TPS has submitted a response to the first consultation (during a 3-year review) by the Law Commission and the Scottish Law Commission on the Legal Regulation of Automated Road Vehicles (ARV’s).  A summary of all responses received is available at https://www.lawcom.gov.uk/project/automated-vehicles/.

Drawing on the wide experience of our members in traffic and highway planning over many decades, we focused on a wide range of practical issues relating to the operation of ARV’s on the existing road system, highlighting risks and limitations.

We were one of 178 respondents. Many of our views were echoed by others and subsumed into general summaries but 12 of our responses were cited individually.

Individual Citations

We were cited for a variety of views including :

• concern that there has been no independent research into the impact of ARV’s on the amount of private vehicle use (and harmful emissions) and the impact on public transport use
• there will be public and political demands for third-party involvement in testing of ARV systems, given the motor industry’s current low credibility in this respect
• support for a single safety assurance body for ARV’s, in which knowledge and experience can be accumulated
• if special training is needed to drive ARV’s, it should me mandatory for all and not undertaken to suit the financial whims of individual insurance companies
• support for a Regulatory Body wherein specialist expertise can be developed
• the need for a clearly nominated “user-in-charge” if the driving mode requires such oversight but the “user-in-charge” is not actually controlling the vehicle at all times
• the risks of a “user-in-charge” not obeying the instructions of a Police Officer if the ARV system had not requested them to resume control
• the risks of ARV’s not detecting road signs obscured by tall vehicles
• the challenge of producing a digital highway code based on determinate rules, when current driving practice relies on judgement.
• an ethics code to be imposed on the industry rather than the ethics policies of individual manufacturers being relied upon
• the limitations of ARV’s need to be clearly understood by users so that they are fully aware of any circumstances in which the system should not be used

Transport Planning Society Policy Group Member, Tim Morton, commented : “Despite all the hype surrounding ARV’s, there are many practical issues that need to be addressed and risks to be mitigated. We are delighted to help the debate along to ensure that ARV’s, when they are introduced, play a safe and effective role in our transport system.”