Written evidence submitted by Project 3 Mobility (SDV0033)

 

Introduction and company description

Project 3 Mobility (P3), a Rimac Group affiliated entity, is dedicated to developing developing a new urban Mobility as a Service (MaaS) ecosystem based on fully autonomous electric vehicles. Although headquartered in Croatia, our subsidiary in the United Kingdom, Project 3 Mobility R&D UK Ltd., is responsible for completing activities regarding vehicle development and assembly line development. The company is specialised in activities regarding design, scientific and technical engineering and technical testing. Founded in Wellesbourne, Warwickshire in February 2020, Project 3 Mobility R&D UK Ltd. was established in the United Kingdom due to its globally significant automotive industry, offering a wide range of highly skilled experts and professionals in the fields of e-mobility and autonomous driving.

The sustainability of the transport system has been in question for many years, primarily due to the number of traffic accidents caused by human errors, the impact of traffic on the environment, and the inefficiency of the time that the driver spends while driving a car. Autonomous driving has been recognized as the optimal solution to eliminate these deficiencies of the transport system.

To that end, the activities of Project 3 Mobility are focused on the research, development and production of new mobility vehicles and supporting infrastructure. The new mobility service will be based on the concept of Mobility-as-a-Service. This concept enables users to plan, book and pay for multiple modes of mobility services on one platform.

Completing the vehicle development activities will result in the development of a completely new autonomous electrical platform for vehicles without steering wheel, with an electric battery system and electric drive system. The mobility service application will enable user interaction with the vehicle and modification of vehicle functionalities. It will also enable Project 3 Mobility (in its capacity as the vehicle operator) to manage the fleet and infrastructure through it. The mobility service application would eventually be integrated with the public transportation system in each target city.

The implementation of our service into UK cities has the potential to bring significant improvements to traffic safety and efficiency. A positive impact on the environment will be achieved through decreased emissions from private internal combustion engine vehicles. The integration of autonomous vehicles with public transport will optimize passenger transport by facilitating multimodal trips. Taking the above into account, it is expected that car ownership will decrease, which will ultimately result in a positive impact on traffic congestion and the environment. Due to improvements in traffic safety, a reduced number of fatalities from traffic accidents is also expected.

As the result of the well-developed recommendations made by the UK and Scottish Law Commissions, we anticipate a progressive regulatory framework to be implemented in the UK, which is a major factor in our investments in the UK and early deployment in UK cities. Therefore, we fully support the efforts of HM Government and the UK Parliament to enable the development and deployment of autonomous vehicles through a comprehensive regulatory, legislative and safety framework. The promulgation of such a framework, which provides certainty for innovators and investors as well as the confidence of the public, would allow the safe commercial deployment of autonomous technologies and services and secure the UK’s long-term position as a leading market to develop and deploy the technologies.

 

Likely uses, including private cars, public transport, and commercial vehicles

Although autonomous vehicles are a trend across the automotive industry, most manufacturers are opting for private-ownership models exacerbating problems related to increased vehicle numbers on roads. To give an example in contrast, a study in Milan has shown that shared robotaxis can reduce traffic congestion. Assuming smart pricing strategies that achieve peak-shaving at 10%, a 33% acceptance rate among current car users and 9,500 robotaxis as an on-demand mobility service, the study showed that the number of vehicles can be reduced by at least 30%, thus drastically alleviating congestion. If the fleets are powered electrically, the introduction of this robotaxi fleet can also drastically lower PM emissions.

The main objective of the Project is the development of an innovative electric autonomous vehicle and a new urban public transport ecosystem. Developing a fully autonomous electric vehicle is fundamental for implementing a new urban public transport system, closely integrated with existing forms of urban public transport. We believe connecting an urban autonomous vehicle ecosystem with existing forms of public transport and the suburban railway will significantly optimize passenger transport and contribute to the reduction of the need for personal cars, especially of the less utilized second (city) car in the household. Rather than being in competition with public transport, the P3 autonomous service would be complementary to it, allowing customers to seamlessly bridge the first- and last-mile gaps that disincentivize the use of public transport.

The autonomous taxi services will offer a myriad of benefits beyond addressing deficiencies in the existing transport system. The MaaS model will aim to provide mobility options to local communities and individuals with difficult accessing public transport options. The services themselves will address mobility and access inequalities for groups with difficulties in using public transport, such as people with disabilities, more acute requirements and economic disadvantages.

The project will support delivery of an inclusive transport system, as set out in the 2018 Inclusive Transport and 2021 National Disability Strategies. This will be achieved by providing public authorities and transport companies with accessibility recommendations via the data produced during the deployment of CAV services, supporting cost-effective solutions. Providing specialist services and augmenting public transport capacity will also benefit councils' budgets and investments by enabling the reallocation of some infrastructure budgets to other priorities. Other positive impacts include contributions to carbon-reduction targets by introducing emission-free taxis, thereby improving air quality.

 

The regulatory framework, including legal status and approval and authorization processes

Project 3 Mobility applauds the comprehensive regulatory framework proposed by the UK and Scottish Law Commissions, and fully supports the intention of HM Government to develop proposals for legislation based on these recommendations and introduce them to Parliament in a new Automated Vehicle Act to deal with the profound legal consequences of self-driving vehicles.

These recommendations will be briefly summarized below, with a focus on new legal actors and new regulatory regimes, which will affect Project 3 Mobility as the owner and operator of a fleet of autonomous taxis.

In the absence of a human driver, the UK and Scottish Law Commissions recommend that three new legal actors – the Authorised Self-Driving Entity (ASDE), the User-In-Charge (UIC) and the No-User-In-Charge (NUIC) Operator – take on the responsibilities on the driver. The vehicle manufacturer or software developer of the AV, which will take on the role of the ASDE, must register with the authorization authority as the first point of contact in case of malfunction, will assume responsibility for the entire AV when it is driving itself on the road, and will be responsible for the entire AV when it is driving itself on the road, and will bear the brunt of any regulatory sanctions caused by a breach of road rules. The NUIC operator is an organization (as opposed to an individual) required to have oversight of the vehicle where a NUIC feature is engaged. Oversight does not require monitoring the driving environment, but the NUIC operator staff will be required to respond to alerts from the vehicle where it experiences issues that it is unable to deal with or where it is involved in an accident. Within the context of the service provided by Project 3 Mobility, it will perform the functions of both the ASDE and the NUIC operator.

The responsibilities of these new legal actors will need to be enforced through new regulatory regimes. The Law Commission therefore also made recommendations for the implementation of a safety standard against which all AV’s can be measured, which will inform three new regulatory regimes, to be established by a new Automated Vehicles Act:

P3 supports the introduction of these new legal actors and new regulatory regimes. As the owner and operator of a fleet of autonomous taxis, it would perform the functions of both the ASDE and NUIC operators, providing a service in an integrated way. To streamline regulatory approval for such partnerships, we support the intention of HM Government to explore the possibility of adding a third entity – a Combined Authorised Self-Driving Operator (CASDO) – for situations where the ASDE and NUIC Operator roles are performed by the same entity.

Aside from the aforementioned, P3 also supports the creation of a new road safety framework which will enable a new era of safe self-driving road vehicles, relating to elements such as, but not limited to: type approval, road safety contribution assessment, authorisation to self-drive, in-use regulation, overall safety of the vehicle fleet assessment, clarity of responsibility, and continuous learning. We particularly applaud the continuous learning concept, creating a flexible regulatory framework that simultaneously enables early deployment and testing of autonomous technologies at scale, while reaping the benefits of the data and learning produced by these early deployments to feed back into the authorization and approval schemes, as well as influence future waves of regulation.

 

Potential effects on patterns of car ownership, vehicle taxation and decarbonization in the car market

In addition to the benefits of an autonomous Mobility-as-a-Service platform which connects shared vehicles with public transport described above, another potential output of the Project will be the development a of a tailored transport model for each city to optimize routes and deployment opportunities of the services, building on the work already done to confirm key factors such as the minimum number of vehicles necessary to service the market. As the owner and operator of the service, P3 will have control over the number of vehicles being deployed and will use the project’s output to avoid excess vehicles entering the transport network. The study will also help to understand the social implications of the service’s deployment and allow P3 to develop relevant offerings for people who may otherwise struggle to use public transport options.

The transport model will allow both P3 and local authorities to understand the integration of the P3 operations with the existing transport infrastructure in UK cities and ensure a more successful, less disruptive, deployment of the service. This will facilitate a more targeted service offering and an increased expected revenue from the service.

The transport model generated will provide reliable data and improvements on several areas key to the MaaS market, allowing public transport to provide a more efficient and cost-effective service. This will enhance residents' access to socio-economic activities and improve quality of life, especially among groups with barriers to access such as disabled people. Stakeholder workshops will improve understanding of the needs of passengers facing such difficulties, with the aim to design specialized services. These services will align with the Taxis and Private Hire Vehicles (Disabled Persons) Bill by providing additional capacity rather than imposing burdens on existing taxis and PHVs that don't have the capability to respond to the changes.

 

August 2022