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Most laws use personal delivery device (PDD). “Delivery robot” is the common plain-language term. A PDD on a sidewalk may be governed by a different legal regime from one using a street, shoulder, crosswalk, or private site. A defensible city program therefore starts with jurisdiction and authority, then sets operating conditions for safety, accessibility, accountability, reporting, and enforcement.
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Start with the legal authority over each right-of-way
There is no single nationwide municipal rule. State law may delegate specific decisions to cities, incorporate local right-of-way rules into a statewide framework, limit local prohibitions, or leave a narrow space for rules addressing hazards and access. A city should map authority separately for sidewalks, pedestrian paths, crosswalks, streets, alleys, and privately owned walkways before drafting an ordinance or permit.
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Pennsylvania’s Vehicle Code, Chapter 85, is a useful warning against treating “local control” as unlimited. The subchapter and a municipal ordinance or resolution under its local-regulation provision govern PDDs and authorized entities. A municipality may permit PDD use on specified roads with posted speeds above 25 mph and no higher than 35 mph. It may also prohibit use on covered roadways or pedestrian areas if, after consulting the authorized entity, it determines that the device would be a hazard. Outside those provisions, the statute says a municipality may not regulate operation in covered public areas.
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The practical lesson is to identify the exact delegated action and the exact prohibited local action. Pennsylvania’s framework does not support a blanket statement that every city may regulate every aspect of a delivery device. Read the current text at the Pennsylvania General Assembly statute before relying on an ordinance.
Washington: local right-of-way rules become a condition of operation
Washington RCW 46.75.020 requires a PDD to operate in accordance with ordinances, resolutions, rules, and regulations established by the jurisdiction governing the right-of-way. The same statute addresses operating locations, monitoring, insurance, incident reporting, and a registered in-state agent. This structure gives local right-of-way rules a direct role while preserving statewide requirements; it does not mean a city can disregard limits elsewhere in state law. The current provision is at the Washington State Legislature.
Use a jurisdiction matrix before writing code
| Question | Why it matters | Evidence to confirm |
|---|---|---|
| Who controls the location? | A city may control a municipal sidewalk but not a state highway or another agency’s corridor. | Right-of-way ownership, interagency agreements, and transportation code. |
| What device is covered? | Definitions may distinguish remote-controlled, semi-autonomous, and autonomous devices. | State definition and proposed local definition. |
| What action is authorized? | Permitting, safety conditions, pilot limits, and prohibitions may have different legal bases. | Delegation, preemption, and local-regulation clauses. |
| Which rules already apply? | Traffic controls, accessibility duties, insurance, reporting, and agency permits may be mandatory. | State statute, administrative rules, and existing right-of-way regulations. |
Choose a regulatory posture that matches local authority
A city normally has four practical choices: authorize a controlled pilot, require an operating agreement, issue permits under an existing code, or prohibit a defined class of operation where state law permits a prohibition. The choice should specify whether it applies only to sidewalks and pedestrian paths or also to streets and crosswalks.
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| City or jurisdiction | Approach described in the cited authority | What it does not establish |
|---|---|---|
| San Francisco | Public Works Code § 794 creates a permit program for sidewalk testing for research and development in anticipation of commercial use. | It is not a general authorization for commercial deliveries; the section excludes city streets and highways under SFMTA jurisdiction and prohibits other purposes under that section. |
| West Hollywood | Chapter 11.50 requires a valid city operating agreement and applicable fees before autonomous or semi-autonomous PDD operation on city sidewalks or pedestrian paths. | An operating agreement in one city does not establish authority in neighboring jurisdictions. |
| Santa Monica | The traffic code prohibits deploying or operating autonomous or semi-autonomous personal delivery vehicles or devices on city sidewalks or pedestrian paths. | The provision is not a statement that every type of remotely controlled device is prohibited; it separately describes requirements for remotely controlled devices. |
| District of Columbia | A permit holder may operate a compliant PDD on sidewalks and crosswalks under a permit framework. | Permit eligibility is not a guarantee of a particular fleet size, route, or continuing authorization. |
| Los Angeles | A September 2025 City Clerk document describes a 2023 ordinance authorizing LADOT to run a pilot and issue permits to qualified operators. | The document describes the program framework; current ordinance text, rules, and permit conditions must be checked before treating any item as current. |
Permit pilots
A pilot is appropriate when the city needs operational data before deciding whether to authorize broader service. The permit should define a geographic boundary, operating hours, fleet ceiling, service area, duration, renewal criteria, and a city power to pause or end the pilot for noncompliance or unacceptable access impacts.
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Operating agreements
An operating agreement can supplement a permit by assigning duties to a named operator, setting fees, requiring insurance and indemnification, and creating performance and meeting obligations. West Hollywood’s requirement for an agreement and fees illustrates this model, but the agreement must still rest on authority that covers the relevant right-of-way.
Prohibitions
A prohibition should identify the device class, location, and conduct covered. Santa Monica’s language targets autonomous and semi-autonomous devices on city sidewalks and pedestrian paths. A city should avoid wording that accidentally reaches remote-controlled devices or private property when the policy goal is narrower.
Define where, when, and how a device may operate
The core rule should draw a map in legal terms, not just in an operator’s software. Specify permitted sidewalks, crossings, streets, loading areas, docking points, and exclusion zones. If the city relies on geofencing, make the operator responsible for maintaining current boundary data and for stopping service when a boundary or map is unreliable.
- Operating areas: identify each permitted facility or zone and the agency responsible for it.
- Crossings: state whether crosswalk use is allowed, how traffic controls apply, and when a device must yield.
- Hours: set service windows where nighttime visibility, school schedules, events, or emergency access require them.
- Speed and maneuvering: establish a maximum speed only where the city has authority, and require a lower speed or stop when congestion, visibility, or surface conditions make normal travel unsafe.
- Parking and storage: prohibit blocking curb ramps, tactile warnings, building entrances, transit stops, fire connections, or the usable pedestrian route.
- Removal: require rapid retrieval of a disabled, abandoned, or communications-failed device, with a contact channel available to the public and emergency services.
Build pedestrian access and accessibility into the rule
Yielding is not enough if a device leaves no usable path. The ordinance or permit should require continuous clear width, access to curb ramps and crossings, and noninterference with people using mobility devices, white canes, service animals, strollers, or other aids. It should address temporary obstructions during loading and provide a deadline for removal.
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West Hollywood’s Chapter 11.50 requires at least two public engagement sessions each year, including one dedicated to accessibility feedback and sidewalk-safety review. A city adopting a different schedule should still identify whom it will consult: disabled residents and organizations, pedestrian groups, businesses, transit providers, emergency services, and operators. Engagement should produce measurable changes, such as revised docking locations, exclusion zones, or response times, rather than serving only as a launch event.
Assign an accountable operator and financial responsibility
A permit should name the permit holder, the legal owner, and a person or entity that can be reached during every operating period. Where state law supports it, require a registered in-state or local agent. Display a phone number or electronic contact method on each device and in the city’s public permit record.
Insurance and indemnification requirements must track state and local authority. Florida’s 2026 statute, for example, requires at least $100,000 in general liability coverage for combined operations under the owner’s, operator’s, or agent’s control. That is a statutory minimum for the covered operations, not evidence of a typical claim cost or a recommended limit for every city. Review the local-authority provision cited by the statute before adding city-specific conditions. The current text is available from the Florida Senate.
Set concrete safety and failure-response requirements
Rules should cover ordinary travel and predictable failures. At minimum, address traffic-control compliance, remote monitoring, communications loss, sensor degradation, obstruction detection, weather limits, and emergency access.
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Communications or control failure
The District of Columbia code provides a concrete model: if technology or communications fail and the operator cannot take direct control, the device must come to an off-roadway stop, and the owner must promptly remove it. The code also requires safe, non-hazardous operation, prohibits unreasonable interference with traffic, and requires contact details. A permit can add a maximum retrieval time, escalation to a staffed dispatcher, and a report when the time limit is missed. Verify the current permanent text because the page notes temporary amendments that expire April 2, 2027. See § 50–110.03 in the D.C. Law Library.
Traffic and pedestrian priority
Require compliance with official signals and signs, yielding to pedestrians where the governing law requires it, and stopping when a person is crossing or when the device cannot pass without forcing someone off the accessible route. A rule should state how an operator handles a blocked sidewalk instead of allowing the device to wait indefinitely in place.
Cargo and physical design
Define prohibited cargo, secure loads, maximum dimensions or weight where authorized, visibility equipment, and markings. If a state statute sets a weight ceiling or delegates one to an agency, incorporate that limit rather than creating a conflicting local number.
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A city cannot evaluate a pilot without timely information. Require a standardized incident report for collisions, injuries, near misses, property damage, obstruction complaints, emergency interventions, communications failures, and manual takeovers. Set reporting deadlines and preserve records long enough for audits and claims, subject to privacy, public-records, and cybersecurity law.
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Los Angeles’s described pilot framework addresses insurance, indemnification, speed limits, sidewalk accessibility, hours, fleet size, data-sharing, advertising, enforcement, and integration with the city’s 311 system. Those subjects form a useful checklist, but the September 2025 City Clerk document is a program description, not a substitute for checking the current ordinance and LADOT rules. Review the Los Angeles City Clerk document.
Complaint handling
Give residents one clear reporting channel, such as 311, and require the operator to acknowledge a complaint promptly, remove an obstruction within a specified period, and provide a written resolution for serious incidents. The city should retain authority to inspect devices and records, issue notices of violation, suspend a route or permit, and recover removal costs where law allows.
Performance review
Publish aggregate counts of incidents, complaints, response times, service hours, and devices in operation. Do not claim that a program reduced injuries, improved accessibility, or replaced vehicle trips unless the city has measured those outcomes with a defined method. The legal sources cited here establish rules and safeguards, not those results.
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Use a repeatable implementation process
- Inventory authority. List every proposed location and identify the state, city, county, transit, or private entity controlling it.
- Classify the device. Distinguish remote-controlled, semi-autonomous, and autonomous operation, and align definitions with state law.
- Select the posture. Choose a pilot, permit, operating agreement, prohibition, or a combination for different locations.
- Draft access rules. Set clear-path, yielding, docking, crossing, speed, hours, and removal requirements.
- Assign accountability. Name the permit holder, emergency contact, local agent where authorized, insurance obligations, and indemnification terms.
- Specify failure response. Require an off-route stop and prompt retrieval when communications or control fail, plus incident reporting.
- Consult and publish. Hold recurring engagement with accessibility stakeholders, residents, businesses, emergency services, and operators; publish maps, contacts, and complaint procedures.
- Review and enforce. Set performance measures, inspection powers, graduated penalties, suspension triggers, and a date to amend or end the program.
Read current examples narrowly
District of Columbia permits
On July 16, 2026, the District Department of Transportation announced permits for Serve Robotics and Coco Robotics to provide sidewalk food delivery. DDOT said expanding starting zones and fleet sizes would be an option if initial operations met permit terms. That announcement is time-specific and does not guarantee current permit status or fleet limits. It does show how a permit can be staged: start with defined zones, then expand only after compliance.
DDOT Director Sharon Kershbaum described the policy purpose this way: “Personal delivery devices offer an additional option for food delivery in the District and can be an alternative to trips made by larger vehicles.” The statement expresses a policy rationale, not a measured vehicle-trip reduction.
Arlington County, Virginia
Arlington County guidance says PDDs are allowed under Virginia law in public rights-of-way. It says the county may adopt safety ordinances but may not prohibit them, giving avoiding hospitals and firehouses as an example of a possible safety ordinance. This is county guidance summarizing state law, not the Virginia statutory text. Consult the underlying statute before drafting a local ban or exclusion zone. The guidance is at Arlington County’s PDD page.
Common drafting mistakes and their fixes
- Mistake: treating sidewalk and street rules as interchangeable. Fix: create separate location provisions and identify the controlling agency for each right-of-way.
- Mistake: assuming a permit equals permanent authorization. Fix: state the term, renewal test, expansion criteria, and suspension or termination triggers.
- Mistake: writing a citywide ban without checking preemption. Fix: identify whether state law limits prohibitions, as Pennsylvania and Arlington illustrate.
- Mistake: mentioning accessibility only in a purpose clause. Fix: require clear routes, curb-ramp access, obstruction removal, complaint response, and recurring accessibility review.
- Mistake: collecting data without a use or privacy rule. Fix: define the fields, retention period, access controls, public reporting, and legal exceptions.
- Mistake: relying on a dated pilot announcement. Fix: verify the current code, agency rules, amendments, and permit roster immediately before enforcement or legal reliance.
What a durable city framework looks like
The strongest framework is neither an unconditional welcome nor a technology-neutral slogan. It ties each rule to a lawful authority, identifies exactly where the device may travel, protects an uninterrupted pedestrian route, assigns a reachable operator, requires insurance and failure response where authorized, and creates public reporting and enforcement mechanisms. A pilot can then be expanded, modified, or ended using published performance criteria rather than assumptions about safety or mobility benefits.
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