The BVRLA has submitted a response to a call for evidence from the Centre for Connected and Autonomous Vehicles on the safe use of Automated Lane Keeping Systems (ALKS) on GB motorways.
With the review by the Law Commission ongoing and with continued uncertainty in areas such as responsibility for driver education, liability, insurance and ownership/control of vehicle data, the association feels that the introduction of vehicles classed as autonomous is too soon and needs a more comprehensive review.
This mirrors the response given by insurers who have also warned this is too soon.
The association highlighted some concerns across three main areas:
- Driver education – it is imperative that drivers are informed about the abilities and limitations of the system to ensure it is used safely, however, where responsibility sits for educating drivers about autonomous features in vehicles is unclear. This needs to be given careful consideration across a range of different vehicle use cases and business models, including leasing, rental and car club.
- Automated vehicle definition/classification - the BVRLA is concerned that any vehicle approved to the ALKS regulation would be automatically considered to be an automated vehicle under the Automated and Electric Vehicles Act (AEVA). The association's main concerns relate to liability and where this sits if a rental or leased vehicle was involved in an accident or if it had a recall notice issued. Cyber security will also be of upmost importance and the regulation and liability behind new technologies needs to be addressed, as well as the ownership of data and members’ ability to access the in-vehicle data.
- Automation as an optional package - there is a question within the call for evidence that relates to manufacturers offering ALKS as an optional package. The BVRLA is keen to learn how manufacturers respond to this question and what the implications might be on how the vehicle is registered with the DVLA. Due to ongoing uncertainty about liability, members may want the ability to choose whether they opt in/out for ALKS. If they did opt out or had the ability to disable the ALKS, then this would need to be recognised by the DVLA. This would ensure the rental or leasing company choosing to disable the functionality would not be liable if the vehicle was then involved in an accident due to an automation fault.