Category Archives: Guest Commentary

Missing Childrens’ Bones: Listen to Kevin Annett, who has been searching for decades

Preamble for my friends and readers: When I had the opportunity to speak with Kevin Annett last year, I expressed the same confusion most Canadians feel: “But Stephen Harper apologized for the Residential Schools. There was a Truth and Reconciliation Committee which worked for years. Didn’t Canada address this issue?”

Because I personally knew several of the Conservative senior political staffers who worked on the file especially around the time of the Apology in Parliament, I offered to go looking for the answer to what ACTUALLY happened after the Apology to make things better for Indigenous families.

I was referred from one person to another, down the list of people I knew personally and with whom I worked between 2006 and 2009. Finally, the last Conservative staffer – by far the most senior and involved person on the file – told me bluntly, “Ask Phil Fontaine.”

As Kevin notes ruefully in the video message below, recorded upon the discovery of 215 childrens’ bodies in Kamloops: “Suddenly this is ‘new news.'”

I am currently writing a 5-article series on stigma and the impact stigma had on on the taxi industry as Toronto welcomed Uber when it gleefully, publicly stomped on the Rule of Law upon its entry in 2014. When I pointed out to Kevin that the dehumanization of taxi drivers by politicians and media in Toronto seemed to be an echo of the dehumanization of Canada’s indigenous peoples in the building of the nation, he suggested I come on his radio show to be interviewed to discuss that parallel. Maybe, dehumanizing innocent people in the quest for opportunity and resources is such a proud Canadian tradition that we don’t even notice when it is happening.

 I declined his suggestion of an interview. I should not have done that.

Kevin’s words are painful to read and painful to listen to. Some of his ideas may seem impossible or outlandish; maybe, as outlandish as 215 children’s skeleton buried under a school run by the Canadian government.

What Children’s Bones Reveal: A Lament for the Dead and a Call to the Living

by Kevin D. Annett

Canadian Field Secretary of the International Tribunal of Crimes of Church and State (

First excavation of Indian residential school children’s bones, Brantford, Ontario, October 2011
(Archives of the ITCCS and Mohawk elders)

I first learned of the mass graves of children in Kamloops twenty-three years ago from an eyewitness who had helped bury them. In June 1998, he spoke at a Vancouver Tribunal I organized to investigate genocide in Canadian Indian schools. His name was Jessie Jules.

Jessie was a frightened man. He had been warned by his own native band council in Kamloops not to speak about what he knew.

“They told me I’d get thrown out of my home on the reserve if I ever mentioned the dead kids” Jessie said on record to our panel of Tribunal judges. But despite this threat he spoke anyway.

Jessie told us how his fellow Kamloops students were starved to death in underground chambers at the school and forced to sleep with children dying of tuberculosis after they tried running away. He named Catholic priests like Brother Murphy who sodomized kids with cattle prods and beat a boy named Arnold to death with a club. Jessie saw another priest push a young girl named Patricia out a window to her death. He even drew us a map of where he buried children at night at the order of the priests.

“There were lots of those little bodies” he said. “We ran out of room in the ground, so they started burning them in the school furnace. It was kept going 24-7. They even chucked in there the babies from the girls they’d got pregnant, to get rid of the evidence. I saw the nuns do it.”

The Kamloops center was a particular house of horrors, even by residential school standards, which is why such an effort has been made by the guilty to hide their atrocities. For many years it was an experimental center where particularly rebellious Indian children were sent for “special treatment”, including involuntary drug testing, sexual sterilizations, and pain threshold studies to see how much torture the mind and body can endure. Generations of experimental vaccines were tried out on Indian children at Kamloops by drug companies like Pfizer, Bayer, and Eli Lilly with the help of the Catholic church and the government. Most of the little test subjects died.

After our Tribunal had catalogued these grisly crimes, in mid-June of 1998, we shared with the world the evidence, including Jessie’s account and that of twenty-eight other survivors with similar stories of the Canadian Holocaust that killed more than 60,000 children over a century. We included Indian school records from Kamloops and across the country showing a huge death rate of over fifty percent that spanned decades, and evidence that disease was routinely and deliberately spread among children by the staff, and letters confirming the sexual sterilization of native children by church doctors that was funded by the Canadian government.

We sent this proof of genocide to the world’s media, the Canadian government, the United Nations and to aboriginal groups and band councils across Canada, including the one in Kamloops. And every single one of them ignored us.

Over the years that followed some of us did not give up. Our campaign to expose our home-grown genocide grew until it threatened the Church and State killers, as lawsuits by survivors escalated thanks to our work. And in retaliation, the RCMP and the blood-soaked Catholic, Anglican, and United churches began attacking us, smearing us to the press and killing our native eyewitnesses. They even dug up and destroyed the graves of children we had identified.

Like a huge baby-burning furnace, Canada has done everything possible to get rid of the evidence and wipe clean the memory of its mass murder of children. And that deadly coverup is still going on. We have witnessed it happen again just this past week, at the scene of the crime in Kamloops, British Columbia.

Last week, the Kamloops Indian band leaders displayed a sudden concern for their relatives in the ground whom they have ignored for so many decades. The state funded Tk’emlups band council announced that it is digging up a mass grave of 215 children just south of the former school. In fact, what they are doing is breaking the law.

The band council officials are interfering with a crime scene and obstructing justice by destroying the evidence of how those children died. So naturally they’re doing the dig quickly and in secret, without any plan to determine how the children died or who caused their death or to lay criminal charges. Even though the site is a crime scene, the police are absent, and the media and public are banned from the site. And since the land is legally owned by the Crown, this subversion of justice is authorized and is being done in the name of the Canadian state and the Queen of England.

To cover their misdeeds, the band council’s public relations people are issuing the usual politically-correct phrases about justice and remembrance. This is mere smokescreen to distract from their destruction of the graves, but it also hides the fact that for decades, the Kamloops chief and council actively colluded in keeping secret the murder of so many of their children.

As early as 1922 the Canadian government made a deal with band council chiefs that in exchange for benefits, they would round up the children from their tribes and deliver them into the residential school death camps and hospitals. The chiefs also agreed to track down runaway children and bury those who died in secret. Is it any wonder that the same chiefly families are now posing as the good guys?

Those kind of sweetheart deals with the native elites are nothing new in Canada and have ensured that our domestic genocide has remained hidden and that it continues today. But a particular insiders’ arrangement took place in the spring of 1996 that ensured that west coast chiefs and councils would steer clear of mentioning dead residential school children and mass graves.

On April 10th of that year in Port Alberni, leaders of all three guilty churches met with the state-funded chiefs. The deal offered by the churches would fork over monetary settlements to residential school survivors for limited “sexual and physical abuses” provided that the chiefs never supported investigations into deaths and burials in the schools. The chiefs agreed to this Judas offer, and their silence was bought.

This private arrangement broke down over the years as our campaign forced the little matter of buried children to the surface and the crime could no longer be denied: especially two years ago, when Justin Trudeau publicly admitted that genocide had happened in Canada. At that point, under international law Trudeau should have been hauled before a War Crimes trial, along with his co-conspirators in the churches, police and native band councils. Instead, the world community turned a blind eye on the Canadian Holocaust and did not enforce its own Genocide Convention. That freed up Trudeau to give the same assurance and legal indemnification to the native chiefs that the churches had received in the summer of 2008 as part of the government’s farcical “apology”. The issue of buried children could then be safely spun and damage controlled, as is now being done in Kamloops.

And so, copying their Church and State partners, the Tk’emlups band council’s disinterring of children’s remains is openly defying international law, which states that the parties to a Crime against Humanity cannot investigate their own crime. The Kamloops dig is nothing less than a smaller version of the massive obstruction of justice that was Canada’s misnamed “Truth and Reconciliation Commission”. The law has become a dead letter and the killers are once again officially exonerating themselves. This fact seems to have eluded everyone who is applauding the dig.

Like a bad comedy, all the dirty actors are jumping in now to milk this chance to evade justice and look good in the process. This week in the press the British Columbia Coroner announced that he will be on the scene working closely with the Tk’emlups band council to “investigate” the children’s remains, as if that’s a good thing. It isn’t, actually, since the BC Coroner has a long and sordid history of issuing fake certificates to conceal the real cause of death of murdered Indians.

My friend William Combes suffered such a fate at the hands of the Coroner’s office. After enduring years of sodomy, torture on a rack and electric shocks at the Kamloops school, William witnessed the abduction of ten Kamloops school children by Queen Elizabeth on October 10, 1964. Just before he was to give his testimony before a citizens’ Grand Jury in February 2011, William was killed by arsenic poisoning at the Catholic St. Paul’s hospital in Vancouver.

The BC Coroner claimed that William’s death was due to tubercular meningitis. But his attending nurse Chloe Kirker has said under oath that William had no symptoms of TB, but rather the bloated face and darkened fingernails of one who has been poisoned by arsenic. So, the very fact that the BC Coroner is showing up in Kamloops now is a sign that an official coverup is at work. You can be assured that any incriminating evidence found on those little bones will be expunged as quickly as were their lives.

The whole sorry charade reminds me of a scene from the movie Mississippi Burning, when three civil rights workers are murdered by the Ku Klux Klan and thrown into a swamp. But when their bodies are discovered, it is the sheriffs and judges who are KKK members who disinter the remains and conduct the autopsy and issue the verdict on their death that prevents anyone from going to jail. And all the locals and the press are satisfied that justice has been done!

In that regard, it’s not only the aboriginal accomplices to the serial killer called Christian Canada that are falsely posing as the friends of the slaughtered innocents. So too is the rest of the world and its media. Suddenly the mass graves of Canadian residential school children have become hot news in the New York Times and the BBC and China’s Peoples’ Daily. But where were they all in the summer of 1998 after our Tribunal first broke the news, and in November 2011 when our campaign unearthed the positively identified bones of Mohawk residential school children in Brantford, Ontario?

We know very well that this contrivance in Kamloops is not simply another sordid coverup. It is the way of all serial killers who hold power. First, they torture and kill their victims for profit or sport, then they secretly bury them and their memory, and much later after the truth begins to emerge and it is safe to do so, the murdered are disinterred by the killers themselves who shed crocodile tears and claim it was all an unfortunate accident, a sad chapter that can be healed and reconciled, somehow.

This farce is ultimately about power. It is how a few people hold power over the many. The killers on their thrones must continually prove that they can murder whoever they like and get away with it, and then with noblesse oblige issue insulting “apologies” to pretend things are different now. That big lie is not just a way to legally indemnify themselves, but to laugh in the face of their victims and keep them and their descendants in their place.

We know the agenda of criminals in power all too well because it keeps repeating itself: the same murderous pattern of Church and State to kill, conceal and repeat. And yet paradoxically their reopening of the graves of those they have tried so hard to erase is also an act of desperate self-destruction; a turning of the tables on themselves, like during an exorcism when the possessing entity is forced to name itself and thereby loses its power.

With all their power, Canadian Church and State have been forced to respond to our initiative, and to the issues that our campaign established as early as 1995. For since then we have done as Sun Tzu advises in The Art of War by first forming the ground of battle on our terms and not that of our adversary. We defined the issue and thereby won the fight before it ever began, even though we faced an enormous adversary. For over two decades we have described the residential schools issue as one of genocide and mass graves, not “abuses” and monetary compensation; and so now despite all their weight the killers have had to do so too.

No matter how much Canada tries to soften its mass murder of children, it can no longer deny the crime or its own collective guilt. Its mask is off and its murderous nature stands revealed.

In truth, the Church and State killers were exposed years ago.  In early 2013, a Brussels common law court established by our campaign convicted Canada, its churches and their sponsors in London and Rome of Crimes against Humanity and sentenced their leaders to prison, even forcing Pope Benedict from office. Every Canadian is therefore required by that precedent and by international law to shun the system that slaughtered entire nations of original people, by not paying its taxes or voting for it or obeying its laws.

The imposition of the COVID police state by the same system that slaughtered the Kamloops children has made our non-cooperation with its evil all the more urgent. For the same agency of Health Canada that is forcing the so-called corona vaccine into your arms used the Kamloops children as lab rats and killed them en masse. Who in their right mind would allow these medical murderers to shove a needle into their arm or their children’s arms?

The graves of the Kamloops children reveal much of the criminality of our society, of the Canadian government and the churches and their aboriginal accomplices. But the graves are also a mirror on all of us and of the future that could await us. For we have all been accessories to the worst crime and the biggest coverup in Canadian history, through our taxes, our church tithings, our willful ignorance of the death camps in our own backyards and our willingness to look the other way and believe the killers in high office. When we fully embrace that dark truth and refuse to participate any longer in the criminal conspiracy called Canada, we have taken our first step out of the shadows.

And yet there is no cheap salvation for any of us. We can change only by first risking and sacrificing the security we have gained off the avails of genocide, and from the torture and death of little children, who were sacrificed in our name.

Canadians stand under a judgement imposed by the consequences of their own complicity in mass murder. As much as we deny our real heritage and history, we cannot escape its results. The tyranny and death we imposed on others is now blowing back on all of us, as it must before we see the truth. If we are to survive ourselves, we must finally realize and act on the realization that there is no answer or salvation for any of us within our corrupt and irredeemable status quo. It is time for the living to leave Sodom and its Moloch-worshipping rituals of child sacrifice.

We can begin today by knowing the truth of the Kamloops death camp and the real history of the system that spawned it in order to halt this latest obscenity of deceit and coverup by the criminals. Stand down orders have been issued and will be enforced against those destroying the children’s graves. We urge people to come to Kamloops and join our witness and protest.

But more importantly, we call on you to act wherever you are to enforce the verdict that disestablished the Catholic, Anglican and United churches. Their property and assets can and should be lawfully seized as reparations for their atrocities against children. Squamish traditional elders in Vancouver did so in March 2008 when Siem Kiapilano legally evicted those churches from his territory. The rest of us can do nothing less if our words are to be more than words.

At the end of the day, we have learned that the power to stop evil and defend the innocent lies in our own hands, but only once we recover ourselves, form the ground of battle and refuse the lies and the strategies of our adversary. The events in Kamloops these days are the playing out of a huge exorcism of that adversary that a few of us began in 1995 and that has reached as far as Rome.

So do not succumb to the lies of that expelled entity. Step out of its collapsing world while you still can, lest you too are embraced by the mass grave that is planned for humanity by the same dark power that slaughtered those children and shoved them in the ground mercilessly. ,

Kevin Annett (left) with Mohawk natives on Parliament Hill, summer 2012

Listen to Kevin and the Voice of the Republic live every Sunday at 6 pm eastern at . The website of the Republic is See the evidence of genocide in Canada and globally at and  and .
Some of Kevin’s books can be ordered here:Murder by Decree – The Crime of Genocide in Canada:
Unrelenting: Between Sodom and Zion:
Establishing the Reign of Natural Liberty: A Common Law Training Manual
At the Mouth of a Cannon: Conquest and Cupidity on Canada’s West Coast ,  
Truth Teller’s Shield: A Manual for Whistle Blowers & Hell Raisers:
Establishing Liberty: The Case for the Republic of Kanata
Here We Stand: The Call of the New Protestant Reformation
Fallen – The Story of the Vancouver Four:
The Sacrifice – Of Family and Empire:
1497 and so on: A History of White People in Canada or, The Caucasian Healing Fund :
The Border: A Post-Canadian Anthology
Kevin’s award winning documentary film Unrepentant can be viewed at . See also an insightful personal interview “Who is Kevin Annett?” (2013) at: and also: and





Zoom funerals: some suggestions for etiquette

The Honourable Steven Fletcher has served as a member of Parliament as part of Canada’s federal government and Manitoba’s provincial government.


Zoom funerals… I just experienced my first one, and here are some observations.

My beloved Uncle Peter passed away this week. He died in New Zealand.

I wish to share some lessons that may be helpful to you when using Zoom or equivalent.

It happened so quickly and my family is all over the world, so we could only participate using Zoom. Unfortunately, it was done badly.

I will share with you some suggestions so you will not have to experience what my family did this week.

First, make sure everyone has the correct app.

Second, be very clear on which time zone is being used and everyone should know their local time.

Third, people should familiarize themselves with Zoom beforehand. For example – know how to mute and unmute.

Fourth, make sure everyone who is speaking at the funeral is speaking into the microphone. Sadly, at our Zoom event, somebody moved the microphone and no one online could hear what was being said.

Fifth, make sure that the funeral chapel or whomever is controlling the feed can be accessed by an alternate method of communication. It would have been very helpful if those who could not hear could in real time email, text or message the funeral staff to place the microphone appropriately.

Sixth, the funeral chapel staff should stay in the room to deal with incoming text messages, or microphone movements etc. The person at my Uncle’s funeral just disappeared for the family portion, which is also the most important segment.

Seventh, consider introducing those in attendance, especially if the numbers are manageable. The family may know each other, but they will not know the friends of the deceased if they live on the other side of the world.

Eighth, the camera needs to be focused. Perhaps more than one camera could be used. In this way, those online can look around the room or zoom in or out. We only had one view from the corner of the room.

Ninth, those on Zoom need to be aware of the lighting behind them: too much light messes up the view.

Remember people can see you during a Zoom service, unless you change the setting which would be rude in my view. In the same vein, since you are going to be seen, it is important to dress appropriately. If you wear a suit and tie in person at a funeral, then one should do the same on Zoom. This last suggestion is my personal preference, but my logic is with Zoom, it is supposed to be as if you were there, and if I was there, I would have been wearing a suit and tie regardless of whose funeral it was.

Finally, number ten. Let there be time to notify family, even though they may not be there. In this case, the service was only a couple of days after my Uncle’s passing. With another few hours, we could have contacted many more cousins and second cousins, and childhood friends etc.

If you cannot be at a funeral, there are ways to be there in spirit. My Uncle was a New Zealander through and through. His loss is felt.

I hope these ten lessons will be of help. Remember to record the ceremony!

–The Honourable Steven Fletcher

May 17, 2020


What has caused Tracey Cook to change her mind about Uber?


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The Honourable Harvey Spiegel, Q.C.

by Harvey Spiegel

On Nov. 18 2014, at a press conference announcing the City’s application to restrain all Uber operations in Toronto, Tracey Cook, the executive director of Municipal Licensing and Standards Division of the City (MLS) said:

“Uber has been operating since 2012 without a proper taxi brokerage license or a limousine brokerage license and since September of 2014 have been recruiting unlicensed drivers with unlicensed vehicles to provide taxi services.”

Uber’s unregulated status puts people in harm’s way due to unregulated fares resulting in alleged price gouging, inadequate insurance, increased safety risk to the drivers due to lack of training.

In her sworn affidavit filed in support of the City’s application, Cook also made the following statements:

  1. The City has brought this application to restrain Uber’s ongoing business operations in the Toronto because Uber is operating in flagrant disregard of the City’s licensing regime, even while it aggressively promotes and expands its services and continues to recruit drivers.
  2. Also, the longer that Uber continues to operate in the City, the greater the potential
    for damage to the taxi and limousine industries. …, protecting the economic interests of participants within these industries is not the City’s role as regulator, but the City has an interest in the long-term sustainability of the industry because it is an important part of the public transportation network. The
    , City wants, among cither things, tdencourage-investment toensure safe, affordable; and equitable service, increase the number of accessible and fuel-efficient taxicabs, and support other important policy initiatives.
  3. I am also concerned about Uber vehicles increasing congestion in Toronto and,
    particularly, the downtown core, which is a key consideration the City makes when determining the appropriate number of taxicabs. It is important to the economic and environmental well-being of the City and beneficial to public health for the City to reduce vehicular traffic when possible; increasing the number of vehicles operating as taxis and limousines will do the opposite.
  4. Therefore, for the protection of public safety, consumers, and the economic and
    environmental well-being of Toronto, the City is seeking clear direction that Uber must cease its operations immediately. It is important to the City and to the public that the issues raised in this application be determined quickly, on an urgent basis

As the executive director of the body charged with the duty to enforce the City’s Licensing laws, Ms. Cook, has an obligation to explain to the public what has caused her to change her mind since she made these statements.

The City’s 2014 injunction application failed because the court found that narrow definitions of Taxicab Broker and Limousine Service Company in the Municipal Code did not capture the activities carried on Uber. Following this decision, the City amended these definitions in the Code to clearly capture Uber’s activities.

Yet Uber continues to flagrantly flout the law; only now, they are doing so with 15,000 to 20,000 vehicles instead of an estimated 6000 in 2014. What has happened to Ms. Cook’s concern about of these vehicles impact on traffic congestion and impact on the economic and environmental well-being of the City?

What happened to her concern about the potential for damage to the taxi and limousine industries? That potential has now become a devastating reality which seriously threatens the long-term sustainability of an industry that in Ms. Cooks words “is an important part of the City’s public transportation network.”

In 2014, Ms. Cook asked the Court to act on an urgent basis to direct Uber to cease its operations immediately for the protection of public safety, consumers, and the economic and environmental well-being of Toronto.

What has caused her to change opinion about the imminent danger posed by Uber’s illegal activities?



Insurance Amnesia: When did auto insurance become a joke?

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Philomena Comerford, President and CEO of Baird MacGregor Insurance

By Philomena Comerford

President and CEO, Baird MacGregor Insurance


To your auto insurance company, carrying paying passengers falls into the same group of troubling excluded uses as does carrying explosives or radioactive materials.

For UberX drivers who mistakenly believe they are “ride sharing,” the news is not good. UberX is not ride sharing; UberX drivers are carrying paying passengers for profit which is absolutely excluded under their personal auto policies.

Unless you have an OPCF 6A Endorsement that permits carrying paying passengers as part of your policy, you are not insured. Every taxi and limousine in Ontario carries this endorsement. UberX drivers are either under the mistaken impression that they do not need this endorsement or are deliberately hiding this excluded use of their personal vehicle from their insurer.

To those of us who have worked for decades as insurance professionals, it seems that politicians, police, and media have been stricken with some kind of “Insurance Amnesia,” the chief symptom of which is to forget that it is against the law to drive without proper insurance, and that personal insurance policies specifically exclude drivers who carry paying passengers.

UberX continues to operate without insurance despite Toronto Council’s motion requesting they cease operating until they are brought within the law.

Insurance Amnesia is running rampant. Officials who are elected to design and uphold the law are, incredibly, promoting wholesale disregard of Ontario’s insurance laws. By now, Tim Hudak, John Tory and City Councils across the province should be fully aware that UberX drivers who do not carry an OPCF 6A endorsement are not covered to carry paying passengers; yet when Toronto’s Chief of Police says he does not have the resources to enforce the law, no one bats an eye.

When did insurance become a joke in Ontario?

In the case of UberX drivers who are pulled over while transporting paying passengers, police or licensing and standards by law enforcement officers should simply ask for a copy of the 6A endorsement and charge the driver if he fails to produce evidence of this proper insurance.

City Council does not have the authority to re-write Ontario’s Mandatory Insurance Act or the Highway Traffic Act. No matter how much users love UberX, technology does not trump the law. To the insurer, it does not matter if the car was dispatched using an app or dispatched using a telephone. If you’re making money from it, you are carrying paying passengers. It’s black and white; there are no shades of grey.

In October, Aviva Insurance began cancelling the policies of clients found to be driving for UberX. Politicians and police now have concrete proof that UberX drivers are not covered by their personal policies and yet police have no plans to take action; this, while they tow hundreds of cars during the “parking blitz.”

This begs the question: which is the greater societal crime to which enforcement resources should be allocated, illegal parking or uninsured vehicles?

Promoting the idea UberX drivers need some special new insurance product is disingenuous and irresponsible. The product that UberX drivers need exists right now: it is the OPCF 6A endorsement. UberX drivers are free to purchase this at a cost of about $4000 to $10,000.

Let’s admit the truth. Uber doesn’t want a new product; it wants a cheaper product.

In spite of all the recent publicity, UberX drivers continue to drive without commercial insurance; this constitutes insurance fraud. By systemically hiding UberX activity from their insurers, considerably increased injury exposure will push the cost of your personal auto insurance up over time, undermining Ontario’s mandate to reduce it.

UberX drivers stubbornly ignore the Financial Services Commission of Ontario and Insurance Bureau of Canada’s warnings about the personal auto paying passenger exclusion and the City of Toronto’s cease order.  It is wishful thinking that these same UberX drivers would buy any new product later when they won’t purchase the existing product now.

Now that Aviva has had the intestinal fortitude to take a stand with uninsured UberX drivers, perhaps the rest of the insurance industry will drink a cup of courage and do the same thing….. before a tsunami of uninsured injury claims come rolling in.


A modified version of this commentary was originally published at Landmark Report

Philomena Comerford is President & CEO of Baird MacGregor Insurance Brokers LP and its affiliate, Hargraft. 

She joined the firm in 1980 after serving at a national brokerage, is the incumbent President of the Toronto Insurance Conference Board, member of the Insurance Brokers Association of Canada’s board of directors, and is a past Chairman of the Insurance Institute of Canada having also served on IIC’s Examination, Education and Executive Committees. 

She is also the incumbent Chair of the Insurance Brokers Association of Canada’s Political Action Committee.  Philomena has served on the Ontario Automobile Operating Committee of the Facility Association and is a frequent public speaker on insurance and risk management topics.

Philomena participated in The City of Toronto Taxicab Review in a series of roundtable consultations regarding public vehicle insurance and risk management best practices.  Baird MacGregor is an established specialty commercial automobile insurance provider with significant public vehicle insurance expertise. 


Political will, not new rules, needed to regulate Uber

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“We took 7 million calls in 2012,” Gail Beck-Souter said that year. “No one is more interested in making riders happy than we are.”

By Gail Souter, President

Toronto Taxi Alliance

Toronto’s taxi industry agrees with Uber’s Chris Schafer on one thing: Uber must be regulated.

As a matter of fact, all of the authority required to regulate it exists right now, in Toronto City by-laws section 545 (which govern ground transportation) and Ontario’s Highway Traffic Act (section 39.1 which governs public transportation for compensation).

We disagree that Uber deserves its own special, custom-created regulatory category.

UberX came to Toronto one year ago and launched its business deliberately choosing to disregard and ignore every one of Toronto’s by-laws and the insurance requirements of Ontario’s Highway Traffic Act. This outrageous act of civil disobedience has, astonishingly, been tolerated by Toronto politicians and Toronto police.

Toronto has all the power and authority it needs to regulate Uber right now. However for the past year, it has simply chosen not to enforce its own laws when dealing with UberX, whose drivers provide transportation for compensation in their personal vehicles, an activity which flies in the face of every regulation Toronto has ever enacted to protect public safety.  Yet at the same time, it has continued to enforce these bylaws with the legally licenced taxi industry.

Uber, a foreign company, has ignored all of Toronto’s local laws, and is now demanding Toronto re-write its by-laws to satisfy Uber. This is brazen and unacceptable.

The taxi industry in Toronto is subject to hundreds of separate requirements under By-law 545. Either these requirements are important to public safety and need to be followed; or they are no longer necessary and do not need to be followed by anyone. Fair enough: what is not fair is to use these rigorous requirements to commercially hog-tie the taxi industry while Uber is allowed to ignore them.

No one is suggesting Uber should not be allowed to dispatch cars in Toronto; we maintain simply that Uber should follow all the same rules for accountability and public safety that all the other dispatch companies follow.

When Schafer writes “Uber welcomes the opportunity to be regulated and follow the rules proposed by MLS,” he overlooks completely the fact that this regulatory framework already exists, and Uber wants nothing to do with it. Why does anyone suppose Uber would follow this proposed new set of rules designed just for them? Ignoring local regulation is an entrenched part of Uber’s business model all around the globe.

Should Uber next decide to get into providing cheaper bus service on TTC routes, or running cut-rate, discount, uninspected Uber restaurants and bars, will Toronto bend over backwards once again to re-write the rules for Uber?

London’s Guardian newspaper interestingly identifies Uber’s motivation in interfering with city governance:

“A more apt understanding of Uber’s ambitions is that the company wants to be involved in city governance – fashioning the new administrative capacities of urban environments. Rather than follow government rules, like any other utility, Uber wants a visible hand in creating urban policy, determining how cities develop and grow, eventually making the city itself a platform for the proliferation of ‘smart,’ data-based systems.

“While Uber is currently fighting for deregulation, it is misleading to understand this as simply attempting to remove legal barriers to market forces. Rather, it is a process of disrupting political power. And Uber has already established itself as a power player.”

The taxi industry calls upon Toronto politicians to demonstrate political will in enforcing its own existing laws fairly and consistently for everyone. Do not reward Uber’s aggressive stance on flouting the law by writing Uber a law of its own.


The Op Ed above was submitted to the National Post on September 18th in response to Chris Schafer’s work of fiction on September 17th. We can only hope the Post will run it.


Star Wars Wisdom from Tom Smith

Princess Leia would have been fired from her job, but would launch a kick-ass start-up, Tom Smith theorizes.

Earlier this year, my brilliant friend Hugh MacPhie published an interesting piece: “What would Star Wars characters be like to work with?” 

I sent the link off to my son Tom in England; he’s so busy launching a new business, it took about 3 weeks to respond but when he did, it was totally worth reading! Nobody loves “Star Wars” more than Tom Smith; and no one works harder. So when he shared his observations on how useless Han Solo is, and how kick-ass Princess Leia would be to work with, he definitely caught my attention.

Just yesterday a friend and I were discussing how fundamentally
useless Han Solo was to the Rebel Alliance – he’s completely
self-centred, takes them to meet his friend Lando on Cloud City where
Darth Vader is waiting for them, then he gets frozen in carbonite
because he owes a gangster money and then the whole team (Leia,
Chewie, both droids and Luke) have to stop fighting the Empire and
spend the first third of the next movie recovering Han from Tattoine.

Han is worse than completely useless; he’s a liability. He can’t even
fix his own ship and needs Chewie to do it. He doesn’t deserve to be
such a popular character. (The only pinch he comes through in is
taking down the tie fighters that are locked on to Luke in the Death
Star trench; but why did he leave in the first place?)

For C3PO, in his defense, although he is a big downer he doesn’t
actually get in the way and he is like one of those co-workers you
have to put up with because no one else has his technical skills
(“fluent in over 2 million forms of communication”). Without C3PO the
whole story would have stalled in the first 30 mins because Uncle Owen
couldn’t find anyone that understands the binary language of moisture
vaporators and Luke would just have to spend all his time trying to
suck water out of the desert rather than going to find Old Ben Kenobi.
There are about a dozen points where the whole story would just
have to stop without C3PO’s translation skills.

R2D2 is a manager’s idea of a good employee, always does what he’s
told, loyal even though he could be paid double if he went elsewhere,
he’s no threat to take his manager’s job, doesn’t come up with his own
ideas and then get attached to them. It doesn’t sound like a career
path worth emulating. He doesn’t even get a medal after they blew up
the Death Star, even though he’s co-piloting Luke’s ship. He’s too
comfortable being underappreciated, which of course the organization

If I had to work with one of them it would be Leia. She’s always on
the ball, has lots of skills, family connections and isn’t a douche.
She would be the most valuable. She’d probably be fired from a big
company because she threatens her manager but then she’d succeed with
her own kick-ass start-up.


UberX drivers and insurance risk: it’s black and white

Media release

June 29th, 2015

June 29th, 2015 (Toronto) — To your Ontario auto insurance company, carrying paying passengers falls into the same troubling category as carrying explosives or radioactive materials.

Unless you have an OPCF 6A Endorsement as part of your auto insurance policy, you are not insured to carry paying passengers, states Philomena Comerford, President & CEO of Baird-Macgregor insurance.

“It’s a very specific endorsement. That’s what you need. This is the endorsement for which taxi drivers pay dearly; without it, your insurer can deny your claim,” she says.

“Technology does not trump the law. To the insurer, it does not matter if the car was dispatched using an app or dispatched using a telephone. If you’re making money from it, you are carrying paying passengers. Period, full stop. It’s black and white; there are no shades of grey.”

Comerford, a specialist in auto insurance, is gravely concerned that Ontario drivers have gotten the impression that they can work for so-called “ridesharing” organizations like Uber and Lyft with only the personal insurance policy they put on their car.

“People are getting into it thinking ‘Oh, it’s like delivering pizza! I’m going to be an UberX driver!’ They do not understand that they could lose everything they own. If they get involved in an accident and there’s no coverage; they could get a judgement against them putting all of their personal assets at stake plus they could face charges for not being properly insured.”

Uber, she says, “is trying to introduce a thousand shades of grey to something that’s black and white.”

Indeed, section 3 of Ontario’s OAF 1 Standard Auto Insurance application asks this very straightforward question:

“Will any of the described automobiles be rented or leased to others, or used to carry passengers for compensation or hire, or haul a trailer, or carry explosives or radioactive material?”

The answer to this question is either “yes“ or “no.” If the applicant answers “yes” to this question, he or she will almost certainly be declined for personal coverage and will instead be referred for a commercial policy.

If the applicant answers “no” to this question and then proceeds to carry passengers for money, the insurer can take the position that there was either misrepresentation or non-disclosure; potentially facing up to a quarter million dollar fine or even jail time for misrepresentation.

“The problem is that everybody is unaware.  It’s been hard getting people to see how important it is. The fact that the City of Toronto is ignoring the insurance issue is maddening: none of these people are properly insured! Injured UberX passengers, pedestrians, cyclists or other motorists could find out the hard way about personally insured UberX vehicle coverage gaps. Toronto has jurisdiction over municipal taxi licensing regulations, but not the provincial Insurance or Highway Traffic Acts.”

The issue of insurance for Uber drivers is now in the spotlight, owing to an accident which took place on June 3rd in Toronto when an Uber car carrying paying passengers apparently ran a stop sign and plowed into a Diamond cab. The Diamond cab is insured with an OPCF 6A Endorsement; the driver of the Uber car had a personal policy with DesJardins.

Joe Daly of DesJardins was quoted in the media after the accident stating, “DesJardins does not insure Uber drivers. We do not insure taxicabs. We do not offer commercial policies in Ontario.”

Comerford points out that a good deal of the confusion has resulted from the fact that Uber holds out an SPF 6 policy as “coverage” for its drivers.

“An SPF 6 provides non-owned auto liability coverage, and there is absolutely no connection between that and the OPCF 6A,” she says. “The purpose of an SPF 6 policy is to protect a corporation whose staff or others use their cars on company business. It does not provide primary coverage; nor does it meet the financial responsibility requirements of the province of Ontario. The critical endorsement is the OPCF6A, Permission to Carry Paying Passengers which must attach to an Ontario Auto Policy OAP #1- Owner’s Policy.”

“Without it, an UberX driver could lose everything they own in the event of an accident.”


 Media wishing to interview Philomena Comerford can call

Mary Valvano

Tel 416-778-8000 ext 2269


Backgrounder:  Risks of Misrepresentation

What is the risk of misrepresenting yourself to your auto insurance company – for example, declaring in Section 3 that your automobile will not be used to carry paying passengers, when in fact you are carrying paying passengers? The possible ramifications are significant, and they are printed on every insurance application[1]:

  • Warning – The Insurance Act provides that where: (a) an Applicant for a contract, (i) gives false particulars of the described automobile to be insured to the prejudice of the Insurer, or (ii) knowingly misrepresents or fails to disclose in the application any fact required to be stated therein; or (b) the Insured contravenes a term of the contract or commits a fraud; or (c) the Insured wilfully makes a false statement in respect of a claim under the contract, a claim by the Insured, for other than such statutory accident benefits as are set out in the Statutory Accident Benefits Schedule, is invalid and the right of the Insured to recover indemnity is forfeited.


  • Warning – Offences It is an offence under the Insurance Act to knowingly make a false or misleading statement or representation to an Insurer in connection with the person’s entitlement to a benefit under contract of insurance, or to wilfully fail to inform the Insurer of a material change in circumstances within 14 days, in connection with such entitlement.


  • The offence is punishable on conviction by a maximum fine of $250,000 for the first offence and a maximum fine of $500,000 for any subsequent conviction.


  • It is an offence under the federal Criminal Code for anyone to knowingly make or use a false document with the intent it be acted on as genuine and the offence is punishable, on conviction, by a maximum of 10 years imprisonment.


  • It is an offence under the federal Criminal Code for anyone, by deceit, falsehood or other dishonest act, to defraud or to attempt to defraud an insurance company. The offence is punishable, on conviction, by a maximum of 10 years imprisonment for fraud involving an amount over $5,000 or otherwise a maximum of 2 years imprisonment.


[1] Source: Ontario OAF1 application form

Dyslexia: how I hate the term

The trouble with dyslexia

by Malkin Dare

April 18, 2015 by mdare at 08:30 AM

This article by a teacher about her “dyslexic” daughter got me going. How much do I hate the term “dyslexia”? Let me count the ways.

Children’s ease of learning to read falls along a continuum. A few kids find it so easy that they practically pick it up if someone whispers the word “phonics” in the next room. The vast majority of kids readily learn to read with so-so instruction. And there is a smallish group of kids who find reading really hard and need to be taught very carefully.

The further along the continuum a child falls, the more carefully he or she needs to be taught. If only this were widely understood! Instead, most education systems find it easier to label the hard-to-teach kids “dyslexic” and thus avoid the heavy lifting necessary to overcome their difficulties. Particularly pernicious is the practice of focusing on the child’s strengths, in this case math and science.

Here’s what Siegried Engelmann, who has taught thousands of students to read directly or indirectly (as a trainer), has to say. “And we’ve shown for the past thirty-four years, that if kids are taught properly in kindergarten, you won’t have non-readers. There are NO non-readers. I’ve never seen a kid with an IQ in the range of 80 or above that couldn’t be taught to read in a timely fashion. And I’ve taken on various comers that said, ‘Oh, this kid has no visual perception’ and so on. They can all be taught to read if you start at the right level and you provide a sequence that is going to teach them systematically.” Thirty years ago, Mr. Engelmann offered a thousand dollars to anyone who could produce an exception to his boast, but he still has his money.

The trouble with the term “dyslexia” is that it implies a life-long condition, a handicap that must be accommodated and worked around, but the truth is that all children who are taught to read properly, no matter how difficult the process, end up in exactly the same place as children who were easy to teach – and the same high standards and bright future should be held out to them.

For more detail, click here. H/T TB


Parents turn in their kids

Small-town Ontario values survive.


From the Orono Times Weekly, March 25 2015:

Two sets of parents turned their sons in to police after seeing reports of stolen military-style pellet rifles.

Durham Regional Police are crediting parents of several teenagers for ensuring their sons took full responsibility for their role in the theft.

In a media release issued last week Tuesday, police reported that sometime between Saturday, February 21 and February 28, 2015, a cube van parked deep in the bush on a rural property on Concession Road 8, east of Canadian Tire Mosport Park was broken into. The property was used by weekend “war game” enthusiasts. Items stolen from the van include five assault style rifles – which according to police look very similar to real AK-47s and MR assault rifles, flare guns, a blank firing pistol and a 1964 decommissioned anti-tank missile and two black helmets. Investigators had been advised the missile was used as a prop during war games, it had been made inoperable. According to police the property is used be weekend “war game” enthusiasts who use decommissioned military equipment and Airsoft pellet rifles.

In a media release issued on Monday, March 32, Durham Regional Police report that two different families brought their 16-year-old sons to the Bowmanville police station in relation to the thefts. Three suspects were involved in the theft of the items while others knowingly took possession of stolen items. In all seven boys 15 and 16 years of age confessed to stealing or possession stolen items.

All the stolen items have been recovered and the seven teens have entered into diversion programs with the court, which if successfully completed will leave the teens with no criminal record.