Author: Bern Grush, Executive Director, Urban Robotics Foundation
Date Published: March 2, 2025
Many of the ideas in this post were compiled during a recent private conversation that included Pedro Homem de Gouveia, Senior Policy Advisor with Polis Network and Mark-Emil Talivere Senior Policy Advisor with Tallinn Strategic Management Office. Thank you to both of them. Many of the insights in this post are theirs, but any error herein is mine.
Cities worldwide are experiencing an unprecedented wave of innovation in urban mobility. From e-scooters and autonomous vehicles to delivery robots and drones, these technologies promise to transform how people and goods move throughout urban spaces. The rapid emergence of these technologies presents significant regulatory challenges for municipal authorities. Cities must balance innovation with public safety, equity, and the effective management of limited public space. Let’s examine some of the key regulatory challenges facing new mobility technologies in urban environments, with particular attention to public-area mobile robots (PMRs) that are beginning to appear on our streets and sidewalks.
The Regulation-Innovation Gap
A fundamental reality in the regulation of new mobility technologies is that regulation chases innovation. As observed by Pedro Homem de Gouveia, it is impossible to regulate what does not yet exist. This creates an inherent tension for companies developing new technologies such as PMRs, who face uncertainty about how their innovations will ultimately be regulated—and this uncertainty affects investment decisions, business models, and deployment strategies.
The gap between innovation and regulation is widened by a significant capacity disparity. Most new mobility services are digitally enabled technology businesses backed by venture capital, while public authorities typically lack equivalent technological expertise. Technology is not the core business of the public sector; it cannot be expected to keep up with the speed and the scale of current innovation. Such knowledge asymmetry makes some regulators defensive and overly risk averse.
This creates a problematic cycle: the more complex the new technologies become, the larger the knowledge gap and the more defensive the regulatory stance. The more defensive governments become, the longer it takes to build capacity and enable innovations that might deliver significant public benefit. This dynamic particularly affects technologies like PMRs, which combine robotics, artificial intelligence, and spatial systems dynamics in ways that few municipal officials have sufficient expertise to evaluate. This makes it challenging to understand the potential opportunities and delays policy and regulatory planning.
Systemic Barriers to Innovation
Rather than focusing solely on regulating new technologies, cities also need to examine how existing regulations and infrastructure create structural disadvantages for innovations. Most current urban mobility spaces, predominantly designed around road vehicles, create inherent barriers for new mobility solutions.
For example, when e-scooters appeared in cities, public discourse focused heavily on regulating their speed and parking. However, e-scooters were often used on sidewalks because users are afraid to ride them on the roadway (because of the high weight and speed differential compared to roadway motor vehicles). Similarly, e-scooter parking was often contentious and chaotic because private passenger cars held a monopoly on street parking.
This same dynamic will affect PMRs. As delivery and maintenance robots proliferate, they will face similar challenges: Where do they stop? Wait? Charge? People will complain if they stop and wait on sidewalks too narrow for this purpose. Current pedestrian infrastructure, already poorly designed in many places, was never designed to include reserved space for service robots.
Paradoxically, the most important regulatory changes to enable technological innovation in urban mobility may be low-tech policy changes: reducing vehicle speeds, creating shared spaces, and opening curb space to be less dominated by street parking. Without a fundamental movement toward more generous pedestrian and micromobility infrastructure within the urban mobility ecosystem, even the most sophisticated regulatory frameworks for these new smaller technologies will fail to unlock their full potential.
Social Considerations for Innovation
Matters of technical insight, the built environment, and the current dominance of the urban motor vehicle are not the whole story. Municipal regulations for new mobility innovations such as PMRs must consider all of the users that will share space with these devices—not just the default concept of "pedestrian." Regulations must consider existing accessibility rights, equitable access to the services offered by these new devices, and if that is not feasible, assurance that those services that are provided do not make some people worse off.
The case of Toronto in 2021 illustrates this challenge. The City Council temporarily banned PMRs because no one at the hearings held to decide whether to permit delivery robots could provide firm assurance that blind pedestrians would be safe. There was no evidence that blind pedestrians would be harmed, but that was insufficient for city council to provide an operating permit. This exemplifies how city regulators must consider issues that innovators, while behaving appropriately and with good intention, may be unable to provide adequate evidence of requisite safety.
Beyond accessibility matters, other social considerations include psychological comfort with robots in public space, perceived fairness of robot priority in shared environments, and cultural acceptance of automation in traditionally human-occupied spaces. Some pedestrians may feel uncomfortable or even threatened by autonomous devices that move unpredictably or lack clear intention signaling from a bystander’s perspective. Some people may resent robots occupying limited pedestrian infrastructure while performing tasks that appear to primarily benefit private interests.
Furthermore, equity concerns arise if PMR services are deployed primarily in relatively wealthier neighborhoods or business districts while bypassing lower-income communities—potentially widening existing disparities in urban service delivery. Privacy concerns also emerge regarding cameras and sensors on these devices that collect data in public spaces.
Regulators need to weigh many more sociological, psychological, or accessibility aspects than may be considered by every innovator. It becomes clear that innovators would benefit from having at least some level of regulated requirements established before they design or manufacture a new mobility device or approach a city for an operating permit. Without these considerations, even the most technically sound innovations risk rejection based on social factors that could have been anticipated and addressed.
Enforcement Capacity Is a Forgotten Dimension
Regulations must consider practical implications for both operators and enforcers. Rules without enforcement capacity create regulatory entropy. They exist on paper but generate confusion and inconsistency in practice.
Public authorities face a critical dilemma when enforcement is challenging: either avoid creating necessary regulations entirely or create vague rules enabling selective enforcement. This issue intensifies as technologies democratize. Paris illustrates this challenge perfectly: after banning shared e-scooters, privately-owned devices proliferated even more widely, with 1.8 million personal e-scooters sold in France compared to only about 50,000 shared devices prior to the ban.
For PMRs, this raises crucial questions. If delivery robots become widely available to individuals and small businesses rather than remaining exclusive to corporate fleets, enforcement becomes far more difficult. Once technology is democratized, it must be regulated very differently. That is because there is a critical difference of care between managed service fleets and private ownership. With personally owned scooters, users demonstrate significantly greater care and responsibility, positioning scooters to the side of walkways to ensure they’re not obstructing the path, primarily to protect their property from theft or damage.
This is critical. Shared mobility devices often suffer from the tragedy of the commons—when resources are communally accessed without individual ownership, users lack the intrinsic motivation to preserve them for the common good. With no personal stake in the long-term condition or availability of shared scooters—or the space they occupy—users may carelessly abandon them, creating sidewalk clutter that diminishes public space for everyone.
This ownership psychology significantly impacts the public acceptability of micromobility technologies. Private ownership tends to produce more responsible usage patterns of the devices, while shared systems require robust management frameworks to counteract users’ reduced social investment in proper device handling and storage.
For PMRs, this raises significant questions. If robots for delivery, security and maintenance become widely available for purchase and operation by individuals and small businesses, rather than remaining exclusive to large, managed fleets, how would this change the way cities would design and enforce regulations about their operation?
Differentiated Regulatory Approaches
There will naturally be several distinct categories of PMR regulations:
Vehicle characteristics: Size, wheels, materials, lights, sensors (typically national-level regulation)
Operational requirements: Safety certification? How is liability decided and managed? Who controls the device from a real time oversight perspective?
Service rules: Market differences, business models, service standards; security and public works robots would likely have very different service rules and each would differ from delivery robots
Public space usage: Where and when they can operate, stop, park, charge?
Each category involves different stakeholders, authorities, and processes. Attempting to regulate at the wrong level creates inefficiencies and barriers. For instance, if each municipality were to create its own distinct standards for robot size or safety features, manufacturers would face impossible compliance challenges. Conversely, if national regulations attempted to set detailed rules about local public space usage, they would likely fail to account for the unique characteristics of different urban environments.
Estonia's approach illustrates this differentiated framework. Since 2017, their traffic laws incorporated delivery robots with clear size and weight parameters established at the national level, while still allowing local authorities to determine where and how these devices can operate within their jurisdictions. More recently, Estonia has become the first jurisdiction to explicitly include PMRs besides delivery robots in their motor traffic code.
Behavioral Standards Are a Missing Element
In addition to basic constraints like weight or speed limits, robots need guidance for critical behaviours particularly in complex scenarios like street crossings. Companies developing PMRs actively seek these behavioral regulations so they can program them into their devices and demonstrate compliance to cities. This is an example of a requirement for fairly detailed regulations that need careful collaboration between the teams writing software to manage these devices and municipal regulators writing legislation to govern them. This is not something that either profession can do on their own, hence the work of drafting ISO/DTS 4448 to bridge that gap.
To-date, over 25 jurisdictions have prepared legislation that calls for PMRs to follow pedestrian rules when crossing a roadway. Surely that is necessary, but it is insufficient for informing the software necessary for road crossing safety without human teleoperation. It turns out that that problem remains unsolved, although many assume it is. This specific issue is already a critical gap, closed only with teleoperation—which is itself unregulated, as well.
We need to view (and prepare) regulation with enough guidance so that when coded into the navigation—or teleoperation—behaviour of these devices that pedestrians, cyclists, micromobility users, and motor vehicle operators can anticipate and rely on those behaviours from every certified PMR. Establishing this level of predictability represents a shift from viewing regulation as restrictive to seeing it as enabling deployment, which is something that Ahti Heinla, a founder of Starship Technologies (a maker/operator of delivery robots) has recently indicated when he asked for regulations to remove operating ambiguities.
The human-robot interaction dimension adds another layer of complexity. When pedestrians encounter motor vehicles, they often make eye contact with drivers to establish communication and intent. Robots need equivalent signaling systems. When there's a robot waiting to cross the street, how can other users communicate with these robots? Understand their intentions?
Draft ISO standards are outlined to address these behavioral issues, as well. When they are ready, municipal regulations will need to incorporate or reference these standards to create consistent expectations for both robot operators and the public.
Strategic Implementation Approaches
Several strategic approaches emerge for cities implementing regulations for new technologies, for example:
Urban acupuncture: Paris created school streets (traffic restrictions near schools) strategically distributed throughout the city, influencing the broader network while focusing on politically uncontroversial locations.
Leverage existing regulations: Many cities repurposed the (EU) five-meter no-parking zones near crosswalks (already prohibited for cars) for micromobility parking.
Seek easy victories: Focus initial regulatory efforts on changes with minimal opposition to build momentum.
These approaches can be applied to PMRs by identifying strategic locations where delivery robots might first be deployed, leveraging existing regulations that can be adapted to accommodate them, and focusing on use cases with broad public support.
Balancing Innovation and Stability
While innovation requires flexibility, regulation creates the stability necessary for substantial investment. Venture capital thrives on uncertainty and rapid growth, but this often leads to “grow at any cost”—an approach that cannot be considered for PMR deployment. Using the example of electric vehicle charging infrastructure, contradictory signals about regulation versus deregulation can easily drive away the private investment needed for scaling. Clear commitment from the public sector on long-term direction provides confidence for more sustainable investment.
This tension is particularly relevant for PMRs. Regulation is needed to provide confidence to invest in the sector. Without regulatory clarity, investors remain hesitant to commit the resources needed to scale these technologies beyond initial pilots. In order for PMR technology to bring a viable and positive impact to our cities they not only need to be safe, but they need to be affordable and profitable. That cannot be done without scale and scale cannot be considered without the kind of regulation that provides the safety and user acceptance required.
Summary
The regulation of new mobility technologies, particularly public-area mobile robots, presents complex challenges for cities. Effective regulatory frameworks must address the gap between innovation and regulation, overcome systemic barriers in existing transportation systems, ensure adequate enforcement capacity, differentiate between various regulatory domains, establish clear behavioral standards, implement strategies gradually, and balance innovation with stability.
The ideal regulatory approach is neither reactive nor overly prescriptive, but rather establishes clear frameworks that provide a modicum of certainty while accommodating continued innovation and prioritizing public benefit. As cities navigate these challenges, they have the opportunity to shape how PMRs and other new mobility technologies integrate into urban environments in ways that enhance sustainability, safety, and quality of life for all their residents.
Engage further…
Register for our webinar (March 20, 2025) to hear our panel and join the conversation: “Order Out of Chaos: The Regulatory Landscape for Public-area Mobile Robots.”
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