INTERNAL AUDIT REPORT 

Operational Audit 
TNC (Lyft, Inc. & Rasier, LLC.) 

April 2017  March 2021 

Issue Date: August 26, 2021 
Report No. 2021-10 & 11

Transportation Network Companies 

TABLE OF CONTENTS 

Executive Summary ........................................................................................................................................... 3 
Background ....................................................................................................................................................... 4 
Audit Scope and Methodology .......................................................................................................................... 5 
Schedule of Findings and Recommendations ................................................................................................... 6 
Appendix A: Risk Ratings ................................................................................................................................... 9 













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Transportation Network Companies 
Executive Summary 
Internal Audit (IA) has completed an audit of Lyft, Inc. and Rasier LLC., referred to as Transportation
Network Company (TNC), for the period April 2017 through March 2021. The audit was performed to
evaluate current processes, systems, and related internal controls to assure compliance with policies,
procedures and contractual obligations governing the TNC's operations. This audit was performed using
both operational and contract compliance procedures. 
On March 31, 2016, the Port entered into a Pilot Program Operating Agreement (Pilot Agreement) with
TNCs. The Pilot Agreement initially required the TNCs to pay a $5 (five) pick-up fee. On November 1,
2017, the fee was changed to $6 (six). Effective January 1, 2021, a new Operating Agreement replaced
the Pilot Agreement and introduced a $2 (two) drop-off fee, in addition to the $6 pick-up fee. 
The Pilot Agreement provided an opportunity for the program to mature into a more permanent system.
Consistent with this evolution, we identified an opportunity that will enhance the internal control
environment related to revenue reporting and the associated payments: 
(Low) A control to assess the accuracy of TNC reported trip data, when it drops below a defined
match rate or threshold, needs to be enhanced. The Port performs observations, traces them to
reports provided by the TNCs and compares the trend month over month. However, no research is
performed to determine the reason for variances. 
This issue is discussed in more detail on page six. 
We extend our appreciation to management and staff of Aviation Business Development, Airport
Landside Operations and Accounting and Financial Reporting teams for their assistance and
cooperation during this audit. 


Glenn Fernandes, CPA 
Director, Internal Audit 



Responsible Management Team 
Jeffrey Brown, Chief Operating Officer, Aviation 
Laurel Dunphy, Director, Airport Operations 
Dawn Hunter, Director, Aviation Commercial Management 
Lance Lyttle, Managing Director, Aviation 
Linda Nelson, Senior Manager, Aviation Finance and Budget 

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Transportation Network Companies 
Background 
The Port entered into a Pilot Program Operating Agreement with TNCs on March 31, 2016 to facilitate
the operation of one or more vehicles to pick-up and deliver passengers at the airport. Under this
Agreement, TNCs were required to pay the Port $5 (five) for every pick-up activity. This rate was
applicable until October 31, 2017. On November 1, 2017, the pick-up trip fee increased to $6 (six). 
On January 1, 2021, a new Operating Agreement was signed and a drop-off fee of $2 (two) was
introduced, in addition to the $6 (six) pick-up fee. It also introduced a drop-off fee reduction if the TNC
can meet electric vehicle (EV) utilization metrics designed to improve the overall environmental
performance. 
During a quality review, Port management identified a drop in the January 2021 EV utilization when
compared to the previous quarter and contacted the affected TNC to review the data more closely. Upon
investigation, they determined that a correction was made to the vehicle make and model (hybrid vs.
hybrid plug-in) and the lower EV utilization was accurate. The TNC revised their fourth quarter 2020 
report, which lowered the EV percentage below the requirement. As a result, this TNC did not qualify for
the reduced drop-off fee they had received. The TNC was immediately invoiced and confirmed they will
be remitting payment.
TNCs connect passengers (riders) and drivers through a mobile application (App). The App has the
functionality to provide the requestor (passenger) with an estimated pick-up time and trip duration and 
manages the payment process. It also provides customers with an opportunity to evaluate the driver.
Drivers can obtain real time trip data to determine how much they have earned. 
A geo-fence has been established around the perimeter of the airport. The geo-fence interacts with the
General Positioning System (GPS) and the TNC App to capture the trip activity. 
To track and review the TNC activity, the Port utilizes two reports: 
A monthly activity report that is submitted by the TNCs and contains information such as vehicle
registration, time stamp, vehicle model, driver ID, vehicle ID, etc. This report is used by the Port for
billing and payments. 
Ground Transportation staff collect observations of vehicles entering the designated pick-up area.
These observations are compared to the TNC monthly reports to establish completeness and
accuracy of the TNCs self-reported monthly trip activity. This could serve as a primary control to
assess the accuracy of self-reported trip data. 
Combined TNC revenues, for the period audited, are reflected below1: 

2017 (Apr - Dec)      2018              2019                 2020              2021 (Jan - Jul) 
$914,987            $4,031,466       $12,973,434         $10,280,640      $8,079,650 


1 Source: Accounting and Financial Reporting 

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Transportation Network Companies 
Audit Scope and Methodology 
We conducted this engagement in accordance with Generally Accepted Government Auditing Standards
and the International Standards for the Professional Practice of Internal Auditing. Those standards
require that we plan and conduct an engagement to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our engagement objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions based on our
engagement objectives. 
The period audited was April 1, 2017 through March 31, 2021 and included the following audit
procedures: 
Internal controls and compliance with significant terms of the Agreement 
Assessed the operators' compliance with contractual/commercial terms of the agreement
including vehicle inspections, credentialling, and trade dress(Uber / Lyft Signage). 
Evaluated operators' compliance with environmental requirements and reviewed any credits
awarded for meeting the environmental key performance indicators (EKPIs). 
Reviewed the TNCs' insurance for compliance with the Operating Agreements. 
Completeness and accuracy of self-reported trip data 
Obtained TNC activity trip data through observations for a sample of dates (total of 126
observations collected on 3 different dates) and established completeness of the data by
comparing operators' monthly reports to the observed data. 
Reconciled the trip activity reported to the Port, to the Port's quality assurance process
conducted by the Business Intelligence team. Determined whether the correct rate was applied. 
Internal billing 
Traced TNC self-reported monthly trip data to internal billing and payment records to validate
timeliness and completeness. 







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Transportation Network Companies 
Schedule of Findings and Recommendations 
1) Rating: Low 

A control to assess the accuracy of TNC reported trip data, when it drops below a defined match
rate or threshold, needs to be enhanced. The Port performs observations, traces them to reports 
provided by the TNCs and compares the trend month over month. However, no research is
performed to determine the reason for variances. 
The Port receives a $6 pick-up fee and a $2 drop-off fee which is tracked by the TNC App that the driver
uses to charge passengers. When the customer is charged using the App, it is captured in a report that
the TNCs then provide to the Port, reflecting the prior months' activity. 
Each month 40 hours of observations are performed by the Ground Transportation (GT) team. The GT
staff observes the customer pick-ups and uses an in-house developed TNC application to capture
information such as the license plate number and time of pick-up. The information is then provided to
the Business Intelligence team who compares the observations to the monthly reports provided by the
TNCs the following month. The following table reflects the match rates between the Port's monthly
counts and those provided by the TNC. 
Date                     Match Rate 
December 2020              90.60% 
January 2021                 92.80% 
February 2021                88.30% 
March 2021                  89.70% 
April 2021                       89.40% 
May 2021                   88.60% 
Our testing included 126 observations of TNC pick-up activity. We matched 121 of these observations. 
We were unable to trace five observations to the TNC report. Three of which, could likely be attributed
to data capture errors on our part. 
The 40 hours of manual observations and identification of variances have the potential to add value and
can be important. However, when no additional efforts are performed to determine the root cause for
the differences and whether corrective measures are necessary, some of the benefits from the manual
observations are diminished. 
Recommendations: 
Internal Audit recognizes the high volume of transactions and the need to rely on technology. However,
we also recognize that technology can sometimes fail and therefore, we recommend that management
should: 
understand the reasons for the variances and adapt processes to minimize these exceptions 
establish a tolerance threshold that would trigger when additional research is needed 
Without researching the variances, technology and manual errors are unknown and could result in
inaccurate reporting and payment. Furthermore, the program relies on external "self-reporting", 
highlighting the need to implement a procedure to determine whether an error has occurred. 

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Transportation Network Companies 
Management Response/Action Plan: 
Aviation Commercial Management staff agrees that implementation of a tolerance threshold, as well as
a procedure to research discrepancies when the threshold is triggered, will further enhance the review
process of the self-reported TNC trip activity. A threshold and process will be developed with a targeted
completion date of the end of October 2021. 
In reference to match rates for vehicles, as identified in the 2017/2018 TNC audit (see Report No. 2017-
22), there are three main reasons explaining why hourly match rates may not be 100%: 
1)  Turnover of TNC vehicles/drivers is very high. New drivers/vehicles are continuously getting
permitted and accessing the Airport for pick-up trips. Many of these new entrants have vehicles
with temporary license plates. When permanent plates arrive and drivers replace the temporary
plates  with  permanent  plates,  TNC  companies  are  often  delayed  in  updating  their
database/systems with the new plate information. When Port GT staff collects real-time trip info
with permanent plate info, yet TNCs report at month-end the temporary plate info, the result is a
"non-match." 
2)  As mentioned, GT staff collects data at random times, and for certain time increments (e.g.- one
hour). Due to the potential time delays associated with GPS data and the real-time systems, data
collected close to the start and finish of time increments can lead to non-matches. An example
would be GT staff collecting data associated with a pick-up at 11:59am, and due to slight data
transfer delays with the TNC systems, at month-end the TNC reports the pick-up time at
12:01pm, leading to a non-match when analyzed by Business Intelligence. 
3)  TNC drivers utilize their application to indicate when they have picked up a passenger. This
information is then sent to the TNCs. Often, drivers will send notification before or after the actual
pick-up (e.g.- a TNC driver may pick up his/her passenger and then several minutes later send
the notification while en-route to the destination). When this occurs, typically it results in a nonmatch.

If vehicle matches are viewed on a daily basis instead of hourly (as presented in this audit report above
for December 2020 through May 2021), a much higher match rate is achieved as shown below: 
DATE            HOURLY MATCH RATE   DAILY MATCH RATE 
December 2020    90.6%                  95.9% 
January 2021      92.8%                    96.9% 
February 2021     88.3%                    96.6% 
March 2021        89.7%                   97.1% 
April 2021           89.4%                      97.5% 
May 2021         88.6%                   99.2% 
In regards to the Audit team's testing of 126 vehicles with five vehicles unable to be matched, Aviation
Commercial Management staff performed additional research on the five and was able to establish
likely matches for three of the five based on the following: 

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Transportation Network Companies 

Two vehicles during the observation time periods had license plates that matched 6 of 7 characters with
the one unmatched character being a character that could easily resemble the reported license plate for
a moving vehicle in a parking garage. 
One vehicle during the observation time period had a license plate not yet in the TNC system.
Only one TNC reported unknown license plate vehicle made an appearance during the
observation period. This is likely explained by the first description of observation rate limitations
discussed in this response. 
Two remaining vehicles were not matched, resulting in a likely observation rate of 98.4% (124 of
126) 

DUE DATE: 10/31/2021 














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Transportation Network Companies 
Appendix A: Risk Ratings 
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only one
of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated Low will be
evaluated and may or may not be reflected in the final report. 
Financial      Internal                                               Commission/
Rating                                   Compliance      Public 
Stewardship  Controls                                         Management 
High probability
Non-compliance
Missing or not                       for external audit   Requires
with Laws, Port
High       Significant     followed                          issues and / or     immediate
Policies, 
negative public     attention 
Contracts 
perception 
Partial              Potential for
Partial controls 
compliance with   external audit
Requires
Medium   Moderate                  Laws, Port       issues and / or
Not functioning                                          attention 
Policies             negative public
effectively 
Contracts          perception 
Functioning as
Low probability
intended but     Mostly complies                       Does not
for external audit
could be        with Laws, Port                       require
Low      Minimal                                   issues and/or
enhanced to    Policies,                            immediate
negative public
improve        Contracts                          attention 
perception 
efficiency 










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