Memorandum of Interpretation issued for dockless scooters, Detroit, MI, 2018

In July 2018, Detroit’s Department of Public Works issued a “Memorandum of Interpretation (MOI)” regarding dockless scooters. The MOI outlined the City definition of a scooter, and it clarified the sections of the city code that applied to them. For example, it limited the fleet size per operator and required specified distribution of the fleet between select neighborhoods.

Rather than pursuing a legislative or contractual strategy to regulate scooters, the City chose to issue a MOI, which aimed to provide a clear guide for how existing law should be applied to scooter-related operations. This approach allows the City to quickly and easily revise the interpretation to accommodate changing trends and needs going forward. However, the MOI does not have the same force as a new law enacted by the City. Nevertheless, Detroit has largely been pleased with the results of its approach; ridership increased in 2019 over 2018, and the average rides per scooter per day is nearly 3 times greater than what the City initially deemed to be the optimal level.