Autonomous systems, railway regulation and standards – In the pursuit of good questions?

1. Autonomous systems, railway regulation and standards – In the pursuit of good questions? Presented by Vaibhav Puri Head of Standards Policy

2. About RSSB RSSB is an expert body that delivers programmes of work on behalf of the rail industry across technical functions that cross rail interfaces in the areas of: Health and Safety Research Standards Sustainability Through research, the understanding of risk, and analysis, we provide an evidence base to support industry decisions and collaboration. RSSB’s membership includes infrastructure companies, train/freight operators, rolling stock owners and suppliers. It is non-profit-making and independent of any single interest.

3. Contents 1. The key principles of legal framework 2. The scope of legislation 3. The role of standards 4. Challenges for autonomous systems

4. Regulatory complexity that confronts a railway company HASAWA 1974 Project Entity Proposer ROGS2006 Transport Operator RIR 2011 Change Infrastructure Manager CSM-RA Railway Undertaking ASBO MHSWR 1998 TSI DEBO NOBO

5. Key fundamentals of the regulatory framework The law places obligations on legal entities responsible for performing a function in a certain context/scenario The obligations can be on parties responsible for • Designing, manufacturing and selling assets • Operating and maintaining the assets and performing related functions/activities • For regulating, supervising, enforcing and authorisation/approvals to be able to perform the functions or sell the assets

6. Objectives of legislation governing the railways • Facilitate cross-border train operations • Market opening for rail products and services • Harmonise approval process for authorisations and certifications • Harmonise Technical and Safety requirements

7. Scope of legal responsibilities Corporate reputation Duty as Corporate entity Duty as Employer Duty as Transport Operator Obligations as a project Example: Railway Interoperability Regulations 2011 Example: Occupiers’ Liabilities Acts ‘57 & ‘87 Example: Health & Safety at Work etc Act 1974 RGSs (National Rules) Railway specific NOT railway specific NOT railway specific

8. Scope of the Legislation CHALLENGE NO. 1:Does the description and boundaries of subsystems in law hinder progress towards autonomous systems? Railway Safety Directive 2004/49/EC Railway Interoperability Directive 2008/57/EC Railway system Railway Undertakings part of the system Infrastructure Maintainers part of the system Combined Subsystems Combined Subsystems Management System, including SMS Vehicles Network Management System, including SMS Subsystems Subsystems Subsystems CCS: All equipment necessary to ensure safety and to command and control movements of trains authorised to travel on the network Trackside Energy Trackside CCS Infrastructure Rolling stock On-board CCS On-board energy Operations & traffic mgt Maintenance Telematics applications Telematics applications Maintenance Operations & traffic mgt Subsystems IC IC IC IC IC IC IC IC IC IC IC IC IC IC IC IC IC IC Structural areas Functional areas Functional areas

9. What is expected of the rail system? Railway Safety Directive 2004/49/EC Railway Interoperability Directive 2008/57/EC Article 4(1) of the Interoperability Directive states that:The rail system, subsystems and interoperability constituents shall meet the relevant essential requirements. ‘Essential requirements’ means all the conditions set out in Annex III which must be met by the rail system…….. Annex III sets out the Essential Requirements: CHALLENGE NO. 2:Do the essential requirements hinder an autonomous system performing a function? • The electricity/thermal energy supply systems used must: • Enable trains to achieve the specific performance levels, • In the case of electricity energy supply, be compatible with the collection devices fitted to the trains Safety Technical Compatibility Reliability & Availability Health Env. Protection Accessibility

10. Beyond high level obligations – where do standards sit? The obligations are given greater granularity via European target system specifications (TSIs) and State imposed National Rules …but the above only address obligations to the extent necessary Additional measures are required to fully meet obligations: • Robust Risk Assessment and Management • Rule Based approaches via standards • Other acceptance principles Parties have other commercial and business obligations and objectives CHALLENGE NO. 3:Do the various specifications hinder progress towards autonomous systems?

11. CHALLENGE NO. 4:Specify functions and not who/what does it • ETCS transmits the information in the form of data but the train driver is still the one who controls the speed of the train based on the available information (albeit with ATP supervision) • How the trackside CCS system contributes to the information needed by the train to control its speed • Currently, the information is codified in the form of signal lights. • ATP removes the train driver but the train driving function is still the same

12. The scope and force and standards EC Regulationsinc. CSMs & TSIs UK Legislation – Acts and Regulations Imposed by law Railway Group Standards (RGS) National Safety Rules Imposed bylicence and law National Technical Rules Rail Industry Standards (RIS) SMS or contract Legal force European standards (EN) harmonised Rail Industry Approved Code of Practice (RACOP) Grant ‘presumptionof conformity’ Project standards Company standards European standards(EN) non-harmonised Voluntary observation British Standards (BS) Guidance Guidance Notes (GN) Project Company GB Network European Scope of Standards

13. The scope and force and standards

14. The scope and force and standards Mandatory Specified in TSIs / NTRs Voluntary Applicant chooses own specification CHALLENGE NO. 5:Standards can be developed which specify characteristics for autonomous to integrate or meet the essential requirements Company/ Project Standards Level of detail

15. Functional Operator/use Individual system • Human operated • Human assisted • Human delegated • Human Supervised • Mixed initiative • Fully autonomous System for systems Structural Manufacturer/design

16. Approvals/verification focus Manufacturer/design Operator/use A system for systems Structural Coordination/Integration/Supervision Nature of the system Functional Individual system

17. Improved understanding of what introduction of an autonomous system does Is there a shift/change in • Obligations • Functions • Impact in terms of scope or scale The boundary of the change may be wider than the component or the function CHALLENGE NO. 6:Understand the system wide impact of autonomous systems

18. Ability to monitor, supervise and intervene Is our operation sufficiently safe, or do we need to make a change? We have decided to change something affecting our operation; is the change sufficiently safe? CHALLENGE NO. 7:Can the party on which obligations are placed in the new railway system made up of autonomous parts, REASONABLY ANSWER THESE QUESTIONS?

19. The seven challenges • Does the description and boundaries of subsystems in law hinder progress towards autonomous systems? • Do the essential requirements hinder an autonomous system performing a function? • Do the various specifications hinder progress towards autonomous systems? • Do standards functions and not who/what does it? • Are standards being developed which specify characteristics needed in autonomous systems to meet the essential requirements? • Is there a full understanding the system wide impact of autonomous systems? • Can parties reasonably fulfil their monitoring & risk assessment obligations?

20. Thank you