1170019 FINAL Automated Vehicle Location System … Vehicle...approximately $5.4 million dollars in...

Project Team

Aaron Cook Deputy City Auditor – IT

Jaki Gerald

Senior IT Auditor

Ross Tate City Auditor

Project Number

1170019

This report can be made available in alternate format

upon request.

Aviation Department

Automated Vehicle Location System Controls

September 12, 2017

Report Highlights

Trip Fees

Aviation is properly tracking ground transportation providers, and determining chargeable trip fees in accordance with City Code. Aviation has corrective controls in place to mitigate the risk of providers being overcharged.

System Accuracy

Radio frequency identification tags were correctly reported by Aviation readers an estimated 95.6% of the time. While tag readers are highly accurate, the risk of lost revenue remains. Due to the complexity of airport roadways, trip logic, and fee structures, estimating the amount of lost revenue is not possible.

City Auditor Department 140 N 3rd Avenue Phoenix, AZ 85004 602-262-6641 (TTY use 7-1-1)

Mission Statement

To improve the quality

of life in Phoenix

through efficient

delivery of outstanding

public services.

City Auditor Department

Executive Summary

PURPOSE We reviewed the Aviation Department’s (Aviation) ground transportation vehicle tracking and billing processes, and evaluated the vehicle location system’s application and general controls. We performed this work to provide assurance that Aviation is tracking and billing ground transportation providers accurately and in accordance with City Code.

BACKGROUND All ground transportation providers (providers) that enter Sky Harbor International Airport (SHIA), except those using GPS technology, must obtain a permit from Aviation’s Ground Transportation Office (GTO) and have a radio frequency identification (RFID) tag applied to their vehicle’s windshield. These tags are part of GateKeeper, a vehicle tracking system that uses electronic readers positioned throughout the airport to track vehicle activity. On a monthly basis, fees are charged based on the number of trips made by providers picking up passengers at SHIA. Providers are not charged for dropping off passengers at SHIA. Revenues related to these trip fees were approximately $5.4 million dollars in fiscal year 2016/2017. On June 18, 2016, the Phoenix City Council approved a City Ordinance to modernize SHIA’s ground transportation policy. This new policy applies to all businesses engaged in commercial ground transportation at SHIA. In addition to increasing fees, the ordinance also implemented new fees for several types of providers that had not previously been subject to fees.

RESULTS IN BRIEF Radio frequency identification tags were correctly reported by Aviation readers an estimated 95.6% of the time. While tag readers are highly accurate, the risk of lost revenue remains. Due to the complexity of airport roadways, trip logic, and fee structures, estimating the amount of lost revenue is not possible. During testing, the RFID tags were correctly reported by Aviation readers an estimated 95.6% of the time. GTO has controls in place to ensure tags and readers are active, and are monitored over time. Gatekeeper has a real-time reader activity feed that identifies readers that are not online, or that have been inactive for a predetermined period of time. The system will automatically generate an email to IT staff when an alarm is triggered for reader inactivity. Aviation is properly determining chargeable trips in accordance with City Code. We validated that providers’ vehicles were properly configured in GateKeeper so that charges were correctly assessed. We traced a sample of 88 providers’ trips through


SHIA and concluded that in all cases each provider was correctly charged per the City Code and GTO rules and regulations. GTO has detective controls in place to mitigate the risk of providers being overcharged. As noted, tags are not being read with 100% accuracy, resulting in some chargeable trips not being properly recorded by the system, and in lost revenue from providers. However, in rare cases a provider could be assessed a chargeable trip fee when the trip should have been non-chargeable. Aviation has implemented appropriate mitigating controls to ensure that providers are not overcharged. A trip exception report is reviewed to write off misreads. We reviewed the trip exception report and found that staff had researched and reviewed the report, maintained documentation supporting those charges written off, and verified the accuracy of those charges. System access to GateKeeper is limited to appropriate staff; however, access controls can be improved by limiting administrative access and implementing appropriate password controls. About one-third of user accounts have administrative access. This high-level access should be limited to only a few system administrator positions. Additionally, while the system has the ability to provide strong password controls, these automated controls have not been activated within the system. The following section includes our recommendations and the department’s response.


Department Responses to Recommendations

Rec. 1.1: Complete the updates to GTO policies and training manual to include tag monitoring via the Sequence Summary report, so staff are trained to determine that reported seat capacity is correct in GateKeeper, and that tags are: working when installed, monitored over time, and replaced as needed.

Response: GTO tag monitoring procedures will be developed, tested and implemented by November 30, 2017. These procedures will incorporate the use of the Sequence summary report and any additional reports needed to ensure information is entered correctly in Gatekeeper and that tags are working.

Target Date:

11/30/2017

Rec. 2.1: Formalize and document the policy and procedures to monitor trip fee exceptions in GateKeeper to avoid overcharging providers and to identify tag / reader issues.

Response: Formal procedures are being developed and will be finalized by November 30, 2017.

Target Date:

11/30/2017

Rec. 3.1: Create formal, documented procedures for Financial Management’s GateKeeper interface and billing processes. Include reconciliation procedures, and the proper segregation of duties (or other compensating controls).

Response: FMD will complete formal procedures for all processes. New staff is being hired and trained on the reconciliation process and segregation of duties will be detailed in the procedures. Appropriate user profiles in the Gatekeeper system will also ensure segregation of duties.

Target Date:

11/30/2017

Rec. 4.1: In compliance with City IT Standard s1.3 – Identity Management: formally provision user accounts (via Remedyforce), implement processes to monitor and remove inactive accounts, restrict administrative access to the system, and remove generic/shared accounts.

Response: All user accounts have been reviewed and any inactive accounts were deleted. Generic or shared accounts have been removed and will no longer be assigned in the system. The admin role will no longer be assigned as a default. Users will be assigned to roles with limited permissions based on their job classifications and duties. Technology has developed status report and they will review the user list on a quarterly basis and review and remove any inactive accounts.

Target Date:

Completed

Rec. 4.2: In compliance with City IT Standard s1.5 – Password Management: automate enforcement of password length, password interval, and password complexity. Store passwords in an encrypted format.


Response: Compliance with City Policy regarding password complexity has been implemented and programed into the system.

Target Date: Completed

Rec. 4.3: Ensure that IT incident management protocol exists for the timely reporting, tracking, and resolution of incidents involving GateKeeper.

Response: GTO staff has been notified that they must generate a Technology Help Desk Ticket every time there is an issue with the AVI system. Technology will add an AVI drop down tab to the General request form on-line. This will allow GTO staff to enter the issue in a timely, receive an almost instantaneous tracking number, and ensure the issue has been sent directly to the Technology team that will be able resolve the issue. The protocol has been established, it may take a technology a month to develop the AVI drop down.

Target Date:

10/31/2017

Rec. 5.1: Work with GPS providers to obtain complete and accurate monthly information as required by GTO ground transportation rules and regulations.

Response: Currently 2 of the 3 GPS providers provide the required data when transmitting their trip data. Outreach to the last GPS provider has begun and we anticipate to start receiving accurate and complete monthly information by December 29, 2017.

Target Date:

12/29/2017

Rec. 5.2: Consider implementing analytical, trend, or reasonableness reviews of monthly GPS provider activity.

Response: The GTO office is working with Technology to evaluate the data provided by the GPS providers on a monthly basis. Once all of the GPS providers are submitting the appropriate monthly information we will implement basic validation analytics.

Target Date:

12/29/2017


Scope, Methods, and Standards

Scope This audit included a review of the vehicle tracking and trip billing process since January 1, 2017, including the:

• Initial capture of RFID activity • Determination and calculation of trip fees • Interface with the City’s financial system (SAP)

We identified and reviewed both preventative and detective controls built into the input, processing, and output of data (application controls). We also reviewed general system access controls for compliance with the following City IT Standards:

• s.1.3 – Identity Management – defines the minimum key elements related to granting authenticated access to City information and information systems to prevent unauthorized or excessive access.

• s.1.5 – Password Management – establishes acceptable practices for creating

and maintaining passwords.

• si.1.5 – Back-End System Configuration Management – identifies the requirements for the back-end configuration management program for physical and virtual servers, including the requirement for departments to create and maintain backups of all soft and hard media and databases.

Those providers using GPS technology (rather than Aviation’s vehicle location tracking system) self-report their passenger pick-up activity on a monthly basis, and thus were not included in the system review. However, we reviewed the information supplied by these providers for adequacy and compliance with GTO Rules and Regulations. One component of trip logic and fee calculation is the time it takes a vehicle to complete a trip, as measured in travel time between two readers. If the time exceeds a predetermined limit for each set of readers (programmed into GateKeeper with considerations for the time of day, and the day of the week), the trip may or may not be considered chargeable. We did not evaluate the reasonableness of Aviation’s predetermined time limits between readers. Methods The following methods were used to complete this audit:

• Interviews and meetings with Aviation IT personnel • Interviews and shadowing of GTO personnel


• Participation in tours and system demonstrations • Verification testing of access control lists • Evaluation of role-based access controls • Review of documentation to support backup efforts • Sample testing and recalculation of trips reported and resulting fees charged • Review and evaluation of Aviation’s GTO and IT staff’s pre-implementation

testing • Recalculation of trip logic system calculations

Unless otherwise stated in the report, all sampling in this audit was conducted using a judgmental methodology to maximize efficiency based on auditor knowledge of the population being tested. As such, sample results cannot be extrapolated to the entire population and are limited to a discussion of only those items reviewed. Standards We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the performance audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.


1 – Input Controls

BACKGROUND Input controls are used to help ensure the integrity of the data entered into a computer system. In the GateKeeper system, the critical data inputs needed to calculate trip fees come from the tags, readers, and manual input of seat capacity by GTO staff. Tags The dependability and accuracy of the tags in use at SHIA are critical in determining providers’ chargeable trips; however, tags have inherent issues that can lead to occasional missed reads. Some tags might not be readable because they are:

• Defective from the vendor • Poorly placed on the ground transportation provider’s vehicle • Tampered with (covered in foil or have had the chip removed) • Outdated

Tags are expected to be highly reliable, but will never read with 100% accuracy. In general, errors heavily favor the ground transportation providers. To assess whether tag activity is being read with a high degree of accuracy, we:

• Reviewed vendor specifications • Reviewed results of Aviation’s pre-implementation testing • Assessed controls in place in the GT Office to ensure issued tags are working

Readers There are approximately 50 areas around SHIA, called plazas, where readers are installed to track providers’ vehicles. Each reader records data about the tags, such as the reader ID, tag number, and date and time of its passing. Each reader has its own memory (the size depends on the reader) so that a network outage will not result in lost data. The readers send the data they collect to GateKeeper’s database. See Appendix A for a map of SHIA that shows the locations of the various readers. Just like tags, the dependability and accuracy of the readers is critical in accurately determining providers’ chargeable trips. Therefore, we assessed whether controls in place ensure readers are working as intended.


Seat Capacity Phoenix City Code Section 4-78 Fees provides a fee summary for all authorized providers permitted prior to June 18, 2016* as follows:

Vehicle Size Beginning

1/1/2017

Beginning

1/1/2018

Beginning

1/1/2019

1 to 8 seats $2.25 $2.75 $3.25

9 to 23 seats $2.75 $3.50 $4.25

24+ seats $6.50 $7.50 $9.00

*Providers permitted on or after June 18, 2016 shall pay the 2019 rates in all years. When providers register or renew their permit, they are required to list their vehicles make, model, and seat capacity. GTOs use that information to verify the seat capacity. The GateKeeper system has a seat capacity based fee table listing the correct fees to apply to each trip. Due to the wide range of fees, it is important the correct seat capacity be input. Assigning the wrong seat capacity to a provider’s vehicle could lead to substantial financial impact over time.

RESULTS The RFID tags were suitable for use under the general conditions experienced by providers at SHIA. All RFID tags come from one vendor. We reviewed the vendor’s specification sheet to determine that the tags were suitable for Aviation’s purpose and conditions. These tags:

• Are readable up to 31.5 feet at highway speeds • Need operating temperatures between -40F and +185F • Attach with semi-permanent adhesive • Are waterproof, vibration tolerant, and are not damaged by long-term sun

exposure The vendor does not publish any type of accuracy rate. During testing, the RFID tags were correctly reported by Aviation readers an estimated 95.6% of the time, indicating that while tags are highly accurate, there is an expected loss of revenue to SHIA. However, due to the complexity of the SHIA roadways, trip logic, and fee structure it was not possible to estimate the amount of lost revenue.


To assess whether tag activity is being read with a high degree of accuracy, we verified results of the pre-implementation testing of tags conducted by Aviation staff in September 2016. Out of 136 times that test tags passed the predetermined readers, tags were missed 6 times leading to a 95.6% accuracy rate. In addition, we reviewed GTO’s Sequence Summary reports. These reports measure (by percentage) the frequency each tag is recorded passing through a possible set of readers, versus the frequency each tag is recorded passing through an impossible set of readers (a missed read). Although this calculation does not provide a true accuracy rate, this report was developed in an effort to increase overall tag accuracy by identifying and replacing tags with a high number of missed reads. Overall, the Sequence Summary reports we reviewed, after GTO’s replacement efforts, had average sequence rates of approximately 93%. As this report is new, no formal policy is in place to dictate how often the report should be run, what sequence rates are acceptable, and at what level the tags should be replaced. GTO has controls in place to ensure tags are active and are monitored over time. Completing the update of the GTO Training Manual would ensure that the importance of these critical controls are understood by staff, and that efforts to verify and improve overall tag accuracy are being performed consistently. GTO staff conduct ongoing provider audits that verify the last read on the vehicle’s tag and the seat capacity of the vehicle. We selected a sample of ten providers’ vehicles noting seven had evidence in the file of a GTO audit in the last year. Three were inactive. GTO has a training manual currently under revision. This manual explains how to determine that the tag is working by checking for the last time the tag was read. Aviation is monitoring the status of readers, and has a procedure in place to identify inactive readers and take action to bring them back online. Gatekeeper has a real-time reader activity feed that identifies readers that are not online or have been inactive for a predetermined period of time. The system will automatically generate an email to IT staff when an alarm is triggered for reader inactivity. We reviewed this online feed during our interview with IT staff, noting that all inactive readers had been investigated. Providers are being charged the appropriate trip fees based on their registered vehicle seat capacity. We used computer-assisted data analytics to review 2,400 vehicle makes and models in GateKeeper’s database to verify that providers’ vehicles were assigned the correct seat size based on their vehicle make, model, and description. Our review found no errors in the reported seat capacity.

RECOMMENDATION


1.1 Complete the updates to GTO policies and training manual to include tag monitoring via the Sequence Summary report so staff are trained to determine that reported seat capacity is correct in GateKeeper, and that tags are working when installed, monitored over time, and replaced as needed.


2 – Chargeable Trips

BACKGROUND The proper determination of chargeable trips is essential to Aviation’s compliance with City Code and its efforts to be a successful business partner with its providers. Zone readers collect data from tags passing by specific locations. At the end of each day, all of the data collected from the readers is compiled and processed through a complex algorithm that determines how many trips each provider made during the month and how many are chargeable based on City Code. To assess whether Aviation is accurately determining which trips are chargeable we:

• Tested a sample of trips to determine the fees assessed were chargeable in accordance with City Code.

• Assessed controls in place in the GTO to ensure providers are not overcharged.

RESULTS Aviation properly determined chargeable trips in accordance with City Code. In accordance with City Code, a provider is only charged once per visit to SHIA to pick up passengers. No charge is assessed for dropping off passengers. For taxis, a single-point trip fee is assessed upon entering the SHIA’s Taxi Hold Lot (C-Lot), but for all other providers, a passenger pick-up (or a “chargeable trip”) is determined based on spending more than a predetermined time in a pick-up zone. A pick-up zone is the distance between a pick-up zone entry reader and a pick-up zone exit reader. There are multiple pick-up zones throughout SHIA. The predetermined time limit for which a charge is incurred is not the same for all pick-up zones. The predetermined time limit for each zone may also change depending on the time of day and day of week. A trip starts when a provider passes a pick-up zone entry reader, and ends when the provider passes the pick-up zone exit reader. The trip is chargeable if it is the initial chargeable trip, and the time incurred in the pick-up zone exceeds the set time for that pick-up zone. See Appendix B for a map of the SHIA reader locations. The pick-up entry readers and the pick-up exit readers are shown in red. The tan paths between these readers represent the fee zones. We obtained a history of all reads by each registered tag for the month of March 2017. From this population, we sampled 88 chargeable trips made by 30 ground transportation drivers. From their read history, we traced each provider’s trips through SHIA and concluded that, in all cases, the provider was correctly charged in accordance with City Code and GTO rules and regulations.


GTO had detective controls in place to mitigate the risk of providers being overcharged. Strengthening these controls by formalizing and documenting the related procedures would ensure that they are implemented consistently, and that trip fees are being charged in accordance with policy and City Code. As discussed in Observation 1 – Input Controls – Tags, tags will not be read with 100% accuracy, which will generally lead to lost revenue due to providers making some chargeable trips that are not recorded properly by the system. However, in rare cases a provider could be assessed a chargeable trip fee when the trip should have been non-chargeable. This occurs primarily when a provider’s tag is recorded as leaving SHIA but is missed by a reader as the vehicle turns around and re-enters SHIA (usually within minutes). In these cases, Aviation recognizes that the provider’s route is continuing and the provider has not truly left SHIA; therefore, the provider should not be subject to an additional trip fee. This can also happen when a provider has been assessed a trip fee, then continues to another pickup zone and misses either the entry or exit read, and then proceeds to and uses a third pick-up zone. At that point, the system believes it is the provider’s initial pick-up, so it charges the provider. The mitigating control for these risks is a trip exception report from GateKeeper which identifies all providers that incurred two chargeable trip fees within fifteen minutes of each other. GTO staff research the tag read history for these ground transportation providers and will:

• Write off one of the charges if they occur within seven minutes of each other as it is highly unlikely that a ground transportation provider could have made two separate trips to SHIA picking up passengers within a seven-minute period.

• For all other charges within fifteen minutes of each other (but more than seven minutes apart) staff will trace the ground transportation providers route through SHIA to determine if it is likely that a missed read caused the secondary fee and will write off those that appear to be due to misreads.

We reviewed the trip exception report for the week of April 9, 2017, and found that staff had researched and reviewed the report, maintained documentation supporting those charges written off, and that charges were verified. There were a total of nine charges on the exception report for the sample week. As this control is new, no documented policy or procedure is yet in place to provide explanation and guidance, or to formalize this process. We also reviewed the billing file for the month of March 2017 noting no trip fees occurring within seven minutes of each other.

RECOMMENDATION 2.1 Formalize the policy and procedures to monitor trip fee exceptions in GateKeeper

to avoid overcharging providers and to identify tag / reader issues.


3 – Fees and Billing

BACKGROUND Each month, once GTO staff is done making final adjustments, IT staff creates a summary charge file that is uploaded by Aviation’s Financial Management staff into SAP, the City’s main financial application. Once uploaded, the Financial Management division is responsible for reconciling the amounts in SAP to ensure that the upload from GateKeeper was successful. The actual invoicing and payment collections are handled by Financial Management in SAP and are not within the scope of this audit. At the time of our audit, IT staff was working to automate the interface, and the Financial Management division was in the process of documenting formal procedures for the billing function.

RESULTS Formalizing billing and reconciliation procedures performed by Financial Management staff would help ensure accurate and timely billing of ground transportation providers. We compared the monthly charge file from GateKeeper to the SAP billing report for March 2017, noting agreement in total. However, no documented procedures were in place for the monthly interface, billing, and reconciliation processes. In addition, staff members in IT and in Financial Management who were involved in this process have administrative account system access to GateKeeper, creating a potential lack of segregation of duties.

RECOMMENDATION 3.1 Create formal, documented procedures for Financial Management’s GateKeeper

interface and billing processes, including reconciliation procedures and the proper segregation of duties, or other compensating controls.


4 – General Controls

BACKGROUND We reviewed the following general control areas to determine controls were in place and operating as intended:

• Identity management • Password management • Incident reporting • Database backup procedures • NTP time server protocol

Password Management Effective access management practices include procedures for access administration and for assigning role-based access, based on each user’s unique job function. We evaluated access management against City IT standards. City IT Standard s1.3 – Identity Management requires that accounts be formally provisioned, monitored for inactivity, and disabled for terminated or transferred employees. City IT Standard s1.5 – Password Management has specific requirements regarding password length, complexity, and intervals. Incident Reporting Incident management ensures that incidents involving hardware or software are recorded, monitored, and resolved in a timely manner, and to the end-users’ satisfaction. Aviation uses Remedyforce as their incident management system. We reviewed the incidents reported by Remedyforce since January 1, 2017 for evidence of proper reporting and tracking. Back Up Procedures In the case of database corruption or hardware failure, compliance with IT Standard si1.5 – Back-End System Configuration Management can help ensure that Aviation is protecting itself against loss of data. Network Timing Protocol (NTP) Because trip fees are based on the time spent in a pick-up zone, the timekeeping and synchronization of the readers is critical. If readers are not operating properly, trip fees could be inappropriately assessed.


RESULTS Access to GateKeeper is limited to appropriate personnel; however, controls could be improved by limiting administrative access and disabling inactive accounts. We found 95 user accounts in GateKeeper. All users were active City employees or authorized contract staff. However, user accounts did not meet the standard formatting requirements of the City, limiting management’s ability to monitor for terminated employees. We also noted that 34 of the 95 user accounts were assigned administrative privileges. This broad level of access should be limited to only a few system administrators. Five accounts had no activity for over ten months, yet were not deactivated. We also found three generic or shared administrative accounts. All user accounts should be assigned to a unique individual, so access can be appropriately tracked.

City IT Standard s1.3 – Identity Management Requirements

In Compliance?

Provisioning: access formally requested and approved

Inconsistent

Inactive Accounts: disabled at 90 days of inactivity

No

Access Review: regularly reviewed (quarterly or annually)

No

Removal: upon termination/ transfer

Inconsistent

No Generic or Shared User Accounts

No

Password configurations in GateKeeper are currently set at minimum levels, although GateKeeper is capable of supporting stronger City password standards. When users are added to GateKeeper, they are given a unique, randomized password. Once they successfully log in, they have the ability to change their passwords, but there is no requirement for strong passwords, or for changing passwords at set intervals. Also, passwords are not encrypted, but are stored in plain text in GateKeeper.


City Standard s1.5 – Password Management Requirements

In Compliance?

Minimum Length 8 characters No

Minimum Interval 60 days No

Password Complexity 3 of 4: upper alpha, lower alpha, numeric, special

No

Re-Use of Password 12 changes No

Failed Login Attempt Lockout

5 attempts No

Aviation’s utilization of Remedyforce for the timely reporting, tracking, and resolution of incidents involving GateKeeper could be improved. We reviewed six incidents related to GateKeeper reported in Remedyforce, noting that these incidents, with priority levels and due dates, were assigned to staff members. All six were handled timely. However, during our fieldwork we noted two incidents that were not handled through Remedyforce:

• A network outage on March 21, 2017, caused most readers to go offline for a period of several hours. The duration was short enough that the readers subsequently uploaded all stored reads to GateKeeper, avoiding any data loss.

• A batch of unassigned tags received from the vendor were not properly activated. When GTO became aware of the problem, the issued tags were recalled and the vendor was notified. The vendor identified the issue and reactivated the tags.

Databases supporting the GateKeeper system are being backed up timely and in accordance with Aviation’s established back-up procedures. We verified that database backups were being performed weekly in accordance with Aviation’s established back-up procedures. Aviation is using time-synchronization technology to synchronize all critical system clocks and readers, so that all clocks have the correct and consistent time as received from industry-accepted time sources.


We verified through configuration snapshots that GateKeeper servers and devices receive their timing information from Aviation’s central time servers. These central time servers are aligned with each other to keep accurate time. The designated central time servers receive time signals from external sources based on industry-accepted practices.

RECOMMENDATIONS 4.1 In compliance with City IT Standard s1.3 – Identity Management, formally provision

user accounts (via Remedyforce), implement processes to monitor and remove inactive accounts, restrict administrative access to the system, and remove generic/shared accounts.

4.2 In compliance with City IT Standard s1.5 – Password Management, automate

enforcement of password length, password interval, and password complexity; store passwords in an encrypted format.

4.3 Ensure that IT incident management protocol exists for the timely reporting,

tracking, and resolution of incidents involving GateKeeper.


5 – GPS Providers

Authorized providers such as Uber and Lyft normally use GPS technology rather than the assigned RFID tags to track their activities. These providers must use a first in, first out dispatch system, and must track, record, and transmit trip information for their drivers in real time to GateKeeper. To prevent these providers’ drivers from repeatedly circling SHIA, which creates congestion, Aviation has established a virtual perimeter (called a geofence) around SHIA, as well as several waiting areas within SHIA. The providers must disable the ability for their drivers to accept reservations while they are within the geofence unless they are in a designated waiting area. Each month, GPS providers submit detailed reports of all trips along with remittances of fees due. These reports must include dates, times of geofence entries and exits, latitudes and longitudes of pick-ups, driver identification numbers, license plates, and trip identification numbers. Because GPS providers are self-reporting, fewer controls exist to ensure all fees owed to Aviation are properly recorded and remitted. During fiscal year 2016/2017, the two largest GPS providers, Uber and Lyft, remitted approximately $2.6 million in trip fees.

RESULTS Inaccurate or incomplete data from GPS providers could lead to inaccurate reporting and remittance of trip fees. We reviewed the monthly reports sent to Aviation from both Uber and Lyft, the two largest providers reporting via GPS reports, to determine compliance with GTO rules and regulations for reporting. Uber Uber’s monthly detailed reports include all the data required by rules and regulations for the pick-up of passengers. Data also includes information regarding drop-offs, although providers are not billed for drop-offs. We conducted a high-level review of the data and noted some issues that might lead to inaccurate determinations or restrict Aviation’s ability to monitor trips and the remittance of trip fees:

• Some of the coordinates listed in driver routes do not correspond with any coordinates in or around SHIA. The following map shows a summary of the coordinates listed in Uber’s April 2017 detail report.


• There were 568 vehicle identification numbers with blank license plates. We were unable to determine if trip fees were properly remitted for these vehicles.

Lyft While detailed information regarding Lyft’s driver activity is uploaded live to GateKeeper, Lyft submits only a monthly summary of passenger pick-ups to support the remittance of fees. No monthly detailed report is submitted as required by the rules and regulations. Developing analytics to monitor GPS provider reports of monthly activity at SHIA will help ensure that Aviation is receiving all trip fee revenue due from these providers. GTO is reconciling the amounts reported by Uber and Lyft in GateKeeper (via the live feed) to the number of trips reported in the month-end summaries, but because the data is from the same sources, additional review and analysis is warranted. No procedures to analyze the detailed data for accuracy has yet been developed. Such analysis could validate GPS coordinates and identify trend information.

RECOMMENDATIONS 5.1. Work with GPS providers to obtain complete and accurate monthly information

as required by GTO ground transportation rules and regulations. 5.2. Consider implementing analytical, trend, or reasonableness reviews of monthly

GPS provider activity.


Appendix A – AVI Reader Locations


Appendix B – AVI Reader Plaza Locations

1170019 FINAL Automated Vehicle Location System … Vehicle...approximately $5.4 million dollars in...

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