Chicago's ordinance O2022-2365 as amended, encoded as a clause register with Boyd Cohen's rulings of 2026-09-10, and run against 10,000 synthetic trips on a 3.977 km² sidewalk and crosswalk network. Trips are synthetic; the permit layer is illustrative; the records are unsigned: the verify command checks structure and determinism, not provenance. Engine @observer-protocol/policy-engine@1.0.0-rc.22; register digest sha256:7080e3500bb57f83606264e0ed9f3cfa83b835fdbe93ccc81803ba788eea7e91.
Synthetic trips, 10,000 of them, seed 20260909, drawn on 6,555 of 25,785 network edges classified sidewalk or crosswalk. Each edge is drawn in the one legend colour of the decision most trips traversing it received in the selected run; a tie goes to refuse over undetermined over allow. Undetermined has its own colour: it means the register could not decide, not that nothing was checked.
54 entries in 42 source sentences, each entry with its term at issue, ruled state, scope, and the ruling note where one exists. Ungrounded entries link to the gap they point at.
| layer, section | source sentence (verbatim) | entries: id, term at issue, state, scope, ruling note |
|---|---|---|
| L1 Section 2(a) | "Commissioner" means the City's Commissioner of Business Affairs and Consumer Protection. |
|
| L1 Section 2(a) | "Personal delivery device" means an electric-powered device that is intended to transport property primarily on areas normally designated for pedestrians. |
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| L1 Section 2(a) | "Personal delivery device operator" or "operator" means an individual who, through electronic communication, controls, or who monitors and has the ability to control, the movement of a personal delivery device. |
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| L1 Section 2(a) | A "personal delivery device operator" does not include an individual who requests the services of a personal delivery device. |
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| L1 Section 2(b), chapeau | Personal delivery devices on the public way shall operate only: |
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| L1 Section 2(b)(1) | after its personal delivery device operator has received a permit allowing their operation on the public way and within the geographic zones permitted by the Department of Business Affairs and Consumer Protection. |
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| L1 Section 2(b)(2) | on sidewalks and crosswalks. |
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| L1 Section 2(b)(3)(A) | in a manner that does not (A) endanger the health, safety, or welfare of any user of the public way. |
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| L1 Section 2(b)(3)(B) | in a manner that does not (B) unreasonably interfere with the use of the public way by others. |
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| L1 Section 2(c)(1) | obey all traffic control devices. |
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| L1 Section 2(c)(2) | yield the right-of-way to all other users of the public way. |
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| L1 Section 2(c)(3) | not transport hazardous materials in a quantity requiring placarding by a regulation issued under the Hazardous Material Transportation Act, 49 U.S.C. Section 5101, et seq. |
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| L1 Section 2(d)(1) | The Commissioner is authorized to promulgate rules or provide standards in any given emerging business permit's terms and conditions for commercial advertising on personal delivery devices, which may include an advertising permit application process, general safety standards, and associated fees. |
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| L1 Section 2(d)(2) | It is unlawful to display any commercial advertising on personal delivery devices in violation of the Commissioner's commercial advertising standards established pursuant to Section 2(d)(1) of this Ordinance. |
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| L1 Section 3 | Violation of the requirements of Section 2 may result in impoundment of a personal delivery device from the public way and prosecution in a court or administrative adjudicative agency. |
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| L1 Section 3 | Any permittee who violates this Ordinance or any rule promulgated hereunder shall be subject to a fine of not less than $500.00 and not more than $10,000.00 for each such violation. |
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| L1 Section 3 | Each day that any violation shall continue shall be deemed a separate and distinct offense. |
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| L1 Section 4(a) | Sections 1 and 2 of this ordinance shall take effect upon passage and approval. |
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| L1 Section 4(b) | Section 3 of this ordinance shall be in full force and effect 10 days following due passage and publication. |
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| L1 Section 4(c) | Sections 2 and 3 of this ordinance shall self-repeal on May 31, 2027. |
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| L1 Section 1, sentence 1 | Notwithstanding the 2-year limitation or renewal provision in subsection (d) of Section 4-4-022 of the Municipal Code of Chicago ("Code"), the Commissioner of Business Affairs and Consumer Protection is authorized to renew the emerging business permit issued to Cyan Robotics, Inc. on November 18, 2024, to operate a personal delivery device ("Emerging Business Permit") for an additional two years. |
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| L1 Section 1, sentence 2 | The Commissioner may attach conditions to the renewed term of the Emerging Business Permit as provided in 4-4-022(e) of the Code. |
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| L1 Section 1, sentence 3 | Except as otherwise provided in this Section 4 of this Ordinance, all applicable provisions of the Code and Rules promulgated thereunder, including Section 4-4-022, shall apply to the renewed Emerging Business Permit. |
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| L1 Section 5 | This ordinance shall be in full force and effect following due passage and approval. |
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| L2 (a) | In reviewing a license application, the commissioner shall determine whether a proposed business activity is an emerging business type or a non-traditional business activity that falls outside the parameters of any existing regulated business license under Chapter 4-6 or other specific license type under Title 4, and whether the proposed business activity presents potential risks to the public health, safety and welfare such that, for the protection of the public, the activity must be subject to more intense regulation than would be associated with a limited business license. |
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| L2 (b) | If the commissioner so determines, the commissioner may disapprove the license application. The applicant may seek a hearing on the disapproval pursuant to the procedures of Section 4-4-060. |
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| L2 (c) | In the alternative, the commissioner is authorized to grant an emerging business permit to the applicant to engage in the proposed business activity on an experimental basis. |
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| L2 (d) | The emerging business permit shall be non- renewable and valid for a maximum of two years. |
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| L2 (d) | The emerging business permit shall be a personal privilege and not property. |
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| L2 (d) | The emerging business permit shall not be transferrable to another location, person or business entity. |
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| L2 (d) | If the officers or owners of the business change, the emerging business permit shall immediately terminate unless the change has been approved in advance by the commissioner. |
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| L2 (e) | The commissioner may attach conditions to the emerging business permit as are reasonably required to protect the public health, safety and welfare from risks including, but not limited to: adverse impact on public health, public safety, increased demand on city services, increased environmental impacts, or increased traffic or congestion in the public way. |
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| L2 (e) | The commissioner may attach any such conditions when the emerging business permit is issued, or the commissioner may attach, remove or modify conditions at any time during the term of the permit, upon reasonable notice to the permit holder. |
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| L2 (f) | The commissioner may make a determination at any time during the term of the emerging business permit that the permitted business activity as conducted presents an unreasonable risk to the public health, safety and welfare which cannot be mitigated, and may rescind the emerging business permit, with or without prior notice. |
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| L2 (f) | If an emerging business permit is rescinded, the permit holder shall be given the opportunity to appear before the commissioner to contest the permit rescission before the rescission is effective or no later than ten days after the rescission is effective. |
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| L2 (g) | At the end of the term of the emerging business permit, the permit holder's permission to engage in the permitted business activity shall terminate unless (1) the City Council has established a new license category or amended an existing license category under which the permitted business activity may be licensed; and (2) the permit holder has applied for and obtained the necessary license. |
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| L2 (h) | When issuing an emerging business permit, and when attaching, removing or modifying conditions on an existing emerging business permit, the commissioner shall make a report to the license review advisory group and to the chairman of the city council committee on license and consumer protection or its successor committee describing the permitted business activity and the conditions imposed upon that activity. |
|
| L2 (i) | After three-fourths of the emerging business permit term has elapsed, the permit holder may submit a report to the commissioner and to the chairman of the city council committee on license and consumer protection or its successor committee requesting that a license category be created or amended to license the permitted business activity. The report shall describe the permitted business activity, the history of its operation under the emerging business permit, any disciplinary, legal or law enforcement problems that arose out of the permitted business activity, any positive or negative impacts of the permitted business activity on the public health, safety and welfare, and the public benefit derived from the permitted business activity. |
|
| L2 (i) | The city council may, in its discretion, elect to establish a new license category or amend an existing license category on the same or different terms as the emerging business permit. |
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| L2 (j) | Each application for an emerging business permit shall be considered independently. The issuance of an emerging business permit to an applicant, or the conditions imposed on a permit by the commissioner, shall not be precedent for the issuance of, or imposition of permit conditions upon, a similar emerging business permit to any other applicant or permit holder. |
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| L2 (k) | Operation of a business under an emerging business permit shall constitute acceptance of the terms and conditions of this ordinance, any applicable rules and regulations, and any special conditions of the permit. |
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| L2 (l) | The commissioner may issue rules and regulations to effectuate the purposes of this section. |
|
Shown as excluded: Section 1 (amending Municipal Code 9-4-010), different device class; not a PDD provision.
Trip SYN-TRIP-005478 from run A, decision refuse. Raw on the left, a plain reading on the right.
{
"record_id": "febc562c-1883-442a-aa67-9d22d10ae960",
"ts": "2026-09-10T01:05:53.459Z",
"principal": "register-v1",
"agent_id": "SYN-DEV-09",
"act": "pdd.trip",
"target": "SYN-TRIP-005478",
"run": "A-public-rules",
"decision": "refuse",
"checks_run": [
"L1-2b-1a",
"L1-2b-1b",
"L1-2b-2",
"L1-2b-3A",
"L1-2b-3B",
"L1-2c-1",
"L1-2c-2",
"L1-2c-3"
],
"clause_results": [
{
"clause_id": "L1-2b-1a",
"scope": "trip",
"result": "undetermined",
"because": "ruled undetermined: Who the permittee is. Section 2(a) defines the operator as an individual and 2(b)(1) says the operator receives the permit; section 4-4-022 issues an emerging business permit to a license applicant, which under section 4-4-050 may be an individual, a corporation, a partnership or a limited liability company; Section 3 fines any permittee, a word the ordinance never defines; the 2025 amendment's Section 1 renews a permit issued to a corporation."
},
{
"clause_id": "L1-2b-1b",
"scope": "trip",
"result": "undetermined",
"because": "ruled ungrounded: the geographic zones permitted by the Department of Business Affairs and Consumer Protection; A Department determination with no public locator: not in the ordinance, not in section 4-4-022, not on the Rules Portal (0 of 155 rules), not in any attachment to either Clerk matter. GAP-02."
},
{
"clause_id": "L1-2b-2",
"scope": "trip",
"result": "allow",
"because": "44 of 44 path edges are sidewalk or crosswalk"
},
{
"clause_id": "L1-2b-3A",
"scope": "trip",
"result": "undetermined",
"because": "ruled undetermined: What conduct endangers health, safety, or welfare; no definition, threshold, or measure is given, so the standard cannot be evaluated per trip without one."
},
{
"clause_id": "L1-2b-3B",
"scope": "trip",
"result": "undetermined",
"because": "ruled undetermined: What interference is unreasonable; no definition, threshold, or measure is given."
},
{
"clause_id": "L1-2c-1",
"scope": "trip",
"result": "refuse",
"because": "13 of 14 traffic control devices complied with"
},
{
"clause_id": "L1-2c-2",
"scope": "trip",
"result": "refuse",
"because": "yielded in 9 of 10 encounters"
},
{
"clause_id": "L1-2c-3",
"scope": "trip",
"result": "refuse",
"because": "cargo_class hazmat_placarded; placarding is required for hazmat_placarded and for nothing else"
}
],
"refusing_clauses": [
"L1-2c-1",
"L1-2c-2",
"L1-2c-3"
],
"undetermined_clauses": [
"L1-2b-1a",
"L1-2b-1b",
"L1-2b-3A",
"L1-2b-3B"
],
"applicability_stipulated": [
"L1-2a-3",
"L1-2a-4",
"L1-2a-5"
],
"framework_applied": [
"L1-2b-0",
"L1-4c"
],
"mandate_version": "register-v1",
"mandate_digest": "sha256:7080e3500bb57f83606264e0ed9f3cfa83b835fdbe93ccc81803ba788eea7e91",
"register_digest": "sha256:7080e3500bb57f83606264e0ed9f3cfa83b835fdbe93ccc81803ba788eea7e91",
"engine": "@observer-protocol/policy-engine@1.0.0-rc.22",
"rail": "stub",
"demo": true,
"synthetic": true,
"signed": false,
"unsigned_label": "unsigned: this verifies structure and determinism, not provenance",
"schema_version": "chicago-pdd-case.determination.v1",
"reason_code": "refused_by_clause",
"reason": "3 of 8 checks refused: L1-2c-1, L1-2c-2, L1-2c-3",
"content_digest": "sha256:d841a674d74737fed0dc8a37bf40433b0744a56d357953074d3c4a8ab9b72974"
}
Verify this run yourself:
node verify/verify.mjs runs/A-public-rulesEngine @observer-protocol/policy-engine@1.0.0-rc.22, tarball shasum 97ae4964bfde548a25e769a5f634be936f122427. Register digest sha256:7080e3500bb57f83606264e0ed9f3cfa83b835fdbe93ccc81803ba788eea7e91. unsigned: this verifies structure and determinism, not provenance.
The pinned engine supplied canonicalization and digests; the register evaluator lives in this repository at evaluate/ and is part of what verify checks. Evaluator evaluate/evaluate-trip.mjs, sha256 8edc15290c13c2bc9b65429e1f457ac2d80119b8c8a8646a94337ebb22b83dcd.
Device count: 10 devices in flight at peak of a limit of 30 (run C, fleet scope).
Injury reporting: post-event scope; 0 of 10,000 synthetic trip records carry a triggering event, so it is evaluated on none and listed on every record as such.
5 of 7 gaps shown under this filter; kept out: GAP-04, advertising standards bear on the device, not on a trip; GAP-06, the permit holder's own report decides nothing. All gaps.
Under the rules as written, no trip can be shown to be authorized: 0 of 10,000 in run A, 0 of 10,000 in run B. Three clauses block every trip. With three stated readings the city could adopt (run C), 2,503 of 10,000 are authorized. In run C the illustrative permit decides every trip: 2,503 of 10,000 authorized and 7,497 of 10,000 refused by a named condition — that is the permit working, not a failed fleet.
Of 8 clauses that decide a trip, public text lets a trip be evaluated on 4. The other 4 depend on a Department determination or a standard the ordinance does not define.
These are not rulings. They are readings a city could adopt; the register still records each question as undetermined.
If you hold permit conditions for a personal delivery device in any city, we can encode them and replace the illustrative file with your real authority. The result is a record of what your devices were authorized to do that a city can verify without you in the room. Write to fieldstudies@observerprotocol.org.