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Call for Evidence: Safe use of Automated Lane Keeping System on Great British Motorways

This act requires that the vehicle is capable of safely and lawfully driving itself without being controlled and without needing to be monitored when it automated mode.

ALKS is vehicle technology designed to control the lateral, left and right, and longitudinal, forward and back, movement of the vehicle for an extended period without further driver command. During such times, the system is in primary control of the vehicle, and performs the driving task instead of the driver, at low speeds on motorways.

The IET will respond to various issues within the consultation.

The IET aims to answer the following questions:

  • Do you foresee any legal barriers to accessing data for incident investigation?
  • If yes, what are those barriers?
  • How do you think the driver should be educated and informed to understand the abilities and limitations of the system to ensure they use it safely?
  • What role do you think manufacturers selling this system should play in providing this education and information?
  • What role do you think Government and its agencies should play in providing this education and information?
  • Subject to the outcome of this call for evidence and subsequent consultation, would you have concerns about a scenario where any vehicle approved to the ALKS regulation would be automatically considered to be an automated vehicle under AEVA?
  • If yes, what are those concerns?
  • How do you think ALKS will detect and respond to the police or other enforcement vehicle approaching from behind signalling for the vehicle to pull over?
  • Do you think that 10 seconds is fast enough in the foreseeable circumstances to comply with the rules on responding to enforcement vehicles? If not, why?
  • How will ALKS detect a minor or low-energy collision, in order to come to a stop and alert the driver?
  • Do you foresee any risks should ALKS vehicles not stop for low-energy impacts?
  • If yes, what are these risks?
  • How will manufacturers ensure that ALKS vehicles deployed in Great Britain are able to recognise signage located above the road that may be unique to Great Britain?
  • Do manufacturers intend to offer automation as an optional package for customers at the point of purchase? Please provide details.
  • Do you have concerns about vehicles that are registered as AVs on the DVLA database but the keeper has chosen to have the functionality disabled so they are not capable of operating as an AV?
  • If yes, what are they?
  • Do you agree that amending Rule 150 is sufficient to clarify that the driver may rely on the ALKS? If not, why?
  • Do you agree that not changing the Motorway Traffic Regulations, except for unjustified stops, ensures the driver is suitably incentivised to take back control when requested? If not, why?
  • Do you agree that the Highway Code should be changed so that drivers of ALKS must be alert to a transition demand? If not, why?
  • Do you think that amending the Highway Code is sufficient to communicate to drivers their responsibility? Why?
  • Do you think the driver should be allowed to perform other activities when ALKS is activated if they must only be ready to respond to a transition demand, with particular reference to any implications for road safety? If not, why?
  • What other activities do you think are safe when the ALKS is activated?
  • Do you think that the driver should be allowed to undertake other activities if ALKS is not listed under AEVA? If not, why?
  • If yes, what other activities could they safely perform?
  • Do you agree that an exception should be added to enable the use of the infotainment system for activities other than driving? If not, why?
  • Are there any activities you consider unsafe to perform through the infotainment system?
  • If yes, what are they?
  • Do you agree with this approach? Why?
  • Do you have any other comments you'd like to make?

The Institution of Engineering and Technology Trustees propose submitting a response to this consultation 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.

For more information and a summary of the questions, please refer to the consultation webpage.

Please respond no later than 9 am 20/10/20 to Paloma Cid, with “Call for Evidence: Safe use of Automated Lane Keeping System on Great British Motorways” in the subject line.