Government pushes ahead with plan to list ALKS-equipped vehicles as self-driving.

Are you sure this is a good idea? Concern as UK Government pushes ahead with plan to list ALKS cars as self-driving

In May, the government’s Centre for Connected and Autonomous Vehicles (CCAV) announced a new £40m funding competition to “kick-start commercial self-driving services” in the UK.

Minister for Investment, Lord Grimstone, said: “Self-driving vehicles have the potential to revolutionise people’s lives, whether it’s by helping to better connect people who rely on public transport with jobs, local shops, and vital services, or by making it easier for those who have mobility issues to order and access services conveniently.”

The launch press release went on to quote the now familiar statistics that self-driving could be worth £42bn to the UK economy by 2035, potentially creating 38,000 new skilled jobs.

ALKS and self-driving

It also contained this eye-catching line: “The first vehicles to be listed as self-driving in the UK – vehicles approved under the Automated Lane Keeping System (ALKS) Regulation – could be available for people to purchase, lease or rent later this year.” Not everyone agrees with the approach or the timetable.

Matthew Avery, Director of Research at Thatcham, was quick to emphasise that there are currently no vehicles Type Approved for automated driving in the UK.

Matthew Avery of Thatcham on self-driving
Matthew Avery of Thatcham on self-driving

“We are signatories to the UN Type Approval mandate, so UK regulation will reflect the UN Type Approval requirements which come through Geneva,” he said. “Any vehicle that is Type Approved will also have to go through a GB approval process.

“It’s important to make sure, before a vehicle is added to the Secretary of State’s self-driving list, that it has been approved to be usable in the UK – that it can follow UK road laws, read UK road signs etc. The exact wording is being worked-up at the moment.

“There are a number of issues we feel are missed within the current UN regulation: 1) the ability of the vehicle to change lanes; 2) the ability of the vehicle to find safe harbour; and 3) the need for the vehicle to record data in every collision.

“However, amendments have been tabled to tackle these issues, which are likely to be signed-off in September and come in from January 2023. These include the ability to change lanes and find safe harbour, and also extend the speed range up to 81mph. These are all very sensible and meaningful additions which will improve usability.”

Insurers unconvinced

The picture is changing fast, but insurers aren’t yet convinced that ALKS-equipped vehicles should be described as self-driving.

Doug Jenkins, Motor Technical Risk Manager at AXA Insurance UK, said: “The government have set out the position – they want the UK to lead in this – but I am concerned that it could become confusing for the public when really autonomous vehicles come to the market.”

Indeed. Compare the headline-making Oxbotica AppliedEV – which in May became the first zero-occupancy, fully self-driving, electric vehicle to operate on public roads anywhere in Europe – with the new Mercedes S Class, BMW i7 or Volvo XC 90. They’re very different beasts.

Oxbotica self-driving vehicle

Interestingly, under the Scope section of the new funding competition, the government insists that “Terminology in your application must comply with the meanings as per BSI Flex 1890 v4.0:2022-03: Connected and automated vehicles – Vocabulary.”

Self-driving definition

Thanks to lead technical author Prof. Nick Reed, the recently updated BSI CAV Vocabulary features a handy new definition for self-driving: “Full function of the dynamic driving task (2.1.24), performed by the automated driving system (2.1.7) within its operational design domain (2.1.48)”.

Does ALKS meet the criteria? There are at least two big problems with the government’s current plan. First, as Jenkins alluded to, the conflation of assisted driving and self-driving risks drivers misunderstanding their car’s capabilities. That’s clearly dangerous.

Second, any approach which involves switching between a human driver and a highly automated car introduces the problematic moment of handover.

Dr Subhajit Basu, of The University of Leeds’ School of Law, has eloquently expressed the serious concerns shared by many experts.

“The main safety messages surround the extreme difficulty most drivers will encounter when an autonomous vehicle suddenly transfers the driving back to them,” he said. “Even if a driver responds quickly, they may not regain enough situational awareness to avoid an accident.”

Please note: a version of this article was first published by the Institute of the Motor Industry’s MotorPro magazine.

Since then, Mercedes-Benz has released details of the sales launch for Drive Pilot in Germany. The conditionally automated driving system can now be ordered as an optional extra for the S-Class for €5,000 and for the EQS for €7,430.

RAC Foundation director Steve Gooding, a member of the Centre for Connected and Autonomous Vehicles’ expert advisory board, talks Highway Code, ALKS and self-driving

Self-driving cars? Think like Parker from Thunderbirds advises RAC Foundation’s Gooding

In this exclusive interview with Cars of the Future, RAC Foundation director Steve Gooding brings much-needed pragmatism to the UK self-driving debate.

We contacted Gooding after he was quoted in the government statement setting out changes to the Highway Code to move Britain “closer to a self-driving revolution”. Yes, the one that triggered national media meltdown, including Clarkson’s memorable “Driverless cars are pointless – and they have built-in instructions to kill you” headline in The Sun.

Fortunately, Gooding is far more level-headed. Fully aware that strong winds of change are blowing through the motor industry, he meets the prospect of connected and automated mobility (CAM) with down to earth opinion based on solid experience.

Assisted or automated?

We started by asking him about the danger of people confusing assisted and automated driving, given his widely reported comment that the Highway Code changes “will help us all understand what we must and must not do as we move forward to an environment where cars drive themselves”. Here’s what he said…

“The guts of the matter are, if you’re in a vehicle that is so highly automated that you don’t need to be involved in controlling it – like you’re sitting on a train – then it shouldn’t be a problem. You can get your phone out and catch up on your emails, flip open your laptop and start to write the next great American novel, or you can fall asleep. None of those things particularly matter until you arrive at your destination. Hopefully you’ll wake up in time to get off at the right stop.

“There’s a direct parallel there with automated driving in a private car. The vehicle needs to be designed and the technology needs to work so that it gets to a place of genuine safety, ideally where you want to be and not some point in the far distance. My wife didn’t appreciate my call to suggest she came to pick me up at the far end of our railway line when I fell asleep after a long day in the office, nor would you want your highly automated car to trundle on past your motorway exit while you snoozed the miles away.

“I think there’s an issue here and I worry about the stance that the auto industry has taken on it; if you tell me the vehicle is driving itself, it better had be. We know that with the most advanced driver-assist technologies you might not be doing much of the driving task, but you are still in control with your hands on the wheel. But what if you’re only required to be able to retake control, and to be able to do so at a moment’s notice?

“I wouldn’t point the finger at any particular manufacturer, but I can think of one whose vehicles are able to sense whether you’ve been holding the steering wheel. But if you go to any of the social media video channels you can look at how some people have chosen to fool these systems. When the vehicle doesn’t even require that much interaction from the ‘driver’ then how distracted, bored or just plain fast asleep do you think drivers, particularly on long motorway trips, will be?

“We also need to get away from the mindset some people still have that the motorway is a racetrack, with 70mph (or more) as a target rather than a maximum speed. I’ve talked with lots of people who are great fans of the latest highly automated driver-assist systems, because they do long journeys and find it more relaxing to use adaptive cruise control and lane-assist to help them waft along comfortably somewhere between 60 and 70mph. The mindset is much more like being on a train, coach or bus. However much you might wish it would get a move on, it’s only going to go as fast as the driver judges to be safe, taking account of the speed at which other traffic is moving.

“Hence I draw a sharp distinction here – and we’re all going have to start getting our heads around it, no matter how sceptical some of us were in the first place – between advanced driver-assistance and genuine automation. It’s often described as a continuum but I think that in reality there’s a massive step-change. And it’s not just a change that affects the people who’ve opted in to the automated vehicle.

Self-driving mode

“Imagine, in the relatively near future you might be driving along a motorway and a car goes past you with the person in the driving seat apparently fast asleep or reading a broadsheet newspaper. You might think ‘What’s that idiot doing?’ and maybe sound your horn. You might think, ‘Good grief, there’s going to be a crash, I’d better call the police’. It’s a world that could happen relatively soon – the people in those vehicles aren’t being irresponsible, they’re just in cars that are driving themselves – but in the early days they are likely to be in quite a small minority.

“While some thought has been given to it I don’t think we’ve really got to the point of being able to say what, if any, indication there needs to be from the vehicle to other road users to indicate that it is operating in self-driving mode, maybe ‘Don’t panic, there is control here, this vehicle isn’t run away’. I think it’s probably sensible for the vehicle to give people some sign. That said, in slow moving city situations I’m conscious of the risk that automated vehicles might find it very hard to make progress if pedestrians all decide to take priority.

“If we went back two or three years I suspect we’d be having a conversation about crisis moments where the automated vehicle couldn’t cope. What I’ve been saying consistently is that the vehicle has to be designed to cope with crisis moments, because humans don’t snap back into control very well at no notice. My plea to the designers is for pity’s sake don’t make the human the failsafe – we’re arguably the weakest link in the drivetrain – and that just doesn’t feel safe to me.”

Highway Code changes

We then went on to talk about the (mis)interpretation of the Highway Code changes, with the implication that automated vehicles might literally be just around the corner.

Gooding’s view was that it is forgivable for people to get the wrong end of the stick (including the idea that propping a 42” widescreen TV on the dashboard would be OK to keep up to date with Love Island or Strictly while the car drives itself), but that this of itself doesn’t mean that the Department for Transport (DfT) should hold off trailing the changes that automation will bring. A long lead time should help ensure that people are prepared.

“The first incarnation of driverless technology that appears to be headed our way is the automated lane keeping system (ALKS),” he said. “That’s the technology that’s closest to market and closest to deployment in this country.

“ALKS is cleared at the United Nations Economic Commission for Europe (UN ECE) level for traffic moving at no more than 37mph. It enables the vehicle to speed up and slow down and stay within a defined lane on a motorway. The insurance industry has voiced concern about the fact that under this system the vehicle can’t change lanes. I think there’s some further head scratching going on at the DfT about that.

Genuine self-driving

“Of course ALKS is some way short of genuine self-driving – but one might imagine a button by which, in the same way that I could trigger adaptive cruise control whilst on a motorway, I could go one step further and trigger a system that would take me on to a certain junction, within the legal speed limit, anticipating the traffic ahead, steering and braking if necessary. How are we going to feel about that? My point is, let’s start that conversation now.

“Imagine you’re in a supermarket car park and someone has parked too close for you to open your door. Wouldn’t it be handy if you could summon the car? Indeed, if it was pouring with rain, wouldn’t it be good if you could just stay under the canopy and summon your car?

“Other shoppers struggling back to their cars with their shopping bags might be quite shocked to suddenly see a car coming towards them that appears to have nobody in it. It’s not science fiction anymore. We need to move the conversation on, to start gearing people up for the thought that this is going to happen, and soon.

“What if you summon your car from the far end of the car park but it never gets to you because there’s a constant stream of pedestrians in the way, or because children decide it’d be hilarious to stand in front it just to make it wait? How’s that to be handled? I think that’s one of the great imponderables for having automated systems in more built-up areas.

“I’m not convinced that I will be driven by a car in a UK city street. I hear a lot about the challenges of the urban environment in America, but jaywalking is illegal in the States. There are parts of this country where you’d assume jaywalking was a moral obligation! But by contrast I’ve long thought that I will be driven by a car on a motorway in my lifetime – within the next 20-30 years (with a bit of luck).”

The RAC Foundation’s role

Talk turned to the RAC Foundation’s role in all this.

“Probably the most important thing we’re doing is by virtue of the fact that I’m a member of the Centre for Connected and Autonomous Vehicles’ expert advisory board,” said Gooding. “It’s a very broad-ranging group of people who are genuinely world-leading experts in their fields, for whom the question is not just “What’s needed to make you safe?” but “What’s needed to make you feel safe?”, which is subtly different.

“One of the things we know from past studies of traffic is that you don’t have to get everybody on the road to drive more smoothly and safely. If you get a proportion to do so, it has a calming and beneficial effect on all the rest.

“I don’t like sideways G-forces when I’m being driven. I can think of no higher praise for an automated system that to compare it to the driving of my great cousin William, who was a professional chauffeur. He could do a three-point turn in a stretch limo and if you were sitting in the back holding a drink you wouldn’t spill a drop. That’s the standard of driving we want from an automated system – that of a highly proficient chauffeur, like Parker from Thunderbirds who’d have been mortified if his driving caused Lady Penelope to spill her champagne down her frock.”

Excellent, that’s the headline sorted.

He continued: “There are two issues with the Highway Code. One is that nobody expects to return to it after they pass their driving test. I passed mine before Margaret Thatcher became Prime Minister, and there’s been a lot of water under the bridge since then. The second issue is that changes to the Highway Code tend to come in fits and starts. In the last year, there have been a few really significant changes, first relating to the hierarchy of vulnerability and the way we should approach junctions, and now about highly automated technologies.

“Some of the work we’re doing at the RAC Foundation is about bringing such changes to people’s attention – informing them there’s been a change they ought to know about. Probably the best we can do in that regard is to get as much coverage in the mainstream and motoring media as we can. We need people to be saying to their friends: ‘Did you see the change to the Highway Code?’”

Personal car ownership

We were wrapping up now, but there was still time for Gooding to give a convincing, perhaps controversial, opinion on the future of personal car ownership.

“I see no evidence that mobility as a service (MAAS) is coming anytime soon,” he said. “The full-on version of MAAS requires a ‘ring-master’ – a system integrator – that is modally agnostic, and therefore able to offer you the full selection of travel options, prices and booking options. Such a system isn’t going to spring into existence all by itself. The nearest thing to it that I’ve seen so far is the Transport for London (TfL) website, and I don’t see TfL volunteering travel by private car as one of its options.

“Imagine you’re a car buyer looking in the £15,000 bracket. You’ve decided which model you want, which spec, which colour. Are you going to ditch all those bespoke choices and the convenience of knowing the vehicle is at your personal beck-and-call because you’re going to be able to summon a self-driving vehicle? With those, you won’t really care what it looks like, so long as it’s been cleaned since the last person travelled in it. I just feel we’re going to need an awful lot of self-driving vehicles and an awful lot of cleaning products for that future to be viable in the sort of street where I live.”

All that look less than half an hour. Amazing eh? Personally, I feel reassured knowing that Gooding has the ear of government. He’s a motoring man embracing self-driving, and he’ll help the UK get there more safely.