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Read the latest news from across the whole sector that highlights the development of affordable, accessible and low-carbon shared mobility

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articles - 21 Nov 2018

What would future mobility look like if designed by real people? Alistair Kirkbride for LTT Mobility Matters

I think the Spice Girls might help us plan the future of mobility. Like an earworm, “I’ll tell you what I want what I really really want…” keeps fusing in my head with me pondering where mobility might be heading.   I would hate to think where we would get to, but the future of mobility is repeatedly said to be service-led where the user is placed centrally in terms of shaping the services. What has been missing is real-world evidence that sets out what real users might actually want, rather than what practitioners might think they want. Clearly there needs some “curation” of competing demands, but that’s not for today. In the past year, a collection of rich evidence has started to emerge that might help sketch out the demands of real future travellers. Firstly, The Commission for Travel Demand’s “All Change” report looked in depth at evidence relating to changing travel demand, and was especially interested in unpicking blips from enduring change. And? People are travelling less, making fewer trips (especially commuting) and miles. Younger people are learning to drive later and are travelling much less by car for a variety of reasons. Figure 1 illustrates that two dimensions of this trend: it is more marked in more metropolitan areas and it is age related. Whilst it could be suggested that people drive more as they get older, Chatterjee et al’s 2018 work (LTTYYY) suggests that the effect is enduring; they showed that the suppression in driving license applications by young people endures as the cohort ages. So it looks like in a future mobility system, the private car won’t be anywhere near as dominant as today. Maybe they’ll all shift to AVs, but we’ll come back to that.   Marsden, G, et al. (2018) All Change? The future of travel demand and the implications for policy and planning, First Report of the Commission on Travel Demand, ISBN: 978-1-899650-83-5; http://www.demand.ac.uk/wp-content/uploads/2018/04/FutureTravel_report_final.pdf http://www.demand.ac.uk/wp-content/uploads/2018/05/FutureTravelDemand_infographic.pdf Chatterjee, K. et al. (2018). Young People’s Travel – What’s Changed and Why? Review and Analysis. Report to Department for Transport. UWE Bristol, UK
So how will people want to travel? MaaS gets a lot of press, but only recently are results of pilots emerging. These get interesting as they show what people actually choose and prioritise when services are presented side-by-side. The ESP group’s Navigogo project[1] involved target users – young adults in the Dundee and north Fife area – in the co-design of the Navigogo MaaS platform. The main demands were facilities such as personalised journey planners, deal matchers, easy payment and booking, information on destinations and taxi fare splitters i.e. facilities to make planning easy, reduce cost and reduce the sense of “missing out” on the best deals. This reflects Transport Focus’s 2018 work “Using the bus: what young people think”[2] (LTTZZZ). This showed that younger people (late teenagers) would like bus services to be easier to use (simpler fares, mobile tech for planning and ticketing), better value for money with better facilities for people to stay connected whilst travelling i.e. wifi and at-seat charging. The value of being connected trumping travel keeps coming to the fore in research. I recently took part in a workshop at a MaaS symposium that revealed some really interesting insight into our possible views on modes in a MaaS system. The participants (imagine those who attend MaaS symposia to gauge the nature of the sample) were asked to convert their existing mobility lifestyles to a private-car-free MaaS lifestyle, then score each mode by how pivotal it was (to make their MaaS work) and how attractive it was to them. And the answers? Though core public transport (intercity & local trains, buses, underground & trams) were pivotal, 1-way bikeshare was the second most attractive mode (after the underground), followed by trains (intercity, local) then 1-way car clubs. Interestingly, ride hailing came quite a way down the list. From a co-mobility / shared transport perspective, I clearly like to hear this, but what does it tell us about future mobility, especially if the user really is going to be more central in defining services?   If I was going to extract main attitudinal themes just from the above evidence to help define a mobility system, they would probably include the following. 1. Personal control of journey-making and personal space; 2. Value for money; 3. Simplicity, transparency & fairness, especially regarding cost; 4. Reliability & back-up service “insurance”. This isn’t new, but how do these translate to a mobility system?   Here’s one stab at translating what people seem to want into a mobility system:
  • mass transit would remain the backbone – both inter-city, inter-settlement and within cities & towns. It provides the efficiency to move lots of people along the main demand corridors in an affordable way.
  • demand-responsive & ride sharing services would both feed mass transit and to pick up the finer-grained matching between users that DR services are able to do.
  • point-to-point services (1-way car sharing, bike sharing, scooters and taxis (conventional or ride hailing)) would allow for journeys where larger scale matching isn’t viable – people or small groups want to go from point to point individually, either because the points are otherwise difficult to access or there are special circumstances (large loads, special needs etc)
  • back-to-base car (sharing/rental) and bike services would provide ways of people making independent back-to-base journeys over different timescales.
Of course, within all of this walking would be the main lubricant and mode for short journeys and linking other components. We can look to continental Europe to consider where private bike use might fit in; whilst we might be jealous of the levels of cycling in places such as Copenhagen, Amsterdam or Ghent, the rise of bike share is seen as a solution to tackle the associated bike parking problems, especially at rail stations in larger cities. Cycling will be a key component for providing local access in future mobility, and how this is split between bike share and private bike use will mainly be determined by type of place.   Let’s just pause and ponder where autonomous vehicles fit in to all of this. It could be argued that they provide independence, personal space and reliability (?). But will they ever manage to provide the VFM that most users would stand? And let’s not get into either the AV spatial efficiency debate nor the public & political acceptability of the constraints required to realise the benefits.   How many traps have I fallen into in writing this? The future is (definitely) uncertain, and setting out different scenarios probably more reasonable than just one. What about rural areas? Won’t peoples’ attitudes and demands evolve with the emergence of new types of services? Yes to all of these, but hopefully the trap that I have explicitly avoided is the future mobility landscape being defined by the disruptor-du-jour, but instead by real user preferences.   So what? Policy and investment need direction, hence why we see so many visions of future mobility scenarios.  Whilst “only a fool would make predictions – especially about the future” (Samuel Goldwyn apparently, or choose your own favourite quote about prediction), there is a difference between laying out visions of the “stuff” (what mobility services will exist) and how we might behave. It’s easier to generate visions & scenarios of “stuff” rather than behaviour. What I have stumbled through here is an attempt to get to some of the future “stuff” from what people are saying they want to use. Cause and effect get messy when we stretch timescales (but that’s for another day). There is currently a risk of the well-funded-disruptor-tail wagging they mobility dog, and what’s likely to happen being dismissed as not visionary enough. Worse still, somewhere in the midst of this, meaningful discussion on what is important to most people gets airbrushed out. Aditya Chakrabortty recently made the point (Guardian, 6th June) “Britons can throw tens of billions on infrastructure projects… or we can choose policies that serve the everyday economy that the rest of us actually live in”. Put another way, if you had a spare few hundred million quid to invest in a mobility system that would be used by most people in 10-20 year’s time and you read the “All change” report, what would you invest in?         [1] https://www.navigogo.co.uk/ [2] Transport Focus (2018) ‘Using the bus: what young people think’ https://www.transportfocus.org.uk/research-publications/publications/using-bus-young-people-think/
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Newsletter - 1 Jun 2018

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articles - 14 Nov 2017

Bike share: reaching people who could cycle, but don’t

Mobility Matters 11 November 2016 The bicycle is an incredible invention. It’s a social leveller, the second cheapest mode (after walking), leads to healthier people and cuts congestion and emissions. There are also still far more bikes in the world than cars. Rather than being displaced by the internal combustion engine, the humble bike is busy reinventing itself as an increasingly important component of future travel and future lifestyles.  
  Whilst there must be access for those who cannot walk or cycle, active travel has to be top of the list for planning local access. This year has seen the Government publish its Value of Cycling report, and the draft Cycling and Walking Investment Strategy. The case for cycling has never been better made.   But cycling is not one uniform activity. There are distinct bike-related cultures in the UK. People riding bikes as utility vehicles and the lycra-clad cycling devotee. From a professional point of view, they seem more like separate species linked at the bike-shaped genus level – maybe cyclum communalis vs cyclum individualis.   How do we reach out to those who might cycle, but don’t? Or those who don’t consider it an option, but could? In short, how do we cultivate the delicate flower that is cyclum communalis or, in transport speak, encourage a modal shift to cycling?   Bike share is an important tool for reaching this group. It consists of mainly public bike hire schemes such as those in London, Liverpool and Glasgow, and also includes bike pools in workplaces or communities and bike hire from rail stations.   A key market for public bike share schemes is people making first or last-mile links with public transport hubs. Many of these people have one or more bikes at home, but they either do not want or can’t use their own bikes for these journeys. This alone probably justifies public bike hire becoming a norm in all urban areas.   Public bike share also reaches a different demographic: people who might cycle but don’t. The most recent research for Transport for London shows that 38% of users were prompted to start cycling by Santander Cycles.   Giving people the option of an electric bike opens access to bikes further. This is not a new idea. Bike share and electric bikes (plus leisure cycling) were all recognised as significant agents in expanding the reach of cycling through the DfT’s Cycle Demonstration Towns, in the latter stages of Cycling England’s work and through the initial results from the Finding New Solutions programme.   Both bike share and electric bikes remove significant known barriers to cycling. Bike share provides access to bikes with no commitment or need for investment or maintenance. Electric-assist bikes ‘iron out’ hills, encourage novice cyclists to give cycling a go, as well as encouraging cycling for longer distances. Whilst these benefits are concrete and obvious, their real value is more subtle and is reflected in the joyful reactions as people try an electric-assist bike for the first time.   The anecdotes are supported by the initial findings of the DfT-funded Shared Electric Bike Programme to be published shortly. In addition, the recent Cycleboom project shows impressive physical and mental health impacts of older people using electric bikes. This highlights an otherwise elusive win; health benefits in a non-traditional cycling user group. In short, people riding electric bikes without having to purchase one were happier and healthier. Scaling this up by making electric bikes available through various bikeshare models would be incredibly simple to do.   A big challenge in “cycling” is in normalising it in the public mind. This requires a change in people’s attitudes to cycling – which we are seeing happening – and then this translating to a shift in individual’s behaviours.   For bike share, it requires planners, policy-makers, advisers, fleet managers and communities to be aware of what’s possible, how to make it work and what the impacts are likely to be. It also requires some re-framing of language and approach – it’s about investing in health benefits, accessibility, social inclusion and reductions in congestion and emissions rather than subsidising a bike hire scheme.  
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articles - 25 Oct 2017

Mobility as a Service – why people are just getting on with it, writes Alistair Kirkbride

Going to conferences is a bit like going on holiday. You try to work out how it’s going to unfold and what it’ll be like by reading blurb, but it’s the sense that emerges that is important to try to capture. My “holiday snaps” from the recent Smarter Travel Live 2017 conference [1] were: bike share is exploding, Local Authorities don’t go to conferences at the moment and MaaS is flexing its muscle as the idea grows and differentiates. Bike share covered several pages in the last LTT [ref], the drought of Local Authority engagement is telling (but of what?), but let’s focus here on the evolution of MaaS.
    Whether MaaS is a platform or a way of thinking was well debated at Wocomoco 2016 [2] and elsewhere. Over the last year, the West Midlands pilot of Whim [3] is demonstrating that it is possible for MaaS to exist in the UK regulatory framework, not that it won’t identify snags that will need some work to resolve. The recent Landor MaaS survey publication demonstrates neatly the differentiation of the core idea of MaaS into multiple scales and contexts. The recent launch of MaaS Scotland [4] shows the rapid shift to a nation-scale swagger of the idea. Perhaps more importantly, MaaS Scotland is almost explicit in not trying to define how it will unfold; this in itself is significant as it demonstrates the wide opportunity for the shaping of future mobility. UITP held a workshop on MaaS at the same time as Smarter Travel Live.   So MaaS is everywhere. Or is it? Let’s look at three aspects that were implicitly on show at ST Live: MaaS defined by outcomes, “Just get on with it” MaaS and “boutique” MaaS.   Firstly, it was refreshing – and somewhat relieving – to hear an increasingly coherent debate about how public benefit needs to define how MaaS unfolds. Like autonomous vehicle development, the sector is asking how pubic benefit will be realised through MaaS, and who will be responsible for delivering the (non-commercial) outcomes. The debate is still live as to the role of the public sector in MaaS development: as the MaaS operator (unlikely) or as the body that sets parameters (via regulation or licensing of some form; desirable but deliverable?). There is an awareness that the public sector having to play catch-up to innovations that head in the wrong direction (such as Uber) is undesirable, and can still be averted. The West Midlands Whim pilot and MaaS Scotland both demonstrate constructive partnerships between the public and private sector who together can help shape the path between innovative idea and useful agent for how people travel. The approaches might be different (a small scale pilot vs a strategic national-scale partnership), but the core idea of mixing what is best about public and private sector approaches and roles is common to both.   What is not yet resolved is a clear understanding of what a MaaS future means in terms of tackling existing social and environmental problems of and related to transport. Like many innovations, MaaS can frame compelling pictures of a better future; realising these will still need some pretty meaty intervention and hard political decisions, as well as the public coming round to the idea of behaving differently. The ITF Transition to Shared Mobility study [5] demonstrated the (modelled) scale of benefits of radical shared mobility in Lisbon on access and environment. More importantly, it also highlighted explicitly what would be necessary to realise the benefits. This has not yet been done for MaaS.   The second MaaS development – spelt out in the Landor MaaS survey – was more of a realisation of “just getting on with it”. There was a quip at Smarter Travel Live that if we waited to get all of our ducks in a row on MaaS, they would be swept away by the Next Big Thing. As the idea of MaaS has emerged, there has been a sense that we were going to have to wait for something(s) to happen before MaaS would be a reality. This might have involved city-wide co-ordination or vision, the realisation of bottom-line benefit among operators or the confidence among MaaS advocates that the public was ready for it. There has perhaps also been an implicit sense that MaaS needed to be “MaaS-pure” – the idea of a mobility account that really is competitive with car ownership in terms of cost and convenience. Waiting for utopia can be at best stifling, and worse used as a mandate to not do anything. Just getting on with it is the license to work within and towards the idea of MaaS, but not to be constrained by MaaS-pure.   “Just getting on with it” can mean many things. The West Midlands WhimApp pilot shows that with the following wind of a committed local public sector, “pure” MaaS can be realised in the UK, if on a small initial scale. Landor’s annual survey of MaaS included examples of where mobility accounts can work fairly easily in a variety of closed contexts such as workplaces. Indeed, shifting to MaaS-type mobility accounts for employee travel provides a new set of opportunities to maximise reductions in environmental impacts of travel choices.    
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articles - 17 Aug 2017

The end of diesel & petrol cars? What about changing mobility? Writes Alistair Kirkbride

  Last week, the press was aflutter with the headline grabbing announcement of the demise of not just diesel cars, but petrol by 2040 to help tackle the UKs air quality problems. This might be great for all sorts of reasons – if a little late – but will the lights stay on? And is this the right way of looking at the urgency of today’s urban air quality crisis anyway?   The Government’s announcement continues the near-fetishism with car ownership, perhaps wrapped this time in the Industrial Strategy, but always in denial of developing a modern mobility system that fits the 21st century that is not based around the flawed 20th century idea of car ownership. Mobility matters (to coin a phrase).    
  But let’s consider this first in terms of the gritty pragmatism of whether it’s even possible to electrify all car travel anyway. Even with the grid getting smarter and generation becoming localised, there are serious misgivings about adding a whole new sector (car travel) to an already strained electricity and distribution network. While the National Grid in its Future Energy Scenarios 2017 [1] suggests that the projected growth in EVs is (just?) possible in terms of impact on generation and distribution, this was before the announcements of no petrol or diesel cars after 2040. Serious misgivings have been voiced elsewhere – such as Green Alliance’s ‘People Power – How consumer choice is changing the UK energy system’ [2] on peak loading and the impacts of EV charging clustering leading to “brownouts”, all of which points to the need for some pretty serious upgrading of the grid to accommodate the proposed numbers of EVs.   Smart grids, targeted upgrading and the use of storage (including in EV batteries) to manage peaks are all possible and compelling, but do we need to take this approach? If access to clean electricity is likely to be limited, then the shift to EVs should be in city centres in shared contexts in order to tackle immediate air quality problems.   If we step back and consider what we are trying to achieve, then my question is whether we are taking seriously the potential of new mobility systems and new behaviours instead of being blinded by drivetrain technology, tailpipe emissions and car ownership.   The two figures are from analysis of MOT data by the www.MOTproject.net [3]. Let’s make an assumption that energy use can be taken as a proxy for overall emissions; these charts show that total emissions are more closely related to how far people travel per year than how clean their cars are. In short, to tackle emissions, we need to get to grips with demand.   Tackling demand is too often seen as being in the “too hot to handle” box. Why?   It’s increasing clear that there are fairly fundamental shifts in travel behaviour. This is often associated with the replacement of the right-of-passage of getting a car with the desire to keep connected.  
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articles - 7 Jun 2017

What proportion of the population can shared transport appeal to? Writes Alistair Kirkbride: LTT Mobility Matters

Who travels how? As we consider new models of mobility – whether these are autonomous vehicles or Mobility as a Service packages – perhaps the more interesting question is, who is likely to travel how in the future? Put another way, of the people you know, how might they be travelling in 5 or 10 year’s time?  
  In the housing sector, an oft-overlooked likelihood is that about 80% of 2050’s housing stock has already been built [1]. In a similar vein, how similar will be people’s mobility lifestyles be in 2050 to now? Who (and how many) might be travelling differently – but more importantly, who won’t be. While we can’t know the answer to this, we canexplore who is currently changing behaviour.   The last 15 years has also led to a much clearer understanding of the sorts of people that use sustainable transport. This is mainly due to the of Government initiatives such as the DfT Sustainable Travel Towns and Local Sustainable Transport Fund programmes, and Scotland’s Smarter Choices, Smarter Places. This has still not been brought together into an evidence-based coherent understanding of future mobility lifestyles. As a complement to this, having good data regarding types of users of shared transport. Spoiler alert – car club use is fairly socially filtered but widening, bikeshare (and especially electric bikes) seems to appeal to a wider demographic than cycling more generally. So who does – and doesn’t – use shared transport, and what might we take from this knowledge regarding broader understanding and influence over how people might travel in the future?   The Table shows that the majority of types of people that currently use car clubs come from a minority of the types of people in the UK population. Perhaps more interesting is the differences between the places: is the wider range of types of people in Scotland’s car clubs a result of the very deliberate intervention and support by the Scottish Government since 2010? Is the narrower range of types in London due to the dominance of the commercial focus of London operations and development? If this is the case, then it is a strong case for public sector intervention to ensure that the benefits of car clubs are spread fairly – across types of users and places.   X% of car club users come from Y Mosaic groups (of 66); these groups account for Z% of the population (Data from Carplus Car Club Annual Survey, 2016)            
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articles - 9 Mar 2017

LTT Comment: Are changes in how we travel bound to reduce social mixing?

Mobility matters 3rd March 2017 Life used to be simple in the transport world. People generally owned cars, used public transport or walked and cycled. OK, I am guilty of opening with what is probably a false premise, but stick with me for now. As the boundaries between private and public transport blur through the emergence of shared models and new forms of ownership, maybe the discussion could shift to private and public spaces of travel. Put another way, if the future means that we summon pods to whisk us to our destination, what have we lost through not mingling with other people on the way?
  What makes a great place? The diagram above demonstrates that a significant part of “great places” involve social contact.   Given free choice, would more (most?) people choose to travel in their own private space than mix with strangers? For anyone who has been skiing, waiting in line for a 6-person gondola is an interesting social experiment: I’d suggest most people secretly hope that the “strangers” behind choose to take the next gondola; get on any busy-and-getting-busier bus or train, and people fill the empty seats first; Jonathan Dunne, the originator of the 2016 “Tube Chat” campaign that aims to get people talking to each other on the London Underground, suggests that about 80% of people think its “terrible, the worst idea ever”.   So are we really social animals? Or does it just need a rethink when we consider transport?   Looking back to the rise of the private car, two of the key drivers for its popularity (ignoring for now issues of affordability or social norms) were the promise of independence of journey making plus the privacy of the capsule.   Robin Chase’s brilliant video of the heaven or hell future scenarios for autonomous vehicles only touches on the idea of social mixing. In the changing world of mobility and the rise of new ways of travelling, should(n’t) we be focussing a bit more on this? The risk of not doing may inadvertently lead us into a form of hell where increasing numbers of people mix even less with others from outside their chosen social bubbles.   Social mixing has been considered in great detail in relation to things that don’t move, but seems to largely to have evaded moving spaces aka transport or mobility.   The approach to design of public realm usually considers social mixing explicitly; this often involves not just how people pass through, but about creating places and opportunities for pausing as well as managing mixing. The explicit development of mixing spaces is a core part of more radical interventions as outlined in Charles Montgomery’s Happy City (2015), as well as the UK’s Home zones and other traffic calmed and traffic free areas.   Perhaps the most obvious sector where social mixing is made explicit is in relation to housing. From the benefits of deliberately designing-in mixed tenures, scale and values of housing in development to the issues of gated communities and social exclusion, the mixing of types of people is a big issue in property development.  Danish Architect Jan Gehl’s recent observations on the social problems of skyscraper living is neatly summarised as “stacking people on shelves is a very efficient method of human isolation” and the observation that “we have seen in the past 20 years a withdrawal from society into the private sphere”. The architecture literature is crammed with classic (if somewhat impenetrable) tomes relating to the design of social interaction including Bachelard’s “The Poetics of Space” (1958), Lefebvre’s “The Production of Space” (1991).  
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articles - 7 Feb 2017

LTT Comment: Could regulation deliver public good and trigger vitality in the new mobility sector?

  Mobility Matters February 2017 The relationship and role between the public and private sector keeps rearing its head as the mobility world develops. Court cases between public sector bodies and Uber, or the lack of meshing between fast-evolving carsharing operators and London Boroughs make the national press. The subtext is often “cash rich young guns outpace conservative old guard”. However, even though the vast majority of people and things that move do so in “traditional” ways, the new and disruptive operations are all predicted to become major players and are already having major influence on the new mobility landscape.
  If we scratch underneath the headlines, what do they say about the growth pains of “new mobility” and how might these get resolved? Is it possible for the private sector’s profit-led drivers (or at least race to viability) to mesh with the public sector’s responsibility to deliver public good for mutual benefit? What might this world look like?   This raises two relevant concepts – viewing transport as a utility (and hence whether the regulatory and governance models of other utilities might illuminate the future direction of “new mobility”) and the Porter hypothesis. Exploring these together might help us understand some of the questions around regulation and fast-moving disruptive mobility services.   Let’s start with the Porter hypothesis.   In its pure form, this says that strict environmental regulations can reduce inefficiency and encourage innovation which improves commercial competitiveness. When proposed (in 1995), it was seen in some quarters as turning prevailing economic theory on its head. The idea of constraining markets through regulation to trigger growth flew in the face of the predominant economic and political dogma of the time. However, its core idea seems to have survived subsequent critiques and reviews pretty much intact, and its application has been stretched to relative competitiveness of whole countries.   So let’s apply the idea to the relationship between the public sector – via regulation and policy – and the disruptive private sector mobility operators. This leads to a couple of useful questions. Firstly, could more – or better – policy and regulation lead to efficiency, innovation and competitiveness in the new mobility sector? The car sharing sector is pretty much unregulated. Quality assurance is provided by the Carplus accreditation scheme or BVRLA membership, and is used by the public sector to determine whether to enter into contractual arrangements with operators. But if we look at London, there are significant differences in how car sharing is implemented in different boroughs, and this is microcosm of the rest of the UK. This is currently limiting the sector’s ability to realise the scale of potential “public good” benefits that could be delivered.   Secondly – and more importantly for the purposes of this argument – would increased efficiency, innovation and competitiveness in this sector enhance public good?   Brought together, these two questions frame the sort of regulatory constraints that might lead to better outcomes.   Alongside the Porter hypothesis, let’s also look at what we can learn from how utilities are regulated. Might utility regulation contribute to a new framework?   Is it appropriate to consider mobility as a utility? A quick trawl provides fairly clear definitions of what constitutes a public utility as “…a business that furnishes an everyday necessity to the public at large. Public utilities provide water, electricity, natural gas, telephone service, and other essentials. Utilities may be publicly or privately owned, but most are operated as private businesses” .   The ongoing shift to people consuming mobility services – and the subsequent challenges being addressed here relating to regulation – suggest that there is at least some mandate to follow this argument. This is interesting when we consider how other utilities are regulated in relation to mobility.   The UK’s system of regulation means that each sector has its Regulatory Office – Ofgem, Ofcom etc. “Ofmob” might not win any points for graceful branding, but let’s consider it for the new mobility sector. If we look at Ofcom for guidance, its purposes are to “… make sure that people in the UK get the best from their communications services and are protected from scams and sharp practices, while ensuring that competition can thrive.” Furthermore, “Ofcom’s principal duty is to further the interests of citizens and of consumers”. These purposes and focus are shared by the other regulatory bodies, if the way in which they carry out their duties vary.  
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