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Submissions for NTC Discussion Paper - Changing driving laws to support automated vehicles - October 2017

Geoffrey Taylor

1 Dec 2017

As submissions closed yesterday, I guess that is why this topic is not listed for current online submissions.

October 17 to November 24 is not a lot of time for discussing such a fundamental change in road transport and putting in a submission. I am a pretty good reader of the news but didn’t see anything in the press from the federal minister responsible.

Principally my current submission is this. The holistic changes to law needed, involving eight parliaments, will not have occurred by 2020 as the timeline requires.

There are also considerable privacy and data security issues around the collection of road operations data to monitor ADS introduction once 2020 arrives.

Can I also refer to the second last sentence of this from the discussion paper:

“1.6.6 Control and proper control of a vehicle if an ADS is driving are not defined State and territory traffic laws generally define ‘drive’ in relation to control of the steering, and movement or propulsion of the vehicle. If the definition of driver is amended to include the ADS of a vehicle with conditional, high or full automation, the ADS would be considered to be in control when it is engaged because it performs the entire dynamic driving task. The Australian Road Rules require a driver to have proper control of the vehicle he or she is driving. There is no definition of proper control, although it is interpreted for enforcement purposes as being seated in the driver’s seat with one hand on the steering wheel. Proper control is designed to deal with human failings such as distraction and inattention and could be considered an irrelevant concept for a machine such as an ADS.

An ADS is either operating correctly and in compliance with road

traffic laws, or it is not. Chapter 5 discusses control and possible

changes to the proper control rule for an ADS at 5.3.5. “

What if it has a program fault, or develops a hardware or software fault? It is worth a look at IEC/AS 61508 in this respect.


Geoff Taylor