Transit and Micromobility (2021)

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22 Regulatory and Policy Review This chapter examines the policy environment surrounding shared micromobility, including areas of regulation and areas where regulatory approaches are still in flux. Since this report is focused particularly on transit agencies and their interaction with micromobility, a large part of this chapter examines the specific policymaking and regulatory role of public transit agencies. However, public transit agencies generally lack the policymaking or regulatory powers that state or local governments possess, and they achieve their policy goals largely through partner- ships with operators and coordination of goals with regulating agencies. Put another way, cities regulate, while transit agencies partner. For that reason, this chapter begins with an examination of the main levers that jurisdictions—of all types—commonly use to regulate micromobility. The Range of Local Regulatory Approaches Most local enabling statutes and permit requirements for micromobility typically cover some combination of several key regulatory approaches. The Shared-Use Mobility Center’s Micro- mobility Policy Atlas provides summaries of policies in a number of cities in the United States and worldwide for a common set of regulatory fields, and provided much of the documentary basis for this chapter (SUMC/NUMO 2020). Vehicle Location: Operation, Parking, and Geographic Limitations Regulations on vehicle location can govern where in the right-of-way riding is permitted or prohibited (particularly with regard to bike lanes and sidewalks) and where and how vehicles should be parked between rides (including bike rack, corral, and lock-to requirements), and outline broader zones where operation is permitted or prohibited (such as certain paths or geographic areas of a city). Atlanta’s 2018 scooter ordinance, for instance, regulates operation and parking location, with scooter riding prohibited on sidewalks and limited to certain areas of the public way (in city parks, including the Atlanta BeltLine, and in vehicle travel lanes, bike lanes, and shared-use paths throughout the city). Scooters must be parked upright and only at bike racks or against a building or curb, and in a way that provides at least 5 feet of clearance for pedestrians, with a minimum of obstruction. Parking is prohibited in a variety of locations, including at bus stops, at bikeshare stations, or where it obstructs pedestrian or wheelchair access to buildings, public facilities, or accessibility features like ramps and handrails (Atlanta 2018). In many jurisdictions, operation is further limited to specific geographic areas. During Chicago’s 2019 scooter pilot, the city limited operations to a 50-square-mile area on the west and northwest sides of the city (see Figure 12)—about a quarter of the city’s geographic C H A P T E R 2

Regulatory and Policy Review 23   area—excluding downtown business and entertainment districts, heavily populated areas along the lakefront, and several major transit corridors (Chicago 2020a). Two western sections comprising about half of the pilot area were further designated as “priority areas” where the program’s equity requirements were focused. In the city’s 2020 pilot (see Figure 13), the area of permitted operation was expanded to the whole of the city except for the core of downtown, two heavily used mixed-use paths, and O’Hare Airport, with the equity priority area expanded to most of the west and south sides (Chicago 2020b). Operators are generally expected to communicate these geographical limits to riders and, in many cases, to use geofencing to physically disable micromobility vehicles if they enter a prohibited area. Limiting Overall Scale and Impact: Fleet Caps, Utilization Targets, and Provider Counts Many jurisdictions seek to limit the impact of micromobility by placing caps on the number of vehicles that can operate and requiring that deployed units see a minimum level of utilization. Source: Chicago 2020a. Figure 12. Operating area for Chicago’s initial 2019 scooter pilot, limited to the city’s west and northwest sides. The dotted lines delineate the two “priority areas” that were the focus of the program’s equity provisions.

24 Transit and Micromobility Fleet caps can appear as a per-operator cap, a citywide fleet cap, a limitation on the number of permitted operators, or some combination of the three approaches. A number of jurisdic- tions use fleet caps as a central part of a performance-based regulatory approach that aligns operator incentives with public goals. In this approach, operators that meet certain performance requirements (such as hitting vehicle utilization targets, providing vehicles in every part of the city, or demonstrating a commitment to recruiting users or employees from disadvantaged communities) are rewarded with higher fleet caps, lower fees, or other incentives that help them reduce operating costs and boost potential margins. Source: Chicago 2020b. Figure 13. Expanded operating area for Chicago’s 2020 scooter pilot, with exclusion areas overlaid in red and the equity priority area outlined in blue.

Regulatory and Policy Review 25   Utilization targets, usually expressed as an operator’s fleet-wide average trips or rides per vehicle per day (rvd), can help ensure that the right number of vehicles are deployed, with jurisdictions ideally adjusting fleet caps to reflect market signals: raising caps as growing utilization demonstrates sufficient demand or reducing them if low utilization suggests that too many vehicles are on the street. The ideal target range is still being established and likely depends on the specific market characteristics, but a number of jurisdictions seem to have settled on 3 rvd as the threshold for fleet cap increases. For example, the Austin Transportation Department’s 2018 Rules for Dockless Units use fleet caps and utilization requirements to address a number of public goals: starting from an initial cap of 500 units per operator, the transportation director can award increases of 250 vehicles for each additional 5-square-mile area (outside of downtown) that an operator services, as long as each additional area maintains a minimum utilization level of 3 rvd (Austin Transportation Department 2018). An examination by the research team of more than a dozen shared-scooter pilots from 2018 to 2019 found typical actual utilization rates clustered between 2 and 4 rvd. This accords with analysis by NACTO, which found that for scooters, smaller systems tended to have higher utili- zation than larger systems (4 and 2.6 rvd, respectively, for fleets below and above 2,500 vehicles), while the inverse was true for bikeshare, in which utilization rose from less than 1 to around 3 rvd as fleets grew over 2,500 (NACTO 2020). Rider and Public Safety While much of the micromobility regulatory regime touches incidentally on safety, especially those regulations focused on locations of operation, several areas of regulation do so more explicitly. The most clearly safety-focused areas common to local regulations center on: • Speed limits, • Vehicle requirements [generally ISO 43.150/4210-1 (ISO 43.150 sec. 4210, 2014), federal consumer regulations (16 CFR §1512.2), or state standards for bikes or personal e-mobility vehicles], • Helmet use, • Rider age restrictions/license requirements, and • Hours of operation and curfews. Washington, D.C.’s 2020 shared-scooter permit agreement touches on nearly all these points, setting a 10 mph speed limit (less in specific areas) enforced by a speed governor, requiring that vehicles meet applicable international and federal vehicle standards, encouraging provision of free helmets, and requiring operators to inform users of local regulations on age restrictions and hours of operation (addressed elsewhere in local code or user agreements) [District Depart- ment of Transportation (DDOT) 2019a]. Santa Monica provides similar rules, and in addition to setting a minimum age of 16 years for shared bikes and scooters, requires scooter users to hold a valid driver’s license or learner’s permit (Santa Monica 2020). In a scan of some 30 U.S. policies collected in SUMC’s Micromobility Policy Atlas (SUMC/ NUMO 2020), operation by riders under the influence of drugs or alcohol appears to be rarely addressed in local regulations, which tend to focus on the providers’ responsibilities, although substance-impaired operation and other facets of safety are generally also part of the terms of the private operators’ own user agreements (Bird and Lime user agreements 2021). However, a number of cities do list intoxicated operation among the prohibitions in informal guidelines provided to users (Tampa 2020; Chicago 2020c).

26 Transit and Micromobility Operator Responsibilities: Parking Enforcement, Rebalancing, Maintenance, and Communications Many jurisdictions place the onus of regulatory enforcement on private operators, outlining regulations dependent on user behavior, such as parking and permitted locations for riding, as well as regulations more centered on fleet operations, such as rebalancing, vehicle maintenance, and outreach to and communications with users. In the case of user behavior, especially around vehicle parking, operators often pass fines or penalties through to the responsible riders under their user agreements. In order to encourage compliance and create a clearer chain of custody for vehicles that can be easily moved, some jurisdictions and many operators require users to photograph their legally parked, upright vehicle at the end of a ride (Bird, Lime, and Skinny Labs/Spin user agreements 2021; Chicago 2019a). Parking regulations and transit access. Some local policies recognize that micromobility vehicles will be used for transit access and include provisions that encourage positioning of vehicles near transit stops and also discourage blocking access or pileups of vehicles around transit stops. Denver’s collaboration between the city’s public works department and the Regional Transportation District (discussed as a case study in Chapter 5: Agency-Micromobility Partner- ship Approaches) is an example of this kind of policy applied on a regional scale. Rebalancing constitutes the regular repositioning of vehicles throughout a service area and is a common mechanism for meeting equity goals as well as for placement near transit assets. For instance, in Chicago’s scooter pilots, operators were required to deploy at least half of their devices to the south and west side “priority areas” daily (described previously), while many of those vehicles tended to end the day in more centrally located (and more affluent) commercial and entertainment districts (Chicago 2020a; Chicago 2020b). Without rebalancing require- ments, those more affluent areas are where the majority of the fleets would likely stay over time. Rebalancing is also central to fleet operations, providing the opportunity to charge, clean, and inspect vehicles, as well as to pull any that are malfunctioning or due for maintenance. Rebalancing and maintenance provisions may set required intervals for inspection and time limits (usually on the order of hours) for addressing inoperable, abandoned, or improperly located vehicles. Communications requirements commonly cover: • Identification and contact information on the vehicles themselves; • The ways operators notify users of rules, regulations, and other information (e.g., through pre-ride tutorials and in-app notifications); • Customer support requirements as well as means for receiving and handling complaints from the public; • Launch, marketing, and outreach plans, often targeting specific communities or popula- tions; and • Communication (other than data-sharing requirements) with regulators or other agency staff (e.g., activity reporting, coordination meetings). Social Equity Considerations: Geographic Distribution and Access for the Unbanked or People Without Smartphones Many agencies incorporate equity requirements in their micromobility regulations, most commonly to ensure geographical distribution of vehicles throughout a jurisdiction (so that they are readily available to people of all income levels and not concentrated only in commercial areas or higher-income districts) and to provide access for users without mobile phones or for those who are unbanked.

Regulatory and Policy Review 27   Geographical equity approaches may be enforced through a combination of increased fleet caps for better performance and reduced fleet caps or even fines for subpar performance or noncompliance. Each operator is commonly required to submit an equity plan detailing its approach. Denver’s 2018 micromobility pilot set initial fleet caps of 400 dockless bikes and 250 scooters per operator but raised the caps by 100 vehicles if the additional vehicles were located in “opportunity areas” (including a subset of “high priority opportunity areas” where the most vulnerable populations are located) during daily rebalancing (Denver 2018). It also required operators to file equity plans “outlining how their services will be available to those without smartphones or those who are under-banked or un-banked” (Denver 2018), as well as to outline rate structures and discount programs for specific populations. Most major micromobility providers offer company-wide equity programs, which are often available even in areas where they are not explicitly required, and several have programs that allow unbanked users to load accounts using cash at retail locations or use prepaid debit cards (Chicago 2019b). Access to discount programs is often tied to enrollment in a means-tested public assistance program such as SNAP, Medicaid, or HUD Section 8. Access for people without smartphones or mobile data plans can generally be accomplished by using short message service (SMS) or voice calls to unlock and lock vehicles and accomplish other account functions. While these allow users without smartphones to use the services, they still generally require a mobile phone of some kind in order to use SMS or call from a verified number at both ends of a ride, thus excluding people with no mobile phone at all. Data-Sharing Requirements and Standards/Specifications Public agencies typically seek some level of data reporting from micromobility providers operating in their jurisdictions. These can range from periodic ridership summaries to near– real-time records and GPS traces of individual vehicles, and can also include user surveys and information on other aspects of program participation. These data may serve a variety of purposes, including identifying trends in transportation and patterns of use of various services, service planning, monitoring operational delivery, accounting and auditing (especially in the case of subsidized services), and regulatory compli- ance (including establishment and enforcement of geofenced areas) (Gururaja and Faust 2019). Even if most of these data are ultimately drawn from trip- or vehicle-level records, each of these tasks is best accomplished using data with varying levels of granularity, aggregation, timing, and frequency. Two major data standards have emerged for the collection, management, and distribution of micromobility data. The General Bikeshare Feed Specification (GBFS) and the MDS both provide standard data definitions and methods for data to be shared between providers and jurisdictions. GBFS is the open-data standard for bikeshare and was originally developed under the leader- ship of the North American Bikeshare Association (NABSA), along with public, private-sector, and nonprofit bikeshare system operators (NABSA 2019). Derived from the General Transit Feed Specification (GTFS) at the heart of many transit trip-planning tools, GBFS takes real-time service availability data (such as vehicle and dock location and status) from micro mobility systems and makes these data publicly available online. GBFS data allow individuals to see the current status of micromobility vehicles, and because of GBFS’s similarity to GTFS, it can also easily be adapted to be displayed alongside transit information in a variety of ways, such as through mobile applications, display boards, or websites. It does not include historical

28 Transit and Micromobility information (although this can be derived from it) nor can it communicate information about paths of travel. Effective use of GBFS can increase the integration between micromobility and public transit, allowing agencies to take advantage of micromobility’s transit-supportive qualities. GBFS is a one-way standard, providing a means only for operators to broadcast their service availability but no way for jurisdictions or users to communicate back to operators. MDS, originally created by LADOT, is a more complex two-way standard with goals to “provide a standardized way for municipalities or other regulatory agencies to ingest, compare, and analyze data from mobility service providers, and to give municipalities the ability to express regulation in machine-readable formats” [Open Mobility Foundation (OMF) 2019a]. MDS was widely adopted and is currently being used by more than 50 cities across the United States to manage micromobility services (OMF 2019b). Unlike GBFS, MDS includes path-of-travel information and enables two-way communication between city and vendor. As such, MDS enables compliance tracking, digital enforcement, and data-driven infrastructure planning. However, its provision of trip-level data to public agencies has also raised privacy concerns, both from vendors and privacy advocates, and by 2020 it was the subject of litigation in Los Angeles and elsewhere (Hawkins 2020). (This is explored in more detail in Appendix B: Digital Policy and Compliance.) Many local policies specify that data provided to the jurisdiction must use one or both of these standards, while others simply state that micromobility operators must provide an unspecified application programming interface (API) for sharing data or use a data portal or API provided by the city. Several jurisdictions designate third-party services or apps to ingest and process micromobility data, and some require that mobility providers work with the data aggregator, trip planner, or ticketing vendor of their choice as a condition of their operating permit. Risk Management Permit programs commonly require operators to carry property damage and personal liability coverage in amounts of $1 million to $2 million or more. Many jurisdictions also require vendors to post performance bonds to ensure payment of fees and regulatory actions. The Transit Agency’s Regulatory Role DOTs and transit agencies differ in tools available to them: as stated before, cities regulate, while transit agencies partner. Many of the key policy and regulatory mechanisms described in the previous sections sit outside the control of transit agencies and are instead located with local and, occasionally, state governments. Transit agencies’ key policy areas of interest include safe station access, risk management, digital policy and data sharing, fare integration, and equitable access. This section explores the transit agency’s role in the regulatory landscape and examines strategies for aligning local policy with agency priorities. Defining Transit Agency Interests in Shared Micromobility City DOTs and transit agencies have different roles, responsibilities, and interests when it comes to shared micromobility operations. Similarly, city DOTs and transit agencies differ in the fundamental tools available to them to achieve their interests. While cities have regula- tory authority over micromobility operators, transit agencies primarily influence micromobility operations and outcomes through partnerships with cities, vendors, or other local partners.

Regulatory and Policy Review 29   Through these partnerships, transit agencies seek to: • Enhance transit access and increase ridership – Transit agencies and cities are both concerned about safe and efficient access to transit stops to foster first- and last- mile micro- mobility access. • Support cities in managing network demand – Micromobility is one of many demand- management tools that engender mode shift. Micromobility can substitute short trips via driving alone or ride hailing, particularly in medium-to-high-density settings. Shared micro- mobility pilot evaluations in Santa Monica (Santa Monica 2019a), Portland [Portland Bureau of Transportation (PBOT) 2019], and Chicago (Chicago 2020a) found that between a third and one-half of trips would have otherwise been made by driving, ride hailing, or taxis. This diversion of car trips is also supported by the Populus Groundtruth survey data described later in this report. Likewise, access to shared micromobility can alleviate demand for bringing personal bikes and scooters onto transit vehicles, a strategy that many transit agencies like Caltrain in the Bay Area seek to increase in-vehicle capacity. Shared micromobility’s poten- tial to shift peak-period trips, alleviate transit crowding, or reduce delays deserves further research. • Make informed service and infrastructure decisions with mobility data – City DOTs can require that micromobility providers share trip and vehicle status data, can set standards around how those data are structured and shared, and can influence whether the data can be shared with third parties such as transit agency partners. Transit agencies have interests in micromobility data for their ability to help them identify priority locations for micromobility infrastructure, identify transit service gaps, and evaluate whether agency partnerships meet program goals. Policy Areas and the Role of Transit Agencies Transit agencies and city DOTs have different roles in achieving their common policy objectives of enhancing transit access and ridership, managing network demand, and making informed service and infrastructure decisions. While city DOTs regulate and permit shared micromobility services, transit agencies’ primary role is partnership, marketing services to reinforce first- and last-mile opportunities, and providing real estate to accommodate short- term device storage. Table 2 identifies key policy areas where cities and transit agencies have an interest in micromobility outcomes and identifies each entity’s role in ensuring those outcomes. Micromobility and the Built Environment As major mobility destinations and transfer points, transit stations and stops are natural centers of micromobility activity, including activity related to personal bikes and other small devices, docked bikeshare, and shared dockless services. Data from docked and dockless systems demonstrate this nexus through the number of trip starts and ends and targeted deployment activity near transit services (Lime 2019; Clewlow 2019a). Historically, transit agencies have implemented and managed bicycle parking on their property and coordinated with other government partners on the siting of station-based bikeshare on their property and bicycle parking nearby. Agencies saw benefits with this approach; studies have found that over 50% of docked bike users frequently link bikeshare and transit trips (NACTO 2016). The evolution and growth of shared micromobility services into private dockless models increases the need for coordination between transit agencies and cities. What can transit agen- cies do on their own, and what is the role of their municipal partners in ensuring the safe and seamless experience of transit and micromobility? By taking a more active role in the develop- ment and management of micromobility systems in collaboration with their municipal partners,

Key Policy Areas (Mutual City/Transit Agency Interest) City DOT Roles Transit Agency Roles Transit Agency Interests Enhance Access and Increase Ridership Support Cities in Managing Network Demand Inform Service and Infrastructure Decisions and Evaluate Partnerships Safe access at stations Parking organization and wayside support • Install bike racks and designated micromobility corrals on city right- of-way • Regulate and ensure compliance through digital policy that micromobility devices cannot be parked in places that block pedestrian right-of-way and transit access (e.g., through geofencing) • Install bike racks or corrals on transit agency property • Partner with cities to install the infrastructure to facilitate first- /last-mile travel to transit stops and stations, and keep personal micromobility devices off transit vehicles Safe access to stations First-/last-mile infrastructure • Install protected bike infrastructure • Regulate micromobility vehicle speeds through speed throttling and geofenced zones where devices are not allowed to be ridden, parked, or deployed • Audit vehicle quality and ensure compliance with safety regulations • Partner with vendors on educational campaigns • Implement building of micromobility infrastructure such as bike lanes, racks, and corrals • Use vendor-shared data to inform priority infrastructure investments • Partner with cities to identify conflict areas with transit for targeting separated bike infrastructure or routing on parallel facilities • Partner with cities and vendors on educational campaigns • Fund and implement micromobility infrastructure on agency property • Maintain wayfinding for users to find designated areas where micromobility devices can be picked up and parked Table 2. City DOT and transit agency policy roles in key areas of regulatory interest.

Digital policy and data sharing • Adopt common data specifications (e.g., GBFS and MDS) • Require the use of data specifications to enable operational restrictions and associated digital compliance and enforcement • Establish data-sharing agreements with transit agencies and vendors • Require geofencing of certain areas to meet safety, saturation, and sensible deployment objectives • Establish and digitally enforce static or dynamic device caps • Set data-sharing requirements in micromobility operating permit • Ensure that contracted or internal data platforms can ingest, store, and protect sensitive mobility data • Ensure that data can be shared with transit agency partners • Establish data-access agreements with cities • Communicate agency data needs related to micromobility and establish data use agreements • Partner with cities to geofence transit conflict areas and supply transit facilities with enough micromobility devices while minimizing oversaturating • Ensure that cities can share data with agencies for planning purposes and that this is built into any permit program App/fare integration • Require or incentivize sharing real- time vehicle availability in mobility as a service or other multimodal trip-planning applications • Require or incentivize integrated fare payments in coordination with vendors • Work with cities and providers toward API integration for multimodal trip planning • Work toward digital fare integration in partnership with vendors (continued on next page)

Key Policy Areas (Mutual City/Transit Agency Interest) City DOT Roles Transit Agency Roles Transit Agency Interests Enhance Access and Increase Ridership Support Cities in Managing Network Demand Inform Service and Infrastructure Decisions and Evaluate Partnerships Enforcement and compliance • Establish compliance thresholds and enforcement actions for noncompliance (e.g., reductions in fleet size, fines, permit suspension, or revocation) • Set incentives or penalties for vendor compliance and market entry • Track and respond to improper parking complaints • Audit vendors for compliance with deployment, distribution, customer service/311 responsiveness, and parking requirements • Coordinate with cities to establish parking and deployment standards at or near transit agency property • Partner with cities to audit and enforce standards • Partner with cities to ensure regulatory penalties for improper micromobility parking or riding at stations and stops Risk management and insurance • Require a certain level of insurance from private operators before allowing legal operations • Partner with cities to ensure that safety risks on transit property are accounted for within city regulations Note: Establishing separate transit-specific insurance requirements for vendors will limit partnership opportunities. Table 2. (Continued).

Market incentives • Set incentives (e.g., fleet cap increases, service area expansion, fee reductions) for meeting or exceeding policy goals • Ensure that regulations are not so onerous that they generate disinterest in a market • Partner with vendors on station- area operations and policy goals on transit access/connection • With future digital fare integration, there is potential to provide user subsidies for micromobility services as an extension of the transit system Equity • Ensure equitable distribution of micromobility devices through permit requirements • Require operators to develop low- income and accessible device programs to increase equitable access and reduce cost burden • Partner with operators or community organizations to provide equitable access and educational programs • Ensure that equitable access programs consider access to and from transit, enhance multimodal connections, and prioritize areas with service gaps • Combine reduced-fare programs with micromobility low-income programs to establish integrated mobility programs Program funding and revenue • Set permit fees and fines to cover program administration, system management, enforcement administration, staffing needs, and other needs that meet the fee nexus • Possibly contribute financial or in-kind resources to cities to better operate and manage micromobility programs Customer service • Require a certain level of vendor responsiveness to customer service complaints (e.g., address sidewalk obstructions within 2 hours of customer complaint) • Require 311 integration to automatically route customer service requests to vendors • Rely on station agents to file complaints for vendor noncompliance on transit property

34 Transit and Micromobility transit agencies can ensure that these services meet agency and city goals. There are five key areas in which this built-environment coordination takes place: • Transit access and parking • Street management and first/last mile • Demand management • Data (and its relationship to the built environment) • Infrastructure funding The relationship between micromobility and the built environment is changing as the adoption of both docked and dockless micromobility services grows. This section explores the extent to which new micromobility services have increased the need for new infrastructure as well as the different roles for cities and transit agencies in managing the built environment. This section synthesizes key themes from existing city and transit-agency policy frameworks, pilots, and permitting programs that are contending with the challenges presented for the built environment given the growth of micromobility services. The section is organized around five key areas in which micromobility impacts on the built environment can be seen and is supported with case studies from around the United States, as well as primary sources that include existing bikeshare station siting guidance applicable to dockless micromobility infrastructure design and publicly available information regarding transit agency involvement in micromobility planning and regulation. Additionally, important insights are sourced from the 2019 Dockless Mobility Summit, which took place in Santa Monica, CA, in October 2019. The summit brought together representatives from 17 cities and institutions across the United States. (The summit included representatives from the following jurisdictions and institutions: Anaheim, CA; Atlanta, GA; Beverly Hills, CA; Culver City, CA; Denver, CO; Detroit, MI; Long Beach, CA; Los Angeles, CA; Minneapolis, MN; Oakland, CA; Portland, OR; San Francisco, CA; San Jose, CA; Santa Monica, CA; Seattle, WA; University of California, Los Angeles; and Washington, D.C.) The summit was convened with the goal of helping cities think through the big questions about dockless mobility and venture- backed mobility models and had a strong focus on experiences and insights from municipal regulatory and right-of-way management efforts. Built Environment Challenges The tools to manage the interface between transit and micromobility are in flux. As managers of public rights-of-way, cities are the entities primarily leading the development of pilots and permitting programs for dockless micromobility. Cities have quickly progressed in their approaches in the several years since the major expansion of these services across the United States, but even they are still in a cycle of experiment-evaluate-iterate. On the other hand, transit agencies are primarily concerned with the operation and manage- ment of the transit network and, as such, have been less actively involved in partnering with micromobility companies and have had a limited role in their regulation. This section out- lines some of the key challenges that emerge specifically for transit agencies given the state of practice today. Transit Access and Parking Transit agencies and cities seek to balance safe and convenient micromobility parking locations without impeding safe and efficient pedestrian movement. Micromobility device parking is also important because transit vehicles have capacity constraints for bicycles and micromobility devices carried inside buses/trains or on vehicle-mounted racks, limiting the

Regulatory and Policy Review 35   maneuverability of these devices within a transit system and increasing the need for adequate device parking at stops and stations. Street/Sidewalk Management and First/Last Mile Transit agencies and local governments are concerned about the design and management of streets and sidewalks given the rise in use of micromobility devices. Cities and transit agencies alike share this concern for ensuring safe rights-of-way for all street users and for people of all abilities. Cities’ regulations address specific challenges around sidewalk access manage- ment, especially for people with disabilities. Transit agencies also have concerns for ensuring Americans with Disabilities Act (ADA) compliance and safe pedestrian access within stations and stops and along streets feeding into stations, but they may have limited ability to address these concerns on property they do not directly control. Additionally, micromobility devices have the potential to provide first-/last-mile access for individuals using the public transporta- tion system. Agencies can also incentivize and encourage the use of these devices by pursuing policies and partnerships that make the built environment around stations safe and comfortable access points. Demand Management Micromobility is a potential demand-management tool in congested areas and a comple- mentary mode for transit systems. For example, some cities’ early evaluation reports suggested that shared micromobility was supporting shifts away from car travel (Santa Monica 2019a; PBOT 2019). However, the full potential of shared micromobility to manage demand has not yet been realized due, in part, to existing built-environment factors and a lack of integrated operations. Data Relationship to the Built Environment In most cases, cities regulate dockless micromobility services. Cities determine whether to require these services to share data, how the data are structured and shared, and whether the data can be shared with third parties such as their transit agency partners. In order to make informed decisions about micromobility infrastructure and the expansion of equitable access, transit agency staff need data at a fine geographic level on transit customers’ use of and reliance on micromobility services. Infrastructure Funding The private and public sectors have shared interests in the provision of safe and accessible on- and off-street infrastructure. While some hope the private sector can, on its own, provide a funding source for micromobility network investments or parking provisions, there is a lack of evidence that this approach is feasible or sustainable. Some cities are testing new revenue mechanisms—such as fees per trip, fees per daily vehicle mileage, or varying rates depending on location—but they are aware that private operators need to operate these services profitably in order for them to be sustained, so a balance must be struck (Santa Monica 2019b). However, micromobility companies can support infrastructure investment in other ways besides directly providing financial resources, such as by activating constituencies to advocate for micromobility infrastructure or by organizing pilots and demonstration projects. Emerging Responses and Findings Transit Access and Parking With the increase of micromobility vehicles in and around transit stations and stops, agencies are reacting to specific infrastructure needs such as for parking, locking, and charging. But

36 Transit and Micromobility transit agencies and cities are also proactive in coordinating and organizing around designated parking areas and mobility hubs. Agencies have leveraged physical and digital tools to manage the capacity, parking, and infrastructure demands of these services. These tools include: • Mobility hubs, • Formal and designated micromobility parking corrals, • Geofencing technology (i.e., using the mobile app to disallow micromobility operation or parking in specified areas), and • Fleet and operations management partnerships. Mobility Hubs. As an organizing concept for all mobility services in a marketplace, mobility hubs provide a natural framework for coordination between cities and transit agencies looking to organize micromobility parking and transit access. The mobility hub concept is a relatively new framework for mobility coordination at the physical level. For the purposes of this document, a mobility hub is the intentional colocation of two or more publicly accessible travel modes within a public space or facility and complemented by information/services such as wayfinding and placemaking elements to make these options broadly useful and accessible. It can also include digital integration of those travel modes and may feature safe bike and scooter parking and curb space dedicated to shared-ride providers (Feigon et al. 2018). More evaluation is needed to understand the effectiveness of mobility hubs at achieving various goals, which could include mode shift, greenhouse gas reduction, economic and community development, and an improved customer experience. Mobility hubs have been built at neighborhood to regionally oriented scales in several European cities, including cities in Germany, Austria, Switzerland, and Italy (Feigon et al. 2018). Though the mobility hub concept is still in the early stages in the United States, one inter- national example illustrates the potential effectiveness of the intentional colocation of mobility services: Bremen, Germany’s Mobil.Punkt mobility hubs. In 2003, the city started expanding its multimodal coordination strategy and set specific objectives for its mobility hub program, including to remove 6,000 cars from its streets by 2020, to enroll 20,000 people in various carsharing programs, and to reclaim 30 linear kilometers of curbside road space from parking (Hurley 2014). The most important achievement of the program was a reduction in private car ownership. Estimates from the European Union were that the carshare component of the mobility hub program had reduced demand for on-street parking by about 5,000 private vehicles (Team Red 2018). For more recently implemented examples in U.S. cities, including Minneapolis and Los Angeles, outcome data are not yet available, particularly related to transit agencies’ interest in micromobility. The infrastructure needs of micromobility services—and the elements provided by a mobility hub—differ depending on the transit context (e.g., bus stops, light-rail stations, and regional/ commuter rail hubs). These parking and access infrastructure needs include: • Demarcated parking areas or corrals located close to transit services but out of the way of the flow of pedestrian traffic, • Electric scooter and bike charging facilities (particularly to support hybrid docked/dockless models), and • Traditional bike racks and other lock-to infrastructure. Transit agencies have the authority to site and provide this infrastructure on their property, and they work in partnership with cities on access infrastructure around their stations, whether as part of a formal mobility hub or not. As such, transit agencies can play a direct role in determining the seamlessness of the mobility experience and the protection of right-of-way for other transit customers.

Regulatory and Policy Review 37   Santa Monica’s experience demonstrates an example of designated micromobility parking areas in locations across the city, including several near transit. The city designated 107 micro- mobility parking areas at on- and off-street locations during its dockless mobility pilot. They were intended to provide locations for riders to park micromobility devices without obstructing sidewalks, ADA access, and pedestrian access to transit stations and stops. Additionally, micro- mobility operators were required to encourage riders to end trips in these designated parking spaces through incentives, such as discounted pricing and monthly raffles for free rides. How- ever, the city’s 2019 evaluation found that only 0.08% of rides ended in these designated areas. Santa Monica took the lessons learned from its 2019 pilot to increase the efficacy of designated parking areas with better education, in-app signals, parking incentives/disincentives, and more designated parking spaces (Santa Monica 2019a, 30). Transit agencies can also form partnerships with jurisdictions to plan, build, and operate a system of mobility hubs. Mobility hubs colocate micromobility and other shared mobility services, community amenities, and electric mobility charging infrastructure, among other features, at rail stations and high-frequency bus stops. In Minneapolis, Metro Transit has collaborated with the city of Minneapolis, Hennepin County, mobility service providers, and neighborhood organizations to pilot a mobility hub program. These mobility hubs are intended to not only enhance first- and last-mile connections, but also to serve as centers of placemaking for residents to gather and learn about new ways to travel in the city (Gray 2019). Transit Agencies’ Shifting Role in Managing Personal and Shared Micromobility Is Supported by Existing Siting Guidance. Transit agencies have actively managed docked bike- share and personally owned micromobility (e.g., bike lockers, racks, and corrals) storage for decades because of the natural use of these modes for transit access. In cities with high transit ridership, 50% of docked bikeshare users linked their bike and transit trips (NACTO 2016). This study’s data explore the linkages between transit and micromobility trips (see Chapter 3), and this has been established by a number of other studies as well. Among dockless systems, the proportion of trips that start or end at transit stations varies, but data suggest a similar linkage. Santa Monica found that 4% of all trips were used to access its Expo Line Downtown station (Santa Monica 2019b), and Denver found that 56% of scooter riders used the scooters to access transit at least occasionally (Denver 2019a). According to Lime’s 2018 Year-End Report, 20% of Lime riders in major urban markets worldwide reported traveling to or from public transit during their most recent trip (Lime 2019). Given the natural relationship between micromobility (docked, dockless, shared, or person- ally owned) and transit, much of the existing guidance on how to design physical, designated micromobility parking or docking areas within transit stations still applies. The NACTO Bike Share Station Siting Guide (NACTO 2016) collects the best practices from around the United States concerning the siting of bikesharing stations and discusses the different street typologies for siting, such as curbside, parking lanes, sidewalks, and open spaces. According to NACTO’s research, bikesharing and transit are linked, and it suggests practitioners site stations as close to transit stations as possible (NACTO 2016). However, high-ridership transit stations and stops are also locations with high volumes of pedestrians, and practitioners should make sure pedestrian access to transit is not degraded. The Bay Area Rapid Transit (BART) board in the San Francisco Bay area played an active role in the siting of Bay Wheels bikeshare stations at BART stations during a system expan- sion in 2018. This example illuminates the impact of community input on siting decisions and applies to the management and siting of docked and dockless systems. In meetings, the board balanced input from local community and bicycle advocacy groups about the specific locations of stations. Some community groups view bikesharing as a symbol of gentrification. At its 24th and Mission station, for example, the BART board directed staff to locate a bikeshare station

38 Transit and Micromobility at a nearby library instead of directly in a plaza due to gentrification concerns raised by local advocates (Rudick 2019). The guidance for the siting of station-based bikeshare discussed in the NACTO Bike Share Station Siting Guide can also be applicable when thinking about both protecting and enhancing pedestrian right-of-way for the siting of designated areas for dockless micromobility devices. Best practice when placing a bikeshare station on a sidewalk is to leave at least 6 feet of clear- ance for the pedestrian right-of-way, with more recommended at locations with high pedestrian volumes. The same clearance rules should apply to designated dockless device parking areas; when 6 feet of clearance isn’t possible, on-street configurations should be considered. Bike- share station siting can also help enhance the pedestrian realm by operating as traffic calming tools and increasing pedestrian visibility at intersections (NACTO 2016). However, designated dockless micromobility parking areas usually do not have the same large, fixed elements (e.g., advertisement boards, information and payment kiosks) as bikeshare stations, so additional permanent and highly visible elements could be considered to help those areas reach the same traffic calming potential. In fact, in some cities, such as Austin (Bliss 2019a); Washington, D.C. (Lazo 2019); Arlington, VA (Bliss 2019a); Tampa (De Jesus 2019); and Ann Arbor (Afana 2019), micromobility docking stations for otherwise dockless services are already being tested. Cities and Transit Agencies Are Starting to Coordinate on Access and Parking Policies Unique to Dockless Models. Instead of developing their own permitting programs and policies, transit agencies can partner with local jurisdictions and co-develop mutually beneficial permit conditions that incentivize rebalancing (the regular redistribution of vehicles to areas preferred by the agency) and operational excellence in exchange for vendor bonuses. Important vendor incentives include performance-based fleet cap increases and relaxed permit fees. The regulating jurisdiction or agency initially sets a cap on the number of vehicles a vendor can operate, but that cap can increase if the vendor exhibits desired behavior such as distributing vehicles in underserved communities or providing parking locations. For example, Oklahoma City’s EMBARK (formerly Metro Transit) partnered with the city of Oklahoma City (Oklahoma City 2018); both were seeking to increase first- and last-mile connections to transit by offering micromobility operators incentives related to fleet size and agency property parking space. Operators can apply for higher fleet caps if they work with the transit agency to provide vehicle parking locations (including some form of physical parking zone or digital geofence restricting parking to specific areas) and ensure that pedestrian and bicycle access to stations is not impeded. Increases in fleet size are approved jointly by the city and the transit agency (Brus 2019). Los Angeles County Metropolitan Transportation Authority (LA Metro) plans to go one step further in its micromobility vehicles pilot program for vehicles parked or operated on its property. In July 2019, LA Metro adopted a 2-year micromobility vehicle pilot program, with the goals of ensuring safe access for transit patrons in and around stations, developing an organized micromobility parking system, and providing equitable access to micromobility vehicles. Through the program’s license agreements, LA Metro requires that participating micro- mobility operators be approved to operate in the local jurisdiction where a given LA Metro property is located and pay a fee per parking space on agency property prior to any deployments or vehicle storage on LA Metro property, parking facilities, or right-of-way. Vehicles must be parked upright in designated parking zones, and any incorrectly parked vehicles must be addressed within 2 hours. ADA violations (parking in ADA spaces or blocking access to them) are strictly prohibited (LA Metro 2019a). Though it was adopted by the board in July 2019, as of spring 2020 the program had yet to be launched; it is unclear whether micromobility operators will participate in the program to gain a competitive advantage or if customer parking and operator deployment will spill over onto city right-of-way.

Regulatory and Policy Review 39   Some agencies are going beyond regulatory approaches and directly partnering with micro- mobility operators. The Greater Dayton Regional Transit Authority (RTA) partnered with e-scooter sharing operator Spin to provide service in the city, building on an earlier docked bikeshare partnership with similar parameters. This partnership and the process leading to it are described at greater length later in the report. A partnership negotiated between Big Blue Bus, the city of Santa Monica, and Lyft includes geofencing prohibited areas (i.e., using the app to disallow micromobility vehicle parking in certain areas) and targeted rebalancing around transit stations. Lyft offers a dollar discount to users who park in a designated “Transit Zone” (Lyft 2018). Transit agencies are wary of crowding and liability associated with bringing micromobility devices on board transit vehicles. Shared micromobility, which is regulated and permitted by transit agencies’ municipal partners, can alleviate some of that pressure. While transit agencies such as BART and Caltrain promote shared dockless micromobility as an enhancement to first- and last-mile connectivity, the vehicles themselves are for the most part forbidden from platforms and trains (Skinny Labs/Spin 2020). Personal bikes and (folded) scooters are allowed on Caltrain cars in limited numbers; BART allows access at all times except for in the first car, but peak-hour trips often do not have capacity for micromobility devices on trains (Caltrain 2019a; BART 2019). Street/Sidewalk Management and the First/Last Mile Transit agencies, which have traditionally focused on providing reliable bus and rail services, are increasingly positioning themselves as mobility agencies. Agencies’ newfound focus on bridging travel needs with mobility choices resulted in a vested interest in supporting and encouraging multimodal access to stations and stops. In fulfilling this role, transit agencies need to coordinate with their city partners on built-environment investments outside agency property. Together, cities and transit agencies are responsible for the safe, convenient, and comfortable multimodal movement of people. The rapid growth of dockless micromobility services, coupled with the new ways these services interact with the built environment, heighten the need for city/ transit agency coordination. Transit agencies concerned with how riders access transit have had to react to an increase in infrastructure needs related to micromobility services (such as more bike lanes and protected infrastructure). Similarly, agencies are grappling with conflicts between transit vehicles, boarding and alighting passengers, and parked/in use micromobility vehicles. Cities’ Requirements for the Equitable Distribution of Micromobility Devices Illumi- nate Gaps in Protected On-Street Infrastructure and Cities’ Overall Accessibility. Transit Agencies Can Be Partners in Addressing These Inequalities. Though it does not identify specific cases of cities investing new or expanded protected bike lanes resulting from the growth of shared micromobility services, Transportation for America’s Shared Micromobility Playbook recommends the following (Transportation for America 2019): Cities should be clear with companies and users about where these vehicles should be operated. As most active transportation and micromobility riders are vulnerable road users, it will be important to designate safe spaces for their operations. Cities will also need to check that their choices aren’t in conflict with their state’s law governing these vehicle types. The rapid popularity and proliferation of micromobility services offers cities an opportunity to dedicate greater lane space and create protected spaces for micromobility and active transportation users. Cities should strive to open as many spaces as reasonably possible to micromobility and create a consistent culture for where and how these vehicles may be operated. Cities are regulating shared dockless scooters and bicycles to advance racial and social equity outcomes, but those efforts are not always coordinated with infrastructure planning and

40 Transit and Micromobility implementation. Washington, D.C., requires every company to deploy at least 400 dockless vehicles (approximately 52% of the total fleet) in “Equity Emphasis Areas” (DDOT 2019a and 2019b; Metropolitan Washington Council of Governments 2019). Similarly, Chicago’s 2019 shared-scooter pilot required that half of each operator’s fleet be deployed daily across two “Equity Priority Areas” on the city’s historically disinvested West Side (Chicago 2019a). How- ever, compliance with these policies has underscored the lack of safe on-street infrastructure such as bike lanes in these areas. D.C.’s Wards 7 and 8 lack designated bicycle lanes due to historic disinvestment, and protected infrastructure on Chicago’s West Side mainly provides access between the area and downtown rather than strong connections between neighborhoods within it. An expansion of safe infrastructure to accompany these new services is vital because expansion of shared micromobility services in these areas will inevitably lead to more clashes on sidewalks with pedestrians or on streets with motor vehicles if there is a lack of safe infrastruc- ture dedicated to bikes and micromobility (Su and Wang 2019). Transit agencies’ interests in first-/last-mile connectivity make them cities’ natural partners in finding opportunities to increase the provision of on-street micromobility infrastructure. Transit agencies can support equitable access by facilitating micromobility access around stations and stops in underserved communities. However, there are other barriers to equitable access to micromobility beyond just geographic distribution and infrastructure. Seattle’s 2018 bikeshare evaluation report identified barriers such as technological access, banking, affordability, knowl- edge of micromobility services and their potential benefits, and helmet access [Seattle Department of Transportation (SDOT) 2018]. Demand Management Micromobility has the potential to help cities and transit agencies manage demand if the built environment supports its safe and convenient operation. Cities and transit agencies alike have a responsibility to manage demand across the mobility system to advance environmental, economic, and equity outcomes. Jurisdictions and agencies generally agree that dockless micro- mobility has the potential to meet climate-change goals by reducing greenhouse gas emissions, extending the reach of transit and providing first- and last-mile connections, mitigating transit congestion and core capacity issues, and reducing car reliance in low-density areas or late at night when many agencies provide limited or no service. Dockless Micromobility Can Extend the Reach of Transit. Some transit agencies see micromobility services as part of their mandate to enhance local and regional mobility. To that end, transit agencies are developing and managing micromobility programs or directly partnering with private micromobility operators to achieve transit access and coverage objectives. In partnership with the Sonoma County Transportation Authority (SCTA) and the Transpor- tation Authority of Marin (TAM), Marin County’s Sonoma–Marin Area Rail Transit (SMART) plans to become the focal point of a new bikeshare system. An $800,000 pilot received funding through the regional metropolitan planning organization (MPO), the Metropolitan Transporta- tion Commission (MTC). In February 2020, SCTA and TAM approved a multiyear pilot with Gotcha Mobility to provide a hybrid (docked/dockless) shared e-bike system. Riders will also be able to link their bikeshare accounts to the Bay Area’s Clipper Card system, which SMART uses for fare collection (Fixler 2020). The system will provide bicycles at SMART train stations and key destinations along the rail corridor. The goals are “to increase access to transit, promote active transportation and provide a direct first and last mile to SMART, and give people another option for travel in Marin County” (Prado 2018). As a pilot, the program will be evaluated for the possibility of future expansion (Fixler 2019). Caltrain, also in the San Francisco Bay Area, was, at the time of writing, planning for micro- mobility and considering how it could be leveraged for first-/last-mile transit access. Caltrain

Regulatory and Policy Review 41   is one of the leading carriers of bicycles on board trains in the United States, and its onboard carrying capacity is filled almost daily. In 2019, Caltrain began work on the “Caltrain Bike Parking and Micromobility Analysis and Implementation Plan” (Caltrain 2019b). The plan includes: • A comprehensive policy about the quantity and type of bicycle parking and shared micro- mobility options to provide at stations over time; • Station-specific designs and implementation plans for additional secure bicycle parking at stations; and • Analysis, coordination, and recommendations for the rollout of bikeshare and potentially other shared micromobility devices along the Caltrain corridor. This plan will provide crucial direction for an investment of $3.5 million in micromobility infrastructure in advance of Caltrain’s electrified train service in 2022, which is expected to generate significant new ridership. It will also set the framework for additional capital invest- ments and grant funding in first-/last-mile infrastructure in the future (Caltrain 2019b). Dockless Micromobility Reduces Car Reliance and Alleviates Core Capacity Issues. Nearly every dockless micromobility pilot has found that shared electric scooters and bikes reduced car use. In 2019, Santa Monica found that 49% of dockless micromobility trips replaced drive-alone/other car (e.g., taxi or ride-hail) trips (Santa Monica 2019b). Portland reported in 2018 that 34% of Portland residents, and 48% of visitors, used a shared e-scooter instead of driving a personal car or using a taxi or ride-hailing service (PBOT 2019), and a 2019 Denver survey found that 32% of e-scooter trips replaced some kind of automobile trip (Denver 2019a). This is true among docked systems as well: one study found that about half of all (docked) bikesharing members reduced their auto and taxi reliance (Shaheen and Cohen 2019). Dockless micromobility also has the potential to alleviate crowding on some of the most congested parts of a transit system and at certain high-use times of day. Santa Monica found that 4% of users shifted away from transit trips to scooter trips (Santa Monica 2019b), although the data are not detailed enough to demonstrate from which routes or times of day people switched. It is clear that dockless micromobility displaces automobile trips to some degree whenever it is made available, and the development of these services can be encouraged to achieve the greenhouse-gas or congestion-reduction goals of cities and transit agencies. Data and the Built Environment At a time where mobility data are increasingly managed as a core infrastructure asset, cities and transit agencies are increasing their role in data collection, management, and distribution. Two widely used mobility data standards, the GBFS and the MDS, provide standardized data definitions and methods for sharing data between cities, vendors, and transit agencies. These standards were described in the Data-Sharing Requirements and Standards/Specifications section earlier in this chapter and are further explored in Appendix B: Digital Policy and Compliance. Data Partnerships Enable Cities and Transit Agencies to Manage Micromobility Parking and Access at and near Transit. Shared dockless micromobility has the same basic opportuni- ties and constraints of docked and personal micromobility access at transit stations. However, what has changed is the scale and speed of growth of these services, which creates an urgent challenge for cities and transit agencies. If managed, these systems could support access and parking investments at transit stations and stops. Transit agencies’ management of dockless micromobility must be firmly rooted in access planning best practices [as exemplified by planning/design guidelines such as the BART Multi modal Access Design Guidelines (BART 2017) and Denver Moves: Transit (Denver 2019b), both discussed in the Infrastructure Funding section that follows] and supported by new digital

42 Transit and Micromobility management tools that empower cities and transit agencies to better understand their riders’ movement across the system, control where companies deploy micromobility devices, and manage where riders park them. These digital management objectives are enabled by the development of the MDS, which was pioneered by LADOT and is now managed by the OMF. MDS defines a set of connections between computers (APIs) that standardize two-way commu- nication between cities, transit agencies, and private companies. This allows mobility providers and mobility managers to share operational and digital policy information. Some cities analyze, visualize, and report shared micromobility trip and operation data from MDS feeds using in-house tools, while others contract this work out to third parties that specialize in ingesting, auditing, processing, and securing mobility data. However, in both cases the capacity to collect, analyze, and interpret the large amount of data produced by dockless micromobility systems varies among jurisdictions and is dependent on the data-sharing requirements imposed on the private operators (Santa Monica 2019b). LADOT has also developed a geofenced “Special Operating Zone” in the Venice neighbor- hood to solve problems related to deployment oversaturation, conflicts with pedestrians on the Venice Boardwalk, and user parking issues. The Special Operating Zone factors in new digital tools, such as no-ride and exclusion zones, throttle zones (vehicles entering an excluded area are automatically slowed to a stop), and enhanced compliance and enforcement auditing. Other cities, like Santa Monica and San Antonio, established similar geofencing tools for non-transit use cases. In each of these cases, the cities use trip and operations data to track provider perfor- mance and compliance at geofenced locations (Sharp 2019). Trip-level data provided to permitting entities can also be used to identify specific routes with high-volume micromobility use. Third-party data tools, such as Populus’ Mobility Manager (https://www.populus.ai/solutions/mobility-manager), Remix’s Shared Mobility plat- form (https://www.remix.com/solutions/streets-shared-mobility), and Ride Report’s data tools (https://www.ridereport.com/), can be used to aggregate and visualize path-of-travel data for shared micromobility services (Clewlow 2019b). When compared with other information such as that from a high-injury network or key transit access corridors, these path-of-travel data can help identify near-term capital investments, such as for protected bike lanes, bike racks, and dockless parking areas. Shared Micromobility Data Illuminate Inequitable Distribution of Resources and Inform Infrastructure Investment Priorities. Use of shared micromobility data can help identify areas that are underserved or oversaturated. Agencies and cities can use these data to not only ensure equitable deployment but also to develop future micromobility infrastructure in the areas of most need. This is particularly important because, without intervention, dockless systems potentially exacerbate existing mobility and access inequalities. For example, the city of Detroit found that micromobility operators concentrated their services in affluent areas, leaving tradi- tionally underserved communities with service gaps in the new services (Santa Monica 2019b). At the time of writing, LA Metro was developing an equity platform for micromobility policies and was planning to use data to develop recommendations for the improvement of disadvantaged communities’ access to micromobility vehicles. Staff planned to monitor metro stations in disadvantaged communities to determine if they were underserved by shared micro- mobility operators (LA Metro 2019a). SDOT also used micromobility data to understand the equity implications of its dockless bikeshare program. Its initial pilot in 2018 required that at least 20% of the areas in which dockless bikeshare operated be Tier 1 equity areas, which were defined as places with low access to opportunity and high risk for displacement. In its 2018 bikeshare evaluation, SDOT used data provided by operators to monitor operations, finding that while ridership was highest in

Regulatory and Policy Review 43   the center city, the entire city was covered by bikeshare supply. However, the city’s most dis- advantaged neighborhoods saw low ridership, suggesting that providing an option does equate to access, nor does it overcome barriers to use in underserved neighborhoods (SDOT 2018; Cohen 2018). Infrastructure Funding The Public and Private Sectors Both Have an Interest in Supporting Infrastructure Needs. The basic tenets of bicycle infrastructure design—that the infrastructure should provide safe and comfortable places to bike—also apply in a world with expanded access to dockless bicycles, scooters, and other micromobility services. With the growing popularity of these services, cities seek to expand the number of bike lane miles, the width of bike lanes, and lane-adjacent spaces for parking and pedestrian throughways. According to responses from the Santa Monica Dockless Mobility Summit (Santa Monica 2019b), some jurisdictions are contending with an increase in demand for micromobility infrastructure such as bicycle or micromobility lanes, bicycle racks, and parking areas to accom- modate scooters. Guidance and plans established before the proliferation of dockless micro- mobility models, such as BART’s Multimodal Access Design Guidelines (BART 2017) and Denver’s Denver Moves: Transit (Denver 2019b), acknowledge that transit agencies share an interest in improving access to stations and stops through new infrastructure investments. Micromobility companies’ growth and sustainability also rely on the provision of safe, comfortable, and ubiquitous on- and off-street infrastructure. However, despite some of the companies’ early attempts to fund protected lane expansion, their business models do not support the funding of major infrastructure investments (Schmitt 2019). While the primary funding source for parking and on-street infrastructure is the public sector, mobility service providers can support expansion through: • Advocacy, community organizing, and promotion of customers’ stories and demand for better infrastructure; • Public messaging campaigns; • Demonstration projects and tactical bikeway and parking installations; and • Limited funding to support the introduction and management of the new service model.