Automated and Electric Vehicles Bill

Written evidence submitted by the International Transport Workers’ Federation (ITF) (AEVB05)

Executive summary

· The bill’s definition of vehicle autonomy is too narrow and should incorporate the five definitions or levels of autonomy used across the industry;

· A clear framework of government leadership and financial support should be contained in the bill. This could entail commitments to building the necessary technological infrastructure, and cooperating with other governments on cross-border standardisation of technology and enforcement of regulations;

· Automation and digitalisation will create, not destroy jobs, if managed properly. The bill should make explicit commitments to retraining workers to ensure that skills shortages do not hinder the modernisation of road transport, trade and the broader economy;

· Without explicit ethical guidelines, developers of the technology will be left to make these judgements themselves. The bill should establish a commission to develop guidelines that secure the ethical integrity of algorithms and public trust in the technology;

· The bill fails to address the difficult balance between data transparency and protection. The ITF welcomes the creation and maintenance of a database of autonomous vehicles and registration, but the bill must be explicit about the right to public access to this information and protections afforded to individual’s privacy;

· Insufficient enforcement of existing regulations is a major issue for road transport, specifically in freight haulage. The bill should remedy these shortcomings by developing institutions or mechanisms that utilise the technology made available by increased vehicle automation and connectivity.

1. Introduction

1.1. This response is submitted by the International Transport Workers’ Federation (ITF), the global union federation for the transport sector. The ITF represents over 16 million transport workers, who are part of 700 affiliated trade unions across 150 countries.

1.2. The ITF’s views are based on research, from workers’ perspective, into how automation and digitalisation of transport can be fair and sustainable. The ITF has worked alongside the International Labour Organization (ILO), the International Transport Forum, the Organisation for Economic Co-Operation and Development (OECD), the World Economic Forum (WEF), and several other international organisations on the issue. The global scope of the ITF gives it a unique perspective and understanding of how technological innovation changes labour and industry.

1.3. Over the past two years, the ITF has been leading field research into the European road haulage industry, as cited by a recent BBC investigation. It has a clear and specialised insight into the realities of the haulage industry and how market forces, including technological innovation and changing regulatory systems, shape the working lives and welfare of millions of workers and their families.

2. Defining autonomy and connectivity

2.1. The bill’s narrow definition of autonomy fails to recognise the diversity and differing scales of vehicle automation being developed and tested. Without an explicit and systematic definition from the government, the private sector will be permitted to forge its own thresholds and exploit legal and regulatory uncertainty. Proper and effective regulation, and therefore the industry’s sustainable growth, is dependent on clear definitions and limits from the outset.

2.2. The academic and business community has largely reached a consensus around five levels or scales of automation as an analytical and technological framework: (1) driver assistance, (2) partial automation, (3) conditional automation, (4) high automation, and (5) full automation. This framework should be embraced by the government to better define vehicle autonomy and connectivity.

2.3. In its current form, the bill would likely only be applicable to level four and five technologies. This would exclude most ‘platooning’ and connected-vehicle technologies currently in development, which could hinder investment, testing and deployment in the UK.

3. Government intervention and technological infrastructure

3.1. Internationally, governments that have shown financial and regulatory leadership in developing autonomous vehicle markets, as seen in China and Germany, have been rewarded with significant external investment. The bill should provide a clear framework for government support for much-needed initiatives, such as the government’s £100 million investment in the MERIDIAN co-ordination hub for connected autonomous vehicles (CAV).

3.2. The bill fails to address the differing infrastructural and funding demands of vehicle autonomy and connectivity. Autonomy requires lower spending on infrastructure, but more funding for advanced research and development by technology manufacturers and developers. Connectivity requires higher spending on network infrastructure (such as 5G and satellite technology) but relatively less financial support for private sector research and development. The bill should commit public funds to develop the necessary infrastructure and provide certainty for industry.

3.3. Clearer government leadership, funding for research, and investment in infrastructure is necessary to prevent increasing ‘regulation avoidance’ and outsourcing of research and testing to China and countries which combine more financial support with less oversight.

3.4. As developers and operators of autonomous technology benefit strongly from public investment in infrastructure, the bill should suggest a taxation mechanism to ensure that these firms share some of the financial burden.

3.5. Standardisation of cross-border and international automated technology is crucial to road haulage continuing to move the vast majority of European freight. The bill must contain commitments to establish frameworks for cooperation with other European states around autonomous vehicle technologies, especially in the context of the UK exiting the European Union. The government should also cooperate with other states on ‘digital taxation’ and regulations concerning transnational work and trade.

4. Employment and the labour market

4.1. The bill fails to recognise that government intervention is also needed to ensure the digital transition is fair and sustainable for workers in the UK. If managed properly, automation will create not destroy jobs, shifting employment to new workplaces, occupations, employers, sectors, and skills. By 2030, the autonomous vehicle industry could create 25,000 in the automotive industry and generate an additional 1% of cumulative GDP growth, translating into a total of 320,000 jobs created (KPMG, 2015).

4.2. Potential skill gaps must be addressed by this bill. If left to fester, a 750,000-job gap in skills, particularly in the areas of science, technology, engineering and maths (STEM), could hinder the automated vehicle industry in the UK by 2025 (Transport Systems Catapult, 2017). This potential labour shortage offers a stark warning of the dangers of government inaction.

5. Ethical concerns and decision-making of artificial intelligence

5.1. Failure to mention the ethical decision-making by artificial intelligence and the processes behind algorithms is a threat to greater automation. Without clear guidelines on ethical standards, the owners and developers of the technology will be left to programme machines to make morally complex and life-threating decisions, such as which human lives should be saved or sacrificed when faced with a fatal choice in the midst of an accident.

5.2. The bill should contain commitments to establish a Commission to develop fundamental ethical guidelines for the algorithms of automated and connected driving systems. This could follow the example provided by the German Federal Ministry of Transport and Digital Infrastructure, which appointed an Ethics Commission, consisting of experts of philosophy, theology, law and engineering, to develop such guidelines.

6. Balancing data protection and transparency

6.1. Although the bill will rightly establish and maintain a database of autonomous vehicles, it fails to address the need to balance issues of transparency and data protection.

6.2. Transparency of data and algorithms protects the users of autonomous technology, the public, and operators and manufacturers. Without transparency, accidents lack explanation, complicating fixes, damaging public trust and slowing industry adoption.

6.3. The public should be able to access data inputs and outcomes of autonomous and connected vehicles using the framework provided by the Freedom of Information Act 2000. Effective sharing of data is also critical to maximise the public good; data generated by autonomous and connected vehicles can be used for traffic management and identifying potential network improvements.

6.4. Cyber security and data protection must be enshrined in both private and public data storage to ensure the safety of drivers and the public. The right to individuals’ privacy should be respected.

7. Enforcement of existing regulations of road freight transport

7.1. The bill should also strive to correct the current failures of road transport, namely the insufficient enforcement of working and resting time regulations. The digitalisation of data collection, potentially through the collection of ‘cloud data’ by connected vehicles, is an opportunity to ensure that cuts to funding do not result in deficiencies in enforcement.

7.2. To aid enforcement of current regulations concerning pay, working and resting time, and working conditions, the proposed database should gather information on working and resting times, locations of work, the names of the transport provider and potential subcontractors, and the end customer.

30 October 2017


Prepared 1st November 2017