Siloed Governance Failures in Mobility: Vignettes
Fragmented agency mandates, misaligned incentives, and absent cross-sector coordination repeatedly stall safe, equitable AV/mobility deployment
Headline Finding
When mobility agencies fail to coordinate on data, space allocation, and rule-setting, programs collapse or produce poor outcomes. Three vignettes—Helsinki MaaS Global, Chicago dockless scooters, and fragmented MaaS implementations—demonstrate that technology is not the barrier. The barrier is institutional: when agencies don’t formally integrate their decision-making (or actively protect their silos), mobility programmes fail.
Vignette 1: Helsinki MaaS Global Collapse (2016–2024)
Programme Overview:
- MaaS Global: Finnish startup founded by Sampo Hietanen (CEO)
- Service: “Whim” app—integrated mobility payment and booking across transit, bike-share, car-share, ride-hailing
- Market: Initially focused on Helsinki metropolitan area; expanded internationally
- Outcome: Company filed for bankruptcy in 2024
Governance Failure:
The Coordination Problem (Hietanen’s own diagnosis): “One of the hardest parts of this industry is knowing how to bring everyone to the same table. And with MaaS, first you need to get everyone saying ‘OK, we’re going to commit to being in others’ platforms jointly with our competitors’.”
This statement captures the core governance failure: the absence of a formal mechanism to require competing mobility operators to integrate their data and payment systems. Without institutional mandate, operators had no incentive to coordinate.
The Multi-Stakeholder Alignment Problem:
- Plurality of actors involved: transit authority, bike-share operators, taxi operators, car-share operators, ride-hailing companies
- Conflicting interests: operators wanted access to customer data; authorities wanted open standards; service providers wanted proprietary platforms
- Misaligned decision-making levels: central MaaS Global (app level) vs. decentralized operators (mode-specific level)
Contributing Factors to Collapse:
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Business Model Fragility:
- Relied on B2C subscription packages (consumer willingness to pay for integrated service)
- Business model collapsed post-pandemic: reduced transit ridership, reduced consumer spending
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Governance Absent:
- No formal public-private coordination mechanism requiring operator participation
- Operators remained optional participants (could use or ignore Whim)
- Lack of regulatory framework incentivizing integration
- No authority structure to resolve operator disputes about data ownership, payment allocation
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Institutional Coordination Failure:
- Helsinki transit authority did not mandate operator integration as a condition for curb access or data sharing agreements
- No formal “gold command” coordinating transit, parking, curb, and shared mobility space
- Each operator made independent decisions about data sharing, pricing, and service hours
Key Lesson for CAM: The MaaS Global collapse reveals that technology and venture capital are insufficient without institutional coordination. Even with a compelling consumer product (Whim), the system failed because the underlying governance was fragmented. CAM governance must include: (1) formal requirement for data integration (not optional), (2) authority structure to resolve conflicts about space and resource allocation, (3) regulatory framework tying operator access to coordination compliance.
Source:
- Does the Collapse of MaaS Global Signify the End of the Road for Mobility as a Service Model? (Frost & Sullivan)
- Development of Mobility-as-a-Service in Helsinki: Multi-Level Governance Analysis (ScienceDirect)
- MaaS Global and Whim: Despite Bankruptcy, Future Does Not Seem Bleak (Pitane.Blue)
Vignette 2: Chicago Dockless Scooter Pilot Governance Breakdown (2019)
Programme Overview:
- Pilot period: June 15 – October 15, 2019 (4 months)
- Scale: 2,500 scooters, 10 operators (250 scooters each)
- Service area: 50-square-mile geofenced zone on west/northwest side of Chicago
- Service hours: 5 AM – 10 PM (scooters removed from right-of-way outside hours)
- Data requirement: operators must report via Mobility Data Specification (MDS) standard
Coordination Failures:
1. Inadequate Curb/Space Coordination:
- No formal curb management framework existed before scooter pilot
- Operators deployed without coordination about parking and maintenance hubs
- Result: sidewalk clutter (scooters left blocking pedestrian movement)
- Equity failure: no advance planning for equitable geographic distribution
2. Safety Data Gaps:
- Lack of pre-deployment coordination with health/emergency services
- Insufficient operator safety training requirements
- Result: 10+ riders hospitalized in first week; children took prohibited joyrides
- No coordination mechanism to quickly escalate safety failures to operators
3. Data Access Disputes:
- MDS data available on City portal, but fragmented operator compliance
- No formal mechanism to require real-time intervention when non-compliance occurred
- Operators could choose disclosure level and data granularity
4. Equity Failure (Siloed Planning):
- 77% of rides started/ended in eastern half of pilot area (zone with existing transit options)
- No integration with community development or equity planning
- No coordination between DOT and community agencies to target underserved neighborhoods
- Result: scooters reinforced existing transportation gaps rather than addressing them
Programme Outcomes:
- Main conclusion: “We need to do another pilot”
- No sustained implementation
- Governance declared inadequate for permanent rollout
- Recommended reforms: create chief mobility officer role (indicating governance fragmentation)
Governance Breakdown Diagnosis: The Chicago pilot failed not because scooter technology is problematic, but because governance was fragmented:
- Space coordination: no pre-pilot curb management framework
- Rules coordination: safety standards not aligned across operators
- Data coordination: MDS compliance not enforced; no real-time operator intervention capability
- Equity coordination: pilot not integrated with community planning
The pilot’s main lesson was institutional (need better coordination) not technological.
Key Lesson for CAM: Chicago shows that when a new mobility service launches without formal curb/space/data coordination, outcomes are chaotic. CAM governance must establish this coordination infrastructure before autonomous mobility deployment, not after. The governance failures in Chicago (no curb management, no safety escalation protocol, no equity integration) must be solved at institutional level, not operator level.
Source:
- Chicago E-Scooter Pilot Evaluation (January 2020)
- City of Chicago - Scooter Sharing in Chicago
- Breakdown of Chicago’s Scooter Pilot, by the Numbers (Smart Cities Dive)
Vignette 3: Fragmented MaaS Governance — Cross-City Pattern of Failure
The Fragmentation Pattern:
Research across European cities reveals a consistent governance failure pattern in MaaS implementations:
- Madrid: Three separate MaaS initiatives operating with zero inter-initiative coordination
- Europe-wide: Multiple cities launching MaaS projects without alignment on data standards, payment systems, or operator rules
- Root cause: Lack of governance framework for MaaS at city/regional level
Systemic Governance Problems:
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Siloed Transport Agencies:
- Transit, parking, bike-share, taxi regulation operate independently
- No unified authority over multi-modal space allocation
- No formal requirement for data-sharing between modes
-
Closed Data Systems:
- Each operator maintains proprietary data access
- No interoperability standards enforced at city level
- Government agencies cannot access cross-modal data for integrated planning
-
Outdated Procurement Policies:
- Agencies procure services independently (transit contract, parking contract, etc.)
- Procurement requirements don’t incentivize integration
- No contractual mandate for data sharing or real-time coordination
Diagnosis (from Research Literature):
“The main challenge facing MaaS initiatives is the lack of a governance framework for MaaS. Siloed transport agencies, closed data systems, and outdated procurement policies make collaboration nearly impossible. Governments must rewrite policies to encourage integration, not isolation.”
Further: “The problem isn’t technical. Most schemes cover app-related functions, but the path to MaaS is hindered by governance issues, not technology. Open standards and interoperability depend on the presence of supportive governance and institutional coordination.”
Programme Outcomes (As of 2025):
“MaaS has not been as successful as expected in terms of improving mobility. It is evident that MaaS failures stem from organizational and governance barriers rather than technological limitations, with siloed agencies and lack of coordinated policy frameworks being central obstacles.”
Key Lesson for CAM:
The fragmented MaaS implementations across European cities demonstrate that technology integration (Whim app, payment systems, booking platforms) cannot overcome institutional fragmentation. When:
- Governance is siloed (separate agencies for transit, parking, curb, shared mobility)
- Data remains closed (operators, agencies don’t share information)
- Procurement remains disconnected (contracts don’t require integration)
…then even well-designed technology fails to create integrated mobility systems.
CAM governance must solve these institutional problems first, before autonomous vehicles deploy. The lesson is: integrated mobility requires integrated governance. Technology is necessary but not sufficient.
Source:
- Mobility as a Service (MaaS) Planning and Implementation: Challenges and Lessons Learned (MDPI)
- Questioning Mobility as a Service: Unanticipated Implications for Society and Governance (ScienceDirect)
- Towards a Framework for Mobility-as-a-Service Policies (ScienceDirect)
Synthesis: Implications for Chapter 3 — The City as an Operating Environment
The Coordination Imperative
All four evidence categories converge on a single argument: multi-domain governance is not optional for CAM deployment; it is architecturally unavoidable.
Why?
CAM deployment requires real-time coordination across:
- Flows: traffic management, routing, congestion, incident response
- Space: curbs, lanes, hubs, parking, emergency staging
- Power: decision authority, rule-setting, conflict resolution, enforcement
- Data: vehicle location, occupancy, demand, safety incidents, equity impacts
No single agency controls all four domains. Current siloed governance structures cannot provide this coordination. Yet coordination IS possible and scalable—emergency management, London congestion charging, and Amsterdam mobility integration all prove it.
The Institutional Lesson from Evidence
EV11 (Curb models) → Multi-domain coordination is achievable with formal institutional architecture (NYC DOT neighborhood-first, TfL multi-borough, Amsterdam cross-departmental)
EV12 (Congestion charging) → Permanent, scaled coordination requires unified statutory authority + data-sharing agreements + transparent revenue allocation + rigorous evaluation. Works for 20+ years only with institutional clarity.
EV13 (Emergency management) → Cross-silo coordination at city scale is operationally proven through hierarchical command structures (Gold/Silver/Bronze, NIMS/ICS, NYC OEM). These models solve the core problem: how to make real-time decisions across dozens of agencies with different legal authorities and cultures.
EV14 (Siloed failures) → When governance remains fragmented (Helsinki MaaS Global, Chicago scooters, fragmented European MaaS), outcomes are failure, chaos, or poor performance. Technology is not the barrier; institutional coordination is.
Drafting Note for Chapter 3
The evidence supports this argument structure:
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Opening: CAM operating in cities requires real-time coordination across Flows, Space, Power, Data. This is not a technical problem; it is an institutional problem.
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Precedent 1 (EV11, EV12): Curb management and congestion charging show that cities can coordinate these domains when they establish formal institutional structures (clear authority, multi-stakeholder alignment, data agreements, revenue frameworks). These precedents are proof of feasibility.
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Precedent 2 (EV13): Emergency management has solved the cross-silo problem at scale (Gold/Silver/Bronze, ICS, OEM). These are not special-case solutions; they are generalizable institutional patterns for multi-domain coordination.
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Precedent 3 (EV14): Conversely, when cities attempt mobility innovation without integrated governance (Helsinki MaaS Global, Chicago scooters, fragmented MaaS), they fail or produce sub-optimal outcomes. Failures confirm the necessity of the coordination architecture.
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Conclusion: CAM governance must adapt institutional models proven in emergency management and transport operations to create real-time coordination across Flows, Space, Power, Data. The question is not whether integration is possible, but which institutional form will work for autonomous mobility.
Research Sources — Complete List
EV11: Curb Management Models
- NYC DOT Curb Management Action Plan: https://www.nyc.gov/html/dot/downloads/pdf/curb-management-action-plan.pdf
- NYC DOT Smart Curbs Program (2024): https://www.nyc.gov/html/dot/html/pr2024/smart-curbs-program-launch.shtml
- TfL Kerbside Loading Guidance: https://content.tfl.gov.uk/kerbside-loading-guidance.pdf
- TfL Boroughs & Communities: https://tfl.gov.uk/info-for/boroughs-and-communities/
- Amsterdam Smart Mobility Programme 2019–2025: https://ai4cities.eu/fileadmin/user_upload/Images/Cities/Amsterdam/190717_Programma_Smart_Mobility_2019-2025_ENGv1.pdf
- Amsterdam Smart City Mobility: https://amsterdamsmartcity.com/channel/mobility
EV12: Congestion Charging Governance
- London Congestion Charge (TfL): https://tfl.gov.uk/modes/driving/congestion-charge
- Congestion Charge Impacts Monitoring—Sixth Annual Report (TfL): https://content.tfl.gov.uk/central-london-congestion-charging-impacts-monitoring-sixth-annual-report.pdf
- Centre for Public Impact—London’s Congestion Charge: https://centreforpublicimpact.org/public-impact-fundamentals/londons-congestion-charge/
- Stockholm Congestion Tax (Wikipedia): https://en.wikipedia.org/wiki/Stockholm_congestion_tax
- The Stockholm Congestion Charges: An Overview: https://transportportal.se/swopec/cts2014-7.pdf
- Long-Term Effects of Swedish Congestion Charges (OECD): https://www.oecd.org/content/dam/oecd/en/publications/reports/2018/10/long-term-effects-of-the-swedish-congestion-charges_41933a53/d944f94b-en.pdf
EV13: Emergency Management Coordination
- UK Civil Contingencies Act 2004 (Wikipedia): https://en.wikipedia.org/wiki/Civil_Contingencies_Act_2004
- Gold–Silver–Bronze Command Structure (Grokipedia): https://grokipedia.com/page/Gold%E2%80%93silver%E2%80%93bronze_command_structure
- Dealing with Civil Contingencies: Emergency Planning in the UK (House of Commons Library): https://commonslibrary.parliament.uk/research-briefings/cbp-8016/
- National Incident Management System (Wikipedia): https://en.wikipedia.org/wiki/National_Incident_Management_System
- Incident Command System (Wikipedia): https://en.wikipedia.org/wiki/Incident_Command_System
- NIMS Doctrine (FEMA, October 2017): https://www.fema.gov/sites/default/files/2020-07/fema_nims_doctrine-2017.pdf
- NYC Office of Emergency Management: https://www.nyc.gov/html/ops/downloads/pdf/mmr0912/oem.pdf
- NYC Charter Chapter 19-A: https://nyccharter.readthedocs.io/c19A/
- NYC REMAC General Operating Procedures: https://nycremsco.org/wp-content/uploads/2022/09/NYC-Combined-GOP-Unified-Protocols-Appendices-v02112020.pdf
EV14: Siloed Governance Failures
- Does the Collapse of MaaS Global Signify the End of the Road? (Frost & Sullivan): https://www.frost.com/growth-opportunity-news/signify-the-end-of-the-road-for-mobility-as-a-service-model/
- Development of Mobility-as-a-Service in Helsinki: Multi-Level Governance Analysis: https://www.sciencedirect.com/science/article/abs/pii/S2210539518300142
- MaaS Global and Whim: Despite Bankruptcy, Future Does Not Seem Bleak (Pitane.Blue): https://pitane.blue/en/2024/03/15/Despite-the-bankruptcy-of-Maas-Global,-the-future-of-Maas-does-not-seem-bleak/
- Chicago E-Scooter Pilot Evaluation (January 2020): https://www.chicago.gov/content/dam/city/depts/cdot/Misc/EScooters/E-Scooter_Pilot_Evaluation_2.17.20.pdf
- Chicago Scooter Sharing Program: https://www.chicago.gov/city/en/depts/cdot/supp_info/escooter-share-pilot-project.html
- Breakdown of Chicago’s Scooter Pilot, by the Numbers (Smart Cities Dive): https://www.smartcitiesdive.com/news/breakdown-of-chicagos-scooter-pilot-by-the-numbers/571461/
- Mobility as a Service Planning and Implementation: Challenges and Lessons Learned (MDPI): https://www.mdpi.com/2673-7590/3/2/29
- Questioning Mobility as a Service: Unanticipated Implications for Society and Governance (ScienceDirect): https://www.sciencedirect.com/science/article/pii/S0965856418309601
- Towards a Framework for Mobility-as-a-Service Policies (ScienceDirect): https://www.sciencedirect.com/science/article/abs/pii/S0967070X19307504
Document Status: Research complete and compiled for Matthew Claudel review Next Steps: Integration into Chapter 3 draft; cross-reference with EV1–EV10; develop governance framework argument