Contents

Letter of Transmittal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

National Council on Disability Members and Staff . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Chapter 1. Current State of Technology of Autonomous Vehicles . . . . . . . . . . . . . . . 13

Chapter 2. Current Federal and State Approaches to Regulation of 

Autonomous Vehicles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Chapter 3. Potential Technological Barriers to the Independent Use 

of Autonomous Vehicles by People with Disabilities ................. 21

Accessibility and Assistive Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Limitations of Sensors (cameras, LIDAR, radar, infrared, 

ultrasonic) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

GPS and Other Mapping-System Accuracy . . . . . . . . . . . . . . . . . . . . . . . . 23

Ultra-Reliability and Redundancy of Software . . . . . . . . . . . . . . . . . . . . . . 23

Equipment Failure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Software Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Chapter 4. Potential Policy and Societal Barriers to the Independent 

Use of Autonomous Vehicles by People with Disabilities . . . . . . . . . . . . . 25

Driver’s Licensing, Regulations, and Model Legislation . . . . . . . . . . . . . . 25

Model Regulatory Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Model Federal and State Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Cost and Income Disparity Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Attitudinal Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Liability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Privacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Self-Driving Cars: Mapping Access to a Technology Revolution i
Ethical Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Cybersecurity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Infrastructure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

V2V Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

NCD Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Appendix A: Summary of Enacted State Laws on Autonomous Vehicles . . . . . . . . . 37

Appendix B: Model Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Appendix C: List of Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 

ii National Council on Disability
November 2, 2015

President Barack Obama

The White House

1600 Pennsylvania Avenue, NW

Washington, DC 20500

Dear Mr. President:

The National Council on Disability (NCD) is pleased to submit the enclosed report, Self-Driving 

Cars: Mapping Access to a Technology Revolution. For more than a decade, NCD has examined 

the positive impact of emerging technology on people with disabilities. NCD now envisions 

opportunities for people with disabilities to promote independence and economic opportunities if 

the marketplace can make emerging technology of personal transportation vehicles a reality.

The potential benefits of autonomous vehicles can hardly be more significant. Indeed, autonomous 

vehicles will change the world for everyone, but the most dramatic impact could be for people with 

disabilities and people who are aging, provided that their needs are understood and technology 

solutions are paired to meet such needs. Inaccessible transportation remains one of the biggest 

deterrents to employment and community involvement in the United States. Accordingly, 

autonomous vehicles have the potential to become an essential component of their independence, 

economic development, and well-being. Autonomous vehicles hold great promise to advance 

social inclusion by offering people with disabilities independent mobility to get to school, jobs, and 

all places that Americans go each day. They offer the possibility of ending the isolation that many 

people who are aging experience by keeping them connected with others and to activities that are 

often lost when we lose the ability to drive.

This report explores the emerging revolution in automobile technology and the promise it holds for 

people with disabilities, as well as the obstacles the disability community faces to realizing that 

promise. The report examines the current state of the technology, current approaches to regulation, 

and potential technological and policy barriers to full use by people with disabilities, and provides 

recommendations for preventing or eliminating those barriers, including model legislative language. 

Key recommendations include:

• All federal requests for proposals that provide funding for the research or development of 

autonomous vehicles or their components should include a requirement that respondents 

demonstrate that any resulting products incorporate accessibility for people with diverse 

disabilities. All technology products should be required to comply with Section 508 of the 

Rehabilitation Act.

• The Department of Transportation should develop a framework and set of national guidelines for autonomous vehicles licensing at the state level. To the extent possible, these 

guidelines should not impose limitations on people with disabilities. The guidelines should 

National Council on Disability

An independent federal agency making recommendations to the President and Congress 

to enhance the quality of life for all Americans with disabilities and their families.

1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004

202-272-2004 Voice ■ 202-272-2074 TTY ■ 202-272-2022 Fax ■ www.ncd.gov
consider the new capabilities of autonomous vehicles and how people with disabilities can 

safely interact with and use these vehicles.

• Congress should pass legislation requiring full accessibility for all types of common and public 

use autonomous vehicles. Legislation should define a process that includes meetings with 

manufacturers, disability groups, and the National Highway Traffic Safety Administration. Relatedly, a disability advisory committee for automation should be created. The Access Board 

should be delegated the responsibility of developing standards. Existing rules, including Section 504 of the Rehabilitation Act and the Americans with Disabilities Act, should be interpreted 

to require accessible autonomous vehicles, including additional regulation by the Department 

of Justice, if needed. 

• Congress should prohibit discrimination on the basis of disability by states or any other governmental authority in licensing for the use of autonomous vehicles. The remedy should be 

the withholding of federal highway funds to states that refuse to bring their licensing rules into 

compliance with this federal requirement. Such a provision would parallel the approach historically taken by the Federal Government with respect to the legal drinking age.

Adopting the recommendations in this report will ensure people with disabilities benefit from and 

realize the freedom of fully autonomous vehicles.

NCD looks forward to working with the Administration, Congress, and the automobile industry to 

ensure that all people with disabilities benefit from these exciting and emerging technologies.

Respectfully,

Jeff Rosen

Chairperson

(The same letter of transmittal was sent to the President Pro Tempore of the U.S. Senate and the Speaker of the 

U.S. House of Representatives.)
National Council on Disability Members and Staff 

Members 

Jeff Rosen, Chairperson

Katherine D. Seelman, Co-Vice Chair

Royal Walker, Jr., Co-Vice Chair

Gary Blumenthal

Bob Brown

Chester A. Finn

Captain Jonathan F. Kuniholm, USMC (Retired)

Janice Lehrer-Stein 

Kamilah Oni Martin-Proctor 

Ari Ne’eman

Benro T. Ogunyipe 

Neil Romano

Lynnae Ruttledge 

Clyde E. Terry

Alice Wong

Staff

Rebecca Cokley, Executive Director 

Phoebe Ball, Legislative Affairs Specialist

Stacey S. Brown, Staff Assistant

Lawrence Carter-Long, Public Affairs Specialist

Joan M. Durocher, General Counsel & Director of Policy

Lisa Grubb, Management Analyst

Geraldine-Drake Hawkins, Ph.D., Senior Policy Analyst

Amy Nicholas, Attorney Advisor

Robyn Powell, Attorney Advisor

Anne Sommers, Director of Legislative Affairs & Outreach

Self-Driving Cars: Mapping Access to a Technology Revolution 3
ACKNOWLEDGMENTS

The National Council on Disability wishes to express its deep appreciation to Susan Henderson, 

Executive Director, and Marilyn Golden, Senior Policy Analyst at the Disability Rights Education and 

Defense Fund (DREDF), who conducted the research and writing for this report.

4 National Council on Disability
EXECUTIVE SUMMARY

Self-Driving Cars: Mapping Access to a 

Technology Revolution explores the 

emerging revolution in automobile 

technology and the promise it holds for people 

with disabilities, as well as the obstacles the 

disability community faces to realizing that 

promise. The report examines the current state of 

the technology, current approaches to regulation, 

and potential technological and policy barriers to 

full use by people with disabilities, and provides 

recommendations for preventing or eliminating 

those barriers, including model legislative language.

The potential benefits of autonomous vehicles 

(AVs) can hardly be more significant, and the buzz 

about this newsworthy topic in the media has 

created the impression that they are just around 

the corner. Although experts in the field across all 

sectors, whether government or industry, agree 

that self-driving cars will evolve through many 

stages, the fully autonomous vehicles needed 

by many people with disabilities are most likely 

to appear on our roads sometime between 2020 

and 2035. Regardless of when AVs are available, 

it is essential that they be accessible to people 

with diverse disabilities from the outset.

Different levels of automation will pose unique 

challenges to people with disabilities, and each 

of these conditions needs to be explored. An indepth exploration of different levels of automation 

and their impact on people with diverse 

disabilities (e.g., physical, sensory, intellectual/

developmental, cognitive) as well as veterans 

with disabilities and the aging population should 

be conducted.

Yet the disability community knows better than 

any other how being involved in planning from 

day one is critical to a successfully accessible 

product, regardless of how many years in the 

future it lies. Due to the fast-paced development 

of this technology and the proprietary nature of 

its engineering, little information has been shared. 

While research reveals that the industry and 

government are explicitly considering disability 

access, insufficient information is publicly available 

to assess how close designers and manufacturers 

are to ensuring access to this very promising 

technology. We recommend increased transparency 

and involvement of the disability community as this 

technology continues development. 

The Administration and Congress have an 

opportunity and the power to guarantee that 

self-driving cars provide a more inclusive, 

economically stable, and independent life for 

people with disabilities.

Current State of Technology of 

Autonomous Vehicles 

The National Highway Traffic Safety 

Administration (NHTSA) of the U.S. Department 

of Transportation (DOT) established the 

Self-Driving Cars: Mapping Access to a Technology Revolution 5
commonly accepted levels of automation that 

the path toward self-driving cars will take: Level 0 

(no automation) through Level 4 (full self-driving 

automation). Level 4 automation will enable 

people with disabilities who are currently unable 

to obtain a driver’s license to take advantage of 

AV technology.

This report reviews the types of technological 

AV systems under development, addresses their 

status, and charts the outlook for adoption in 

personal vehicles and public transit systems.

Current Federal and State 

Approaches to Regulation of 

Autonomous Vehicles

While there has been a call from AV researchers 

and manufacturers for federal attention, Congress’ 

involvement has been limited to two exploratory 

hearings on AV technology in the House and 

Senate.1 NHTSA’s 2013 “Preliminary Statement 

of Policy,”2 which has been widely adopted by 

researchers and states, provides a much-needed 

framework to bring a common understanding and 

language of the types of AV automation. 

Some states have been reluctant to move 

forward with legislation or regulations on AVs. To 

date, four states and the District of Columbia have 

adopted legislation that defines AVs, allows for 

their testing under certain conditions, and limits 

the liability of the original manufacturer of cars that 

have been converted to operate in autonomous 

mode by a third party. Many states have pending 

legislation and some have considered, but not 

adopted, legislation related to AVs.3

In 2013, Thomas Bamonte, the General 

Counsel at the North Texas Tollway Authority, 

expressed concern that public agencies 

responsible for infrastructure have not engaged 

in planning for AVs, with the exception of the 

Florida Department of Transportation, which 

is sponsoring testing on Florida roads as well 

as research to inform future legislation and 

policymaking.4

Moreover, it appears that some local and state 

transit officials and politicians are already reluctant 

to expand conventional public transit, stating that 

self-driving cars will more effectively fill the gap, 

without cognizance of the long wait involved and 

other possible barriers to realization of this hope.

Potential Technological Barriers to 

the Independent Use of Autonomous 

Vehicles by People with Disabilities

AVs present a tremendous opportunity to end 

exclusion and promote independence for anyone 

who presently cannot obtain a driver’s license, 

but significant work remains to ensure that 

technological systems currently in development 

will enable independent use by people with 

disabilities. It is important that manufacturers 

and government agencies collaborate with 

stakeholders, such as the disability community, 

to ensure that these technologies are fully 

accessible and available to all. 

Potential Policy and Societal 

Barriers to the Independent Use of 

Autonomous Vehicles by People with 

Disabilities

There are nine areas where policy decisions can 

affect the use of AVs by people with disabilities. 

While some of these barriers only affect people 

with disabilities, all potential users share most of 

them:

Driver’s Licensing

Once Level 4 AVs (i.e., fully self-driving cars) 

are available, there is no reason for an occupant 

6 National Council on Disability
to be licensed at all. In order for all people 

with disabilities, no matter where they reside, 

to benefit from the technology, licensing or 

operating requirements must be the same across 

all 50 states.

Currently, states set the rules for issuing 

driver’s licenses, while NHTSA sets motor vehicle 

safety standards. Although NHTSA lacks legal 

authority to regulate state driver’s licensing 

requirements for individuals, the agency works 

closely with states and the American Association 

of Motor Vehicle Administrators (AAMVA) on a 

broad range of behavioral issues, some of which 

relate directly to driver licensing. Examples include 

driver’s licensing best practices and application 

of medical standards to drivers who are aging 

and individuals with disabilities. NHTSA also has 

been delegated responsibility to ensure that state 

driver’s licensing policies and decisions comply 

with the Title II of the ADA and does so through 

compliance reviews and complaint investigations 

conducted by its Office of Civil Rights.

Because the current edifice anticipates a 

human driver, all standards and regulations must 

be revisited. Varying state licensing laws may 

prove to be problematic for AVs that cross state 

lines, and there has been consideration of national 

legislation that would preempt state law.5 In 2014, 

through a grant from NHTSA, the Autonomous 

Vehicle Best Practices Working Group convened 

to develop a guide for best practices to assist 

states in regulating autonomous vehicles and the 

testing of drivers who will operate them.6

Cost and Income Disparity Barriers

While AVs will include technologies that 

are expensive today, trends suggest that 

manufacturers will want to produce and sell 

these vehicles in the future. This suggests that 

there will be high-end and low-end models with 

affordability to some degree. Where AVs circulate 

in a closed loop, or where they are shared and 

individually summoned by the user, the per-trip 

charge will be the only cost to the user—much 

like how we pay for taxis and many other car 

services today.

Attitudinal Barriers

Though general public polls show Americans as 

uncertain about the safety of AVs, industry and 

technology experts expect the vehicles to be far 

safer than cars because most auto accidents are 

related to driver error. As state regulators develop 

new licensing rules, they should consider the 

new capabilities of AVs and how people with 

disabilities can safely interact with and use these 

vehicles, rather than continuing restrictions based 

on the capabilities of old technology. As required 

by Title II of the ADA, restrictions on AVs must be 

based on evidence of actual risk, not unsupported 

generalizations about the capabilities of people 

with disabilities. 

Liability

AVs present many insurance and liability issues 

that are not unique to people with disabilities, but 

some of the issues will need to be resolved to 

facilitate people with disabilities using self-driving 

cars. Fortunately, as safety and automation 

enhancements appear on vehicles, insurers 

are responding with new policies. They are 

also looking forward to the day when the driver 

disappears from behind the wheel.7

Privacy

AVs may involve a significant exchange of data, 

and privacy is a key question in developing and 

regulating this technology. Two such concerns 

Self-Driving Cars: Mapping Access to a Technology Revolution 7
are the availability of data about disability and 

health status to insurers and of user habits to 

marketers.

Ethical Considerations

Ethical considerations abound in the frontier 

technology of AVs. For example, discussions 

are already underway about how AVs should be 

programmed to decide who should be injured if a 

crash is inevitable and no solution exists without 

harming someone.

Related to people with disabilities, it is 

unclear if the data exchanged by AVs will 

include information about the occupants. Such 

information could be used in ways influenced 

by prejudices in society today, including, but not 

limited to, prejudices about disability. NHTSA 

is aware of no data that could be collected or 

exchanged relating to a motor vehicle (AV or 

other) that would contain information about 

the potential disability of a vehicle’s occupants. 

Nevertheless, the National Council on Disability 

(NCD) is concerned that the lives of people 

with disabilities or seniors may be devalued 

when these automated systems must, at 

lightning speed, calculate who should be injured. 

Accordingly, NCD recommends federal legislation 

that prohibits the collection or transmission of 

information about occupants in AVs. 

Cybersecurity

Policymakers are well aware that data-intensive 

AVs could be hacked to cause life-threatening 

accidents, and cybersecurity research is 

underway. Cybersecurity concerns must be 

addressed before self-driving cars are allowed 

on the road. At least one policymaker, however, 

thinks that the security of digital systems to be 

used in AVs is inadequate.8

Infrastructure

Some experts believe that infrastructure changes—

in roadways, signage, and so forth—will be 

necessary for reliable self-driving cars to evolve. 

Vehicle-to-Vehicle Communications

Vehicle-to-vehicle (V2V) communications can 

further strengthen the quality of information 

available to AVs to make judgments about 

their surroundings by supplementing onboard 

vehicle sensors with basic safety information 

from surrounding vehicles. The Federal 

Communications Commission (FCC) has reserved 

a portion of a currently reserved 5.9 gigahertz 

bandwidth for V2V communications. 

Recommendations

Adopting the recommendations in this report 

will ensure people with disabilities benefit from 

and realize the freedom of fully autonomous 

vehicles. The recommendations address AV 

accessibility; funding for research; uniformity of 

requirements across the 50 states that address 

nondiscrimination, privacy, and ethics; financing; 

and inclusion of disability access in future hearing 

testimony. 

Key Recommendations include:

■ All requests for proposals that provide 

federal funding for the research or 

development of AVs or their components 

should include a requirement that 

respondents demonstrate that any resulting 

products incorporate accessibility for people 

with diverse disabilities. All technology 

products should be required to comply with 

Section 508 of the Rehabilitation Act.

■ The DOT should develop a framework and 

set of national guidelines for AV licensing at 

8 National Council on Disability
the state level. To the extent possible, these 

guidelines should not impose limitations 

on people with disabilities. The guidelines 

should consider the new capabilities of AVs 

and how people with disabilities can safely 

interact with and use these vehicles.

■ Congress should pass legislation requiring 

full accessibility for all types of common 

and public use AVs. Legislation should 

define a process that includes meetings 

with manufacturers, disability groups, and 

NHTSA. Relatedly, a disability advisory 

committee for automation should be 

created. The U.S. Access Board should be 

delegated the responsibility of developing 

standards. Existing rules, including Section 

504 of the Rehabilitation Act and the 

Americans with Disabilities Act, should 

be interpreted to require accessible AVs, 

including additional regulation by the U.S. 

Department of Justice, if needed. 

■ Moreover, Congress should prohibit 

discrimination on the basis of disability by 

states or any other governmental authority 

in licensing for the use of AVs. The remedy 

should be the withholding of federal 

highway funds to states that refuse to bring 

their licensing rules into compliance with 

this federal requirement. Such a provision 

would parallel the approach historically taken 

by the Federal Government with respect to 

the legal drinking age.

Self-Driving Cars: Mapping Access to a Technology Revolution 9
And then when you look at the rest of the community that can’t drive 

today—be it because they have a disability or because they’ve gotten 

older and they either don’t trust themselves to drive or family members have that very difficult conversation about taking the keys away—

enabling them to get around the community is really kind of a big deal.

Chris Urmson, Director [ Self-Driving Cars, Google

10 National Council on Disability
One of science fiction’s promised 

technologies—autonomous vehicles, 

also known as driverless cars or selfdriving vehicles—are on the horizon. Quickly 

advancing AV technology is producing one of the 

most dramatic revolutions in transportation since 

we shifted from the horse-drawn buggy to the 

Model A Ford more than 100 years ago. At that 

time, we removed the horse from the driving 

team. This time, we are removing the driver, and 

by removing the driver, AV technology promises 

to provide people with disabilities greater 

independence.

Headlines such as “Nissan Expects to 

Market Self-Driving Cars by 2020”10 and videos 

from Google with drivers who are blind have 

led us to believe that people who currently 

cannot obtain a driver’s license will “be in the 

driver’s seat” in five or so years. While AVs 

hold tremendous promise for people with 

disabilities, there is reluctant consensus among 

carmakers, technology companies, academics, 

and government agencies that fully autonomous 

vehicles (AVs that will not require human 

intervention while operating on the open road) 

may be decades away. In November 2014, Brad 

Stertz, a spokesperson for Audi, wrote in an 

email to the New York Times, “Fully autonomous 

driving is mostly a human generation away no 

matter who is making promises.”11

AVs will change the world for everyone, but 

the most dramatic impact could be for people 

with disabilities and people who are aging, 

provided that their needs are understood and 

technology solutions are paired to meet such 

needs. Inaccessible transportation remains one 

of the biggest deterrents to employment and 

community involvement in the United States. 

Accordingly, AVs can become an essential 

component of their independence, economic 

development, and well-being. AVs hold great 

potential to advance social inclusion by offering 

people with disabilities independent mobility to 

get to school, jobs, and all places that Americans 

go each day. They offer the possibility of ending 

the isolation that many people who are aging 

experience by keeping them connected with 

others and to activities that are often lost when 

we lose the ability to drive. It has the potential to 

create new and innovative solutions to first milelast mile issues (how one gets to and from their 

connection to transit) that have hindered many 

with disabilities for a long time; it is also likely 

that AV can help convert some ADA paratransit 

rides to fixed-route public transportation.

These remarkable benefits will not come at 

once and will not occur without cooperation 

among federal and state governments, research 

institutions, and private industry. Benefits 

will not emerge if the technology develops 

INTRODUCTION

Self-Driving Cars: Mapping Access to a Technology Revolution 11
without universal accessibility for people with 

diverse disabilities, including intellectual and 

developmental, sensory, and physical disabilities. 

Accessibility must be infused in the research and 

development of AVs. 

The data needs for those with disabilities should 

be further explored. Travelers with disabilities need 

in-depth accessibility information about points of 

interest and municipal infrastructure. An example 

of a data integration solution is a standardized user 

profile for a person with accessibility needs that 

allows for location-based services both locally and 

nationally. Based on the user profile, applications 

can be developed to alert relevant authorities in 

advance that a user requires accommodations, 

such as a wheelchair at the airport.

The reality of fully autonomous vehicles 

that people with disabilities can use is in 

the works, it is gradual, and it enjoys the 

support of governments, researchers, 

technology companies, automakers, and the 

public. Congress, through its legislative and 

appropriation powers, has an opportunity 

to guarantee that AVs contribute to a more 

inclusive, economically stable, and independent 

life for people with disabilities. 

12 National Council on Disability
Chapter 1.  Current State of Technology of 

Autonomous Vehicles

T

he vision of driverless vehicles carrying 

people, including people with disabilities 

who cannot drive to their destinations, has 

captured our imaginations and media attention. 

All major carmakers, automotive technology 

companies, academic researchers, and Google are 

developing technology that will eventually lead to 

fully automated vehicles where we are occupants 

instead of drivers. In the ten years since the 2004 

DARPA Grand Challenge,12 AV technology has 

accelerated to the point that, in December 2014, 

Google introduced a prototype vehicle with no 

manual controls, and Delphi Automotive test-drove 

a fully automated Audi SQ5 from San Francisco to 

New York City in March 2015.

The media predicts that fully autonomous 

vehicles will be available in the next decade or so. 

Optimism abounds that the time is near for AVs 

usable by people presently unable to drive, but 

many experts in the field suggest caution. Steven 

Shladover, a research engineer at the Partners for 

Advanced Transportation Technology program at 

the University of California, Berkeley, has been 

researching automotive technology for 

40 years. He wrote in 2012 that “Unfortunately, 

the vast majority of what is being written and 

said is naive, uninformed speculation that 

seriously underestimates the technical challenges 

that must be overcome before fully automated 

driving can become reality.”13 More recently, 

Shladover’s sentiments were echoed at the 

Transportation Research Board 2014 Automated 

Vehicle Symposium, as reported in the MIT 

Technology Review:

John Leonard, an MIT expert in autonomous 

driving who attended the conference, says 

that he and other academics find themselves constantly battling the assumption 

that all of the technology challenges associated with robotic cars have been solved, 

with only regulatory and legal issues remaining. “It’s hard to convey to the public 

how hard this is,” he says.14

At the same conference, 500 AV experts were 

asked when they would trust a fully robotic car 

to take their children to school. More than half 

responded 2030 at the very earliest, a fifth said 

not until 2040, and roughly 1 in 10 said never.15

Countering these longer-term predictions, 

manufacturers, such as Nissan, have announced 

Availability Predictions

Five hundred AV experts were asked when 

they would trust a fully robotic car to take 

their children to school. More than half said 

the year 2030 at the very earliest, a fifth said 

not until 2040, and roughly 1 in 10 said never.

Self-Driving Cars: Mapping Access to a Technology Revolution 13
that the technology for fully autonomous vehicles 

is rapidly evolving, and it expects to have 

technology in place by 2020; but vehicles are 

unlikely to be on the road until 2025. In March 

2015, Nissan CEO Carlos Ghosn stated, “After 

we’ve introduced our autonomous technology 

comes driverless cars, but they’re in the long 

term in ten years plus.”16 Regardless of when 

fully autonomous vehicles are available, it is 

important that they be fully accessible to people 

with diverse disabilities from the outset.

To bring a common understanding about the 

development and capabilities of autonomous 

vehicles, NHTSA developed categories along a 

continuum of automation. NHTSA’s Preliminary 

Statement of Policy Concerning Automated 

Vehicles17 provides what have become welladopted definitions of the different levels of 

vehicle automation. Increased autonomy and 

the resulting independence for people with 

disabilities who currently are barred from holding 

a driver’s license (Level 4) depends on better 

technology than what is currently available on 

vehicles and in the public infrastructure. NHTSA’s 

levels of automation include:

Level 0: No Automation. The human driver is in 

complete control of all functions of the car.

Level 1: Function-Specific Automation. One 

or more functions are automated, but they work 

independently of each other. The driver is always 

in control but can turn on a function like cruise 

control or parking assist.

Level 2: Combined-Function Automation. There 

are at least two automated functions that are 

designed to work together. In Level 2 vehicles, 

the driver can cede control to an automated 

function; but the driver remains in overall control, 

must remain alert, and is expected to take over all 

functions at any time. For example, cruise control 

working with automated speed control to sense 

traffic flow.

Level 3: Limited Self-Driving Automation. Drivers 

can give full control over to the vehicle under 

certain traffic or environmental conditions. The 

driving functions are sufficiently automated so 

that the driver can safely engage in other activities 

and the car will signal the driver to reengage with 

adequate time to safely regain control.

Level 4: Full Self-Driving Automation. The AV 

can drive itself without a human driver. The driver 

will provide trip or navigation input but is not 

expected to be available to take control of the 

vehicle at any time during the trip. 

Level 4 automation will make it possible for 

people with disabilities who are currently unable 

to obtain a driver’s license to take advantage of 

AV technology. Notably, hand controls, a common 

technology used by many drivers with physical 

disabilities, would not be needed in Level 4 vehicles 

but would still be needed in Level 0 through Level 3.

14 National Council on Disability
Many of the cars on the road today fall 

into Level 1, and at least one automaker has 

announced that it will have a Level 2 AV in the 

showroom by 2017.18 Beyond the Level 2 AV, 

there are no firm projections for when more fully 

autonomous cars will be available to commercial 

transportation providers or consumers. 

New and emerging technologies, increasingly 

sophisticated software, and algorithms that 

provide real-time processing of vast amounts of 

collected data are how AVs make their way on 

the road. AVs that have been undergoing testing 

on and off our roads by Google and carmakers 

over the past six years use a combination of 

technologies intended to complement each other 

to ensure safe driving. The technologies include: 

■ Global positioning systems (GPS), which use 

satellites to keep track of the AV’s position.

■ Light Detection and Ranging (LIDAR), which 

is the laser remote-sensing system seen on 

the roofs of test AVs. It uses spinning laser 

beams to create detailed “maps” of the 

vehicle’s surroundings.

■ Radar sensors that detect the location and 

speed of nearby vehicles.

■ Ultrasound sensors that detect distance to 

nearby objects.

■ Cameras that detect lane stripes, signs, 

stop lights, road signs, and other objects.

■ V2V and vehicle-to-infrastructure (V2I) 

systems, which allow AVs to communicate 

with each other and with roadway structures.

Google and vehicle manufacturers such as 

General Motors appear to be committed to 

enhancing and developing new technologies 

that will result in Level 4 vehicles, and these 

companies are aware that it will take time. 

According to GM spokesperson Dan Flores, 

“We believe that one day there will be fully 

automated cars that drive themselves under all 

circumstances.... A lot of societal benefits are 

possible, but we’re years away from achieving 

those benefits.”19 Regardless of when fully 

autonomous vehicles are available to the public, 

it is important that they be fully accessible 

to people with diverse disabilities from the 

beginning.

While personal use of self-driving cars by 

people with disabilities is likely years away, they 

may reap the benefits of AV technology sooner. 

Shladover says that it is possible to increase 

mobility by 2022 by applying AV technology to 

vehicles that use dedicated public rights of way, 

such as buses. The physical separation from 

the rest of the traffic allows the vehicles to be 

managed safely without human intervention.20

New and Emerging AV Technologies

■ Global positioning systems use satellites to 

keep track of the AV’s position.

■ Light detection and ranging (LIDAR) uses 

spinning laser beams to create detailed 

“maps” of the vehicle’s surroundings.

■ Radar sensors detect the location and 

speed of nearby vehicles.

■ Ultrasound sensors detect the distance to 

nearby objects.

■ Cameras detect lane stripes, stop lights, 

road signs, and other objects.

■ Vehicle-to-vehicle and vehicle-toinfrastructure systems allow AVs to 

communicate with each other and with 

roadway structures.

Self-Driving Cars: Mapping Access to a Technology Revolution 15
However, depending on the type of vehicle, 

people with disabilities may still require 

assistance in driverless public transit vehicles. 

For instance, wheelchair users may still need 

assistance securing their wheelchairs in an 

automated bus rapid transit system.

In fact, AV technology is already being 

used in four publicly operated wheelchairaccessible public transit systems around the 

world. Currently, public transit at West Virginia 

University; Masdar City, United Arab Emirates; 

Heathrow Airport, London; and Suncheon, South 

Korea, use guideways that are limited to their 

exclusive use. The driverless automatic user 

pods at Heathrow Airport are compliant with the 

UK Disability Discrimination Act, and by some 

reports, with the Americans with Disabilities Act. 

According to reports, the pods provide access 

for wheelchair users, include hearing loops for 

people who are deaf or hard of hearing, and 

raised symbols on all controls for people who are 

blind or have low vision.21

Testing of systems that eschew guideways 

and instead employ an array of sensors, 

GPS, and pre-programmed routes to navigate 

streets (such as Navia’s wheelchair-accessible 

electric autonomous shuttle) are being tested 

in Greenwich and Milton Keynes, England, and 

Singapore. The Dutch Parliament announced 

plans to start testing wheelchair-accessible, 

fully autonomous electric shuttles in the city of 

Wageningen by December 2015.22

Levels of Vehicle Automation

Level 0: No Automation. The human driver is in complete control of all functions of the car.

Level 1: Function-Specific Automation. One or more functions are automated, but they 

work independently of each other. The driver is always in control but can turn on a function 

like cruise control or parking assist.

Level 2: Combined-Function Automation. There are at least two automated functions 

that are designed to work together. In Level 2 vehicles, the driver can cede control to an 

automated function; but the driver remains in overall control, must remain alert, and is 

expected to take over all functions at any time. For example, cruise control working with 

automated speed control to sense traffic flow.

Level 3: Limited Self-Driving Automation. Drivers can give full control over to the vehicle 

under certain traffic or environmental conditions. The driving functions are sufficiently 

automated so that the driver can safely engage in other activities and the car will signal the 

driver to reengage with adequate time to safely regain control.

Level 4: Full Self-Driving Automation. The AV can drive itself without a human driver. The 

driver will provide trip or navigation input but is not expected to be available to take control of 

the vehicle at any time during the trip.

16 National Council on Disability
Chapter 2 Current Federal and State Approaches to 

Regulation of Autonomous Vehicles

F

ederal and state approaches to regulation 

of autonomous vehicles are still in their 

infancy. 

Congress has held two exploratory hearings 

on AVs. In May 2013, the Senate Committee 

on Commerce, Science, and Transportation 

convened “The Road Ahead: Advanced 

Vehicle Technology and Its Implications” to 

hear testimony from the automotive industry, 

researchers, and NHTSA on the safety benefits, 

potential risks, and policy implications from the 

development and implementation of advanced 

vehicle technologies.23

In November 2013, the Subcommittee on 

Highways and Transit of the House Committee 

on Transportation and Infrastructure also 

brought together experts from NHTSA and 

the automotive and academic sectors for its 

“Hearing on How Autonomous Vehicles Will 

Shape the Future of Surface Transportation.” The 

hearing examined the potential impacts of the 

technology on the transportation network as well 

as federal policies that may be necessary for their 

integration into the infrastructure system.24

In February 2015, after the release of their 

report “Hacking & Tracking: Security and Privacy 

Gaps Put American Drivers at Risk,” Senators 

Edward Markey and Richard Blumenthal 

announced that they would introduce legislation 

to establish federal standards for all new cars 

with wireless technology that would protect 

them from malicious hacking and to protect 

drivers’ privacy.25

In May 2013, NHTSA issued a “Preliminary 

Statement of Policy,” which identifies areas 

needing data to establish safety regulations and 

recommends principles that states may wish to 

apply, such as ensuring that drivers understand 

how to operate a self-driving vehicle safely 

and regulating testing of self-driving vehicles. 

According to this statement, NHTSA “does not 

recommend that states authorize the operation 

of self-driving vehicles for purposes other than 

testing at this time.”26

According to Stanford University’s updated 

“Automated Driving: Legislative and Regulatory 

Action,” the District of Columbia and four states 

(Nevada, Florida, Michigan, and California) have 

passed laws regarding autonomous vehicles.27

Bernard Soriano, Deputy Director of the California 

Department of Motor Vehicles, commented 

that the California and Nevada statutes relate 

to both testing and operations. The Nevada 

regulations are minimal, while California’s are 

“more exhaustive.” Soriano said that about two 

dozen states are debating allowing autonomous 

vehicles on their roadways but that “we don’t 

want a patchwork of regulations. We have 

NHTSA on our steering committee so they 

provide us their expertise. Potentially, the 

Self-Driving Cars: Mapping Access to a Technology Revolution 17
California regulations could be a model for federal 

regulations.”28

Bryant Walker Smith, Affiliated Scholar at the 

Center for Internet and Society at Stanford Law 

School, wrote in 2013 that automated vehicles 

are probably legal in the United States because 

no law categorically prohibits automated driving. 

Smith disputes Soriano’s suggestion that the 

legality of allowing AVs is a matter for states to 

debate. He also points out that the four states 

with related statutes do not really legalize AVs, 

but rather, regulate these technologies.29

The RAND Corporation issued a 2014 report 

cataloguing how every state is addressing the 

issue of autonomous vehicles, including both 

current and pending legislation.30

Despite the enormous amount of AV research 

and development, media attention, and the 

consensus that AVs will have a significant impact 

on lives and infrastructure, Thomas Bamonte, 

General Counsel at the North Texas Tollway 

Authority, noted that the 

agencies responsible 

for public infrastructure 

are paying little 

attention. He wrote, 

“Conspicuously absent 

from this list of the 

forces driving the development of driverlessvehicle technology are infrastructure providers 

such as highway authorities. State departments 

of transportation are neither focused on nor 

invested in driverless-vehicle technology.”31

One exception is Florida. In 2014, the Florida 

Department of Transportation created the Florida 

Automated Vehicles (FAV) initiative to plan and 

prepare for the eventual introduction of AVs on 

the road. The FAV initiative develops research, 

sponsors pilot projects, and is creating awareness 

of AV technologies. Florida currently hosts two 

AV urban testing sites in Orlando and Tampa. In 

2015, FAV announced two research projects to 

explore the implications of AV on policy. The first 

project, conducted by the University of Florida, will 

help policymakers and 

planners understand 

how metropolitan 

planning organizations 

will need to update 

long-range transportation 

plans, traffic operation 

considerations, and alternative land-use scenarios. 

The second project has direct implications for 

people with disabilities and people who are aging: 

researchers at Florida State University will examine 

how AV technology could assist transportationdisadvantaged individuals to remain mobile.32

While AVs are certainly a boon to 

transportation for people with disabilities, they 

will not eradicate the need for mass transit. 

Unfortunately, the promise of AVs has become 

a talking point for opponents of public transit 

Congressional Hearings 

on AV to 2015

May 2013—Senate Committee on 

Commerce, Science, and Transportation, 

“The Road Ahead: Advanced Vehicle 

Technology and Its Implications”

November 2013—Subcommittee on 

Highways and Transit of the House 

Committee on Transportation and 

Infrastructure, “Hearing on How Autonomous 

Vehicles Will Shape the Future of Surface 

Transportation.”

While AVs are certainly a boon 

to transportation for people with 

disabilities, they will not eradicate 

the need for mass transit.

18 National Council on Disability
systems. Fortune magazine described this trend, 

including how one Florida state senator argued 

“that the entire idea of bus- or train-based 

public transit is on the verge of obsolescence. 

Instead, he [saw] a future in which autonomous 

vehicles ... solve the region’s transit problems.”33

According to this logic, why put funding into 

public transit at all? 

Then, in 2015, an article in the web publication 

Streetsblog SF reported:

The Sunnyvale City Council voted 4-3 ... 

to oppose dedicated bus lanes that could 

cut transit riders’ trip [lengths] nearly in half 

along ... El Camino Real, making bus trips 

almost as quick as driving. More than one 

council member said the city shouldn’t invest in transit because self-driving cars are 

going to make it irrelevant....

Some council members dismissed better 

bus service entirely as impractical and outdated, despite the repeated success of dozens of [bus] rapid bus projects worldwide, 

and pointed to self-driving vehicles as a 

more appropriate transit solution for 

Silicon Valley.

“Instead of getting involved in Bus Rapid 

Transit, let’s start thinking of new and 

innovative ways that make travel better for 

everyone,” said Council member Davis. “I’m 

not against smart transportation, but smart 

transportation is not increased numbers of 

buses. World class transportation systems 

are not those that rely on traffic lights and 

roadways.”

“When cars are actually autonomous and 

speak to each other, they will be packed 

more densely on the roads, and they won’t 

be creating that congestion,” said Council 

member Whittum. “So the idea of spending 

huge amounts of money on concrete to do 

this, it’s not a futuristic 21st century idea, 

it’s actually a very 20th century idea.”

Not only are self-driving vehicles many 

years away from hitting the market, let 

alone saturating it, but even in a hypothetical future with autonomous vehicles, the 

geometric reality is that cars take up far 

more roadway space than buses, and the 

financial reality is that many people won’t 

use them.34

While AVs may significantly change the way 

we travel, avoiding important expenditures on 

public transit today would have a disproportional 

impact on the disability community, given their 

dependence on the public transit sector for a high 

proportion of their mobility.

Autonomous vehicles can also serve a positive 

role in public transit through, for example, public 

fleets of accessible autonomous vehicles. 

Additionally, people with disabilities as well as 

the public could continue to use buses, trains, or 

paratransit to reach and transfer to new closed 

loop AV systems.

State Laws on AVs, 2015

Adopted Legislation: DC, CA, FL, MI, NV

Pending Legislation: CT, GA, HI, ID, IL, MD, 

MA, MO, NJ, NY, ND, OR, TN, UT 

Self-Driving Cars: Mapping Access to a Technology Revolution 19
20 National Council on Disability
Chapter 3 Potential Technological Barriers to the 

Independent Use of Autonomous Vehicles 

by People with Disabilities

 [Self-driving car] technology can’t be less good than today’s traffic safety, and in the United States, there are 

3.3 million vehicle-hours per fatal accident and 64,400 vehicle-hours per injury. Developing fully autonomous 

vehicles that can achieve similar traffic-safety levels is “not a hard problem, that’s a superhard problem.”35

Steven Shladover, Research Engineer

Partners for Advanced Transportation Technology, UC Berkeley 

L

ack of personal independent mobility has 

resulted in the exclusion of people with 

disabilities from education, employment, 

and social life. Autonomous vehicles present a 

tremendous opportunity to end exclusion and 

promote independence for anyone who presently 

cannot obtain a driver’s license. As Steve Mahan, 

the Director of the Santa Clara Valley Blind Center 

in California, told the BBC, “In America, getting a 

driver’s license is a rite of passage. It represents 

being able, having the liberty to go where you want 

to go. Cars and car ownership are important parts 

of a sense of independence and personal power.”36

Generally, the current technological barriers 

standing between the use of Level 4 AVs by 

people with disabilities who are unable to hold a 

driver’s license are the same for people who can 

drive now. The technological “superhard problems” 

summarized below will have to be resolved before 

anyone, with or without a disability, enjoys a ride as 

a passive occupant in a driverless AV.

There is one critical and unique addition to 

the list of technical challenges that is of particular 

importance for people with disabilities—ensuring 

that AV user interfaces, how we give to and 

receive information from our vehicles, are 

accessible to all people. Engineers can facilitate 

access for these systems by building interfaces 

that provide audio and visual access, not one or 

the other. As Marc Riccobono, President of the 

National Federation of the Blind said, “The average 

engineer thinks you just talk to the car and listen 

to the car to get information. That won’t work for 

people who are deaf or hard of hearing.”37

The technical challenges include:

A. Accessibility and assistive technologies 

B. Limitations of sensors (cameras, LIDAR, 

radar, infrared, ultrasonic)

C. GPS and other mapping-system accuracy

D. Ultra-reliability and redundancy of 

software

E. Equipment failure

F. Software security 

Accessibility and Assistive Technologies

Advancing AV technology holds the key for 

independent use of vehicles by people who 

Self-Driving Cars: Mapping Access to a Technology Revolution 21
cannot hold a driver’s license. However, 

without explicit inclusion of accessibility in the 

development of AV technologies, the potential 

for opportunity wanes. During the early days 

of the Internet, and still today, accessibility for 

people with disabilities was not considered 

by web developers, and many people with 

disabilities experienced unnecessary obstacles 

to information (e.g., text that is inaccessible 

to screen reader software, lack of captions on 

audio content, keyboard-only navigation). Those 

obstacles diminish the opportunities available to 

people with disabilities that the Internet presents 

for people without disabilities. This is a lesson for 

AV researchers and engineers—the time is now 

to commit to and include accessibility. To guide 

their designs, AV developers can borrow from 

Web Accessibility in Mind’s guide for building 

accessibility into websites:

■ Awareness is the foundation to a 

commitment to accessibility. 

■ Leadership must express a commitment to 

accessibility.

■ Policies and procedures must be in 

place that back up the commitment to 

accessibility and outline specific standards, 

procedures, and methods for monitoring 

compliance. 

■ Training and technical support on 

accessibility and assistive technologies 

must be available to researchers, 

designers, and engineers.38

The inclusion of accessibility in AV user 

interfaces is not limited to programming access 

for navigation or user controls for people with 

sensory or physical disabilities. AV systems 

must not conflict with the use of hand controls 

(in Level 2 and 3 AVs), wheelchair ramps, lifts, or 

lockdown systems.

Limitations of Sensors (cameras, LIDAR, 

radar, infrared, ultrasonic)

■ Processing real-time data. Due to the variety 

of sensors in use on an AV, a great amount 

of raw data is being generated to build an 

accurate picture of the AV’s surrounding 

environment. According to the RAND 

Corporation:

Different combinations of sensors 

offer different combinations of capabilities and redundancies at different 

price-points, and cost is a key constraint. While every additional sensor 

may contribute some degree of 

navigational assistance in a particular 

set of conditions, it also increases 

the physical and computational complexity and cost of the vehicle, and 

decreases the feasibility of its introduction in commercial vehicles.39

■ Making sense of a quickly changing and 

dynamic environment. 

For example, AVs must be able to detect, 

understand, and process information 

about other vehicles; other road users, 

such as pedestrians (e.g., tell the difference between a person waving at someone and a police officer waving traffic to 

the side), bicyclists, runaway pets, and 

wildlife; and random obstacles like mattresses that fall off the backs of trucks. 

Sensors are not yet sophisticated 

enough to operate in weather conditions 

such as fog, snow, and severe storms.

22 National Council on Disability
GPS and Other Mapping-System 

Accuracy

GPS systems, even when combined with 

complementary systems such as inertial navigation 

systems that engage when GPS positioning is lost, 

must be robust and accurate. Indeed, if the vehicle 

has “machine vision” that is equivalent to human 

vision (a large technological challenge on its own), 

then the GPS only needs to be able to provide 

street-level positioning, while the vehicle itself will 

use machine vision for 

precise positioning. 

The AV will also have 

the advantage of 

digital information, 

where provided, such 

as sign location and 

information (e.g., speed 

limit changes and icing conditions).

Ultra-Reliability and Redundancy 

of Software

Developing reliability and redundancy remains 

a steep challenge to Level 4 AVs. According to 

UC Berkeley’s Steven Shladover,

The vehicle sensor, control, and actuation 

systems will need to be self-diagnosing, 

self-healing, and functionally redundant in 

order to prevent their own failures of hardware or software from causing crashes. This 

will require extensive development and testing beyond the current state of the art for 

consumer systems and is likely to be very 

expensive.40

Equipment Failure

AVs will need to be able to detect and act 

accordingly when sensors and other critical 

equipment are failing 

for all the same 

reasons equipment 

on cars fails now, 

including poor design 

or construction, 

physical damage, or 

aging.

Software Security

Passenger safety is reliant on software 

understanding the nature of threats posed by 

the environment. It also must be immune to 

harmful threats imposed by humans through the 

introduction of viruses or remote intervention 

over wireless networks. According to Raj 

Rajkumar of Carnegie Mellon, the technology 

does not yet exist.41

The average engineer thinks you just 

talk to the car and listen to the car to get 

information. That won’t work for people 

who are deaf or hard of hearing.

—Marc Riccobono, President, 

National Federation of the Blind

Self-Driving Cars: Mapping Access to a Technology Revolution 23
24 National Council on Disability
Chapter 4 Potential Policy and Societal Barriers to 

the Independent Use of Autonomous 

Vehicles by People with Disabilities

Policymakers,42 Google,43 and vehicle 

manufacturers44 have frequently stated 

that they expect a Level 4 AV that people 

with disabilities will be able to use independently. 

While the ultimate vision of fully accessible AVs for 

people with disabilities who do not have a driver’s 

license is often cited, research and development 

incentives in AVs follow the same principles as 

those for all market products: there must be the 

prospect of a market and significant revenues 

in order for companies to invest. According to 

research at Princeton University, a market appears 

to exist as shown by forecasts of an increase of 

vehicle miles traveled spurred by people who do 

not currently have driver’s licenses: 

When fleet penetration reaches 95% and 

when non-drivers are permitted to travel in 

robotic cars, VMT [vehicle miles traveled] 

increases may reach as high as 35% on portions of the transportation network.45

While the potential for profit is good, and 

private companies have taken the lead in AV 

research and development, there are still barriers 

to the realization of fully accessible AVs—barriers 

to the market in general and barriers specific to 

disability. The most significant policy and societal 

barriers to the realization of Level 4 AVs by 

people with disabilities are:

A. Driver’s Licensing, Regulations, and 

Model Legislation

B. Cost and Income Disparity Barriers

C. Attitudinal Barriers

D. Liability 

E. Privacy

F. Ethical Considerations

G. Cybersecurity

H. Infrastructure 

I. V2V Communications

Driver’s Licensing, Regulations, and 

Model Legislation

“For an autonomous vehicle without a 

steering wheel, I’m not sure you need 

any more training than you’d get for a 

dishwasher.” Ryan Calo, University of 

Washington School of Law.46

We know that fully self-driving cars can bring 

individual mobility to people who do not have a 

driver’s license, including people with disabilities, 

people who are aging, and youth. This begs the 

question, Is there any reason that an occupant 

of a Level 4 AV must be licensed? For all people 

with disabilities to benefit from the technology, 

the only answer is no, and it must be the same 

answer across all states, so that people with 

disabilities have the opportunity to use this 

technology no matter where they reside.

Self-Driving Cars: Mapping Access to a Technology Revolution 25
Notably, in the beginning, high levels 

of automated driving may rely on the road 

infrastructure as well as the vehicle. That is, both 

the vehicle and the road may need to be certified 

at Level 4. Accordingly, state and local agencies 

may need to determine if specific roads are ready 

for Level 4 vehicles.

Currently, states set 

the rules for issuing 

driver’s licenses and 

operating vehicles, and 

NHTSA sets vehicle 

safety standards. NHTSA 

also works with states 

on a variety of licensing 

and driver behavioral 

issues. These laws and 

regulations anticipate a human driver, but for 

Level 4 autonomy, this premise is outdated and 

dictates that the laws need to be revisited. Some 

automakers and experts in the field are calling 

for national standards for safety, liability, privacy, 

security, and driver’s licensing. When it comes to 

licensing drivers, however, stakeholders are split. 

NHTSA is reluctant to involve itself in “licensing, 

driving training, and conditions for operation related 

to specific types of vehicles.”47 Experts at the 

University of Texas at Austin, however, believe that 

the “U.S. DOT should develop a framework and 

set of national guidelines for AV licensing at the 

state level. With a more uniform set of standards 

in place, states can pool efforts developing safety, 

operational, and other requirements.”48

Steven Shladover agrees and believes that 

vehicle automation calls for new rules: “There 

need to be national rules to govern all of this, but 

the legislative process is very slow.”49

Given the existing patchwork of state laws 

in place for the testing of AVs (California, District 

of Columbia, Nevada, Florida, and Michigan), the 

potential for vastly different licensing rules is real, 

and the Federal Government should consider 

regulations that preempt state laws to ensure that 

people with disabilities are not prevented from 

operating fully autonomous vehicles. In the Houston 

Law Review, attorney 

Julie Goodrich calls for 

the Federal Government 

to uniformly define 

who is an “operator” 

and create uniform 

preemption regulations 

using its power under 

the Commerce Clause 

of the Constitution. She 

also stated that Congress 

has the option under the Supremacy Clause of 

the Constitution to create laws and regulations by 

preempting state statutes.50

Model Regulatory Framework

NHTSA is involved in developing a national 

regulatory framework for AV operations that 

states can use and has provided funding to the 

AAMVA to establish an Autonomous Vehicle Best 

Practices Working Group. The Working Group has 

representatives from motor vehicle departments 

and law enforcement from 16 states and Canada, 

state legal and technology representatives, the 

AAMVA, and NHTSA. The purpose of the Working 

Group is to develop a best practices guide 

to assist states in developing regulations for 

operation of autonomous vehicles and for testing 

the drivers who operate them. It will consider 

input from stakeholders such as manufacturers, 

technology companies, and academic 

researchers.51 The guide is due to NHTSA in 

the fall of 2016.52 At the Working Group’s first 

The potential for vastly different 

licensing rules is real. The Federal 

Government should consider 

regulations that preempt state 

laws to ensure that people with 

disabilities are not prevented 

from operating fully autonomous 

vehicles.

26 National Council on Disability
meeting in February 2015, it established two 

guiding principles for the framework: 

(1) regulations should be broad enough to allow 

jurisdictions to adopt them within their state 

laws, policies, and practices, yet specific enough 

so there is consistency among jurisdictions; and 

(2) the framework should address the technology 

that will be available in the near future and 

identify a path for the development of regulations 

for technology that will be available into the 

distant future.53

Because the launch of AV technology by 

most vehicle manufacturers is expected to be 

incremental, the second principle is particularly 

relevant to the operation of AVs by people with 

disabilities. State regulations developed today 

must be flexible enough to ensure that when 

fully self-driving cars are available to the public, 

those regulations have anticipated that people 

who currently do not hold driver’s licenses will be 

granted licenses.

Given the potential impact that the Working 

Group’s recommendations will have on future 

regulations throughout the United States, NHTSA 

should ensure that people with disabilities and 

experts in accessible and assistive technology 

inform its work. 

Model Federal and State Legislation

Appendix B to this report includes suggested 

model federal legislation relating to AVs, on which 

state laws should be predicated.

Bryant Walker Smith has drafted model 

state legislation that includes a brief but clear 

and unequivocal provision against disability 

discrimination in the use and operation of AVs by 

people with disabilities (Article 5.1.1):

Any natural person of legal driving age 

who solely by reason of physical disability 

is ineligible for a [regular noncommercial] 

driving license shall be eligible for an

automation-only license.

Walker Smith’s language is a good start, but 

should be amended to omit the word “physical,” 

as follows:

Any natural person of legal driving age who 

solely by reason of disability is ineligible for a 

[regular noncommercial] driving license shall 

be eligible for an automation-only license.

While this model legislation was developed for 

states, the Federal Government may also wish to 

use it, particularly the disability nondiscrimination 

provision, in any preemption legislation the 

Federal Government develops.

Cost and Income Disparity Barriers

Affordability may be one barrier to the 

independent use of AVs by people with 

disabilities. While no one yet knows what AVs 

will cost, initial indications are contradictory.

For example, a report by KPMG and the 

Center for Automotive Research pointed out 

factors that would lead to a high-costing AV:

Creating a 360-degree view of the vehicle’s 

environment requires a combination of sensors and may cost more than consumers 

Model Disability Nondiscrimination 

Legislative Language

“Any natural person of legal driving age who 

solely by reason of disability is ineligible for a 

[regular noncommercial] driving license shall 

be eligible for an automation-only license.”

Self-Driving Cars: Mapping Access to a Technology Revolution 27
are willing to pay. Light Detection and 

Ranging (LIDAR)-based systems provide 

360-degree imaging but are complex, expensive, and not yet ready for the market. 

The LIDAR system used in the Google car, 

for example, cost $70,000. Value chain 

stakeholders will need to have a clear and 

compelling business case before investing 

in this technology.54

At the same time, most, if not all, producers 

of AVs will be private automakers that will 

wish to sell them, so they cannot viably remain 

unaffordable. It is expected that some will be 

high-end and some will be lower-end. 

In cases where AVs circulate in a closed 

loop, or where a fleet of AVs will be shared 

and individually summoned by the user, the 

cost will be limited to the price points for rides 

taken, just as with car-share services today. 

These will likely be the most affordable way to 

use AVs.

Attitudinal Barriers

As reflected in Chapter 5 and other polls and 

surveys, AVs receive mixed reviews regarding 

trust by the public. Many people do not trust 

autonomous vehicles. However, most experts 

in the field believe public confidence will grow 

as automated features are phased in, as with 

any new technology. Jeffrey Miller, an associate 

professor of computer systems engineering at 

the University of Alaska-Anchorage, told Wired.

com:

As more vehicular controls begin being 

automated, such as parallel parking and automatic braking, people will become more 

accepting of autonomous technologies. So 

by 2040, driverless vehicles will be widely 

accepted and possibly ... the dominant vehicles on the road.55

Many technology writers believe that AVs 

will be safer than cars with human drivers, 

after the rigorous safety testing that is 

expected. For example, a report by KPMG 

and the Center for Automotive Research 

stated,

Over 40 percent of ... fatal crashes involve 

alcohol, distraction, drug involvement and/

or fatigue. Self-driven vehicles would not fall 

prey to human failings, suggesting the potential for at least a 40 percent fatal crashrate reduction.... Such reductions do not 

reflect crashes due to speeding, aggressive 

driving, over-compensation, inexperience, 

slow reaction times, inattention and various 

other driver shortcomings. Driver error is 

believed to be the main reason behind over 

90 percent of all crashes.56

And, according to the RAND Corporation,

Many factors contributed to reducing the 

rate of crashes, injuries, and fatalities—

Important Questions about AV Data

■ Who owns and has control of the data?

■ Can the data be used for marketing or sold?

■ Will data be discoverable in legal 

proceedings?

■ How long may data be retained?

■ How will data be destroyed?

28 National Council on Disability
including the gradual adoption of on-vehicle 

safety technologies. These systems were 

introduced in various model years: modern 

frontal air bags in 1984, antilock brakes in 

1985, electronic stability control in 1995, 

head-protecting side air bags in 1998, and 

forward collision warnings in 2000. But 

it typically takes three decades for safety 

features that start out on luxury vehicles 

to reach the entire vehicle fleet, as older 

vehicles are replaced with newer models. 

If the adoption of forward collision warning 

systems continues on its current path (standard on one percent and optional on 11 percent of model year 2010 vehicles), it could 

take nearly 50 years to reach 95 percent of 

the fleet.

Based on the data 

from 1960 to 2011, 

the rate of fatalities 

has halved every two 

decades on U.S. roadways. It is likely that 

AVs could bend this 

fatality curve substantially. But the safety 

benefits will likely depend upon the level of automation.57

It will be important that any restrictions on 

use by people with disabilities be based on 

actual risks, rather than unsubstantiated fears 

associated with disabled people.

Liability

“No one will insure a blind person to drive!”58

AVs will present many insurance and liability 

issues, especially as the technology is perfected 

and the role of human drivers diminishes. Even 

with estimates that vehicle accidents will be 

decreased by 90 percent, there will be times 

when a crash is unavoidable. In a fully selfdriving car, where there is no driver, who will be 

held liable? The insurance industry and vehicle 

manufactures are thinking about how liability will 

be assigned in the future. Does liability shift to 

vehicle manufacturers, technology companies, 

or infrastructure providers (federal, state, and 

local governments)? Quoted in the National 

Journal, Brad Stertz of Audi said, “That’s going 

to be an issue. It’s tough to argue the passenger 

(who may well be the victim) should be held 

responsible if a car controlled by a computer 

runs itself off the road. But should automakers 

face long, expensive lawsuits when life-saving 

technology suffers a rare glitch?”

If car owner liability 

decreases, the inverse 

may be true for car 

manufacturers, and 

as a result, they are 

considering whether to 

pass on the cost of risk 

to consumers.59 It has 

been suggested that 

Congress should limit 

their liability.60

While the issue of insurance coverage and 

liability remains unsettled, there are many years 

to solve it. In the meantime, it appears that the 

evolutionary nature of AVs fits within our current 

liability system. 

The incremental approach to automation, 

having the computer do more and more and 

the driver less and less fits comfortably within the existing legal regime. The challenges 

are where that begins to break down in the 

Even with estimates that vehicle 

accidents will be decreased by 

90 percent, there will be times when 

a crash is unavoidable. In a fully 

self-driving car, where there is no 

driver, who will be held liable?

Self-Driving Cars: Mapping Access to a Technology Revolution 29
far reaches of automation so when a human 

is no longer engaged in any meaningful 

sense do they still have legal obligations 

even though they don’t have technical requirements. When we see different service 

models, different vehicles that don’t quite 

look like cars today, how will law treat them? 

It’s concepts that are further from the present that pose the greatest legal challenges.61

Walker Smith’s expectation for assigning 

liability in the future is not that different from 

what we see today.

That will be a very fact specific inquiry. Just 

as today, if two vehicles crash, we need to 

ask about the circumstances, about the behavior of the driver, about the environment 

in order to determine who is liable. In the 

future, if an automated vehicle crashes, we 

will likely ask the same questions. What 

was the human supposed to be doing if 

anything, did they properly maintain the car, 

did they use it in the right environment? Did 

the manufacturer properly instruct the human user about that? Did the manufacturer 

supervise the human to the extent that 

that was required? Did the vehicle make a 

mistake? If so, what caused the mistake? 

Was it incorrect data, was it incorrect programming, was it some other failure? All of 

those will need to be considered after the 

fact to determine in that specific issue who 

was liable.62

Privacy

AVs should know where they are and software 

will produce substantial information about the 

vehicle and its surroundings. Consumer groups 

have indicated concern about the tremendous 

amounts of data that will be generated about the 

car and its occupants. Depending on what data is 

generated, it can have high value for advertisers, 

retailers, insurance companies, and public 

safety agencies. Important questions raised by 

consumer groups include:

■ Who owns and has control of the data?

■ Can the data be used for marketing or sold?

■ Will data be discoverable in legal 

proceedings?

■ How long may data be retained?

■ How will data be destroyed?

Reflecting on the experience of consumer 

adoption of the Internet, California’s Consumer 

Watchdog wrote in 2012 to then California 

Assembly Speaker John Perez: 

Without appropriate regulations, Google’s vehicles will be able to gather unprecedented 

amounts of information about the use of 

those vehicles. How will it be used? Just as 

Google tracks us around the Information Superhighway, it will now be looking over our 

shoulders on every highway and byway.63

While data collection for marketing purposes 

may be concerning, data collection about health 

and disability raises even more concern. Such 

data should remain confidential and not be 

shared with companies and other entities. For 

example, AV companies should not be informed 

if an individual goes to kidney dialysis four times 

a week or an adult day health center six times 

a week. 

30 National Council on Disability
Speaking at CES 2015, the annual high-tech 

trade show, Edith Ramirez, the chair of the U.S. 

Federal Trade Commission, warned of:

A future where smart interconnected devices enable technology firms to build a 

“deeply personal” and increasingly detailed 

and granular picture of consumers that will 

subject consumers to highly targeted advertising of products and services, as well 

as leaving them vulnerable to data attack. 

Ms. Ramirez said that smart devices [including AV (connected cars)] could potentially 

collect data such as an individual’s health, 

religious and other lifestyle preferences, 

and asked, “Will this information be used 

to paint a picture of you that you won’t see 

but that others will?” Data should only be 

gathered for a specific purpose, said Ms. 

Ramirez ... “I question the notion that we 

must put sensitive consumer data at risk on 

the off-chance a company might someday 

discover a valuable use for the information.”64 [Emphasis in original]

Data collection, management, ownership, 

and privacy issues are far from being settled 

and must be addressed by policymakers and the 

private sector.

Ethical Considerations

Ethical considerations abound in the frontier 

technology of AVs. For example, discussions 

are already underway about how AVs should be 

programmed to decide who can be injured in an 

inevitable accident.65 As the Associated Press wrote,

A large truck speeding in the opposite direction suddenly veers into your lane. Jerk 

the wheel left and smash into a bicyclist? 

Swerve right toward a family on foot? Slam 

the brakes and brace for head-on impact?

Drivers make split-second decisions based 

on instinct and a limited view of the dangers 

around them. The cars of the future—those 

that can drive themselves thanks to an array 

of sensors and computing power—will have 

near-perfect perception and react based on 

preprogrammed logic.

While cars that do most or ... all of the driving may be much safer, accidents happen. 

It’s relatively easy to write computer code 

that directs the car how to respond to a 

sudden dilemma. The hard part is deciding 

what that response should be.66

Society’s prejudices about disability must 

not be projected into the realm of AVs. For 

example, if, for some reason, an AV “knows” 

there is a person with a disability or an older 

person in the vehicle, that knowledge must not 

become part of any program that may steer the 

vehicle’s decision-making process in unavoidable 

collisions. Driver’s licenses already include age 

information. If operating licenses for people with 

disabilities are permitted to include information 

about the person’s ability to take over manual 

operation and that is conveyed to other selfdriving cars, software engineers could then make 

that information part of the calculus in a collision 

decision between the cars. Additionally, in a selfdriving vehicle, an occupant’s disability status has 

no role in liability assignment.

Cybersecurity

At a Senate hearing on vehicle technology, Sen. 

John Rockefeller asked witnesses, “And as our 

Self-Driving Cars: Mapping Access to a Technology Revolution 31
cars become more connected—to the Internet, 

to wireless networks, with each other, and with 

our infrastructure—are they at risk of catastrophic 

cyber-attacks?”67 The simple answer is yes.

As early as 2010, researchers from the 

University of California and University of 

Washington demonstrated that it was possible 

to introduce a virus into a car’s computerized 

systems that could cause it to crash by shutting 

down the engine or engaging the brakes.68

AV technology uses the same wireless 

technologies as cell 

phones, leaving them 

vulnerable to attacks from 

anywhere in the world. 

Cybersecurity experts 

have pointed out that 

carmakers have not adequately protected their 

systems, leaving them vulnerable to theft and 

control by hackers’ malicious attacks. Bruce Snell, 

an expert at McAfee, a leading digital security firm, 

pointed out how self-driving cars escalate the need 

for car manufacturers to resolve security issues.

If your laptop crashes you’ll have a bad day, 

but if your car crashes that could be life 

threatening. I don’t think people need to 

panic now. But the future is really scary.69

In response to Senator Rockefeller’s question, 

NHTSA Administrator David Strickland stated, 

“We have initiated cybersecurity research, with 

the goal of developing a preliminary baseline 

set of threats and how those threats could be 

addressed in the vehicle environment.”70

In response to growing concern that security 

issues might impact marketability, in July 2014 

the Alliance of Automobile Manufacturers and 

the Association of Global Automakers announced 

plans to create an Information Sharing and 

Analysis Center to address the cybersecurity 

threat, similar to those created by the energy, 

financial services, and other industry sectors.71

In February 2015, Sen. Edward Markey 

released a report detailing the responses from 

automakers to questions he posed to them 

about security of their digital systems. The 

report states, “These findings reveal that there 

is a clear lack of appropriate security measures 

to protect drivers against hackers who may 

be able to take control of a vehicle or against 

those who may wish to 

collect and use personal 

driver information.”72 

Senator Markey’s 

report reinforces the 

need for policymakers 

and the private sector to ensure that current 

and emerging technology have the capacity to 

prevent breaches by malicious agents. 

Infrastructure

Much of our attention is focused on the 

breakthrough in rapidly advancing technology 

taking place now and in the future in the 

drive to develop AVs. Just as interesting and 

breathtaking is the change that will occur in the 

public infrastructure. At a November 2013 House 

hearing on AV, U.S. Rep. Thomas Petri made it 

clear that Congress is aware that change is on 

the horizon and must act accordingly.

All of these concerns must be addressed 

before benefits from autonomous vehicles 

can be realized. Vehicles and infrastructure 

that they utilize are becoming increasingly 

integrated with computer technology, which 

has the potential to revolutionize highway 

safety and mobility in our country. In order 

to see these benefits come to fruition, 

If your laptop crashes you’ll have a 

bad day, but if your car crashes that 

could be life threatening.

– Bruce Snell, McAfee

32 National Council on Disability
Federal and State officials should begin 

planning for the benefits and the challenges 

that autonomous vehicles will bring to the 

future of our Nation’s surface transportation 

system.73

The extent to which our infrastructure needs 

to be upgraded, what it will cost, or how it will 

be funded is not yet known or agreed upon. 

On the one hand, Google and carmakers such 

as Nissan and GM have maintained that their 

AVs will not require substantial change to the 

public infrastructure. Mike Robinson, GM Vice 

President of Sustainability and Global Regulatory 

Affairs, testified at the November 2014 House 

hearing:

It should not be surprising that GM is investing in technologies that ultimately will provide even greater levels of driver assistance 

and vehicle management, and importantly, 

we are working on systems that do not require dramatic upgrades or modifications to 

the national highway infrastructure network.

To the greatest degree possible, our goal is 

to keep the systems we are talking about 

contained within the vehicles and between 

the vehicles. However, we do have one 

low-tech need: clearly marked lanes and 

shoulders. This will enhance the capabilities 

of these technologies that we are already 

using to sense the road, such as radar, ultrasonic sensors and cameras, along with, of 

course, GPS location capabilities.74

On the other hand, Terry Bennett, the senior 

industry program manager and lead strategist 

for civil infrastructure at Autodesk, believes that 

vehicles are only as smart as the infrastructure 

that surrounds them. Bennett contends that 

the investments in smarter infrastructure will 

provide benefits that go beyond transportation to 

other kinds of infrastructures such as water and 

utilities.75

I think [autonomous cars] more than anything create a lot of space for people to 

think differently.... But with Detroit and 

other cities looking at dedicated roads for 

vehicle-to-vehicle or vehicle-to-infrastructure 

communication, you’re starting to see the 

point that having infrastructure that’s intelligent, has sensors and can communicate, 

is a much better long term approach than 

trying to automate a single car.76

In recognition of the challenges and 

opportunities that AVs and connected vehicles 

pose for the national infrastructure, the American 

Association of State Highway and Transportation 

Officials released “National Connected Vehicle 

Field Infrastructure Footprint Analysis.” This 

report helps state and local agencies understand 

and know to prepare for a future of vehicles 

requiring V2V and V2I communications, and what 

investments may be needed.77

V2V Communications

Many stakeholders, such as automakers BMW 

and Nissan, along with the DOT, believe that 

V2V, V2I, and vehicle-to-everything (V2X) 

technologies (e.g., cell phones, pedestrians, 

and cyclists) will help support the development 

of AVs because they will afford AV systems 

with more robust information. These 

communications will require a secure, fast, 

and extremely reliable network. The Federal 

Government had the foresight to support 

the development of dedicated short-range 

Self-Driving Cars: Mapping Access to a Technology Revolution 33
communications applications that allow V2V and 

V2I communications, and the FCC has reserved 

5.9 gigahertz bandwidth for this use.

Nevertheless, with the phenomenal 

expansion of devices and technologies that use 

broadband, the FCC is considering allowing 

nonautomotive wireless technologies the use 

of a portion of this reserved block, which has 

carmakers and others concerned. Joachim 

Taiber, Director of the International Center for 

Automotive Research at Clemson University, 

stated bluntly, “A dropped call on a cell phone 

caused by interference is no big deal, but the 

loss of even a little data on a car’s collisionavoidance system could be fatal.”78

At the November 2013 House hearing on 

AV, Kirk Steudle from the Michigan Department 

of Transportation told representatives that the 

FCC’s contemplation of giving away some of 

the bandwidth must be considered carefully:

Connected vehicle technology must have a 

secure and fast communications network to 

work, faster than is currently available with 

traditional cellular communications. The FCC 

has reserved 5.9 gigahertz bandwidth for 

this use. They are now considering sharing 

this use with other wireless communications providers, and we think that that 

needs to be done very cautiously.79

34 National Council on Disability
NCD Recommendations for Preventing or Eliminating Technological, 

Policy, and Societal Barriers to the Independent Use of Autonomous 

Vehicles by People with Disabilities

1. Congress should appropriate funds to DOT so that NHTSA has the resources to ensure 

that all user interface systems on autonomous vehicles are fully accessible to people with 

diverse disabilities. 

2. All federal requests for proposals that provide funding for the research or development of 

AVs or components should include a requirement that respondents demonstrate that any 

products resulting from the research or development incorporate accessibility, and that all 

resulting products will be fully accessible for people with diverse disabilities. All technology 

products should be required to comply with Section 508 of the Rehabilitation Act.

3. Congress should increase funding to DOT’s Intelligent Transportation Systems’ Joint 

Program Office to ensure that NHTSA and other DOT modes can conduct research on AVs 

and develop tools to establish safety and accessibility standards for AVs.

4. Policymakers should support research into how AVs could affect transportation and landuse patterns, and how to best alter U.S. transportation systems to maximize benefits 

while minimizing negative consequences of the transition to a largely autonomous fleet of 

motor vehicles. This should include the relationship of AVs to public transit.

5. Carmakers and DOT (as well as the 50 state DOT agencies) should work together to 

create a national “smart highway” initiative and draft plans for AVs, rather than allowing 

the development of a confusing and conflicting patchwork of plans across the United 

States. 

6. DOT should develop a framework and set of national guidelines for AV licensing at the 

state level. The development of the guidelines should include input from a cross-section 

of people with disabilities, and the guidelines should not impose limitations on people 

with disabilities to the extent possible. Any restrictions must be based on actual risks 

rather than unsubstantiated fears about people with disabilities.

7. Congress should pass legislation that establishes firm limitations regarding privacy of AVrelated data.

8. Congress should pass legislation that, as software is developed to make decisions 

about harm in unavoidable collisions, collected data should not include disability-specific 

information about the passengers in AVs.

9. Legislation should preclude discrimination on the basis of disability by states or any 

other governmental authority in licensing for the use of AVs. The remedy should be the 

withholding of federal highway funds to states that refuse to bring their licensing rules into 

Self-Driving Cars: Mapping Access to a Technology Revolution 35
 compliance with this federal requirement. Such a provision would parallel the approach 

historically taken by the Federal Government with respect to the legal drinking age. 

10. Congress should allocate, and the Executive Branch should administer, low-interest 

loans, subsidy programs, financing, and tax credits (among other examples) to help 

people with disabilities and low-income individuals and families to afford AVs.

11. Congress should pass legislation requiring full accessibility for all types of common 

and public use AVs. Legislation should define a process that includes meetings with 

manufacturers, disability groups, and NHTSA. Relatedly, a disability advisory committee 

for automation should be created. The U.S. Access Board should be delegated this 

responsibility, as well as that of developing standards. Existing rules, including 

Section 504 of the Rehabilitation Act and the Americans with Disabilities Act, should 

be interpreted to require accessible AVs, including additional regulation by the U.S. 

Department of Justice, if needed. 

12. Congress should pass legislation requiring that, as a matter of civil rights, all new 

technology incorporate the needs of people with disabilities at the earliest possible point. 

Congress should create a transportation institute to guarantee that new transportation 

technology is accessible to people with disabilities. A permanent task force or other 

oversight body should bring together federal and state governments, private sector 

manufacturers, and the legal and insurance industries to create a complete package that 

will enable universal use of vehicles and other forms of transportation as they emerge. 

13. People with disabilities and accessibility experts must be included in all future 

Congressional hearings concerning AVs.

36 National Council on Disability
Appendix A Summary of Enacted State Laws on 

Autonomous Vehicles

State Bill No. Purpose

Date 

Enacted Bill Text

California SB 1298 Defines autonomous vehicles 

and authorizes the operation 

of autonomous vehicles 

for testing if specified 

requirements are met, 

including that the driver be 

seated in the driver’s seat, 

monitoring the safe operation 

of the autonomous vehicle, 

and capable of taking over 

immediate manual control of 

the autonomous vehicle in 

the event of an autonomous 

technology failure or other 

emergency. The bill also 

required the California 

Department of Motor Vehicles 

(CA DMV) to issue regulations 

by January 1, 2015, that 

establish the requirements that 

manufacturers must meet to 

certify that their autonomous 

vehicle has been successfully 

tested, meets certain safety 

requirements, and is ready for 

the public to operate on public 

roads. The CA DMV missed the 

January 1, 2015, deadline.

9/25/13 http://www.leginfo.

ca.gov/pub/11-12/bill/sen/

sb_1251-1300/sb_1298_

bill_20120925_chaptered.pdf

District of 

Columbia

B 19-0931 To authorize autonomous 

vehicles to operate on District 

roadways, to require the 

Department of Motor Vehicles 

to create an autonomous 

vehicle designation, and 

to establish safe operating 

protocols for autonomous 

vehicles.

1/23/13 http://dcclims1.dccouncil

.us/images/00001

/20130110191554.pdf

Self-Driving Cars: Mapping Access to a Technology Revolution 37
State Bill No. Purpose

Date 

Enacted Bill Text

Florida CS/HB 1207 Provides for operation of 

autonomous motor vehicles 

on public roads; directs 

DHSMV to prepare report 

on safe operation of such 

vehicles; provides for content 

of report; requires submission 

of report to Legislature.

4/16/12 http://www.myfloridahouse

.gov/Sections/Documents/

loaddoc.aspx?FileName

=_h1207er.docx&Document

Type=Bill&BillNumber=1207

&Session=2012

Michigan SB 0169 To define autonomous 

vehicles and allow testing by 

certain parties under certain 

conditions and directs the 

Michigan Department of 

Transportation to report by 

February 1, 2016, whether 

any additional legislative or 

regulatory action that may be 

necessary for the continued 

safe testing of automated 

motor vehicles and automated 

technology installed in motor 

vehicles.

12/26/12 http://www.

legislature.mi.gov/

documents/2013-2014/

publicact/htm/2013-PA-0231

.htm

Nevada AB 511 Requires the Nevada 

Department of Motor Vehicles 

(NV DMV) to adopt regulations 

allowing autonomous vehicles 

in Nevada and defines 

“autonomous vehicle.” It also 

requires the NV DMV to create 

regulations to establish a 

driver’s license endorsement 

for the operation of an AV in 

Nevada.

6/17/11 http://www.leg.state.nv.us/

Session/77th2013/Bills/AB/

AB511.pdf

Nevada SB 313 Amends the law to state 

that there must be a human 

present in the driver’s seat 

during testing, relieves 

original manufacturers of 

vehicles of liability for injury 

that results from a conversion 

to an autonomous vehicle 

by a third party, and requires 

$5,000,000 liability insurance 

before testing an AV in the 

state.

6/2/13 http://leg.state.nv.us/

Session/77th2013/Bills/SB/

SB313_EN.pdf

38 National Council on Disability
Model Legislative Language – Recommendation No. 6

Language for the development of national guidelines ensuring nondiscrimination on the basis of 

disability in autonomous vehicle licensing.

Act to Ensure Nondiscrimination on the Basis of Disability for Autonomous Vehicle Operating 

Licenses and Establishing an Autonomous Vehicle Licensing Disability Advisory Committee 

Findings

(1) Because there exists a patchwork of state laws for the testing of autonomous vehicles, and the potential for vastly different state driver’s licensing rules is real, there is a need for federal guidance to 

ensure that people with disabilities across the United States are, in a consistent way, not prevented 

from operating fully autonomous vehicles, particularly people with disabilities who are currently unable to obtain a driver’s license;

(2) in enacting the Americans with Disabilities Act (ADA), Congress sought to “provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities;”

(3) there is a need to ensure that Level 4 autonomous vehicles, as defined by the National Highway 

Traffic Safety Administration (NHTSA), are accessible to and operable by people with disabilities, 

particularly people with disabilities who currently are unable to obtain a driver’s license.

Purposes

The purposes of this act are

(1) to ensure that state or federal autonomous vehicle licensing regulations do not discriminate on the 

basis of disability;

(2) to develop guidance that ensures that state or federal regulations do not impose limitations on the 

operation of autonomous vehicles by people with disabilities to the extent possible; and

(3) to ensure that the development of federal guidance for autonomous vehicle licensing includes input 

from a cross-section of people with disabilities.

Appendix B Model Legislation

Self-Driving Cars: Mapping Access to a Technology Revolution 39
Definitions

(1) “disability” means a physical or mental impairment that substantially limits one or more major life activities of an individual, a record of such impairment, or being regarded as having such an impairment. 

This definition must be broadly interpreted, consistent with the ADA Amendments Act of 2008.

(2) “autonomous vehicle” means a Level 4 autonomous vehicle capable of full self-driving automation 

as defined by NHTSA. The autonomous vehicle can drive itself without a human driver. The driver 

will provide trip or navigation input but is not expected to be available to take control of the vehicle 

at any time during the trip. 

(a) IN GENERAL. To ensure that no state deny a person a license to operate an autonomous vehicle solely on the basis of the person’s disability, the Secretary of Transportation will disseminate 

guidance to the states to ensure that people with disabilities are not prevented from operating 

fully autonomous vehicles, particularly people with disabilities who are currently unable to obtain a driver’s license. The Secretary shall consider the recommendations of the autonomous 

vehicle licensing disability advisory committee established in subsection (b) when developing 

the guidance. 

(b) AUTONOMOUS VEHICLE LICENSING DISABILITY ADVISORY COMMITTEE.

(1) ESTABLISHMENT. Not later than 60 days after passage of this Act, the Secretary of Transportation shall establish an advisory committee to be known as the Autonomous Vehicle 

Licensing Disability Advisory Committee (“Advisory Committee”).

(2) MEMBERSHIP. The Advisory Committee shall be composed of the following members:

(A) The Secretary of Transportation (or the Secretary’s designee).

(B) The Administrator of NHTSA (or the Administrator’s designee).

(C) The Director of the Office for Civil Rights, Department of Transportation (or the Director’s 

designee).

(D) The Chairperson of the National Council on Disability (or the Chairperson’s designee)

(E) The following members, to be appointed by the Secretary:

(i) Representatives of State departments of motor vehicles, and state public safety 

agencies;

(ii) Representatives of national organizations representing people with disabilities. Individual representatives shall include but are not limited to individuals who are blind 

and who have visual impairments; individuals who are deaf and who have hearing 

loss; individuals with intellectual, cognitive, or development disabilities; and individuals who have mobility disabilities;

(iii) Representatives of national organizations representing people who are elderly; 

(iv) Experts in accessible and assistive technology; and

(v) Qualified representatives of such other stakeholders as the Secretary considers appropriate.

40 National Council on Disability
(3) RECOMMENDATIONS. The Advisory Committee will develop recommended guidelines for 

autonomous vehicle licensing that ensure that federal or state regulations do not discriminate or set limitations on the operation of autonomous vehicles by people with disabilities 

to the extent possible and that any such restrictions be based on actual risks, rather than 

unsubstantiated fears associated with people with disabilities.

(4) REPORT. The Advisory Committee will submit its report to the Secretary not later than six 

months after the date of the establishment of the Advisory Committee.

(5) The Secretary will disseminate the guidelines to the states within six months after the date 

of receipt of the Advisory Committee’s report.

Model Legislative Language – Recommendation No. 9

Congressional legislation should preclude discrimination on the basis of disability by states or any other 

governmental authority in licensing for the use of AVs. The remedy should be the withholding of federal 

highway funds to states that refuse to bring their licensing rules into compliance with this federal 

requirement. Such a provision would parallel the approach historically taken by the Federal Government 

with respect to the legal drinking age. 

Uniform Disability Nondiscrimination Autonomous Vehicle 

Licensing Act

(a) Withholding of Funds for Noncompliance.

(1) In general.

(A) The Secretary shall withhold 10 percent of the amount of Federal-aid highway funds to be apportioned to any State that discriminates on the basis of disability in licensing individuals to 

use or operate Level 4 autonomous vehicles as defined by the National Highway Traffic Safety 

Administration (NHTSA).

(2) A state will be found in compliance if enacted licensing regulations have affirmative statements of 

nondiscrimination on the basis of disability that meet or exceed standards from the Department 

of Transportation guidance to the states on nondiscrimination on the basis of disability in licensing 

people with disabilities to use or operate autonomous vehicles dated .

(b) Effect of Withholding of Funds. No funds withheld under this section from apportionment to 

any State after , shall be available for apportionment to that State.

(c) Discrimination on the basis of disability includes promulgating, implementing, or enforcing licensing 

regulations that have the effect of denying people with disabilities who have reached the legal driving 

age a license to use or operate a Level 4 autonomous vehicle solely on the basis of their disability.

Model Legislative Language – Recommendations No. 11 and No. 12

Congress should adopt legislation requiring full accessibility for all types of autonomous vehicles, based 

on minimum standards from the U.S. Access Board, which must include convening a meeting with 

manufacturers, disability groups, and NHTSA. 

Self-Driving Cars: Mapping Access to a Technology Revolution 41
Congress should enact legislation requiring that all new technology incorporate the needs of people 

with disabilities at the earliest possible point, as a matter of civil rights. 

Ensuring Accessibility in Autonomous Vehicles

Findings

(1) while emerging technologies such as websites, consumer devices, and software applications have 

transformed the way Americans work, communicate, shop, and learn, many of these technologies 

are inaccessible to people with vision, hearing, and/or other disabilities because accessibility was 

not considered during research and development;

(2) in enacting the Americans with Disabilities Act (ADA), Congress sought to “provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities;”

(3) there is a need to ensure that Level 4 autonomous vehicles, as defined by the National Highway 

Traffic Safety Administration (NHTSA), are accessible to and operable by people with disabilities, 

particularly people with disabilities who currently are unable to obtain a driver’s license. 

Definitions

(1) “disability” means a physical or mental impairment that substantially limits one or more major life 

activities of an individual, a record of such impairment, or being regarded as having such an impairment. This definition must be broadly interpreted, consistent with the ADA Amendments Act of 

2008.

(2) “autonomous vehicle” means a Level 4 autonomous vehicle capable of full self-driving automation 

as defined by NHTSA. The autonomous vehicle can drive itself without a human driver. The driver 

will provide trip or navigation input, but is not expected to be available to take control of the vehicle 

at any time during the trip. 

(3) “assistive technology” is any item, piece of equipment, or system, whether acquired commercially, 

modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities of individuals with disabilities.

(4) “accessible” means a product that complies with standards developed by the U.S. Access Board.

(a) IN GENERAL. To ensure that Level 4 autonomous vehicles, as defined by the National Highway 

Traffic Safety Administration (NHTSA), are accessible to and operable by people with disabilities, particularly people with disabilities who currently are unable to obtain a driver’s license.

U.S. ACCESS BOARD’S AUTONOMOUS VEHICLE ACCESSIBILITY ADVISORY 

COMMITTEE.

(1) ESTABLISHMENT. Not later than 90 days after passage of this Act, the U.S. Access Board shall 

establish an advisory committee to be known as the Autonomous Vehicle Accessibility Advisory 

Committee (“Advisory Committee”).

42 National Council on Disability
(2) MEMBERSHIP. The Advisory Committee shall be composed of the following members:

(A) The Secretary of Transportation (or the Secretary’s designee).

(B) The Administrator of NHTSA (or the Administrator’s designee).

(C) A representative of the Department of Transportation, Office of the Assistant Secretary for Research and Technology.

(D) The Chairperson of the National Council on Disability (or the Chairperson’s designee)

(E) The following members:

(i) Representatives of national organizations representing individuals with disabilities. Individual representatives shall include but are not limited to individuals who are blind and who have 

visual impairments; individuals who are deaf and who have hearing loss; individuals with 

intellectual, cognitive, or development disabilities; and individuals who have mobility disabilities;

(ii) Representatives of national organizations representing people who are elderly; 

(iii) Experts in accessibility and assistive technology; 

(iv) Representatives of automotive manufactures;

(v) Representatives of companies developing autonomous vehicle technologies, including software, vehicle parts or components;

(vi) Qualified representatives of such other stakeholders as the Secretary considers appropriate.

(F) CONSULTATION WITH NONMEMBERS. The Advisory Committee shall consult with groups 

that are not represented on the Advisory Committee, especially to consider new and developing technologies that may help to ensure that autonomous vehicles will be accessible to 

and operable by people with disabilities who currently cannot obtain a driver’s license. Those 

groups may be:

(i) entities engaged in federally funded research; and

(ii) academic institutions engaged in relevant work and research.

(3) MEETINGS.

(A) INITIAL MEETING. The initial meeting of the Advisory Committee shall take place not later than 

150 days after the date of enactment of the Ensuring Accessibility of Autonomous Vehicles Act.

(B) OTHER MEETINGS. After the initial meeting, the Advisory Committee shall meet at least semiannually.

(4) CONSULTATION WITH NONMEMBERS. The Advisory Committee shall regularly meet with groups 

that are not represented on the Advisory Committee to consider new and emerging technology that 

may be beneficial in ensuring the accessibility of autonomous vehicles.

(5) RECOMMENDATIONS. The Advisory Committee will develop and submit annual reports under 

paragraph (7), including recommendations for the development of standards that ensure that 

autonomous vehicles are accessible to people with disabilities. The recommendations shall include protocol for ensuring that standards can be amended to incorporate emerging and future 

technologies.

Self-Driving Cars: Mapping Access to a Technology Revolution 43
(6) REPORT. The Advisory Committee will submit a report to the Secretary and the U.S. Access Board 

not later than 18 months after the date of the establishment of the Advisory Committee, and every 

year thereafter until Congress sunsets the Advisory Committee.

(c) INTEGRATING ACCESSIBILITY REQUIREMENTS INTO THE DESIGN PROCESS.

(1) The Department of Transportation, Office of the Assistant Secretary for Research and Technology 

(OST-R) shall be responsible for ensuring that federally funded autonomous vehicle research and development incorporate the needs of people with disabilities at the earliest possible point. 

44 National Council on Disability
Harry Brown, national disability advocate, Port Huron, MI, July 18, 2014.

Ann Cupolo-Freeman, Member, Board of Directors, Disability Rights Education & Defense Fund, 

July 28, 2014.

Lauren Grudzinski, Work Incentive Benefits Specialist, Independence First, Milwaukee, WI, July 15, 

2014.

Sarah Holland, U.S. Public Policy for Strategy & Programs on Youth and Technology, Google, 

September 29, 2014.

David New, Chair, Disability Access Committee of Miami Beach and President, Miami Beach Council of 

the Blind, July 8, 2014.

Mark Riccobono, M.S.ed, President, National Federation of the Blind, October 7, 2014.

Karen Rose, Marriage and Family Therapist and person who is blind, July 9, 2014.

Daniel C. Smith, Senior Associate Administrator for Vehicle Safety; Nathaniel Beuse, Associate 

Administrator for Vehicle Safety Research; R. Ryan Posten, Associate Administrator for Rulemaking; 

Steve Wood, Office of Chief Counsel; and Regina Morgan, Office of Civil Rights; National Highway 

Traffic Safety Administration (NHTSA); December 3, 2014.

Bernard Soriano, Deputy Director, California Department of Motor Vehicles, September 29, 2014 and 

May 27, 2015. 

Appendix C List of Interviews

Self-Driving Cars: Mapping Access to a Technology Revolution 45
46 National Council on Disability
1 “Hearing on How Autonomous Vehicles Will Shape the Future Of Surface Transportation,” Subcommittee on 

Highways and Transit of the Committee on Transportation and Infrastructure, November 19, 2013; and Senate 

Committee on Commerce, Science, and Transportation, Hearing on The Road Ahead: Advanced Vehicle Technology and Its Implications, May 15, 2013.

2 National Highway Traffic Safety Administration (NHTSA), “Preliminary Statement of Policy Concerning Automated Vehicles,” May 30, 2013, accessed March 3, 2015, www.nhtsa.gov/staticfiles/rulemaking/pdf/Automated_

Vehicles_Policy.pdf.

3 Adopted Legislation: California, District of Columbia, Florida, Michigan, Nevada. Pending Legislation: Connecticut, Georgia, Hawaii, Idaho, Illinois, Maryland, Massachusetts, Missouri, New Jersey, New York, North 

Dakota, Oregon, Tennessee, Utah. Considered, Failed to Adopt Legislation: Arizona, Louisiana, Minnesota, New 

Hampshire, Oklahoma, South Carolina, South Dakota, Texas, Washington, Wisconsin.

4 Thomas J. Bamonte, “Autonomous Vehicles: Drivers of Change,” RoadsandBridges.com, Summer 2013, www

.roadsbridges.com/sites/default/files/05_autonomous%20vehicles.pdf.

5 David E. Zoia, “Autonomous Vehicles Coming, But Not Slam Dunk You May Have Read About,” Wards Auto, 

April 21, 2015, http://wardsauto.com/vehicles-technology/autonomous-vehicles-coming-not-slam-dunk-you-mayhave-read-about.

6 Bernard Soriano, Deputy Director, California Department of Motor Vehicles, Interview with Susan Henderson, 

May 27, 2015.

7 Theo Francis, “The Driverless Car, Officially, Is a Risk,” Wall Street Journal, March 3, 2015. Accessed April 12, 

2015, www.wsj.com/articles/will-the-driverless-car-upend-insurance-1425428891.

8 Office of Senator Edward Markey, “Markey, Blumenthal To Introduce Legislation to Protect Drivers from Auto 

Security and Privacy Vulnerabilities with Standards and ‘Cyber Dashboard,’” February 11, 2015, www.markey

.senate.gov/news/press-releases/markey-blumenthal-to-introduce-legislation-to-protect-drivers-from-autosecurity-and-privacy-vulnerabilities-with-standards-and-cyber-dashboard.

9 Clifford Atiyeh, “Interview: Google’s Self Driving Car Director on Its Autonomous Car, the Future of Mobility and 

Drifting Priuses,” Car and Driver, January 20, 2015, http://blog.caranddriver.com/interview-googles-self-drivingcar-director-on-its-autonomous-car-the-future-of-mobility-and-drifting-priuses/.

10 Joseph B. White, “Nissan Expects to Market Self-Driving Cars by 2020,” Wall Street Journal, August 27, 2013, 

www.wsj.com/articles/SB10001424127887323407104579038832031956964.

11 Paul Stenquist, “In Self-Driving Cars, a Potential Lifeline for the Disabled,” New York Times, November 7, 2014, 

www.nytimes.com/2014/11/09/automobiles/in-self-driving-cars-a-potential-lifeline-for-the-disabled.html?_r=0.

12 The DARPA Grand Challenge was created by the U.S. Department of Defense to accelerate the development 

of AVs that the military could use to transport cargo into combat zones without endangering the lives of human 

drivers.

13 Steven Shladover, “Dreaming with Deadlines,” Thinkinghighways.com, Vol. 7, No. 3, November 2012, http://

content.yudu.com/Library/A2t7h1/ThinkingHighwaysNort/resources/22.htm.

Endnotes

Self-Driving Cars: Mapping Access to a Technology Revolution 47
14 Lee Gomes, “Urban Jungle a Tough Challenge for Google’s Autonomous Cars,” MIT Technology Review, July 24, 

2014, www.technologyreview.com/news/529466/urban-jungle-a-tough-challenge-for-googles-autonomous-cars/. 

15 Ibid.

16 Steve Fowler, “Renault and Nissan Confirm Autonomous Cars by 2020,” Autoexpress, March 4, 2015, accessed 

April 15, 2015, www.autoexpress.co.uk/renault/90707/renault-and-nissan-confirm-autonomous-cars-by-2020.

17 National Highway Traffic Safety Administration (NHTSA), “Preliminary Statement of Policy Concerning Automated

 Vehicles,” May 30, 2013, accessed March 3, 2015, www.nhtsa.gov/staticfiles/rulemaking/pdf/Automated_

Vehicles_Policy.pdf.

18 Jerry Hirsch, “GM will Introduce Hands-free, Foot-free Driving in 2017 Cadillac,” Los Angeles Times, September 7, 

2014, www.latimes.com/business/autos/la-fi-hy-gm-cadillac-super-cruise-20140907-story.html.

19 Paul Stenquist, op. cit.

20 Steven Shladover, op. cit.

21 Advanced Transit Association, Applications: Heathrow Pods, accessed February 15, 2015, www.advancedtransit

.org/advanced-transit/applications/heathrow/.

22 Joel Rei, “Up Next: Driverless Cars,” Business Standard, March 7, 2015, www.business-standard.com/article/

specials/up-next-driverless-cars-115030400847_1.html.

23 The Road Ahead: Advanced Vehicle Technology and Its Implications Wednesday, May 15, 2013, U.S. Senate, 

Committee On Commerce, Science, and Transportation, www.gpo.gov/fdsys/pkg/CHRG-113shrg82768/html/

CHRG-113shrg82768.htm.

24 “Hearing on How Autonomous Vehicles Will Shape the Future Of Surface Transportation,” Subcommittee on 

Highways and Transit of the House Committee on Transportation and Infrastructure, November 19, 2013, accessed March 7, 2015, www.gpo.gov/fdsys/pkg/CHRG-113hhrg85609/pdf/CHRG-113hhrg85609.pdf.

25 Office of Senator Edward Markey, op. cit. 

26 NHTSA, “Preliminary Statement of Policy Concerning Automated Vehicles,” op. cit. 

27 “Automated Driving: Legislative and Regulatory Action,” accessed March 3, 2015, http://cyberlaw.stanford.edu/

wiki/index.php/Automated_Driving:_Legislative_and_Regulatory_Action.

28 Interview, Bernard Soriano, Deputy Director, California Department of Motor Vehicles, September 29, 2014.

29 Bryant Walker Smith, “Automated Vehicles Are Probably Legal in the United States,” April 15, 2013, accessed 

March 3, 2015, http://cyberlaw.stanford.edu/blog/2013/04/automated-vehicles-are-probably-legal-united-states.

30 RAND Corporation, “Autonomous Vehicle Technology: A Guide for Policymakers,” January 10, 2014, accessed 

March 3, 2015, www.rand.org/content/dam/rand/pubs/research_reports/RR400/RR443-1/RAND_RR443-1.pdf.

31 Thomas J. Bamonte, “Autonomous Vehicles: Drivers of Change,” RoadsandBridges.com, Summer 2013, www

.roadsbridges.com/sites/default/files/05_autonomous%20vehicles.pdf.

32 Florida Department of Transportation, Florida Automated Vehicles Program, accessed March 3, 2015, www

.automatedfl.com.

33 “The promise of autonomous vehicles is becoming a talking point for opponents of mass transit systems,” 

Fortune, November 12, 2014, accessed March 4, 2015, http://fortune.com/2014/11/02/trains-autonomousvehicles-politics/. 

34 Streetsblog SF, “Fantasizing About Self-Driving Cars, Sunnyvale Opposes El Camino Bus Lanes,” March 10, 

2015, accessed March 12, 2015, http://sf.streetsblog.org/2015/03/10/fantasizing-about-self-driving-carssunnyvale-opposes-el-camino-bus-lanes/.

35 Philip E. Ross, “Self-Driving Cars Face Serious Roadblocks, Experts Say,” IEEE Spectrum, September 10, 2014, 

http://spectrum.ieee.org/cars-that-think/transportation/self-driving/future-of-self-driving-cars-detroit-panel. 

36 Damon Rose, “Blind Drivers at the Steering Wheel,” bbc.com, April 14, 2013, www.bbc.com/news/

magazine-21720318.

37 Mark A. Riccobono, Interview with Marilyn Golden, October 17, 2014.

38 WebAIM, “Implementing Web Accessibility,” WebAim.org, http://webaim.org/intro/.

39 RAND Corporation, “Autonomous Vehicle Technology: A Guide for Policymakers,” January 10, 2014, op. cit. 

48 National Council on Disability
40 Steven Shladover, op. cit.

41 Philip E. Ross, “Self-Driving Cars Face Serious Roadblocks, Experts Say,” IEEE Spectrum, September 10, 2014, 

http://spectrum.ieee.org/cars-that-think/transportation/self-driving/future-of-self-driving-cars-detroit-panel.

42 Congressman Thomas Petri, Opening Remarks, “Hearing on How Autonomous Vehicles Will Shape the Future 

Of Surface Transportation,” Subcommittee on Highways and Transit of the Committee on Transportation and 

Infrastructure, November 19, 2013, accessed March 7, 2015, www.gpo.gov/fdsys/pkg/CHRG-113hhrg85609/pdf/

CHRG-113hhrg85609.pdf.

43 Google X, Media Release, Wednesday, January 14, 2015, Google Self-Driving Car Project Update at Automotive News World Congress: “We have always had fully autonomous operation as our end goal for the Google self-driving car project because we believe this could significantly improve road safety and help people 

who are blind, disabled or otherwise can’t drive,” accessed March 7, 2015, www.autonews.com/assets/PDF/

CA97975114.PDF.

44 Paul Stenquist, op. cit.

45 Jane Bierstedt, et al. “Effects of Next-Generation Vehicles on Travel Demand and Highway Capacity,” Princeton 

University. January 2014. Accessed February 25, 2015, http://orfe.princeton.edu/~alaink/Papers/FP_

NextGenVehicleWhitePaper012414.pdf.

46 Mark Harris, “Will You Need a New License to Operate a Self-Driving Car?,” IEEE Spectrum, March 2, 2015, 

accessed March 3, 2015, http://spectrum.ieee.org/cars-that-think/transportation/human-factors/will-you-need-anew-license-to-operate-a-selfdriving-car. 

47 NHTSA, “Preliminary Statement of Policy Concerning Automated Vehicles,” op. cit.

48 Daniel J. Fagnant and Kara Kockelman, “Repairing a Nation For Autonomous Vehicles: Opportunities, Barriers 

And Policy Recommendations For Capitalizing On Self-Driven Vehicles,” submitted for presentation at the 93rd 

Annual Meeting of the Transportation Research Board, Washington D.C., January 2014, and publication in Transportation Research Part A (July 2013), accessed March 3, 2015, www.caee.utexas.edu/prof/kockelman/

public_html/TRB14EnoAVs.pdf.

49 Verne Kopytoff, “Will We Need a Learner’s Permit for Self-driving Cars?,” Fortune.com, October 30, 2014, accessed February 25, 2015, http://fortune.com/2014/10/30/learners-permit-for-self-driving-cars/.

50 Julia Goodrich, “Driving Miss Daisy: An Autonomous Chauffeur System,” Houston Law Review, Fall 2013, 51 

Hous. L. Rev. 265.

51 Bernard Soriano, Deputy Director, California Department of Motor Vehicles, Interview with Susan Henderson, 

May 27, 2015.

52 Cathie Curtis, Director, Vehicle Programs, American Association of Motor Vehicle Administrators, “Presentation 

at the Autonomous Vehicle Best Practices Working Group Project Kick-Off Meeting,” February 24, 2015. 

www.aamva.org/DownloadAsset.aspx?id=6297. 

53 Casey Garber, Manager, Vehicle Programs, American Association of Motor Vehicle Administrators, 

“Vehicle Technology Development Coming at Light Speed: An Update from the Autonomous Vehicle Best Practices Working Group,” Presentation at the AAMVA 2015 Region IV Conference, June 3, 2015. 

www.aamva.org/2015-Region-IV-Conference-Presentations/

54 Self-driving cars: The next revolution, KPMG and the Center for Automotive Research, Gary Silberg and Richard 

Wallace, p. 12, accessed March 4, 2015, www.kpmg.com/US/en/IssuesAndInsights/ArticlesPublications/

Documents/self-driving-cars-next-revolution.pdf.

55 Doug Newcomb, “You Won’t Need a Driver’s License by 2040,” Wired.com, September 17, 2012, accessed 

February 28, 2015, www.wired.com/2012/09/ieee-autonomous-2040/.

56 KPMG, op. cit., p. 3.

57 RAND Corporation, “Autonomous Vehicle Technology: A Guide for Policymakers,” January 10, 2014, p. 14, op. cit.

58 Mark A. Riccobono, Interview with Marilyn Golden, October 17, 2014.

59 RAND Corporation, “Autonomous Vehicle Technology: A Guide for Policymakers,” January 10, 2014, p. 14, op. cit.

60 Ibid, p. 142.

Self-Driving Cars: Mapping Access to a Technology Revolution 49
61 Bryant Walker Smith, “Bryant Walker Smith of Univ. of South Carolina Discusses Driverless Cars,” cctv.com, 

November 22, 2014, accessed on November 22, 2014, www.youtube.com/watch?v=8wyDUm338Y0.

62 Ibid.

63 Doug Newcomb, “Privacy Group Voices Concerns Over Google-Backed Autonomous Vehicle Legislation,” 

Wired.com, June 1, 2012, accessed March 3, 2015, www.wired.com/2012/06/watchdog-autonomous-privacy/.

64 Tim Wright, “FTC Chairs warns of threats from the Internet of Things (IoT),” JDSupra Business Advisor, March 12, 

2015, accessed March 13, 2015, www.jdsupra.com/legalnews/ftc-chairs-warns-of-threats-from-the-int-55844/.

65 Justin Pritchard, Associated Press, “How to Teach Self-driving Cars Ethics of the Road,” Record Searchlight, 

December 14, 2014, accessed March 9, 2015, www.redding.com/lifestyle/how-to-teach-self-driving-cars-ethicsof-the-road.

66 Ibid.

67 Senate Committee on Commerce, Science, and Transportation, Hearing on The Road Ahead: Advanced Vehicle 

Technology and Its Implications, May 15, 2013, accessed February 14, 2015, www.gpo.gov/fdsys/pkg/CHRG113shrg82768/html/CHRG-113shrg82768.htm.

68 Center for Automotive Embedded Systems Security, “Experimental Security Analysis of a Modern Automobile,” 

May 2010, accessed February 2, 2015, http://www.autosec.org/pubs/cars-oakland2010.pdf.

69 Jim Finkle, “Insight: Experts Hope to Shield Cars From Computer Viruses,” Reuters.com, August 20, 2012, accessed December 14, 2014, www.reuters.com/article/2012/08/20/us-autos-hackers-idUSBRE87J03X20120820.

70 Testimony of The Honorable David L. Strickland, Administrator, NHTSA, Senate Committee on Commerce, 

Science, and Transportation, Hearing on The Road Ahead: Advanced Vehicle Technology and Its Implications, 

May 15, 2013, accessed December 10, 2015, www.commerce.senate.gov/public/?a=Files.Serve&File_

id=566d5c52-be38-4245-ab44-1ccbf2f198db. 

71 Stephen Kelly, “Connected Vehicle Cybersecurity: Opportunity and Responsibility,” TheHill.com, August 4, 2014, 

accessed October 23, 2015, http://thehill.com/blogs/congress-blog/technology/213951-connected-vehiclecybersecurity-opportunity-and-responsibility.

72 Staff of Senator Edward J. Markey, “Hacking & Tracking: Security and Privacy Gaps Put American Drivers at 

Risk,” February 2015, accessed January 23, www.markey.senate.gov/imo/media/doc/2015-02-06_

MarkeyReport-Tracking_Hacking_CarSecurity%202.pdf.

73 Congressman Thomas Petri, Opening Remarks, “Hearing on How Autonomous Vehicles Will Shape the Future 

Of Surface Transportation,” Subcommittee on Highways and Transit of the Committee on Transportation and 

Infrastructure, November 19, 2013, accessed March 7, 2015, www.gpo.gov/fdsys/pkg/CHRG-113hhrg85609/pdf/

CHRG-113hhrg85609.pdf.

74 Mike Robinson, “Hearing on How Autonomous Vehicles Will Shape the Future Of Surface Transportation,” Subcommittee on Highways and Transit of the Committee on Transportation and Infrastructure, November 19, 2013, 

accessed March 7, 2015, www.gpo.gov/fdsys/pkg/CHRG-113hhrg85609/pdf/CHRG-113hhrg85609.pdf.

75 Terry Bennett, “Google’s Plan For Autonomous Cars Doesn’t Go Far Enough,” wired.com, September 30, 2013, 

www.wired.com/2013/09/we-need-to-think-about-the-infrastructure-for-autonomous-cars-too/.

76 Janice King, “How Transportation Technologies Will Change Everything,” Solutions for State and Local Government 

Technology, November 4, 2014, www.govtech.com/transportation/How-Transportation-Technologies-Will-ChangeEverything-.html.

77 American Association of State Highway and Transportation Officials, “National Connected Vehicle Field 

Infrastructure Footprint Analysis,” US Department of Transportation, June 27, 2014, http://ntl.bts.gov/

lib/52000/52600/52602/FHWA-JPO-14-125_v2.pdf.

78 Glenn Garvin, “Automakers to Sell Self-Driving Cars by the End of the Decade,” Miami Herald, March 17, 

2014, www.govtech.com/fs/news/Automakers-to-Sell-Self-Driving-Cars-by-the-End-of-the-Decade.html?__

rmid=523263753.html.

79 Kirk Steudle, Testimony, “Hearing on How Autonomous Vehicles Will Shape the Future Of Surface Transportation,” Subcommittee on Highways and Transit of the Committee on Transportation and Infrastructure, November 

19, 2013, accessed March 7, 2015, www.gpo.gov/fdsys/pkg/CHRG-113hhrg85609/pdf/CHRG-113hhrg85609.pdf.

50 National Council on Disability