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? Any corporate presence and this organisations most senior management must be subject to the full force of Australian law. Option 3 will mean this is not met.

How would a requirement for the corporation to be an Australian registered company impact business models of potential ADSEs? It would mean it would need to follow Australian law and not as easily direct profits overseas.

How suitable are the matters we propose to include in an ADSE’s safety management system? Should other matters be considered? Concerns over privacy are not addressed adequately. Need to ensure data is not sold to insurance companies and other entities without the owner's permission. Interaction with current assistive technology for people with a disability that drive.

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? yes

Are there other modifications that should be considered significant? Is there other information an ADSE should provide when seeking authorisation for a significant modification? Interaction with current assistive technology for people with a disability that drive.

What are your views on the proposed additional AVSL measures to manage the safety risks of repairs, maintenance and modifications? How will you ensure appropriate interaction with current assistive technology for people with a disability that drive.

For how long should ADSEs be required to retain data? Should there be different periods for different types of information? 7 years

Are there risks associated with information management that are not covered in these proposals? Privacy for consumers.

What are your views on the proposed additional AVSL measures to manage the safety risks of remote operation of a vehicle with an ADS? Impacts on people living with disability. Accessibility of the technology.

Should an ADSE be required to ensure certain technical information is provided to consumers to inform purchasing decisions? yes particularly around how data is used, carbon footprint, integration with assistive technology.

Should the AVSL include offences in relation to misrepresenting vehicle capabilities? Yes

Are there other measures needed to address consumer risks? Integration with assistive technology.

What are your views on the options identified for human user obligations in vehicles with higher levels of driving automation? Yes

Do you support third-party interference offences being included in both the AVSL and state and territory law? Yes

Do you support the proposed automated vehicle regulatory framework as a whole, and are there any barriers to its implementation? Yes - more consideration needs to be given to drivers/passengers with disability.

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? Laws must be in place first.

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

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? Limited consideration for disability or drivers with a disability and the integration of ADS with assistive technology. Vehicles must be built with this in mind to ensure there is not a significant cost burden for a person driving with assistive technology. This is already a problem with hybrid vehicles.