[SystemSafety] Review of the legislative and regulatory framework for testing driverless cars

[Martin Lloyd]

Dear Colleagues

The UK IET (Institute of Engineering Technology) is inviting 
contributions to a submission on this matter, as shown below.  It is 
very disappointing that I only received this notice yesterday. However, 
despite the lack of time perhaps individual members of this list could 
make a response. I am particularly exercised by the software 
implications of driverless cars and the standards that should be applied 
to them.


*_Review of the legislative and regulatory framework for testing 
driverless cars
_*

In the Autumn Statement 2013, the Government announced its plan to 
review the legislative and regulatory framework for developing and 
testing driverless cars in the UK, reporting by the end of 2014.

The Department for Transport is interested in comments on any regulatory 
or other issues that may need to be addressed in considering the testing 
of cars with advanced autonomous safety systems on public roads, and the 
areas where new regulation may be necessary in order to maintain road 
safety and provide the appropriate safeguards in the introduction of 
this novel technology.

The DfT are interested in hearing views on the below questions;

  * Q1. Should any special training/testing or a minimum number of years
    of driving experience be specified for drivers involved in testing
    driverless cars with high automation?
  * Q2. Should a second person be required to be present, as an observer?
  * Q3. Do you believe that the normal set of requirements for driver
    behaviour should still apply or are any exemptions from these
    required, if so please specify?
  * Q4. Are any new requirements or constraints necessary?
  * Q5 Do you have any suggestions for an indication to other road users
    that the vehicle is operating autonomously, or capable of autonomous
    operation? For example, a warning signal showing autonomous
    operation or a distinguishing sign (different number plate, sticker
    on windscreen, etc.) indicating the potential capability of
    autonomous operation?
  * Q6. Should educational materials be developed to advise other road
    users about the testing of highly autonomous cars?
  * Q7. Do you have any observations on the possible reactions of other
    road users, or the risks of interaction with driverless cars, and
    possible mitigation measures?
  * Q8. Do you see any difficulties with the existing product liability
    regime, when operating driverless cars with high automation?
  * Q9. Do you have any suggestions for standards to regulate the
    testing of prototype cars with high automation?
  * Q10. Are there current type approval or construction rules that
    prototype cars with high automation might not comply with?
  * Q11. Are you able to suggest any specific areas (e.g. braking,
    steering) or any specific systems/technologies (e.g. ABS, ESC) where
    regulation needs to be amended or developed, as a priority ?
  * Q12. Are any changes to the current roadworthiness regime required
    to permit the testing of driverless cars, or ensure their safety?
  * Q13. Have you any initial thoughts about any longer term risks and
    issues as driverless cars age, and possible requirements to address
    this?
  * Q14. Cars with high automation would need to be registered. In due
    course, decisions would be required as to the level of taxation and
    whether the capability for autonomous operation would be recorded on
    the DVLA database, in order to provide data on uptake, but that
    seems to be outside the scope of this initial review. Do you have
    any comments on this approach?
  * Q15. Do you anticipate a need for special infrastructure to permit
    the testing of cars with high automation?
  * Q16. What issues would need to be addressed, to enable insurers to
    offer suitable insurance products?
  * Q17. Are there other insurance-related issues which may affect the
    introduction and testing of driverless cars?
  * Q18. Do you have any suggestions or concerns over data collection
    and privacy, when considering the testing of cars with high automation?
  * Q19 Do you (a) support amending diverse current regulations to cater
    for driverless cars alongside conventional ones, or (b) support
    creating a special regime via specific regulations to permit the
    testing of driverless cars under certain circumstances or
    constraints? (Or does it not matter as long as the regulations are
    appropriate and clear?)
  * Q20 Do you have any other comments on the need for a special regime
    to cover the testing of driverless cars with high automation? Do you
    consider any other regulations or aspects of driving practice would
    pose a barrier, or do you consider that extra conditions would need
    to be imposed? Please give full details.

The Institution of Engineering and Technology Trustees propose 
submitting a response to this consultation 
<http://email.ietinfo.org/c/13LOxnHzRgD0p5dfrbwKjtnu> and invite 
comments from Members who have expertise in this area and have studied 
the consultation documents. In its capacity as a professional body the 
IET will confine itself to only addressing those questions that are 
within its area(s) of competence.

Members contributing are asked to state their relevant experience.All 
inputs will be treated confidentially in the production of a corporate 
view and individual contributors will not be named. “Member” should be 
interpreted as IET Technician Members, Members and Fellows.

For more information and a summary of the questions, please refer to the 
consultation document 
<http://email.ietinfo.org/c/13LOxzdValXfghjpdhEdpIjr>.

The deadline for response to this consultation is the *_01 September 
2014_*. Please send your responses to Sahar Danesh 
<mailto:sdanesh at theiet.org>.

Full details located here 
<http://email.ietinfo.org/c/13LOxWgBMwBIYFvILtT9Ccbl>.

For more information and other submissions, please visit our website 
<http://email.ietinfo.org/c/13LOy7MX5BVXPRBSxA0CIr7i>.

IET Policy

Michael Faraday House,
Six Hills Way,
Stevenage,
Hertfordshire,
SG1 2AY

-- 
Kind regards

Martin Lloyd


===========================
Dr M H Lloyd CEng FIET
martin.farside at btinternet.com

Tel: +44(0)118 941 2728
Mobile: +44(0)786 697 6840

www.farsideresearch.co.uk
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