The City of Portland is taking feedback RIGHT NOW on its policies for the entrance of Autonomous Vehicles (like Waymo) into the Portland area.

PLEASE SEND AN EMAIL to the city to comment on this policy before 5PM on Friday April 10th. You can use the talking points at the bottom of the page, or the explanation that follows here, to help start your thinking!

SEND YOUR EMAIL TO:
pbotpolicycomments@portlandoregon.gov

USE THE SUBJECT LINE:
TRN-14.34 comments

Remember! Your email does NOT need to be long.

You can just send a simple message that states that you are concerned about the threat that Autonomous Vehicles (AVs) pose to public-privacy in the environment around them, and that you want to see protections for vehicles, pedestrians and people.

That alone would help a ton!

Of course, we have more involved ideas below, if you have just a bit more time… Read on!

You can see the city’s webpage on this subject here: https://www.portland.gov/transportation/code-rule-updates/news/2026/2/18/updates-trn-1434-automated-vehicles

Where Does PDX Privacy Stand on AVs?

Our official stance is that Autonomous Vehicles (AVs) pose a massive surveillance threat to the city and its inhabitants, due to the huge amount of data they must constantly record, and send back to centralized servers.

As a result, PDX Privacy urges that AVs be denied permits to operate, until these threats can be effectively managed.

We believe that the only safe way to manage the potential for AV data to be used in the creation of a massive surveillance system would be to limit the data collected to the vehicle itself, in an End-to-End-Encrypted, zero-knowledge state (including encryption-at-rest), with a 24-hour retention period for data.

The current state of the technology is such that this would be impossible.

As a result, we feel that AVs should be denied the ability to operate until these restrictions become feasible.

You can read our official email here:
PDX Privacy Official Email on AV Policy

However, we also understand that you may have a more moderate view of these vehicles, and we respect that.

In the event that you feel differently, we have more moderate policy demands at the end of these talking points.

(Even in our own letter, you will notice that we add these policy demands, should a ban on AVs fail.)

Please use your own judgement and advocate for whichever position fits your own personally-held values most effectively.

Background Information:
From the Electronic Frontier Foundation: The Impending Privacy Threat of Self-Driving Cars
From Criminal Legal News: Driverless Vehicles Are the Newest Mass Surveillance Tool of Law Enforcement
From Bloomberg: Police Are Requesting Self-Driving Car Footage for Video Evidence

Talking Points: Help with crafting your email to the city!

Use the talking points below to start your thinking, and then make them your own!

(We have a list of policy reform options at the bottom that you can advocate for as well.)

Talking Points on Autonomous Vehicles

1. Autonomous vehicles collect vast amounts of data just to function. This data is collected by many independent vehicles, in many locations, simultaneously, and then potentially saved over time. This data currently is retained in a centralized server by the companies operating these vehicles, and there is no policy or law restricting how that data could be used. The potential for creating a massive surveillance database that could be accessed by federal agencies or law enforcement is a clear and present danger. To prevent this from happening, AVs should be denied permits to operate, until they can be trusted to limit their data collection to the individual vehicle itself, and maintain it in an end-to-end-encrypted state. (AND/OR: Use one or more policy ideas below).
2. Many vehicles now feature cameras and recording devices that aid drivers in making decisions and parking successfully. These cameras can record this data, but are only needed to communicate to the occupants of the cars they are attached to. As a result, their data can be localized to the vehicle and do not need to be sent elsewhere. This is entirely different than the recording devices used on autonomous vehicles. 
   • Autonomous vehicles must transmit data to a central server location in order to function. This means that the data they collect is being saved into a single location, managed by a single company. There is nothing currently in place to prevent this data from being aggregated into a massive surveillance network that could identify and track the movements of residents, protestors or marginalized groups. As a result, AVs should be denied permits to operate, until they can be trusted to limit their data collection to the individual vehicle itself, and maintain it in an end-to-end-encrypted state. (AND/OR: Use one or more policy ideas below).
3. I applaud efforts by many autonomous vehicle companies to resist over-broad requests by police around the country for the data that AVs collect and store. However, these efforts are entirely voluntary. There is nothing legally stopping an AV company from sharing its data with the police department or a federal agency.
   • If there is a protest or there are at-risk people involved, then data of this kind can be a massive risk to the first amendment rights of people in our country. We need strong policies in place that protect our rights to associate freely and express ourselves, without the fear that we might be swept up into a database that might be accessed in the future. Therefore, we must have (insert some policy demands here).
4. Communities of color are most at-risk for being over-surveilled and over-policed. Adding Autonomous Vehicles to our streets here in Portland threatens to make this problem even worse.
   • AVs need to extract huge amounts of data from the areas around them in order to function. Right now, there is no limit on how that data can be used, and in traditionally-marginalized communities, there is nothing to stop these vehicles from acting as a constant watch-dog over the activities of residents. There is no warrant requirement for the release of data to the police or federal agencies, making the potential for abuse of this data extreme.
   • We must protect our most vulnerable residents, especially those at threat of deportation or harassment by ICE, like our African communities and latino communities. Please deny the entry of AVs into Portland until we can prevent the sharing of aggregated data into AV company servers and ensure that this data cannot be accessed or shared by the companies involved. (OPTIONAL: At a minimum, I demand that you… insert a few policy ideas here, especially with regard to warrants.)
5. The Trump administration has made it clear that it will be tracking and creating databases of protestors. With the outrageously quick advance of AI systems and their abilities to create profiles, identify individuals, track vehicles, and create pattern-of-life dossiers on regular people, large pools of data held by huge tech companies are now a clear and present danger to those of us expressing our first amendment rights.
   • Because AVs must collect gigantic amounts of data from the environment in order to function, these vehicles are constantly sweeping up massive amounts of geo-tagged information, and aggregating it into huge pools of data that can easily be mined later. It can also be sold to data brokers, fueling the Trump administration’s goals by providing it with ever more data that can be purchased by the government.
   • Allowing large tech companies to create databases of this kind is extremely dangerous, and even if they “promise” not to use it in this way, there is nothing preventing them from changing their minds. There is also nothing in place to prevent the saving of this data far into the future, giving them the opportunity to change their minds much later, especially when conditions change.
   • In order to prevent these kinds of outcomes, we must require that, at the very least, (insert policy demands here).

POLICY DEMANDS for the end of your email

STRONGEST DEMAND:
I urge you to deny permits for any autonomous vehicles, because the only way to make them safe is to restrict the data they collect to the vehicle itself. This data must be end-to-end encrypted and maintained in a zero-knowledge structure that is completely deleted every 24-hours. This is currently impossible in the AVs that operate right now, and therefore, the only safe way forward is to prevent them from operating in Portland until these conditions can be met.

SLIGHTLY LESS-STRONG DEMANDS:
In the event you allow AVs to be permitted and function here in Portland, you must require the following restrictions (choose a few from the list, especially those that pair up well with your introduction):

1. There must be a complete ban on the sale of any and all data collected from the environment in which the vehicle operates.
2. There must be a complete ban on the use of any environmental or ambient footage or data, for any purposes, besides the direct operations of the vehicle itself.
3. There must be a complete ban on the sharing of data or footage of any kind with any city entity, without a warrant, signed by a judge, that identifies specifically the exact footage needed, for what purpose, and identifies an open investigation in direct need of such footage. All other incidental data and information would need to be scrubbed prior to release.
4. The use of all ALPR technology must be strictly prohibited – at no time may a vehicle identify or record the whereabouts of any other vehicle on the road, in any personally-identifying way.
5. The use of any technology that records or reveals the identity of pedestrians, cyclists, vehicles, or persons, at any time and by any means, must be strictly forbidden, including the use of any object-recognition systems capable of building identifying-profiles.
6. The creation of any profiles or patterns-of-movement for any unique category of any object in the environment, including persons or vehicles of any kind, whether or not they are specifically linked to an identity, must be strictly forbidden.
7. Data and footage retention must be strictly limited to 72 hours, unless an incident is reported, and footage is needed for an active investigation.

(Don’t feel like you need to include all of these restrictions – you can just choose one or a few).

Thank you for participating!!

Your opinion is absolutely essential in this conversation, and even a line or two in an email will make a huge difference. Thank you for making your opinion heard!