So I decided to dig into this a little further…

I looked up some relevant regulations for California. So the following arguments are probably only relevant in the state of California. I would be surprised if they are not subject to change in the near future. Also, I am not a lawyer, so not only is the following not legal advice, it might also be totally incorrect. But it’s interesting to think about.

I found there are at least three relevant sections of the California Vehicle Code, namely Section 227, Section 228, and Section 38750.

Section 38750(a)(4) states:

    An “operator” of an autonomous vehicle is the person who is seated in the driver’s seat, or, if there is no person in the driver’s seat, causes the autonomous technology to engage.

How is this operator relevant? Well, the presence of a remote operator is mandatory for both testing (Section 227) and deployment (Section 228) of autonomous vehicles on public streets in the state of California. Section 228.06(c)(3) states that a manufacturer applying to deploy autonomous vehicles must provide:

    A copy of a law enforcement interaction plan that meets all of the requirements specified in Section 227.38(e) of Article 3.7.

Section 227.38(e)(1)(A) states that the law enforcement interaction plan shall include:

    How to communicate with a remote operator of the vehicle who is available at all times that the vehicle is in operation, including providing a contact telephone number for the manufacturer;

Further, Section 227.02(n) does define the remote operator as a natural person.

So, there is a remote operator available at all times, in both testing and deployment of autonomous vehicles. This remote operator can operate the vehicle remotely, and presumably one remote operator can be responsible for many autonomous vehicles, because otherwise the business plan breaks.

I would be interested to see if in the future there is a mandated ratio of vehicles per remote operator. My guess is the ratio will approach one.