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? Australia is currently behind when it comes to automated vehicles use. The tests have proved that automated vehicles are safer that normal drivers.

How would a requirement for the corporation to be an Australian registered company impact business models of potential ADSEs? I don’t believe that will have any impact, and we do need the company to be registered in Australia to make sure we can uphold our laws and responsibilities

How suitable are the matters we propose to include in an ADSE’s safety management system? Should other matters be considered? Very suitable

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? No

What are your views on the proposed additional AVSL measures to manage the safety risks of repairs, maintenance and modifications? We do need additional regulations, that hardware and software required to automate driving will need certain level of engineering education to be able to diagnose any problem.

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 less than 1 year to evaluate decision making.

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

Should an ADSE be required to ensure certain technical information is provided to consumers to inform purchasing decisions? Yes

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

Are there other measures needed to address consumer risks? No

What are your views on the options identified for human user obligations in vehicles with higher levels of driving automation? Licensing should remain as is. Automation will take years and drivers needs to know how to control and react to different situations that might arise until we have 100 percent automation

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, no barriers

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 measures, for now the driver should still be responsible accepting the risk of automated driving and keeping attention on the road

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? No

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? We should allow the beta testing of automated driving by allowing companies like Tesla to sell the FSD capabilities. Given the high cost of the service and also the user interest the amount of users will be small enough to keep it safe but big enough to gather significant data