PA Autonomous Vehicle Testing Legislation Still Needs Work

PA HB 2398 would legalize autonomous vehicles (AVs) without human drivers in Pennsylvania. Having passed the PA House, it is pending in the PA Senate Transportation Committee. While the bill has improved, my 25 years of experience working on AV safety at Carnegie Mellon University leave me with significant remaining concerns:

  1. A municipal preemption clause would prevent Pittsburgh from restricting the testing of immature self-driving vehicle technology in active school zones and other high risk locations.
  2. A loophole regarding vehicles “approved for noncommercial use” apparently exempts most AVs from certification when using conventional vehicle retrofits, potentially rendering the bill toothless.
  3. Test drivers are not required to conform to an established industry standard for testing safety as done elsewhere in the US. Argo AI is the sole company conforming to the relevant safety standard: SAE J3018.
  4. The recent National Highway Traffic Safety Administration release of AV crash data makes it clear that crashes will happen. The bill should require AV testers to attest that their technology is acceptably safe. Perfect safety might be unrealistic, but AV companies should at least promise on the record that their testing will be no more dangerous than human driven vehicles.

The current bill leaves Commonwealth constituents unnecessarily vulnerable on public roads. In exchange for placing road users at risk from this work-in-progress technology, we at least deserve to have these issues fixed before the bill is made into law.

Philip Koopman, Ph.D.
Squirrel Hill neighborhood, Pittsburgh PA


Pittsburgh Post-Gazette article was published here:

Update 6/30/22: the PA Senate Transportation Committee updated SB 965 to largely include language from the PA House bill.  It does seem to have addressed two of my points to a degree:

  • I no longer see the "approved for noncommercial use" loophole, which is good.
  • A safety management plan must be filed, which partially addresses the issue of promising that operations and testing will be no more dangerous than human driven vehicles (but does not require that level of safety). 
See printer number 1839 here:


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