Licensing Regime Analogues for CAM Governance

EVIDENCE TIER: 1 (Proven Regulatory Instrument – Conditions-Based)

Headline Finding: London, NYC, and TfL have established multi-level conditions within mobility operator licenses: data-sharing mandates, service obligations, accessibility standards, geographic coverage, and safety requirements. Evidence demonstrates that cities routinely impose non-price conditions on mobility operators via licensing, proving the regulatory architecture exists for CAM operator oversight.

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London TfL – Micromobility Concession Framework

Mechanism:

• Pan-London Micromobility Scheme (e-bikes + e-scooters, operational by early 2026)
  • Mandatory parking rules across London
  • Fleet cap applied London-wide
  • Dedicated TfL operational management team
  • Independent data verification solution required from operators
  • Commercial fee structure: (a) annual administration fee, (b) monthly per-vehicle fee, (c) monthly per-bay fee

Licensing Conditions:

• Borough-level commercial concession agreements set local rules: vehicle numbers, parking requirements, service standards
• Proposed English Devolution Bill will introduce formal licensing framework giving TfL/boroughs regulatory powers
• “Slant towards e-bikes” in contract design and requirements
• Parking compliance and user behavior standards mandated

Data Requirements:

• Operators must provide independent-verified operational data
• TfL manages contract and operations with dedicated team

Outcomes & Metrics:

• Consistency of scheme design across London boroughs
• Improved parking compliance (targeted outcome)
• Data transparency enabling TfL oversight

Data Maturity: Policy finalization stage; operational data collection to commence 2026 Sources:

• ebiketips: “Is a common contract for London e-bike and e-scooter share schemes on the way?”
• London Assembly Press Release: “Allow TfL to regulate e-Bikes and scooters”
• TfL Board Document: “Electrified Travel Devices (Micromobility)” (Mar 2023)
• London Councils Press Release: “Calls on e-bike companies to respect contracts with boroughs”

Drafting Note for Chapter 7: TfL micromobility regime is directly analogous to CAM licensing. Shows how a city authority can impose: (1) fleet caps, (2) parking/curb-use rules, (3) data reporting, (4) fee-based cost recovery, (5) local variability within city-wide standards. Use as template for CAM licensing structure. Note: Contracts not yet live; pilot outcomes will strengthen evidence.

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TfL – Private Hire Vehicle (PHV) Licensing Post-Uber

Mechanism:

• Prescribed conditions defined in Private Hire Vehicles (London) Act 1998 and PHV Licences Regulations 2004
• Recent regulatory evolution (July 2024) shows ongoing tightening of conditions

Current Licensing Conditions:

• Safety & Compliance:
  • Mandatory Disclosure and Barring Service (DBS) checks for all new drivers (£33 cost, annual renewal requirement)
  • Safety, Equality, Regulatory Understanding (SERU) assessment for all drivers (speaking/listening + reading/writing)
• Environmental:
  • Zero Emission Capable (ZEC) requirement for all newly licensed PHVs (from Jan 2023 onward)
• Data & Reporting:
  • Trip data submission requirements (varies by base type; Central Dispatch Exception requires expanded reporting)
• Service Quality:
  • Operator must be “fit and proper” (reputational/financial fitness test)
  • Uber required to implement safety systems beyond industry standard

Evolution Post-Uber Disputes:

• 2017: TfL initially denied Uber license (not “fit and proper”)
• March 2022: TfL granted Uber 30-month license, noting “many systems [Uber] deployed go beyond those deployed by majority of PHV operator industry”
• July 2024: Strengthened DBS and safety assessment requirements; annual DBS renewal (new)

Outcomes & Metrics:

• Uber achieved compliance with safety and operational standards and now operates under TfL license
• Fleet adoption of ZEC vehicles beginning (new vehicle requirement)
• Driver safety training now mandatory for all license holders

Data Maturity: Tier-1 regulatory evidence; live enforcement Sources:

• TfL Transport for London: “Changes to private hire regulation” and “Apply for a private hire vehicle licence”
• TfL Notice 05/24 (July 2024): “Changes to Licensing Requirements from 1 July 2024”
• Zego Blog: “TFL New Rules & Requirements For Private Hire Drivers (2025)”
• Hogan Lovells Case Study: “How Uber navigated three licensing appeals in London and won”

Drafting Note for Chapter 7: TfL PHV licensing shows mature regulatory toolkit: safety (DBS, SERU, training), environmental (ZEC), data (trip records), and fit-&-proper operator tests. Post-Uber evolution demonstrates regulatory bodies can iteratively tighten conditions in response to operational evidence. Use to support argument that CAM operators can be held to specific, verifiable standards via licensing conditions. Emphasize: TfL did not ban Uber but conditioned its operation.

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NYC – For-Hire Vehicle (FHV) Licensing & TNC Regulation

Mechanism:

• TLC (Taxi and Limousine Commission) licenses all FHV bases and drivers
• Local Law 147 (2018): Paused issuance of new FHV licenses (with WAV exception) to manage congestion
• Two-tier accessibility approach: Trip Mandate + Central Dispatch Exception

Licensing Conditions:

Accessibility & Service Equity:

• All FHV bases must provide equivalent service to wheelchair users
• Trip Mandate: Minimum % of annual trips routed to Wheelchair Accessible Vehicles (WAVs)
• Central Dispatch Exception: Bases can provide equivalent service via dispatcher-managed accessible fleet
• Mandatory wheelchair passenger assistance training for all drivers (in-person)

Data Reporting & Compliance:

• Trip Record Submission Requirements: All FHV bases must report trip data to TLC
• Central Dispatch Exception bases have expanded reporting obligations
• TLC publicly tracks accessible FHV fleet (Q1 FY2025: 7,642 active accessible FHVs, 3,992 accessible Medallion Taxis)

License Pause & Congestion Management:

• New FHV licenses paused (exceptions for WAVs and lease-to-own drivers)
• February 2025 License Review Report: TLC reassesses FHV license issuance quarterly

Outcomes & Metrics:

• 7,642 active accessible FHVs (as of Q1 FY2025)
• Trip mandate compliance tracking by base
• Congestion impact measured via license pause methodology

Data Maturity: Tier-1 regulatory evidence; live enforcement and public reporting Sources:

• NYC TLC: “FHV Accessibility Rules,” “Accessible Vehicle Requirements,” “FHV Wheelchair Accessibility Owner/Driver Info”
• NYC Open Data: “For-Hire Vehicles (FHV) - Active” (real-time database)
• NYC TLC License Review Report (February 2025)
• NY DMV: “Information for Transportation Network Company (TNC) Passengers”

Drafting Note for Chapter 7: NYC FHV licensing demonstrates: (1) quantity controls (license pause for congestion), (2) equity conditions (Trip Mandate for accessibility), (3) mandatory data reporting (trip records), (4) training requirements (wheelchair assistance). TNC operators (Uber, Lyft) operate under these same FHV base rules. Use as evidence that cities can control ride-hailing scale via licensing and impose service obligations (accessibility) as condition of operation. Public data on accessible fleet provides outcome measurement example.

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Chicago – Freight Zoning & Loading Zone Licensing

Mechanism:

• Chicago Department of Planning and Development (DPD) manages zoning code and freight-related regulations
• Non-Commercial Loading Zone Permits: Required for vehicles using ordinary Illinois passenger plates for deliveries and service calls
• Commercial districts: Thousands of public-use loading zones regulated by permit

Licensing Conditions:

• Permit-based access to loading zones
• Time restrictions: Max 30 minutes per zone (enforceable via DPD)
• Zoning-based differentiation of freight access (commercial vs. restricted zones)

Data Maturity: Operational; specific outcome metrics not detailed in available sources Sources:

• City of Chicago DPD: “Non-Commercial Loading Zone Permit Information & Application”
• Chicago Zoning Ordinance Administration

Drafting Note for Chapter 7: Chicago provides evidence that cities use permit-based licensing to regulate freight access. Less mature than TfL/NYC examples on data-driven regulation, but demonstrates permission-based curb access model (applicable to CAM fleets). Note contact: DPD_Zoning@cityofchicago.org (312-744-5777) for operational details if deeper evidence needed.

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EV33 Summary Table – For Ch.7 Licensing Conditions Menu

Condition Type	London TfL (Micro)	TfL PHV	NYC FHV	Chicago Freight	Applicability to CAM
Fleet cap / quantity controls	✓ (London-wide)	—	✓ (pause)	Permit-based	HIGH
Data sharing mandate	✓ (verified data)	✓ (trip records)	✓ (trip records)	Implicit	HIGH
Service obligations	✓ (parking std.)	✓ (fit & proper)	✓ (accessibility)	Implicit	HIGH
Geographic coverage	✓ (borough levels)	—	—	Zoning-based	MEDIUM
Safety/training	—	✓ (DBS, SERU)	✓ (wheelchair training)	—	HIGH
Environmental standards	✓ (planned)	✓ (ZEC)	Emerging	—	HIGH
Fee-based cost recovery	✓ (admin/vehicle/bay fees)	Implicit (license fees)	Implicit (base license)	Permit fees	MEDIUM

Key Numbers for Chapter 7:

• TfL micromobility: Pan-London scheme, fleet cap applied, independent data verification required
• TfL PHV: 30-month license term, DBS check £33/year, ZEC requirement from 2023
• NYC FHV: 7,642 active accessible FHVs, Trip Mandate compliance tracked per base
• Chicago: Thousands of loading zones, 30-min dwell limit per permit

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