Aeravai Autonomous Electric Road and Air Vehicle Association of Ireland Submission www.gov.ie/en/consultation/15a35-public-consultation-on-connected-and-autonomous-mobility-in-road-transport/
Name REDACTED
Organisation name: Aeravai Autonomous Electric Road and Air Vehicle Association of Ireland
Question 1. What are the overarching guiding principles that should inform the roll-out of CAM in Ireland?
Road safety should be the number one priority with the goal being to eliminate road deaths, with human error being one of the biggest causes of road deaths in Ireland.
Connected and autonomous mobility technologies will bring about enormous improvements in traffic management and will improve journey times a major cause of daily mental health distress.
CAM will be crucial in the adoption of MaaS (mobility as a service), shared mobility, and improvements in public transport provisions not just in urban areas but also to improve rural transport provisions which have been neglected.
CAM should be used to reduce the cost of transport which is a huge financial burden to both the state and individual citizens.
Question 2. What do you see as the main areas that should be included in a national CAM strategy?
CAM technologies will have huge social and societal benefits that must be realised by politicians, planners, industry, and the general public.
We need a national education campaign for the general public and industry on the social benefits of CAM’s.
Connected and autonomous mobility technologies will not just be for improving traffic and transport but improvements but will help with improvements in our environment and in our health and mental health.
Redeployment, retraining, upskilling, and compensation scheme for displaced professional drivers.
Question 3. In your opinion, what strategic goals should Ireland adopt for CAM? What are the outcomes to be achieved?
Eliminate road deaths and accidents.
Reduction in traffic.
Speed up journey times.
More efficient use of infrastructure.
Reduction in the national fleet.
Improve Public transport.
Make MaaS and Shared mobility more feasible.
Reduce the cost of transport.
Improve our environment.
Improve the quality of life.
Improve the domestic economy.
Improve rural Ireland connectivity.
Question 4. What do you see as the greatest opportunities associated with CAM in Ireland? How can the Government facilitate these opportunities?
We need public education programs like the one the RSA currently runs on the benefits of CAM and how we could eliminate road deaths and accidents from a quick adoption of it. CAM will reduce human error accidents and reverse the public perception that it is socially acceptable to lose millions of citizens globally and thousands here due to car accidents.
The government should consider CAM-only vehicle lanes on motorways and urban settings as soon as possible. This will encourage the adoption and deployment of CAMs.
CAM and AI traffic management will help eliminate the majority of human-caused traffic. Just one Autonomous vehicle has been proved to improve traffic conditions
CAM will allow increased speeds and improve journey times and because it is much safer than human-controlled vehicles increased speed limits should be prioritised on motorways 200kph+
More efficient use of road infrastructure CAM vehicles will make it possible to handle more vehicles on our roads in a smaller amount of space, stopping the extra lane traffic issue that has plagued motorway expansion here in Ireland and globally.
Tax incentives should be used to help adoption like with the incentives used for EV adoption at the moment and should be completely import duty, VRT and VAT free.
Should the price of this vital safety equipment be regulated by the EU or Irish government with controls in place for anti-monopoly practices?
Reduction in the national fleet is needed. There are currently over 2million cars in Ireland and most of them sit doing nothing for 90% of their life. This is a complete waste of resources and has damaged the environment. The production of this fleet of CAM vehicles will make MaaS mobility as a service, car share, and shared mobility more feasible.
CAM vehicles will reclaim the urban realm back from parked cars.
Reducing the cost of transport CAM will allow the cost of transport to be shared more fairly
CAM will Improve our environment by reducing the number of vehicles on the road.
CAM’s will Improve the quality of life. At the moment uncontrolled human-directed traffic is having detrimental effects on our health and mental health and could be eliminated with more orderly control of traffic and transport.
Improve the domestic economy.
Improve rural Ireland connectivity.
Industry leaders in CAM technology have indicated that they are willing to share their technology. Should new vehicles be allowed to be sold without this safety technology? Should it be compulsory with all new vehicle sales? We wouldn't allow a car to be sold without seatbelts and airbags now, would we? A deadline for new sales of unequipped Vehicles should be set along with this technology being a requirement of all road-legal vehicles. This should happen as soon as possible to prevent further deaths.
Question 5. What do you see as the main barriers to the development and deployment of CAM in Ireland? How can the Government best address these barriers?
The current government's main transport strategy is to invest in 20th-century public transport solutions without considering what the general public desires. This will result in poor use of public funds and it is suspect if it will achieve the desired goals.
By excluding CAM in public transport strategy which the NTA (National Transport Authority) has done to date under the mistaken belief that CAM technology will not be deployed in the near future, despite many submissions to public consultations and world events indicating otherwise. Ireland's public transport could be obsolete before delivery of current major investment plans making it further less desirable to use, at huge financial cost to the taxpayer and Citizens further disillusioned with transport provisions thus causing further detrimental health and mental health of the Nation that is currently not being considered by planners and authorities satisfactorily.
Lack of transport or lack of access to transport is a major mental health concern due to loneliness and isolation which is so bad for your health. It's the equivalent of smoking a pack of cigarettes every day! This is not just in Rural areas that get most of the press but suburban and Urban isolation is a cause for concern as well due to poor availability or cost of Transport being a contributing factor to mental health decline in cities.
The NTA has not been in contact with international experts and it is very unclear if they currently employ any themselves on CAM’s but I agree with you that this is an incredibly important area that is often overlooked. You can find Dr. Rebbca Posner’s paper that summarises the work that was conducted here: https://trl.co.uk/uploads/trl/documents/Mental%20health%20and%20transport_0.pdf
It is quite a lengthy report on research aimed to understand how mental health could impact travel mode choice and explore the factors that influence or are barriers to accessing certain modes of transport and how these vary across different forms of mental health difficulties.
Prof. Roger Mackett, a visiting professor at University College London has also conducted work in this area you can find his initial study here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/662737/report-on-mental-impairments_final.pdf.
We also conducted some work last year on behalf of the Department for Transport to expand the current guidance on the accessible public realm. A stream of this work focused on this wider range of mental health difficulties experienced in England - you can find all of that research here: https://www.gov.uk/government/publications/accessible-public-realm-updating-guidance-and-further-research.
Most recently in Ireland a survey for Transport Infrastructure Ireland found that more than half of the women it spoke to said they would not use public transport after dark or late at night. The report entitled Travelling in a Woman's Shoes found that 34% of women stated that the feeling of being unsafe has on occasion stopped them from going out altogether. The study conducted last year says 33% of public transport users have seen or experienced some form of harassment or violence while using public transport. The report says that staying safe is a top priority for many women while traveling every day. It says a single incident often has a lasting impact.
I did ask the NTA what if any considerations it has?
In answer to your question, the NTA has not carried out any mental health surveys with regard to transport planning and future needs.
The Accessibility on Public Transport Survey that you mentioned below was sent out to over 290 User Groups nationwide including organisations for Mental Health. This was the first time that the NTA compiled a survey like this and it was to try and get general feedback from a wide range of groups rather than specific elements.
There have been surveys on the Accessibility in Transportation carried out by the Irish Wheelchair Association but I am unsure if any organisations for Mental Health have carried out any previously on behalf of their members.
The NTA contacted many User Groups (including Mental Health Ireland, Mental Health Reform, Grow, and Jigsaw) for Bus Connects with details of how to attend the webinar events on it and how to make submissions on behalf of themselves or their group.
Transport Infrastructure Ireland (TII) is running Metro Link. They are asking people to register their interest at
https://www.metrolink.ie/#/contribute
This allows people to be informed on the progress of the various stages but also to make submissions too.
Kind Regards,
NTA REP
Question 6. What do you see as the greatest risks associated with the roll-out of CAM in Ireland? How can these areas of concern be mitigated?
The greatest risk is delay or slow rollout! Every day it’s delayed it will cost further lives and make daily life more stressful and cause further damage to the environment from producing cars that are not needed.
Redeployment, retraining, upskilling, and compensation schemes for displaced professional drivers need to be planned for and mitigate any further distress of workers during the inevitable transition so social unrest within the industry could and should be avoided.
Question 7. What do you see as the most pressing issues to be addressed in the immediate term (as opposed to a medium-term or longer-term perspective)?
Allowing and encouraging deployment to date there has only been one public deployment in Ireland with the general public planners and politicians still very uneducated on the coming technology. We need a public education program like the one the RSA currently runs on media and educates the overall social benefits of CAM on Irish roads.
Ireland is following the UNECE direction which is now woefully out-of-date to the detriment of deployment in Ireland. We should consider withdrawing from the agreement to follow the directive if it is not updated this year to encourage more international companies to locate in Ireland for CAM deployment.
Question 8. Any additional comments
There is currently a concerted effort to mislead politicians and the general public about the development and deployment of Autonomous Vehicles. Some in the Irish media and consultants in traditional public transport are heavily dependent on car ownership and the advertising revenue that comes from it and outdated 20th-century transport proposals. It may be directed by some of the existing car manufacturers who advertise with them who are extremely worried about declining car sales, saying Autonomous vehicles are decades away. Even some competitors within the Autonomous vehicle industry are agreeing to go along with this false narrative because their own technology may be inferior to others. It's from the same playbook from some in the media with vested interests against the electric car which they successfully delayed by decades! Think General Motors and the EV1, now some vested interests are trying to do the same with Autonomous vehicle deployment. One manufacturer Tesla has proved them wrong about the deployment of electric cars and is about to do the same with their CAM-capable fleet that will have huge social benefits and will make many who are unprepared face reality like a ton of bricks.
Tesla's FSD "feature complete" (Fully deployable in the real world) as the company calls it is much closer to happening than most people realise due to the misinformation campaign against Autonomous vehicle deployment. We can't let this misinformation campaign continue! There are huge social benefits to come from the deployment of Autonomous Vehicles with the potential to save millions of lives. We need to replace the entire vehicle fleet with electric, that's a given now. We're finally winning the war against the electric car! But do we need as many vehicles? The answer is clearly NO we don't! The current fleet of cars we have sits doing nothing for 90% plus of its life and it's also a huge financial burden many simply just can no longer afford! The whole car loan industry PPP is dysfunctional and warnings are coming from regulators. Cam’s will make Shared mobility more feasible and will replace the current ideology of car ownership. The traditional view of having to own a car is slowly coming to an end. Tesla intends to be the world leader of MaaS & shared mobility and when FSD is feature complete it will launch its Tesla Network similar to Uber/Lyft combined with CarSharing except for no driver upfront and when it is up and running current Tesla owners with FSD will be able to share their car and make money from their car, making it a revenue-earning asset rather than money pit that most current cars are and normally only functional for a small amount of its lifetime wasting and stealing so much of our space from the urban realm being parked cars. We could reduce the number of cars on our roads by quite a significant amount, up to 75% of our current fleet of cars are simply not needed! It's no wonder the traditional motor industry is terrified. Some of them are already selling their cars at near cost and depend on income from finance and parts. Volkswagen's (VW) CEO is so scared he thinks VW may go the same way as Nokia! A better comparison though would be what the mobile did to landline telephones. Autonomous CAM’s vehicles will help our Health and Mental Health. Autonomous vehicles will be electric by default. They will reduce air pollution, they will reduce the cost of travel. They will reduce the stress of traveling and will help alleviate both suburban and rural isolation. With so many places not covered by public transport, Autonomous vehicles could and should be the future of public transport! The societal and environmental benefits are huge and we can't let vested interests deny us this much-needed technological advancement as they did with the electric car.
Aeravia, Autonomous Electric Road & Air Vehicle Association of Ireland.
Please accept recommendations for the Public consultation on the government’s Road Safety Strategy 2021-2030. It is my hope you will put all of these proposals to the minister of transport of the day.
This is a brief outline of what I think should be the goals of the Road Safety Authority for the next 10 years with all of them to be implemented at the earliest possibility.
more detail can be added to this at requested
Public Consultation on the Development of the Government’s Road Safety Strategy 2021–2030
Traffic and unnecessarily long journeys is detrimental to health and mental health.
Traffic and unnecessarily long journeys has been proven to be detrimental to health and mental health and should be considered the number one priority and is actually the number one concern for everyday road users in their daily life and quality of life.
AI (artificial intelligence) traffic management control systems (AMCS)
All traffic to be controlled, directed and managed by a State run AI (artificial intelligence) traffic management control systems (AMCS)
All data & metadata controlled by the state.
All data and metadata to be controlled by the state and monitored by the data protection commissioner and all data collected by private companies compulsorily handed over to the states traffic management control systems (AMCS).
Fastest possible journey times and recommended opening times
With recommended journey times for individuals for traffic free journeys via app on phone with provisions for those unable to use mobile phones. Shops, schools and workplaces having to follow recommended opening and closing times to reduce traffic.
Real-time GPS trackers onboard all vehicles.
All vehicles to be compulsory be connected to the (AMCS) for real-time display in all road-legal vehicles. Real-time GPS trackers onboard all vehicles including personal mobility vehicles bicycles and E-scooters. Bringing the vehicle registration display into the 21st century.
Driver license log in.
Smart driver's license should be logged into all manually controlled vehicles to start the ignition and before departure with only a valid license being able to start the manually controlled vehicle.
(too many disqualified drivers have continued to drive illegally with many causing deaths this is preventable with this technology)
Driver license review
With a review of the suitability of driving manually conducted at least every 5 years. With this decision being made by the previous manual driving. The current one-off driving test for the suitability of driving should be reviewed.
All road-legal vehicles to be Autonomous capable by 2025.
We should aim to have all road-legal vehicles autonomous
All vehicles to be compulsory level 4 or level 5 autonomous vehicles.
All current EV’s are actually autonomously capable upgradeable with the use of additional devices such as the one from www.comma.ai
A published timetable for Motorways and tunnels to be fully compulsory electric vehicles and Autonomous asap.
An incentive to convert all vehicles to electric would be to ban ICE internal combustion engines petrol, diesel, and hybrid vehicles from motorways and tunnels.
All speed limits should be reviewed to accommodate for Autonomous Vehicles.
Motorways could have speed limits increased to 200+kph when Autonomously controlled.
Public education program.
Public education program on road technology and the benefits to health, mental health, and society in general of such technology as (AMCS) and Autonomous vehicles. via media and social media like current education programs.
Ireland should set an example for the EU & UNECE to adopt.
Rather than Ireland just following EU & UNECE road directives we should also try to set an example for the EU & UNECE to adopt from our example for them to follow Ireland's example.
Traffic to be put underground vehicle tunnels and pedestrianization in urban centers.
As much city to outer suburbs traffic should be put underground and traffic to be removed from city centers and put underground as much as possible. Pedestrianisation should be prioritised and considered for all urban centers. With drones and tunnels used for stock deliveries.
Cycling infrastructure to be prioritised over vehicle traffic.
With best international practice followed with completely separate cycle lanes.
The disabled community and our older population to be prioritised.
People with disabilities and our older population to be prioritised with door-to-door services.
Overweight and obese citizens should be encouraged to walk a medically recommended amount before being offered free public transport or private transport.
Public transport nationally to be free at the point of use paid for through general taxation.
Car ownership to be discouraged and car-sharing programs to be both state-run
and private operators. The Car remains unused for 95% of its lifetime and is a complete waste of precious resources and is a financial burden to many.
All vehicles to be electric.
The damage to the environment should be considered in the Government’s Road Safety Strategy as there is plenty of evidence that road traffic pollution is contributing to a number of deaths every year including causing extra deaths by helping covid19 spread on pollution.
Basic insurance to be nationalised
CTP (compulsory third party insurance) With 1 in 13 drivers in Ireland now driving uninsured (illegally) and the private motor insurance industry price-fixing making basic third party insurance unaffordable for many, It's time to nationalise third party insurance and incorporate it into the motor tax system with private insurance companies only responsible for fully comprehensive insurance.
All HGV’s to be banned during the hours of 7:30-19:30 in urban areas.
All HGVs over a certain weight should be banned during the daytime hours of 7:30am till 19:30pm in built-up urban areas to many children and cyclists have been killed by HGVs.
All professional vehicles and HGVs to have cameras and black boxes onboard
All professional vehicles and HGVs to have full 360 visibility and cameras and a black box onboard for recording and playback.
Óglaigh na hÉireann our Irish Defence Forces should store and maintain a sufficient and adequate supply of completely electronics-free buses and emergency vehicles with enough people trained to use said vehicles for emergencies for use, in the unlikely event caused by either a natural or man-made disaster or attack on the country such as a solar storm or EMP attack on the country, that would render all electronic vehicles unusable that will provide emergency care for the whole country and its total population.