Memorandum submitted by The Intelligent
Transport Society for the United Kingdom
The Intelligent Transport Society for the United
Kingdom, known as ITS (UK), is pleased to provide comment on the
Report on the Vehicle Excise Duty 2006-07 Accounts. ITS (UK) is
a "not for profit" organisation of around 150 organisations
in the transport field who are working to promote the use of Intelligent
Transport Systems (ITS). These are combinations of sensors, communications
and mobile Information Technology designed to assist all modes
of transport. ITS (UK) is fortunate in having membership from
across the UK and beyond drawn from the public and private sectors
and from academia. We are funded entirely from member subscriptions
and can therefore independently represent the interests of the
whole membership spectrum in this rapidly developing field.
Lesser known acronyms, used in the submission,
are included in full as below:
| ACPO VCIS | —
| Association of Chief Police Officers—Vehicle Crime Intelligence Service
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| DSRC | — | Digital Short Range Communication
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| EVI | — | Electronic Vehicle Identification
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| OEM | — | Original Equipment Manufacturer
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| PNC | — | Police National Computer
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| RFID | — | Radio Frequency Identification
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| VED | — | Vehicle Excise Duty
|
| VIN | — | Vehicle Identification Number
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| VRM | — | Vehicle Registration Mark
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1. OVERVIEW
Motoring and vehicle taxation offences are currently enforced
by police officers or specialised single-function systems. The
current concerns about the rapid rise in evasion of Vehicle Excise
Duty (VED) offer an opportunity to consider a 21st Century approach
based on flexible Intelligent Transport technology that is technically
very much harder to deceive, and which offers benefits across
a wide range of enforcement activities such as MOT, Insurance
status, PNC Lost/Stolen vehicle index, road user charging etc.
ITS (UK) believes that it would be ineffective to launch an initiative
to improve the coverage or/and accuracy of the DVLA databases
without radically changing in parallel the roadside systems for
detecting and tracking offenders.
2. CURRENT SITUATION
Traditionally VED enforcement has been achieved by recognising
the vehicle registration mark—the "number plate"—and
looking up the associated name in the DVLA records. Initially
identification was done by a person viewing an actual vehicle
or at a photograph or TV image however the development of Automatic
Number Plate Recognition speeded this process considerably. At
first error rates—"incorrect readings" or "failure
to read"—were high but improvements to camera mountings,
photosensitive electronics and image recognition software helped
push accuracy above 90%. The acceptability of digital camera evidence
has now extended the accuracy and flexibility of deployment.
However, despite the improvements in camera performance non-compliance
with the current Regulations regarding the display of VRMs is
increasing. Motorists are deceiving ANPR cameras using plates
that are cloned, stolen or distorted (eg incorrect spacing and/or
fonts or foreign registered marks) to avoid detection; the statistical
evidence, contained in the Committee's Report, is confirmed by
anecdotal evidence.
ANPR is a multi-stage process. The camera has to recognise
the presence of the moving vehicle; it has to "find"
the number plate which would be in a very different location for
a small car compared to a 38 tonne HGV; it then has to capture
the plate's image and translate it to alphanumeric characters
before the decoded plate can be matched against the DVLA database.
This is an intrinsically slow and cumbersome process and further
ANPR improvement is difficult and expensive.
3. ITS TECHNOLOGY OPTIONS
A far better way to carry out enforcement would be to use
some form of Electronic Vehicle Identification (EVI). EVI is not
one unique product—it is a term for a variety of systems
that can identify vehicles at a distance using a roadside unit
that interrogates some form of in-vehicle unit by wireless. Technologies
readily available range from a "dumb" device holding
minimal information (eg the Vehicle Identification Number [VIN]
), to a "smart" device that provides two-way communication;
stores and updates vehicle, driver and traffic data; and is integrated
with other on-board systems.
An EVI system cuts out at least three steps in the process:
a roadside installation would interrogate the EVI devices on passing
vehicles generating an instant stream of identities which could
be matched either at the roadside or in a back-office database.
The mis-matches (or "electronic silence" from non-equipped
vehicles), would then be used to check the vehicle's VED, MOT,
Insurance, disqualified driver status, etc) and could automatically
trigger enforcement action as required. In effect the roadside
device would be notifying that a particular vehicle was on the
road.
The most commonly discussed EVI systems for enforcement are
some form of "chip" (very similar to the tags used by
shops to deter theft) which would be embedded in the actual number
plate or in a VED licence holder. Alternatively, there are microwave
devices of the types used extensively for road user charging (eg
the Dart-Tag or the M6(T) tag). The chip embedded in the plate
is cheaper than the microwave device but being located low on
vehicles' bodywork limits accurate reading; consequently the chip
should be placed in a more favourable position—e.g. within
a VED licence holder.
Various forms of EVI are currently available however there
are issues regarding their introduction and deployment. There
are emerging standards for EVI (with development being sponsored
by the DfT) but there is much commercial pressure and the market
is still vulnerable to proprietary designs. The microwave standards
used for pricing are not only well established but are specified
in an EC Directive. Microwave devices are usually fitted to the
windscreen so there would be an immediate opportunity to use the
device to give remote wireless confirmation of payment of Vehicle
Excise Duty. Both types of EVI would be extremely difficult to
clone cost-effectively.
Finally, the Committee may wish to consider the social issues
and the potential that most VED [and similar] evasions constitute
an inability to pay relevant fees as opposed to a determined effort
to evade detection by the registration authorities. Any serious
process aimed at boosting vehicle registration or insurance is
likely to be opposed by lobby groups because they tend not to
recognise the difference between anonymity and personal privacy
so it will be difficult to argue convincingly against the claims
of extending "the ability of Big Brother to track us".
The adoption of wireless ITS technologies for vehicle identification
may bring immediate benefits to VED enforcement whilst simultaneously
facilitating the detection of a multitude of additional capabilities
such as detection entry onto/within road user charging zones,
minimising the environmental impacts of noise and exhaust pollutants,
simplifying checks on vehicle and driver documentation speeding
up stolen vehicle verifications and enabling the delivery of traffic
data and traveller information to the vehicle.
4. SUMMARY
ITS (UK) invites the Committee consider this issue in a wider
context other than solely identifying better ways to ensure VED
compliance. The widespread deployment of EVI technology was last
considered over two years ago and since then performance has increased
and prices have fallen. Consequently a "Requirements and
Technology" study, coupled with an implementation plan, could
aid identification of the broader policy interactions.
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