November 1, 2023
The Honorable Alice Busching Reynolds
President
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
RE: Driverless Autonomous Vehicle Passenger Deployment Program in Los
Angeles
Dear President Reynolds,
I have serious concerns over the recent California Public Utilities Commission (CPUC)
decision to approve a Driverless Autonomous Vehicle (AV) Passenger Deployment
Program in the City of Los Angeles.
A decision to allow AVs to operate in the City of Los Angeles without local regulation,
and without a well-developed and collaborative deployment plan, will likely have
adverse impacts on the residents of Los Angeles. As the Los Angeles Department of
Transportation (LADOT) has stated repeatedly in comments to the CPUC, responsible
AV deployment demands early collaboration between state agencies, cities, and
industry to set clear regulations that maximize the benefits of new transportation
technologies for all our communities, while protecting emergency response capability,
safety on our roads, and equitable service. To date, local jurisdictions like Los Angeles
have had little to no input in AV deployment and are already seeing significant harm and
disruption.
In a letter submitted at a recent CPUC hearing, the Chief of the Los Angeles City Fire
Department (LAFD) stated her serious concerns about several incidents where AVs
prevented emergency vehicles from arriving on scene in San Francisco. San Francisco
Fire Department (SFFD) AV incident reports include:
Driverless AV Passenger Deployment Program in Los Angeles Mayor Karen Bass
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November 1, 2023
Ignoring yellow emergency tape and warning signs to enter a street with
compromised electrical wires, causing entanglement around the rooftop vehicle
sensors;
Blocking firehouse driveways, requiring more distant resources to be dispatched,
and increasing response times
Sitting motionless on one-way streets, creating traffic and prohibiting emergency
vehicles from responding to incidents;
Pulling up behind a fire truck with emergency lights on which interfered with
firefighters unloading ladders; and
Entering an active fire scene, then parking on top of the fire hose.
Since that letter was sent, an AV blocked an ambulance in San Francisco, which first
responders say contributed to the death of the individual being transported because the
ambulance was unable to expeditiously make it to the hospital. Earlier this month an AV
rolled on top of a pedestrian struck by a human-driven vehicle and dragged them 20
feet at a speed of up to 7 miles per hour when it attempted an emergency maneuver,
significantly contributing to life-threatening injuries. That operator’s self-reported data
did not provide the full incident. Thankfully, the Department of Motor Vehicles’
investigation did and they have since pulled that operator’s permit, but further
deployment must include regulations that require complete and accurate reporting.
AV companies started testing in Los Angeles this month, and our traffic enforcement
personnel have already experienced at least one incident where an AV could not
properly identify or obey an officer who was directing traffic in an intersection where
traffic signals were offline. Accurately detecting and responding to traffic officers, and
other road users such as pedestrians and cyclists is a basic requirement for safe AV
deployment. Unrestricted deployment before operators demonstrate this basic ability,
and without clear requirements to address these concerns, present a serious risk to
public safety. More testing is needed to ensure operators can safely expand their
service.
These public safety, road safety, and other serious concerns remain unaddressed by the
CPUC as it permits commercial AV deployment in a number of cities across the state.
The City of Los Angeles continues to work toward a system where every Angeleno has
reliable, safe, and affordable transportation options that serve their needs. We continue
to be optimistic about advancements in transportation technology that have the potential
to increase mobility options for all, but we cannot meet these goals without direct input
or authority over new modes. I am concerned that the CPUC will not consider the clear
adverse impacts of unrestricted AV deployment in San Francisco in its decision to
further deployment in Los Angeles. In a city that spans 500 square miles, has a
population of approximately 4 million people, and contains 7,500 miles of roadways, the
risk is exponentially greater.
Driverless AV Passenger Deployment Program in Los Angeles Mayor Karen Bass
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November 1, 2023
The City of Los Angeles is equipped with the tools to effectively regulate AV service
within its jurisdiction, and should determine the requirements for future deployment to
maximize the benefits of new transportation technologies and mitigate harm across our
diverse communities. I look forward to working with the Commission to ensure
deployment in Los Angeles meets this goal.
Sincerely,
KAREN BASS
Mayor
City of Los Angeles
CC: The Honorable Genevieve Shiroma, Commissioner
The Honorable Darcie L. Houck, Commissioner
The Honorable John Reynolds, Commissioner
The Honorable Karen Douglas, Commissioner