Automated and Electric Vehicles Bill

Written submission from Guide Dogs (AEVB 25)

Automated and Electric Vehicle Bill: House of Commons Public Bill Committee

13 November 2017

1. About Guide Dogs

1.1. Guide Dogs provides a range of mobility services to increase the independence of people with sight loss in the United Kingdom. Alongside our mobility work we campaign to break down physical and legal barriers to enable people with sight loss to get around on their own terms. We also work alongside government and industry to develop technologies and systems that enable people with sight loss to have greater freedom.

2. Summary

2.1. Guide Dogs recognises the considerable benefits of electric vehicles and the potential for fully automated vehicles in particular to revolutionise door-to-door transport for blind and partially sighted people. There remains an outstanding question concerning the safety of quiet electric vehicles for pedestrians with sight loss that requires clarification. This submission will address the safety of electric vehicles, as well as the potential benefits of automated vehicles, and the importance of ensuring their development considers the needs of blind and partially sighted pedestrians and passengers.

3. The audibility of electric vehicles

3.1. A timetable for introducing a requirement for artificial sound generators on quiet hybrid and electric vehicles was agreed by the member states of the European Union in 2014. Guide Dogs is calling for confirmation from the Government that the timescales for this requirement will be made clear in domestic legislation after the UK’s departure from the EU.

3.2. The quiet nature of electric and hybrid vehicles means that they pose a danger to road users who cannot hear them approaching. Research published in November 2014 shows that electric and hybrid vehicles are 40% more likely to be involved in a collision causing injury to a pedestrian than a conventional vehicle [1] . Contrary to popular belief, it is up to guide dog owners rather than guide dogs to make the decision of when it is safe to cross roads, using their hearing to detect whether cars are approaching. It is therefore essential that vehicles are audibly detectable for guide dog owners to be able to cross roads safely.

3.3. Guide Dogs, along with other organisations across Europe, campaigned for quiet vehicles to be fitted with a simple speaker system called an Acoustic Vehicle Alerting System (AVAS) to make them audibly detectable. As a result, in 2014, Regulation (EU) No 540/2014 on the sound level of motor vehicles [2] stated that AVAS must be fitted on new models of quiet hybrid and electric vehicles by 1 July 2019 and all new quiet hybrid and electric vehicles by 1 July 2021.

3.4. The creation of the specification of the AVAS was referred to the World Forum for Harmonisation of Vehicle Regulations (WP.29), a working party of the Sustainable Transport Division of the United Nations Economic Committee for Europe (UNECE). All EU member states are signatory to what is known as ‘the 58 agreement’; the international legal framework for harmonising and agreeing technical prescriptions for road vehicles. A preliminary specification was agreed in March 2016 [3] . The agreement reached by the UNECE does not prescribe timescales for adopting the specifications; the deadlines for introduction are only mentioned in EU regulation No 540/2014.

3.5. The UK is a contracting party to the 58 agreement in its own right, and therefore the specifications for AVAS on road vehicles will continue to apply after leaving the EU. However, the Government has not confirmed that they will convert the EU regulation setting out the time scales for introduction into domestic legislation. As the Government’s stated position is that "once the UK leaves the EU, it will no longer be subject to EU law" [4] , it is therefore important that the deadlines are clearly stated in domestic legislation.

3.6. Reassurance on this matter has been sought previously, but the Government has not confirmed its position. In February 2017, Baroness Scott of Needham Market and Lord Low of Dalston raised the matter in a debate on Brexit and disabled people in the House of Lords. The Government spokesperson, Lord Henley, followed-up the debate with a letter to participants, but did not provide confirmation on timescales. The Minister said: "Turning to electric and hybrid vehicles, I would like to confirm that we take the safety of vulnerable road users very seriously. The Office for Low Emission Vehicles (OLEV) welcomes thoughts and evidence in this area and will use these views to inform policy decisions. Furthermore, the Department for Transport continues to carefully consider issues around ultra-low emission vehicles." [5] In July 2017, Dr Lisa Cameron MP returned to the issue in a debate on Brexit and Disability in the Commons, however the responsible minister did not respond to the point [6] .

3.7. On vehicle standards more broadly, in November 2016 then Minister of State at the Department for Exiting the European Union David Jones said in the House of Commons that "Many vehicle standards are actually shaped in United Nations bodies, and the EU absorbs them into EU law. That process would therefore be absorbed into our domestic law as part of the great repeal Bill process." [7] While the European Withdrawal Bill does state that "Direct EU legislation, so far as operative immediately before exit day, forms part of domestic law on and after exit day" [8] , as the EU regulation relates to a future requirement, it is important that the Government’s commitment to ensuring that quiet vehicles do not pose a threat to blind and partially sighted pedestrians is clear.

Recommendation: Guide Dogs asks the Government to explicitly confirm that they will require AVAS to be fitted on new types of quiet and electric vehicles by 1 July 2019, and all new quiet and electric vehicles by 1 July 2021, and this timetable will be unaffected by the UK’s departure from the EU. As the key piece of legislation on automated and electric vehicles – and the only legislation on the topic likely prior to the UK’s exit from the EU - this bill is an appropriate opportunity for the Government to provide reassurance on this matter.

Automated vehicles and people with a visual impairment

3.8. Guide Dogs recognises the significant benefits that increases in automation and, eventually, fully automated vehicles could deliver. We are working with government and manufacturers to ensure the concerns and aspirations of vision impaired people are considered at every stage of this evolution in private and public transport. This currently involves liaising with a number of automated vehicle pilots taking place in locations around England.

3.9. Whilst understanding the restricted focus of the Bill, Guide Dogs believes wider issues surrounding automated vehicles should be discussed to ensure that the needs of all passengers and pedestrians, including those who are blind and partially sighted, are considered from the outset. An overview of the advantages and potential challenges of automated vehicles is outlined below.

3.10. The benefits of automation in vehicles, even in a limited form could include:

a) A significant reduction in collisions due to driver error.

b) A significant reduction in the number of vehicles parked on UK roads and pavements. Cars parked on pavements are a particular hazard for people with sight loss who may be forced into the road against oncoming traffic which they are unable to see.

3.11. Fully automated vehicles could provide further benefits including:

a) Full autonomy in where to travel and when

b) The elimination of needing someone with sight to control a vehicle, putting vision impaired people on an equal footing with sighted drivers.

c) Meaningful door-to-door transport, with the vehicle accurately getting passengers from their pickup point to the drop off point of their journey, limiting reliance on public transport.

d) The ability to access a vehicle as needed without the associated costs and responsibilities of ownership.

3.12. To fully harness the benefits of automated vehicles, there are issues that need to be addressed in their development. These include:

a) Accessible design. Fully automated vehicles available for hire should incorporate safety and accessibility features in their design. Public services vehicles such as buses and trains have clear standards on colour-contrast grab-rails, low-flooring, wheelchair spaces and illuminated door controls. Where automated vehicles serve as a public service vehicle they should also meet equivalent standards of accessibility.

b) As raised in the Committee sessions and in other evidence, there are ethical considerations surrounding the behaviour of vehicles in unavoidable crash situations, which are likely to be particularly relevant if there is a period when fully automated, partially automated and conventional vehicles are navigating the streets at the same time.

c) There is a question of whether people who are unable to manually control a vehicle would eventually be able to make an unaccompanied journey in an automated vehicle safely.


Automated vehicles have the potential to revolutionise transport and permanently alter the way we travel. Whilst recognising that the focus of the Automated and Electric Vehicle Bill is limited, there is a clear need to address the issues that will stem from the proliferation of fully automated vehicles. To ensure that the necessary infrastructure and framework of legislation is accessible for generations to come, it is important that manufacturers, regulators, road-user groups and passenger groups are all involved in developing policy from the outset.

To this end, Guide Dogs encourages the Government to expand the issues under consideration, and take a leading role in bringing together interested parties that will enable the UK to become a world leader in  rolling out safe and accessible automated vehicles for the benefit of everyone in society.

November 2017


Prepared 15th November 2017