Submission

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View the feedback we have received on the Automated vehicle safety reforms consultation paper.

What are the benefits and drawbacks of different corporate presence requirements? Clear terms of liability

How would a requirement for the corporation to be an Australian registered company impact business models of potential ADSEs? The approach should be inclusive of international corporations as these are likely to best equiped and with the best technology to deploy in Australia

How suitable are the matters we propose to include in an ADSE’s safety management system? Should other matters be considered? You should enable supervised ADS systems to be deployed in the short term to gather data in a safe and meaningful way.

Are there are other matters that the law enforcement and emergency services interaction protocol should account for? No

Do the certification procedures for aftermarket installations of an ADS adequately manage safety risks or should other matters be considered? Aftermarket installed systems are u likely to be of practical use I the near future. Autonomous vehicles should be build from the ground up as autonomous vehicles.

Are there other modifications that should be considered significant? Is there other information an ADSE should provide when seeking authorisation for a significant modification? The focus should be on demonstrated safety data, I.e. evidence of Km per disengagement or km per near miss or km per incident

What are your views on the proposed additional AVSL measures to manage the safety risks of repairs, maintenance and modifications? This goes back to my previous view on how autonomous vehicles should ve built from the ground up. This ensures the manufacture has responsibility to maintain the vehicle.

Are there measures we should consider to manage the consumer impacts of an ADS being disabled due to suspension, cancellation or surrender of certification? No

For how long should ADSEs be required to retain data? Should there be different periods for different types of information? No change to normal

Are there risks associated with information management that are not covered in these proposals? No

What are your views on the proposed additional AVSL measures to manage the safety risks of remote operation of a vehicle with an ADS? No comment, if remote operation is possible or required then it is not an autonomous vehicle.

Should an ADSE be required to ensure certain technical information is provided to consumers to inform purchasing decisions? Key statistics on safety

Should the AVSL include offences in relation to misrepresenting vehicle capabilities? Standardise the key metrics of performance and safety I.e. km driven per incident etc

Are there other measures needed to address consumer risks? No comment

What are your views on the options identified for human user obligations in vehicles with higher levels of driving automation? Yes the person in the drivers seat should be able to eat, sleep and watch a movie, subject to the licences of the vehicle. I.e. a level three system the driver should not be permitted to sleep, and must be able to take control within 10 seconds. Level 4-5 should be complete hands and attention free.

Do you support third-party interference offences being included in both the AVSL and state and territory law? Yes, you should not be allowed to deliberately interfere with an autonomous vehicle, although the rules should be no different to manually driven vehicles, which also should not be subjected to interference by third parties

Do you support the proposed automated vehicle regulatory framework as a whole, and are there any barriers to its implementation? Yes rapid deployment of supervised systems (ADS but level 2) for data collection is extremely important. Let providers gather data with someone in the drivers seat who is ready to take over as use it as a means to justify licence applications for level 3, 4 and 5.

Are measures needed to prevent vehicles with an active ADS from being provided to the market before the automated vehicle regulatory framework is in place? Which option or options is most suitable? No if it is subject strict supervision by a person with a drivers licence then full ADS systems should be able to operate as a level 2 system for data collect and for safety.

Is it necessary to restrict aftermarket installation of an ADS, activation of a disabled ADS, or use of an ADS to approved trials only, before the automated vehicle regulatory framework is in place? Yes aftermarket installations should be more strictly regulated and systems that are built from the ground up as autonomous vehicles

What are the barriers to more complex and large-scale trials in Australia? How could trial arrangements be improved? Should there be provision in the AVSL for interim certification to support trials? Yes interim certification for supervised self driving systems should be enabled immediately for data collection on local roads