To: Economic Development and Parks Committee
CC: Shirley Hoy, Manager of Toronto, David Miller, Mayor of Toronto, Hello and thank you for this opportunity to be heard...

My name is Dianne Eibner. I am the Founder and President of the Professional Dog Walkers Association International.
I have been attending meetings since last June as a member of the sub committee for the Dogs in Parks Strategy team.

I have concluded that I and others were led to believe that we were going to be implementing a registration system for professional dog walkers. It was just recently at the April 13 meeting we were told that the Legal Department for the city recommends calling it a permit, so that is what they are going to do. We never agreed to a permit system we only discussed a registration system.

I am addressing 6 points of concern.

Professional Dog Walker Income

I'd like to clear up a misconception about a professional dog walker's income. The city is saying we make $15 an hour which is comparable to the rate of pay they receive.
We don't make $15 an hour, like a city worker does. We don't get paid when we don't show up. We don't get paid for taking off days when we are sick and we don't have a benefit plan paid for by our employer. We are entrepreneurs. We provide a service in demand and we lose money when we don't work, unlike a city worker.

In fact a group walk takes up to 2 two hours to properly complete therefore we are actually making about $7.50 and hour. Then you must factor in gas expenses. The traveling from one house to the next for six different dogs gets very costly. In a matter of a day you can really only do two group walks during the peak hours that are in demand. Most dog walking businesses are sole proprietorships. We make an average amount of money. So to say that we make $15 an hour is inaccurate and misleading.

Reason for Permit / Registration

It needs to be pointed out that a reason for a permit has never been clearly stated. First we were told we must be permitted because it was a "no no" to walk in a city park and get paid for it. I asked for a legal definition of No No but never go it. We challenged it by pointing out how home based Nanny's use parks for their business and get paid by their clients the same way we do. Then the city changed their motivation for permitting us. In fact at that point, it was suggested that the word permit be changed to the word registration which we used from then on. Since the reasoning for a permit was not on account of park use, we were led to believe that we were not going to be purchasing a permit but instead we were registering.

Then the motivation focused on the criteria that a dog walker should have in order to be a professional. But that fell through after realizing that pet dog training and pet first aid did not all offer accreditation and the qualifications were too different to monitor.

Then the city decided that insurance was something that a dog walker must have because of the liability issues that the city would face. At this point the notion of keeping the 3 dog bylaw was mentioned and if a dog walker wanted to walk 4-6 dogs they could do so only if they had insurance. Insurance was to be a requirement for registering. I'll reiterate that we only discussed a registration of professional dog walkers not a permit system. The city for a reason unknown, decided that dog walkers do not need to have insurance now.

The reason for registering as we were calling it, changed so many times. A legitimate reason as to why we need to have permits has still not been determined. In fact I question the need for registering since the reasons have changed so many times.

Even though we might not be able to change your mind now, you need to know how the city used ambiguity, vagueness and misrepresentation to get what they had set out for. But we were led to believe that our opinions mattered, that we were being heard, that we had a say in the process. I posed questions from day one that came from the members of the association that Sandy never answered, though said she would. Even my own area councilor Janet Davis' assistant Liz Manion, would not help me. Liz Manion told me that she spoke to Sandy and Sandy said that she would answer me. I told Liz that Sandy has not answered anything and Liz just told me again that Sandy would answer me.

Opposition to Fee

There has been a significant opposition to the $100 fee which was not debated in the sub committee. Documentation was given to Sandy from me as well as members of a group called the Dog Walkers Coalition of Toronto. I read those letters and there were many dog walkers questioning the reason for a fee and the high cost of $100. There should have been a discussion about the fee due to the opposition to it.

I never did agree to the $100 registration fee because it was never determined as to why we needed to pay a fee. Our clients are taxpayers who pay the city worker's wages. Many dog walking companies pay taxes too therefore they are already paying the employees of the city. Our clients pay for the parks to be maintained. Parks are paid for by the taxpayers, and we use the parks on behalf of the taxpaying client. Furthermore it is discriminatory to target and permit one group of people and not another who carry on a business in the same manner.

I knew that something was very odd because Sandy Straw would not answer any of my questions and in fact got extremely annoyed with me when I kept asking for her to give me answers before I agreed with anything.

There were instances at meetings where Sandy displayed her aggravation towards me. For example at the second meeting with regards to my consistently asking questions and asking for answers from her she just blurted out, "You are so closed against permits."
I said, "I'm not closed, I just want my questions answered first." Sandy replied, "Get over it", to which I asked, "Get over my questions Sandy?" Then the subject was changed.

Lack of Proper Consultation

Further to the vagueness and deception, the disorganization within the sub committee, including the fact that there were never any minutes reviewed, there was a lack of proper consultation in this process. Where the staff report indicates that the "Strategy Team consulted extensively with both individual and organized dog walkers" and where it says that there was "considerable investigation and consultation," I have to disagree. If my questions were not answered and the questions I brought forward from the members of the Professional Dog Walkers Association International were not answered, then how could much of an effort have been made to really consult and see what other opinions and options there were?

I asked Sandy about how a permit system worked and if she could provide any information and documentation so I could learn, but she would not tell me. I read in the Staff Report that this permit system that is supposed to be implemented will be issued through the CLASS system that is already used by Parks, Forestry and Recreation. So this tells me that she had the answer but decided not to let me know.

We discussed some details of a registration system whereby Sandy tried to impose a revoking of our registration. The sub committee members all opposed this revoking system as it was too indicative and comparable to a permit system which was something we were not agreeing to.

If you happen to think that my claim of Sandy Straw ignoring me and not answering my questions is absurd, you need to be aware of the hardships that Mr. Michael O'Sullivan, the CEO of the Humane Society of Canada experienced with Sandy Straw. He describes in HSC newsletter: "We've been trying to get answers for months and all we get in return is a wall of silence."

He goes on to say: "A recent article in the local Beach Metro News claimed that "The Humane Society" had been a part of discussions relating to the City's Dogs in Parks Strategy. Nothing could be further from the truth." He was also ignored by some councillors when he contacted them for assistance. Please review attached documents.

Opposition to 3 dog bylaw

I wrote to councilor Luby and Fletcher, with regards to an incident where a member said that a unanimous agreement was made within the sub committee on the notion that a two tiered bylaw be implemented where the dog owner is limited to three dogs. No councilors replied to discuss the issue. Please see attached documents. The reason why there has been a discussion with dog walkers this past year is because the 3 dog bylaw was passed without consultation. I never agreed to the 3 dog bylaw and it should not have been passed the way it was. Even Sandy said that the reason for the interim change on the number from 3 to 5 was because it was proven that no public consultation was made before passing it. Unfortunately the city was able to take advantage of this situation and use it as a prelude for implementing a permit system because the 3 dog bylaw affected the professional dog walker negatively. It still does. However, there are members of the general public who will be negatively affected by this 3 dogs limit too since there has never been a limit on the number of dogs a person can walk.

You may not hear from them right away, because this whole process has been kept very quiet, under the city's hat. In the sub committee we were instructed, in fact threatened, that if we went to the media with any of our discussions that the deal with the city we were working on, would be off. I have discovered that we were not truly a part of the deal making process to begin with. We were also threatened that if we did not accept the $100 registration fee - (as it was being called a registration fee at that time), if we did not accept it then it could go back to the municipal licensing department and the cost could go up to $1000 or more. We were also told that the fences would be taken away from the two East Toronto parks if compliance was not met and new parks would not have fences implemented.

There is an attached document on the subject of legal bylaw drafting. If there was a case of bad faith upon which a bylaw was drafted it would be here and now. This bylaw is also discriminatory since the city is willing to allow professional dog walkers walking a maximum of 3 dogs, not be required to pay the $100 fee. We were told that the money would be going back into the maintenance of the parks because dog walkers and their dogs are destroying the parkland. But by allowing dog walkers with 3 dogs to use the parks, and not pay a fee….the same contribution is being made to the damage as there would be if one dog walker with 6 dogs came into a park furthermore 2 or 3 people with three dogs each. In fact, the traffic has now been increased by the many dog walkers walking 3 dogs at a time.

If this 3 dog bylaw remains, I need to declare that neither the association nor I was representing the dog owner or speaking on behalf of the dog owner when I attended the Dogs in Parks Strategy sub committee meetings. There were no dog owners consulted at those meetings.

Validity of Complaints

One of my other concerns is about the complaints that are being filed with the city. There needs to be some accuracy as to whether or not they are really due to professional dog walkers or if they are due to the dog owner. I have asked if I could hear about the complaints and was told that the information is confidential. There has been a request filed with the Freedom of Information Act. There was one complaint we heard, about a dog barking at 7am in a park. This complaint was implied to have been due to a professional dog walker. It is not very likely that a professional dog walker would be in the park with a dog at 7am. It would more likely be a dog owner. These are the sorts of complaints that are getting lumped into one category and aimed at professional dog walkers and this is hurting our image. Due to this bad image, it is now hurting our livelihood because the city is taking these complaints at face value without investigation and basically saying that professional dog walkers are causing all the problems in the parks.

This is the sort of flippant accusation that I worry about taking precedent when the permit system is implemented. If complaints do not need to be proven, where is the justice and mutual benefit?

Our service is one which is in demand. We are not squeegee kids. There are dog walkers that abide by a code of conduct and a code of ethics which are the same as the parks codes. It should be recognized that professional dog walkers clean up the parks when they walk through and the parks are cleaner after the professional dog walker has been there. An effort is made to clear debris such as garbage, broken glass, unrelated dog poop and other hazards so the next person that comes into the park will be walking through a cleaner park.

There are dog walkers out there that are walking more than six dogs and those ones do need to restructure their business. Those are the dog walkers that the city should be targeting, not the already converted dog walker who will only be penalized time and again for complaints that are lumped into one category.

Finally, The Pro Dog Walkers Association International was founded in Toronto. We offer an educational package consisting of pet dog training courses, pet first aid and a mentoring program for the dog walker in Toronto who is starting up a new business.
Members must sign a contract to abide by a code of conduct and ethics, they already limit themselves to 6 dogs, and they already have insurance and are registered businesses with the provincial government and they already have or are obtaining pet first aid and pet dog training classes.

I would have thought that the city of Toronto would have been interested in the education we provide and would have wanted to work with us to implement more programs. Instead the only qualification the city is interested in is money from the person who wants to become a dog walker.

The bylaw should be set at a legal limit of 6 dogs per person.

Clearly there are concerns regarding the proceedings that took place leading up to the proposal of permits. I hope that you will consider what I've said and agree that there needs to be further consultation on this subject before implementation.

Thank you.

Dianne Eibner, Founder/President
The Professional Dog Walkers Association International.
www.prodogwalker.com

391 Main St.
Toronto, Ont.
M4C 4X9
647-296-3647