network if these problems in Cruise operations continue and are replicated by
similar problems from Waymo. We urge the Commission to understand recent road
and transit blockages as a message to proceed with caution and to continue its
incremental approach to approving driverless AVPS expansion.
2) Transparency. Waymo and Cruise have both sought confidential treatment of basic
operational data about AV driving. Since 2020, the Commission has issued
numerous decisions and rulings that reflect California’s strong public policy favoring
public access to documents and data that inform the public about both the
performance of regulated transportation providers and the performance of the
Commission itself as regulator. Yet Waymo seeks exclusive authority to make
judgments about the readiness of its systems for driverless operation while
obscuring basic operational data from the public.
3) Driverless Testing. Waymo has tested both automated driving and passenger
service extensively, but as of August 31, 2022, the latest date for which information
is available to the public, Waymo had not tested any passenger service in San
Francisco in vehicles that have no safety driver. This increases concern about the
potential for increased AV street obstructions.
4) Inadequate Reporting and Monitoring. The Commission’s existing data collection
requirements, public disclosure, and analysis do not provide the information
necessary to assess how automated driving technology is actually affecting the
safety, operations, equity, and accessibility of the City’s transportation network—as
distinct from how the industry hopes and asserts that it will. While the Commission
has not set any specific benchmarks for required AVPS performance, where events
illustrate significant performance problems, San Francisco urges the Commission to
collect performance data about those problems and use that data to support
transparent evaluation of more incremental expansion approvals.
San Francisco appreciates the wisdom reflected in the Commission’s Resolution TL-
19137 approving the first commercial AVPS deployment in California for a small fleet of Cruise
AVs operating only at night. San Francisco recommends that the results of that limited
deployment to date call for further restraint and limited initial deployments outside the
downtown core
3
and peak travel hours (weekdays, 7-10 AM and 4-7 PM) until a permittee
demonstrates that they can operate in the most demanding circumstances without
compromising safety, equity, accessibility and street capacity. A series of limited
deployments—rather than unlimited authorizations—offer the best path toward public
3
For purposes of AVPS permitting, San Francisco recommends that the Commission define the downtown core as
reflected in the boundaries of “Northeast San Francisco” in Exhibit A, an area in which transit density, communities
of concern and overall traffic congestion are all high. However, the more acute concerns could be addressed by
protecting the smaller area identified in Exhibit A.