1/ USDOT has released its voluntary AV 3.0 framework. The doc. starts with six “automation principles.” #6 promotes the notion that driving is freedom. Additionally, #6 comes close to defining the *act of driving* as a de facto right. 
2/ Equating the *act of driving* with freedom is problematic in multiple ways. First, the rhetoric and the reality around driving diverge enormously. OEMs sell a sanitized version of Jack Kerouac when the daily grind is congestion and pollution.
3/ Second, more than 37,000 people died in 2016 from roadway accidents involving motor vehicles. And dying is the ultimate loss of freedom to say nothing of the people who suffer non-fatal but serious injuries.
4/ Third, equating the *act of driving* with freedom conflates the means with the end. The ability to move freely is essential to any meaningful conception of liberty. Importantly, this definition of freedom is mode (and means)-neutral.
5/ In short, movement is central to freedom, not driving. Yet, principle 6 states: “U.S. DOT embraces the freedom of the open road, which includes the freedom for Americans to drive their own vehicles.”
6/ Once autonomous driving systems become a fully mature technology (clearly many years away), embracing the *act of driving* is embracing unnecessary death and serious injury. How do we know this?
7/ According to NHTSA, in 2016, there were 10,497 alcohol-impaired-driving fatalities and 4,253 fatalities from distracted & drowsy driving, and 10,111 from speeding. USDOT says 94% of fatalities are the result of human error/law-breaking.
8/ #6 also states “We will protect the ability of consumers to make the mobility choices that best suit their needs.” If we eliminate the first part of #6, this comes closer to being the correct approach.
9/ Ideally, each person should have the ability to choose walking, cycling, public transit, ridesharing & ridehailing with AVs, depending on their particular needs w/r/t price, speed, privacy, storage capacity, and other travel characteristics or amenities.
10/ Finally, #6 states: “We will support automation technologies that enhance individual freedom by expanding access to safe and independent mobility to people with disabilities and older Americans.”
11/ The importance of improving mobility for people with disabilities and seniors cannot be overstated. However, this language seems overly passive—as though it is a foregone conclusion that AVs will naturally serve these communities.
12/ In the absence of regulatory mandates, will AV fleet operators purchase any/enough ADA-compliant vehicles? Will they hire the support staff necessary to facilitate booking/boarding/alighting?
13/ What will be the cost of these special trips? Will seniors on fixed incomes or people with disabilities have the funds to cover their mobility needs if fleet operators have higher charges for these services?
14/ In other words, technology innovation is only one part of ensuring all people have true mobility freedom. True level-5 AVs appear to still be many years away. And even after they arrive, there will be tens of millions of analog vehicles still on the road.
15/ With that said, it seems important to recognize that truly embracing the life-saving value of AVs will one day mean letting go of the act of driving. And ensuring their presence delivers on our goals for inclusion and equity will likely mean mandates and subsidies.
