5 Sections 55 minutes Author: Shared-Use Mobility Center
The adoption of AV technologies has the potential to impact the urban environment significantly in both positive and negative ways. It is important for cities to think through the complex interactions between vehicle autonomy and, for example, pedestrians, transit, cycling, scooters, ridesourcing, parking, local business, and public space. Streets will need to be planned, and in some cases reconfigured, to balance mobility, safety, economic prosperity, environmental responsibility, equity, and quality of life. Forward-thinking cities have an opportunity to leverage AV technological innovation to achieve public goals rather than merely allowing their communities to be overwhelmed by whatever comes next.
This learning module will focus on the impacts of AV technology on shared-use and on-demand modes, and it will consider them in the context of complex urban environments. Specifically, it will explore how AVs can be leveraged as a shared mode of transportation to both increase mobility access and reduce carbon emissions. According to the Federal Transit Administration (FTA), shared mobility includes public transportation, taxis and limos, carsharing, bikesharing, e-scooter sharing, shuttles, carpooling, ridesharing and commercial delivery vehicles.
Although the technology for fully-autonomous driverless cars has not yet been realized, progress toward this goal is taking place rapidly. As a result, this case study examines what hurdles that process may encounter, and what the eventual outcomes are likely to be. It also explores some key considerations raised by the prospect of the proliferation of shared AV fleets, including what technological challenges remain, what legal frameworks will be required, and how transportation as a whole may be impacted.
AV technology can improve traffic safety, reduce parking demand, and enhance shared mobility if adapted appropriately.
AVs and AV technology can positively or negatively impact a transportation network depending on how communities implement and use them.
Policymakers can use AV technologies for projects that include microtransit, fixed-route transit, deliveries, and other forms of shared mobility. All of these projects have impacts, and decision-makers should consider the potential for unintended or undesirable consequences.
AV technologies are rapidly evolving and bring new opportunities and challenges for mobility providers and regulators. Policymakers should constantly seek to stay informed about new developments to ensure that autonomous vehicles positively benefit their jurisdictions and systems.
Autonomous vehicles (AVs): A classification system based on six different levels, ranging from fully manual (Level 0) to fully automated (Level 5) systems, was published in 2014 by the Society of Automotive Engineers (SAE) International, and since 2016 it has been the operating classification under the National Highway Traffic Safety Administration (NHTSA). [7]
Fixed-route transit: According to the Federal Transit Administration (FTA), fixed-route transit is a “system of transporting individuals (other than by aircraft), including the provision of designated public transportation service by public entities and the provision of transportation service by private entities, including, but not limited to, specific public transportation service, on which a vehicle is operated along a prescribed route according to a fixed schedule” [49 CFR 37.3]. This commonly refers to public transit that operates on established routes and schedules, such as buses, trains, trams, and shuttles. AV technologies are used in some smaller-scale transit projects and pilots.
Microtransit: Microtransit is a transportation service that falls between fixed-route transit and ridesourcing operations. It resembles traditional demand-responsive transit (DRT), such as dial-a-ride, in that it often uses similar vehicles (passenger vans or cutaways) but with improved dispatching and routing, enabled by various mobile technologies like smartphones and tablets. Rides may be arranged through a smartphone app, in addition to more traditional phone- or web-based booking systems. According to the SUMC-authored TCRP Report 188, microtransit is defined as an “app-enabled private multi-passenger transportation service that serves passengers using dynamically generated routes, and may expect passengers to make their way to and from common pick-up or drop-off points.” [8] Some common microtransit vendors in the US include TransLoc, DemandTrans, Via, and Transdev. Increasingly, microtransit is being explored by public agencies, as well as private operators. Microtransit is an area of great interest for proponents of AVs, because AVs are commonly viewed as a mode well-suited for microtransit service. For more on microtransit in general, see SUMC’s Microtransit Learning Module.
Ridesourcing: Ridesourcing involves the use of online platforms to connect passengers with drivers and automate reservations, payments, and customer feedback. Typically, a transportation network company provides the online platform and manages drivers. Importantly, ridesourcing differs from ridesharing in that ridesharing involves trips where both driver and passenger(s) share the same destination: that includes travel types such as carpooling and vanpooling.
Vehicle miles traveled (VMT): According to the University of Texas A&M Transportation Institute, VMT “measures the amount of travel for all vehicles in a geographic region over a given period of time, typically a one-year period. It is calculated as the sum of the number of miles traveled by each vehicle.” [9] Because VMT measures travel demand, it is useful in determining where resources are most needed, and it is an important measure to monitor and forecast. For example, the FTA’s Office of Highway Patrol Information releases regular forecasts for VMT nationally. In order to meet transportation sector emission-reduction targets, total VMT will need to be reduced, and greater use of AVs as a shared mode of travel is one avenue to achieve that aim. An alternate measure, passenger miles traveled (PMT), accounts for that shared rides may provide more mobility access.
Mobility as a Service (MaaS): MaaS is a transportation model that integrates various forms of transportation – including both fixed-route and on-demand services – into comprehensive digital platforms that “integrate end-to-end trip planning, booking, electronic ticketing, and payment services across all modes of transportation, public or private.” [10] Rather than each transportation mode being viewed and experienced in its own silo, MaaS is a more user-centric paradigm that seeks to incorporate all modes into a more connected system that benefits customers. Future mobility platforms will need to consider ways to incorporate shared AV fleets into their models.
Self-driving vs. Driverless: Although the terms “self-driving” and “driverless” are often used interchangeably, self-driving usually refers to vehicles that fall in the SAE Level 3-4 range, where the vehicle is capable of handling some or most conditions, but a human driver is required to take control in certain conditions. A driverless vehicle is a fully autonomous Level 5 vehicle.
5G vs. dedicated short-range communication (DSRC) technology: 5G is the mobile broadband that is rapidly being rolled out by mobile carriers and cities around the globe. 5G is particularly important for AVs, as it will enable AVs to connect to other vehicles around them more readily than previous broadbands, as well as to certain 5G-compatible infrastructure, such as smart traffic lights and signals. However, there are uncertainties about 5G’s readiness, as well as the logistics of how the SIM cards necessary for 5G use in vehicles will be distributed and paid for. [11] Unlike 5G, which is a cellular-based technology, DSRC technology uses wi-fi to connect to surrounding vehicles and infrastructure. While both technologies enable vehicles to sense and react to intelligence around them, they may interfere with one another on the road, meaning that one technology is likely to become standard down the line. Currently, some auto manufacturers (like BMW) are advocating for the widespread use of 5G, and others (like Volkswagen) are advocating for use of DSRC.
1. Government Technology: “Why Autonomous and Electric Vehicles are Inextricably Linked”, https://www.govtech.com/fs/Why-Autonomous-and-Electric-Vehicles-are-Inextricably-Linked.html. Accessed March 31, 2022.
2. International Energy Agency: “Shared, autonomous…and Electric?”, published March 28, 2019. https://www.iea.org/commentaries/shared-automated-and-electric.
3. International Energy Agency: “Shared, autonomous…and Electric?”, published March 28, 2019. https://www.iea.org/commentaries/shared-automated-and-electric.
4. Fleet Europe: “How AVs Will Revolutionise Fleet and OEM Revenues by 2030”, published February 19, 2019. https://www.fleeteurope.com/en/autonomous/europe/analysis/how-avs-will-revolutionise-fleet-and-oem-revenues-2030?a=JMA06&t%5B0%5D=KPMG&t%5B1%5D=Autonomous&t%5B2%5D=EVs&curl=1.
5. Society of Actuaries: “An Update on the Outlook for Automated Vehicle Systems”, published October 2019. https://www.soa.org/globalassets/assets/files/resources/research-report/2019/automated-vehicle-update.pdf.
6. Intergovernmental Panel on Climate Change: “Summary for Policymakers of IPCC Special Report on Global Warming of 1.5°C Approved by Governments”, published October 8, 2018. https://www.ipcc.ch/2018/10/08/summary-for-policymakers-of-ipcc-special-report-on-global-warming-of-1-5c-approved-by-governments/.
7. US Department of Transportation: “Preparing for the Future of Transportation: Automated Vehicles 3.0”, published October 4, 2018. https://www.transportation.gov/sites/dot.gov/files/docs/policy-initiatives/automated-vehicles/320711/preparing-future-transportation-automated-vehicle-30.pdf.
8. Transportation Research Board, The National Academies of Sciences, Engineering, and Medicine: “TCRP Report 188: Shared Mobility and the Transformation of Public Transit”, published 2016. https://www.trb.org/TCRP/Blurbs/174653.aspx.
9. Texas A&M Transportation Institute: “Methodologies Used to Estimate and Forecast Vehicle Miles Traveled (VMT)”, published July 2016. https://static.tti.tamu.edu/tti.tamu.edu/documents/PRC-2016-2.pdf.
10. Deloitte Review: “The Rise of Mobility as a Service”, published 2017. https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/consumer-business/deloitte-nl-cb-ths-rise-of-mobility-as-a-service.pdf.
11. EE Times Asia: “The DSRC vs 5G Debate Continues”, published October 29, 2019. https://www.eetasia.com/The-DSRC-vs-5G-Debate-Continues/.
Safety & Liability: According to a 2018 study by the American Automobile Association, 63% of US drivers say they would be afraid to ride in a fully self-driving car. [20] In part, that number reflects the uncertainty many Americans feel regarding whether an AV will be truly capable of responding appropriately to all contexts it might encounter. Crashes – like that of the killing of a pedestrian by an Uber self-driving test vehicle in Arizona in 2018, or the low-speed collision between a supervised AV shuttle and delivery truck in Las Vegas in 2017 – have likely kept conversations relating to AV safety prevalent in the public discourse. Interestingly, a 2019 study found that public perception of present and future AV safety is far less optimistic in Western nations when compared with developed Asian nations. [21] Regardless of current attitudes, there are serious questions relating to AV safety that will need to be resolved at various governmental levels before AVs can be adopted broadly. For example:
State and federal agencies are actively working to ensure that legislation addresses these and other safety-related concerns, but consensus has not been reached about “how safe is safe enough”. One particular challenge for AV technology are pedestrians and cyclists; pedestrians and bicyclists can be more difficult for sensors to pick up, and can behave unpredictably. In fact, a 2020 report released by the Insurance Institute for Highway Safety suggests that even if all vehicles on the road were AVs, the vehicles’ more accurate perception would only be able to eliminate about one third of crashes. Furthermore, a 2019 report from the Georgia Institute of Technology concluded that every AV programming system studied was less accurate in detecting dark-skinned pedestrians compared to lighter-skinned pedestrians, raising additional questions about the safety of AVs relative to the size and racial make-up of the datasets from which programmers are drawing.
Employment Impacts: For many public transit employees, AVs can be seen as more of a potential risk than benefit. For example, if cities replace even a single bus route with an automated fleet of vehicles that do not require human supervision, that will likely mean a decrease in the number of total drivers required by the agency. Similarly, the anticipated reduction in accidents resulting from greater adoption of personal AVs could lead to a significant change in the auto insurance industry. According to a KPMG analysis in 2015, the US personal automotive insurance sector could shrink by 40 percent within 25 years, with the number of accidents per vehicle dropping by 80 percent; similarly the Bank of England has predicted a fall in motor insurance premiums of 21–41 percent by 2040. [22] This potential reduced need for drivers and insurance providers could negatively impact the job market.
Publicly-funded AV infrastructure:
Resulting increase in VMT: One of the major concerns regarding the widespread adoption of AVs is that car owners will simply switch from traveling via private non-automated vehicle to private automated vehicle. This would not lead to a reduction in the number of vehicles on the road, nor a reduction in road congestion or vehicle infrastructure, even if vehicles travel closer together. [28] A 2019 article published in Transport Policy argues that, due to their ability and incentive to cruise between trips rather than pay for parking, AVs will “blur[] the boundary between parking and travel”, and even traditional congestion pricing will be limited in its effectiveness in dense urban areas. [29] This possibility is particularly concerning given that VMT for delivery vehicles is already anticipated to rise to 78 billion miles annually in the US by 2040 as consumer demand for same-day or same-hour delivery expands. [30]
Capability of AVs to meet needs of shared fleets: Currently, many AV models are not built to meet the needs of multiple travelers in the same way that traditional shared modes are. For example, electrically-powered AVs will need to be able to travel long distances without needing a recharge, which many are currently not capable of doing. Similarly, questions remain about the cost to retrofit AV models to provide more trunk space or accommodate oversized mobility devices like wheelchairs, which many shared fleets will require to meet customers’ needs. [31]
Data security: Cybersecurity is already a concern for non-autonomous vehicles; in 2015, there were 1.4 million recalls in the US alone due to cybersecurity vulnerabilities. [32] With AVs that use cellular networks and/or wi-fi to connect to their surroundings, there are many more areas of connectivity vulnerable to attack, and these opportunities are likely to grow as the systems used to connect to the surrounding world (such as LiDAR, DSRC, 5G, RADAR, cameras and GPS) become more widespread on the road. [33] See the image below from the European Union Agency for Cyber Security for some of the networks with which AVs will interact.
20. Bloomberg: “American Drivers Begin Warming Up to Riding in Self-Driving Cars”, published January 24, 2018. https://www.bloomberg.com/news/articles/2018-01-24/american-drivers-begin-warming-up-to-riding-in-self-driving-cars.
21. MIT Department of Urban Studies & Planning: “Public Perceptions of Autonomous Vehicle Safety: An International Comparison”, published 2019. https://dusp.mit.edu/publication/public-perceptions-autonomous-vehicle-safety-international-comparison.
22. KPMG: “2019 Autonomous Vehicles Readiness Index: Assessing Countries’ Preparedness for Autonomous Vehicles”, published 2019. https://assets.kpmg/content/dam/kpmg/xx/pdf/2019/02/2019-autonomous-vehicles-readiness-index.pdf.
23. The International Council on Clean Transportation: “California’s Continued Electric Vehicle Market Development”, published May 2018. https://theicct.org/sites/default/files/publications/CA-cityEV-Briefing-20180507.pdf.
24. KPMG: “2019 Autonomous Vehicles Readiness Index: Assessing Countries’ Preparedness for Autonomous Vehicles”, published 2019. https://assets.kpmg/content/dam/kpmg/xx/pdf/2019/02/2019-autonomous-vehicles-readiness-index.pdf.
25. Curbed: “Why High-Tech Parking Lots for Autonomous Cars May Change Urban Planning”, published August 8, 2016. https://archive.curbed.com/2016/8/8/12404658/autonomous-car-future-parking-lot-driverless-urban-planning.
26. The International Council on Clean Transportation: “Quantifying the Electric Charging Infrastructure Gap Across U.S. Markets”, published January 2019. https://theicct.org/sites/default/files/publications/US_charging_Gap_20190124.pdf.
27. Federal Highway Administration: “Development of Guidance for Electric Vehicle Charging Infrastructure Deployment”, published November 29, 2021. https://www.federalregister.gov/documents/2021/11/29/2021-25868/development-of-guidance-for-electric-vehicle-charging-infrastructure-deployment.
28. World Economic Forum: “Reshaping Urban Mobility with Autonomous Vehicles: Lessons from the City of Boston”, page 4, published June 2018. https://www3.weforum.org/docs/WEF_Reshaping_Urban_Mobility_with_Autonomous_Vehicles_2018.pdf.
29. Transport Policy: “The Autonomous Vehicle Parking Problem”, published March 2019. https://www.sciencedirect.com/science/article/abs/pii/S0967070X18305924.
30. KPMG: “2019 Autonomous Vehicles Readiness Index: Assessing Countries’ Preparedness for Autonomous Vehicles”, published 2019. https://assets.kpmg/content/dam/kpmg/xx/pdf/2019/02/2019-autonomous-vehicles-readiness-index.pdf.
31. International Energy Agency: “Shared, autonomous…and Electric?”, published March 28, 2019. https://www.iea.org/commentaries/shared-automated-and-electric.
32. The Verge: “Chrysler Recalls 1.4 Million Cars at Risk of Being Remotely Hijacked”, published July 24, 2015. https://www.theverge.com/2015/7/24/9032179/chrysler-announces-voluntary-recall-hack.
33. Towards Data Science: “Future of Cyber Security for Connected and Autonomous Vehicles”, published January 2, 2020. https://towardsdatascience.com/future-of-cyber-security-for-connected-and-autonomous-vehicles-4c553def6d50.
Although countries and cities are currently at different stages of AV deployment and development, there are some trends shared globally. As recently as 2016, many companies and individuals excited about the sector anticipated the operation of fully autonomous, driverless cars on public roads in just a few years’ time. However, the anticipated timeline has been extended, as developers and programmers tackle the significant hurdles related to large-scale AV deployment. In fact, in 2019, the CEO of Ford asserted that “[w]e overestimated the arrival of autonomous vehicles.” [34] The cost of developing and testing sensors is decreasing, which may help accelerate this timeline, but the arrival of AVs operating widely on public roads remains unclear. A 2019 McKinsey assessment anticipates the mass deployment of Level 4 and 5 AVs in China in about a decade, while a 2022 report by the Victoria Transport Policy Institute anticipates Level 5 vehicles may be commercially and legally available globally by the late 2020s, but that the benefits of AV technology will only be realized when AVs are mainstream, likely in the 2050s or 2060s. [35] Because transportation is more highly regulated than some other industries, the testing and legislation necessary to deploy them broadly may slow the market penetration.
Generally, most experts anticipate that some of the earliest major deployments of autonomous technology on roads will involve intercity trucks that are able to be linked together along designated corridors. Testing of such projects is occurring, for example, with the EU-funded ENSEMBLE Consortium in 2021 and a US-based Truck Platooning Early Deployment Assessment planned for by the end of 2023.
Furthermore, according to a 2019 report released by the Society of Actuaries, entirely autonomous technology that involves no driver will likely be limited to ODDs such as weather conditions, geofenced areas, and designated times of day for several years to come as the necessary technology and infrastructure improve. [36] Due to these ODDs constraining their operation, AVs are anticipated to be deployed primarily in fleets rather than as a private means of transportation. [37] The report even suggests that some states may prohibit private ownership of AVs altogether.
An estimate released by GM’s AV unit, Cruise, in early 2020 values the entire global AV industry at $8 trillion. A similar analysis from Intel in 2017 placed the estimated value at $7 trillion. As a result, it is perhaps not surprising that companies are eager to gain a competitive advantage regarding AV technology, testing and deployment. The following list is by no means exhaustive, but it includes some of the major private-sector players pushing the needle on AV deployment.
As of December 2021, 28 companies had submitted their Voluntary Safety Self-Assessment to NHTSA, and all are publicly available here.
Safety & Liability: According to an annual report released by KPMG on AV readiness at the national level, there are several key components a country needs to have in place locally in order to be sufficiently prepared for AV proliferation. First, in regards to national infrastructure, some of the elements that will be most important to support shared AVs are sufficient numbers of EV charging stations, overall technological infrastructure, such as mobile internet and 4G or 5G coverage, and high-quality roads. Specific roadway infrastructure that many agencies are exploring include smart traffic signals and parking and curb management. Second, having national and local policies and legislation in place will also be critical to ensure safe deployment of AV fleets; KPMG suggests that AV regulations pertaining to safety, government-funded AV pilots, and data-sharing policies are most central. Many agencies are also establishing AV-focused departments or agencies to handle such regulation. See the following section, “Existing AV Regulations” for some national, state- and city-level AV policies. Lastly, to be fully prepared for the mass deployment of AVs, countries need to have a well-established marketplace that facilitates innovation. Markers of such a marketplace include AV firms headquartered in the country, patents filed locally, and a high EV market share.
Steps to Ease the Transition from Traditional Types of Service to AVs: There are four types of service for which shared AVs are anticipated to be adopted most readily.
Steps to Ensure Adequate Safety and Infrastructure:
In addition to the approaches listed above that cities can pursue to better facilitate the use of AVs among traditional types of service, there are also several policies that pertain to road infrastructure and traveler safety that cities can pursue.
International & National Policies and Programs:
Examples of US State Level Policies & Programs:
Considerations at the City Level:
Cities have a wide range of authority to enact laws that might impact AV operations and deployment. For example, some cities may choose to prohibit AVs in school zones or require certain data-sharing practices from operators. One issue that will likely be of increasing concern to cities is the extent to which state and federal laws might preempt such authority. Just as some states have prohibited the local regulation of TNCs, states might also opt to regulate AV-related matters, thereby blocking cities to address concerns as they might otherwise choose. Cities should proactively work with state and federal legislators to ensure their authority to manage AV operations in uniquely urban contexts.
Additional resources for decision-makers and planners at the city level:
34. Bloomberg: “Ford CEO Tamps Down Expectations for First Autonomous Vehicles”, published April 9, 2019. https://www.bloomberg.com/news/articles/2019-04-09/ford-ceo-tamps-down-expectations-for-first-autonomous-vehicles.
35. Victoria Transport Policy Institute: “Autonomous Vehicle Implementation Predictions: Implications for Transport Planning”, published March 3, 2022. https://www.vtpi.org/avip.pdf.
36. Society of Actuaries: “An Update on the Outlook for Automated Vehicle Systems”, published October 2019. https://www.soa.org/globalassets/assets/files/resources/research-report/2019/automated-vehicle-update.pdf.
37. Society of Actuaries: “An Update on the Outlook for Automated Vehicle Systems”, published October 2019. https://www.soa.org/globalassets/assets/files/resources/research-report/2019/automated-vehicle-update.pdf.
38. WIRED: “The Feds Ban a Self-Driving Shuttle Fleet from Carrying People”, published February 29, 2020. https://www.wired.com/story/feds-ban-self-driving-shuttle-fleet-carrying-people/?bxid=5cec24fbfc942d3ada068985&cndid=57041884&esrc=DailyNLPromo?utm_ter&source=EDT_WIR_NEWSLETTER_0_TRANSPORTATION_ZZ&utm_brand=wired&utm_campaign=aud-dev&utm_mailing=WIR_Transportation_030220&utm_medium=email&utm_source=nl&utm_term=WIR_Transportation.
39. Office of the City Manager, City of Vancouver: “Memo – Smart Cities Challenge Joint Application”, submitted on March 4, 2019. https://vancouver.ca/files/cov/2019-03-04-smart-cities-challenge-joint-application.pdf.
40. Transport Policy: “The Autonomous Vehicle Parking Problem”, published March 2019. https://www.sciencedirect.com/science/article/abs/pii/S0967070X18305924.
41. Urbanism Next, University of Oregon: “Changing Parking Infrastructure with Autonomous Vehicles”, published May 9, 2018. https://urbanismnext.uoregon.edu/category/inputs/ownership/.
42. Bloomberg: “Why Speed Kills Cities”, published August 8, 2019. https://www.bloomberg.com/news/articles/2019-08-08/lower-speed-limits-could-save-your-city-and-life.
43. National Association of City Transportation Officials: “Blueprint for Autonomous Urbanism: Second Edition”, published September 2019. https://nacto.org/publication/bau2/transit/.
44. Law Commission of England and Wales, Scottish Law Commission: “Automated Vehicles: Joint Report”, published January 26, 2022. https://www.lawcom.gov.uk/project/automated-vehicles/.
45. Government of the Netherlands: “Self-Driving Vehicles”. https://www.government.nl/topics/mobility-public-transport-and-road-safety/self-driving-vehicles. Accessed April 4, 2022.
46. Centre for Connected and Autonomous Vehicles: “UK Connected & Autonomous Vehicle Research & Development Projects 2018”, published September 2018. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/737778/ccav-research-and-development-projects.pdf.
47. Law Commission of England and Wales, Scottish Law Commission: “Automated Vehicles: Joint Report”, published January 26, 2022. https://www.lawcom.gov.uk/project/automated-vehicles/.
48. Land Transport Authority, Government of Singapore: “Joint Media Release by the Land Transport Authority (LTA), Enterprise Singapore, Standards Development Organisation & Singapore Standards Council – Singapore Develops Provisional National Standards to Guide Development of Fully Autonomous Vehicles”, published January 31, 2019. https://www.lta.gov.sg/content/ltagov/en/newsroom/2019/1/2/joint-media-release-by-the-land-transport-authority-lta-enterprise-singapore-standards-development-organisation-singapo.html.
49. National League of Cities: “Autonomous Vehicle Pilots Across America: Municipal Action Guide”, published 2018. https://www.nlc.org/wp-content/uploads/2018/10/AV-MAG-Web.pdf.
50. RAND Corporation:”Autonomous Vehicles and Federal Safety Standards: An Exemption to the Rule?”, published 2017. https://www.rand.org/content/dam/rand/pubs/perspectives/PE200/PE258/RAND_PE258.pdf.
51. Congressional Research Service: “Issues in Autonomous Vehicle Testing and Deployment”, published April 23, 2021. https://crsreports.congress.gov/product/pdf/R/R45985.
52. Government Technology: “Washington State in the Dark Over Public AV Testing”, published September 23, 2019. https://www.govtech.com/fs/automation/washington-state-in-the-dark-over-public-av-testing.html.