parking enforcement operation would provide the benefits of improved traffic and transit flow, reduced demand on police resources to address parking issues, effective response to community and municipal concerns, and increased parking tag issuance.

The Parking Enforcement Unit issues approximately 90 percent of the total parking tags issued in the City, which translates into approximately $43 million in revenue. Consequently, the level of tag issuance and the quality of tags issued, which are under the control of the unit, have a significant impact on parking tag revenue.

The unit is currently developing a formal performance review process to be implemented in 2000, which sets performance standards relating to parking tag issuance, non-processible tags, non-patrol hours and absenteeism. These standards will assist the unit in better managing its operations.

As discussed previously, changes to the organizational structure and re-deployment of officers can result in increased productivity. Other factors affecting the level of tag issuance are non-patrol hours and absenteeism rate, which the unit is currently monitoring. It is important, however, that any reductions in the non-patrol hours and absenteeism rate are linked to corresponding increases in enforcement activities.

Of the total tags issued by parking enforcement officers in 1998, approximately 5.5 percent or 123,000 parking tags, with an estimated value of $2.3 million, were not processed due to reasons classified as officer controllable. This non-processible rate decreased from 7 percent in 1997 and has further declined to 4.6 percent in the first half of 1999. A breakdown of the reasons for non-processible tags is shown in the adjacent graph.

It should also be noted that approximately another one percent of the parking tags issued by the unit are either withdrawn upon the request of the issuing officer or replaced by another tag. These parking tags are not included in the calculation of non-processible rate. It would be more appropriate to include these withdrawn or cancelled tags in calculating the non-processible rate to better reflect officer performance.

One of the reasons for non-processible tags is attributable to the misidentification of the proper by-law under which the infraction is committed. With the continuance of the existing by-laws, which vary across the former municipalities, this matter continues to be a problem.

It is anticipated that the establishment of a uniform by-law that consolidates all the parking-related by-laws will significantly reduce the occurrence of this type of error. The unit intends to work with the appropriate City officials in drafting this uniform by-law.

In 1999, with the implementation of the management information system, the unit was able to undertake a review of the non-processible tags and investigate the reasons that were classified as officer controllable. As a result of the review and in consultation with staff of City Finance, the unit identified problem areas and took some corrective action. The unit has indicated that it will continue to monitor officer controllable errors and take necessary action to keep the level of non-processible tags to a minimum.

We recognize that the unit has made progress in developing performance standards. However, the process could be further enhanced by including other indicators that measure the overall effectiveness of the unit, such as the level of service calls made and the number of complaints handled. The unit should also benchmark its operations against other comparable organization, as appropriate.

Currently, City Finance submits a quarterly report to the Administration Committee on tag issuance and the status of collection. However, this report does not include information with respect to the average number of PETs deployed in a given month, average issuance by PETs, officer controllable non-processibles and absenteeism rate. Consequently, there is a need to enhance the current report in order to provide more complete and meaningful information to the Toronto Police Services Board and Council.

It is recommended that:

12. the Parking Enforcement Unit enhance the performance review process, currently being developed for implementation in 2000, to include other performance indicators and benchmarking with other comparable organizations, that would further assist in measuring the benefits and effectiveness of the unit;

13. the Parking Enforcement Unit include the number of tags that are withdrawn upon officer request or replaced by another tag in calculating the non-processible rate, in order to better measure officer performance;

14. the Parking Enforcement Unit, in consultation with the appropriate City officials, expedite the drafting of a uniform by-law that consolidates all existing parking-related by-laws of the former area municipalities; and

15. the City's Chief Financial Officer and Treasurer enhance the current quarterly parking tag report submitted to the Administration Committee to include information on the average number of parking enforcement officers deployed each month, average issuance per officer, non-processible rate (broken down between officer controllable and non-controllable) and the absenteeism rate for the Parking Enforcement Unit; and that the unit provide the necessary information to City Finance in this regard.

Absenteeism

The Budget Committee requested the City Auditor to report on whether the definition of absenteeism used by the Parking Enforcement Unit and the unit's absenteeism rate are comparable to other agencies, boards and commissions, specifically the Toronto Transit Commission (TTC).

In 1999, the City Human Resources Division compiled information with respect to sick days taken by employees in 1997 and 1998 in the TTC, Toronto Police Service, Ambulance Services, Fire Services and the Toronto Zoo. However, there was no consistent definition of what was included as sick days, particularly relating to injury-related sickness under Workers Safety Insurance Board (WSIB), unpaid sick days, ill-dependant days, etc. Consequently, a meaningful comparison of absenteeism among the City departments, agencies, boards and commissions is not possible at this time.

The TTC includes absenteeism in its regular monthly report to management and the Commission. A preliminary comparison was made of the Parking Enforcement Unit's absenteeism rate with that of the TTC, as requested. The comparison indicated that the unit's absenteeism rate was significantly higher than the TTC during the first few months in 1999, but the gap was narrowed in the subsequent months. In its report of July 1999 to the Toronto Police Services Board, parking enforcement staff indicated that the reduction in absenteeism was attributable to initiatives taken by management to monitor and better manage absenteeism in the unit.

The unit is currently reporting semi-annually to the Policy and Finance Committee, through the Toronto Police Services Board, on absenteeism. Since City Finance reports quarterly on parking tag-related information to the Administration Committee, it would be appropriate to include absenteeism in that report, as previously indicated.

As part of the 2000 Audit Work Plan, a review of absenteeism will be conducted throughout the corporation including the various agencies, boards and commissions. The review will include an assessment of corporate policies, procedures and management information available, in order to ensure that management can appropriately measure, monitor and manage absenteeism in their respective program areas.

It is recommended that:

16. the Parking Enforcement Unit establish an acceptable absenteeism rate and continue to monitor absenteeism in order to determine the effectiveness of the unit's absenteeism reduction initiatives and take any additional action required. In addition, the absenteeism rate should be compared periodically to other comparable organizations and jurisdictions; and

17. the City's Executive Director, Human Resources, report to the Administration Committee by September 30, 2000 on a framework for reporting absenteeism across the corporation, which should include the development of appropriate definitions and reporting guidelines, to enable a meaningful comparison of absenteeism among the various departments, agencies, boards and commissions.

Management Information Systems

The Parking Enforcement Unit maintains a database system called the Parking Information System (PINS), which was designed in 1997, and became fully operational in late 1998. The system contains data related to parking tags, vehicle tows and service calls, which are used to analyze enforcement activities and for performance management purposes. The system allows management to extract information by officer, platoon or area. It also has the capability of geographically plotting data.

Data contained in PINS are obtained from various sources. Parking tag information is obtained from the Parking Tag Operations Unit of City Finance, which is responsible for data entry and processing. This information is transmitted electronically to the police system on a daily basis, but there is no confirmation process in place to ensure that all records have been captured by the police system. Consequently, the possibility exists that the information obtained is not complete.

In addition, while all parking tag data are stored in the police computer server, only data that match with officer information obtained from the Toronto Police Service Data Entry Control System are carried forward to PINS. Parking enforcement staff have advised that, as a result, approximately four percent of total tags issued by the officers are not included in the production statistics. Consequently, the accuracy and completeness of information contained in PINS are compromised.

It is recommended that:

18. the Parking Enforcement Unit investigate the reasons for unmatched data between the City Parking Tag Management System and the Toronto Police Service Data Entry Control System and take appropriate action to ensure that the unit's Parking Information System contains a more accurate and complete record of parking tag information; and

19. the Parking Enforcement Unit implement procedures to ensure that the parking tag information received from the City Parking Tag Management system is complete.

Vehicle Replacement

The unit's fleet is comprised of 89 vehicles and 39 bicycles. Included in the fleet are 31 vehicles that are 1988 to 1990 models. According to the Toronto Police Service's replacement guidelines (five years or 135,000 kilometres), 37 vehicles are due for replacement.

The unit has contributed a total of $700,000 in 1998 and 1999 from its annual operating budget to the City's corporate vehicle replacement reserve to fund the replacement of its vehicles. We have been advised that the police has recently ordered seven new cars and two vans for the unit at total cost of about $250,000. Nonetheless, the unit has indicated that the number of vehicles purchased does not meet its replacement requirements and is not reflective of the total contributions made by the unit in the last two years. Police staff explained that the decisions with respect to fleet replacement were made based on priorities within the overall police budget. Consequently, vehicle replacement for front-line officers took precedence over those for parking enforcement officers.

On January 14, 2000, the Budget Advisory Committee requested that the City Auditor and the Chair of the Toronto Police Services Board, in consultation with the Chief Financial Officer and Treasurer report to the Budget Advisory Committee on:

- the annual amount required to maintain the police fleet at a reasonable rate; and

- a vehicle replacement policy for both marked and unmarked cars.

The Parking Enforcement Unit's vehicle replacement and related funding requirements will be reviewed as part of that report.

Administrative Overhead Charges

The Toronto Police Service provides support to the unit, and charges back either the actual costs or prorated costs as overhead. With the police increasing the number of common services in the calculation, this charge has escalated from a budget of $450,000 in 1994 to $748,100 in 1999. The actual charge in 1998 was $795,625.

The unit is charged a prorated share of common services costs (fleet maintenance, human resources support, information system support, financial management, facilities management, purchasing and legal) of approximately 4.7 percent based on the ratio of staff in the unit to the total police workforce. The use of this percentage on costs that have no bearing on the number of staff in the unit is questionable. For example, with respect to vehicle repairs, parts are charged at actual costs while labour charges are based on the staff ratio. In this case, it would be more reasonable to use actual hours of service at a predetermined labour rate instead.

It is recommended that:

20. the Parking Enforcement Unit, in consultation with appropriate Toronto Police Service personnel, review the current overhead charges in detail and determine whether a more reasonable basis of allocation can be used to fairly reflect the actual costs of the services provided to the unit. Support for the basis of allocation should be documented in writing and reviewed annually, making appropriate changes as required.

Hand-held Ticket Issuing Equipment

The Parking Enforcement Unit has considered the use of hand-held ticket issuing equipment for parking tag issuance several times in the past. A pilot project was initiated in 1997. However, the project was abandoned when no equipment was found suitable to meet the unit's operational demands.

The unit is now re-considering the use of hand-held ticket issuing equipment. Parking enforcement staff have advised that there is now hand-held ticket issuing equipment available that meet the operational needs of the unit, however, none use paper that meet the processing requirements of the banks and the Canadian Payment Standards Association. Currently, the City utilizes the banking system to process approximately 70 per cent of parking tag payments, which City Finance staff also indicate is the most cost-effective means of processing payments. Consequently, it is imperative that the paper used by hand-held ticket issuing equipment can be processed through the banking system.

The use of hand-held ticket issuing equipment has the potential to increase officer efficiency and productivity and would reduce the number of illegible tags, thereby increasing the collection rate and revenue. The equipment would also significantly reduce the amount of data entry by the City Parking Tag Operations, thereby reducing the City's processing costs. It is therefore appropriate that the use of hand-held ticket issuing equipment be explored in more detail, in order to identify all costs, benefits and issues related to the potential use of this technology.

It is recommended that:

21. Parking Enforcement and City Parking Tag Operations staff meet with potential hand-held ticket issuing equipment suppliers to explore possible solutions that would enable the paper used by hand-held ticket issuing equipment to be processed through the banking system; and

22. the Chief of Police, in consultation with the City's Chief Financial Officer and Treasurer, prepare a complete cost benefit analysis and identify any issues with respect to the use of hand-held ticket issuing equipment by parking enforcement officers, and report to the Policy and Finance Committee by September 30, 2000.

Municipal Law Enforcement Program

The Contract Services Section of the Parking Enforcement Unit is responsible for administering the Municipal Law Enforcement (MLE) Program. The program includes training and certification of municipal law enforcement officers (MLEOs); registration and regulation of commercial parking enforcement operators; and investigation into police vehicle tows and complaints on MLEOs. The objective of the program is to authorize municipal law enforcement officers to issue parking tags on private property, relieving police and parking enforcement officers of this responsibility.

In 1998, MLEOs issued approximately 266,600 parking tags, representing 11 percent of the total tag issuance, which generated about $5 million in revenue for the City.

In 1994, municipal by-laws were changed to restrict MLE agencies from charging owners of towed cars. Since then, some property owners and private security agencies have opted to print their own tickets and remove unauthorized vehicles parked on their private property under the Trespass to Property Act or "Common Law" (which is governed by precedent not municipal by-laws). Some agencies have been found issuing tags that very much resemble those issued by the City, and collecting the fines for themselves.

The City Solicitor, in his report of September 1999 submitted to Council, confirmed that "the City does not possess any direct authority to prohibit or regulate this type of practice, since neither the property owner nor his agent are purporting to act under a City by-law." Further, the City lacks legal standing to challenge this practice on the basis of a copyright infringement as any current copyright rests with the Province, and the Province has chosen not to create a provincial offence for the use of "look-alike" tags. Council has since directed the City Solicitor to take legal action to prevent the issuance of "look-alike" parking tickets, and to retain outside legal counsel if necessary. The Toronto Police Service will also determine whether the use of "look-alike" tags warrants prosecution under the Criminal Code.

Notwithstanding the action taken by police and the City on this matter, the development of a structured public awareness program may help to educate property owners and the public about the pitfalls of common law towing and encourage property owners to engage certified MLE agencies to address their parking concerns.

While the Toronto Police Service has been delegated the authority to supervise the MLEOs, it has no formal supervisory authority to regulate activities of the MLE agencies. Clear policy and properly delegated authority are essential to effective program administration.

The former municipalities enacted local municipal by-laws to specify conditions under which unauthorized vehicles parked on private property can be tagged and towed by MLEOs. These by-laws differed from municipality to municipality and as a result, there are significant disparities in MLEOs' authority to tag and tow, even after the amalgamation.

The unit has recently drafted two new by-laws: one to unify parking enforcement activities on private property, and another to better define the role and responsibilities of the Chief of Police in the management of this program. These by-laws are currently being reviewed by City Legal.

Results of this program are measured in terms of program cost per MLEO ticket issued, average complaint investigation time, and percent of parking officer tows resulting in complaints. However, the quality of parking tags issued by MLEOs is not currently monitored. The unit is in the process of enhancing its management information system to provide the information required to monitor tag issuance by MLEOs.

It is recommended that:

23. the Parking Enforcement Unit develop a strategy to promote the use of certified municipal law enforcement agencies by property owners and develop appropriate policies and procedures to monitor the performance of these agencies;

24. the Parking Enforcement Unit expedite the finalization of the by-laws with respect to unifying parking enforcement activities on private property and defining the role and responsibilities of the Chief of Police in the Municipal Law Enforcement Officer Program, so that these by-laws are submitted to City Council for approval by September 30, 2000; and

25. the Parking Enforcement Unit enhance the performance standards used by the unit to include the level of non-processible tags issued by municipal law enforcement officers.

Conclusions:

The Parking Enforcement Unit of the Toronto Police Service is responsible for the enforcement of the City's parking by-laws, follow-up of parking-related complaints and responding to service calls. The unit is responsible for issuing approximately 90 percent of the total parking tags for the City, which generates approximately $43 million in revenue. The level of tag issuance and the quality of tags issued, which are under the control of the unit, have a significant impact on parking tag revenue.

The unit has undertaken various initiatives to improve productivity and the quality of parking tags. As a result of these initiatives, the unit has experienced a decline in the non-processible and absenteeism rates. Management is currently in the process of developing performance standards with respect to tag issuance, non-processible tags, non-patrol hours and absenteeism. It is anticipated that a performance review process will be implemented in 2000. Management has also commenced updating the unit's policy manual and has set various objectives for 2000. These objectives include the development of training initiatives for parking enforcement staff, working with appropriate City officials on the consolidation of parking by-laws of the former area municipalities and other initiatives to deal with issues relating to disabled parking and the municipal law enforcement program.

While we recognize the progress made by the unit in improving its operations, opportunities exist wherein management can further enhance the operational efficiency of the unit. In our view, the current organizational structure can be flattened and certain functions and positions eliminated or re-aligned, freeing up parking enforcement officers for direct enforcement duties. The current deployment strategy can also be modified to better utilize resources by transferring officers from off-peak periods to other times when there is a greater demand for enforcement. In addition, the number of officers dedicated to tag issuance can be increased by re-assigning the functions for service call and complaint follow-up to designated officers.

The unit could also benefit from the relocation of its current offices closer to the area with high volume enforcement requirements. While the unit is bound to the 10-year leases on the current premises, which expire in June 2004 and December 2005, management should start the search for potential location(s). The possibility and benefits of consolidating its office space requirements into one centralized location should also be explored.

The use of hand-held equipment to issue parking tags could also significantly improve productivity and the quality of tags, as well as reduce tag processing costs. Management has considered this technology over the past several years. However, locating hand-held ticket issuing equipment that uses paper suitable for bank processing remains a problem that must be resolved in order to consider this option further.

In 1993, the parking enforcement function was consolidated into a centralized unit, previously operated from the various police divisions. While the consolidation resulted in a more cohesive unit with a more consistent and focused approach to parking enforcement, the significant increase in tag issuance projected at the onset has not materialized. To date, Council has yet to receive a full report on whether the consolidated function has delivered the operational and financial benefits expected.

The unit's 2000 preliminary budget of $22.5 million is $1 million higher than the approved 1999 budget. The increase is mainly attributable to the salary settlement, the establishment of a disabled parking unit and an increase in police overhead charges. The initiatives commenced by the unit and implementation of the recommendations contained in this report will assist management in reducing the unit's operating budget requirements and improve enforcement activities, thereby optimizing net revenue to the City.

While we realize that the implementation of some of the recommendations contained in this report will occur in the longer term, it is essential that the unit develop an implementation plan with specific time lines to address the issues raised.

We have reviewed this report with the Superintendent, Parking Enforcement Unit, who generally concurs with the recommendations made. The Toronto Police Services Board will be considering this report and will forward a formal response to the Policy and Finance Committee.

Contact:

Tony Veneziano, Acting Director, Audit Services, tel: 392-8353, fax: 392-3754,

e-mail: Tvenezia@toronto.ca

Jeffrey Griffiths

City Auditor

List of Attachments:

Appendix A - One Page Report

AUDIT SERVICES Appendix A

ONE PAGE REPORT



Subject: Review of Parking Enforcement Unit, Toronto Police Service January 4, 2000



Area of Responsibility:

Douglas Reynolds, Superintendent

Parking Enforcement Unit

Toronto Police Service



Audit Team:

Tony Veneziano, Acting Director

Sonia Villanueva, Audit Project Manager

Anne Cheung, Audit Project Manager



General Information/Highlights:

The Parking Enforcement Unit of the Toronto Police Service is responsible for the enforcement of the City's parking by-laws to facilitate traffic and transit flow. The unit issues approximately 2.3 million parking tags, representing about 90 percent of the total tag issuance in the City and generating approximately $43 million in revenue for the City. In 1994, the parking enforcement function, which previously operated from the various police divisions, was consolidated into one centralized unit.



Objectives and Scope:

To review the operations of the Parking Enforcement Unit, Toronto Police Service assess the effectiveness of the unit in carrying out its mandate. This review was completed in accordance with the 1999 Audit Services Work Plan and as requested by the Budget Committee.



Significant Observations and Conclusions:

Ø The consolidation of the parking enforcement function in 1994 has resulted in a more consistent and focused approach to parking enforcement and has allowed police officers to concentrate their efforts on policing functions. However, the consolidation has resulted in significantly higher operating costs for the unit, which has not been offset by a corresponding increase in tag issuance and revenue as projected at the time. A full report to Council on the costs and benefits of the consolidation is therefore in order.

Ø The current organizational structure of the unit can be flattened by eliminating at least one layer of management. Certain administrative functions and positions can be re-assigned or eliminated, freeing up parking enforcement officers for direct enforcement duties. A progress report on the civilianization of the remaining uniform positions in the unit is also required.

Ø The current enforcement deployment strategy can be modified to better utilize resources by transferring officers from non-peak periods to other times when there is a greater demand for enforcement. There is also a need to determine the optimal number of officers required to ensure adequate and effective enforcement throughout the city, and the costs and benefits of any proposed changes in the unit's establishment, including the effect on tag issuance.

Ø The quality of parking tags issued, number of patrol hours and absenteeism all have an impact on the effectiveness of the unit's enforcement activities and ultimately on the amount of revenue realized by the City from the enforcement of parking by-laws. The unit is currently monitoring absenteeism very closely and has developed performance standards with respect to non-patrol hours and non-processible tags.

Ø While the unit is bound to office space leases that expire in 2004 and 2005, an action plan should be developed taking into account the unit's operational requirements, optimal location, estimated cost of other locations and the feasibility of consolidating the two current offices into one location.

Ø The initiatives commenced by the unit and the recommendations in this report will assist the unit in optimizing its budgetary requirements and improve its enforcement activities. It will be difficult for the unit to properly implement many of the recommendations in 2000. It is therefore important that an implementation plan be developed, with specific timelines, such that the resulting budgetary adjustments can be incorporated and considered in the unit's 2001 budget.



Management Response:

Generally concurs



Follow-up Review Date by:

Parking Enforcement Unit and Audit Services

September 2000

 

   
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