Hello, my name is Abigail Jackson and I’m the Transportation Associate at Regional Plan Association (RPA). We are a non-profit research, planning and advocacy organization that, for more than a century, has worked to shape the region’s transportation future. Today we advance ideas that create alternatives to private cars and make our streets more safe, efficient, equitable, and sustainable. We thank you for the opportunity to provide comments on the proposals on today’s agenda.

The following comments highlight support for specific proposals and additional areas to consider beyond others on the agenda today.

RPA supports proposals aimed at improving point-of-sale regulation and consumer awareness as well as enforcing safe rider behavior, including Int 95, 110, 985, and 988. We support the intent of Int 244 but do not support the proposal.

RPA tentatively supports Int 986 and opposes T2026-2361.

The likelihood of serious injury and death increases with speed and device weight, and 20 mph is widely considered a safe speed limit on urbanized roads with a mix of motorized and non-motorized users. Class 3 e-bikes, which NYC DOT defines as devices with throttles that can exclusively propel the bicycle up to 25 mph, have the potential to be used safely in bike lanes under 20 mph as well as in the general travel lane. While RPA supports the intent of Int 244, the City and State need to clarify the regulation of Class 3 e-bikes and what the goals of that regulation are. We support the end of the false advertisement of e-motos and high-speed scooters, that in reality exceed speed and weight limits, as e-bikes or e-scooters, which is also strengthened by the proposal to require moped retailers to distribute information on moped operation at the point of sale. Working together, these proposals take the onus for safety from the consumer and put it on manufacturers and retailers to get dangerous devices off our streets and apply existing rules upstream. The success of these proposals hinges on having an off-ramp for existing users of illegal devices, which is accomplished through Int 985. New York City must proactively support the transition from e-motos to e-bikes and e-scooters, and any rebate or trade-in program should consider the high cost of acquiring a new bike, especially for those who depend on e-bikes or e-scooters to reach or do their job, and how repurchases should work, such as through bulk purchasing or a rental program.

RPA strongly supports the proposal to expand the City’s commercial bicycle safety laws to include other delivery devices that are used for commercial purposes. The majority of app-delivery workers use e-bikes and e-scooters rather than human-powered bikes, and common sense tells us that e-bikes and e-scooters, which go faster and are heavier, require at least as strict a treatment as human-powered bikes. Applying the commercial bicycle safety laws to other devices also creates a framework for regulation which can adapt as technology changes.

RPA tentatively supports providing NYPD with the technology required to test device max speed as proposed in Int 986. Enforcement should be phased in with enough time to allow complementary efforts for education and outreach on transitioning away from illegal devices to make a meaningful impact. The proposal should include language clarifying where the dynamometer will be used and why those locations were selected, exactly what constitutes probable cause, in what cases and how illegal devices will be dealt with, and also how NYPD will treat riders when they are not found to be at fault. This is especially important for delivery workers who will face delays due to traffic stops and this effort should be integrated with requirements for safety plans from delivery service providers. We do not want a situation where people are being chased down and subjected to this test. The greatest concern is not max speed but whether devices are operated within or beyond the speed limit.

Finally, RPA opposes proposal T2026-2361 to ban Class 3 e-bikes. As mentioned above, Class 3 e-bikes have the potential to be used safely in bike lanes under 20 mph and in the general travel lane at their top speed potential.

RPA supports the proposal to require NYPD and NYC DOT to disclose timely, detailed reporting on e-bike and e-scooter traffic enforcement, including with Int 787 and Int 1052.

RPA opposes Resolution 44.

Quarterly reporting will allow Council to understand how and why police resources are being allocated to e-bike and e-scooter enforcement, however, Int 787 should clarify what purpose this serves, such as ensuring fair enforcement or providing additional data to support safety planning. RPA strongly supports the proposal to require NYPD and NYCDOT to provide more granular reporting by micromobility device type, which is critical to safely regulating micromobility. For example, granular data on crashes and injuries by device would inform decisions around which devices are safe and where as well as where traffic calming or other interventions are needed. NYCDOT should also study this information to inform street safety treatments.

Without such data or studies, however, RPA does not support increasing penalties for leaving the scene of a crash involving an e-bike or e-scooter, as is called for in Resolution 44. The proposal should clarify why the penalty for leaving the scene of a crash should differ for e-bikes and e-scooters compared to human-powered devices. If the goal is to align penalties with more severe injuries caused by faster and heavier devices, then we need data supporting which device types are more dangerous. Otherwise, we run the risk of treating all e-bikes and e-scooters the same and villainizing them in general, which suppresses their use and potential to replace car and truck trips which are ultimately responsible for more fatalities and more severe injuries. We need to align rules with device safety, but first we need data to back up where we draw the line on safe vs. unsafe.

RPA supports proposals which require greater accountability and transparency from third-party delivery services and which incentivize them to promote safety, including Int 389, 950, 994, and 1021.

RPA tentatively supports Int 78 and 1069-2026 with amendments.

RPA opposes Resolution 43.

Up to now, third-party delivery companies have prioritized speed over safety, which has resulted in unsafe behavior from delivery workers driven by fear of missed performance metrics or deactivation. Requiring insurance for third-party delivery apps creates an incentive for companies to promote safe delivery behavior rather than speed at any cost, and providing historical and current data on trips will allow the city to verify safe behavior as well as allow DCWP to study data which supports planning for safe streets and delivery rules. However, Int 78 and 1069-2026 should be amended to require data on planned routes, rather than information on individual delivery worker routes which could result in negative consequences and surveillance of individuals rather than the companies. In the same vein, RPA opposes proposal T2026-2587 because it inappropriately targets individual delivery workers and because it is premature to focus on delivery worker behavior before ensuring delivery companies are incentivizing safe practices.

RPA strongly supports the proposal to require delivery services to obtain a business license from DCWP, the requirement for licensed third-party delivery services to provide safety reports and planning, and the requirement for third-party delivery services to verify the registration of mopeds used for deliveries. Together these proposals take the onus for safety off individual delivery employees and put it back on third-party delivery services. New York would not be the first to require licensing of third-party delivery services–as of April 2026 Boston requires third-party food delivery apps to get a permit to operate in the city and to obtain that permit, they must have insurance covering delivery workers on the job and also provide data on delivery vehicles and aggregate trips. While it’s too early to say whether safety improvements have resulted from these regulations, Boston faced similar challenges to New York City and has certainly created an enforcement mechanism with teeth which will also allow New York to adapt to the regulatory landscape and clarify rules for critically important third-party delivery services.

In requiring safety reports with Int 1021, the implementation of the rule should ensure third-party delivery services clarify expectations for employee performance, how they meaningfully encourage safe behavior, and also how their safety plans account for factors outside of employee control, such as no-fault traffic stops which can nevertheless impact delivery times and performance metrics. Council should also ensure proposals are tailored to the largest food delivery companies in order to target specific behaviors and avoid burdening small businesses or other forms of delivery.

RPA strongly opposes Resolution 43, calling on New York State to pass the ​“Commercial E-Bike Licensing Act.” Registering commercial e-bikes arbitrarily singles out people using e-bikes to earn their living, delivery workers and does nothing to address the use of e-motos, which pose a greater threat to safety than e-bikes. This act also creates barriers to e-bike usage, which the city and state should seek to promote –albeit in a safe way– and the act goes too far to regulate all classes of e-bikes with blanket rules which could require delivery employees on class 1 e-bikes to hold a driver’s license and register them as they would a motorcycle or car.

RPA supports Int 214 and Int 989, but we oppose T2026-2590 because it is unsafe for riders and premature given the current state of our bike infrastructure. 

While the goal is to end sidewalk riding, the reality is that stations are on the sidewalk and that riders are sometimes forced onto the sidewalk to get through unsafe pinch points where there is no safe place to ride. It is unclear how this technology works, and RPA has concerns that it could lead to unsafe situations and unfairly punish riders for the flaws in our street network and street design.

RPA tentatively supports Int 1004 and 1066 which require NYC DOT to make specific street design changes. These proposals should be amended to require the department to study which treatments are most effective and then include them in the Streets Plan.

RPA looks forward to continuing to partner with the Council and agencies to make sure the final legislation will truly address street safety while preserving access to micromobility as an accessible and affordable option for New Yorkers. Thank you.