2003-3418 OrdinanceORDINANCE NO. 2003-3418
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF
THE CITY OF MIAMI BEACH, FLORIDA, AMENDING MIAMI
BEACH CITY CODE CHAPTER 18, ENTITLED "BUSINESSES,"
BY AMENDING ARTICLE VIII, ENTITLED "PARKING LOT," BY
AMENDING DIVISION 2, ENTITLED, "VALET PARKING
PERMITS FOR USE ON PUBLIC PROPERTY"; BY AMENDING
SECTION 18-336 THEREOF BY_/~R~IDING
FOR
REQUIRED
"VOTE" (VALET OPERATOR TRAINING ENFORCEMENT)
TRAINING PROGRAM; BY AMENDING DIVISION 3, ENTITLED,
"RENTALS"; BY AMENDING SECTION 18-341 THEREOF BY
PROVIDING ADDITIONAL CODE OF CONDUCT
REQUIREMENTS FOR VALET OPERATORS AND THEIR
EMPLOYEES; BY AMENDING SECTION 18-342 BY PROVIDING
EXPANDED RAMPING AREAS UNDER CERTAIN
CIRCUMSTANCES; BY AMENDING SECTION 18-343 BY
PROVIDING THAT VALET PERMITS FOR SPECIAL EVENTS
SHALL BE APPLIED FOR FROM THE CITY'S TOURISM AND
CULTURAL DEVELOPMENT DIRECTOR; BY AMENDING
SECTION 18-344 BY AMENDING THE FINES AND
ENFORCEMENT PROCEDURES FOR VIOLATORS; AND
PROVIDING FOR REPEALER, SEVERABILITY, CODIFICATION,
AND AN EFFECTIVE DATE.
WHEREAS, amendments to Miami Beach City Code Chapter 20, regulating in
part the operation of valet parking services in the City of Miami Beach, were adopted on
April 29, 1995, pursuant to Ordinance No. 95-2987; and
WHEREAS, further amendments were adopted on May 12, 1999, pursuant to
Ordinance No. 99-3182, providing for requirements for the use of a moving lane of
traffic; establishing residential valet parking requirements; and providing an on-call valet
program; and
WHEREAS, the Administration has identified the need to further amend the
Ordinance, by establishing required training for valet parking employees; expanded
ramping opportunities under certain circumstances, as defined herein; and a revised
enforcement fine schedule and amending enforcement procedures for violators; and
WHEREAS, the Parking Department held a workshop on March 20, 2003, with
valet parking operators in the City of Miami Beach in effort to develop constructive
amendments to the Ordinance.
NOW, THEREFORE, BE IT ORDAINED BY THE MAYOR AND CITY
COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA:
Section 1. That Division 2, Article VIII of Chapter 18 of the Miami Beach City Code is
hereby amended as follows:
ARTICLE VIII. PARKING LOT
DIVISION 2. VALET PARKING PERMITS FOR USE OF PUBLIC PROPERTY
Sec. 18-336. Separate Permit Required
The City of Miami Beach shall issue valet parking permits to valet operators who
conduct their operations on public property. No valet parking shall occur on
public property without the operator securing a valet parking permit from the
City's Parking Department. A separate permit is required for each location where
valet parking services are provided. Valet parking permits shall only be issued to
operators who are licensed by the City of Miami Beach pursuant to this Chapter.
Sec. 18-337. Requirements
No valet parking permit shall be issued without the proof of the following:
Approval from the City's Risk Manager indicating that the
valet parking operation has met the following insurance
requirements:
a. Commercial general liability or garage liability
insurance in the amount of $1,000,000 per
occurrence and per location covering bodily injury and
property damage resulting from the valet operator's
activities connected with the handling of vehicles on
public property. This policy must name the City as an
additional insured.
b. Garage keepers legal liability insurance to provide
collision and comprehensive coverage for vehicles
under control of the valet parking operation with
minimum limits of $300,000 per location with a
maximum Self-Insured Retention (SIR) or deductible
of $1,000.
c. All required insurance policies ara to be issued by
companies rated B+VI or better per Best's Rating
Guide, latest edition and must provide the City with 30
days written notice of cancellation. Any deviation
from this requirement is subject to the City Risk
Manager's approval.
(2)
(3)
(4)
(5)
d. Valet operators must submit a certificate of insurance
and a certified copy of their policies to the City's Risk
Manager for determination that the insurance
requirements of this Ordinance have been met.
e. Each valet operator applying for a permit for use of
public property shall execute an agreement approved
by the City Attorney's Office providing for the valet
operator to indemnify, hold harmless and defend the
City, its officers, agents and employees against and
assume all liability for any and all claims, suits,
actions, damages, liabilities, expenditures, or causes
of actions of any kind arising from its use of the public
streets or public parking spaces for the purposes
authorized in this Section and resulting or accruing
from any alleged negligence, act, omission or error of
the valet parking operation, its agents or employees
and/or arising from the failure of the valet parking
operation, its agents or employees to comply with
each and every requirement of this Section or with
any other City or County ordinance or State or
Federal law or regulation applicable to the valet
parking operation resulting in or relating to bodily
injury, loss of life or limb or damage to property
sustained by any person, firm, corporation or other
business entity. The valet operator hereby agrees to
hold the City of Miami Beach, its officers, agents and
employees harmless from and against all judgements,
orders, decrees, attorney's fees, costs, expenses and
liabilities incurred in and about any such claim,
investigation or defense thereof, which may be
entered, incurred or assessed as a result of the
foregoing. The valet operator shall defend, at its sole
cost and expense, any legal action, claim or
proceeding instituted by any person against the City
of Miami Beach, its officers, agents, and employees
as a result in any claim, suit or cause of action
accruing from activities authorized by this Section, for
injuries to body, limb or property as set forth above.
If incorporated, the valet operator shall provide a copy of its
articles of incorporation.
Notarized written authorization on company letterhead from
owners/operators of the City-licensed commercial
establishments for which the valet operator is providing
parking services.
Valid valet parking occupational license from the City of
Miami Beach.
Identification of the location of vehicle storage space, and
proof in the form of an executed lease or rental agreement,
(6)
or notarized letter of authorization from the owner of the
property, either of which shall include the number of spaces
authorized for use by the valet operator, and term of the
lease or agreement for storage space sufficient to service
the establishment for which the permit will be issued. The
storage space must meet all requirements pursuant to all
applicable city ordinances.
Valet parking operators are required to enlist all employees
servicing the public (runner, supervisors, and managers) to
attend the "VOTE" (Valet Operator Training on Enforcement)
Training Program sponsored by the City's Parking
Department. All new valet parking operators' employees
must be enlisted for training within sixty (60) days of
employment or at the next regularly scheduled traininq
session. The modules provided as part of the traininq
include, but are not limited to, the following subiects:
Customer Service
Valet Ordinance Regulations
Enforcement
Professionalism/Ethics
Sec. 18-338. Term and renewal
(a) The term of each permit shall be for one year.
(b) Renewal shall be on an annual basis and shall only be granted after
approval from the city's risk manager and occupational license division.
Sec. 18-339. Cancellation and revocation
The City shall cancel and revoke the permit if the valet operator no longer
services the commercial establishment which authorized its operation at that
location. This cancellation and revocation may be effective whether the valet
operator voluntarily discontinues service to the establishment, the establishment
cancels and revokes authorization for the valet operator to service the location,
or the Parking Department cancels and revokes authorization for the valet
operator to service the location. Cancellation and revocation of the valet parking
permit under this paragraph shall be effective immediately upon service of the
notice of cancellation. The Parking Department shall inform in writing the
commemial establishment being serviced by the valet operator, of any
cancellation and revocation by hand delivery or certified mail, return receipt
requested. Service of the notice of cancellation and revocation shall be by hand
delivery or certified mail, return receipt requested.
Sec. 18-340. Private storage of valet vehicles
Valet operators shall store vehicles on private parking lots which are properly
permitted and zoned as parking lots. The valet operator shall provide to the
Parking Department a copy of the proper City of Miami Beach occupational
license or certificate of use issued to the storage parking facility and satisfactory
documentation from the parking facility owner or management company/agent
authorizing the valet operator to use those facilities for the purpose of storing
valet parked vehicles.
Sec. 18-341. Employees and valet operators code of conduct
The valet parking operators shall require its employees and independent
contractors to meet the following requirements:
(1) All employees who operate motor vehicles shall have a valid
Florida Driver's License in good standing and shall abide by all City
of Miami Beach and Miami-Dade County traffic regulations.
(2)All employees shall be in similar uniform.
(3) All employees shall wear on their uniform, a name-tag identifying
the employee's name.
(4) All supervisors shall wear on their uniform, a name-tag identifying
them as such.
(5) All employees shall perform their duties in a courteous and
professional manner.
(6) All new employees must attend the "VOTE" (Valet Operators
Traininq on Enforcement) Program provided by the City's Parking
Department within sixty (60) days of hire or at the next re,qulady
scheduled training session.
(7) Valet operators shall submit to the Parking Department a list of all
employees employed by the valet operator who are engaged in
valet services on Miami Beach. Additions and deletions to the valet
employee roster shall be reported monthly. The employee report
shall be submitted to the attention of the Parking Director or his/her
designee no later than the fifth day of each month. The employee
list shall contain the name of the employee and the employee's
valid Florida Driver's License number. A photocopy of each
employee's valid Florida Driver's License shall be submitted for
each employee on the roster. Failure to comply with this
paragraph shall result in a fine of $25 per day to the valet operator.
Sec. 18-342. Operation of service
(a) Identification of Rented Spaces
Rented spaces shall be so designated by the Parking Department as
rented parking areas. The designation shall be by bagged meters and/or
clearly marked signs indicating the parking restriction.
(b) Ramping
(1) Ramping shall only be operated in the spaces provided for ramping.
The Valet Operator may use the moving lane of traffic during periods of
high demand. High demand periods are defined as periods when the
volume of vehicles to be processed exceeds the resources available.
Valet operators must demonstrate a good faith effort to provide sufficient
resources to meet demand. Storaqe of vehicle(s) may be allowed in up to
fifty (50%) of the designated ramp area. Note: Use of the ramp area for
storage constitutes waiver of Section 7 (b)(1) Th, .,~,~ .... ~,,~,,h'~ll ~h .... ,,~ v.~.--~v{' ..... C~(,
vehlc ......... 3rc3 ............ ~.,, ,~.
not occur in any other location than the public on-street/curbside parking
spaces provided for ramping, except as defined in Section 7(b)(1) and (2)·
~'Jthcr!zsd by th~ CSt¥.
(2) Valet operators may petition the Parking Department to utilize a
moving lane of traffic for the expeditious loading or unloading of
passengers· The expeditious loading or unloading of passengers is
defined as taking possession and removal of the vehicle by either the valet
operator or vehicle ownedoperator within two (2) minutes of stopping
and/or standing in the moving lane of traffic· The vehicle must be
immediately moved to either the authorized ramping area and/or
authorized storage area. A committee of three (3), comprised of two (2)
department heads (Parking Director and Police Chief, or designees) and a
designee of the City Manager shall evaluate, approve, and/or disapprove
requests based on one or both of the following criteria:
a. On-street parking is not available within one hundred
feet of the front door of the establishment to be
serviced.
b. Volume of patrons utilizing valet parking service at an
establishment creates a safety hazard for either
vehicular and/or pedestrian traffic.
Notes: (1) Requests for the use of a moving lane of traffic
will not be accepted or considered within the following
boundaries: North - Centerline of 17th Street, South -
Centerline of 5th Street, West - Biscayne Bay, East - Atlantic
Ocean.
(2) Requests for the use of a moving lane of traffic must be
resubmitted annually in conjunction with the occupational
license renewal for said location(s)· All required criteria and
approvals contained herein remain in effect· The committee
reserves the right, on 24-hour notice, to revoke and/or
suspend said approval·
(3) The valet operator must provide the following:
(a) Maintenance of traffic plan (must be
approved by the Director of Planning and
Zoning) and (b) Off-Duty Police· The
Committee will evaluate and determine the
need for off-duty police contingent upon
the establishment's location, volume of
service, and other existing conditions·
c. On-Call (Hotel) Valet Ramps
Valet operators may establish on-call valet ramps for establishments that
require valet service intermittently. The following criteria must be adhered:
6
(1) Valet operator must obtain an occupational license in order
to provide On-call Valet Service.
(2) Ramping - an existing passenger loading zone must be used
for ramping purposes. The valet operator must provide
written consent from the establishment (hotel) for the use of
the passenger loading zone for this purpose. All regulations
contained herein remain in effect and govern the use of
ramp spaces.
(3) The ramp (passenger loading zone) may be identified with
signs. At no time shall signs be placed on the roadway,
impeding vehicular and/or pedestrian traffic. All signs must
be approved by the City Manager or his designee. The use
of other traffic devices, including cones, and/or any other
device is strictly prohibited.
(4) The Valet Operator must post a current and valid Valet
Parking Permit at the Hotel's Front Desk.
(d) Storage
Storage of vehicles shall only be in private spaces, authorized ramp areas,
or in leased municipal spaces as provided by the Parking Department.
Other than the leased municipal spaces, there shall be no storage of
vehicles on any municipal property whatsoever. Valet operators shall
clearly identify the vehicles in their possession during the entire period that
the car is in their possession. Such identification shall be made through a
ticket stub affixed to the rear view mirror of the stored vehicle and shall
state the name of the valet operator and identification of the ramp from
which the vehicle was picked-up. Ramp identification shall be made by
stating the name of the establishment which the ramp is servicing.
Unauthorized storage of valet vehicles in municipal parking facilities, or at
any public on-street/curbside parking spaces is strictly prohibited and shall
result in the issuance of a valet violation to the valet operator in the
amount of $250.00, per occurrence.
Sec. 18-343. Exceptions
a. Valet Service - Special Event
Valet services operating for a special event may apply for a special event
permit from the City's Tourism and Cultural Development Director cf .~.,'tc,
~'"~* ...... ~ "'-*"'*~" .... * Special event parking shall be restricted to
any event occurring no more than twice per year and lasting no longer
than three (3) days in length. The special event permit will allow the valet
operator to request from the Parking Department, additional ramping
and/or storage space, if available, as long as it does not_reduce the
number of parking spaces needed to serve the general public in the area
of the request.
b. Valet Service - Residential
Valet service may be provided for non-commercial uses, including private
functions in residentially zoned areas. Valet operators must meet the
following criteria: (1) Valet Operator must obtain a Zero Street Address
Occupational License through the Occupational Licensing Division/City of
Miami Beach Finance Department, (2) Zero Street Address License is only
permitted for use in areas zoned residentially, (3) Zero Street Address
License may not be simultaneously used in multiple residential locations,
(4) Valet operators must complete a Temporary Valet Parking Permit
Form and submit this form to the Parking Department three (3) days prior
to the scheduled event.
Note: Temporary Valet Parking Permit Requests submitted within less
than three (3) working days of a scheduled event will only be accepted for
situations deemed as an emergency. An emergency is defined as a
situation or occurrence of a serious nature, developing suddenly and
unexpectedly within less than three (3) working days of the event and
demanding immediate attention.
The following requirements must be satisfied:
(1) Ramping. Valet ramping may be provided either on private
property at the location to be serviced or on public property.
Ramping on public property shall not occur in any other
location than the public on-street/curbside parking spaces
provided for ramping. Ramping from a moving lane of traffic
is strictly prohibited unless authorized by the City. The
ramping area shall be determined as stated in Section 3 {C}
entitled, Number of spaces leased for ramping.
(2) Storage. Storage of vehicles must be in compliance with
Section 5, entitled, Private Storage of Valet Vehicles and/or
Section 4, entitled, Rental of Additional Parking for Storage
of Vehicles. Storage of vehicles on public right-of-way is
strictly prohibited, unless authorized by the Parking
Department.
a. Storage on public right-of-way. Valet operators may
request the use of public right-of-way for storage
under the following conditions:
1. Private or public storage (parking lot and/or
garage) is not available within 2,500 feet of the
location to be serviced.
2. All prohibited parking regulations (fire hydrants,
crosswalks, etc.) are strictly enforced.
Sec. 18-344. Enforcement; fine schedule, and right of appeal.
(a) Enforcement:
The Parking Department shall enforce the provisions of this Ordinance.
The Police Department and Code Enforcement Department shall also
assist the Parking Department in the enforcement of the Valet Operators
Code of Conduct, as set forth herein. This shall not preclude other law
enforcement agencies or regulatory bodies from any action as necessary
to assure compliance with this Ordinance and all applicable laws. If a
parking enforcement specialist finds a violation of this Ordinance, the
parking enforcement specialist shall issue a Notice of Violation to the
violator as provided in Ch""*"-~..v, wa"' of ~-'~"v,~,,,_,,vv ..... ,,v,l~'l~ v~(3~-' ~,9097 Section 30-
7~8, as may be amended from time to time. The Notice shall inform the
violator of the nature of the violation, amount of fine for which the violator
may be liable, instructions and due date for paying the fine, notice that the
violation may be appealed by requesting an administrative hearing before
the Special Master within ten (10) days after service of the Notice of
violation and that failure to appeal the violation within the ten (10) days,
shall constitute an admission of the violation and a waiver of the right to a
hearing.
(b)
1.
Fines. The following civil fines shall be imposed for each
violation per location:
Illegal Ramping:
Illegal use of public right-of-way for the purpose of accepting
or delivering a vehicle or accepting or delivednq a vehicle
when a vehicle is stored in the assigned ramp for over ~ 5
minutes.
Violations: First Offense:
$150
Second Offense: $150
Third Offense: $150
Fourth Offense: $150
Fifth Offense or
Subsequent
offense:
Mandatory Referral to Special
Master
Ille,qal Stora~qe:
Ille,qal storaqe of vehicle(s) in public facilities and/or
public d,qht-of-way or in unauthorized private storage
location(s) as described in permit (occupational
license).
Violations:
First Offense:
Second Offense:
Third Offense:
Fourth Offense:
Fifth Offense
or subsequent
Offenses:
$25O
$250
$500
$500
Mandatory Referral to
Special Master
Operation without Valet Permit $50.OOper offense/per day
Penalty for Lapse in Required Insurance Coverage (from
date of lapse) $150.00 per offense/per day
No Name Tag $25.00 per offense
(c)
No Uniform $25.00 per offense
No Valid Florida Driver's License $25.00 per offense and
immediate removal of the employee from the valet operation.
Non-compliance with Valet Employee list $25.00 per day.
Special Master Review:
In addition to the factors set forth in Section 30-74(e), the
Special Master may consider, inter alia, the following factors
when determininq the amount of the fine:
a. Number and type of violations under permit where
violation originated (specific location).
b. Permitted location utilization (hours/number of days a
week location is operational).
c. Parkinq and traffic conditions existinq at the subiect
location at the time of the violation.
Rights of violators; payment of fine; right to appeal; failure to pay civil fine,
or to appeal.
(1) A violator who has been served with a Notice of Violation shall elect
either to:
a. Pay the civil fine in the manner indicated on the Notice; or
b. Request an administrative hearing within ten (10) days of receipt of
the violation before a special master appointed by the City
Commission upon recommendation of the City Manager, to appeal
the decision of the Parking Department or other Department which
resulted in the issuance of the Notice of Violation.
(2) The procedures for appeal by administrative hearing of the Notice
of Violation shall be as set forth in Sections 20 '!,3 30-71 and 20
~,~, 30-72 of the Miami Beach City Code, and amendments thereto.
(3) If the named violator after notice fails to pay the civil fine or fails to
timely request an administrative hearing before a special master,
the special master shall be informed of such failure by report from
the Parking Department. Failure of the named violator to appeal
the decision of the Parking Department within the prescribed time
period shall constitute a waiver of the violator's right to
administrative hearing before the special master. ^ waiver of the
right to an administrative hearing shall be treated as an admission
of the violation and penalties may be assessed accordingly.
Any party aggrieved by the decision of a special master may appeal
that decision to a court of competent jurisdiction.
(4)
(5)
10
(d) Recovery of unpaid fines.
(1) The City may institute proceedings in a court of competent
jurisdiction to compel payment of civil fines.
(2) A certified copy of an order imposing a civil fine may be
recorded in the public records and thereafter shall constitute
a lien upon any other real or personal property owned by the
violator and it may be enforced in the same manner as a
court judgment by the sheriffs of this State, including levy
against the personal property, but shall not be deemed to be
a court judgment except for enforcement purposes. After
two (2) months from the filing of any such lien which remains
unpaid, the City may foreclose or otherwise execute upon
the lien.
(3) As an additional means of enforcement, the City may seek
injunctive relief and /or follow procedures to revoke an
occupational license as set forth in the City Code when there
are repeated violations of this Ordinance.
(4) Additionally, The Parking Department, shall withhold
issuance of any new valet permits and leased public on-
street/curbside valet parking spaces, and suspend current
valet permits until past due violations are paid in full. The
Parking Department reserves the right to bring forward to the
Special Master any party who has waived their right to
appeal and has over three outstanding violations.
(e) Valet operators responsibility for vehicles in their possession:
Valet operators shall pay all fines and fees, including towing
charges, arising in connection with a patron's vehicle which is in the
possession of the valet operator at the time such charge is
incurred. This does not preclude the valet operator from also being
cited by the Parking Department for violations of this section which
resulted in the imposition of the fines and fee.
Section 2. That Division 3, Article VIII, of Chapter 18 of the Miami Beach City Code is
hereby amended as follows:
DIVISION 3. RENTALS
Sec. 18-361. Rental and operation of municipal parking spaces
(a) Rental of Public Spaces for Ramping.
The parking department shall rent to the valet operator public on-
street/curbside parking spaces that shall be usedv,"""',,, for ramping of
vehicles or storaqe of vehicle(s) (stora.qe is defined as the stoppin(~,
standing, or parking of vehicle(s) for over fifteen (15) minutes within the
designated loading area). In no event shall storaqe take place in over fifty
(50%) percent of the allotted ramp space. Ramp space size is determined
by length (linear feet). Ramping of vehicles shall consist of allowing
customers to enter or exit a vehicle and to turn it over to or retrieve it from
ll
valet employees. Ramping shall only be operated in the public on-
street/curbside spaces provided by the Parking Department for ramping o_r
moving lane of traffic as described in Section 7 (b)(1) and (b)(2). :F-here
c~,~u ~, .... , ..... ct ,,,~,;,.~,,~ ;,, ,h ......... '~ ~ ...... ;"" A vehicle will
be considered stored if it remains in the ramping area for more than fifteen
(15) minutes. The operator may choose to store vehicle(s) in no more than
50% of the ramp area. Upon exercisinq said option, the Valet Operator
waives the right to use the "moving lane of traffic" provision as described
in Section 7 (b)(1) and (2). Ramping on public property shall not occur in
any other location than the on-street/curbside spaces provided for
ramping, except as described in Section 7 (b) (1) and 7 (b) (2).
Leased spaces shall not be blocked by any type of sign, structure or other
type of object. Leased spaces shall not be cordoned off by any type of
signage, rope or barrier of any kind, except that signage provided by the
City indicating the designation of the restricted valet parking area. At its
sole discretion and judgement, the Parking Department shall provide to
the valet operator sufficient ramping space in a close proximity to the
establishment being serviced, if sufficient spaces are available. If there is
not sufficient space available for rental in front of the establishment, the
Parking Department shall lease spaces as close to the establishment as
possible. Notwithstanding the above, ramping will not be allowed if the
Parking Department determines, at its sole discretion, that it would be an
unsafe activity at that location.
(b) Rental Fees for Public On-Street/Curbside Spaces.
The parking department shall post in the offices of the parking department,
the fee for use of public on-street/curbside spaces. All Valet Parkinq
Meter Rental Fees are codified in CMB Ordinance No. 2000-3267. Thc
,v~ ,v, ~v v, ,v,,~ ~l~vv~ ~,,~,, wv ~v.vv I''v' vl~vv'l~v'
...... ,~ ,~ ,~ .... ,~ .....,~. ~.. ~ o~.~ n...~.., All additions
or changes to existing leased public on-streeffcurbside parking spaces for
ramping, shall bo paid upon roquost. All valor spaco Ioaso roquosts shall
bo roquirod in writin~ to tho ~arkino Diractor or his/her dosi~noo,
four (24) hours in advanco, and received no lator than 3:00 ~.M. daily.
fixcoptions and Ioaso cancollations not mado within tho proscribod poriod
will bo assossod a $20.00 procossin~
(c) Number of spaces leased for ramping.
The amount of ramping spaces available to the valet operator shall be
determined by the frontage of the establishment being serviced provided
that there is sufficient public on-street/curbside spaces available for
ramping, as determined in the sole discretion of the Parking Department.
12
(d) Subletting.
Leased public on-street/curbside or off-street spaces may not be sublet to
another valet parking operator,
Sec. 18-362. Rental of additional parking for storage of vehicles
Storage space required for the operation of a valet service must be provided in
private parking lots or authorized municipal facilities. All such facilities must meet
all applicable Code and Ordinance requirements of the City of Miami Beach. The
Parking Department may lease additional valet spaces for the storage of vehicles
for special events, special programs, residential functions, or at the request of the
valet operator, if the proposed valet storage space does not take away from
public parking demand in the area. The parking department shall post in the
offices of the Parking Department, the fee for use of storage parking spaces. The
fee for use of storage parking spaces shall be based on a twelve (12) hour period
at a rate of $10.00 per space/per day. Fees shall be paid in full, twenty-four (24)
hours in advance of the special event.
SECTION 2. REPEALER
All ordinances or parts of ordinances in conflict herewith be and the same are hereby
repealed.
SECTION 3. SEVERABILITY
If any section, subsection or provision of this Ordinance is held invalid, the remainder
shall not be affected by such invalidity.
SECTION 4.
CODIFICATION
It is the intention of the Mayor and Commission of the City of Miami Beach, and it is
hereby ordained that the provisions of this ordinance shall become and be made a part
of the Code of the City of Miami Beach, Florida. The sections of this ordinance may be
renumbered or relettered to accomplish such intentions, and the word "ordinance" may
be changed to "section", "article", or other appropriate word.
SECTION 5. EFFECTIVE DATE
This Ordinance shall take effect on July 12,
,2003.
PASSED and ADOPTED this
ATTEST:
2nd day of ~ July
,2003.
Mayor
Ci~ Clerk
F:\PING\$ALL\SAUL\COMMRESO\valetordinanceamendments070203.ord.doc
Rev.7/2/03
APPROVED AS TO
FORM & I.N'~E
& FOR EXECUTION
14
CITY OF MIAMI BEACH
COMMISSION ITEM SUMMARY
Condensed Title:
IAn Ordinance amending Division Two, entitled, "Valet Parking Permits for Use on Public Property"; and
Division Three, entitled, "Rentals"; providing for required training "VOTE" (Valet Operators Training on
Enforcement); Expanded ramping areas under certain circumstances; Revised enforcement provisions and
graduated fine schedules.
Issue:
IWhether to adopt the proposed and subsequently revised amendments from the first reading on May 21,
2003 to the Valet Parking Ordinance on second reading?
Item Summary/Recommendation:
The Parking Department in conjunction with the valet parking industry collaborated to formulate the
following amendments to the valet parking ordinance. Amendments include, required participation in
V.O.T.E. (Valet Operator Training on Enforcement); Expanded ramping areas via the occasional use of a
moving lane at peak periods, use of the ramp area to store vehicles (exercising this provision waives right
to exercise moving lane of traffic provision), strict enforcement of illegal storage on public or unauthorized
parking spaces; revised enforcement fine schedules, including potential referrals to the Special Master
Proceedings upon receipt of a fifth violation for certain offenses, including criteria for the Special Master to
consider in the review process. Historically, neither the valet parking ordinance nor the collection of fees
(parking space rentals) have been applied for the use of the public parking spaces on the west side of
Ocean Drive between 5th and 15th Streets. The Finance and Citywide Projects Committee directed the
Administration to meet with the Ocean Drive Association and valet operators in order to formalize a
recommendation.
At the first reading on May 21,2003, the Mayor and Commission directed the Administration to revise the
enforcement provisions establishing a graduated fine schedule for certain violations. A graduated fine
schedule was incorporated resulting in fines of $150 to $450 and $250 to $1,000 for illegal ramping and
illegal storage, respectively. In addition, the Administration reserves the right to refer any valet operator that
is deemed a habitual offender to the Special Master. The Administration recommends that the Mayor and
City Commission approve the ordinance on second and final reading on July 2, 2003.
Advisory Board Recommendation:
The Transportation and Parking Committee's Sub-Committee on Valet Parking endorsed the proposed
amendments to the ordinance on April 22, 2003. The sub-committee reported back to the committee of
the whole on May 13, 2003 and on June 3, 2003. On June 3, 2003, the committee of the whole reviewed
the amendments and re-stated an endorsement of the initial Administration recommendation requiring a
mandatory special master proceeding upon a third (or subsequent) violation for illegal ramping and/or
storage.
Financial Information:
Amount to be expended:
Source of
F u n d s:
Iii~;~ ~i~i~:~i
~)i! ii!~ ~!!
Finance Dept. ~ ~
City Clerk's Office Legislative Tracking:
I Saul Frances, Parking Department
Si n-Offs:
T:~AGEN DA~003\apr3003\reg ular~valet parkingordina nce043003.su~n~OC~
AGENDAITEM
DATE
7-2_-0%
CITY OF MIAMI BEACH
CITY HALL 1700 CONVENTION CENTER DRIVE MIAMI BEACH, FLORIDA 33139
www.ci.miarni-beach .fl .us
COMMISSION MEMORANDUM
To:
From:
Mayor David Dermer and
Members of the City Commission
Jorge M. Gonzalez ~
City Manager
Date: July 2, 2003
SECOND READING
PUBLIC HEARING
SubJect:
AN ORDINANCE OF THE MAYOR AND CITY COMMISSION OF THE CITY OF
MIAMI BEACH, FLORIDA, AMENDING MIAMI BEACH CITY CODE CHAPTER
18, ENTITLED "BUSINESSES," BY AMENDING ARTICLE VIII, ENTITLED
"PARKING LOT," BY AMENDING DIVISION 2, ENTITLED, "VALET PARKING
PERMITS FOR USE ON PUBLIC PROPERTY"; BYAMENDING SECTION 18-
336 THEREOF BY PROVIDING FOR REQUIRED "VOTE" (VALET
OPERATOR TRAINING ENFORCEMENT) TRAINING PROGRAM; BY
AMENDING DIVISION 3, ENTITLED, "RENTALS"; BY AMENDING SECTION
18-341 THEREOF BY PROVIDING ADDITIONAL CODE OF CONDUCT
REQUIREMENTS FOR VALET OPERATORS AND THEIR EMPLOYEES; BY
AMENDING SECTION 18-342 BY PROVIDING EXPANDED RAMPING AREAS
UNDER CERTAIN CIRCUMSTANCES; BY AMENDING SECTION 18-343 BY
PROVIDING THAT VALET PERMITS FOR SPECIAL EVENTS SHALL BE
APPLIED FOR FROM THE CITY'S TOURISM AND CULTURAL
DEVELOPMENT DIRECTOR; BY AMENDING SECTION 18-344 BY
AMENDING THE FINES AND ENFORCEMENT PROCEDURES FOR
VIOLATORS; AND PROVIDING FOR REPEALER, SEVERABILITY,
CODIFICATION, AND AN EFFECTIVE DATE.
ADMINISTRATION RECOMMENDATION
Adopt the Ordinance on second and final reading.
BACKGROUND
On July 28, 1994, the Mayor and City Commission amended Miami Beach City Code
Chapter 20, entitled "Business Licenses" amending Section 20-32, entitled "Parking Lot;
Exemptions; Valet Parking" by ratifying and establishing the Valet Parking Ordinance (CMB
Ordinance No. 94-2935). The primary goal of the Ordinance was to establish regulatory
guidelines forvalet parking operators utilizing public right-of-way. Residents and business
operators expressed their concern over private valet parking operations that use municipal
parking spaces and public streets for operation of their service. The regulatory
requirements included the provision of a business license, insurance requirements, and
storage spaces, ramping spaces (drop-off and pick-up), rental fees, enforcement, fine
structure, appellate process (Special Master), etc.
July 2, 2003
Commission Memorandum
Amending Chapter 20 CMB Code- Valet Licenses
Page 2 of 7
On April 19, 1995, the Mayor and City Commission revised the Valet Parking Ordinance
(CMB Ordinance No. 95-2987) in a continual effort to meet the evolving needs and
circumstances surrounding valet parking operations utilizing public rights-of-way. These
revisions included strengthening several provisions in the Ordinance including: insurance
requirements, identification of storage spaces, limitation of the number of curbside spaces
used for ramping, and the use of public parking spaces for valet storage at municipal
parking facilities.
On May 12, 1999, the Mayor and Commission approved the following amendments to the
Valet Ordinance (CMB Ordinance No. 99-3182) providing for: (1) procedures and
requirements for the use of a moving lane of traffic in areas void of on-street parking; (2)
on-call valet parking for small hotels, and (3) procedures and requirements for valet parking
in residential areas.
In early 2002, the Mayor's Blue Ribbon Task Force on Tourism identified various
recommendations for the improvement of service to visitors/tourists. A specific sub-
committee on Parking was formed. The Parking Sub-Committee made various
recommendations, including an amendment to the enforcement provisions of the valet
ordinance establishing a "five" strike enforcement program aimed at habitual violators of
the ordinance in order to encourage adherence to the regulations and ultimately improve
service. After various discussions, including one at the Transportation and Parking
Committee, the five-strike program was abandoned due to the valet industry's contentions
that overzealous enforcement could potentially jeopardize the industry. Subsequently,
Commissioner Steinberg requested that the City Attorney's Office draft an amendment to
the valet ordinance proposing to replace the existing enforcement fines/provisions within
the Valet Ordinance with Chapter 30 of the City Code (Code Enforcement/Special Master
Proceedings). At the request of Commissioner Steinberg, the Mayor and Commission
referred the item to the Neighborhoods Committee.
On February 24, 2003, the Neighborhoods Committee heard the proposed amendment s to
the valet ordinance recommending revisions replacing the existing enforcement
procedures/fines with the City's Code Enforcement procedures. Upon further discussion
and input from participants in the valet industry regarding this and other operational issues,
the Neighborhoods Committee directed the Administration to hold a workshop with
members of the industry in order to present proposed amendments to the Transportation
and Parking Committee, and ultimately to the Mayor and Commission.
Commission Directives at First Reading (May 21, 2003)
At the first reading of the ordinance at the May 21, 2003, City Commission Meeting, the
Mayor and City Commission approved all proposed amendments with the exception of the
enforcement provisions requiring third or subsequent violations of illegal ramping and/or
illegal storage to be referred to the Special Master proceeding. The Mayor and
Commission directed the Administration to revise the enforcements provisions with a
graduated fine schedule for these two specific violations. To this end, the Administration
held a workshop with representatives of the valet industry on June 28, 2003 and revised
Juiy 2, 2003
Commission Memorendum
Amending Chepter 20 CMB Code- Valet Licenses
Pege 3 of 7
the ordinance to reflect a consensus graduated fine schedule of $150 to $450 and $250 to
$1,000 for illegal ramping and illegal storage, respectively. It is important to note that at the
initial workshop held with the valet parking industry, various amendments were proffered as
concessions to the valet parking industry and were contingent upon having an enforcement
procedure with "teeth" in order to prevent abuse and/or habitual offenders of these and
other regulations. In keeping with the intent and direction of the Mayor and Commission
and in light of the concerns of overzealousness in both enforcement and/or Special Master
proceedings, the Administration has increased the graduated enforcement schedule from
three to five fines with the aforementioned graduated fines. It should be taken into account
that the intent of the initial "Special Master" recommendation was to have an independent
third party evaluate the valet operator's historical performance, intent, and efforts to comply
with the ordinance in order to: (1) identify habitual offenders, (2) alter their behavior, and
(3) ultimately provide a higher level of service on a level playing field for all operators.
Absent a mandatory Special Master referral, the Parking Department is placed in a position
of having to identify habitual offenders and refer them to the Special Master. These
circumstances may create opportunities for criticism of the Administration of selective
enforcement and/or "targeting" of valet operators. Notwithstanding these issues and absent
a mandatory referral to the Special Master, the Administration reserves the right to refer a
valet operator that is deemed a habitual offender to the Special Master.
The Transportation and Parking Committee's Sub-Committee on Valet Parking endorsed
the initially proposed amendments to the ordinance on April 22, 2003. The sub-committee
reported back to the committee of the whole on May 13, 2003 and subsequently to the full
committee on June 3, 2003 with the Commission directives. On June 3, 2003, the
committee of the whole reviewed the amendments directed by the Mayor and Commission
and re-stated an endorsement of the initial Administration recommendation requiring a
mandatory special master proceeding upon a third (or subsequent) violation for illegal
ramping and/or storage.
ANALYSIS
On March 20, 2003, the Parking Department held a workshop with the valet parking
industry. As a prelude to the workshop, the Department issued a letter of invitation to all
valet operators requesting that they participate and provide their issues of concern with the
existing ordinance and issues affecting them in general. The industry responded with a
summary of issues and corresponding scenarios to be discussed at the workshop. There
were predominantly four issues raised that were eventually addressed resulting in
consensus for the proposed amendments. These issues are: (1) training/communication,
(2) ramping (loading/unloading of passengers), (3) vehicle storage locations, and (4)
enforcement fines/procedures. The following is a summary of each revision to the
ordinance outlining the existing regulation and proposed amendments:
V.O.T.E. Training (Valet Operators' Training on Enforcement):
Currently, there is no provision in the ordinance for required training; therefore, this is a
new initiative recommended by the Administration in order to dissemination the regulations
April 3O, 2003
Amending Chapter 20 CMB Cede- Valet Licenses
Page 4 of 7
being enforced and to begin to inculcate a code of conduct by which all valet operators can
provide courteous service. Technically, valet operators are leasing public parking spaces
(City Property) to provide a valet parking service as a "for profit" entity. The City has a
vested interest in ensuring that we all commit to providing the best service within our
resources. Both valet parking operators and the Administration identified a need for better
communication between employees of the industry and enforcement personnel. To this
end, the Parking Department developed a training module specifically for valet parking
employees (runners, supervisors, and managers). The modules are comprised of: (1)
Customer Service, (2) Valet Ordinance Regulations, (3) Enforcement, and (4)
Professionalism and Ethics. The goals of the training efforts are to: (1) establish
communication by educating all on each other's challenges, (2) provide helpful customer
service tips/behavior, (3) interpret regulations consistently by both valet parking employees
and enforcement personnel, (4) understand the need for consistent and equitable
application of enforcement, and (5) develop professionalism and encourage ethical
behavior amongst all serving the public. All valet operators will be required to enlist for
training all new employees within sixty (60) days of employment or at the next regularly
scheduled training session.
RAMPING
Existing Regulation:
Ramping is the expeditious loading or unloading of passengers in authorized areas
established typically at bagged meters and/or posted areas. Valet operators may
not ramp in any location other than their authorized ramp area. Use of a moving
lane of traffic or unauthorized parking areas are a violation of this provision resulting
in a $150 fine.
Proposed (Consensus) Regulation:
Valet operators may use the moving lane of traffic during peak demand periods.
Peak demand is defined as periods when demand exceeds resources (ramps area
or number of runners) available. It is important to note that valet operators must
demonstrate a good faith effort in providing resources to meet expected demand.
This provision will afford valet operators flexibility to provide more expedient service
to users without violating the ordinance. A secondary request by the industry was to
increase the size of ramp areas (number of meters bagged) by either increasing the
number of spaces or allowing unutilized parking spaces immediately adjacent to
their ramps for their use. From a policy perspective, it is the Parking Department's
goal to minimize the number of spaces reserved for private and/or specialty uses in
order to maximize the availability of public parking. Cleady, the occasional use of a
moving lane of traffic is a more efficient use of space than removing additional
public parking spaces from the available inventory.
Secondly, a provision for storage of vehicles within the ramp area was established;
however, at no time could more than fifty (50%) of the ramp area be used for
storage. Vehicles are considered stored if stopping, standing, or parking for a period
exceeding fifteen (15) minutes. Furthermore, exercising the ramp storage provision
April 3O, 2003
Amending Chapter 20 CMB Code- Valet Licenses
Page 5 of 7
automatically waives the valet operator's right to use the "moving lane of traffic"
provision. This caveat was recommended in order to minimize abuse such as valet
operators storing vehicles in their ramp area and using the moving lane of traffic to
process customers. Ramp areas are for loading/unloading purposes. Storage in
the ramp area is a "business decision" of the valet operator that constitutes waiver
of any additional ramping areas and/or opportunities.
STORAGE
Existing Regulation:
Storage is only allowed in authorized locations, typically in private parking facilities.
The storage facilities must be identified in the valet operator's occupational license.
Proposed (Consensus) Regulation:
All valet operators have agreed that storage in on-street or off-street public parking
space(s), except authorized uses such as the aforementioned ramp provision, is a
violation of the ordinance and should be strictly enforced.
ENFORCEMENT PROVISIONS
Existing Regulations:
The following is the
amendment:
existing
fine schedule
for the violations proposed for
Illegal Ramping: First and all subsequent violations $150 per occurrence.
Illegal Storage: First and all subsequent violations $250 per occurrence.
Proposed (Consensus) Regulation (Revised):
The following are the fine schedules for the violations proposed for amendment:
Illegal Ramping: Illegal use of public right-of-way for the purpose of accepting or
delivering a vehicle or illegal use of a lane of traffic for the purpose of accepting or
delivering a vehicle when exercising the ramp storage provision.
First Violation:
Second Violation:
Third Violation:
Fourth Violation:
Fifth or subsequent
Violations:
Illegal Storage: Illegal
and/or in unauthorized
(occupational license).
First Violation:
Second Violation:
Third Violation:
$150 per occurrence.
$150 per occurrence.
$300 per occurrence.
$300 per occurrence.
$450 per occurrence.
storage of vehicles in public facilities, public right-of-way,
private storage locations as described in the permit
$250 per occurrence.
$500 per occurrence.
$750 per occurrence.
April 30, 2003
Amending Chapter 20 CMB Code- Valet Licenses
Page 6 of 7
Fourth Violation:
Fifth or subsequent
Violations:
$750 per occurrence.
$1,000 per occurrence.
Special Master Referral: Violators fifth or subsequent offenses may result in a
referral to the Special Master Proceedings.
If referred, the Special Master shall consider the following factors:
· Number and type of violations under permit (location).
· Frequency of use (days per week) of permit location.
· Violations shall remain on file for Special Master review for a period not
exceeding twelve (12) consecutive months.
Notwithstanding these amendments to the enforcement provisions of the Code, the
City Code also provides certain remedies for habitual offenders:
Section 102-381. Grounds for suspension, revocation and denial.
(a) The City Manager or his or her designee shall either revoke or temporarily
suspend the license of any Person where it is determined by the city manager or
his or her designee that:
(4) Habitual conduct has occurred at the licensee's premises that violate city,
county or state law.
In addition, the valet parking industry contends that enforcement of the ordinance is too
strict and, at times, overzealous. An analysis of the Valet Parking Ordinance enforcement
efforts of the Parking Department for calendar year of 2002 (January 1, 2002 through
December 31, 2002*) reveals the following results:
Total number of violations: 197'
Total number of violations administratively waived: 15'
Balance of Valid Violations: 182'
Total number of operators: 11'
Total number of ramps: 51'
Note: 197 violations for 51 ramps in a twelve (12) month period equates to one
violation per ramp every 3.1 months. Clearly, operators with the most ramps (locations)
have more opportunities for violations. A review of the distribution of violations by numberof
ramps revealed the following:
Number of Ramps
Number of Violations
1 2
1 4
2 2
3 4
4 6
4 10
4 12
Apdl 3O, 2OO3
Amending Chapter 20 CMB Code- Valet Licenses
Page 7 of 7
Total:
4 24
8 25
8 30
12 78
51 197
A further review by type of violation revealed that illegal storage is the most pervasive
amongst all operators:
Violation: Number of Violations J~_.)
Illegal Storage: 89 45.1%
Illegal Ramping: 69 35.1%
No Name-Tag: 20 10.2%
No Permit (License): 12 6.1%
No Driver's License: 5 2.5%
No Insurance 2 1.0%
Total: 197 100%
Ocean Drive
Historically, neither the valet parking ordinance nor the collection of fees (parking meter
space rentals) have been a~plied for the use of the public parking spaces on the west side
of Ocean Drive between 5 and 15th Streets. This issue was discussed at the May 12,
2003 Finance and Citywide Projects Committee. The Committee directed the
Administration to meet with the Ocean Drive Association and affected valet parking
operators in order to determine the appropriate size and type of regulation for the area in
question.
CONCLUSION
The recommended amendments to the valet parking ordinance are a result of the
collaborative efforts of all parties affected (Valet Parking Industry, Administration, and
Business Community). Our collective goal is to improve communication, streamline
processes, and provide fair and equitable enforcement of regulations. The Administration
recommends that the Mayor and Commission approve the revised amendments at the
second and final reading on July 2, 2003.
JMG/CMC/b~
T:~AGENDA~2003~apr3003\regular~VALETORDINANCEAMD043003.CME.doc
CITY OF MIAMI BEACH
NOTICE OF A PUBLIC HEARING
REBY ivan that a publ c hearing will be held by the Mayor and k~
NOTICE IS HE -g- ....... ,:-~ =,,cch Florda, in the Comm_issio. n I~
· lesion of me ~lty u~ ,v,a,,, ,~v,,. , . . .
~YamCb°erms,m3rd floor, City Hall, 1700 Convention Center Drive, Miami Beacn,
Florida, on Wednesday, July 2, 2003, at 10:15 a.m., to consider the following:
AN ORDINANCE AMENDING MIAMI BEACH CiTY CODE CHAPTER 18, ENTITLED
,, "BY AMENDING ARTICLE VIII, ENTITLED "PARKING LOT," BY
BUSINESSES .............. ~, "VA ET PARKING PERMITS FOR USE ON
~,MENDING DIVISION z, ~'[~H~-'-~, _..L
PUBLIC PROPERTY"; BY AMENDING SECTION 18-336 THEREOF BY PROVIDING
FOR REQUIRED "VOTE" (VALET OPERATOR TRAINING ENFORCEMENT)
TRAINING PROGRAM; BY AMENDING DIVISION 3, ENTITLED, "RENTALS"; BY
AMENDING SECTION 18-341 THEREOF BY PROVIDING ADDITIONAL CODE OF
CONDUCT REQUIREMENTS FOR VALET OPERATORS AND THEIR EMPLOYEES;
BY AMENDING SECTION 18-342 BY PROVIDING EXPANDED RAMPING AREAS
UNDER CERTAIN CIRCUMSTANCES; BY AMENDING SECTION 18.343 BY/'~
PROVIDING THAT VALET PERMITS FOR SPECIAL EVENTS SHALL BE APPLIEDI[~
FOR FROM THE CITY'S TOURISM AND CULTURAL DEVELOPMENT DIRECTOR;I-a'
THE FINES AND ENFORCEMENT
BY AMENDING SECTION 18-344 BY AMENDING
w~nLATORS' AND PROVIDING FOR REPEALER,~
· ROCEDURES FOR ~,,-,~,- ,
SEVERABILITY, CODIFICATION, AND AN EFFECTIVE DATE.
Inquiries may be directed to the Parking Department at (305) 673-7505. ~
INTERESTED pARTIES are invited to appear at this meet ng, or be represented by I
ex ress their views in writing addressed to the City Commission,[
an agent, or_to . p ..... . ' .1st Floor, Cit Hall, Miami Beach, ~
c/o the City (;larK, 1.700 Co[_,..v_~_nt ~n Center Dn~we~; Is for Dub~ inspection during !
· o les of th~s u[d,nance are --- ab _
Florida 33139 C p = , ' 700 Convention Center Dnve., 1st,
normal business n..ours, in the C,t,y__C..l,e_rk s OfflC.~.~ rneetina may be continuecl
· it HalI, M~am Beach Florida33139 ............. ~.. - .. ~ -
.F.l..o~..r; ?,,~h ~-ir~..mstances additional legal notice would not os provided. _.. /
u,,~ ................ Robert E. Parcher, City (JlerK !
· City of Miami Beach-
286 0105, Fla Stat, the City hereby adv see the public that: fi. a !
Pursuant to Section · · '. ' · Commission with respect t.o .~l.y !
to a cai any decision made by the City
arson dec,des PP .... n must ensure that a va..rt~um
P · at its mee[~ng or ~ts heanng such parco . .
matter considered · -- · includes the testimony and e~. ~oence
record of the..proceedin.gs i_s mad_e~hl~.hhi~ec((~idce does not const tute consent b.y
tu on which the a.pp.e, al ts to be ,b_~.-_.. .....n , , m'ssible or rrelevant evi=ence,
~ he introduction or adm~ss o. of other~.?e ~nad_! .....
C~ty for t .................. aais not omerwise allowed oy ~uw.
~or does it aumonze CI~r'~II~#H~~;;~ v/ dvp
~ accordance with the Americans with Disabilities Act of 1990, persons needing special
accommodation to participate in this proceeding, or to request information on access
..... or to r uest this publ cation in accessib e format, or to request
~ersons w~th d~sa.b hbe.s, eq he ltv Clerk's off ce at (305) 67_3~74_1.1,.,.n,o_
sign language i.nterpre, ters., s..hould co?t~a.._ct_ t.l~-heCiat~dn'' imnaired' contact the City Ule~
later than four c~ays prior to me procee(2,~. ,. ~
office via the Flodda Relay Service numbers, (800) 955-8771 (TYY) or (800) 955-8770
(VOICE). ~ .... o
(Ad #0~8~) "'