Bicycles, Disabled Persons, the Question of Independent Verification and Portland, OR

Introduction: Waymo, the world’s first declared autonomous ride hailing service, is actively planning its Portland, Oregon rollout and has been mapping streets with human driven vehicles since April 2026.[1]This report is not an indictment of Waymo’s technology. It is a finding about accountability, and accountability requires the specific, independently verified safety conditions set forth herein.

Issue:

How safe are Portland’s cyclists and disabled citizens in the presence of Waymo vehicles?

Conclusion:

The data on Waymo’s safety record, particularly regarding vulnerable road users such as cyclists and wheelchair users, cannot yet be evaluated independently with confidence. Waymo’s involvement in nearly every study and report on its own safety record creates serious accountability concerns. Waymo’s published research reports substantially fewer injury crashes than human benchmarks, including for cyclists, and those findings may prove accurate.[2]The question this memorandum addresses is not the direction of that data but who is positioned to verify it.

I. From “Self-Driving” to “Autonomous”: A Change in Terminology

Origin: Waymo began as the Google Self-Driving Car Project in 2009. When it spun out of Google as a separate Alphabet subsidiary in December 2016, it was still described as a “self-driving car company.”

The shift, January 2021:Waymo announced that it would no longer use the term “self-driving.” Its blog explained that its vehicles “don’t drive themselves,” and that because Waymo is automating the task of driving, autonomous is the more accurate term.[3]

Why the Word “Autonomous” Matters

The word derives from ancient Greek: auto, meaning “self,” and nomos, meaning “law,” so that it literally describes one who gives oneself one’s own law. In moral and political philosophy, autonomy is the basis for determining moral responsibilityfor one’s actions.[4] The word therefore carries connotations of independent judgment and self governance, and it invites the question of who is responsible when such a vehicle fails. Waymo’s own explanation is more modest, since it says its vehicles automate the task of driving rather than drive themselves. Both points lead to the same question: who verifies the safety claims made for the technology?

The Pattern

Waymo called its technology “self-driving” for roughly twelve years before changing the term in 2021.[5]The change was also widely read as an effort to distance Waymo from Tesla’s “Full Self-Driving” terminology.[6]

II. The Closed Loop: The Core Finding

What the research reveals is not an isolated conflict of interest but a systemic gap in independent oversight. Waymo generates its own safety data. Researchers affiliated with Waymo publish it as peer reviewed science. Waymo and its current and former personnel have taken part in Transportation Research Board forums convened to discuss research needs for automated vehicle deployment, and the federal agency responsible for oversight has revised its reporting requirements in a way that safety advocates describe as a dilution. The public has no fully independent source of verification.

• Waymo generates the safety data[7]

• Researchers affiliated with Waymo publish it as peer reviewed science[8]

• Swiss Re, a global reinsurance company more than 160 years old, formally partnered with Waymo in 2022 on research that Waymo then promoted as independent validation of its safety record[9]

• Transportation Research Board (TRB) forums on automated vehicles included individuals associated with Waymo, and Waymo joined one such forum as a sponsoring organization[10]

• NHTSA revised its crash reporting requirements in April 2025 to allow manufacturer data to be treated as confidential, a change that Advocates for Highway and Auto Safety characterized as a dilution of reporting requirements[11]

The most independent voice found in this research is Advocates for Highway and Auto Safety, independent in the sense that it is not affiliated with Waymo. It is an alliance of consumer, medical, public health, law enforcement, and safety groups together with insurance companies and agents, and it was founded in 1989 by executives of major property and casualty insurance companies and several prominent consumer and safety leaders.[12]

Its voice is largely drowned out by the volume and institutional credibility of the industry connected sources surrounding it.

As recently as February 2026, Advocates sent a letter to the Senate Commerce Committee urging Senators to advance proven safety solutions and establish safeguards ahead of a hearing titled “Hit the Road, Mac: The Future of Self-Driving Cars.” The hearing was chaired by Senator Ted Cruz, who framed the issue almost entirely around competitiveness with China. Waymo and Tesla executives were the primary witnesses. Cyclist safety and wheelchair user detection were not mentioned once during two and a half hours of testimony.[13]

Sources Independent of Waymo

• NHTSA: raw mandatory incident data only (nhtsa.gov)

• California DMV: raw incident by incident data only (dmv.ca.gov)

• DREDF, the Disability Rights Education and Defense Fund, October 2025 (dredf.org)[14]

• Advocates for Highway and Auto Safety: independent of Waymo, funded by insurance and consumer interests (saferoads.org)

• NHTSA Report to Congress, July 2025: with the caveat that the agency’s reporting framework was revised in April 2025, as discussed below[15]

III. The Evidence: Source by Source

A. The Swiss Re Study: Not Independent of Waymo

Swiss Re is one of the three largest reinsurers in the world. A reinsurer’s business depends on accurate risk assessment, which is why an endorsement from Swiss Re carries more weight than one from a think tank or a technology journalist.

The problem: Swiss Re and Waymo formally partnered in 2022 to develop autonomous vehicle risk assessment methodologies together. Waymo announced the first resulting study on its blog in September 2023, under a headline stating that its vehicles are significantly safer than human driven ones according to research led by Swiss Re.[16]Waymo supplied the core data, and Waymo employees were among the co authors. A peer reviewed version appeared in Heliyon in 2024,[17]and Waymo announced a further Swiss Re study in December 2024.[18]

Waymo employees among the authors of the first study:

• Tilia Gode, Waymo’s Head of Risk and Insurance

• Trent Victor, Director of Safety Research and Best Practices at Waymo

• Ruoshu Chen, a senior actuary at Waymo

The announcement was widely circulated online, including by AutoTech Insight and EE Times, and it was cited by the U.S. Senate Committee on Commerce, Science, and Transportation in its February 4, 2026 report, “Hit the Road, Mac: The Future of Self-Driving Cars,” which states: “Reinsurer Swiss Re published an analysis of 3.8 million autonomous miles driven by passenger AVs operated by Waymo. The analysis found that when compared to baseline human drivers, Waymo AVs reduced property damage claims by 76 percent. These results led Swiss Re to conclude that Waymo’s AVs are ‘significantly safer towards other road users than human drivers are[.]’”[19]

Swiss Re’s reputation lends the study weight, but the study was produced in partnership with Waymo, using Waymo’s data and with Waymo authors, and it should be read on those terms. It is not an independent verification.

B. The Transportation Research Board: Industry Participation

The Transportation Research Board (TRB) is a division of the U.S. National Academies of Sciences, Engineering, and Medicine, and its work is relied on by transportation agencies and policymakers.

Who Are They? Who Funds Them? Who Oversees Them?

• Who are they? From 2018 to 2023, TRB convened a Forum on Preparing for Automated Vehicles and Shared Mobility Services, composed of experts from industry and from the public sector as well as academia.[20]

• Who funds them? The Forum’s own meeting record states that Waymo joined as a sponsoring organization.[21]

• Who oversees them? Nominally the National Academies. A 2025 commentary by three transportation researchers concluded that TRB’s recent actions, including cancelled research contracts and a restructuring, suggest that it is no longer able to act with scientific integrity.[22]

Waymo Affiliated Individuals in TRB Activities

• Mauricio Peña, Chief Safety Officer at Waymo

• Trent Victor, Director of Safety Research and Best Practices at Waymo, keynote speaker at TRB’s Automated Road Transportation Symposium (ARTS)

• Scott Schnelle, Safety Best Practices Specialist at Waymo, presenter at TRB sessions

• Timothy Papandreou, a member of the TRB Forum from 2018 to 2023, whose published biography describes him as a former strategic partnerships manager at Google X and Waymo.[23]

The Transparency Problem

The Forum’s member page lists names only, with no affiliations or employer disclosures and no conflict of interest statements. To learn that Timothy Papandreou worked for Waymo, a researcher must search his name and connect the affiliation independently. Disclosure requirements are policy choices, and someone decided not to require affiliation disclosure on that page.

C. NHTSA: Reporting Requirements and Oversight

NHTSA is the federal government’s primary authority on vehicle safety. Under its 2021 Standing General Order, it requires autonomous vehicle companies to report incidents involving physical contact, property damage, injury, or fatality.[24]

The problem: In April 2025, Transportation Secretary Sean Duffy announced a new NHTSA Autonomous Vehicle Framework that revised reporting requirements to allow data submitted by automakers to be deemed confidential.[25]Advocates for Highway and Auto Safety responded that the change diluted rather than strengthened reporting requirements.[26]

The School Bus Investigation

NHTSA opened a preliminary evaluation of Waymo’s autonomous driving system in late 2025 after at least 20 documented incidents in Austin, Texas in which Waymo vehicles illegally passed stopped school buses with children present, including after Waymo deployed a software update intended to address the problem.[27]NHTSA’s evaluation of Waymo and Waymo’s participation in the institutions that study automated vehicle policy are not directly connected, but together they show how closely the industry and those institutions are interwoven. That is the structural entanglement that independent verification is meant to address.

The Department’s Stated Priorities

The Department of Transportation oversees NHTSA. According to the Department’s own biography, Secretary Duffy served as a district attorney and a member of Congress, and later hosted a business television program.[28]The Department announced its April 2025 automated vehicle framework as part of an innovation agenda.[29]

D. NHTSA FY2024 to FY2025 Research Plan: What Was Proposed and What Happened

What was proposed (with an approximate budget of $20 to $30 million): In 2023, the 110 page plan was designed to commit to protecting vulnerable road users, including pedestrians, bicyclists, people who use wheelchairs and other mobility devices, and those in underserved, disadvantaged, rural, and communities of color as part of the National Roadway Safety Strategy.[30]

What happened: NHTSA’s July 2025 Report to Congress describes continuing research into disability-related information needs, wheelchair securement, and automated vehicle safety assessment. It does not, however, establish whether Waymo’s system has been independently tested for detecting wheelchair users in Portland-relevant street and crosswalk conditions.[31]

IV. Waymo and Bicycle Safety

A. What the Data Shows

A documented concern involves dooring incidents, in which a passenger opens a door into a cyclist’s path. In one published analysis of the 45 most serious Waymo crashes reported to NHTSA between mid February and mid August 2025, three were dooring incidents, and they accounted for two of the seven crashes that caused significant injuries.[32]

That analysis concluded that the dooring crashes were not failures of Waymo’s driving software, which makes them a question of how Waymo designs and delivers safe exit warnings to passengers.[33] A San Francisco cyclist sued Waymo in 2025 over a February dooring incident, alleging that the Safe Exit alert did not sound, and Waymo denied the claim.[34]

For context, Waymo estimates that through June 2025 crashes injuring cyclists occurred 78 percent less often than for typical human drivers in the same locations. That estimate is Waymo’s own, and the question addressed here is whether it can be verified.[35]

In a March 15, 2026 interview with The New York Times, Waymo co chief executive Tekedra Mawakana said that the company faces pressure to explain incidents before the facts are known, that it must be disciplined, and that it will speak after it has taken the time it needs.[36]

B. Credible Sources on Cyclist Safety

1. NHTSA Crash Data.NHTSA crash datasets suggest that most collisions involving autonomous vehicles in Austin, Texas in 2025 were likely not the fault of the autonomous vehicle, including one incident in which a cyclist collided with a stopped Waymo. Raw data are available at nhtsa.gov.

2. NHTSA Traffic Safety Facts 2023: Bicyclists and Other Cyclists (published July 2025). In 2023, there were 1,166 pedalcyclist fatalities nationally, accounting for 2.9 percent of all traffic fatalities, and an estimated 49,989 pedalcyclists were injured, an 8 percent increase from 2022.[37]

3. NHTSA Report to Congress on Autonomous Driving Systems (July 2025). NHTSA has called for swift compliance with automatic emergency braking standards improved to detect bicycle and motorcycle riders, which indicates that cyclist detection remains an unresolved challenge.[38]

4. California DMV Raw Incident Data. The California DMV collects and publishes autonomous vehicle collision reports for vehicles operating in California. It provides raw incident by incident data, useful for verifying specific incidents but not for analytical conclusions.[39]

A notable specific incident:On February 6, 2024, a Waymo driverless taxi collided with a cyclist at a four way intersection in San Francisco’s Potrero Hill neighborhood. The cyclist was traveling behind a truck, and the Waymo vehicle was blocked from identifying the cyclist and struck them. Injuries were not life threatening. The California DMV and the San Francisco Police Department both launched investigations.[40]

New California AV regulations: Approved April 28, 2026, these regulations comprehensively update AV rules and strengthen oversight and enforcement.[41]

V. Waymo and Wheelchair Users in Crosswalks

The Core Detection Problem

Research has revealed serious failures in pedestrian detection algorithms when wheelchair users move in non standard ways. In one documented test, a researcher presented visual captures of a friend who propels herself backward in her wheelchair using her feet and legs. The system not only failed to recognize her as a person but indicated that the vehicle should proceed through the intersection, effectively directing the vehicle to collide with her.[42]

Because Waymo’s own detection system is proprietary, the question for Portland is whether anyone independent of Waymo has tested it against scenarios of this kind.

This is not a minor edge case. Anecdotal evidence suggests broader issues with algorithms’ ability to detect disabled people in or around roadways, particularly if those individuals do not move as the algorithm was trained to expect.

The Built Environment Compounds the Risk

Wheelchair users are often forced to travel in the road when a sidewalk has no curb cuts or is damaged, or during snowstorms or heavy autumn leaf fall when street clearing is prioritized over sidewalks. These are scenarios that autonomous vehicle systems may not be reliably trained to anticipate.

Federal Acknowledgment of the Gap

NHTSA’s Report to Congress on Accessibility of Automated Vehicles acknowledged the need for crash testing with dummies that accurately represent people with disabilities, which indicates that current safety testing protocols do not adequately account for wheelchair users.[43]

Waymo’s Institutional Response and Its Limits

In 2022, Waymo launched the Waymo Accessibility Network, a coalition of twenty disability advocacy organizations including the American Association of People with Disabilities, the National Federation of the Blind, the National Association of the Deaf, United Spinal Association, and United Cerebral Palsy, along with several San Francisco organizations: the Independent Living Resource Center SF (ILRCSF), LightHouse for the Blind and Visually Impaired SF, and The Arc of San Francisco.[44]

San Francisco is where this engagement has been most substantive. LightHouse for the Blind SF participated in early stage product development and testing, enabling blind and low vision community members to provide direct feedback on rider experience design. The ILRCSF has written publicly that Waymo’s autonomous service “continues to evolve” with ongoing disability community consultation. The same San Francisco organizations have also been candid about what remains unresolved. LightHouse CEO Sharon Giovinazzo acknowledged publicly that Waymo still needs more wheelchair accessible vehicles in its fleet.[45]

That candor points directly to the gap. According to Waymo’s Help Center, its wheelchair accessible vehicle (WAV) service does not use autonomous vehicles: WAVs are manually driven. In San Francisco and Los Angeles, riders may request a WAV through the Waymo app; in Phoenix, riders must contact Waymo Support; and in Las Vegas, Waymo directs riders to local wheelchair-accessible transportation providers.[46]This is a separate, lower tier system operating alongside, not integrated with, the autonomous fleet. 

When Waymo announced its Atlanta expansion in September 2024, wheelchair users discovered that the autonomous vehicles would not be accessible. Waymo’s support team had said that the company “always ensures wheelchair-accessible vehicles are available” in every new city, but that assurance referred to the human driven WAV tier and not to the autonomous service itself.[47]

This pattern fits the broader accountability concern identified throughout this report. The Waymo Accessibility Network, like the Swiss Re partnership and the TRB involvement, should not be mistaken for independent validation. Participation by twenty disability organizations in a network that Waymo convened is not the same as those organizations independently verifying that wheelchair users are equitably served by Waymo’s autonomous fleet.

Additional Sources on This Issue

• DREDF, Disability Rights Education and Defense Fund (https://dredf.org/)

• OPB, Oregon Public Broadcasting, April 28, 2026 report on Waymo’s Portland rollout and local disability advocate concerns (https://www.opb.org/article/2026/04/28/waymo-portland-rollout-driverless-taxi-mapping-streets/)

• University of Michigan Transportation Research Institute (UMTRI), Technical Report on Independent Safety for Wheelchair Users in Automated Vehicles, April 2023 (abstract available at https://deepblue.lib.umich.edu/items/df17d376-25b7-47ef-ac72-aea34fb46ce0)

VI. Portland Specifically

Current Status, October 2026

Waymo began mapping Portland streets in April 2026 with vehicles operated by licensed human drivers, and a Waymo spokesperson said the company will not operate in Portland until it receives a permit.[48] As of September 21, 2026, Waymo was still in the mapping phase, PBOT had not issued any permit allowing driverless operation, and the City was not issuing such permits while it updates its rules for autonomous vehicles.[49]

In its April 28, 2026 blog post, Waymo said that it would begin manually driving its vehicles in Portland to familiarize the Waymo Driver with the city’s streets.[50]

PBOT’s official statement of April 28, 2026 explained:

“PBOT understands this process will entail Waymo automated vehicles being operated by a licensed human driver with their sensor systems engaged to create a digital map of the city for future robotaxi operations. Since there will be a licensed human driver operating the vehicle and the automated driving system will not be engaged, Waymo does not need a PBOT AV testing permit, meaning the City has no regulatory ability to restrict these activities.”[51]

A significant regulatory gap:

Because Waymo’s mapping vehicles are operated by licensed human drivers with the automated driving system disengaged, Portland has no legal authority to restrict that activity, although a permit is required before driverless vehicles may operate.

The Political Situation

• Council Vice President Olivia Clark called the prospect of Waymo’s arrival “kind of disturbing” at a February 2026 legislative hearing, according to OPB.[52]

• Councilor Mitch Green stated publicly that he does not support Waymo’s expansion to Portland.[53]

• Oregon House Bill 4085, which would have given Waymo a clear legal path to operate statewide, died in committee during the Legislature’s short session.[54]

• PBOT’s recommended regulatory framework includes requiring companies to provide a safety plan based on Portland’s Vision Zero goal of zero traffic deaths, to pay ride fees to support transportation maintenance, and to comply with city restrictions on total AV numbers on Portland streets.[55]

• In late July 2026, PBOT staff presented seven policy concepts to the City Council’s Public Works Committee, including a cap on the number of driverless vehicles and a minimum testing requirement before a for hire permit may issue, and the committee also discussed data sharing, data privacy, and fees.[56]  Councilor Clark directed her office to begin drafting an automated vehicle ordinance for possible consideration by the full Council.[57]

• Staff told the committee that no city in the country currently regulates for hire automated vehicles and that every city with an active deployment has been preempted by state legislation, and committee members agreed that Portland should codify its rules before the state legislature convenes in 2027.[58]

• Disability Rights Oregon has said that it sees promise in Waymo as a mobility solution but wants strict safety and accessibility guarantees from the City Council.[59]

The City’s rules are still being written. The committee’s next step is to agree on updated administrative rules and bring them to the full Council this fall.[60]Because state legislation could displace local rules once the legislature convenes in 2027, the window in which Portland can set permit conditions on its own terms is open, but it may not stay open.

Waymo’s Current National Footprint

As of September 1, 2026, Waymo offered paid driverless service in 14 U.S. cities,[61]with a fleet reported at more than 4,000 vehicles.[62] As of September 14, 2026, Waymo offered public fully autonomous service in 15 U.S. markets, with Las Vegas becoming its fifteenth market when the company began offering fully autonomous rides to public riders there.[63]

VII. Conclusion

In conclusion, what the research reveals is not an isolated conflict of interest but a systemic gap in independent oversight. Waymo generates its own safety data. Researchers affiliated with Waymo publish it as peer reviewed science. Waymo personnel have taken part in the forums that study automated vehicle policy. And the federal agency responsible for oversight has revised its reporting requirements in a way that safety advocates describe as a dilution. The same hand that produces the data also grades it. The public has no fully independent source of verification.

Waymo’s published results may prove accurate. Portland, including its cyclists and wheelchair users, deserves to learn whether they are before a permit issues, and it deserves honest answers about the technology that is about to roll down its streets. Those residents deserve better than a safety record verified only by those who produced it.

_________________________________________________________

Michele A. Peters, Esq. (Retired) | Waymo Research | October 7, 2026 Updated

[1] Oregonian, Apr. 28, 2026, https://www.oregonlive.com/business/2026/04/self-driving-car-service-waymo-coming-to-portland.html.

[2] See K.D. Kusano et al., Comparison of Waymo Rider-Only Crash Rates by Crash Type to Human Benchmarks at 56.7 Million Miles, Traffic Injury Prevention (May 16, 2025), https://pubmed.ncbi.nlm.nih.gov/40378124/ (all six authors affiliated with Waymo LLC; corresponding author listed a Waymo email address).

[3] Waymo Blog, Jan. 6, 2021, https://waymo.com/blog/2021/01/why-youll-hear-us-say-autonomous-driving/.

[4] John Christman, Autonomy in Moral and Political Philosophy, Stan. Encyc. Phil. (Fall 2025 ed.), Edward N. Zalta & Uri Nodelman eds., https://plato.stanford.edu/archives/fall2025/entries/autonomy-moral/.

[5] Kirsten Korosec, Waymo Is Dropping the Term “Self-Driving,” but Not Everyone in the Industry Is on Board, TechCrunch (Jan. 7, 2021), https://techcrunch.com/2021/01/07/waymo-is-dropping-the-term-self-driving-but-not-everyone-in-the-industry-is-on-board/.

[6] Andrew J. Hawkins, Waymo Says It’s Ditching the Term “Self-Driving” in Dig at Tesla, The Verge (Jan. 6, 2021).

[7] Waymo Team, New Data Hub Shows How Waymo Improves Road Safety (Sept. 5, 2024).

[8] Kusano et al., supra note 2.

[9] See infra note 16.

[10] Forum on Preparing for Automated Vehicles and Shared Mobility Services, Nat’l Acads. of Scis., Eng’g & Med., https://www.nationalacademies.org/our-work/forum-on-preparing-for-automated-vehicles-and-shared-mobility-services (last visited Oct. 7, 2026); Nat’l Acads. of Scis., Eng’g & Med., National Academies/TRB Forum: Preparing for Automated Vehicles and Shared Mobility(meeting summary reporting that Waymo joined as a sponsoring organization), https://www.nationalacademies.org/cdn/materials/9fba12da-4be8-47d4-aa19-ae8239e28f78.

[11] Statement by Cathy Chase, President, Advocates for Highway & Auto Safety, on New Automated Vehicle Framework (Apr. 24, 2025), https://saferoads.org/2025-nhtsa-av-framework-statement/.

[12] Advocates for Highway & Auto Safety, About Us, https://saferoads.org/about/.

[13] S. Comm. on Com., Sci. & Transp., Hit the Road, Mac: The Future of Self-Driving Cars (Feb. 4, 2026), https://www.commerce.senate.gov/meetings/hit-the-road-mac-the-future-of-self-driving-cars/.

[14] DREDF, DREDF Comments on Research Ideas to Support Nationwide Automated Vehicle Deployment (Oct. 2025), https://dredf.org/dredf-comments-on-research-ideas-to-support-nationwide-automated-vehicle-deployment/.

[15] Nat’l Highway Traffic Safety Admin., NHTSA Research and Rulemaking Activities on Vehicles Equipped with Automated Driving Systems (July 2025), https://www.nhtsa.gov/sites/nhtsa.gov/files/2025-07/report-congress-research-rulemaking-automated-driving-systems-july-2025-tag.pdf.

[16] Waymo Team, Waymo’s Autonomous Vehicles Are Significantly Safer Than Human-Driven Ones, Says New Research Led by Swiss Re, Waymo Blog (Sept. 2023), https://waymo.com/blog/2023/09/waymos-autonomous-vehicles-are-significantly-safer-than-human-driven-ones/.

[17] L. Di Lillo et al., Comparative Safety Performance of Autonomous- and Human Drivers: A Real-World Case Study of the Waymo Driver, 10 Heliyon e34379 (July 14, 2024), https://doi.org/10.1016/j.heliyon.2024.e34379 (Waymo affiliated co authors).

[18] Waymo Team, New Swiss Re Study: Waymo Is Safer Than Even the Most Advanced Human-Driven Vehicles, Waymo Blog (Dec. 19, 2024), https://waymo.com/blog/2024/12/new-swiss-re-study-waymo/.

[19] S. Comm. on Com., Sci. & Transp., Hit the Road, Mac: The Future of Self-Driving Cars  (Feb. 4, 2026), https://www.commerce.senate.gov/meetings/hit-the-road-mac-the-future-of-self-driving-cars/.

[20] Forum page, supra note 10.

[21] Meeting summary, supra note 10.

[22] Alex Karner, Dana Rowangould & Jesus M. Barajas, U.S. Transportation Research at a Crossroads (UC Davis Inst. of Transp. Stud. 2025), https://itspubs.ucdavis.edu/publication_detail.php?id=4779.

[23] Forum page, supra note 10; Timothy Papandreou, Speaker Biography, Art of City Building, https://www.artofcitybuilding.ca/presenter-timothy-papandreou.

[24] Nat’l Highway Traffic Safety Admin., NHTSA Orders Crash Reporting for Vehicles Equipped with Advanced Driver Assistance Systems and Automated Driving Systems (June 29, 2021), https://www.nhtsa.gov/press-releases/nhtsa-orders-crash-reporting-vehicles-equipped-advanced-driver-assistance-systems.

[25] Press Release, U.S. Dep’t of Transp., Trump’s Transportation Secretary Sean P. Duffy Unveils New Automated Vehicle Framework as Part of Innovation Agenda (Apr. 24, 2025), https://www.transportation.gov/briefing-room/trumps-transportation-secretary-sean-p-duffy-unveils-new-automated-vehicle-framework.

[26] Chase Statement, supra note 11.

[27] Autonomous Vehicles, School Zones: Waymo Incidents Trigger NHTSA Review, ACT News (Jan. 21, 2026), https://www.act-news.com/news/waymo-incidents-trigger-nhtsa-review/.

[28] U.S. Dep’t of Transp., Get to Know DOT Secretary Duffy, https://www.transportation.gov/office-of-secretary.

[29] DOT Press Release, supra note 25.

[30] Nat’l Highway Traffic Safety Admin., Annual Modal Research Plan FY 2024: Program Outlook FY 2025 (Apr. 3, 2023; pub. Aug. 2024), Program Outlook FY 2025 at 8–12) https://www.transportation.gov/sites/dot.gov/files/2024-08/AMRP%20FY2024-2025%20NHTSA.pdf.

[31] NHTSA Report to Congress, supra note 15.

[32] Kai Williams, Very Few of Waymo’s Most Serious Crashes Were Waymo’s Fault, Understanding AI (Sept. 17, 2025), https://www.understandingai.org/p/very-few-of-waymos-most-serious-crashes.

[33] Williams, supra note 32.

[34] Suit by SF Cyclist Doored by Driverless Waymo Says Safety System Failed, S.F. Chron. (2025), https://www.msn.com/en-us/money/companies/suit-by-sf-cyclist-doored-by-driverless-waymo-says-safety-system-failed/ar-AA1H3WjW; see also Williams, supra note 32 (reporting Waymo’s denial).

[35] Williams, supra note 32 (reporting Waymo’s published estimate).

[36] Jordyn Holman, interview with Tekedra Mawakana, N.Y. Times (Mar. 15, 2026), https://www.nytimes.com/2026/03/15/business/waymo-ceo-robotaxi.html.

[37] Nat’l Highway Traffic Safety Admin., Traffic Safety Facts 2023 Data: Bicyclists and Other Cyclists (July 2025), https://crashstats.nhtsa.dot.gov.

[38] NHTSA Report to Congress, supra note 15.

[39] Cal. Dep’t of Motor Vehicles, Autonomous Vehicle Collision Reports, https://www.dmv.ca.gov/portal/vehicle-industry-services/autonomous-vehicles/.

[40] Joel Umanzor, San Francisco Cyclist-Waymo Collision, S.F. Standard (Feb. 6, 2024), https://sfstandard.com/2024/02/06/waymo-collides-san-francisco-cyclist-police-say/.

[41] Cal. Dep’t of Motor Vehicles, New Autonomous Vehicle Regulations Strengthen Oversight and Enforcement, Authorize Trucks and Transit (Apr. 28, 2026), https://www.dmv.ca.gov/portal/news-and-media/new-autonomous-vehicle-regulations-strengthen-oversight-and-enforcement-authorize-trucks-and-transit/.

[42] DREDF, Autonomous Vehicle Safety and Accessibility for People with Disabilities (Virtual Capitol Hill Briefing, Mar. 7, 2023), https://dredf.org/autonomous-vehicle-safety-and-accessibility-for-people-with-disabilities/.

[43] S. Rep. No. 116-109 (2019), accompanying Further Consolidated Appropriations Act, 2020, Pub. L. No. 116-94 (requesting NHTSA research on the accessibility of automated vehicles); Nat’l Highway Traffic Safety Admin., Research on the Accessibility of Automated Vehicles(Report to Congress), https://www.nhtsa.gov/sites/nhtsa.gov/files/2022-12/Report-to-Congress-Research-on-the-Accessibility-of-Automated-Vehicles-tag_0.pdf.

[44] Waymo Accessibility Network, https://waymo.com/waymo-accessibility-network/ (listing all twenty current member organizations); see also Lana Nieves, Why Autonomous Vehicles Are Essential to the SF Disability Community, S.F. Examiner (Dec. 16, 2025), https://sfexaminer.com/forum/waymo-sf-disability-community-essential/; Waymo, Waymo’s Accessibility Work with Advocates Recognized by U.S. Department of Transportation (Aug. 9, 2022), https://waymo.com/community/articles/waymos-accessibility-work-with-advocates-recognized-by-usdot/.

[45] Disability Advocates Support Waymo Self-Driving Cars, Axios S.F. (July 21, 2023), https://www.axios.com/local/san-francisco/2023/07/21/disability-advocates-support-waymo-self-driving-cars.

[46] Waymo Help Center, Wheelchair-Accessible Vehicles, https://support.google.com/waymo/answer/10656347.

[47] Delaney Tarr, Waymo Is Coming to Atlanta, But Not for Everyone, SaportaReport (Sept. 26, 2024), https://saportareport.com/waymo-is-coming-to-atlanta-but-not-for-everyone/.

[48] Driverless Taxi Company Waymo Plans Portland Rollout, OPB (Apr. 28, 2026), https://www.opb.org/article/2026/04/28/waymo-portland-rollout-driverless-taxi-mapping-streets/.

[49] Waymo Is Still Mapping Portland as Driverless Cars Await Next Steps, KGW (Sept. 21, 2026), https://www.kgw.com/article/money/business/waymo-mapping-portland-driverless-cars-await-next-steps/283-f2f24e65-bf8c-4f97-a2aa-0a34b3d1ca0c.

[50] Waymo, Waymo in Portland (Apr. 28, 2026), https://waymo.com/blog/shorts/waymo-in-portland/.

[51] Portland Bureau of Transp., Automated Vehicle Updates (Apr. 28, 2026), https://www.portland.gov/transportation/newmobility/news/2026/4/28/av-newsletter-automated-vehicle-updates.

[52] OPB, supra note 48.

[53] Id.

[54] Carlos Fuentes, Self-Driving Cars, Limits on Needle Handouts: These Are Among the Dozens of Bills That Are Dead in Oregon’s Short Session, Oregonian (updated Feb. 26, 2026), https://www.oregonlive.com/politics/2026/02/self-driving-cars-limits-on-needle-handouts-these-are-among-the-dozens-of-bills-that-are-dead-in-oregons-short-session.html.

[55] Sophie Peel, Robotaxi Company Waymo Is Eyeing Portland, PBOT Director Says, Willamette Wk. (Jan. 31, 2026), https://www.wweek.com/news/city/2026/01/31/robotaxi-company-waymo-is-eyeing-portland-pbot-director-says/.

[56] Waymo Is Already Mapping Portland, but City Leaders Are Pressing the Gas on Proposed Rules, KOIN (July 2026), https://www.koin.com/news/portland/waymo-portland-city-leaders-proposed-rules-consideration/; Julia Pickar, Portland Moves to Regulate Robotaxis, OPB (July 30, 2026), https://www.opb.org/article/2026/07/30/portland-oregon-robotaxis-waymo-autonomous-vehicles/.

[57] KOIN, supra note 56.

[58] KOIN & OPB, supra note 56.

[59] Amelia Arvesen, Training Wheels: Waymo Considers Portland as Portland Considers Waymo, Portland Monthly (Fall 2026), https://www.pdxmonthly.com/news-and-city-life/2026/07/portland-waymo-autonomous-vehicles.

[60] Pickar, supra note 56.

[61] Waymo Opens Robotaxi Rides to the Public in 3 New Cities, Now 14 Total, Electrek (Sept. 1, 2026), https://electrek.co/2026/09/01/waymo-public-robotaxi-denver-san-diego-tampa/.

[62] Waymo Takes Robotaxi Service Public in Denver, San Diego and Tampa, Drive Tesla Canada (Sept. 22, 2026), https://driveteslacanada.ca/news/waymo-driverless-rides-denver-san-diego-tampa/.

[63] Waymo Team, Vegas, Deal Us In! We’re Welcoming Riders Today, Waymo (Sept. 14, 2026), announcing that Waymo began providing fully autonomous trips to public riders in Las Vegas, Waymo announcement; Kirsten Korosec, Waymo Opens Robotaxi Service in Las Vegas, TechCrunch (Sept. 14, 2026) (reporting Las Vegas as Waymo’s fifteenth market).