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

The benefits include that the corporation (ADSE) can be held accountable to Australian law which gives consumers of these vehicles comfort in terms of safety compliance and quality. From a corporation's point of view, the drawback for them would be that they need to set up a presence locally in Australia in at least one state and that will come at a cost and no doubt be passed on in the sale price of their automated vehicles.
All ADSEs wishing to promote and sell their automated vehicles in Australia will as mentioned above need to meet all Australian Laws including Consumer Law obligations and ensure their business models make allowances for required local infrastructure to monitor the ongoing performance of the ADS for their lifetime. They will also need to ensure they comply with the Automated Vehicle Safety Laws once developed and put in place.
The areas to be addressed in an ASDE Safety Management System are all suitable and well thought out. My only suggestion would be to have the AVSL set all ADSEs with a minimum review term for their Safety Systems which could be a minimum of every 2 years by an external independent auditor like NHVR and a minimum of annually by their own in-house Safety and Compliance officers.
In NSW all vehicles after 3 years I think it must undergo an annual vehicle inspection to ensure they are roadworthy. Part of this process must be to identify if an ADS is fitted to the vehicle, and it must also be assessed as part of the annual inspection as in compliance. In other states such as QLD for example, their vehicles don't have to undergo an annual inspection. I think this will need to change so that we can ensure all vehicles are roadworthy and none are fitted with unauthorised ADSs.
The document states at this stage it is proposed that an ADSE or authorised person by an ADSE can make minor modifications without further approval from a regulator and only significant modifications must be authorised. I think this area needs to be tightened up so that all modifications must be authorised by a regulator or authorised agent of the regulator as what someone might think is minor is not minor to others, especially if the minor modification goes wrong and leads to a fatality.

We also think there should be some pre-approved or predefined minor modifications to help cut down red tape.
a. Are the risks arising from repairs to an ADS different enough from the risks arising from
repairs to a conventional vehicle to require additional regulatory measures? Yes, I believe they are as we are talking about modifications to a vehicle that would potentially if a level 4 or 5 not have anyone sitting in the driver seat to assist if something went wrong with the vehicle operationally. I believe all modifications must be inspected by an authorised representative of the AVSL or State regulators before the vehicle being able to be used on the road after a modification is completed.
b. Is express authorisation of repairers, maintainers, and modifiers a suitable approach to
manage the risks of unqualified parties working on an ADS? Yes, but we still need their workmanship to be assessed before releasing the vehicle back on the road are any modification or repair has been done. We need to be on the side of caution and humans completing the modifications or repairs can make errors in the process. We need a quality checking process to be implemented.
c. What is an appropriate balance between the level of control or discretion an ADSE has
over who it authorises to work on its ADSs, and the level of responsibility placed on either
the ADSE or the repairer, maintainer, or modifier doing that work?
An ADSE should establish the minimum standards that any potential modification or repairer organisation for their ADS must meet to ensure their level of workmanship and compliance is met. It is good that the ADSE is responsible for the ADS for its entire lifespan as it will avoid a sell and forget attitude when selling their vehicles. More companies these days are offering a 3 or 5 years service cost inclusion on new car sales. This might need to become the norm for the entirety of the vehicle or be at least expanded to possibly 10 years with the ADSE providing purchasers the details of their local authorised service agents and then the service agents seek his reimbursement for costs from the ADSE. The ADSE and its authorised repairers are all in the chain and all need to understand the importance of them completing all works and thoroughly testing for safety purposes prior to handing it back to the owner of the vehicle fitted with the ADS.
d. Should the AVSL require that an ADSE does not unreasonably withhold authorisation, and that it share necessary information? For what reasons should an ADSE reasonably be allowed to withhold authorisation? 
Yes, an ADSE should not unreasonably withhold authorisation as long as their certification standards can be met. The only reason for non approval should be due to the proposed repairer/modification organistion having a proven poor safety performance or having been known to have breached the ADSE minimum requirements previously.
e. Should the AVSL include safety duties for repairers, maintainers, and modifiers of ADSs? 
Yes, 100% as the bottom line is that the AVSL will be holding the ADSE liable for the safety of all its ADSs for their entire lifespan.
If so, how suitable are the proposed elements of the safety duty on repairers, maintainers
and modifiers?
They are suitable but consideration should be given to an independent authority being required to inspect all or as a minimum at random ( frequency to be agreed by regulator and industry bodies) a number of modifications and repairs to ensure the quality and safety of the workmanship.
f. How may the proposed additional measures for repairs, maintenance, and modifications
affect business models for both ADSEs and repairers, maintainers, and modifiers?
The more checks we put in place or the inclusion of external requirements the added costs to the ongoing servicing of all ADSs.
 
Potentially you could look at all ADSEs having a regulated pool of monies to offer consumers a vehicle buyback program option that would decrease the potential exposure to the ADSE as the vehicle aged.
As with most legal regulations, 7 years could be the min requirement.
What is being proposed looks sufficient.
a. How are companies using or planning to use remote operations as part of ADS
deployment, and what business models are likely to be used? Which parties will have an
influence on the safety of remote operation?
Not aware of companies that are using remote automated vehicles other than in Mining at present but thoughts are they could be used for human transport via buses and taxis, distribution of freight from place of production to distribution sites. Could also be used in other industries requiring Heavy Vehicle drivers as there is a shortage of good drivers. Regulators such as Police, NHVR and SafeWork , Unions and employers will all have an influence on the safety of remote operations.
b. Do you agree with the proposed scope of remote operations to be managed under the
AVSL, and if not, which forms of remote management do you consider should be managed
under the AVSL? 
Yes, I agree it needs to be managed under the proposed AVSL, so we have a national regulator and national standards to comply with

c. Should an ADSE have responsibility for the safety remote operation performed to support its ADS? Should we consider other models for allocation of safety responsibility for remote operation?
Yes, I believe it is a good thing if the ADSE remains responsible for the safe remote operation of their product for its entire lifespan. 
d. What duties should be placed on an ADSE or on other entities for remote operations?
Regular review of performance from both a usage, safety and maintenance aspect, ensuring sufficient training is given to those monitoring the ADS and inclusion of highlighting their role in the Chain of Responsibility and potential penalties for negligent breaches, sufficient training including awareness of all associated risks to be given to consumers. These are a minimum requirement. Auditing of any approved repairers or modification organizations

e. Should remote operators be subject to a safety duty, or any other requirements, under the AVSL?
100% as they have the control of the vehicle.
f. What specific skills or proficiencies should be required of remote operators?
They need to be trained in the safe operation of the ADS and understand the associated risks and potential repercussions should their actions or lack thereof result in a serious incident.
g. Should the AVSL require that remote operations centres be located in Australia? What
are the advantages and disadvantages of this?
Yes, as highlighted in the reading material this is a big plus as it greatly assists if they have an understanding of local road rules. I would also suggest that consideration be given that they are represented in each state so they are familiar with local roads and conditions.
 
Yes, this is important as they will be making a considerable investment in their purchase. They should also be told upfront what the after-sales service they should expect including the proposed lifespan that the ADS will be monitored for and after that time it will be disabled
Yes.
Consumers need to know clearly what they are accountable for. This could mean the ADSE needs to give every purchaser of an ADS vehicle a risk assessment based on their purchase, training on the do's and don'ts, and be assessed on the training so we get sign off that they understand the training. Need to ensure that they also accept that any liability would be null and void should they use an unauthorised vehicle repairer for their ADS
a. Which types of vehicle control and seating configurations are being considered or
developed by the industry for vehicles with highly or fully automated driving features? Can
vehicle control/seating design help to determine the obligations of users of these vehicles?
Yes, vehicle control/seating design can assist in determining the obligations and also limitations of what a passenger of a highly or fully automated vehicle can do. Technology is great, however even in a fully ADS system I think it would be wise to still have the requirement for a suitably licensed driver sitting in the driver's seat as per suggested Option 1. This will allow the ADS fails for the driver to manually take control of the vehicle and continue their journey safely.
b. In vehicles with higher levels of driving automation that are configured with manual driving controls, should there be specific requirements about seating position when the ADS is engaged? Do you support any of the options identified, or propose any other options? 
We would support Option 1. That is there must be a suitably qualified, skilled, and licensed person for the vehicle type being driven sitting in the driver's seat at all times. SAFETY must come first. Driver a vehicle is a skill that can't be taken lightly as you need to be aware of your surroundings at all times and have the time to react to prevent serious incidents from occurring. Having a backup or no backup (unlicensed driver) sitting in a passenger seat or the rear of the vehicle will cause delays if manual intervention is required to avoid an incident.
c. How should licensing requirements apply to users of vehicles with highly and fully
automated driving features with accessible manual controls? Do you support any of the
options identified, a combination of options, or propose any other options?
Option 1 with a licensed person sitting in the driver's seat at all times is the preferred preference to attempt to eliminate the risk of serious incidents in cases of ADS failure or disengaging occurring. SAFETY first. This especially is the case for all commercial vehicles that could be carrying full loads. The commercial vehicles, when fully loaded, are harder to pull up and require a skilled licensed driver, especially with adverse weather conditions, to maintain control and avoid serious damage or injury to third parties. The first rule of Risk Assessments is to try and eliminate the risk. A driver in the driver's seat will greatly reduce the risk at all times.
d. How should drug and alcohol restrictions apply to users of vehicles with highly and fully
automated driving features? Do you support any of the options identified, a combination of
options, or propose any other options? 
Preference is Option 3. If there is a risk that an ADS-fitted vehicle could cease to operate and to avoid the passengers being stranded in a vehicle remotely, there should be a suitably licensed and fit-for-driving driver in the driver's seat at all times. Having a passenger under the influence of drugs or alcohol could result in that person making a poor decision and trying to take control of the vehicle.

e. Do you think there should be a requirement to always have a person capable of driving
and traveling in a vehicle with highly or fully automated features? Why or why not?
Yes, purely for safety reasons, I believe this should be the case. The person should be a capable, skilled, and licensed driver for the class of vehicle they are within. We see in the documentation reference to the ADS potentially disengaging, being limited to the areas it can operate, etc. Should the ADS cease to operate you need a qualified driver not under the influence of Drugs or Alcohol in the vehicle to ensure the passengers and third parties are safe at all times.
f. Do you support permitting a person seated in the driving position in vehicles with highly or fully automated driving features to undertake secondary activities? Do you support any of the options identified, a combination of options, or propose any other options? 
No. We support Option 2 because as per the example mentioned in the documentation, the ADS could give the person sitting in the driver's seat an alert that the ADS is approaching the end of its operational design and therefore needs a response from the person in the driver's seat that could be delayed if they are distracted by performing secondary activities. The person should remain alert and aware of the surrounding environment at all times.
g. How should non-dynamic driving task obligations be assigned or shared in vehicles with highly and fully automated driving features? Do you agree with our analysis? 
Yes, I agree with your analysis of the Rules mentioned in the tables.
 
Yes 100%, especially if it relates to an incident occurring.
Yes, I support the proposed framework with the AVSL being in place and the clear understanding from the ADSE that they are responsible for their ADS's for their entire lifespan.
Yes, measures are required to be implemented to restrict the usage of automated vehicles in Australia on public roads before a regulatory framework is in place. As stated in the documentation limited usage should be allowed under a controlled environment for testing purposes. It could be that a suitable region outside a Capital city or a smaller Capital city like Adelaide or Perth for example could be used for initial trials as they may provide a level of traffic suitable for a trial at lower risk than a Sydney or Melbourne for example.
Yes, restrictions should be in place and potential fines legislated, if possible, for any driver found to be driving a vehicle fitted with an unauthorised installation before the automated regulatory framework being in place. To assist in the identification of early installations and use, all states should ensure those organisations authorised to perform annual vehicle roadworthy inspections are educated to look out for these ADS vehicles and to report details of the vehicles to their state regulators.
Barriers to large-scale trails include the safety of the public in the case of trials being considered in highly populated cities where traffic can sometimes become quite hectic. I believe that trials are an important part of the long-term safety of all if we are to introduce ADS vehicles within Australia. As suggested in response to question 18, we may benefit by restricting initial trials to smaller Capital cities like Perth or Adelaide, so we get a snapshot of performance at a slightly smaller scale. I believe that yes there needs to be an interim certification process for those potential ADSEs selling their ADS-fitted vehicles in the Australian marketplace.