Autonomous Deliver Robots were enabled in Arizona in 2018, and further re-vamped the law in 2020.
Side-note:This all reminded me of the pizza delivery robot in an episode of Black Mirror.
As of Sept 2025, Doordash says they are rolling out “Doordash dot” for testing.
Polar labs based in Tempe/Mesa have been testing for some time (?early to mid-2024. At the time I saw them, pictured right, they were still accompanied by a “chaperone” following on an ebike).

Polar Labs appears to be supplying doordash.

Roaming robots and dental therapists make it into law
Coming soon to a sidewalk near you: 200 pound autonomous delivery robots. …Without comment, Gov. Doug Ducey signed legislation Thursday authorizing these devices to use sidewalks. That in turn will pave the way for several companies to start rolling out the robots

Legislation Updates 2020

Update/expansion of the law from 2018, which had a sunset provision… SB1304 from 54R2 (spring 2020) (Here’s a link to the chaptered law). The law is a little hard to read, and keep in mind the 2018 law was sunsetted, so, e.g. if you go looking for 28-913. it appears to be non-existent and does not show up in the chaptered law as repealed.

The meat of it is 28-1221 thru 1228. The operating max speeds in particular were updated, see 28-1225

• Max Speed in a “pedestrian area” is 12mph; and Local authorities have some ability to further restrict speeds on “pedestrian areas” down to 7mph.
• Max Speed  “on the side or shoulder of a highway in an area that is not a pedestrian area” is 20mph. Note the 2018 rule about only allowed on roads with 25mph or less posted limits is gone.
• Insurance requirements of at least $100K

I have questions in my mind about exactly what “on the side or shoulder of a highway” means… note that there’s no requirement to use a sidewalk whether or not one is available. It also seems to me that direction of travel is not specified which seems like a major omission in the law* — it seems unlikely a robot operator would intentionally go counter-flow… this would be a big problem as that would place ‘bots in a head-on collision course with bicyclists.

This all gets slightly weirder if you consider a road without sidewalks, since 28-1224 makes the ‘bots equivalent to a pedestrian. Peds are required to travel counter-flow on roads with no sidewalks.

*Drivers (and bicyclists) are required to go only in the direction of traffic; details here. Furthermore, some cities (Tempe) have a rule for a variety of devices, including bikes, when ridden on sidewalks must be ridden only in the direction of adjacent traffic. This rule would not apply to the delivery ‘bots.

In any event, it’s interesting and curious that the-powers-that-be cast these devices as pedestrian-rules rather than driver-rules.

Robot Discrimination

There are also a variety of laws applying to the robot that are often, wrongly, thought to apply to bicyclists. I presume that’s because it’s okay to discriminate against a robot; whereas it’s not okay to discriminate against a person, say a bicyclist. The robots must “Yield to or not obstruct the right-of-way of all other traffic”, there is no such responsibility on bicyclists; for people using the road it’s all about safety, bicyclists sometimes, for example, be going slower than other traffic in a normal (normal is narrow) travel lane; yet the bicyclist has no duty to get out of the way (with a caveat for the 2 lane road / 5 or more impeding rule that applies to all road users). See here for Arizona’s frequently misconstrued Far To the Right law.; or here for why bicyclists cannot be cited for impeding.

Legislature Hearings

I went back and watched the committee hearings for both the 2018, and 2020 law. (gripe: in the olden days, someone wrote up detailed minutes of hearings; now we have to spend a lot of time and watch/listen to an hour or more of videos to get the info. It’s better and worse at the same time!)

2018: HB2422 / 53rd, 2nd regular. The bill’s prime sponsor was Kelly Townsend, a Republican representing Apache Junction area (eastern Phx metro area). The bill was heard in the House Transportation and Infrastructure Comm, where Rep. Townsend stated she saw the robots (they were Starship Technologies) at an NCSL (National Conf of State Legislators) convention in Boston the year prior and thought they would be good in Arizona. That whole deal was apparently driven by Starship Technologies… and some lobbyists and/or employees also spoke.

The Senate Transportation and Technology Comm. hearing went much the same. Rep. Townsend told the same origin story, and there was a speaker from Starship.

There were a few tweaks made and bill had to go into conference, in the end passed with large margins. The bill had a sunset (a “delayed repeal” in the jargon) provision of Aug 31, 2020.

The Starship Tech. went commercial notably at Arizona State University in 2020.(and I think also NAU). Just in time to catch the covid wave.

2020: SB1304 from 54R2, 54th / 2nd Regular session. Given that the 2018 law was sunsetting, there was some urgency to get it re-visited.

The prime sponsor is Senator David Livingston, a Republican representing Peoria (west Phx metro). Livingston was also a co-sponsor of the 2018 bill when he was a representative (Arizona has term limits and politicians tend to ping-pong between the house and senate — both he and Townsend were representatives in 2018 and in 2020 were both senators). Livingston also happens to be chairman of the Senate Transportation and Technology Comm, where it was heard…

Mostly Sen. Livingston emphasized the bill needed to get done because the 2018 law was sunsetting. Interestingly speakers this time did not include anyone from Starship, but rather Fedex who have a robot in development called Roxo (development was discontinued in 2022)

There were some questions about the min amount of liability insurance ($100K), that didn’t go anywhere in the Senate where it passed 29-0 (!), however by the time it got to the House there was a bit of noise, mostly seemingly coming from AZ League of Cities and Towns. By this time in early 2020, legal ramifications from the 2018 pedestrian death that involved an autonomous Uber were happening and Tempe was being sued for $10M. Ultimately the bill stood as is and just squeaked by in the House at 31-29. The bill’s backers all said we could “look at next year”.

Where does that leave us? As of this writing in 2025: I believe Starship is still operating (albeit possibly only on college campus? ASU, NAU, etc). Polar lab / Doordash Dot appears to be in development as noted above. Fedex’s Roxo as well as Amazon’s last mile robot both suspended development in 2022.

For Historical purposes; here is the now SUNSETTED 2018 law

A few points about the 2018 law:

• May, but are not required to be, autonomous
• Sidewalks use is permitted, and is primary by definition.
• Use in street permitted on 25mph posted roads.
• When operating on a sidewalk / crosswalk the device “has all of the rights and duties” of a pedestrian
• Speed is limited to 7mph (localities can allow higher but not lower limits)
• Is excluded from the def’n of  vehicle and of motor vehicle.
• The law automatically “sunsets” in Aug 2020, which seems like an oddly short amount of time given I don’t know if any of these devices actually exist yet.

Bike-law-watchers will recognize the language similarities to bicyclist regulation (“AFRAP”, “except by their nature”, etc), when riding on roads.

This is yet another vehicle that is “slow by nature” (along with bicycles, street sweeper, farm equipment, construction equipment, neighborhood elec vehicles, golf carts, busses, heavily loaded trucks, animal wagons, etc etc) that can and will impede other drivers/vehicles under normal conditions, and cannot be in violation.

I’ll put in one final plug; bike-law-watchers already know that state statute does not regulate sidewalk bicycling, leading to a tangled morass of local laws and Maxwell (an AZ State Supreme Court decision). I believe the most straightforward solution is to do the “all of the rights and duties” of peds when bicycling on the sidewalk/crosswalk — as was done with the pizza robot law.

HB2422 / 53rd, 2nd regular.  Here’s a direct link to the chaptered version, it’s very difficult to read; not sure why, probably because it went thru conf committee process(?). There was an Amazon lobbyist registered in favor.

28-101
49. "Personal delivery device" means an electronically powered device that:
(a) Is operated primarily on sidewalks and within crosswalks and that is designed to transport property.
(b) Weighs less than two hundred pounds, excluding cargo, unless otherwise authorized by a local authority pursuant to section 28-627.
(c) Operates at a maximum speed of seven miles per hour, unless otherwise authorized by a local authority pursuant to section 28-627.
(d) Is equipped with technology to allow for the operation of the device with or without the active control or monitoring of a natural person.
(e) Is equipped with a braking system that when active or engaged enables the personal delivery device to come to a controlled stop.

41. "Motor vehicle":
...(b) Does not include a personal delivery device, a motorized wheelchair, an electric personal assistive mobility device, an electric bicycle or a motorized skateboard. For the purposes of this subdivision...

71. "Vehicle":
(a) Means a device in, on or by which a person or property is or may be transported or drawn on a public highway.
(b) Does not include:
(i) Electric bicycles and devices moved by human power.
(ii) Devices used exclusively on stationary rails or tracks.
(iii) Personal delivery devices.

28-913. Personal delivery devices; operation; insurance
A. A personal delivery device may operate on a sidewalk, within a marked crosswalk or within an unmarked crosswalk at an intersection and on roadways in this state with a posted speed limit of no greater than twenty-five miles per hour operated as far to the right as practicable. A personal delivery device has all of the rights and duties that are contained in this chapter and chapter 5 of this title and that are applicable to pedestrians except those provisions that by their nature can have no application.
B. A person who owns and operates a personal delivery device in this state must maintain an insurance policy that provides general liability coverage of at least one hundred thousand dollars for damages arising from the operations of the personal delivery device under the person's control unless otherwise authorized by a local authority pursuant to section 28-627.

Service Begins

According to this arstechnica article; actual deliveries in a full-blown personal delivery vehicle began in Dec 2018 at one Fry’s (Kroger) grocery in Scottsdale.