HomeMy WebLinkAboutOIG No. 23-11 Trolley Ridership InspectionJoseph M. Centorino, Inspector General
TO: Honorable Mayor and Members of the City Commission
FROM: Joseph M. Centorino, Inspector General
DATE: July 14, 2023
PROJECT: Trolley Ridership Inspection
OIG No. 23-11
PERIOD: October 1, 2021 -March 31, 2023
EXECUTIVE SUMMARY
This inspection was planned and carried out by the City of Miami Beach Office of the Inspector
General (OIG) at the request of Miami Beach Commissioner Ricky Arriola, who expressed
concerns regarding the accuracy of the reported ridership figures for the City's free trolley service.
Those figures, presented to the July 22, 2022 Finance and Economic Resiliency Committee
(FERC) meeting, had been based on an analysis of both manual counts recorded daily by trolley
drivers and the Automatic Passenger Counters (APCs) installed in the trolleys and relied upon by
the City Transportation and Mobility Department in connection with the 2019 Miami Beach Trolley
Passenger Survey data performed by Marlin Engineering, Inc.
The City trolley contractor, Limousines of South Florida, Inc. (LSF), is responsible for operating
the trolley system, and its subcontractor, TSO Mobile by Tracking Solutions Corp. (TSO Mobile),
hired by LSF at the direction of the City, to provide hardware, software, and installation of the
APCs, among other equipment. In addition, the City Transportation and Mobility Department is
responsible for monitoring and determining compliance with the executed Agreement and
Amendments with LSF.
OIG staff researched methodologies to test the reliability of the figures reported to the FERC and
performed an independent inspection to assess the accuracy of the reported ridership data
through visual examination of the limited available footage provided from video cameras installed
in the trolleys. The ridership counts derived from the video footage inspection by OIG staff were
then compared with the reported number of passengers from the APCs and the manual counts
prepared by the trolley drivers. The inspection concluded that the data generated by the APCs
installed in City trolleys and the manual counts prepared by the trolley drivers are unreliable
indicators of the actual ridership for the trolley system, based on the sampled trolleys examined
during March 2023.
Despite multiple requests, the OIG did not receive from the contractor all requested video footage
or daily manual ridership counts prepared by trolley drivers. On some occasions, substitute video
Page 1 of 9
footage of other non-requested trolleys was received instead of the requested footage. The
contractor's failure to provide all the requested video footage created a scope limitation for this
inspection. However, the Transportation and Mobility Department provided an Excel spreadsheet
to the OIG, prepared by TSO Mobile, containing March 2023 trolley drivers' manual counts and
APC counts, so that some additional analysis could be completed by OIG staff.
In the end, the OIG concluded that, due to the insufficiency of the camera footage provided; the
lack of reliable data on which to draw any inference regarding overall ridership; and the skewing
of the data due to the fact that among the nine trolleys tested, the ridership of one trolley was
included three times (which happened to be the trolley which showed the greatest percentage
discrepancy between the reported ridership and that observed by the OIG); no conclusion was
warranted concerning the overall ridership in the system, including any assessment of whether
the ridership count provided to the City was underreported or overreported. The OIG recommends
that the City consider utilizing a more reliable technology for the counting of passengers on its
trolley system.
Written responses to the draft report were received from the City Transportation and Mobility
Department, LSF, and TSO Mobile. Some, though not all, of their comments have been
incorporated into this final report. All responses received are attached to this report in their
entirety.
INTRODUCTION
On May 8, 2014, the City of Miami Beach entered into an Agreement with LSF for turnkey
operation and maintenance services of a Municipal Trolley System in the City of Miami Beach.
According to City Resolution No. 2014-28708, the Agreement provided an option to procure
additional equipment, including, without limitation, Global Positioning Systems with capabilities to
report, Automatic Passenger Counters, Wi-Fi services, and Automated Voice Information
Systems. Pursuant to Article 3, Section 1 of the agreement, the City Administration recommended
that the City secure the optional equipment through LSF, for a sum not to exceed $150,000, during
the initial five-year term of the Agreement, which the Mayor and City Commission approved and
authorized through Amendment No. 1.
Amendment No. 1 to the Agreement, approved on September 30, 2014, authorized the execution
of a subcontract between LSF and TSO Mobile to equip the trolleys with the following optional
equipment: Automatic Passenger Counters (APC), Automated Voice Information System, Wi-Fi
services, real-time GPS tracking services (with capabilities to provide mileage, service hours and
ridership reports, and capabilities to provide data in a format that is compatible with Miami-Dade
County's mobile application, "Miami Dade Bus Tracker") and additional automated stop
Page 2 of 9
announcement equipment, with the capability of displaying public advertisements. The OIG
recommends that in the future the City enter into a contract directly with the subcontractor to
enable direct access to the technology provider.
Exhibit B of LSF's contract with TSO Mobile, entered into at the recommendation of the City,
states, "The accuracy of our Automatic Passenger Counting Systems is considered to exceed
that of a single checker on board a bus and comparable to that obtained by two checkers, one
stationed at each door. APC users in the transit systems that have utilized our APC system
consistently express satisfaction with the accuracy of our APC system. In the following, the overall
concurrence value represents the total number of boardings and alightings 1 counted by the APC
system compared to the total number of boardings and alightings counted by experienced manual
checkers. The Manual-APC Deviation Range +/-1 represents the percentage of time the manual
and APC observations were within one (1) of each other. Implementation of our APC system will
result in APC Passenger Count Accuracy levels exceeding 95% concurrence with manual
observations."
Transportation and Mobility Department management emphasized that the comparison of APC
counts to a "single checker on board" is not meant to include the manual trolley driver counts, but
there has been no practice to place single checkers on board other than the drivers that could
provide the basis for a comparison. Therefore, the OIG relied upon its own visual inspection of
riders entering and exiting the trolleys to determine compliance with the Amendment 1 Exhibit B
standard cited above. The OIG's testing posited that, if the APC system report indicates 150
passengers rode a given trolley during the day based on the automatic counters, the manually
observed video ridership counts by OIG staff should range between 149 and 151, most of the
time (95%).
It is understandable that the accuracy of the manual counts performed by the trolley drivers may
be affected by the other responsibilities of the driver throughout the day, including assisting
passengers, driving, communicating with other LSF personnel, etc. Nonetheless, the fact that the
manual counts by the drivers are utilized in place of the APC counts when the latter counts are
unavailable, as indicated below, makes the accuracy of the trolley driver counts fair for
comparison with the OIG counts.
Miami Beach trolley service was suspended on March 26, 2020, following the outbreak of the
COVID-19 pandemic, and eventually resumed at a reduced service level on February 15, 2021.
Therefore, the pre-pandemic analysis involved all trolley operations prior to March 26, 2020, and
post-pandemic represented all trolley operations after February 14, 2021.
It is worth noting that the City does not base its payments to LSF on ridership but rather on
scheduled service hours and established hourly rates as stipulated in Amendment 11 to the
Agreement. Scheduled service hours are defined as the requested number of hours by the City
for services available to the public for transport along designated routes.
Furthermore, the Transportation and Mobility Department stated that fleet size for the trolley
system is based on desired frequency of service and service area, and not on ridership. The
service hours exclude deadhead hours2, interruptions in service, and idle times exceeding 15
minutes. The free Miami Beach trolley covers the following routes: South Beach Loop A and B,
Alighting means to get out a vehicle, especially a train or a bus, according to the Cambridge English Dictionary.
Deadhead hours refers to the measurement of time (in hours) when a vehicle travels from its garage or yard facility to the first
scheduled pick-up point or any time the vehicle travels from the last scheduled drop-off point to its garage or yard facility.
Page 3 of 9
Middle Beach Loop, Collins Express, and North Beach Loop (see Appendix A located at the end
of this report).
The OIG believes that accurate ridership figures would be helpful in the City's overall assessment
of the effectiveness of the trolley program, including the following :
• the number of trolleys that should be operating daily;
• identification of the busiest and least busy routes;
• the most productive hours of operation;
• assessment of the trolley program's appropriate funding level.
WORK PERFORMED
TEST 1
During the July 22, 2022, FERC meeting, the Transportation and Mobility Department presented
post-pandemic trolley service metrics. The following presentation extract indicated that daily
ridership had decreased by 56% from approximately 14,400 pre-pandemic daily riders to 6,300.
MIAMI BEACH
Official Webslto ol rh.e Cary of Miom• Beoch
Trolley Service
rat,ng Houf\ 18h,/<k,y l~ l,r./duy · 17
~hl(ttft !UM")' 1 S mu, 100lO "''" io ""'"
ltid,, J,,p 14.400/S 2S M 6,300/'J M ·56 N/A{d.,lly/aonual)
Co"/ponmo $2 30 SJ.00 3 N/A
o of veh,clo, '1S IS -40%n ~,vic.o "
Some ridership declines can likely be attributed to the changes in trolley operating hours and
frequency. Prior to the pandemic, trolley service was available 18 hours a day, operating from 6
a.m . to 12 a.m., with 25 vehicles servicing the public at an average interval of 15 minutes.
Following the pandemic, trolley service was initially reduced to 15 hours a day, operating from 8
a.m. to 11 p.m., with 15 vehicles servicing the public at an average interval of 30 minutes. The
Transportation and Mobility Department informed the OIG that trolley service was subsequently
expanded as of October 1, 2022, to include 21 vehicles servicing the public at an average interval
of 20 minutes and operates from 8 a.m. to 11 p.m., which is the current service level.
TSO Mobile representatives informed OIG staff that its automatic counter system produces
ridership reports that can be accessed through its http://app.tsomobile.com website. OIG staff
accessed the corresponding Passenger Counter reports from October 1, 2021, through March
31, 2023, to compute the average daily and monthly ridership. The results indicated an average
Page 4 of 9
of 5,205 daily riders from October 1, 2021, through September 30, 2022, and 6,232 daily riders
from October 1, 2022 through March 31, 2023.
Upon comparing the limited internal TSO Mobile data provided to the OIG with the figures in the
post-pandemic analysis presented by the City Transportation and Mobility Department to the
FERC covering a broader period, the OIG found those figures to be consistent. As the trolley
ridership data before July 1, 2021, was not available, it was not examined by the OIG, so its
accuracy could not be determined.
TEST2
OIG staff initially sought to determine the accuracy of the 14,400 daily ridership figures reported
in the 2019 Passenger Survey conducted by Marlin Engineering Inc. However, TSO Mobile
representatives informed the OIG that the 2019 trolley reports and related video footage were
unavailable, and, therefore, the accuracy of the related reported ridership could not be verified.
Given this limitation, OIG staff had to find an alternative method to assess the accuracy of reported
ridership data and to test the reliability of the passenger counting system.
In response to initial inquiries made by OIG staff, representatives from Transportation America
Inc. (TA), the parent company of LSF, stated that each trolley is outfitted with four interior
cameras. The related video footage is stored on a hard drive within the camera system .
Customers can only enter or exit the trolley through its one door, and the cameras record all its
activities.
In emails to the OIG, TA representatives stated that the video recordings would be stored for
approximately thirty days, thereby limiting the OIG's analysis to 2023 data. However, after
requesting video footage related to the operation of nine trolleys, each operating during a single
day within the prior thirty-day period, TA representatives indicated that video footage was only
available for up to two weeks, although the Exhibit A of Amendment 5 of the agreement states a
minimum period for the storage of recorded data of three weeks.
Consequently, OIG staff accessed the daily Passenger Counter reports from March 13 through
March 19, 2023, within the designated two-week period, and similarly requested video footage of
one day's activities for ten trolleys operating during the same week. The selected sample was
stratified to focus primarily on trolleys with higher reported ridership and to avoid those out of
service during the designated week.
After encountering unexpected difficulties obtaining the requested video footage, TA
representatives provided OIG staff with USB flash drives containing most of the recordings. It is
important to note that one trolley's video footage was unavailable, and substitute video footage
was received for two other trolleys, which resulted in footage for three different days related to a
single trolley, MB08, i.e., the footage provided for three out of the nine trolley days examined
included the same trolley. The OIG utilized all of this footage but must note that, while the repeated
use of footage for one trolley helped to confirm that trolley's inaccurate automatic counter, it would
have been far preferable to have received footage for two other trolleys.
OIG staff examined approximately 135 hours of video footage pertaining to 4,326 riders,
representing 9.4% of the 46,238 riders for the designated week. The number of passengers
entering each trolley during the reviewed day was counted and recorded. The table below
summarizes the identified variances between the TSO Mobile Passenger Counter reports and the
OIG video footage counts:
Page 5 of 9
Trolley Date Route•
TSO Mobile
Report
Video
Count** Variance Variance%
MB08 Thursday, March 16, 2023 South Beach Loop B 297 671 374 125.9%
MB08 Monday, March 13, 2023 Collins Express 301 710 409 135.9%
MB08 Saturday, March 18, 2023 Collins Express 373 643 270 72.4%
MB13 Wednesday, March 15, 2023 Collins Express 557 657 100 18.0%
MB15 Thursday, March 16, 2023 North Beach 417 416 (1) -0.2%
MB18 Sunday, March 19, 2023 Collins Express 659 749 90 13.7%
MB28 Thursday, March 16, 2023 South Beach Loop B 790 388 (402) -50.9%
MB30 Wednesday, March 15, 2023 South Beach Loop B 447 441 (6) -1.3%
MB31 Friday, March 17, 2023 South Beach Loop A 373 311 (62) -16.6%
Trolleys may cover more than one route each day.
** The video count figures include each time the trolley driver entered the vehicle during the examined day as
the APC counts would have done the same. The number of times that the trolley drivers was observed entering
the vehicle during the sampled days above ranged from three for MB13 to 21 for MB30.
The widespread positive and negative variances between the TSO Mobile reports and the OIG
video counts raise concerns about the accuracy of the rider counting process. Each variance,
except for trolley MB15, exceeded the threshold deviation listed in Exhibit B of the TSO Mobile
Contract, some significantly.
In addition, trolleys MB28, MB30, and MB31 were equipped with overhead people sensor APCs3,
which Transportation and Mobility Department staff presented to the OIG as a newer and better
technology than the one used on the other trolleys. As reported in the table above, the associated
variances ranging from 6 riders (-1.3%) to 402 riders (-50.9% ), failed to support the assertion that
the newer technology is more accurate than the older technology. It also reported higher ridership
than observed in the video footage related to all three sampled trolleys examined.
Consequently, the OIG recommends that the installation of overhead people sensor APCs for
more trolleys be suspended until the reasons for these deficient counts can be determined and
corrected. If not possible, other more effective counting methods should be researched and
utilized prospectively.
Although the objective of the analysis performed was to assess the reliability of the APCs, the
outcome of which suggests malfunctions leading to inaccurate reporting of ridership figures, the
OIG was also concerned with the inability of TA to provide all requested footage and the
occasional submittal of substitute unrequested footage. For example, video footage for an
additional eight trolleys was requested from TA representatives on April 18, 2023, pertaining to
dates ranging from April 10, 2023 through April 16, 2023, well within the 14 days designated by
TA. On April 27, 2023, the OIG received an email from TA stating that three of the eight requested
videos were obtained, three were unavailable, and they were in the process of obtaining the
remaining two.
The OIG was also informed that trolley drivers perform daily manual ridership counts, which are
compared with TSO Mobile counts, and used when the APC counts are not available. As a result,
the OIG emailed TA representatives on April 27, 2023, requesting the March and April 2023
manual ridership counts, but no response was received.
In the interim, the OIG requested and received an Excel spreadsheet from the Transportation and
Mobility Department, which was previously provided to the City by TSO Mobile, containing the
https ://people-sensing.com/sites/default/tiles/counter datasheet apc-eco engl.pdf
Page 6 of 9
APC counts and the daily manual ridership counts prepared by trolley drivers operating in Miami
Beach during March 2023. Consequently, the requested April 2023 video footage and daily
manual ridership counts prepared by the trolley drivers were no longer pursued from TA.
The OIG Auditors' examination of the March 2023 Excel spreadsheet found that the APCs for 202
of the 723 line items were blank (27.9%), containing no count whatsoever. This suggests that
APCs installed on many trolleys are not functioning and need repair. After eliminating the 202
blanks from analysis, the OIG compared the remaining 521 reported APC counts with the
corresponding trolley drivers' manual counts. Although the +/-1 benchmark stated in Exhibit B of
Amendment No. 1 is meant to apply, according to Transportation Department staff, only to a
possible manual account "by a single checker on board a bus" and not to the drivers' manual
counts, it was still concerning to the OIG that only 5 of the 521 line items were within the stated
benchmark.
It should be noted that, on those occasions where the APC devices are not functioning correctly
and do not report any daily riders, the trolley drivers' manual counts are substituted by the
contractor to represent ridership for those days until the devices are recalibrated and repaired, so
it is not illogical to compare the reported APC counts to the trolley drivers' manual counts as a
reasonable measure of their accuracy.
Although not tested by the OIG, it was recommended to the Transportation and Mobility
Department Director in a telephone conversation with the OIG that designated staff monitor the
submitted monthly Excel spreadsheets, if not already done, to ensure that the repair and
recalibration of all malfunctioning APCs occurs within a reasonable time.
Three sampled trolleys, MB28, MB30, and MB31, were equipped with the overhead people sensor
APCs containing cameras which provide a continuous view of the trolley drivers. The
corresponding video footage reviewed by OIG staff found the reliance on manual counts prepared
by trolley drivers questionable, as only one (MB30) of the six observed drivers of the examined
sampled trolleys equipped with overhead people sensor APCs was noticed recording ridership
counts through a clicker hanging from his neck. Although this is not conclusive evidence that
manual counts were not recorded by the other trolley drivers, it does raise questions as to the
origin and accuracy of the manual counts based on trolley driver input.
In a meeting with City staff and TA management, it was stated that the Agreement does not
prescribe how trolley driver manual counts must be completed . Given the number of blanks in the
APC counts for March 2023 (27.9%), the OIG believes that a defined methodology by which the
manual counts are to be performed by the trolley drivers will help result in more accurate ridership
figures reported to the City. As a result, it is recommended that these terms be prospectively
negotiated and added to the next Agreement.
The OIG also compared its video counts from the sampled trolleys examined, each for one day's
operation during the week of March 13 through March 19, 2023, with the manual counts prepared
by the trolley drivers (see the table below). In doing so, it was determined that the trolley drivers'
manual counts were similarly unreliable.
Page 7 of 9
Trolley Date Route Drivers
Manual Counts
OIGVideo
Count Variance Variance%
MB08 Thursday, March 16, 2023 South Beach Loop B 604 671 -67 -11.1%
MB08 Monday, March 13, 2023 Collins Express 758 710 48 6.3%
MB08 Saturday, March 18, 2023 Collins Express 768 643 125 16.3%
MB13 Wednesday, March 15, 2023 Collins Express 985 657 328 33 .3%
MB15 Thursday, March 16, 2023 North Beach 466 416 50 10.7%
MB18 Sunday, March 19, 2023 Collins Express 700 749 -49 -7 .0%
MB28 Thursday, March 16, 2023 South Beach Loop B 364 388 -24 -6.6%
MB30 Wednesday, March 15, 2023 South Beach Loop B 318 441 -123 -38.7%
MB31 Friday, March 17, 2023 South Beach Loop A 380 311 69 18.2%
In sum, the documentation provided related to March 2023 showed widespread differences
between the APC counts and the trolley drivers' manual counts. Furthermore, both counts
differed, some significantly, from the OIG video counts performed on the daily activities of nine
sampled trolley day-rides. Given the limited documentation received and the small sample in
comparison to the population , the OIG cannot conclude whether the APC counts or the manual
counts prepared by the trolley drivers are more accurate representations of ridership.
The OIG is also concerned that the City may have based some decisions regarding trolley service
on these inaccurate ridership figures. Going forward, the Transportation and Mobility Department
should periodically conduct its own sample ridership inspections with any deficiencies exceed ing
a designated percentage promptly addressed with the contractor until being resolved.
Based on the inspection done by the OIG and its communications with the City's Transportation
and Mobility Department, LSF, and TSO Mobile, the OIG recommends that the City consider
utilizing a more reliable technology for the counting of passengers on its trolley system.
cc: Alina T. Hudak, City Manager
Rickelle Williams, Assistant City Manager
Jose R. Gonzalez, Transportation Department Director
Nick Mazorra, COO, Limousines of South Florida, Inc.
Wendy Diaz, Sr. Technical Support Manager, TSO Mobile by Tracking Solutions, Corp.
Rafael Paz, City Attorney
Mark Fishman, First Assistant City Attorney
O FFICE OF THE INSPECTOR GENERAL, City of Miam i Beach
1130 Washington Avenue, 6th Floor, Miami Beach , FL 33139
Tel: 305.673.7020 • Hotline: 786.897.1111
Email: CityofMiamiBeachOIG@miamibeachfl .gov
Website: www.mbinspectorgeneral.com
Page 8 of 9
,..
'" 1?Y
LEGEND
O NORtH BEAa-t LOO,
COUENS
EXPltfSS
MlOOU: 8(A0.
LOOP
0 SOUTH BEA CH LOOPS
_ TRANSFER POINTS
':5 0 ~
~0 ~
~ O:
=m o ie
n
11r
For a full list of trolley stops visit. miamibeachtrolley.com
ni, M IAMIBEACH
!:!. TROLLEY
151UUa ...
l41UlJJl ... $ ~ ""l?SJ
11• .....
N ;
w E
5
i 9
I
~ ei
Ii : ,,.
1
Appendix A
.,. ..
1"1i..,..1<.l,,_-...,f'.-" ~· '""· ►
1"'\I SOUTH BEACH LOOP • A ~ ,-~~hv,..,.
...... C1-J
"r!JElol(RI' ~ e
IIRIIA({
h 1UlM£
Page 9 of 9
::
A TRANSPORTATION AMERICA COMPANY
June 21 , 2023
Joseph M. Centorino, Inspector General
The Offi ce of Inspector General
City of M iami Beach
11 30 Washington A venue
6th Floor
Sent Via Email
Josepl!Ccntor1no{a m1am 1beaeh1l.gL,,
Miami Beach, FL 33139
Re: LSF Response To Draft OIG Trolley llidersbip Inspection Report
Dear Mr. Centorino:
Limousines of South Florida, Inc. (LSF) thanks the Office of Inspector General (OIG) for the
opportunity that was provided to discuss the Draft Trolley Ridership Inspection Report (OIG Report)
during the June 16. 2023 Virtual Meeting, by and between the OIG, City staff, and LSF, and to hereby
submit Responses/Comments in connection thereto.
LSF is committed to ensuring that the public record provides a factual and accurate account of the
issues discussed in the OIG's Inspection Report, inclusive of perspectives from all relevant parties -the
OlG (as author of the Report), and the City staff and LSF as parties of the Miami Beach Trolley Program
Agreement. To this end, attached please find LSF's Response To Draft OIG Trolley Ridership Inspection
Report.
For purposes of clarity in the public record, LSF's response is provided within the text of the
Draft OIG Report that was provided. Specifically LSF provides comments in Blue Italics Font in
response to each paragraph of the OI Draft Report immediately after each paragraph in the
Memorandum, so tbat the OIG can determine which responses will be incorporated into the Final OIG
Report.
Consistent with Section 2-256. Sub-Section (h) of the Code of the City of Miami Beach, LSF
respectfully requests that this complete Response be nonetheless attached to the Final OIG Report so that
LSF' s comments that are not incorporated into the OIG Final Report can be available for anyone that
wishes to review LSF's Respons /C mments.
If you have any questions, or require any further information, please do not hesitate to advise.
Attachment
2766 NW 62nd Street
Miami, Florida 33147
Tel305.265.3302
Fax305.265.3303
1
LSF RESPONSE TO DRAFT OIG TROLLEY RIDERSHIP INSPECTION REPORT
(All LSF Responses/Comments are in Blue Italics Font)
For purposes of clarity ,n the public record. LSF provides comments m Blue Italics Font rn
response to each paragraph of the O/G Draft Report 1mmed1ately after each paragraph m the
Memorandum so that the O/G can determme which responses will be incorporated rnto the Final
OIG Report
Consistent with Section 2-256 Sub-Section (h) of the Code of the City of Miami Beach LSF
respectfully requests lhal this r,omplele Response be nonetheless attached to the Final OIG
Report so that LSF s comments that are nol ,ncorporated into the O!G Final Repo11 can be
avaJ/able for anyone that v1ishes to review LSF s Response/Comments
TO Honorable Mayor and Members of the City Commission
FROM: Joseph M. Centorino, Inspector General
DA TE: June 2, 2023 DRAFT
PROJECT: Trolley Ridership Inspection
OIG No. 23-XX
PERIOD: October 1st, 2021 -March 31st, 2023
EXECUTIVE SUMMARY
This inspection was planned and carried out by the City of Miami Beach Office of the Inspector
General (OIG) at the request of Miami Beach Commissioner Ricky Arriola, who expressed
concerns regarding the accuracy of the ridership figures for the City's free trolley service. Those
figures, presented to the Finance and Economic Resiliency Com mittee (FERC), had been based
on the Automatic Passenger Counters (APCs) installed in th e trolleys and relied upon by the City
Tra nsportation and Mobility Department in connection wi th the 201 9 Miami Beach Trolley
Passenger Survey data performed by Marlin Engineering, Inc.
LSF Comments (All LSF Comments are in Blue Italics Font)
LJmousmes of South Florida Inc (LSF) t/1an/(s the Office of Inspector General (OIG) for the
opportunity thal was provided to cilscuss the Draft Trolley Rrde,shrp Inspection Report (O/G
Repott) during the June 16. :C023 Virtual Meet,ng by and between the O/G City staff ancl LSF,
and lo hereby submit Responses/Comments m connection thereto LSF 1s committed to ensurmg
that t11e pubflc record prov,cles a factual and accurate occow1/ of the issues chscussed 111 the OIG s
Inspection Repon. 1nc1Us1Ve of perspectives from all relevant pa111es -the O/G (as author of the
Report) and the City staff and LSF as parties of tf1e M1am1 Beach Trolley Program Agreement
With respect to the substance of Paragraph J of the Executive Summary. LSF 1s aware of
Commrss1oner A110Jla concerns ahout the accwacy of rrclers/11p figures fat the City s ftee trolley
service fn observmg Com111issio11e1 A11iola s specific concerns as expressed from the
Commrss1on Oats. LSF notes his concerns that the published rrdersh1p figures may be inflated
In fact. based on lus pet sonal observations. Comm,ss,oner Arno/a has speculated that ndersh,p
figures were potent,ally inflated, and has therefore. quesltoned whether the City should contmue
mve sling rmlltons of doll a, s mto a Program with /owe, -than-, eported ridership ftgw es
1
2
In Chis regard LSF notes that the OlG s lnspec:t,011 dtd not conclude tfle Crty s trolley ndersh1JJ
1gU(es are mflated In (act it was quite the opposite Dunng the designated one-we1::k
observation penoci conducted 111 March 2023 the OIG found that ndershrp figures were
tmderreponed by almost sixteen percent (16%) In other words during the designated one-week
period the Trolley Program transported almost sixteen (16%) more passengers than reported by
the APC eqwpment
LSF respectfully submits that these details are highly probative, and should be disclosed
in the opening paragraph of the OIG 's Inspection Repon
The City trolley contractor, Limousines of South Florida, Inc. (LSF), is responsible for operating
the trolley system, and its subcontractor, TSO Mobile by Tracking Solutions Corp . (TSO Mobile).
,s the independent party that installs and maintains the APCs. In addition , the City Transportation
and Mobility Department 1s responsible for monitoring and determ ining com pliance with the
executed Agreement and its Amendments.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF notes that its sub-contract Agreement with TSO Mobile was entered mto at the direction of
the C,ry Please I efer co Amendment No 1 of the Miami Beach Trolley Program Agreement
entered on September 30, 2014, which states. 111 relevant paI1
ThP Contractor shall provide ,ts Optional Services by en/enng into a Sub-contract
wa/1 TSO Moh,le
Accordingly. LSF respectfully requests that the OIG c/anfy this paragraph 111 the Draft OIG Report
as follows
The Ctly trolley contractor Limousines of South Florida Inc. (LSF), ,s responsible
fo, operatmg the trolley system -and-I_ >>Its<< subcontracto, TSO Mobile by
Trackmg Sotur,ons Corp. (TSO Mobde). ,s che independent party >>contracted at
the direction of the City<< that installs and mamtarns the APCs. In addition. the
Cirv Transportallon ancl Mob1/1ty Department ,s responsible for momtormg and
determinmg compliance with the executed Agreement and ,ts Amendments
(D/pnsA nc,fp t/1 ;if ;, 11 ncc111ncy LSF.: suaqcsr,011. /hat rill' sr11rl<.e11 r/11nugh are rec:nmmemlerl lo /1p
ael1c:tetf from lf11-0/G 01011 RepOJt ..i11rl tlw e l/1Ar .-1Ie > double arrowed and bold<< arb suqgested
1y LSF I /JP ,,(/,/Pd rn•o /he 0/G F,nal Reporr J
OIG staff researched methodologies to test the reliability of those figures and performed an
independent inspection to assess the accuracy of the reported ridership data through visual
examination of the limited available footage provided from video cameras insta lled in the trolleys.
The ridership counts deri ved from the video footage inspection by OIG staff were then compared
with the reported number of passengers from the APCs and the manual co unts prepared by the
trolley drivers. The inspection concluded that the data generated by the APCs installed in City
trolleys and the manual counts prepared by the trolley drivers are unreliable indicators of the
actual ridership for the trolley system , based on the sampled trolleys examined during March
2023
2
3
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF notes ll1at the in tallatio11 of the APr s 1s performecJ by TSO
To ensure that there is no misunderstanding as to which entity installs the eqwpment. LSF s11nply
reques1s this paragraph 111 the Draft O/G Repo1t be mod1f1ed as follows.
OIG staff researched methoclofog1es to test the re/1ab1/1ty of those figures ancf
performed an mdependent mspect1on to assess the accuracy of the reported
ncfersh1p data through visual exammat1on of the /united available footage provided
from video cameras mstalled in the trollevs The ndersh1p counts derived from the
video rootage 111spect1on by OIG staff were then comparec/ with the reported
numtJer of passengers from the A PCs >>installed by TSO<< and the manual
counts prepared by the trolley cit 1vers The inspection concluded that the data
generated by the APCs mstalled ->by TSO<< ,n City trolleys and the manual
coums prepared by 1he trolley dnvers are unreliable indicators of the actual
t idership for the trolley system, based on the sampled trolleys exammed during
March 2023
fPIP<1 P. norP //1.Jt fo, w·(.11Ic1cv L F s . uupest1011~ ti/ill a,e ·r11u,,m Ih1r ugh r1re 1ecommenrlecJ to tie
Je/P/1:uf Im m the O/G O•dlt Rt!po,t 1ml tho:e Iha/ c1If' ->>double arrowed and bold<< are suqge'terl
1 }· LSr I 1,... a<fOect into II,e OIG F nm RP.µc,rr I
The OIG did not receive from the contractor, despite multiple requests, all requested video footage
or daily manual ridership counts prepared by trolley drivers. On some occasions substitute video
footage of other non-requested trolleys was received instea d of the requested footage. The
contractor's failure to provide all the requested video footage created a scope limitation which
raises concerns as to the underlying reasons why it wa s not furnished to the OIG and what other
deficiencies may exist. However, the Transportation and Mobility Department provided an Excel
spreadsheet, prepared by the contractor, containing March 2023 manual counts and APC counts
to the OIG.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF apolo91zes for any delay m the delivery of requested mformat,on/data As noted m the vanous
email exchanges LSF generally responded to commumcaf!ons by the O/G either on the same
date 01 w1thlf a reasonable penod Regrettably, the process of oblammg the video footage was
delayeci e1tf1e, because of opera1ionallse1v1ce-related respons1bi/Jt1es and/or due to
faultvloutdated equipment
As LSF noted ctunng the Virtual Meeting with the O/G and City staff. LSF provided the video
footage that was available and/or operable as soon as taff was able to retneve ,t l SF and TSO
have commumcated to the City that the video eqwpment 1s outdated and shoulcl be replaced As
a/so discussed, there 1s new and better passenget cotmte1 equipment and video technology
available and LSF ,s w1f/mg to test t/lese new sofvt1ons
Respectfully the char actenzat1on that the unava1lab1/ity of video footage raises conce111s as to
Ille w1lie1fy111g reasons wily ,twas nm furn1sl1ert to the O/G cind what other cleftc1enc1es may exist'
suggests the poss1bJ/1tv of some improper conduct This ,s simply not true nor s11pportable 111 the
O/G Report In fact as noted m Parag, aph 1 of this Draft OiG Report the basis for the Inspection
Report is to assess the accuracy of the nders/11p figured of t/1e City s free trolley service -
3
4
spectf1calfy whether r1cie1sh1p was mf/ated While the APCs and the manual counts have been
dete,rmned unreliable the Draft O/G f11spect1on Report did find that the numbers were
uncleneportecl Thus. there 1s no benefrt for LSF to r..le/ay the procluct1on of requested video
footage ancJ to suggest that c1nv delay raises co11ce1ns or that there 1s an "1mderly111g 1easo11
for such delay 1s simply not necessa,y and misplaced
As such LSF respectfully requests tllat the 0/G modify this paragraph m the Draft OIG Report as
follows
The OIG did not receive from the contractor, despite multiple requests all
requested video footage or daily manual ndership counts prepared by trolley
dnvers On some occasions. substitute video footage of other non-requested
/101/eys was, ece,ved msleacJ of the 1eqt1e. terJ footaqe The contractor's fa,twe to
provide all the requested video footage created a scope /1mitat1on whiGJ:i..-.r-a;ses
G01lGefr~./y,AfJ-reasono-w-l=µ; it was noc tu, mshed-J..e.-1.he GJ.G-..aA.d
what other del1c,e,1<,ies may exist However. the Transportation and Mob1//ty
Department provided an E. eel spreadsheet. prepared by the contractor
contammg Marc/1 2023 manual counts and APC counts to the O/G
1P/p.is ru '"' fhnl f, , -11 n11nI,"y LSF ~11,mest1011~ /ml 11e :,;/11ckert tf11,JL1g/1 .-11 e tA(;ommPnrted to hP
•e1e1Pct r ,m tne OIG Oral/ Rep ,r 1ml /ho ·e Iha/ a,e »double arrowed and bold< •are sug9es/ert
J L F tone m/llF•U ,mo rne OIG ~rnal Report J
INTRODUCTION
On May 8, 2014, the City of Miami Beach entered into an Agreement with LSF for turnkey
operation and ma intenance services of a Municipal Trolley Syste m in the City of Miami Beach.
According to City Resolution No. 2014-28708, the Agreement provided an option to procure
additional equipment, includ ing, without limitation . Global Positioning Systems with capabilities to
report, Au tomatic Passenger Co unters, Wi-Fi services. and Automated Voice Information
Systems. Pursuant to Article 3, Section 1 of the agreement, the City Administration recommended
that the City secure the optional equipment through LS F, for a sum not to exceed $150,000, during
the initi al five-year term of the Agreement, which the Mayor and City Commission approved and
authorized through Amendment No. 1.
LSF Comments (All LSF Comments are in Blue Italics Font)
As noted pre~ musty LSF s sub-contract Agreement with TSO Mobde was entered into ac the
di1ect1on ot the City Please refer to Amendment No 1 entered on September 30 '014 which
4
s
sraies. 111 relevant par1.
TIie Contracro, shall prov,cle its Optional Services by entenng mto a Sub-contract
w1fl1 TSO Moblfe "
Acco,dm1. /y LSFrespectfully requests thal the O/G clanfy this paragr ap/7 in the 01 aft OfG Report
a, follows
On May 8 2014. tlie City of M1am1 Beach entered mto an Agreement w,tn LSF for
turnkey operation and rnamtenance erv1ces of a M1m1c1pal Trolley System 111 the
Ci/ of M1am1 Beach Ace ordmg to City Resolution No 2014-28708 the Agreement
p1ov1derl an oplion lo procure additional eq111pment at the City s 1eq11est mc!11cli11g
without l1m1tat,on Global Po ,t,onmg Systems with capab1/Jt1es to report. Automatic
Passenger Counters W1-F1 services, and Automated Voice Informal/on Systems.
Pursuant to Article 3 Section 1 of the agreement the City Admm1strat1on
reGOmmem.i-efi direct eel LSF to th8t-+Re City secure the optional equipment through
LSF for a sum 101 to exceed S150 000 duflng the initial fire-year term of the
Agreemem wl11ch the Mayor a,1d City Comm1ss1on approved and authorized
through Amendment No 1
Pie J!il' note that Jo, accuruc~ LSF s s11qoes11011s that c11€ ,tucke, lhrour1n lfr Acommenderl to be
lelotud 110111 //11.: 0/G Draft Report ml //Jn c If at cJ/e ·>do11ble arrowed and bold<< Arn S(lgge<:led
tiy L sr /0 be d(J//~rl II Ir) rh > 0/G Fm.:11 Reµc1rt I
Amendment o. 1 to the Agreement, approved on September 30, 201 4, authorized th e execution
of a subcontract between LSF and TSO Mobile to provide a full turn key Tro lley Service , to include
equipping the trolleys with the following optional equipme nt: Autom atic Passenger Counters
(APC), Automated Voice Information System, Wi-Fi services, real-time GPS tracking services
(with capabilities to provide mileage, service hours and ridersh ip reports , and capabilities to
provide data in a format that is compatible with Miami-Dade County's mobile application, "Mi ami
Dade Bus Tracker") and additional automated stop announcement equipment , with the capability
of displaying public advertisements. The OIG recommends that in the future the City enter into a
contract directly with the subcontractor to help avoid the perception or the possibility that LSF may
exert undue influence on its subcontractor to enhance its rid ership figures and/or perfo rmance
image.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF does not 0L"i1ect to. nor part,cularly disagrees w1f/1 f/1e 0/G s suggestion that the City should
have direct contractual prw,ty with an APC prov1cler to prov1cle I icfers/11p figures fot the City s trolley
program Howeve, LSF does ob1ect to the inaccurate suggestion that LSF may be exerting
undul➔ 1nflue11cE: 011 Its suhc.ontractor to e11l1a11ce rts ude1sh11, figures ancflor pedormance clata •
In tilts regarcl as p1efaced earlier. LSF r!Oces that the City selected TSC Mobile as rts preferred
APC vendor based on r.mce. dnd per il1e p1eviously quoted Amendment No 1 to the M1am1 Beach
Trolley Progtam Agreement directed LSF to execute a subcontract with TSO LSF believes thrs
detail I c11t1cal to understandmg the orrgm of the APC :subcontract ancl tl1e nature of LSF's
relationsh1r1 vllh T
Moreove, LSF spec1f1cal/y asserts that there Is no basis -in perception or ,n fact -that LSF ,nay
exert undue mfluence on the sub-contractor to en/1ance ndersh1p numbers. Indeed, as
5
6
e plained during the Vu1ual Meeting with the O/G and C,ty staff LSF is compensated based on
erv1ce hours -NOT by ndersl11p. This fact 1s also ac/11ally acAnowledged m a subsequent
paragraph 111 the Draft OJG Inspection Report In fact during the Virtual Meetmg. City staff also
expressed tn1s point and fur/he, noted that the number of vehicles was/1s not based on rrdersh1p
f1gwes but rathe, on desned head-way times and to mm1m1ze bunching
It 1s therefore frankly. ironic that the O/G would suggest that LSF would seek to exen undue
1niluence and/or enhance ndersh1p figures when there 1s clearly no benefit -financial or otherwise
-for LSF to do so. In shon such language 1s unsupportable and unnecessanly ,nflammato1y
LSF therefore respectfully requests that the OIG modify this paragraph m the Draft O/G Report
as follows
Amendment No 1 to the Agreement. approved on September 30. 2014. authonzed
che execution of a subcontract between LSF and TSO Mobile to provide a full
turnkey Trolley erv1ce, to include eqwpp,ng the trolleys w!lh the fol/owmg optional
eqwpmenr Automatic Passenger Countets (APC). Automated Voice lnformat,on
System. W1-F1 services real-time GP trackmg services (with capalJilit1es to
provide mileage. servrce hours and ndership reports and capab1/!l1es to provide
data ma format that 1s r.ompal!ble with M1ami-D~de County s mobile application.
Mmm1 Dacie Bus T1arke1 ) ami acld1t10naf automated . toµ announcement
eqwpment. wllh the capab1/1ty of displaymg public advertisements. The O/G
recommends >--and LSF concurs --< that m the future the City enrer mto a
l,ont1 act directly with the subcontractor >>, ,n order to directly oversee and
manage the performance of the deployed technology.<< l.e-l?elp avoid the
f=HY-Gepl-1-0A-el-" the fJ<Jssibi/1/y tha1--~1-1a-y-e--x.en VFKit:1e-1Afl.i:leAOO-en ll.s
suhcont-r-acwr to enhanGe-it.s ndersh1f}-IUJ ires--andler r.erferm-anoe ima§e-
/Plt--iJSP n ,re ttir1r tor ric ,111 cv LSF" s11gae. lI011s tilat arP-{/rwi,e11 ti11nuqh a,e Iei;ommPn<led lo be
.I0Ir>1en 110,n the 0/G Drnft Reporr ana 1/mse 11m1 'lite >>double arrowed and bold<< arP suggostect
hy LSF-to/) • c11< ccl ,1110 fh1 OIG Ftr1t1I Rep("T}
Exhibit B of the TSO Mobile Contract states, "The accuracy of our Automatic Passenger Counting
Systems Is considered to exceed that of a single checKer on board a bus and compara ble to that
obtained by two checkers , one stationed at ea ch door. APC users in the transit systems that have
utilized our APC system consistently express satisfaction with the accuracy of our APC system.
In the following, the overall concurrence value represents the total number of boardings and
alightIngs1 counted by the APC system compa red to the tota l number of boardings and alightings
counted by experienced manual checkers. The Manual-APC Deviation Range +/-1 represents
the percentage of time the manual and APC observations were within one (1) of each other.
Implementation of our APC system will result in APC Passenger Count Accuracy levels exceeding
95% concurrence with manual observations."
LSF Comments (All LSF Comments are m Blue Italics Font)
LSF concurs with rh1s pa, agraph
In other words. tf the APC system report indicates 150 passengers ro de a given trolley during the
day, the manua l counts will range between 149 and 151. most of the time (95%). Furthermore,
Alighting means to get out a vehicle, especially a train or a bus, according to the Cambridge English Dictionary.
6
7
both the manual counts and the APC system report counts should be consistently within the same
+/-1 deviation range with the video footage counts performed by OIG staff.
LSF Comments (All LSF Comments are in Blue /ta/Jes Font)
LSF concurs with this paragraph
Miami Beach trolley service was suspended on March 26, 2020, fo llowing the outbre ak of th e
COVIO-19 pandemic, and eventually re sumed at a reduced service level on February 15, 2021 .
Therefore. pre-pandemic analysis from LSF involved all trolley operations prior to March 26, 2020,
and post-pandemic represented all trolley operations after February 14, 2021 .
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF concws with this paragraph
It is worth noting that the City does not directly base its payments to SF on ridership but rather
on scheduled service hours as stipulated in Amendment 11 to the Agreement. Scheduled service
hours are defined as the requested number of hours by the City for services available to the public
for transport along designated routes. The service hours exclude deadhead hours2, interruptions
,n service, and idle times exceeding 15 minutes. The free Miam i Beach trolley covers the following
routes: South Beach Loop A and B, Middle Beach Loop, Collins Express , and North Beach Loop
(see Appendix A located at the end of this report).
Among other benefits, accurate ridership figures are importa nt to help the City Administration to
determine the following:
• the number of trolleys that should be operating daily;
• identification of the busiest and least busy routes through which decisions could be made
to add or reduce the number of trolleys or the hours of operation;
• whether program costs may be offset by gra nt funding based on the achievement of
specific riders hip targets ; and
• assessment of the trolley program's overall effectiveness and its appropriate funding level.
The first two listed above could impact scheduled service hours, and, therefore, payments
due by the City to LSF.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF generally concw s w,th the first several sentences of this pa,agraph but again stresses that
routes a1e cletermrnecl by the City and have nothmg to do with ridership figures. As LSF noted
earlier and City staff conf1m1ed clu11ng the Virtual Meetmg with the OIG and LSF, the number of
trol/ev necessary to provide the service was also cletermmed by the City based on trolley route
alignment established headways/frequency of service. and to minrm1ze bunching Thus. the
numbe1 of trolleys and service hours are not dependent on the number of passengers using the
service and 11dersh1p f1gu,es have no impact on tl1P. Tto/ley Programs se1v1c hours a, the
amount of payments to LSF
Deadhead hours refe rs to the measurement of time (in hours) when a vehicle travels from its garage or yard facility to the first
scheduled prck-up point or any time the vehicle travels from the last scheduled drop-off point to its garage or yard facility.
7
8
The, etore LSF respectfully requests that the OIG make the fol/owmg modtficalrons to thrs
paragraph 111 the Draft OIG Report to ensure accuracy ,n the public record as follows
It 1s wonh noting that tne City does not L1uectly base its payments tn LSF on
nciersh1p but rathe1 on scheduled service hours as stipulated in Amendment 11 to
t/Je Agreement ScheCluled service hours -are defined as the requested numbe1 of
hows by the City for services avarlable to the public fo1 transport along designated
routes The service hours exclude deadhead hours 1nterrupt1ons m service and
idle tunes exceeding 15 mrnutes >>Routes are determined by the City. and the
number of trolleys necessary to provide the service was a/so determined by
the City based on established headways and to mmim,ze bunching. Thus,
the number of trolleys and service hours are not dependent on the number
of passengers using the service<< The free M1am1 Beach trolley covers lhe
fo!lowmg routes South Beach Loop A and B. Middle Beach Loop Collins Express
and North Beach Loop /see Appendix A located at rhe end of this report)
Among other benefits. accurate nclersh1p figures are important to help the City
Admm,strac,on to determme the following
._ the rH:Jmhe+-of trolle-ys tJ:l.al-MieHld ee---eµeratmg cJail.y.
• -ifiemff.H:;at-10,1 of #1e--01c1&esJ-anfl /easl misy 1m1tes throul§Jh-wf.-11sh--deG1s1ons-oowd
iJe made to adfi-0r reduce the nwnbef-el...tr-O!Je-yo--01:..t-he hours of-t}f)eFa~
• wnether prog1am costs may be offse1 by rant fund111g based on the achievement
of specific ndershrp targets: and
• assessmellt of the trollev prog,am' overall effectiveness and its appropriate
funding level
The fiFSt two Jisted-abav~uld impaGt-sGheauled servi<:;e-het:Jrs, and.
therefar-e,paymenls-due-oy-the-City-to-b.Si=.
!p1,.·1:;;, notP 1/1.11 frn ,r:,:11rn<:v L.SF s s11qpesr1om, tl1cir ,Im sr11,.1-.en //11n11t/h nre 1Pr.on,men<fecl In lie
<!&!,-red ir ,m rn 0/G DrcJft Re1;m1 net /ho. e /hct! aie >>double arrowed and bold<< i'lte suggesteci
1, F In I1e 11Jclerf min rhe ::JIG F111,1/ ReuCJt/)
WORK PERFORMED
TEST 1
During the July 22, 2022 FERC meeting, the City Transportation and Mobility Department
presented post-pandemic trolley service metrics. The following presentation extract indicated that
daily ridership had decreased by 56% from approximately 14,400 pre-pandemic daily rid ers to
6,300.
LSF Comments (All LSF Comments are ,n Blue Italics Font)
LSF concurs with t!Hs pa,ag,aph.
Deadhead hours refers to the measurement of time (in hours) when a vehicie travels trom its garage or yard facility to the first
scheduled pick-up point or any time the vehicle travels from the last scheduled drop-off point to its garage or yard facility.
8
9
Trolley Service
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF conwrs with //11s Chari
Some ridership declines can likely be attributed to the changes in trolley operating hours and
frequency. Prior to the pa ndemic, trolley service was available 18 hours a day, operating from 6
a.m to 12 a.m., with 25 vehicles servicing the public at an average interval of 15 minutes.
Following the pandemic. tro lley service was reduced to 15 hours a day, operating from 8 a.m . to
11 p.m ., with 15 vehicles servicing the public at an average interval of 30 minutes, wh ich is the
current service level.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF concurs w,th th1c; paragraph
TSO Mobile representatives informed OIG staff that its automatic counter system pro duces
ridership reports that can be accessed th rough its http://app.tsomo bile.com website. OIG staff
accessed the corresponding Pa ssenger Counter reports from October 1si, 2021 , th rough March
3P1, 2023, to compute the average da ily and monthly ri dership. The results indicated an average
of 5,205 daily riders from October P 1 2021, through September 301t, 2022. and 6,232 daily riders
from October P, 2022 through March 31'1, 2023.
LSF Comments (A ll LSF Comments are ,n Blue ltahcs Font)
LSF c/oes 1101 ciispute t/Je OIG s 1epresentat1011s 111 this paragraph
Upon comparing the lim ited internal TSO Mobile data provided to the OIG to the figures in the
post-pandemic analysis presented by the City Transportation and Mobility Departmen t to the
FERG covering a broader period , the OIG found those figures to be consistent. As the trolley
ridership data before July 1. 2021 . was not available, it was not exammed by the OIG , so its
accuracy could not be determined.
9
10
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF concurs w1rt1 this paragrap/1
TEST2
OIG staff initially sought to determine the accuracy of the 14,400 daily ridersh ip figures reported
in he 2019 Passenger Survey conducted by Marlin Engineering Inc. Howe er, TSO Mobile
representatives informed the OIG that the 2019 trolley reports and related video footage were
unavailable, and, therefore, the accuracy of th e related reported ridership could not be verified.
Given this limitation, OIG staff had to find an alternative method to assess the accuracy of reported
ridership data and to test the reliability of the passenger counting system.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF cloes nor U1spute r/JP OJG s 1ep,esentat1ons m this pa, □ graph.
LSF also adds that as discussed with the OIG and City staff then~ 1s new and better passenge1
counrer eqwpmem c1nd video technology available and LSF 1s w1/fmg to test these new solutions
In response to initial inquiries made by OIG staff, re pre sentatives from Transportation America
Inc. (TA), the parent company of LSF, stated that each trolley is outfitted with four interior
cameras. The related video footage is stored on a hard drive within the camera system.
Customers can only enter or exit the trolley through its one door, and the cameras record all its
activities.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF Joncurs with 1h1s paragraph
In emails to the OIG, TA representatives stated that the video recordings would be stored for
approximately thirty days, thereby limiting the OIG's analysis to 2023 data. However, after
requesting video footage rela ted to the operation of nine trolleys , each operati ng during a single
day within the prior thirty-day period , TA representatives indicated that video footage was only
available for up to two weeks.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF eneral/y concurs with this µaragrap/1, although to unclersco1 e a previous pomt because the
eqwpmenr 1s outdated LSF has found that the maximum storage capacity of the memory ca, d
was unreliable to fo1ecast. As such LSF p1ov1ded what wa~ ava!lable
LSF thererore respect{uf/1 ,equests that the O/G make the follow mg mod1f1cat1ons to the Draft
O/G Reporr co this paragraph as follows
In emaJ/s to the OJG TA representatives stated that the video reco,dmgs would be
sto,ecJ for aµpro 1marelv l/11rty clavs tfle,e/Jy llfnitmg tl1e OIG analysis to 2023
(iata Howeve, afte, ,equestmg video footage r'elateci to the operation of mne
troff~ys each operatmg during a smgle day w1lhtn tie pno, thirty-day penod, TA
representatives mdtcated that video footage was only available for up to two
10
11
weeks >>, as that is the maximum storage capacity of the outdated memory
card.<-<
(Pl,>r1s1 not 11,a/ / ll a ·cura( v LSF s11ggesI1011. r/Jat m st11<. '<e, lhrouqn irr-rer.ommendeo to lk
lo/(>{11rf from 111 0/~ Orn/I Rcf.]orr c1mi tho..:u lhc1/ 11 u ·>double arrowed and bold ..: are su,mesied
b1 LSr r(I ti, .lc/clf'CI 1111, U1e OIG F,niil Reornt 1
Consequently, OIG staff accessed the daily Passenger Counter reports from March 13 through
March 19, 2023. within the designated two-week period, and similarly requested video footage of
one day's activities for ten trolleys operating during the same week. The selected sample was
stratified to focus primarily on trolleys with higher reported ri dership and to avoid those out of
service during the designated week.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF rtoes not cJ,spute t11e OIG s repr sentat1uns of the methoclology employed m the analysis.
After encountering unexpected difficulties obtaining the requested video footage, TA
representatives provided OIG staff with USB flash drives containing most of the recordings. It is
important to note that one trolley's video footage was unavailable, and substitute video footage
was received for two other tro lleys, whic resulted in footage for three different days rel ated to a
single trolley, MB08, Le., the footage provided for three out of the nine trolley days examined
included the same trolley. The OIG utilized all of this footage but must note that, wh ile the repeated
use of footage for one trolley helped to confirm that troll ey's inaccu rate automatic counter, It wou ld
have been far preferable to have received footage for two other trolleys.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF cloes not dispute tt,e OIG s ,epresentallons of the methodology employed in the analysts
and agrees tllat ,t would have been far preferable to have received footage for two other trolleys
OIG staff examined approximately 135 hours of video footage pertaining to 4,326 riders,
representing 9.4% of the 46,238 riders for the designated week. The number of passengers
entenng each trolley during the reviewed day was counted and recorded. The table below
summanzes the identified variances between th e TSO Mobile Passenger Counter reports and the
OIG video footage counts:
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF c/oi:,s nor ci1spute the 0/G -rep," entauons ot the rnethodoloqy employed 11 , the analysis.
Trolley Date Route •
TSO
Mobile
Report
Video
Count Va ria nce Variance%
MB08 Th ursd ay, March 16, 2023 Sou t h Bea ch Loop B 297 661 364 122.6%
M B08 Monday, March 13, 2023 Collins Express 301 703 402 133.6%
MB08 Saturday, March 18, 2023 Co llins Express 373 637 264 70.8%
M B13 Wednesd ay, March 15, 2023 Coll ins Exp ress 55 7 654 97 17.4%
MBlS Thursd ay, March 16, 2023 North Beach 41 7 397 -20 -4 .8%
M B18 Sunday, M arch 19, 20 23 Collins Express 659 736 77 11.7%
I MB28 Thursday, March 16, 2023 South Bea ch Loop B 790 37 8 -412 -52.2%
11
12
MB30 Wednesday, March 15, 2023 South Beach Loop B 447 420 -27 -6.0%
MB31 Fri day, March 17, 2023 South Beach Loop A 373 297 -76 -20.4%
Trolleys may cover more than one route each day.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF does not cl1spute Ille DIG s 1eprese11tat1ons contamed ,n the Cl1ar1 prepared 111 connection
with the OIG Draft Inspection Report
The widespread positive and negative variances between the TSO Mobile reports and the OIG
performed video counts ra ise concerns about the accuracy of the ri der counting process. Each
variance exceeded the threshold deviation listed in Exhibit 8 of the TSO Mobile Contract, some
significantly.
LSF Comments (All LSF Comments are in Blue Italics Font)
LS~ gene,ally oncurs with this paragraph. but agam notes for the public record that there was
no evidence of over-reponmg of ndersh,p figures -which ,s the pnmar y slated reason for the
O/G s l11spect1011 Repor
LSF th I efore respectful/ requests that the OIG modify this paragraph in the Draft O/G Report
as follows
The widespread positive and negative variances he/ween the TSO Mobile reports
and the OIG performed video counts raise ~oncerns about the accurac,y of the nder
countmg process Each vanance exceeded the threshold dev,at,on fisted m Exh1b1t
§_ of tile rso Mon1re Contract some s1gnd1cantf_y '>However the review did
not support a finding that LSF was over-reporting the number of
passengers<
rPt, c1"P nrirc l/1c11 fo: ,-,, cwar.y L F s ugc,os1w11s (!,at ,H,. 111c1<c•p t/-Jrr,u<1t1 iJlt) 1ec.rJmrnenrlc I 1.-he
le/P./1-11I fr, ,r, tnP. 1.J/G [Jr,iff Report. •mrl thosf:: rhw <11 >>double arrowed and bold are suqgestecl
1\ SF rri bP if/t>d, 11 the O/G Ftniil Repr,,r J
Also concerning is that Trolleys MB28, MB30, and MB31 were equipped with overhead people
sensor APCs· , which Transportation and Mobility Department staff expected to produce more
accurate results. The use of the overhead people sensor APCs was presented to the OIG as a
newer and better technology tha n the one used on the other trolleys. As reported in the ta ble
above, the associated variances, ranging from -6 .0% to -52 .2%, failed to support this assertion.
Consequently, the OlG recommends that the installation of new overhead people sen sor APCs
for more trolleys be suspended until the reasons for these deficient counts can be determined
and corrected. If not possible other more effective cou nting methods should be re searched and
utilized prospectively.
LSF Comments (All LSF Comments are m Blue Italics Font)
LSF concurs wrlh this paragraph and aga,n adds that LSF has commumcated to the O/G and
City staff that there 1s new and !Jetter passenger counter eqwpment and video technology
available and LSF ,s w1lf111g to test these new sofu/1ons
https.//people sen~ing ~0111/s1tes/default/files/counrer datasheet apc-eco engl pdf 4
12
13
Although the objective of the performed analysis was to assess the reliability of the APCs, the
outcome of which suggests malfunctions leading to inaccurate reporting of ridership figures, the
OIG was also concerned with the inability of TA to provide all requested footage and the
occasional submittal of substitute unrequested footage. For exam ple, video footage for an
additional eight trolleys was requested from TA representatives on April 18, 2023, pertaining to
dates ranging from April 10, 2023 through April 16. 2023, well within the 14 days designated by
TA. On April 27. 2023, the OIG received an email from TA stating that three of the eight requested
videos were obtained, three were unavailable, and they were in the process of obtaining the
remaining two.
LSF Comments {All LSF Comments are in Blue Italics Font)
As noted 111 response to other para9raphs by the O/G d1scussmg the unavaJ/ab1l1ty of some video
ootage LSF again apolog,zes for any delay ,n the delivery of requested information/data As
stated in the various email exchanges, LSF generally responded to communicafions by the DIG
either on the ame date or wlfhm a reasonable periocl Regrettably the process of obtammg the
vrdeo footage was delayed either for ope1at1onal reasons or due to faulty eqwpment As LSF also
noce :J dunng the V11 tual Meeting with the OIG and City staff LSF provided the video footage thal
was available and101 operable as soon as taff was able to rerneve it LSF and TSO have
comm11nica1ed ro the Cit} t11at the v,cleo eqwpment rs dated and should /Je replaced As also
discussed the ,s 1ew and better passenger counttt eqwpment and video technology available
and LSF 1s w1/fmq to test these new solur,ons.
The OIG was also informed th at trolley drivers perform da ily manual ridership counts, which are
compared with TSO Mobile counts , and used when the APC counts are not available. As a result,
the OIG emailed TA representatives on April 27, 2023, requesting th e March and April 2023
manual ridership counts, but no response was received.
LSF Comments (All LSF Comments are m Blue Italics Font)
LSF rncorporates and re-states ,ts Comments ,n response to the pnor paragraph m the Dratt O/G
Report to t/11s paraqraph as well
In the interim, the OIG requested and received an Excel spreadsheet from the Transportation and
Mobility Department. which was previously provided to the City by the contractor, con ta ining the
APC counts and the manual ridership counts for trolleys operating in Miami Beach during March
2023. Consequently, the requested April 2023 video fo otage and the March through April 2023
daily manual ridership counts were no longer pursued from TA.
LSF Comments {All LSF Comments are in Blue Italics Font)
LSF mcorporates and re-states ,ts Comments m response lo (he prior paragraph in the Draft OIG
Report to tt11s paragraph as well
The OIG compared the reported APC counts to the manual counts to determ ine whether each
figure would be within +/-1 of the other 95 times out of 100 (95% confidence level), as claimed in
Exhibit B of the TSO Mobile contract. The OIG Auditors' examination of the provided March 2023
Excel spreadsheet found that the APCs for 202 of the 723 line items were blank (27.9%),
containing no count whatsoever. This analysis suggests that APCs installed on any trolleys are
not functioning and need repair.
13
14
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF ct es 1101 ci,sµute tl1e O/G s ,ep,esenta/1011s relative ro the rnetl?odology u/1/rze<I m the
analysis LSF .:ind TSO Inv" commumcated to rhe City that the video eqwpment 1s datecl. ancl
should Lie replaced As also cliscussed. there is new and better passenger counter eqwpment
and video tec/Jnology ava1iable . and LSF 1s willing to test these new solutions
The trolleys equipped with the overhead people sensor APCs contained cameras which provide
a continuous view of the trolley drivers. The OIG fo und the reliance on manual counts
questionable, as none of the three sampled tro lleys equipped with overhead people sensor APCs,
showed the dnver recording ridership counts during the days examined. Although th is ,s not
conclusive evidence that manual coun ts were not recorded by the troll ey drivers, it does raise
questions as to the origin and accuracy of the manual count, especially given the high umber of
blanks m the APC cou nts.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF generally concw with this parag, aph. and aga111 adds that LSF has commumcated to the
OIG and City staffthat there is new and better passenger councer eqwpment and video technology
available and L SF 1s w1ll111g to test these new solutions
After eliminating the 202 blanks from analysis, the OIG compared the remaining 52 1 reported
APC counts with the corresponding manual counts. It was determined that only 5 of the 521 line
items compared in the Excel spreadsheet (0 .96%} were within th e +/-1 benchmark stated in
Exhibit B of the Agreement. The 0.96% correspondence between the APC and manual counts Is
far less than the stated 95% confidence level listed in the Agreement, fu rther supporting the OIG's
conclusion that reported ridership counts are unreliable.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF c!oes not cl1spute tt1e OIG s rep1esentatw11s relative to the meihodofogy utl/1zed 111 tile
analysis and adds that while the resu/1s of the mspect1ons were unreliable the ridership figures
were underreported LSF and TSO have commurncated to the City that the passenger counter
and video equipment 1s oucdated and should be replaced As also discussed. there is new and
better 11assenge1 counte1 eqwpment and video technology available. and LSF is willing to test
thes ne solutions
The OIG also compared its video counts from the sampl ed tro lleys, each for one day's operation
during the week of March 13 through March 19, 2023, with the man ual cou nts prepared by the
trolley drivers (see the table below). In doing so, it was determined that the manual counts were
similarly unreliable. It is worth noting th at four of the nine sampled trolley days resulted in the
manual counts being lower than th e OIG video co unts (trolley MB08 on March 16, MB18 on March
19, MB28 on March 16 , and MB30 on March 15 .
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF incorporates and re-states ,ts Comments m ,esponse to the pno, paragraph m the Draft OIG
Repo,1 to this paragraph as well
14
15
Trolley Date Route •
Drivers
Manual
Counts
OIG
Video
Cou nt
Variance Variance %
MB08 Thursday, M arch 16, 2023 South Beach Loop B 604 661 -57 -~4%
I MB08 M onday, March 13, 2023 ! Collins Express 75 8 703 55 7.3%
1MB08 Saturday, March 18, 2023 Colli ns Express 768 637 131 17.1%
I MB13 Wednesd ay, March 15, 2023 Col lins Express 985 654 331 33.6%
M BlS Thursday, March 16, 2023 North Beach 466 397 69 14.8%
M B18 Su nday, March 19, 2023 Collins Express 700 736 -36 -5.1%
I MB28 Thursday, March 16, 2023 South Beach Loop B 364 378 -14 -3.8%
I M B30 Wedn esday, March 15, 2023 Sou th Beach Loop B 318 420 102 -32.1%
MB31 Friday, March 17, 2023 South Beach Loop A 380 297 83 21.8%
LSF Comments (All LSF Comments are in Blue Italics Font)
L F doe not disf}ufe flu, O/G ~ rerresentat,011s of tile Chat1 prepared ,n connection with the
analysis
The analysis performed in this report indicates that the City incorrectl y relied on the ridership
figures submitted by TA in March 2023. The documentation provided showed widespread
differences between the manual and APC counts, contrary to Exhibit B of the Agreement, and
both differed from the corresponding OIG video coun ts performed on ni ne sampled trolley days.
The OIG is also concerned that the City may have based some decisions on these inaccurate
ridership figures, which may al so have been reported to oth er governmental agencies. Going
forward, the Transportation and Mobility Department should periodically conduct its own sample
ridership inspections with any deficiencies exceeding a designated percentage promptly
addressed with the contractor until being resolved.
LSF Comments (All LSF Comments are in Blue Italics Font)
LSF cannot opme on whethe1 the City incorrectly relied on 11dersh1p data submitted by LSF m
Maren of 2023 As noted previously the unrel1abil1ty of some data 1s generally IJased on outdated
enwpmenr and technology In this regarcl LSF has communicated to the O/G and City staff that
tt1ere is new and bette, passenger counter equ1pmen1 and video technology available and LSF
1s w,llmg to test these new solut,ons.
LSF w1her obse1 ve Thar the Agreement between the City does not prescnbe any method for the
collect1on ot r 1anual nde1sh1p counts LSF further subm1ls lhat manual co(lnts provided by LSF
dnver s cJur,ng the designated obse, vat1on period were approximately 9 4% which is consistent
with 111dustry standa, ds and entirely reasonable given lhe other important duties assigned to
trolley drivers In trus regard LSF ,e,teraces its conce, n with the suggestion that the Clly
vomm1s ,on ma hcive haserl ome decisions n macr-urate rrclersl11p figures "
Whtie not cleai/y rated tl1e O/G suggests that the C,ty Comm1ss1on may have allocated rm/lions
of ta dollars co funcl <1 program with tnflatecl ridership r,gwes This ,s 1ust not accurate as the OIG
lnspecr,on revealed that uder sf11p figures clunng the cfes1gnated obse,vat1on penod were
unae, reported not tnflatecl In addition as noted above. ndership figures have not featured
prommently 111 the C,tv clec,s,ons 1eqard1ng trolley service hows and payments to LSF.
4, to t/7P, 0/G, 1.on"'"'11s orll1e City tv:1s111g some Jec1c::1ons on lfWccurate nrlersl11p figures agam
C!I , staff conf,rmect du1111g the Virrual Meelmg with tl1e OIG ancl LSF that the number of vehicles
15
16
used lot routes and tne number of service hours requested 1s not based whatsoever on r, le1sh1p
figures Rather C,ty staff has srated that the number of trolleys determmed for service by the City
1s based on establrshecl heaaways and ro m1mmize bunchrng Thus the nurnber of trolleys ana
service hours are not dependent on the number of passengers using the service
LSF thererore r"'spectful/y reqCJests that the OIG make the following mod1f1cat1ons to this
para<.,raph m the OIG Draft Repo1t as follows
The analysis-performed in this report md1Gates Jhat t/:1~ Glly 1ncerr-eGtly--Felie<J-on
lhe n,:iBfsh-~ik,1fTes wm-Ril-te!l-by--:fAm Mar~R 2-00-3-. The documentation provided
showed w1clespread d1fferences between the manual and APC counts contrary to
E. h1b1t B of the Agreement. and both differed from the correspondmg O/G video
;;aunts pe110rmed on n,ne sampled trolley days T-he OIG is a/sG-GGRGemea-that
the -G+iy-Ri-a.,· ha~,e based -!:iOllW ctec1sm11s on these inaccurate ndershtp figures.
w111Gh may also -hav heen 1'-&f30'1fW le otl~ EWeHRmfmlal e-AGleS:-Gomg
forward the Transportation ,ind Mobility Department hou/d period1cally conduct
,t own sample ndersl11p mspect,ons with any deflc1enc1es exceeding a designated
percentage promptly add,essed with the contractor until resolved
IPlr ;i nut 111•,11, , u c,ir,11 ~ L F "suyuc<111 ,n 1/1,11 ,11 .. /f1Ck£'" //11nu1111 me ,ec ,mmoncle<I lone
,1011.d t, ,m till' OIG .'}al/ KL'on,I .1111, 'nose tha! ,110 • double arrowed and bold < are suaqcs/ed
Lw L F 1 111. a(l<t,1 1 1110 //, , 1G F,nal Re1)t111 1
Joseph M. Centorino, Inspector General Date
Mark D. Coolidge, Chief Auditor Date
cc: Alina T Hudak, City Manager
Rickelle Williams, Assistant City Manager
Jose R. Gonzalez, Transportation Department Director
Appendix A
LEGEND -
16
Alonso, Elisa
From: Wendy Diaz <wdiaz@tsomobile.com>
Sent: Tuesday, July 11, 2023 2:50 PM
To: Centorino, Joseph
Cc: Dan Ocampo; Mark Gilmore; Rick Dunn (GPST)
Subject: Re: TSO Mobile Comment
[ THIS MESSAGE COMES FROM AN EXTERNAL EMAIL ‐USE CAUTION WHEN REPLYING AND OPENING LINKS OR
ATTACHMENTS ]
Joseph,
I wanted to give you some comments on the current Audit for the City of Miami Beach. I wanted to make sure that it
was understood that our hardware's performance is at times affected by issues the Trolley's may have. As an example
our APC system requires an event of Door Open and Close so that we know they were passengers picked up. If the
system does not receive the door open and close it will ignore the count that was just done. There are quite a few of the
Trolleys that currently have the door mechanisms not working properly, thus the APC is not working properly. TSO is
responsible to provide the service to visualize the results of the data obtained by the equipment, process any hardware
failure/replacement when hardware is still under warranty
(12 months) or offer an upgrade to the latest technology, in order to resolve issues and/or improve results. Any issues
caused by tampering are not covered under warranty and it is the responsibility of LSF to maintain that portion
(mechanic and working of the Trolleys). We have on many occasions helped LSF with these issues, because we value the
City and we are all working together. TSO provides the hardware and installation of the same.
I do know that the City has trolleys still running the older technology for the Passenger Counters. The city has purchased
some replacements that will be the newest technology and should be installed soon. We will install them in Trolley
MB05 and MB07. Once they are installed you can re audit these for accuracy and notice the difference.
Thank you for your time.
Best Regards,
Wendy Diaz
TSO Mobile | a GPS Trackit company
Sr. Technical Support Manager
wdiaz@tsomobile.com | 1‐877‐477‐2922 Ext. 1109
1
Transportation Department Response In Red Line To Draft Report
Honorable Mayor and Members of the City Commission
Joseph M. Centorino, Inspector General
June 2, 2023 DRAFT
Trolley Ridership Inspection
OIG No. 23-XX
October 1st, 2021 -March 31st, 2023
EXECUTIVE SUMMARY
This inspection was planned and carried out by the City of Miami Beach Office of the Inspector
General (OIG) at the request of Miami Beach Commissioner Ricky Arriola, who expressed
concerns regarding the accuracy of the ridership figures for the City’s free trolley service. Those
figures, presented to the Finance and Economic Resiliency Committee (FERC), had been based
on an analysis of both manual (i.e. driver) counts and the Automatic Passenger Counters (APCs)
installed in the trolleys and relied upon by the City Transportation and Mobility Department in
connection with the 2019 Miami Beach Trolley Passenger Survey data performed by Marlin
Engineering, Inc.
The City trolley contractor, Limousines of South Florida, Inc. (LSF), is responsible for operating
the trolley system, and its subcontractor, TSO Mobile by Tracking Solutions Corp. (TSO Mobile),
is the independent party that installs and maintains the APCs. In addition, the City Transportation
and Mobility Department is responsible for monitoring and determining compliance with the
executed Agreement and its Amendments with LSF.
OIG staff researched methodologies to test the reliability of those figures and performed an
Commented [WR1]: To OIG: Should reference date when
figures were presented to the FERC
Commented [WR2]: Which figures?
independent inspection to assess the accuracy of the reported ridership data through visual
examination of the limited available footage provided from video cameras installed in the trolleys.
The ridership counts derived from the video footage inspection by OIG staff were then compared
with the reported number of passengers from the APCs and the manual counts prepared by the
trolley drivers. The inspection concluded that the data generated by the APCs installed in City
trolleys and the manual counts prepared by the trolley drivers are unreliable indicators of the
actual ridership for the trolley system, based on the sampled trolleys examined during March
2023. Based on the OIG’s inspection of the limited video footage available, the APCs appear to
be under-reporting actual ridership figures while the driver counts appear to be over-reporting
actual ridership figures.
Page 1 of 8
Draft Report
Trolley Ridership Inspection
June 2, 2023
The OIG did not receive from the contractor, despite multiple requests, all requested video footage
or daily manual ridership counts prepared by trolley drivers. On some occasions, substitute video
footage of other non-requested trolleys was received instead of the requested footage. The
contractor’s failure to provide all the requested video footage created a scope limitation which
raises concerns as to the underlying reasons why it was not furnished to the OIG and what other
deficiencies may exist. However, the Transportation and Mobility Department provided an Excel
spreadsheet, prepared by the contractorTSO Mobile, containing March 2023 manual counts and
APC counts to the OIG.
INTRODUCTION
On May 8, 2014, the City of Miami Beach entered into an Agreement with LSF for turnkey
operation and maintenance services of a Municipal Trolley System in the City of Miami Beach.
According to City Resolution No. 2014-28708, the Agreement provided an option to procure
additional equipment, including, without limitation, Global Positioning Systems with capabilities to
report, Automatic Passenger Counters, Wi-Fi services, and Automated Voice Information
Systems. Pursuant to Article 3, Section 1 of the agreement, the City Administration recommended
that the City secure the optional equipment through LSF, for a sum not to exceed $150,000, during
the initial five-year term of the Agreement, which the Mayor and City Commission approved and
authorized through Amendment No. 1.
Amendment No. 1 to the Agreement, approved on September 30, 2014, authorized the execution
of a subcontract between LSF and TSO Mobile to provide a full turnkey Trolley Service, to include
equipping the trolleys with the following optional equipment: Automatic Passenger Counters
(APC), Automated Voice Information System, Wi-Fi services, real-time GPS tracking services
(with capabilities to provide mileage, service hours and ridership reports, and capabilities to
provide data in a format that is compatible with Miami-Dade County’s mobile application, “Miami
Dade Bus Tracker”) and additional automated stop announcement equipment, with the capability
of displaying public advertisements. The OIG recommends that in the future the City enter into a
contract directly with the subcontractor to enable direct access to the technology provider. to help
avoid the perception or the possibility that LSF may exert undue influence on its subcontractor to
enhance its ridership figures and/or performance image.
Exhibit B of the TSO Mobile Contract states, “The accuracy of our Automatic Passenger Counting
Systems is considered to exceed that of a single checker on board a bus and comparable to that
obtained by two checkers, one stationed at each door. APC users in the transit systems that have
utilized our APC system consistently express satisfaction with the accuracy of our APC system.
In the following, the overall concurrence value represents the total number of boardings and
Page 2 of 8
Draft Report
Trolley Ridership Inspection
June 2, 2023
alightings1 counted by the APC system compared to the total number of boardings and alightings
counted by experienced manual checkers. The Manual-APC Deviation Range +/-1 represents
the percentage of time the manual and APC observations were within one (1) of each other.
Implementation of our APC system will result in APC Passenger Count Accuracy levels exceeding
95% concurrence with manual observations.”
In other words, if the APC system report indicates 150 passengers rode a given trolley during the
day, the manual counts will range between 149 and 151, most of the time (95%). Furthermore,
both the manual counts and the APC system report counts should be consistently within the same
+/-1 deviation range with the video footage counts performed by OIG staff.
Miami Beach trolley service was suspended on March 26, 2020, following the outbreak of the
COVID-19 pandemic, and eventually resumed at a reduced service level on February 15, 2021.
Therefore, pre-pandemic analysis from LSF involved all trolley operations prior to March 26, 2020,
and post-pandemic represented all trolley operations after February 14, 2021.
It is worth noting that the City does not directly base its payments to LSF on ridership but rather
on scheduled service hours and established hourly operating rates as stipulated in Amendment
11 to the Agreement. Scheduled service hours are defined as the requested number of hours by
the City for services available to the public for transport along designated routes. Furthermore,
fFleet size for the trolley system is based on desired frequency of service and service
areacoverage, and not on ridership. The service hours exclude deadhead hours2, interruptions in
service, and idle times exceeding 15 minutes. The free Miami Beach trolley covers the following
routes: South Beach Loop A and B, Middle Beach Loop, Collins Express, and North Beach Loop
(see Appendix A located at the end of this report).
Among other benefits, Aaccurate ridership figures are important to help the City Administration to
determine the following:
• the number of trolleys that should be operating daily;
• identification of the busiest and least busy routes through which decisions could be made
to add or reduce the number of trolleys or the hours of operation; ; • whether program costs may be offset by grant funding based on the achievement of
specific ridership targets; and
• assessment of the trolley program's overall effectiveness. and its appropriate funding
level.
The first two listed above could impact scheduled service hours, and, therefore, payments
due by the City to LSF.
Ridership figures are not used to determine the number of trolleys that should be
operating, hours of operation, grant eligibility, or the appropriate funding level for the
program.
WORK PERFORMED
1 Alighting means to get out a vehicle, especially a train or a bus, according to the Cambridge English Dictionary.
2 Deadhead hours refers to the measurement of time (in hours) when a vehicle travels from its garage or yard facility to the first
scheduled pick-up point or any time the vehicle travels from the last scheduled drop-off point to its garage or yard facility.
Page 3 of 8
Draft Report
Trolley Ridership Inspection
June 2, 2023
TEST 1
During the July 22, 2022 FERC meeting, the City Transportation and Mobility Department
presented post-pandemic trolley service metrics. The following presentation extract indicated that
daily ridership had decreased by 56% from approximately 14,400 pre-pandemic daily riders to
6,300.
Some ridership declines can likely be attributed to the changes in trolley operating hours and
frequency. Prior to the pandemic, trolley service was available 18 hours a day, operating from 6
a.m. to 12 a.m., with 25 vehicles servicing the public at an average interval of 15 minutes.
Following the pandemic, trolley service was reduced to 15 hours a day, operating from 8 a.m. to
11 p.m., with 2115 vehicles servicing the public at an average interval of 230 minutes, which is
the current service level.
TSO Mobile representatives informed OIG staff that its automatic counter system produces
ridership reports that can be accessed through its http://app.tsomobile.com website. OIG staff
accessed the corresponding Passenger Counter reports from October 1st, 2021, through March
31st, 2023, to compute the average daily and monthly ridership. The results indicated an average
of 5,205 daily riders from October 1st, 2021, through September 30th, 2022, and 6,232 daily riders
from October 1st, 2022 through March 31st, 2023.
Upon comparing the limited internal TSO Mobile data provided to the OIG to the figures in the
post-pandemic analysis presented by the City Transportation and Mobility Department to the
FERC covering a broader period, the OIG found those figures to be consistent. As the trolley
ridership data before July 1, 2021, was not available, it was not examined by the OIG, so its
accuracy could not be determined.
TEST 2
OIG staff initially sought to determine the accuracy of the 14,400 daily ridership figures reported
in the 2019 Passenger Survey conducted by Marlin Engineering Inc. However, TSO Mobile
representatives informed the OIG that the 2019 trolley reports and related video footage were
unavailable, and, therefore, the accuracy of the related reported ridership could not be verified.
Page 4 of 8
Draft Report
Trolley Ridership Inspection
June 2, 2023
Given this limitation, OIG staff had to find an alternative method to assess the accuracy of reported
ridership data and to test the reliability of the passenger counting system.
In response to initial inquiries made by OIG staff, representatives from Transportation America
Inc. (TA), the parent company of LSF, stated that each trolley is outfitted with four interior
cameras. The related video footage is stored on a hard drive within the camera system.
Customers can only enter or exit the trolley through its one door, and the cameras record all its
activities.
In emails to the OIG, TA representatives stated that the video recordings would be stored for
approximately thirty days, thereby limiting the OIG’s analysis to 2023 data. However, after
requesting video footage related to the operation of nine trolleys, each operating during a single
day within the prior thirty-day period, TA representatives indicated that video footage was only
available for up to two weeks.
Consequently, OIG staff accessed the daily Passenger Counter reports from March 13 through
March 19, 2023, within the designated two-week period, and similarly requested video footage of
one day’s activities for ten trolleys operating during the same week. The selected sample was
stratified to focus primarily on trolleys with higher reported ridership and to avoid those out of
service during the designated week.
After encountering unexpected difficulties obtaining the requested video footage, TA
representatives provided OIG staff with USB flash drives containing most of the recordings. It is
important to note that one trolley’s video footage was unavailable, and substitute video footage
was received for two other trolleys, which resulted in footage for three different days related to a
single trolley, MB08, i.e., the footage provided for three out of the nine trolley days examined
included the same trolley. The OIG utilized all of this footage but must note that, while the repeated
use of footage for one trolley helped to confirm that trolley’s inaccurate automatic counter, it would
have been far preferable to have received footage for two other trolleys.
OIG staff examined approximately 135 hours of video footage pertaining to 4,326 riders,
representing 9.4% of the 46,238 riders for the designated week. The number of passengers
entering each trolley during the reviewed day was counted and recorded. The table below
summarizes the identified variances between the TSO Mobile Passenger Counter reports and the
OIG video footage counts:
Trolley Date Route *
TSO
Mobile
Report
Video
Count Variance Variance %
MB08 Thursday, March 16, 2023 South Beach Loop B 297 661 364 122.6%
MB08 Monday, March 13, 2023 Collins Express 301 703 402 133.6%
MB08 Saturday, March 18, 2023 Collins Express 373 637 264 70.8%
MB13 Wednesday, March 15, 2023 Collins Express 557 654 97 17.4%
MB15 Thursday, March 16, 2023 North Beach 417 397 -20 -4.8%
MB18 Sunday, March 19, 2023 Collins Express 659 736 77 11.7%
MB28 Thursday, March 16, 2023 South Beach Loop B 790 378 -412 -52.2%
MB30 Wednesday, March 15, 2023 South Beach Loop B 447 420 -27 -6.0%
MB31 Friday, March 17, 2023 South Beach Loop A
Total:
373
4,214
297
4,883
-76
-669
-20.4%
-15.8%
Formatted Table
Page 5 of 8
Draft Report
Trolley Ridership Inspection
June 2, 2023
* Trolleys may cover more than one route each day.
The widespread positive and negative variances between the TSO Mobile reports and the OIG
performed video counts raise concerns about the accuracy of the rider counting process. Each
variance exceeded the threshold deviation listed in Exhibit B of the TSO Mobile Contract, some
significantly. However, it is important to note that the OIG’s limited review did not support a finding
that APCs wereas over-reporting the number of passengers as the APCs appear to be under-
reporting the number of passengers based on the video footage available.
In addition,Also concerning is that Trolleys MB28, MB30, and MB31 were equipped with overhead
people sensor APCs3., which Transportation and Mobility Department staff expected to produce
more accurate results. The use of the overhead people sensor APCs which was presented to the
OIG as a newer and better technology than the one used on the other trolleys. As reported in the
table above, the associated variances, ranging from -6.0% to -52.2%, failed to support that the
newer technology is more accurate than the older technologythis assertion. Consequently, the
OIG recommends that the installation of new overhead people sensor APCs for more trolleys be
suspended until the reasons for these deficient counts can be determined and corrected. If not
possible, other more effective counting methods should be researched and utilized prospectively.
Although the objective of the performed analysis was to assess the reliability of the APCs, the
outcome of which suggests malfunctions leading to inaccurate reporting of ridership figures, the
OIG was also concerned with the inability of TA to provide all requested footage and the
occasional submittal of substitute unrequested footage. For example, video footage for an
additional eight trolleys was requested from TA representatives on April 18, 2023, pertaining to
dates ranging from April 10, 2023 through April 16, 2023, well within the 14 days designated by
TA. On April 27, 2023, the OIG received an email from TA stating that three of the eight requested
videos were obtained, three were unavailable, and they were in the process of obtaining the
remaining two.
The OIG was also informed that trolley drivers perform daily manual ridership counts, which are
compared with TSO Mobile counts, and used when the APC counts are not available. As a result,
the OIG emailed TA representatives on April 27, 2023, requesting the March and April 2023
manual ridership counts, but no response was received.
In the interim, the OIG requested and received an Excel spreadsheet from the Transportation and
Mobility Department, which was previously provided to the City by the contractor, containing the
APC counts and the manual ridership counts for trolleys operating in Miami Beach during March
2023. Consequently, the requested April 2023 video footage and the March through April 2023
daily manual ridership counts were no longer pursued from TA.
The OIG compared the reported APC counts to the manual counts to determine whether each
figure would be within +/-1 of the other 95 times out of 100 (95% confidence level), as claimed in
Exhibit B of the TSO Mobile contract. The OIG Auditors’ examination of the provided March 2023
Excel spreadsheet found that the APCs for 202 of the 723 line items were blank (27.9%),
containing no count whatsoever. This analysis suggests that APCs installed on many trolleys are
not functioning and need repair. When TSO identifies that APC devices are not functioning
correctly and in need of repair, TSO uses drivers’ manual counts for those days until the devices
are recalibrated and repaired.
https://people-sensing.com/sites/default/files/counter_datasheet_apc-eco_engl.pdf
Page 6 of 8
3
Draft Report
Trolley Ridership Inspection
June 2, 2023
The trolleys equipped with the overhead people sensor APCs contained cameras which provide
a continuous view of the trolley drivers. The OIG found the reliance on manual counts
questionable., as none of the three sampled trolleys equipped with overhead people sensor
APCs, showed the driver recording ridership counts during the days examined. Note that the
Agreement does not prescribe the manner by which driver manual counts must be completed.
Although this is not conclusive evidence that manual counts were not recorded by the trolley
drivers, it does raise questions as to the origin and accuracy of the manual count., especially
given the high number of blanks in the APC counts.
Commented [GJR3]: Not relevant. Accuracy of drivers’
counts are irrespective of APC counts.
After eliminating the 202 blanks from analysis, the OIG compared the remaining 521 reported
APC counts with the corresponding manual counts. It was determined that only 5 of the 521 line
items compared in the Excel spreadsheet (0.96%) were within the +/-1 benchmark. stated in
Exhibit B of the Agreement. The 0.96% correspondence between the APC and manual counts is
far less than the stated 95% confidence level listed in the Agreement, further supporting the OIG’s
conclusion that reported ridership counts are unreliable.
The OIG also compared its video counts from the sampled trolleys, each for one day’s operation
during the week of March 13 through March 19, 2023, with the manual counts prepared by the
trolley drivers (see the table below). In doing so, it was determined that the manual counts were
similarly unreliable. It is worth noting that four of the nine sampled trolley days resulted in the
manual counts being lower than the OIG video counts (trolley MB08 on March 16, MB18 on March
19, MB28 on March 16, and MB30 on March 15).
Commented [GJR4]: Not sure as to the relevance of this
paragraph or what it is trying to convey as Exhibit B does
not call for APC counts to be compared to driver counts.
Trolley Date Route *
Drivers
Manual
Counts
OIG
Video
Count
Variance Variance %
MB08 Thursday, March 16, 2023 South Beach Loop B 604 661 -57 -9.4%
MB08 Monday, March 13, 2023 Collins Express 758 703 55 7.3%
MB08 Saturday, March 18, 2023 Collins Express 768 637 131 17.1%
MB13 Wednesday, March 15, 2023 Collins Express 985 654 331 33.6%
MB15 Thursday, March 16, 2023 North Beach 466 397 69 14.8%
MB18 Sunday, March 19, 2023 Collins Express 700 736 -36 -5.1%
MB28 Thursday, March 16, 2023 South Beach Loop B 364 378 -14 -3.8%
MB30 Wednesday, March 15, 2023 South Beach Loop B 318 420 -102 -32.1%
MB31 Friday, March 17, 2023 South Beach Loop A 380 297 83 21.8%
Total: 5,343 4,883 460 8.61%
Formatted Table
Commented [GJR5]: However, TSO’s monthly exercise of
blending both data sources ultimately yields more accurate
ridership figures as shown by the results of the two
independent OIG tests.
The analysis performed in this report indicates that the City incorrectly relied on the ridership
figures submitted by TA in March 2023. The documentation provided showed widespread
differences between the manual and APC counts, contrary to Exhibit B of the Agreement, and
both differed from the corresponding OIG video counts performed on nine sampled trolley days.
The OIG is also concerned that the City may have based some decisions on these inaccurate
ridership figures, which may also have been reported to other governmental agencies. Going
Commented [GJR6]: As noted previously, the trolley
service level since inception has been based on initial policy
decisions regarding desired frequency of service, service
area (i.e. routes), and hours of operation, not on ridership.
Ridership has not been a criteria in current or prior service
levels nor a factor in terms of payments to LSF. Payments
are based solely on number of service hours and
contractually established hourly operating rates minus any
performance penalties including service interruptions and
on-time performance penalties.
forward, the Transportation and Mobility Department should periodically conduct its own sample
ridership inspections with any deficiencies exceeding a designated percentage promptly
addressed with the contractor until being resolved.
Page 7 of 8
Page 8 of 8
___________________________ ___ ________
___________________________________ ________
Draft Report
Trolley Ridership Inspection
June 2, 2023
Joseph M. Centorino, Inspector General Date
Mark D. Coolidge, Chief Auditor Date
cc: Alina T. Hudak, City Manager
Rickelle Williams, Assistant City Manager
Jose R. Gonzalez, Transportation Department Director
Appendix A