The first U.S. state statutes for certificate of public convenience ( CPCN ) were issued in 1870 .
The U.S. Congress included a certification provision in U.S. federal law in the Transportation Act of 1920 .
The first U.S. state statutes for certificate of public convenience ( CPCN ) were issued in 1870 , and the U.S. Congress included a certification provision in U.S. federal law in the Transportation Act of 1920 .