June 29, 2018

Hon. Joe Hargrave

Minister of Crown Investments Corporation,
Minister Responsible for Saskatchewan Government Insurance
Room 302, 2405 Legislative Drive
Regina, SK, S4S 0B3

RE: REGULATION OF TRANSPORTATION NETWORK COMPANIES

Minister Hargrave,

Congratulations on the passing of The Vehicle for Hire Act, 2018. This is an essential first step
in bringing ridesharing to Saskatchewan. Because of your work and leadership, Saskatchewan
is primed with the opportunity to join Ontario and other Canadian provinces in improving
transportation services. This will help the people of the province get to work, see family and
friends, and reach home safely after a night out.

While the legislation was a great first step, Lyft remains concerned that driver licencing
regulations under consideration by Saskatchewan Government Insurance (SGI) would halt our
shared goal of expanding safe transportation options. ​Should SGI recommend regulations
requiring ridesharing drivers to carry a Class 4 Licence, or any more than a Class 5 Licence, it
would be nearly impossible for Lyft to​ launch in the province.

Not only would these licencing requirements be unprecedented, the inability to launch ride
sharing services in Saskatchewan would have several negative consequences for the province,
including: 1) Safety would not be increased; 2) Transportation options may be frozen or
reduced; and 3) Saskatchewan would not see a potential $4 million in increased economic
impact.

Our mission is to improve people’s lives with the world’s best transportation. Across North
America, Lyft provides 1 million affordable and reliable rides daily. All of these rides are
provided by drivers holding the equivalent of a Class 5 Driver’s License. Ridesharing using
Lyft’s platform is safe in-part because Lyft’s technology provides a more seamless pathway for
drivers to be screened electronically. Instead of requiring additional licenses or costly in-vehicle
safety technology, Lyft partners with an accredited and reputable third party provider to conduct
thorough and comprehensive criminal and driver history background checks.
Our technology also includes several continuous in-ride safety features not present in legacy
taxi-industry vehicles. Each driver and passenger can track rides in real-time, rate each other
immediately upon completion of rides, communicate to each other with anonymized and
encrypted phone numbers, and send estimated times of arrival to chosen friends and family.
Passengers can access the make and model and licence plate number of drivers’ cars, as well
as the name and picture of the drivers before a ride begins. Drivers also are shown the picture
and name of the passengers.

Additionally, ridesharing presents new opportunities for enhanced transportation service across
greater Saskatchewan. Lyft sees real opportunity to improve the reliability and safety of
transportation options in communities large and small. As discussed, we know we can play an
important role in addressing rates of impaired driving. With obstacles to our entry in
Saskatchewan in place, we will not be able to deliver on these shared public policy outcomes.

It remains our hope that SGI will continue the work you and cities across the province to bring
ridesharing to Saskatchewan. As such, we provided the attached comments to review at your
convenience as a resource to assist throughout the regulation making process.

Lyft commits to working with SGI, staff and other stakeholders to craft comprehensive
regulations that allow the ridesharing industry to serve the residents of Saskatchewan by
protecting passengers and drivers while also increasing economic opportunities.

Thank you for your time and consideration.

Sincerely,

Matt Patton
Public Policy Manager
1. ILLUSION OF INCREASED SAFETY BROUGHT BY CLASS 4 LICENCES

Ridesharing provides not only a different service than the legacy industry, but also a more
seamless - and perhaps safer - ride experience for passengers.

Before giving their first ride, all drivers who apply to drive on the Lyft platform undergo a criminal
background check, a driving record check, a vehicle inspection and an in-person screening. Lyft
also provides in-app photos of the driver and vehicle, license plate number, real-time ride
tracking, digital receipts, two-way rating systems, an around-the-clock Trust and Safety team, and
professionally administered criminal background checks. This means consumers can provide
immediate feedback on their experience and know that a Lyft team member is always available to
respond to any questions or concerns.

Because all Lyft drivers are already subject to such a process, requiring a Class 4 Licence would
in no way increase the level of safety for ridesharing, but instead only decrease the quantity of
drivers willing to undergo additional, more costly licensing regulations.

2. POTENTIAL FREEZE AND REDUCTION OF TRANSPORTATION OPTIONS

We recognize that the legacy industry is subject to different regulations that accomplish similar
consumer protections than those proposed for ridesharing, yet creating similarities within
regulations could lead to a reduction of transportation options for two reasons:

First, by requiring the legacy industry and ridesharing drivers to carry the same class of licence,
Lyft believes that new drivers would be severely discouraged from joining our platform and as a
result, the existing level of safety and service would be preserved in Saskatchewan.

Second, if some existing legacy industry drivers chose to use their personal vehicles and Class 4
Licenses yet switched to the Lyft platform, the legacy industry may experience a hemorrhaging of
drivers from its existing service, thus putting their industry in jeopardy. It remains Lyft’s intention
to supplement the legacy industry, not drive it out.

3. LOSS OF ECONOMIC OPPORTUNITY

Finally, Lyft has estimated based on the positive impact ridesharing has in states, provinces and
municipalities when people have the opportunity to earn supplemental income and have a safe
ride home after a night out, they stay out longer in restaurants and bars.

If SGI adopts regulations that foster ridesharing, not stifle the services it can offer, an estimated
$4.1 million would be generated for local businesses and $2.2 million would be earned by drivers
- 90 percent of which would be likely to only drive less than 15 hours per week on average.