National body responsible for administering the safety assurance system (options 3 and 4 only) Flexibility and responsiveness ADSEs Commonwealth government State and territory governments and the National Heavy Vehicle Regulator National body responsible for administering the safety assurance system (options 3 and 4 only) Consultation question Has the consultation RIS captured the relevant individuals or groups who may be significantly affected by each of the options? Who else would you include and why? Multi-criteria analysis We use a comparative analysis scale to assign each option a rating against each impact category. Table 6 shows the scale we use to indicate an option’s comparative advantage or disadvantage compared with the baseline (option 1). Comparative analysis scale Very negative impact Negative impact Neutral Ambiguous / uncertain Improvement Large improvement The option would likely result in a large decline compared with the baseline option The option would likely result in some (limited or moderate) decline compared with the baseline option The option would likely have a negligible impact compared with the baseline option The option could result in an improvement or decline compared to the baseline option The option would likely result in some (limited or moderate) improvement compared with the baseline option The option would likely result in a large improvement compared with the baseline option We then test the validity of the outcomes of this assessment, by: examining outcomes against different deployment scenarios assessing the factors that would lead to a different preferred option. A provisionally preferred option is set out in chapter 7. This will be re-assessed on evidence gathered through the consultation process.
The administrative costs of option 1 are uncertain because there would be no defined standards for which an ADS would be assessed against. This would make the application process uncertain and potentially costly for industry. This uncertainty makes it difficult to judge whether the administrative costs for options 2–4 would be higher or lower than option 1. However, the safety assurance system provides an ADSE with a degree of certainty about the regulatory requirements, which option 1 does not. It is also unclear whether the administrative costs would be greater for option 1 with its uncertain requirements, or for the remaining options with their more certain requirements. In practice, the administrative costs may depend on how closely the assessment requirements under option 1 resembled those of the safety assurance system. Options 3 and 4 would provide a more streamlined administrative process than options 1 and 2 by removing the requirements to obtain ADR exemptions and individually register automated vehicles on a vehicle-by-vehicle basis. Under option 4, we expect that ADSEs, as duty holders, would incur higher administrative costs than under option 3. However, it is unclear whether the administrative costs under option 4 would be higher or lower than those of options 1 or 2. costs Delay costs are expenses and loss of income incurred because of an application and/or approval delay. We consider delay costs may be incurred by the ADSE. Option 1 provides less certain regulatory requirements than options 2–4, which involve safety assessment criteria under the safety assurance system. We consider that the increased certainty about what is required, for both the ADSE and those making the assessment, means ADSEs are likely to incur fewer delay costs under options 2–4. There is no reason to believe that delay costs would be significantly different between options 2, 3 and 4. Table 9 summarises the extent to which we consider each of the four options addresses regulatory cost to industry assessment criteria. Assessment of options against the regulatory costs to industry assessment criteria Option 1 Option 2 Option 3 Option 4 Results in low upfront and ongoing compliance, administrative and costs (partially criterion) Lowest (baseline) upfront compliance costs. Uncertain, but potentially higher ongoing administrative and delay costs (partially meets criterion) Higher upfront compliance costs but lower administrative and delay costs than option 1 (partially criterion) Higher upfront compliance costs and potentially lower administrative costs than options 1 Lower delay costs than option 1 Highest upfront compliance costs. Higher administrative costs than option 3 expected, but uncertain as compared against options 1 and 2 delay costs than option 1
compared with the baseline option compared with the baseline option compared with the baseline option Uptake of automated vehicles This option represents the baseline option The option would most likely result in a limited improvement compared with the baseline option The option would most likely result in a moderate improvement compared to with baseline option The option would most likely result in a moderate improvement compared with the baseline option Regulatory costs to industry This option represents the baseline option The option would most likely result in limited improvement (lower costs) compared with the baseline option The option would most likely result in a moderate improvement (lower costs) compared with the baseline option The option could result in an improvement or decline compared with the baseline option Regulatory costs to government This option represents the baseline option The option could result in an improvement or decline compared with the baseline option The option result in an improvement or decline compared with the baseline option The option could result in an improvement or decline compared with the baseline option Flexibility and responsiveness This option represents the baseline option The option would most likely result in limited improvement in flexibility and responsiveness outcomes compared with the baseline option The option would most likely result in a moderate improvement in flexibility and responsiveness outcomes compared with the baseline option The option would most likely result in a large improvement in flexibility and responsiveness outcomes compared with the baseline option Summary This option represents the baseline option Overall impacts: Moderate improvement compared to with baseline option Overall impacts: Moderate improvement compared to with baseline option Overall impacts: Large improvement compared to with baseline option The analysis is provided for consultation purposes, but the NTC acknowledges that there is a high degree of uncertainty due to a lack of clear evidence on which to base a number of these assessments. We are seeking additional evidence and will update the analysis in the final decision RIS. Our analysis that all of the reform options (options 2–4) resulted in overall benefits compared with option 1 (baseline option).