New York City Mayor Eric Adams and NYC Department of Transportation (DOT) Commissioner Ydanis Rodriguez released robust safety requirements for responsible and safe autonomous vehicle (AV) testing in the City, as well as announcing the opening of applications for a new permit program.

DOT has established a permitting program to ensure approved applicants are ready to test their technology in the country’s most challenging urban environment, safely and proficiently. Consistent with state law, a trained safety driver will still be required to sit behind the wheel, and be ready to take control of an AV-enabled vehicle at all times.

NYC DOT is trying to encourage innovation by facilitating the responsible testing of new technologies and services that may contribute to a safer, more equitable, more sustainable, and more efficient transportation system. AVs could support these goals.

Applicants may apply to test AVs anywhere in NYC, understanding that the city presents some of the most challenging urban street environments for an AV to navigate. To protect public safety and ensure AV testing does not unduly impede traffic flow, pedestrian and cyclist movement, transit service, or emergency response, NYC DOT said it will work with each applicant over the course of the application process to:

  • Understand the competencies of their AV technology
  • Review the scope of their proposed testing plan
  • Review their test vehicle operator training program
  • Discuss their company’s approach to safety, particularly as demonstrated through previous urban testing experience

In early July, driverless app-hail service Waymo, owned by Google parent Alphabet, deployed its fleet in NYC and began mapping out city roads, with humans still sitting behind the wheel… as the company awaits a change in state law to allow fully driverless service. Waymo submitted its DOT application in June 2025, which will include a “human safety operator” behind the wheel to comply with the New York State law, which currently requires that a test vehicle operator be present and ready to assume control of the vehicle while the AV technology is in operation.

While Waymo is currently seeking to test its AVs in NYC with a specialist behind the wheel, they are also advocating for a change in the law that currently requires a vehicle operator to be present. Waymo is also advocating for changes to New York State law to enable it to introduce a fully autonomous ride-hailing service in NYC. Waymo made it clear they have every intention of introducing its fully autonomous ride-hailing service to the city in the future. While the initial stages will involve humans (not robots) driving the cars, the fact remains that eliminating drivers entirely is their goal.

Waymo currently operates 1,500 fully electric, autonomous cars across San Francisco, Los Angeles, Phoenix, and Austin. But NYC comes with its own unique set of challenges – like jaywalkers, cyclists who veer out of bike lanes, horse-drawn carriages, and construction work. Waymo has grown massively since its creation in 2009 as Google’s Self-Driving Car Project. Now, it provides more than 250,000 fully autonomous paid trips each week across major US cities.

NYC’s ground transportation industry has expressed to DOT Commissioner Rodriguez its deep concerns about Waymo’s recent announcement: that it has applied for a permit to test autonomous vehicles on city streets. The most immediate concern is the threat of job displacement. The introduction of autonomous vehicles poses a direct risk to the livelihoods of tens of thousands of professional drivers. It also represents a high risk of the city facilitating Waymo’s monopoly on autonomous for-hire vehicles (FHVs).

The impact of autonomous vehicle deployment will be felt throughout the entire traditional FHV industry. Dispatch bases, vehicle owners, and other ancillary businesses stand to be disrupted and even eliminated. Additionally, numerous high-profile safety incidents involving autonomous vehicles have occurred across the country, raising serious questions about the readiness of this technology.

Despite the potential benefits, AVs are expected to disrupt tens of thousands of drivers, resulting in job losses for workers in the FHV industry, a majority of whom are from socially and economically marginalized communities. As automated systems replace human drivers, there will be a need for retraining programs to help displaced workers make the transition to new employment opportunities. This shift may exacerbate existing inequalities, as drivers with lower education levels and fewer transferable skills may find it more challenging to adapt to new roles in the labor market.

At this moment, more than 30 companies across the globe say they are working on autonomous vehicle technology. These companies range from computing-technology firms like Apple, Google, and Intel to those usually associated with automobile manufacturing, such as BMW, Ford, Honda, and Volvo. Their most optimistic predictions are that in as few as three to five years, fully autonomous vehicles – automobiles without human drivers – will be commonplace on U.S. roads.

The growth of autonomous vehicles isn’t going just to transform how we commute. It will transform an entirely new workforce that needs to be built from the ground up. The transition to a fully autonomous transportation system will require policymakers to develop strategies to mitigate the negative effects of job displacement.

Although safe, fully automated and appropriately tested vehicles are likely at least five years away, policymakers must start addressing the policy and regulatory issues immediately. It isn’t time to panic, but policymakers and business leaders cannot afford to be complacent either.

According to a report by the McKinsey Global Institute, up to 800 million jobs could be lost worldwide due to automation by 2030. According to a report by the Federal Highway Administration, the cost of upgrading infrastructure to support AVs could be as high as $1 trillion. According to a report by the RAND Corporation, the regulatory framework for AVs will need to address issues such as safety standards, cybersecurity and liability.

The economic implications of AVs are significant, with both benefits and challenges to be addressed. While AVs have the potential to increase productivity and improve safety, they also pose significant challenges, including job displacement and infrastructure costs. As the development and deployment of AVs continues to evolve, policymakers need to address these challenges head-on. The failure to do so can have disastrous consequences for the future. In the interim, we must maintain a positive and productive dialogue with policymakers.

Article by Steven J. Shanker, Esq.

Steven J. Shanker, Esq. is General Counsel to the Livery Roundtable, Inc. and the New York Independent Livery Driver Benefit Fund.

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