AVs Archives - Transportation For America

AVs aren’t solving our transportation problems. They’re automating them.

A car rests just before a crosswalk on a wide roadway

Autonomous vehicles (AVs) have been dangled as a transportation “silver bullet” for decades. Now, they’re finally operating as robo-taxis in San Francisco. However, the Bay Area’s experience with these vehicles so far shows that it’s our reliance on cars—not who’s behind the wheel—that’s our most pressing problem.

On August 10, the California Public Utilities Commission (CPUC) voted to allow two autonomous vehicle (AV) companies to operate robo-taxis in San Francisco 24 hours a day and charge for the rides. This decision came despite significant, wide-ranging opposition, brought up before the hearing and highlighted during. As part of limited, fare-free pilots conducted by these companies, San Franciscans have experienced exactly the chaos that replacing imperfect humans with impartial computers was supposed to solve.

This decision by the CPUC is a continuation of the mistakes we’ve made with our transportation systems for the past century. AVs are assumed to be the solution to dangerous streets, traffic congestion, and transportation emissions. Unfortunately, as they’re set up right now, AVs are nothing more than a distraction from the policy changes that would make our transportation system safer, more equitable, and more sustainable.

The unmet promise of automating transportation

Automating transportation isn’t a bad idea. In fact, automated transportation has existed for decades, in the form of public transit. Automated metros in places like Tokyo, Vancouver, and now even Montreal and Honolulu move millions of people every day around the globe. At airports across the U.S. you can also find automated “people movers” helping people move between terminals and access local transportation options. These technologies are highly regulated and implemented with a clear purpose: they reduce operating costs while increasing the capacity of public transit, allowing more people to travel.

For nearly a century now, car-makers have been arguing that automation could similarly revolutionize car travel. As historian Peter Norton has described, the automobile industry has depicted self-driving cars as a generation away for the past several decades. For people who can’t drive due to a disability, people too old to drive, people too young to drive, and people who simply don’t want to drive, this technology would be transformative.

Unfortunately, even if this future were as close as it seems, it may not live up to its promise. According to an advertisement by Cruise—one of the two companies now operating robo-taxis in San Francisco—if their technology was behind the wheel instead of humans, we would have far fewer deaths on our roadways because their products are “designed to save lives.”

This contrasts with reporting and data collected by the National Highway Traffic Safety Administration (NHTSA) highlighting that AVs are certainly still involved in crashes, many of which result in serious injuries and fatalities. San Francisco’s experience as an AV-guinea pig provides some data on crashes and some insight into AVs’ current flaws. There are documented cases of AVs driving away from police, cruising down sidewalks, and coming to a dead halt when cell service is bad. While AV makers say these are anomalies, without data from the companies to disprove this we can only believe what we see plainly before us.

Beyond safety, AV proponents also promise less wasted time. With our cars driving themselves, we will be able to travel everywhere we need to go while still being able to work, catch up with friends and loved ones, or just relax from inside a car. However, this argument assumes that the amount we drive stays the same, an unlikely scenario when driving no longer requires anybody actually driving. In fact, research replicating an AV future and an analysis of data from existing partially automated driving technology show that AVs will lead people to spend significantly more time on car travel.

This additional time spent in a car also threatens to torpedo any hopes of a more sustainable transportation system. No matter whether AVs are electric or not, a future with more driving would still involve more extraction of natural resources and more pollution from tires and brakes. We will never reach ambitious climate targets with a transportation system that requires people to drive more, not less.

Promising a technological solution to a political problem—and then using political will to force their solution on society—is a consistent behavior of the auto-industry. In the 1920s, the industry knew that their products were killing children and congesting city streets. But instead of changing their products, they changed our communities. They created and supported the policies that have destroyed vibrant neighborhoods and displaced their residents, emitted huge amounts of carbon, and killed tens of thousands of us every year. That’s not innovation, it’s exploitation.

Selling us a bill of hoods

If AVs were being pursued because they were the most effective way to help people who will never be able to drive, maintain mobility for aging members of our communities, and save lives, we would all welcome them with open arms. That’s why the Advocates for Highway and Auto Safety have released a list of tenets, which Transportation for America has signed on to, to guide an introduction of AVs into our vehicle fleet.

These guardrails aren’t an attempt to stop us from getting to a self-driving future. These policies are what’s required to ensure that the future includes everybody, including those outside of a car. That’s why individuals and advocacy organizations who exist to make transportation safer have made it clear: without changes to transportation policy, AVs aren’t set up to solve our problems, just automate them.

Right now, AV-makers would have us believe that all of our transportation concerns will go away if we simply replace human drivers with computers. But we know this is not true. Automation that leads to more driving will not reduce congestion or emissions. It will not free people from increasingly long trips to reach their essential destinations. It will not relieve people of the financial burden of car ownership. And it will not change the dangerous design of our roadways, which encourages high vehicle speeds at the cost of pedestrian safety. If we continue to give AV-makers free reign, without government regulation and data collection to understand their impact on our roadways, we will not get any closer to solving the problems AVs are supposedly ready to solve.

AV-makers—including the robo taxi companies in San Francisco —aren’t trying to solve these problems. They’re just trying to sell us cars.

Ten things to know about USDOT’s new framework to guide the future of automated vehicles

The USDOT’s newly released policy guidance for automated vehicles is consistent with Congress’ attempts to limit regulations and give private industry carte blanche to operate mostly in secret with little public oversight.

Recently, the U.S. Department of Transportation (USDOT) released Preparing for the Future of Transportation: Automated Vehicles 3.0, the Department’s latest effort to try and describe a plan for integrating automated vehicles. This updated version of 2017’s Automated Driving Systems 2.0: A Vision for Safety fails to answer basic questions, leaves local communities with few tools to safely integrate this technology onto their roads, and puts private industry in control of what data local communities can access about automated vehicles.

This policy guidance is voluntary, but it does start to provide a big-picture view of how USDOT is approaching this emerging industry at the same time that Congress is trying to pass their first comprehensive law to regulate it. Here are 10 key things you need to know about this guidance:

1) USDOT is doing nothing to help states and cities receive vital data on AV operations

Local governments recognize that in order to properly manage their roadways, ensure safety for all, and provide service to the residents who face the most transportation barriers (low-income people, communities of color, and people with disabilities), they need data on operations and travel patterns of automated vehicles. Yet this guidance is virtually silent on this critical issue, only restating the principles outlined in 2.0 for developing “voluntary data exchanges.”

This is simply unacceptable.

Without a robust federal framework to set expectations and requirements for sharing data, the likeliest outcome is that local communities will be pitted against each other in a race to the bottom to attract AV companies by enacting little to no regulation, thus ensuring the public will stay in the dark about AV deployment on their local roadways, leaving millions of Americans in harm’s way. Such was the case with Arizona’s move to create a highly permissive and opaque regulatory climate, where a pedestrian was struck and killed by an automated Uber earlier this year.

2) Public safety officials will be left in the dark

Tacked onto the very end of the guidance is a section in which USDOT encourages “engagement” with first responders and public safety officials. However, once again, the guidance does not provide any instruction or best practices for how manufacturers, communities, and public safety officials should engage with one another. Further, without access to data, public safety officials will have zero idea about how these vehicles are operating and will likely be unable to fully execute their responsibilities.

3) It ignores the impact on land use and curb space in cities

The guidance contains 120 words on two of the most pressing impacts of automated vehicles for cities: land use and curb space. Continuing with the theme, the guidance tells cities to consider the implications of automated vehicles on the built environment, but doesn’t provide cities any of the tools (like data) necessary to do so.

4) Automation will almost certainly increase congestion, but that’s just a problem for cities to figure out on their own

The guidance contains even fewer words—only 85!—on the congestion impacts of automated vehicles. USDOT correctly notes that automated vehicles can create an entirely new problem of zero occupancy vehicle trips and potentially drive riders away from transit, further increasing vehicle miles traveled and road congestion, but does little to even start a discussion about how to deploy AVs without increasing congestion. A study from the SFCTA released just a few weeks ago noted that the overwhelming majority of new congestion on San Francisco County’s streets are due to ridesourcing companies, the same companies most eager to deploy AVs on a wide scale. We are working hard through our Smart Cities Collaborative to help communities plan for integrating automated technology without increasing congestion, but communities need USDOT to provide more than a one-paragraph acknowledgement that there may be an issue.

NTSB investigators in Arizona examining the automated Volvo operated by Uber that killed a pedestrian. Photo by the NTSB.

5) Safety assessments are still voluntary—and not that helpful

Previous iterations of federal AV guidance encouraged manufacturers to provide “voluntary safety assessments” to help build “public trust, acceptance, and confidence through transparent testing and deployment of ADSs [automated driving systems].”

If you tell your kids that making their beds is voluntary, do you think most will still go to the trouble? Only a few of the companies that are testing have even met this low bar, and most are just glossy marketing docs with little to no substantive information. This new guidance encourages manufacturers to make these voluntary safety assessments public, but if a manufacturer fails to provide a useful assessment and make it easy for the public to find and understand, there are no repercussions. It’s also important to note that the template from NHTSA isn’t really asking for the kind of information that would be most helpful for the public.

6) USDOT will adapt definitions for “driver” and ”operator” to incorporate driverless vehicles, but crucially fails to define “performance.”

This action, while a potentially useful step that recognizes a changing world, does not address an even bigger question about terminology: how to interpret the word “performance”. Why is the definition of this single word important? The AV legislation currently being considered by Congress (The AV Start Act) would preempt most state and local laws and regulations that affect the “design, construction, or performance” of a highly automated vehicle or automated driving system.

“Performance” has traditionally referred to the mechanical operation of a vehicle or vehicle component. But now, given that the driver of AVs will be both mechanical and software-based in nature, the lack of a definition for “performance” in the AV START Act (or any other federal law for motor vehicles) will likely lead to lengthy and costly legal fights over the definition and whether or not proposed state and local laws or regulations will affect it.

While USDOT acknowledges that they want to “strike the appropriate balance between the federal government’s use of its authorities…and the State and local authorities’ use of their traditional powers,” the guidance provides no indication of how USDOT’s views on what the appropriate roles are for federal, state, and local governments. The lack of clarity is a significant concern for local communities who are left unsure if current control over their roads will, in the end, apply to this new technology.

7) USDOT says it already has the authority to set testing and regulatory standards for vehicles configured without human controls. What?

If true, this begs the question: why do we even need federal AV legislation? This guidance states that, for high-level and full automation, “NHTSA’s current safety standards constitute an unintended regulatory barrier to innovation” and that, “in an upcoming rulemaking, NHTSA plans to seek comment on proposed changes to particular safety standards to accommodate automated vehicle technologies and the possibility of setting exceptions to certain standards.” If USDOT feels that they (through NHTSA) already have this authority to set safety standards for AVs, why are the House and Senate even considering legislation? The guidance is completely silent on further explaining this critical topic for local communities and the public.

8) USDOT wants to update the federal manual that governs street design to “take into account” automated driving

As with anything, the devil is in the details. AV 3.0 provides no details on when or how the Manual on Uniform Traffic Control Devices (MUTCD) will be updated, only that the FHWA is conducting research. As previously stated, this guidance does nothing to provide communities with data about how automated vehicles are performing, so how would communities or even the FHWA have the foggiest idea what kinds of updates are required for the MUTCD to incorporate AVs in a productive and safe way?

9) The guidance advises state legislatures to adopt common terminology and assess roadway conditions

USDOT really leaves states holding the bag with this one. The guidance tells states to use voluntary, consensus-based terminology when discussing automated vehicles. While it provides an example, in practice, it allows 50 states to select 50 different ways of discussing this new technology. In the next paragraph, the guidance states that “states may want to assess roadway readiness for automated vehicles, as such assessments could help infrastructure for automated vehicles, while improving safety for drivers today.” How would states or cities have any idea how to “assess roadway readiness” considering that the guidance (as with the AV START Act,) completely and utterly fails to provide communities with any data about how and where automated vehicles are operating?

10) Complete Streets get a welcome shout out, but only in the “transit” section.

We were pleased to see that this guidance recognized the value of complete streets policies in improving safety. However, the guidance refers to these policies only in the context of transit, in encouraging transit providers to review complete streets policies when planning for automation. Complete streets are a proven tool to make streets and cities safer, with or without transit or automation, and the most potentially dangerous impacts of AVs will be felt by those who are not driving and attempting to share the road with them while walking and biking, as well as taking transit.

USDOT’s AV Guidance: Preparing for the Future of Transportation: Automated Vehicles 3.0

On October 11, 2018, the US Department of Transportation (USDOT) released Preparing for the Future of Transportation: Automated Vehicles 3.0. According to the USDOT, this document builds upon, but does not replace the voluntary guidance previously released in 2017 as Automated Driving Systems 2.0: A Vision for Safety. An analysis exclusively for Transportation for America members on this latest guidance is here.