WEF SafeDI Creating Safe AV Policy 2020
WEF SafeDI Creating Safe AV Policy 2020
WEF SafeDI Creating Safe AV Policy 2020
Contents
3 Preface
4 1 Executive summary
6 2 Key terminology
7 3 Motivation
9 Technical standards
12 Case insights
13 Case insights
14 Case insights
15 4.4 Discussion
16 5 Synthesis
16 5.1 Opportunities
19 Contributors
20 Endnotes
A cohesive Autonomous vehicles (AVs) promise to This framework will be detailed in a subsequent
approach to revolutionize the future of mobility, from how we Safe Drive Initiative publication.
autonomous travel and commute to automating the operations
vehicles is of logistics and supply chains. While this promises In the course of this policy review, we interviewed
a future of efficient transport with fewer road a range of national, state and local policy-makers
possible only when
fatalities and injuries, the AV technologies remain and advisers to understand the thinking behind
accompanied by
under development, and policy-makers are trying the various approaches that exist today. When
a clear top-level to navigate the trade-off between facilitating coupled with a legal documentation review, this
vision for the testing and trials of AVs, and protecting their highlights a number of important success factors
future mobility citizens from unproven self-driving vehicles. to developing an optimal policy environment for
ecosystem. AVs. One message became abundantly clear: A
Transport officials cannot be expected to maintain cohesive approach to AVs is possible only when
cutting-edge knowledge on the operational safety accompanied by a clear top-level vision or strategy
of autonomous systems. Moreover, the industry statement for the future mobility ecosystem in the
has yet to align on a common approach to market. With a clear vision statement for the future
demonstrating the operational safety of automated of mobility, it becomes easy to define what role
vehicles. This creates tensions between policy- AVs can play in achieving that vision, and enabling
makers and industry stakeholders, who may the creation of an achievable policy roadmap for
prefer that regulators trust their expertise in AV testing, development and commercialization.
developing safe solutions, but simultaneously want
to safeguard their intellectual property and other While this is straightforward from a strategists’
trade secrets. perspective, the reality is that many markets
have various levels of state, ministerial and
So far, policy-makers are largely allowing for local regulations that may be affected by
self-certification by AV companies, while making AV deployment, and these various levels of
minimal amendments to their existing road subnational regulators may also seek input on
traffic regulations to enable testing of automated future AV policies. This tension is all too common,
vehicles. A small handful of regulators are taking and may create unnecessary hurdles for AV
a hands-on approach to evaluating AVs, creating developers to navigate. Without a cohesive top-
a structured, graduated testing and approval down strategy, it is easy to see how regulatory
process as the basis for a licensing programme. patchworks emerge.
Broadly, the Safe Drive Initiative is seeks to This project is continuing to study and propose
improve regulators’ decision-making abilities on optimal approaches to AV policy, as the
automated vehicle technologies. In this paper, the technologies move from small trials to larger
World Economic Forum offers a holistic review of pilots and deployments. The recommendations
the leading approaches to AV policy, to identify and methodologies identified in this document
and highlight the most effective techniques in are intended to provide actionable insights for
these approaches in order to facilitate the testing global policy-makers, while also informing our own
and development of AVs. Following this review, we research into AV policy.
identify gaps that we believe can be addressed
through a graduated, scenario-based approach The World Economic Forum is grateful for the
developed in partnership with our multistakeholder insights from several contributors and the analytical
Automotive and Autonomous Mobility community. support of McKinsey & Company.
1 Executive summary
There is limited The development of automated driving is far but these have yet to be converted into workable
global consensus from complete. From software to hardware, the policies. Moreover, AV developers are often reluctant
on how to define technology is still evolving, particularly in Level to share any information about their own safety
milestones for AV 4 and 5 systems. Meanwhile, regulators are still metrics regarding their operations out of fear of
safety, because catching up with this fast-growing sector, and at losing their competitive advantage, creating a siloed
best are reactive in creating policy to enable testing industry that essentially competes on safety.
the definition of
– with considerable variation in methodologies
safety is a function
between nations and states. The United Nations Some authorities, such as the California Department
of its operating Economic Commission for Europe (UNECE) recently of Motor Vehicles (DMV), require routine data
environment. proposed new autonomous driving guidance to reporting, including miles driven and disengagements,
ensure passenger safety, signalling the importance but these limited metrics are frequently refuted as
of this subject. Still the challenge of creating policy poor indicators of safety by industry, academia and
for high-level automation remains unresolved. other governments alike. Despite this criticism, there is
limited consensus among industry stakeholders as to
The industry’s rapid development to this point has what metrics could be used to indicate system safety.
outpaced policy-makers’ response to AVs. While the
technology is continuing to evolve, regulators need While the progress of development to date
to understand how these development activities and has been rapid, AV technologies remain largely
future deployments will affect their citizens’ lives and unproven for many operators, and the industry has
influence their decision-making in everything from not yet been able to align on a common framework
transport policy to urban development. for assessing the safety of AVs necessary for full
deployment. While self-certification may be the
Some countries, such as Singapore, have been preferred approach for AV providers during the
highly proactive in engaging with, and providing testing phase, many regulators and members of
funding for, the industry and research institutions the public will expect some form of independent
to study the technology and create regulatory assessment of AV safety in the future.
sandboxes. This enables them to understand AVs
intimately and shape policies that meet their own An effective validation process must strike a balance
goals for mobility in their jurisdiction. Others, such in order to create a rigorous process that ensures
as the United States, have taken a more hands- safety for all road users without demanding too much
off approach, creating broad guidelines for AV from AV providers, opening doors to costly litigation
development and relying on the industry to set the or exposing trade secrets. Policy-makers need to
pace of investment and deployment. In the absence use this period of development to engage with the
of suitable federal or state regulation, cities may also industry to advance their own understanding of
feel the need to set their own guidance, creating a these vehicles and establish suitable competencies
fragmented and varied broad policy landscape for AV to inform their future decision-making if they want to
companies to navigate across the country. succeed in enabling safe deployments of automated
vehicles when the technology matures.
Globally, there is limited consensus on how to
define milestones for AV safety, since the problem Thus, the key research question behind the Safe
of defining safety invariably becomes a function of Drive Initiative is the following: How can policy-
the operating environment. Several technically driven makers ensure an AV is safe to operate in their
initiatives have proposed validation frameworks, jurisdiction?
– Simulation: Highly parameterized digital twins of roads that can be used to test AV systems under
many different parameter values and estimate the vehicle’s expected response.
– Test track: A controlled environment that mimics a city infrastructure and can be used to simulate
real-world driving in a lower-risk situation. Can enable verification of simulation scenarios in a real-world
analogue with minimal risk.
– Naturalistic on-road testing: Using public roads for testing in regular traffic, typically supervised by a
safety driver or remote operator. This is necessary to prove the safety of the vehicle in the real world, but
also presents the most risk to the public.
To date, the industry’s development efforts have These applications of the technology represent very
focused upon three main applications of automated different business models, and require separate
driving systems. considerations in the engineering of the vehicle and
its safety requirements.
– Initially, the autonomous vehicle industry was
heavily focused on autonomous mobility, Delivery has become a particularly attractive
developing vehicles for use in automated ride- application of AVs, not just because of an increased
hailing or transit services. demand for last-mile deliveries in light of the
COVID-19 pandemic, but because it represents a
– Recently, there has been a pivot to developing more compelling business case for a complex and
vehicles for delivery purposes by many expensive vehicle to be a fleet-owned asset with
operators. These delivery applications span a a potentially high degree of use. This is also true
range of applications, from heavy-duty trucking for trucking and long-haul logistics, which is also
to small ground robots for last-mile delivery. viewed as a prime application of AV technologies.
A spectrum of initiatives exist globally to study and licensing programmes, the AV policy landscape
develop AV policy solutions. From the amendment of remains a fragmented one globally. Some nations
existing traffic laws to the development of structured and cities have been highly proactive in developing a
United Kingdom
Code of practice requires PEGASUS, Europe
documentation of vehicle testing, but Dedicated to validation approach
does not require permit as long as for Level 3 technology, currently ANSI/UL 4600
safety driver is behind the wheel exploring Level 5 approach Describes situation
examples and metrics to
evaluate performance of
AVs within an ODD
California, USA
Self-certification Headstart, Europe
requires applications Aligning scenario-based
detailing the ODD that approaches to validation ISO 26262
the AV can function in of Level 2/3 connected Risk-based safety
and a description of and automated vehicles standard for functional
safety features such as across Europe safety of electronic
how a remote operator systems in vehicles
can take over throughout life cycle
Singapore
Developing a
three-step
graduated validation ISO/PAS 21448
approach requiring Describes validation
demonstration approach to address faults
of vehicle capability due to system limitation,
to regulators not technical failure
Pittsburgh, PA, USA (e.g. LiDAR not being able
Policy leans largely on Dubai, UAE Australia
Code of practice outlines to correctly interpret a
self-certification and Code of practice
general approach to certain situation)
NHTSA Voluntary Safety Self allows self-certification
Assessment certification, but does not with a safety driver to
detail test parameters enable testing
Through industry coalitions, standards bodies and – ANSI/UL 4600 – Standard for Safety for
other ventures, a range of technical standards are the Evaluation of Autonomous Vehicles
currently under development to inform the technical and Other Products: Safety principles and
development of AVs across a range of topics, from processes for evaluating fully autonomous
functional safety to building an end-to-end safety products requiring no human driver supervision
case. Many existing industry standards are geared
towards mass-production passenger cars and their – ISO 26262 – Road Vehicles – Functional
advanced driver assistance systems (ADAS), but Safety: Risk-based safety standard for the
several efforts to develop the necessary standards functional safety of electronic systems in
for highly automated driving systems are under way. vehicles throughout the vehicle’s life cycle
However, these standards are largely industry-led, and
may not be directly suitable for policy implementation. – ISO/PAS 21448 – Road Vehicles – Safety
of the Intended Functionality: Provides
There is a broad range of technical standards for guidance on the applicable design, verification
autonomous vehicles – covering aspects from and validation measures needed to achieve
individual component performance to organizational safe system operation, reducing hazard risk
safety measures. Policy-makers should not of functional insufficiencies of the intended
expect to follow the full technical spectrum of functionality even when components are
such standards, but should be made aware of operating correctly or are affected by
cornerstone standards that are frequently referred foreseeable misuse
to in AV safety development:
International collaborations on AV validation tend Other nations, including the UK and Japan, have
to focus on developing validation approaches to sponsored similar coalitions to explore and develop
form the basis of operational safety assessments, scenario-based assessments for automated
such as the PEGASUS Project in Germany. The vehicles, and are employing a multistakeholder
PEGASUS Project was initiated by the German methodology to develop their initial requirements
Federal Ministry for Economic Affairs and Energy and structure their assessment programmes.
and is supported by a range of industry participants,
including BMW, Continental, Daimler, the German Successful regulatory implementation requires
Aerospace Center, IPG, Opel and Volkswagen. input from multiple stakeholders, but most
The project’s mission is to define a standardized stakeholders want someone else to make the
procedure for the testing and development of first move: In an ideal world, city, state, federal, AV
automated vehicle systems in simulation, on test providers and the public would work together in the
tracks and in real-world environments, through a development of AV policy. In reality, governments
scenario-based assessment enabled by creating are open to suggestions from the AV industry on
harmonized approaches to data acquisition, the creation of safety metrics and assessments,
definition and labelling. and consultations with other stakeholders are
fragmented at best.
Traditionally, the US federal government has been The DoT’s current policy acknowledges that
responsible for certifying conventional vehicles responsibility for AV licensing and compliance with
to be safe at the point of manufacture, and state local traffic laws remains at the state level, as with
governments have been responsible for certifying conventional vehicles.
human operators to drive vehicles safely.
Each state’s Department of Transportation
The US Congress has considered legislation or Department of Motor Vehicles has primary
in each of the last two congresses that would responsibility for the licensing of AV operators, and
establish a national legislative and regulatory many states have implemented their own approval
framework for AVs, but the efforts have ultimately process for autonomous vehicles in the interests
fallen short of becoming law. of safety assurance. The State of California has
the best-known AV licensing programme, given
Meanwhile, the United States Department of the number of companies testing in the state. This
Transportation (US DoT) has set out a series programme is administered by the California DMV.
of top-level policy papers outlining the federal
government’s role in AV governance. The most Across the US, cities and other local authorities
recent publication, Ensuring American Leadership have limited scope to influence federal AV
in Automated Vehicle Technologies: AV 4.0, builds regulatory policy, despite being directly affected by
upon previous publications by mapping the role the presence of AVs on their streets. As a result,
of adjacent government departments such as local authorities may wish to see stricter safety
the Department of Defense in future autonomous requirements than state or federal regulators
vehicle development and governance. Previous request. However, the adoption of unique local
publications set out a range of reference terms requirements may create a patchwork of regulations
and created a handful of safety requirements, such across jurisdictions that undermines the ability
as the establishment of a Voluntary Safety Self- of AV operators to develop compliant systems
Assessment (VSSA) reporting programme. that can operate statewide. Some cities have
created additional, albeit voluntary, reporting and
Broadly, the spirit of the current US DoT policy operational requirements for AV operators.
is to provide an open regulatory environment for
innovation, remain technology-neutral and allow For AV companies, the lack of federal AV laws has
the industry to set the pace of development and created a fragmented patchwork of regulations across
deployment through a self-certification approach. the US market, with considerable differences in
requirements at the state and, sometimes, local level.
– AV deployment programme (no permits issued at Testing and operation of an AV without a safety
the time of writing): driver also requires companies to attest to the above
requirements, as well as several further statements:
– Description of intended ODD, any commonly
occurring restrictions – The AV has all required federal certifications
(unless an exemption from the National
– Description of vehicle safety mechanism in the Highway Traffic Safety Administration [NHTSA]
event of ODD excursion, and when occupant has been granted) and meets all required
is unable to take manual control of vehicle licensing and insurance requirements
– Requires data recorder to capture at least 30 – AV developers must submit and follow a Law
seconds of data before a collision with another Enforcement Interaction Protocol instructing
vehicle, person or object first responders on how to interact with the
AV in emergency situations (e.g. how to
California’s publication of disengagement data has interact with a fleet support specialist; how
become one of the de facto indicators of autonomous to move the vehicle from the roadway)
Case insights
Devolution of vehicle licensing responsibility testing and safeguarding the public”. The NTSB
has created a fragmented market, which may also describes the NHTSA’s voluntary safety self-
harm widespread deployment of AVs in the assessment requirements as “inadequate”.
US: The federal government’s hands-off approach
has enabled states to set their own requirements The California DMV’s disengagement reporting
for AVs, but this has led to a variety of different has been criticized as lacking suitable context
safety requirements in various states. California’s and depth to indicate safety or technology
AV permitting programme is the most stringent in maturity: Many industry leaders have publicly
the US, while other states, such as Arizona, place criticized the use of disengagement reporting as
minimal requirements on AV operators. This lower a safety metric. Disengagements are a function of
bar may encourage some AV operators to trial their complexity of test conditions and the number of
vehicles in other states, but the long-term viability of miles driven. In addition, a disengagement indicates
this patchwork approach is questionable. only that a human test operator took over an AV at
a given time, not necessarily that there was a failure
While the DoT and NHTSA have recently launched of the automated driving system. Moreover, the way
new initiatives in AVs (such as the AV TEST initiative) this data is reported varies considerably between
these have done little to harmonize the regulatory operators, from lengthy descriptions of each
patchwork across states. disengagement and of system faults to single-word
entries. This highlights the need to improve the
Not all self-certification policies have the way in which such data is reported to standardize
same level of oversight. California requires some inputs, making comparisons possible. Doing so
supporting documentation regarding the AV’s would enable other stakeholders, such as cities, to
development process and safety procedures, while derive their own insights from this dataset.
Arizona requires only that companies attest to the
AV’s ability to operate safely and achieve a minimal Despite such vocal criticism of the disengagement
risk condition if it leaves its intended ODD. Arizona’s reporting approach, AV operators are reluctant
approach leans entirely on companies to develop to share publicly how they measure safety and
AVs safely, while California has attempted some level development progress internally, as a means of
of independent assessment and ongoing monitoring. protecting intellectual property. Given the varied
approaches AV companies in the US are taking,
Arizona’s lack of regulatory oversight has been and the fact that the AV industry as a whole is still
identified as a contributing factor in the first in a testing phase, there is not yet consensus on
fatality from AV development. Following an exactly which metrics will be necessary to make this
investigation by the National Transportation Safety safety case.
Board (NTSB) into the accident, in which an AV
struck a pedestrian in Tempe, Arizona, in March The industry-led development in the US is
2018, the open policy environment was identified creating an environment in which safety can
as one of the contributing factors in this collision. be a source of competitive advantage: Without
In addition to identifying a problematic safety harmonized, uniform requirements across the
culture and a range of other contributing faults on country, AV operators treat information on their
the part of the AV company, the NTSB wrote in its technology’s safety and maturity as the most closely
2019 analysis of the accident that “Arizona’s lack guarded industry secret. When combined with the
of a safety-focused application-approval process race to launch commercial AV services, this creates
for ADS [automated driving system] testing at the an unhealthy competition where safety is something
time of the crash, and its inaction in developing on which AV companies compete, rather than
such a process since the crash, demonstrate the collaborate with one another.
state’s shortcomings in improving the safety of ADS
In 2019, the United Kingdom published the non- Additionally, the British Standards Institution
regulatory Code of Practice: Automated Vehicle (BSI) is actively developing a range of connected
Trialling2 following a review of existing road traffic and autonomous vehicle publicly available
laws, to provide guidance for AV companies seeking specifications (PAS) standards to complement
to test vehicles on UK roads. This code of practice the UK’s policy needs. The PAS 1880 series
outlines the need for compliance with existing traffic establishes relevant requirements for AV trials in a
laws, covering subjects from insurance to vehicle number of fields, including:
roadworthiness, while encouraging engagement with
the relevant government agencies and the public. – PAS 1880: Guidelines for Developing and
Assessing Control Systems for Automated
According to this code of practice, no further permit Vehicles
is required to conduct testing of an AV on UK roads,
provided there is a safety driver or operator, in or out – PAS 1881: Assuring the Safety of Autonomous
of the vehicle, ready to take control of the vehicle. Vehicle Trials and Testing
This code of practice is not a stand-alone policy – PAS 1882: Data Collection and Management for
in the UK; it has been accompanied by a series Automated Vehicle Trials
of strategic initiatives to strengthen the UK’s
development of, and investment in, AVs. This – PAS 1883: Operational Design Domains (ODD)
began in 2015 with the creation of the Centre for Taxonomy for Automated Driving System (ADS)
Connected and Autonomous Vehicles (CCAV), a – Specification
government centre of excellence established jointly
from within the Department for Business, Energy and Furthermore, the UK is also undertaking the
Industrial Strategy (BEIS), and the Department for development of its own scenario library for
Transport (DfT). CCAV’s mission is to work across the the purpose of establishing a scenario-based
government to support and enable the development operational safety assessment in a programme
of connected and automated vehicles in the UK, called CertiCAV, led by the Connected Places
thorough funding, conducting direct research and Catapult (a government-created non-profit
collaborating with other government entities. organization) and Warwick Manufacturing Group
(WMG), University of Warwick.
Following the creation of CCAV, the UK government
has continued to make connected and automated Finally, the UK Law Commission is currently
vehicles a priority for the nation’s industrial policy, undertaking a three-year review to understand
and it has embarked upon setting up a further non- the need to modify the legal framework to further
governmental entity to create a strategic roadmap for support and enable AV deployment.
CCAV policy in the UK, called Zenzic. This roadmap
was issued in 2019 and establishes a range of policy
priorities across subjects such as cybersecurity and
creating test beds for AVs, until 2030.
Case insights
The British government has established a While this meets the objectives of not creating
top-down strategy to position the UK as a additional barriers to testing, and creates a level
leader in connected and automated vehicles: playing field for AV companies, this code of practice
By establishing and funding an initial mission to is not a suitable framework for AV deployment at
encourage the development of AVs and related scale, and may require additional stipulations for
technologies in the UK, the government has been AV safety as the number of operators trialling in the
able to subsequently create an achievable policy UK increases. The UK government acknowledges
roadmap to ensure there are minimal barriers to AV this, and has further commissioned the creation of
testing on UK roads. a certification and approval scheme, called CAV
PASS, which is intended to create an assurance
The broad code of practice provides guidance process for approving the sale and deployment of
on how to test AVs on the road in the UK AVs at scale in the UK.
in compliance with UK law: This enables AV
operators to ensure AVs can be tested and The UK is developing a scenario library for
developed on the public road legally and with the operational safety assessment: In future, the
support of the government. AV Code of Practice is likely to be superseded by
further regulation, creating an operational safety
assessment based on the CertiCAV library.
Since 2017, Singapore’s regulators have been to enable the regulator to assess the safety of the
highly proactive in creating policies to enable the vehicles under development, while engaging the
development and testing of automated vehicles public and demonstrating a transparent series of
in their city-state. This approach has led to the assessments to assure the safety of the vehicles as
establishment of a joint centre of excellence (CoE) they are tested.
with Nanyang Technical University (NTU) called
CETRAN, and the creation of a series of technical In partnership with CETRAN, by using an
standards and regulations for autonomous incremental, consultative approach engaging AV
vehicles in Singapore. developers, the LTA set out a tiered evaluation
programme to study and license AVs, enabling the
One of the critical success factors of Singapore’s LTA to study and learn about the technology while
approach to AV policy was establishing a vision licensing developers on the road.
early on for the authorities’ role in Singapore’s future
mobility ecosystem – namely, they envision that high- Core to this evaluation programme are three
capacity, shared and electric AVs are a crucial tool milestones, each with a corresponding technical
in addressing the city’s problems with congestion, reference (TR) standard:
limited road space and shortage of drivers.
– Milestone 1: An on-road demonstration of basic
Beyond AVs, Singapore’s future strategy for mobility behaviours such as turns, stopping and safety
seeks to encourage greater use of shared transport operator intervention, to permit the operator
modes. To incentivize AV companies to develop to conduct limited testing in the One North
solutions that fit with this vision, the Singapore Business District
government initiated the Singapore Autonomous
Vehicles Initiative (SAVI), to support the development – Milestone 2: A combination of on-road and
and trials of AVs on their streets. Hence, the Singapore simulation-based assessment, using a scenario
Land Transportation Authority (LTA) sought to create a library representative of Singapore, to allow
policy environment to enable this development to take access to a subset of the city’s public roads for
place and to encourage the creation of solutions that further testing
meet with the city’s future mobility strategy.
– Milestone 3: Currently under development, but
The mission of the resulting AV policy instruments includes additional scenario edge cases and
issued by the LTA is intimately connected to the considerations for cybersecurity
future mobility objectives; the LTA believes that
consumer acceptance of these technologies as These milestones were established, tested and
safe, useful and efficient is crucial, so a public- improved through multistakeholder collaboration
facing, proactive testing programme was devised with the industry, CETRAN and the traffic police.
Case insights
Establishing a clear vision for the role of that industry leads in the area of technological
autonomous vehicles in Singapore’s future expertise, so they should work closely with industry
transport ecosystem enabled the creation of a stakeholders to develop policies that serve all
cohesive policy: Setting a clear mission statement parties’ needs.
early on enabled Singapore to dedicate resources
and research efforts to develop a clear set of policies Passing Singapore’s test may also be a
with the support of industry and other stakeholders. quality assurance mark: There is no one-size-
fits-all answer to regulation, but it may help AV
This collaboration on AV research and providers in other countries to demonstrate
development between regulators, AV providers that one government has robustly tested them.
and CoE creates a healthy tension: All Other governments can also adopt the technical
stakeholders want to maximize safety, and this reference standards developed by Singapore. For
collaboration enables AV providers to supply example, TUV (a German road safety institute) was
input to developing a feasible test while also not an external participant in the development of the
hindering development. The government recognizes Singapore AV standards.
Light Heavy
touch touch
We keep in These three case studies highlight the breadth for AVs has led to states stepping into the policy
contact with other of approaches taken in three different nations vacuum and establishing a patchwork of state-level
authorities to share in enabling AV trials; each approach has its certification requirements. Similar to the UK, the US
experiences … strengths and limitations and reflects the specific currently relies exclusively on AV developers to certify
I don’t think it’s geographical, economic and political realities of the that their systems are safe to test. Acknowledging
three countries. The level of external independent the importance of public trust, AV companies assert
one-size-fits-all.
assessment varies between the approaches, that they are operating as safely as possible and do
We need to learn
directly correlated with the level of complexity in not need external oversight to do so.
which approach implementation on the regulator’s side, as well as
fits best for the burden of proof placed on the AV developer Moreover, each company operates differently and
each market and and country-specific societal norms relating to companies assert that different measures of safety
regulator. government regulation. would be difficult to standardize into a universal
regulation. Hence a performance-based approach
– City regulator Singapore’s operational safety assessment is the to regulation becomes an attractive solution.
most hands-on approach for a regulator, to create
a structured, independent assessment of AV safety. As AV technology continues to evolve, different
Due to Singapore’s small land area, a finite scenario jurisdictions will have varying appetites for
library is easier to develop and parameterize regulation, as well as varying authority to implement
than, for instance, a large country such as the it. Governments with more unilateral regulatory
US. In addition, such a hands-on process is also power (such as Singapore) and a history of
more challenging to implement in a decentralized investment in research and development will likely
government such as the US. have an interest in developing and authority to
implement high-touch policy frameworks, such
The UK’s code of practice provides a clear path as operational safety assessments, if they wish to
for AV developers to begin trialling on public roads dictate requirements for AV safety in their market.
because it provides guidance on safe and lawful
operation without requiring additional permitting The US, with its complex network of local,
or an additional demonstration of safety. While state and national government regulations will
effective for promoting on-road testing, this find implementing such an operational safety
policy will likely be superseded following the Law assessment much more challenging. The federal
Commission review and the creation of the CAV government’s lack of standardized regulations will
PASS programme to allow for commercial services keep the door open for AV regulation at the state
to be launched. This will be further compounded level, but AV providers will not want to go through
by the public’s expectation that the government a different process for every state. As such, in the
will provide assurances of AVs’ safety through continued absence of a federal framework, regional
independent assessment. coalitions of states with similar requirements
may decide to work together to implement such
In the US, the combination of historical delegation assessments (e.g. western states, southern states,
of vehicle operator regulation to the states and the New England etc.).
lack of a federal statutory or regulatory framework
5.1 Opportunities
We’ve finally Approaches to AV regulation lack commonality Regulations, where implemented, are generally
gotten to a place between markets, and policies currently temporary guidance to enable testing. Even for
where we’re implemented are frequently intended to serve as Singapore, existing regulatory policies are interim
comfortable temporary guidance to promote innovation. One of solutions to facilitate trials and promote innovation and
to demand a the greatest challenges to AV regulators is that there development. AV developers will likely want to keep
demonstration of is no widely accepted measure of safety, in part light frameworks such as self-certification because
because AV developers are still determining exactly these impose minimal effort. However, it is too early
safer than a human
how to measure this themselves. These and other to create AV policies that can be considered “final”
driver, not just self-
gaps will present long-term challenges to public because the technology is continuing to evolve. Due
certification. acceptance of AVs, with citizens likely demanding to the technical complexity and knowledge required,
that AV players undergo independent, external coupled with a preference for minimal regulation by the
– City regulator
assessment to ensure that AVs are safe to use. AV industry, few governments have successfully
created a formal safety assessment for AVs.
There is no clear, objective milestone for Existing validation efforts have not yet been
when it would be safe to remove a driver. converted into implementable policy. There
While some markets allow driverless operation, are numerous efforts to create scenario libraries,
the exact requirements for this critical milestone technical standards and validation approaches for
are ambiguous and poorly defined at present, AVs. However, translating these into achievable
reflecting the nascent nature of the industry and policy is challenging, due to the technical complexity
the reality that AV companies are still in the testing of AVs, the evolving technology landscape and the
phase of development. challenge for regulators to engage on the technical
details of a system. While it may be premature to
AV companies must not compete on the basis of expect to develop a lasting policy solution for
safety. Safety is a shared goal, not a competition, AVs, more can be done to ensure the safety of
and regulators should seek to encourage active the public as testing and development continues.
cooperation with industry for safe development,
testing and deployment. This can be done in a Local governments want to ensure that their
number of ways, from funding research to creating needs will be met, but AV developers will push
test beds and pilot environments. for standard policy at the market level. An AV
that is safe to operate in one city may not be safe
In future, the public will expect assurance that in another, and local regulators will desire proof that
AVs are safe. As with other forms of transport, AV developers have considered regional differences.
citizens will expect some level of oversight to assure At the same time, AV developers will not want to go
them that AVs are safe to use. through extensive validation processes for every city
in which they wish to operate.
A scenario- A new policy approach, with a more proactive the same street should be held to the same standard
based assessment approach to safety assessment, should address of safety, regardless of the hardware that they use.
allows for a range each of the above pain points. Standardizing a new
of vehicles to approach across local and national governments Such an assessment should be focused on practical
be subjected to could reduce overheads for all stakeholders. Any exposure to naturalistic situations because the highly
successful AV policy should minimize burdens on AV complex nature of on-road driving is impossible to fully
the same test,
developers so they can focus on core technology account for in a deterministic, rule-based system.
which considers
development while also providing regulators with tools
AV’s behavioural to verify the safety of AV systems without extensive Such an external assessment could be beneficial
competencies in technical knowledge. This approach should also be not only to government regulators responsible
the context of its communicable to the public, because public trust in for assuring system safety, but also to additional
environment. AVs is critical to long-term AV adoption. stakeholders such as logistics companies that will
likely need to evaluate different AV systems when
The value of a scenario-based assessment they choose to implement autonomy at scale. It is
Every company developing AV technology uses a likely that AV developers will continue to see safety
different development process, hardware/software as a competitive advantage for the foreseeable
stack and safety metrics to evaluate system future, and therefore someone choosing to
performance. As such, an external assessment to purchase an AV system will be challenged to
evaluate multiple AV platforms will require a highly objectively choose between multiple options.
abstracted evaluation of a system’s behaviour, not
the performance of individual components. In simple A scenario-based assessment represents one
terms, this means that two different AVs operating on approach for this independent safety assessment.
– Designating a technically minded independent – Ongoing data collection during testing and
body with representation from the public post-deployment to ensure the relevance of the
sector, private industry, academia, traffic assessment and to address any missed scenarios
engineers etc. to develop and administer a or accidents that occur after deployment,
safety assurance programme improving the testing process over time
The Safe Drive Initiative seeks to establish a high- 3. The regulator is the sole party responsible for AV
level framework to enable a regulator to implement governance in its respective market or country
an operational safety assessment; the end goal is to
facilitate allowing AV companies to operate without 4. The regulator can assure AV companies that their
a safety driver. The SafeDI framework will provide a intellectual property will be protected
synthesis of the core technical knowledge required to
understand the validation process, and customize it to While this framework cannot provide a universally
the specific jurisdiction by identifying key steps, design prescriptive approach, it will offer high-level
choices and policy levers. guidance that local regulators can use to inform their
interactions with AV developers and policy decisions.
This approach makes the following assumptions: Regulators will also need to consider the nuances
of their political and geographic environments when
1. A regulator wishes to implement a more rigorous applying this framework.
validation approach than self-certification or a
code of practice In the spirit of its organizational mission to Improve
the state of the world, the World Economic Forum will
2. An AV provider has not conducted extensive continue to advocate for and encourage AV operators
testing in the deployment ODD within the to share knowledge and learnings on AV safety, to
regulator’s jurisdiction benefit the broader industry and the public.
Lead Author
Tim Dawkins
Project Lead, Automotive and Autonomous Mobility, World Economic Forum
This white paper benefitted from the input of many experts and diverse stakeholders who shared case
studies, insights and lessons learned through a series of interviews and conversations in 2020. We would
also like to thank our Safe Drive Initiative project community for their support and insights in the creation of
this document:
Claire Eagle
Principal Policy Officer, Greater London Authority