The City of Toronto Municipal Licensing & Standards (ML&S) Division is soliciting comments on its review of current street food vending by-laws. The survey period stays open for comment until Halloween.
After wrapping up my own comments, it became clear just how much this means to my heart and tummy. I wound up with what is now a quick editorial of remarks the ML&S Division will have to chew through.
You, meanwhile, can digest an edited version of it here.
What do you think of the level of regulation of Toronto’s street food vending industry?
[Worth mentioning: I’m speaking as an outsider to the food truck and food cart industry, but I am qualified to speak on this as an urban planner and as an urbanist.]
I’ve experienced food carts and food trucks in quite a few cities beyond Toronto. I can map my experiences in Seattle, Buenos Aires, Phuket, Tokyo, Austin, Vancouver, and Houston. There are probably other cities I’ve forgotten about, too.
Given the capital and regulatory barriers which befell the 2009–2010-era Street Food Project (“Toronto à la Cart”), and given an anecdotal understanding of the costs linked with acquiring vendor licensing (plus exceptional expense to meet food safety regulations intended for fixed-location eateries), Toronto’s food truck ventures over the past couple of years — the “food truck craze” — suggest that the margins to break even as a vendor must be pretty high.
In turn, this also suggests how and why Toronto’s newer food truck vendors have had to assemble major food truck events (necessitating entry admission fees); purchase and import new, “all-in” vehicles (many truck outfitters are based in the U.S.); appear in high-profile locations; and participate in pre-existing “taste of the street”-type fests.
Of course, I could be completely wrong about all of this.
This high baseline of regulation might be discouraging two essential ingredients for a healthy urban food truck and food cart culture in Toronto:
- a reasonable entry threshold for chef-entrepreneurs to be able to participate and offer their food on a week-daily basis (and also to maintain steady, consistent service over time); and
- more importantly, an end to necessarily confine mobile food service to high-profile, high-cost venues and closed, admission entry-based events.
Both of these practical barriers in Toronto upend the very principles for what a vibrant history of street food globally has long delivered to people of all walks: affordably priced, physically accessible, flavourfully good food (wherever people will want to buy and eat that food) — doing so in ways to animate places that otherwise lay fallow socially and commercially.
That capital stakes are so high as a function of regulatory costs and requirements — notably, regulatory barriers which discourage street food vendors from siting and utilizing underused places (e.g., vacant lots in transition; parking lots unused for much of the week; inside low-trafficked city parks) — it’s understandable why Toronto’s culture and history with street food vending has yet to flourish as befitting to a city as ours.
Amalgamated Toronto also lacks much precedent for semi-outdoor food and coffee kiosks found in fixed locations where one can simply walk up to place an order. Unlike food trucks and carts, kiosks can take advantage of permanent facilities characteristic to fixed restaurants and cafés.
Seattle and Austin have long used this food service model as way to deliver espresso, breakfast tacos, and other foods on a walk-up, walk-away basis. The great thing about walk-up kiosks, as with food trucks, is it’s especially convenient when one has younger children in tow: the means to assemble everyone inside a restaurant setting — even fast food chains — can often be involved and exhausting.
Street food culture here remains an affair confined seemingly for two vending groups: vendors willing to work within long-standing regulations which necessarily confine offerings conventionally to street dogs, burgers, fries, and ice cream (e.g., Queen Street, in front of Nathan Phillips); or vendors willing (and able) to assemble the capital to meet a high baseline of participating otherwise. The financial risk involved tends to confine food truck appearances to assured, high-trafficked special events and high-profile venues.
Here’s the deal: street food is street food because it’s meant to be prosaic and exceptional at the same time. Street food is also meant to be accessible and affordable at the same time. And street food is powerful for catalyzing localized social activity and serving as starting points for new food offerings at the same time. This approach encourages new vendors to make their bona fide debuts close to home communities and build their reputation and their craft. Then they can extend horizons by taking their dishes on the road to other communities throughout our city.
This can certainly be done in a safe, sanitary manner without it being cost-prohibitive. A review and revamping of those licensing regulations could reasonably facilitate this stimulation.
Please comment on your level of satisfaction with food trucks operating in other cities.
The sheer variety of offerings and sometimes idiosyncratic menu items (whether it’s particular ingredients or regional dishes) have made my truck food and food cart experiences elsewhere a genuinely fascinating journey in of themselves.
When I can eat well and eat deliciously for well under $10 (or if feeling indulgent, $15), and if I can do it as I stumble into new flavours, new ideas, and time-tested comfort dishes made amazingly well, then I often get as much from those tiny, ordinary experiences as I do from visiting the city itself. Sometimes I get even more from it.
Do you think food trucks should be allowed to operate in front of restaurants?
That seems like a loaded question. Was it one parried by entrenched restaurant vendors who might be resistant to the growth of street food here?
If anything, by encouraging more people to drop by a specific area (like an intersection where an existing restaurant may already be), it really is in the positive interest of that restaurant. More foot traffic to a food truck also draws more eyes to what they as restaurateurs are offering.
The proliferation of street food may also stimulate existing restaurants to enhance their own menu offerings. This is what a competitive market is meant to facilitate, right?
Where should food trucks be allowed to operate?
Under-utilized private properties (like parking lots) can benefit from food trucks. Co-operative arrangements can benefit fixed-location businesses and mobile vendors alike.
Under-utilized city parks both large and small can definitely benefit from more pedestrian traffic. This traffic populates those public spaces. A populated public space brings a stronger baseline for public safety from having more “eyes upon the park, within the park.” Site location permits could be issued online by the City to licensed vendors.
Curb-side locations, meanwhile, can provide a third option for the aforementioned site settings, especially during winter months when snow accumulation makes city park and parking lot sitings less feasible. As with public spaces, a licensed vendor would have a way to buy a site location permit online on a first-come, first-served basis. That permit would indirectly pay for street maintenance costs (ploughing, sweeping, etc.).
The City, meanwhile, can stimulate curb-side siting circulation by regulating site permits for a particular location, for a particular vendor, to maybe a week or month at a time, before opening other vendors to seek out a permit for that curb-side spot. High-demand curb-side site permits can be priced at an adjustable premium, based on supply-demand and season-based metrics.
Street food ought to be mobile places of cultural, social, and economic engagement. They ought to showcase our remarkable plurality for cultural and social capital. Our plurality is what every other major city in North America invested in creative economies seems to quietly envy. By giving our visitors greater and easier access to street-side and public space food vending, we can kick up the spiciness of that envy a little bit further.
That’s how we ought to roll.