R Street Testimony for MD Commission on Climate Change in Support of AV Deployment in Maryland
September 17, 2026
The Honorable Serena McIlwain
Chair, Maryland Commission on Climate Change
Secretary, Maryland Department of the Environment
1800 Washington Blvd
Baltimore, MD 21230
Re: Comments on Proposed 2026 Individual Commissioner Recommendation #2, “The Maryland legislature should make it legal to use autonomous vehicles that are EVs.”
Secretary Serena McIlwain and Members of the Commission:
My name is Robert Melvin, and I am the Northeast region director at the R Street Institute, which is a nonprofit, nonpartisan public policy research organization. We engage in policy analysis and outreach promoting free markets and limited, effective government in a variety of policy areas, including technology and innovation policy. For this reason, we want to share our support for Individual Commissioner Recommendation #2, “The Maryland legislature should make it legal to use autonomous vehicles that are EVs.”
As you may know, during the most recent session of the General Assembly, Delegate Ziegler and Senator love championed legislation that would have established a comprehensive policy framework to govern the deployment of highly autonomous vehicles (AVs) in Maryland. These measures, House Bill 1295 and Senate Bill 909, would have permitted autonomous vehicles to operate without a human driver, provided they met applicable federal safety standards and complied with state traffic laws.[1] In addition, the bills would have established accountability requirements and protocols for interacting with law enforcement.
An often overlooked but critical consideration when deploying these AVs is their environmental benefits. As noted by the International Energy Agency, all commercial AVs are electric, in part because the technical characteristics of EVs are well suited to autonomous driving.[2] Accordingly, if Maryland adopted legislation like those proposed during the most recent General Assembly session, it could help the state meet its emissions-reduction goals.[3]
Beyond helping the state meet its climate goals, it would have prevented regulatory fragmentation by precluding a patchwork of conflicting local rules and would have ensured consistent standards across Maryland. The bills would have authorized autonomous vehicles for transportation networks and other for-hire transportation services, which would have broadened consumer access and enabled full market participation. The bills also updated antiquated equipment statutes by exempting vehicles designed exclusively for autonomous operation from requirements written for human drivers, allowing vehicle design to evolve without being tethered to obsolete assumptions.
Recent trends in Maryland indicate an increase in roadway fatalities, with the number of fatal crashes climbing from 535 in 2019 to 621 in 2023.[4] While multiple factors contribute to this increase, human error remains a leading cause—including impaired driving, reckless or aggressive behavior, and distracted driving.[5] Maryland ranks 44th in the nation for traffic congestion, making it one of the most congested states.[6] The financial toll of gridlock is substantial, costing drivers an estimated $638 to $2,183 annually depending on their location.[7] Although no single policy can resolve these complex transportation challenges, legislation such as HB 1295 and SB 909 represents a meaningful step toward improving safety and mobility in Maryland.
AVs also have the potential to reduce costs for Maryland drivers. Research indicates that when autonomous vehicles operate at the front of traffic flow, they can smooth driving patterns, reduce stop-and-go conditions, and lower overall fuel consumption among conventional combustion engine vehicles by as much as 42 percent.[8] By improving traffic efficiency, AV integration could translate into meaningful reductions in transportation costs while also easing congestion on Maryland’s roadways and potentially reducing emissions from conventional vehicles as Maryland works towards its 2045 climate goals. Beyond these potential mobility and environmental benefits, AVs also offer potential safety benefits.
An analysis by Swiss Re, one of the world’s leading reinsurers, examined liability claims associated with 25.3 million miles driven by autonomous robo-taxis. The findings indicate that the autonomous vehicles studied had significantly lower rates of liability claims than comparable human-driven vehicles including an 88 percent reduction in property damage claims and a 92 percent decline in bodily injury claims.[9] Overall, the analysis estimates that the autonomous driving system was approximately 10.4 times safer than the human-driver benchmark used in the study with the data estimating that it’s safety performance had improved at a rate that effectively doubled every five years.[10] In the relatively rare cases where collisions do occur, the evidence frequently points to human drivers as the primary cause rather than the autonomous system.[11]
Additional evidence underscores the safety advantages of autonomous vehicles. Compared to human-driver benchmarks, AVs were associated with 62 percent fewer police-reported crashes, 78 percent fewer injury-related collisions, and 81 percent fewer airbag deployments.[12] These reductions have significant economic implications. A review of National Highway Traffic Safety Administration data estimates that motor vehicle crashes generate roughly $23 billion annually in medical costs across the United States.[13] A 90 percent reduction in collision rates could translate into approximately $20.7 billion in annual savings.[14] These safety and mobility benefits are complemented by broader economic benefits.
Since AV deployment is capital-intensive, companies will need to invest in fleet infrastructure, maintenance hubs, remote operations centers, and other areas. A supportive legal framework could help attract private investment in Maryland. One analysis projects that the autonomous vehicle sector could generate up to 455,000 new jobs nationwide over the next 15 years, with roughly 190 positions created for every 1,000 AVs deployed on the road.[15] For a state ranked as the sixth most innovative in the country, embracing this emerging industry presents a meaningful opportunity to reinforce that standing.[16] By establishing a supportive framework for deployment, this proposal could help draw additional private investment and support Maryland’s position as a hub for technological advancement.
Although some skepticism remains, autonomous vehicle technology is no longer limited to experimental testing. It has already been deployed at scale in numerous states, and Maryland currently permits on-road testing of these systems.[17] Advancing this legislation would move the state from a framework on limited testing to broader authorization, aligning Maryland with the 26 other states that have already approved autonomous vehicle deployment on their highways.[18]
Ultimately, the Commission’s proposed recommendation related to AVs could encourage the legislature to adopt legislation permitting their widespread rollout of this technology. Such legislation would advance multiple policy objectives at once—assisting the state in meeting its emissions reduction targets, enhancing roadway safety, reducing congestion, and supporting innovation-driven economic expansion. We respectfully urge the Commission to adopt Proposed 2026 Individual Commissioner Recommendation #2, “The Maryland legislature should make it legal to use autonomous vehicles that are EVs.”
Thank you,
Robert Melvin
Northeast Region Director, State Government Affairs
R Street Institute
rmelvin@rstreet.org
[1] Maryland General Assembly, 2026 Legislative Session, Senate Bill 909, Last Accessed February 24, 2026. https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/SB0909?ys=2026RS.
Maryland General Assembly, 2026 Legislative Session, House Bill 1295, Last Accessed February 24, 2026. https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/HB1295/?ys=2026rs.
[2] IEA (2026), Autonomous vehicles, IEA, Paris https://www.iea.org/reports/autonomous-vehicles
[3] Maryland Department of the Environment, “Maryland Department of Environment Releases Climate Pollution Reduction Plan to Significantly Cut Greenhouse Gas Emissions by 2031,” December 28, 2023. https://news.maryland.gov/mde/2023/12/28/maryland-department-of-the-environment-releases-climate-pollution-reduction-plan-to-significantly-cut-greenhouse-gas-emissions-by-2031/
[4] Maryland Department of Transportation, Motor Vehicle Administration, “Zero Deaths Maryland, Crash Summaries,” Last accessed February 24, 2025. “https://zerodeathsmd.gov/resources/crashdata/.
[5] CDC, “Global Road Safety,” May 16, 2024. https://www.cdc.gov/transportation-safety/global/index.html.
[6] Adam McCann, “Best & Worst States to Drive in (2026),” WalletHub, February 25, 2026. https://wallethub.com/edu/best-worst-states-to-drive-in/43012.
[7] TRIP, “Maryland Transportation by the Numbers,” March 2025. https://tripnet.org/wp-content/uploads/2025/03/TRIP_Maryland_Transportation_by_the_Numbers_Report_March_2025.pdf.
[8] Alexandre M. Bayen, “Eliminating Traffic Jams with Self-Driving Cars,” University of California at Berkeley, March 15, 2021. https://ce.berkeley.edu/news/2537.
[9] Luigi Di Lillo, et al., “Do Autonomous Drivers Outperform Latest-Generation Human-Driven Vehicles? A comparison to Waymo’s Auto Liability Insurance Claims at 25 million Miles,” Waymo, 2024. https://waymo.com/research/do-autonomous-vehicles-outperform-latest-generation-human-driven-vehicles-25-million-miles/.
[10] Gale Pooley, “Waymo Drivers Are Way Safer (10x) Than Humans,” Human Progress, Jan. 7, 2025. https://humanprogress.org/waymo-drivers-are-way-safer-10x-than-humans.
[11] Timothy B. Lee, “Human drivers are to blame for most serious Waymo collisions,” Understanding AI, Sept. 10, 2024. https://www.understandingai.org/p/human-drivers-are-to-blame-for-most.
[12] Waymo, “Waymo Safety Impact: Waymo Driver Compared to Human Benchmarks,” Last accessed February 24, 2025. https://waymo.com/safety/impact/.
[13] Kareem Othman, “Exploring the implications of autonomous vehicles: a comprehensive review,” Innovative Infrastructure Solutions, March 1, 2022. https://pmc.ncbi.nlm.nih.gov/articles/PMC8885781/.
[14] Ibid.
[15] Chamber of Progress, “Opportunity AV: How Many and What Types of Jobs Will Be Created by Autonomous Vehicles?,” October 3, 2024. https://progresschamber.org/wp-content/uploads/2024/03/Opportunity-AV-How-Many-and-What-Type-of-Jobs-Will-Be-Created-by-Autonomous-Vehicles.pdf.
[16] Maryland Business Support, “Data Rankings, Innovation and Industry,” Last accessed February 24, 2025. https://business.maryland.gov/ranking/?bj-ranking-topics%5B%5D=innovation-industry.
[17] Ariel Wolf, et al., “State Autonomous Vehicle Laws and Regulations,” Venable LLP, December 2024, https://books.venable.com/Autonomous-Vehicles/4/.
[18] Ibid.