expand the definition of soliciting. Street prostitution was described as a " plague" and there was pressure to deal with activity that was claimed to blight residential and commercial areas, and to be associated with criminal activity, including drugs and exploitation of children. The federal government was seen to not be proactive on this prompting some cities to take action. Montreal (1980) and Calgary (1981) enacted bylaws that banned the use of streets and other public areas for prostitution. These cities claimed powers, derived from the provinces, to regulate the streets and restrict criminality. Although police and city officials claimed the bylaws to be effective, they were found to be unconstitutional. In Westendorp v R (1983) the Supreme Court found the Calgary by‑law was ultra vires. Similarly for Montreal (Goldwax et al. v. City of Montreal, [1984] 2 S.C.R. 525). These rulings therefore nullified other similar bylaws enacted or proposed in Vancouver, Niagara Falls, Regina and Halifax. However, a 1983 Montreal by‑law forbidding the selling of any services on city streets without a permit was upheld in Quebec Superior Court. Agitation for change continued at the municipal level as being most directly affected by the presence of prostitution. Ottawa and Edmonton created task forces in 1992 while Halifax, Montreal and Toronto police addressed juvenile prostitution and, in particular, exiting schemes. Ottawa Ottawa made 33 recommendations. Many of these focused on enforcement, while others addressed crime prevention, education and crisis intervention programs. Others supported the 1990 C49 report for a re-examination of the Fraser Report. Specifically, these addressed funding for research and more control of harassment or obstruction. The Ottawa report also asked the Minister to work with municipalities to establish a National Crime Prevention Council. In response, the City took action to deter automobile traffic in certain areas. Edmonton Edmonton focused on the juvenile issue, proposing amendments to child welfare legislation and the Criminal Code. It also proposed bylaws to regulate dating and escort services, exotic entertainers and massage parlours, including licensing, which were subsequently enacted. Toronto In response to the 1995 Federal-Provincial-Territorial Working Group on Prostitution report "Dealing with Prostitution in Canada," Toronto's Board of Health advocated decriminalisation in 1995, with the City taking the responsibility of regulating the industry. The City then endorsed these proposals, further specifying that it involved only adult prostitution, supporting the federal report's proposals on juveniles. Toronto also enacted a bylaw to restrict intimate