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Submissions for NTC Discussion Paper - Clarifying control of automated vehicles - April 2017

Poida Santh

19 Apr 2017

Do you agree with the assumptions and objectives underpinning the NTC’s work to develop national enforcement guidelines? If not, what other assumptions or objectives should be considered?

Do you agree that national enforcement guidelines should clarify issues of 'control' and 'proper control' based on SAE International Standard J3016 Levels of Driving Automation? If not, what other approach should be considered?

For the purposes of enforcing 'proper control', is there value in grouping levels of driving automation according to whether vehicles are capable of automated operation?

Do you agree that the human driver should remain in control of a vehicle with partial or conditional automation, and that the automated driving system should be in control of a vehicle operating at high or full automation? If not, why?

I think you should also consider the load on the vehicle/truck.

I believe there should be a legal requirement for a human occupant (driver) capable of taking control if required for the following types of vehicles:

◦vehicles carrying Oversize or Overmass loads

◦vehicles carrying dangerous goods (when such goods are being carried. Who will respond in an emergency if no driver?)

◦buses (while carrying passengers where the vehicle is equipped to carry more than 12 adults including the driver)

In the event that the automated driving system is determined to be in control of a vehicle operating with conditional automation, should road traffic laws introduce obligations on the human driver as supervisor of the automated driving system?

Do you agree with the suggested indicators of proper control for each level of driving automation (outlined in Table 2 on page 34 of this paper)? Are there any other indicators that should be included in the guidelines?

Should special consideration be given to automated parking functions that are partially automated and can only operate without the driver holding the steering wheel?

Should the national enforcement guidelines also clarify the application of due care and attention offences to automated vehicles? If so, what behaviours usually penalised under these offences require clarification when applied to automated vehicles?

Do you agree that the guidelines should not apply the 'proper control' test to the automated driving system until the automated driving system and automated driving system entity are recognised in legislation? If not, what alternative approach should be considered?

Do you agree that the guidelines should only specify enforcement agency interaction with automated vehicles once the technology capability of automated vehicles is more developed and enforcement practices implemented in overseas jurisdictions? If not, what alternative approach should be considered?

Please provide any additional comments below.

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