Question 1 – Do you support the use of the Society of Automotive Engineers (SAE) International
Standard to classify automated road vehicle functions? Do you have any issues with using the SAE
International Standard?
Although the question does not identify which SAE standard is referred to, it is assumed from the
context of section 3 that the question refers to J3016. Yes, I support the use of SAE standard as the
commonly used by all practitioners. For example, SAE standards J2735 “DSRC Message Sets” or draft
J3067 for V2V and V2I communications. The second question implies that other alterative
standards may be considered. Have NTC identified these alternative standards? If so, then
the analysis of the issues and comparison with SAE J3016 may be required.
Question 2 – What do you think the regulatory role of governments should be to support
the introduction of automated vehicles in Australia?
Government should be engaged in regulation at various stages (section 4.3) to a various
extent (section 4.2). For example, governments need to provide regulatory support for trials
during current stage of “technology and implementation certainty”. Transition to next
stages of initial deployment and further market saturation would require different approach
to what and how to regulate. Ongoing process to assess international developments and
Australian conditions would be required to manage this.
1) This section provides very good structure of types of regulation, timeframes and
specific approaches in section 4.4. However, I believe there is lack of recognition that
L2-3 automation vs L4-5 automation would have a very different risk and liability
profile. The current (and future) US/EU development in this space would provide
some guidance for Australia.
2) The statement “Regulate the automated vehicle only, or regulate both the
automated vehicle and the broader automated vehicle operating system?” may
require clarification. Automated vehicles would be regulated through the ADR and
certification/registration (addressed in sections 6, 7). If Automated vehicle operating
system means the CITS Core system (refer Austroads CITS program), which is the
responsibility of the State Road Authorities (SRA) and is to be maintained by
Government or outsourced to authorised 3rd party. This system would support CITS
and in future automated vehicle operation including security management (PKI,
etc.), dynamic map updates and Core System attributes.
3) The other Role of the Government, in addition to being a regulator, is the road
network owner and manager (this is to some extent addressed later in analysis of
the liabilities). In this other role, the SRAs must develop road infrastructure to
support CITS and autonomous vehicles. This important role is missing in the paper.
Maybe it can be addressed in section 12 Other issues.
Question 3 – Have we identified the key issues relating to the Australian Road Rules and
state and territory road safety and traffic laws? Are there other issues that should be
assessed as part of the NTC review?
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NTC have identified the key issues. However, the issue analysis and discussion would differ
for automation L2-3 and L4-5 (refer Fig.4). It may be beneficial to have a staged approach,
i.e. focus on issues when “the human driver is in control” and then progress to full
automation. It would beneficial to monitor and actively participate in overseas projects and
developments (NHTSA, EU, etc.).
Question 4 – Have we identified the key issues relating to the Australian Design Rules and
other vehicle standards? Are there other issues that should be assessed as part of the NTC
review?
NTC have identified the key issues. The following comments are offered for NTC
consideration:
1) Page 32. “security standards for automated vehicle systems could be included in the
design rules.” Suggest reinforcing the mandatory nature of these new requirements.
The data Exchange referred to in the table and the whole system (Automated
vehicles – Smart infrastructure) would only be possible in strict compliance with the
Standards and specifications including security (most likely using internationally
harmonised standards), managed by the government, and the ongoing certification
regime.
2) Page 33. 3rd bullet point. I don’t believe, self-certification for new or aftermarket
modifications would be acceptable due to high safety and other risks, even with
regulatory oversight and prequalification (vehicle crash is a critical safety issue and
CFC example is not really valid). Only government or appointed authorised third
party with associated controls should carry this task.
3) Issue 7. I do not believe ADR can capture the driving task and compliance with
various Australian Road Rules (ARR). The software implementing appropriate
“driving profile” would achieve the compliance with the specific ARR. ADR can
provide the specifications and assurance framework for the vehicle computer to be
able to generate and manage such driving profiles, but ADR cannot provide
assurance on how these scenarios are implemented to achieve ARR compliance.
Question 5 – Have we identified the key issues relating to heavy vehicles? Are there other issues
that should be assessed as part of the NTC review?
NTC have identified the key issues. For example, platooning may explore the potential
exemption scenario, when the safety and other risks are mitigated to achieve belter
outcome. This example would provide the methodology for ongoing revision of the road
rules and /or provision of exemptions.
Question 7 – Have we identified the key issues relating to privacy and access to data by
government agencies? Are there other issues that should be assessed as part of the NTC review?
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The privacy issues and concerns presented in section 9 will need to be clarified. As it is currently
described it appears as if all the “significant volumes of data , some of which will be very precise
location generated with GNSS technology and communicated with CITS to generate freely available
open data”. In fact all (not some) data must be very accurate and rich in order to operate safely and
cover numerous safe and efficiency application. However all this rich data will be ANONIMISED. Data
anonymisation is the key requirement for all the CITS communications protocols (DENM, etc.) and
specifications. None of the safety (collision avoidance), traffic management (probe vehicle data,
SPAT), environmental or asset condition feedback (potholes notification to the SRA) applications
require private or vehicle specific data. The user can opt in for other applications such as ETC
(Electronic Toll Collection) or parking access that require personal data for payment or other needs.
This area is well established and well described in clause 9.1. This scenario is also similar to Telco
managing the privacy issues when most people are having location services enabled as default on
their smart phone to use for various apps.
With this in mind, Issue 14 may be revisited. As currently written it implies that any CITS and
automated vehicle data exchange with the Government (or its agent) will have all the data listed
(seat occupancy, ID, medical history, etc.), which is not the case. The use of toll tags (which do have
private data embedded but that is not accessed by the Government system) for travel time purposes
has does not breach the privacy and surveyance devices acts according to recent the legal
assessments.
Question 8 – Have we identified the key issues relating to on-road trials of automated road
vehicles? Are there other issues that should be assessed as part of the NTC review?
NTC have identified the key issues, in particular the NTC intention to undertake a full review
of exemption powers in each state and territory is very important to facilitate CITS and AV
trials and to follow up on SA Bill. Following up on UK DfT and NHTSA developments is a good
start.
Question 10 – Are there additional issues or risks that should be considered in the NTC’s
assessment of regulatory barriers to more automated vehicles?
Additional issue of the Government’s role as the road network owner and manager and the
obligation to develop road infrastructure to support CITS and autonomous vehicles (see comment 3,
question 2 above).
General Feedback
1) Section 1 (and 1.4 in particular) discussed only Australian condition without any reference to
a large body of work internationally. Suggest addressing the monitoring and potentially
Australian participation in overseas projects and developments in USA (NHTSA, DoT, etc.)
and EU (POLIS and others) as a separate clause or at least within clause 1.5 “Strategic
context”. For example, international experience and trials can offer the path to
implementation in Australia (e.g. AON initiative and trial on Netherlands highway this March
http://safecarnews.com/netherlands-plans-50-platooning-vehicles-on-a2-motorwayfe7294).
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2) 1.6. Method. Currently proposed approach is to pose the question (very good questions
raised in the paper), provide Australian context (as has been done), but it would be
beneficial to provide examples of how it has been addressed (if it was) internationally. The
responses of industry, academia and government experts and overall project would benefit
if international experience and lessons learnt were provided as context. This has been
manifested by a number of Austroads and academic research projects that often start from
international literature and projects search.
3) 3.1 Fig.2 The paper regularly refers to CITS (V2V, V2I) – it would be beneficial to map CITS to
the applicable level of automation (L2-3).
1) P.18 Examples of partially automate driving. These examples prompted to raise an issue of
Drivers becoming over reliant on the technology, deskilling and lack of attention when
relying on the semi-automated system. NTC mentioned training and licensing in section 12.
Other issues, but this particular issue and associated risks may need further analysis.
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