Written Testimony
of
Briana James, Sierra Club DC Chapter
For the Hearing on the "Autonomous Vehicle Deployment Authorization Amendment Act of 2026" (B26-0684)
Before the Council of the District of Columbia’s
Committee on Transportation and the Environment
27 July 2026
Chair Allen and members of the Committee, my name is Briana James. I am a resident of Ward 6 and a member of the Sierra Club DC Chapter Sustainable Transportation Committee. The Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. In DC, we represent about 7,000 members and supporters across all eight wards.
The Sierra Club DC Chapter recognizes the potential benefits of autonomous vehicles (AVs), including greater accessibility for riders with disabilities, safety improvements over human driven rideshares, and increased vehicle electrification. AVs have the potential to be part of a safe, clean, and equitable transportation system, existing alongside transit and active transportation. However, we have concerns regarding AVs and the Autonomous Vehicle Deployment Authorization Amendment Act of 2026, particularly vehicle miles traveled and traffic congestion, its impact on public transit, electrification infrastructure costs, and the handling of data privacy. We believe these concerns are not sufficiently addressed in the bill as introduced.
Traffic Congestion and Vehicle Miles Traveled (VMT)
The bill does not include a framework for managing the traffic congestion that expanded AV deployment would bring. AVs are still cars, and will increase VMT through "deadheading" (driving without a passenger on board) and by drawing riders away from transit. The bill requires permittees to plan to minimize deadheading, but "minimize" is not defined or quantified, so there is no way to measure compliance or hold permittees accountable. The bill's $0.15 per-mile tax on commercial AV operations directs revenue to public transit and supports rideshare drivers through education, vocational training, and workforce development. Although the bill’s cover letter describes this funding as supporting both taxi and rideshare drivers, the bill’s actual language only refers to rideshare drivers, leaving taxi drivers unaddressed by the funding itself. Furthermore, it is unclear how the bill would also offset the environmental effects of increased VMT and congestion. Even an all-electric AV fleet would not eliminate this harm. The fleet still draws on the District's electricity grid, which is not fully powered by renewable energy, and the added AV traffic would contribute to congestion alongside fossil fuel-burning vehicles, buses, and delivery traffic sharing the road, worsening the environmental harm that congestion causes. The bill's curbside management provisions are also underdeveloped, despite the new demands AVs will place on limited curb space for pickups, drop-offs, and parking.
To address these problems, the Sierra Club DC Chapter recommends a comprehensive demand management study covering curbside strategies and congestion pricing, which DDOT’s April AV policy report named a "key strategy" to manage VMT growth from AVs. The study's findings should inform the bill's VMT tax amount and structure, such as introducing higher fees for deadheading. Finally, the tax rate should be periodically reviewed and potentially increased to reflect changing traffic conditions and the bill’s required VMT data.
Public Transit Support
The bill’s primary transit-support measure asks AV operators only to “explore the feasibility” of a program offering discounts or credits to all customers for AV rides that connect to transit. This is a soft commitment with no guarantee that it will ever be implemented, and it is not paired with a clear plan for reinvesting AV-generated revenue directly into transit service. Looking at WMATA’s evaluation of its 2019 after hours pilot for $3 Lyft subsidies might help inform the mechanics of a discount program.
Rising Demand for EV Infrastructure
Expanding AV deployment accelerates demand for the electric vehicle charging infrastructure the District needs to meet its climate goals. A growing commercial AV fleet builds the case for continued investment in DC's charging network. However, adding this new AV-driven load onto an already underfunded system raises the concern of whether the existing infrastructure will be ready to support it. A growing AV fleet will add pressure to a charging network that is already seeing high utilization, raising questions about whether capacity will keep pace. The bill does not address who would bear the cost of expanding charging capacity to meet this new commercial need.
Data Sharing and Privacy
The bill requires permittees to report vehicle miles traveled, trip counts, and safety data to DDOT on a quarterly basis, and requires DDOT to publish these reports publicly. However, there is an opportunity for the District to use AV data for additional transportation planning purposes, such as identifying high-use corridors for new transit or bike infrastructure, or conducting congestion studies.
In addition, as written, the bill does not address the privacy implications of the extensive cameras and sensors that autonomous vehicles carry. Companies can use safety or legal justifications as a pretext for broad, open-ended collection of identifiable data. Riders and other DC residents may not fully understand, or simply forget, that they are being continuously monitored. We believe this is a significant gap in the bill as introduced.
We look forward to working with the Committee to ensure that any AV deployment framework addresses these concerns and advances, rather than undermines, the District’s climate, transit, and privacy goals. Thank you for the opportunity to submit this testimony.