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, (partially (partially (partially Highest administrative and criterion) meets criterion) upfront costs criterion) compliance Lowest Higher upfront costs. (baseline) Higher upfront compliance upfront compliance costs and Higher compliance costs but potentially administrative costs. lower lower costs than administrative administrative option 3 Uncertain, but and delay costs than expected, but potentially costs than options 1 uncertain as higher ongoing option 1 compared administrative Lower delay against and delay costs than options 1 and costs option 1 2 delay costs than option 1
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
safety_assurance_for_automated_driving_systems.docx