“Unbanked people should be able to rent scooters with EBT cards.”
Dear Dockless Scooter Share Companies,
In this short open letter, we make the case that unbanked people are the very people who can most benefit from new and emerging mobility services. We also point out that unbanked people, precisely because they are unbanked, often face the largest barriers to the adoption of such services. We then suggest the use of government EBT (Electronic Benefit Transfer) cards as a simple and equitable solution to this dilemma.
According to the FDIC, unbanked people tend to be people of color, people experiencing poverty, and immigrants.  In addition, people of color, people experiencing poverty, and immigrants are also the most prolific users of public transportation. 
Therefore, there is a large correlation between being (1) a person who is unbanked, (2) being a person of color, and/or a person experiencing poverty, and/or an immigrant, and (3) being a person who uses public transportation.
For these three overlapping groups, public transportation is essential – not only to their physical mobility, but also to their upward mobility. In fact “[t]he relationship between transportation and social mobility is stronger than that between mobility and several other factors, like crime, elementary-school test scores or the percentage of two-parent families in a community.” 
Given the above, it is not hard to see that public transportation is a crucial lifeline for people who are unbanked, people of color, people experiencing poverty, immigrants, and others who are economically and socially marginalized.
Unfortunately, the people who use public transportation the most, and who need it the most, are also the very people who most often have the hardest time accessing public transportation.
“[M]any low-income individuals and households [including the unbanked] fall into the geographic gaps between bus and rail lines and are therefore largely excluded from the connectionsthat public transit provides. The result is that jobs, education, and health care services located only a few miles away are often out of reach for low-income families, especially those that lack access to a car.” 
In addition, because people of color, people experiencing poverty, and immigrants own cars and drivers licenses at a lower rate, public transportation is often their only option. 
This creates a catch-22 in that the people who most need the benefits of social mobility, are also the people who often lack the “last mile” access to public transportation.  Therefore, in addition to pre-existing social and economic marginalization, these people are also geographicallysevered from opportunity.
THE EMERGING MOBILITY OPPORTUNITY AND ITS CHALLENGE
The good news is that emerging mobility services can bridge that gap.
We therefore agree with the following statement from SFMTA’s recent Emerging Mobility Evaluation:
“Emerging Mobility Services and Technologies must promote equitable access to services. All people, regardless of age, race, color, gender, sexual orientation and identity, national origin, religion, or any other protected category, should benefit from Emerging Mobility Services and Technologies, and groups who have historically lacked access to mobility benefits must be prioritized and should benefit most.” 
However, unlike legacy public transportation services, which can still be purchased with cash, emerging mobility solutions are generally cashless. This presents a serious barrier to people who are unbanked. In fact, in SFMTA’s Emerging Mobility Evaluation Report, one of the key criteria for evaluating equity is to look at options and preferences for people who are unbanked:
“Access for the unbanked: How many people do not have bank accounts? What payment options are preferred by people who do not have bank accounts? What kinds of policies could enable access to emerging mobility services by the unbanked?” Ibid.
THE SOLUTION IS EBT (“ELECTRONIC BENEFIT TRANSFER”) CARDS
There is a simple policy solution to all of this. . .
People here in California who are receiving almost any kind of state or federal cash benefits already have access to a cashless payment service. That service is in the form of an EBT (“Electronic Benefit Transfer”) card. These cards are identical to credit cards, and are processed through the same data network via Quest. 
While some people may be aware that these cards can be used to pay for food items via the federal SNAP program, they may not be aware that many other forms of benefits are also loaded onto these cards. For example, General Assistance benefits are loaded onto EBT cards. As are CalWORKS benefits.  The recipient of these benefits uses their EBT card the same as they would use any prepaid debit card. Any store that is linked into the Quest network can accept EBT cards for cash(non-SNAP) benefits. The store does not need to be a grocery store. 
As this letter is being written, SFTMA is still evaluating Dockless Scooter Share Permit applications. We have reviewed all 12 applications.
The 12 scooter share companies who have applied have all made sincere attempts to devise various schemes which would allow unbanked people to rent dockless scooters. These schemes all involve requiring the user to find and visit a brick and mortar location where the user can pay cash.
Thus, for someone who lacks access to last mile transportation, a second kind of catch-22 problem attaches to these well-intentioned schemes. That is, someone may have to walk a great distance, then board a bus across town to a brick and mortar location to pay cash for a scooter ride that may be only a couple of blocks long.
By having an option to pay for a discounted scooter rental via EBT card, a scooter company would instantly know that the user is low income. This would actually solve two problems: (1) ascertaining whether someone is entitled to a low-income discount, and (2) providing services to the unbanked.
In addition, the user could use the standard scooter share app in the same way as a banked user. The onboarding process would be the exact same. No more taking a bus to a brick and mortar. This would save onboarding time on the user end, and administrative costs and overhead the scooter share company end.
We think that the renting of dockless electric scooters with EBT cards will lead to more widespread adoption of dockless electric scooter use among the people who could most benefit from this new emerging technology.
This benefits everyone.
 “FDIC National Survey of Unbanked and Underbanked Households.” Federal Deposit Insurance Corporation, 2016, www.fdic.gov/householdsurvey/2015/2015report.pdf.See also: “FDIC – Place Data.” EconomicInclusion.gov, FEDERAL DEPOSIT INSURANCE CORPORATION, 2016, www.economicinclusion.gov/surveys/place-data.html?where=San_Francisco_Oakland_Fremont_CA.
 Anderson, Monica. “Who Relies on Public Transit in the U.S.” Pew Research Center, Pew Research Center, 7 Apr. 2016, www.pewresearch.org/fact-tank/2016/04/07/who-relies-on-public-transit-in-the-u-s/.
 Bouchard, Mikayla. “Transportation Emerges as Crucial to Escaping Poverty.” The New York Times, The New York Times, 7 May 2015, www.nytimes.com/2015/05/07/upshot/transportation-emerges-as-crucial-to-escaping-poverty.html?_r=1.
 DeGood, Kevin, and Andrew Schwartz. “Can New Transportation Technologies Improve Equity and Access to Opportunity?” Center for American Progress, 2016, www.americanprogress.org/issues/economy/reports/2016/04/27/135425/can-new-transportation-technologies-improve-equity-and-access-to-opportunity/.
 “ Commuting in America 2013.” Transportation.org, American Association of State Highway and Transportation Officials, 2013, traveltrends.transportation.org/Documents/B7_Vehicle%20and%20Transit%20Availability_CA07-4_web.pdf.
 DeGood, Kevin, and Andrew Schwartz, ibid.
 “Emerging Mobility Evaluation Report.” Sfmta.com, 2018, www.sfmta.com/sites/default/files/reports-and-documents/2018/05/6-7-18_cac_item_7_emerging_mobility_evaluation_report.pdf.
 Welcome to Quest® | NACHA, web.nacha.org/quest.
 “CalWORKs.” Wikipedia, Wikimedia Foundation, 21 July 2018, en.wikipedia.org/wiki/CalWORKs, and “Electronic Benefit Transfer.” Wikipedia, Wikimedia Foundation, 3 July 2018, en.wikipedia.org/wiki/Electronic_benefit_transfer.
 California, State of. “Merchant Questions and Answers.” California EBT Project Office, 2018, www.ebtproject.ca.gov/CommercialInformation/commercialFaq.shtml.