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
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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.
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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.
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Management Response:
Generally concurs
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Follow-up Review Date by:
Parking Enforcement Unit and Audit Services
September 2000
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