I have previously drawn attention to the impact of Digital Navigation (DN) of travel behaviour. The providers of this service, commonly known as satnav, respond to requests from users by providing routing options and journey times that take account of prevailing traffic conditions. Here I want to consider how this is achieved.

There is only fragmentary published information on how the routing algorithms function. It appears that a model of travel behaviour on the road network is constructed from trip data derived from users of the navigation service: trip origins, destinations, routes through the network, time of day/week, prevailing traffic conditions, journey times. Such a model may be analogous to a microsimulation model, but using observed trip data rather than synthetic data. It could also be viewed as combining the trip generation, distribution and assignment stages of the standard four-stage transport model (the mode split stage not being relevant for committed road users seeking routing advice).

Providers of DN offer predictions of journey time in advance of setting out. Comparison of predicted and outturn journey times provides a check on the validity of the model. Machine Learning has been employed to improve the accuracy of journey time predictions of Google Maps.

The type of model developed by DN providers is novel and powerful in that it can utilise huge amounts of trip data, both real time and historic. A question is whether such models could be used to inform decisions on road investments and other interventions aimed at improving experience on the road network. That is, could the DN models replace conventional transport models for planning purposes?

The DN models already exist. Their cost of construction and operation is met by the income generated from sales, whether of direction services to business premises (e.g. Google Maps) or to vehicle manufacturers that fit DN as standard equipment (e.g. TomTom). So, the cost of using these models for planning purposes could be less than for building and using conventional models.

TomTom offers Origin Destination Analysis as a service and may therefore be open to suggestions for use of the underlying model for planning purposes.

Another possibility would be to create an open-source, crowd-funded DN model – a kind of not-for-profit version of Waze, a provider that encourages user input. The funders might be road authorities that would gain access the the underlying model for planning purposes.

A further possibility arises from the likelihood that some form of electronic road user charging will be introduced, as electric propulsion replaces the internal combustion engine, to replace revenue from fuel duty. This is likely to involve technology similar to DN, and might therefore be the basis of traffic modelling for other purposes.

DN is both changing travel behaviour and generating new travel models to inform public policy. We may be at the beginning of a new era of travel and transport analysis.

I post a blog a few months ago about the Office of Rail and Road (ORR), which was consulting on its involvement in the third road investment strategy (RIS3). The outcome of this consultation was recently announced.

I had responded to the consultation, suggesting that the ORR should take an interest in the benefits of road investment as experienced by road users, since there was doubt about who mainly benefited, local users (commuters and others) or business users. My contribution was published by the ORR, anonymously, as ‘Response from member of the public D’ (I would have been happy to be named, but was not asked).

In its detailed response to the consultation, the ORR responded to my suggestion at paragraph 3.7, saying that it is not within its remit. It is unusual for an industry regulator to take no interest in the consumer experience. This is a central concern for the regulators of other industries – energy, water, telecoms, financial services.

The ORR also ducked out of accepting other suggestions for extending its responsibilities, including in relation to other important government objectives such as Net Zero and Levelling Up. The detailed critique of the Transport Action Network (page 78 of the ORR response document) is well worth reading.

Altogether, the ORR is a pretty feeble regulator in respect of roads.

The House of Lords Built Environment Committee is carrying out an inquiry into public transport in towns and cities. I was invited to submit written evidence, which is now published.

My conclusions:

For public transport in towns and cities to be improved, the share of car travel needs to be reduced, to lessen both competition for passengers and road traffic congestion.


To reduce car use, better public transport is needed, which requires both local government to take overall charge of services and to have a sustainable source of funding beyond the farebox.


There are no new technologies that will make much difference.

I have a new article published in a peer reviewed journal:

Metz D. The impact of digital navigation on travel behaviour. UCL Open: Environment. 2022;(4):05. https://doi.org/10.14324/111.444/ucloe.000034

Abstract

Digital navigation – the combined use of satellite positioning, digital mapping and route guidance – is in wide use for road travel yet its impact is little understood. Evidence is emerging of significant changes in use of the road network, including diversion of local trips to take advantage of new capacity on strategic roads, and increased use of minor roads. These have problematic implications for investment decisions and for the management of the network. However, the ability of digital navigation to predict estimated time of arrival under expected traffic conditions is a welcome means of mitigating journey time uncertainty, which is one of the undesirable consequences of road traffic congestion. There is very little available information about the impact of digital navigation on travel behaviour, a situation that needs to be remedied to enhance the efficiency of road network operation.

An article in Local Transport Today of 13 June broadens the consideration.

The Department for Transport (DfT) has started planning its third Road Investment Strategy (RIS3), a five-year investment programme for the Strategic Road Network (SRN) for the period 2025-2030. The approach is conventional – a programme of projects, with little overview of how societal objectives will be advanced by the likely substantial expenditure. Yet there are five major issues that need to be addressed for the programme as a whole.

First, there is a need to reconcile the government’s Net Zero objective with the carbon emissions from both the tailpipes of the additional traffic arising from increased road capacity and the embedded carbon in the cement, steel and asphalt used in construction. Recent presentations by the DfT’s Transport Appraisal and Strategic Modelling (TASM) division indicated an intention to tackle this issue at scheme level, but this is misconceived. What matters is the overall contribution of RIS3 to carbon emissions and how this is to be offset or otherwise justified.

Second is the question of how RIS3 advances the government’s Levelling Up agenda, where the recent, well-received White Paper identified twelve medium-term ‘missions’ to be pursued across all departments. The one specific to transport states: ‘By 2030, local public transport connectivity across the country will be significantly closer to the standards of London, with improved services, simpler fares and integrated ticketing.’ Although the rate of progress implicit in ‘significantly closer’ is vague, the direction of travel is clear and the objective is not in dispute.

There is no mention of investment in the SRN in the Levelling Up White Paper. This is appropriate since there is, if anything, an inverse relation between the performance of the road network and economic prosperity across the nation, given that delays on the SRN due to congestion are greater in London and the South East than in other regions of England.

The implication of the White Paper approach is that there should be a substantial switch of DfT funds from road investment to improve public transport beyond London, if the Department is to play a full role in supporting the government’s the Levelling Up agenda. Yet the Department’s recently issued Levelling Up Toolkit is essentially a pro forma for a box-ticking exercise aimed at justifying investments already forming part of agreed expenditure programmes. There is palpable inconsistency here.

Third, we have the problem of the safety of smart motorways. These require conversion of the hard shoulder to a running lane as an economical means of increasing capacity without the expense of rebuilding bridges. Generally, new roads are safer than older roads, which meant that adding road capacity yields a modest safety benefit. But this is not obviously the case for smart motorways, and there has been considerable pushback from the public and the House of Commons Transport Committee. As a result, the DfT has paused the roll out of new smart motorways until five years of safety data is available for schemes introduced before 2020. A decision on the generic safety of smart motorways will be an important factor in developing RIS3.

Fourth, and less recognised, there is a question about the economic benefits from additional road capacity. There are two published evaluations of smart motorway schemes where the traffic flows after opening were very different from those that had been forecast. For the M25 Junctions 23-27 scheme, the traffic flowed faster one year after opening but subsequently delays reverted to what they had been before opening on account of greater traffic volumes than forecast. For the M1 J10-13 scheme, traffic speeds five years after opening were lower than before opening. Since the main economic benefit of road widening is the saving of travel time, both schemes had negative benefit-cost ratios (BCR) at outturn.

Examination of the reports of the traffic and economic modelling of these two schemes showed substantial time-saving benefits expected for business users, offset by a small amount of increased vehicle operating costs (VOC) arising from additional traffic volumes. There were also time savings to non-business users (for commuting and other local travel) but these were entirely offset by increased VOC – because these were local trips that rerouted to the motorway to save a few minutes of time, at the expense of additional fuel costs.

The scope for rerouting local trips to take advantage of increased motorway capacity is likely to be underestimated in modelling. Local users have the flexibility to vary routes whereas long distance business users will stay on the motorway unless there is a major holdup. Moreover, the general use of digital navigation in the form of Google Maps and similar offerings makes choice of minimum time options commonplace.

Even when the outturn total traffic flows are a reasonable match to those forecast, the scheme economics could be much worse than predicted if there is more local traffic, and hence less long distance business traffic, than projected. Traffic and economic modelling involve recognition of different classes of road user with different values of travel time: cars, LGVs, HGVs, business, local commuters, and other local users. However, the monitoring of outturn traffic flows does not distinguish between these classes of users. GPS tracking make such distinctions possible.

The DfT has emphasised the importance of evaluation of outturns of investments. Yet the failure to appreciate the need to break total traffic flows down into the segments that had been modelled reflects a serious professional shortcoming. As a result, we cannot be at all confident that investments to increase SRN capacity do more than facilitate rerouting of short trips by local users, of nil economic value. Likewise, we do not have the kind of detailed evaluation data that would allow traffic models to be better calibrated for future use.

The fifth issue for RIS3 is that the widespread use of digital navigation by drivers prompts questions about the continued focus of DfT and National Highways on major civil engineering expenditure. Contrast the aviation sector, where new runways or terminals are occasional efforts, not regular business. The main focus of airlines and air traffic control is to improve operational efficiency, to sweat the assets employing the techniques of operational research. We have a mature road network in Britain. It’s time to focus on operational efficiency. Yet it seems not to occur the National Highways that working with Google Maps, TomTom and other providers of digital navigation services would be a cost-effective means of improving the performance of the network.

More generally, the DfT is trapped in its box labelled Transport Analysis Guidance (TAG), a thousand pages of prescription to which more text is added when some new issue or policy arises, such as Net Zero, Levelling Up, inequalities or gender. The task for those promoting a scheme is to tick all the boxes and flex the modelling to generate BCRs that represent good value for money. Evaluation of outturns is inadequate to distinguish between success and failure.

Although the DfT pays lip service to the need to think at the strategic level, the TAG framework does not facilitate this in that the detailed analysis is at project level. Other interested parties do not challenge the Department’s approach. The consultants and local authorities do not bite the hand that feeds them. The professional societies, institutions and think-tanks do not engage. The National Audit Office carries out good analysis of road investments on occasion, but not systematically. The Office for Rail and Road scrutinises the management of the SRN, including how well new investments are delivered, but does not see its role as enquiring into how investments benefit road users. This is quite unlike the regulators of other infrastructure industries – electricity, gas, water, telecoms – that are focused on how consumers benefit from investment.

The DfT is stuck in its box and seems unlikely to break out. The best bet for a strategic view of RIS3 may come from the National Infrastructure Commission, which has begun the development of its second National Infrastructure Assessment. The Commission’s advice was the basis of the government’s £96 billion rail investment programme for the North and the Midlands. This required fresh thinking about the benefits of transport investment at the level of the whole programme, an approach clearly needed for RIS3.

This blog post formed the basis of an article in Local Transport Today of 25 March 2022.

The House of Lords Environment Committee is carrying out an inquiry into public transport in towns and cities. I was asked to provide a submission, as follows.

The scope for public transport in cities and towns depends importantly on the level of car use, both because the car competes for passengers and because car traffic impedes the progress of buses, lessening their attractiveness.

The car is the dominant means of travel in Britain and other developed economies. It offers efficient door-to-door travel over short to moderate distances where traffic congestion does not lead to unacceptable delays and where parking is available at both ends of the journey. Public transport does not offer an attractive alternative to most car drivers in these circumstances. However, in urban areas where congestion causes delays and where parking is costly and limited, alternatives to car travel become attractive. To grow public transport use in towns and cities, it is necessary both to improve bus and rail services and constrain car use.

Urban travel and traffic

It is necessary to recognise that our availability of time always constrains the amount we can travel. There are many activities that we need to fit into the 24 hours of the day, and on average we spend just an hour on the move. This limits the build-up of road traffic congestion, which arises in areas of high population density and high car ownership where there is not enough road space for all the car trips that might be made. If traffic volumes grow for any reason, delays increase and some potential car users make other choices. We may change the timing or route of a car journey, or the travel mode where there are alternatives available, or a different destination such as an alternative shopping centre, or not to travel at all, for instance by shopping online.

Road traffic congestion is therefore self-limiting. We know from experience that we cannot build our way out of congestion by adding road capacity, since this allows previously suppressed car journeys to emerge, restoring congestion to the previous level. Conversely, if urban road space is taken away from cars in order to create bus or cycle lanes, then initially congestion will increase. But the additional delays will induce some car drivers to make alternative choices and congestion will revert to what it had been. The overall impact of reducing urban road space is to reduce the share of journeys by car.

Accordingly, it is difficult to reduce the intensity of traffic congestion, but it is possible to reduce the amount of congested traffic by reducing road space available to general traffic, which can be publicly acceptable if alternatives to the car are provided. This is what has been happening in London over many years, as the population has grown, as there has been large investment in public transport, and as there has been a reduction in road space available for cars. Private transport use fell from 48% of all trips in 2000 to 37% in 2019, while public transport use grew from 27% to 36% over the same period. Cycling increased from 1.2% to 2.4% while walking held steady at 25%. The London Mayor’s transport strategy, published in 2018, ambitiously aimed to cut private transport use to 20% of all trips by 2041.

Creating cycles lanes reduces the space available for cars but in itself it does not get people out of their cars. Copenhagen is a city famous for cycling, with 28% of journeys made by bike. Yet car traffic is only slightly less than in London. Aside from cycling, the other big difference is that public transport accounts for only half the proportion of trips compared with London. The experience of Copenhagen indicates that we can get people off buses onto bikes, which are cheaper, healthier, better for the environment and no slower in congested traffic. Yet buses are an efficient way of using road space to move people in urban areas, with diesel engines being replaced by electric or hydrogen propulsion to cut carbon emissions. We would like to get drivers out of their cars onto bicycles, yet this has proved difficult, even in Copenhagen, a small flat city with excellent cycling infrastructure and a strong cycling culture.

Looking across a range of European cities, we find very diverse patterns of journeys by the different travel modes, reflecting, history, geography, size and population density. But we do not find cities with high levels of both cycling and public transport.

Policy options for towns and cities

British cities tend to have lower population densities than European counterparts on account of our preference for low-rise housing with gardens; this means that public transport is harder to deliver cost-effectively. British cities vary considerably as regards use made of public transport. Two otherwise seemingly similar cities, Brighton and Bournemouth, have very different shares of commuting by public transport – 23% and 7% respectively. Nevertheless, there are two broad policy options available to all towns and cities, for local decision:

  • whether to push back the cars to increase street space for engagement by those on foot, with active travel and public transport as the alternative to the motorised mobility, as successfully implemented in London;
  • or whether to accommodate car travel, as has been the practice in the past and as remains popular with many residents.

Pushing back the car requires improving the public transport alternative. Urban rail is fast and generally reliable, but costly to implement. It can provide an attractive offering, as for instance London’s Overground, created from existing underused tracks, and Nottingham’s tram network where an extension was financed from the proceeds of the local Workplace Parking Levy. Bus Rapid Transit on dedicated traffic-free routes is a less costly alternative to new rail, for example the Cambridgeshire Guided Busway. Buses on roads with general traffic, whether in bus lanes or not, offer a less attractive alternative to motorists – a chicken-and-egg situation.

Integration of public transport across the modes increases its attractiveness, as do the innovations adopted in London, including cashless ticketing with daily or weekly capped charges, and extensive real-time information about services available through mobile phone and other devices. The ability of city regions to take responsibility for public transport, on the London model, will be an important means to improve public transport where adopted.

The recent well-received Levelling Up White Paper identified twelve medium-term ‘missions’ to be pursued across all departments. The one specific to transport states: ‘By 2030, local public transport connectivity across the country will be significantly closer to the standards of London, with improved services, simpler fares and integrated ticketing.’ Although the rate of progress implicit in ‘significantly closer’ is vague, the direction of travel is clear and the objective is not in dispute. However, as well as devolving relevant responsibilities to city regions, it will be necessary to allocate additional funds on a sustainable basis. The experience of relying on private sector bus companies has shown that a high level of service cannot be sustained by commercial financing.

It would be worth considering the example of the French ‘versement transport’, a hypothecated urban regional payroll tax levied on the total gross salaries of all employees of companies of more than 11 employees, which was originally intended to raise capital for investment in local public transport infrastructure, but is more and more used to cover its operating expenses.

New technologies

There are four new technological developments affecting road transport:

  • Electric propulsion, being adopted for buses, eliminates tailpipe emissions of pollutants and carbon, but does not otherwise change the nature of the service.
  • Digital platforms are having a big impact on retail businesses. For transport, booking of rail and air travel has been transformed. Ride-hailing, exemplified by Uber, has made a major impact on the taxi business. There have been trials of Demand Responsive Travel whereby smartphone apps are used to book a trip on a minibus that operates a flexible route to meet demand, but the economic viability of this mode is not yet generally established.
  • Digital navigation, typified by Google Maps’ routing recommendations, is changing how the road network is used, but is not relevant to buses on fixed routes.
  • Vehicle automation may offer the prospect of driverless buses, but whether this would be feasible in city traffic is far from clear, as is the cost of the technology and the support it might need. Driverless trains are possible on systems constructed for that purpose, such as the Docklands Light Railway, but an attendant rides on every train to oversee safety and security.

In short, it seems unlikely that public transport will be transformed by new technologies.

Summary

For public transport in towns and cities to be improved, the share of car travel needs to be reduced, to lessen both competition for passengers and road traffic congestion.

To reduce car use, better public transport is needed, which requires both local government to take overall charge of services and to have a sustainable source of funding beyond the farebox.

There are no new technologies that will make much difference.

The Department for Transport’s National Transport Model (NTM) was first constructed two decades ago and has subsequently undergone a number of phases of development. The main function of the model has been to provide projections of travel demand as the basis for justifying investment in the road network. The model has also been used to project future carbon emissions, to inform the Department’s Transport Decarbonisation Plan, as well as to explore the impact of technological developments such as electric vehicles.

An account of the latest version, effectively a new model known as NTMv5, was released recently in the form of a 250-page ‘Quality Report’, oddly, two years after completion. NTMv5 is a spatially detailed conventional four-stage transport model structure, iterated so that congestion feeds back into demand. The model has been implemented using the standard commercial software, PTV Visum. The intention is that the model should be transparent to external stakeholders, a very welcome development given the opacity of previous versions of the NTM. The complexity of the model means that a single run takes around ten hours, with a number of iterations needed to achieve convergence of outcomes.

However, there are some notable limitations to the model. There is no detailed treatment of public transport capacity. Car ownership data derives from a separate model, which has not been updated. And the primary source of growth of travel demand is the DfT’s National Trip End Model data set that projects expected changes in demography and land use, which are problematic of account of uncertainty of economic growth, population growth and distribution, and planning policy.

A number of potential applications of the model have been identified, of which the most immediate is the preparation of new national road traffic forecasts. Also recognised is a need to project future transport carbon emissions, and for the analysis of packages of road schemes at national level, including value for money.

The purpose of the succession of NTM versions has been to support the traditional ‘predict and provide’ approach to road investment. This viewpoint persists in the latest version where the stated rationale for analysis of packages of road schemes is to identify ‘gaps in the network… where the road capacity in future may be insufficient, leading to unacceptable rises in congestion and journey times.’ (section 2.4.2). Yet we do not adopt that approach when considering urban roads, and the scope for enlarging peri-urban motorways at acceptable cost by converting the hard shoulder to a running lane is now problematic on account of public concerns about safety. Besides, the scale of induced traffic has been persistently under-estimated in traffic modelling, so the aim of avoiding unacceptable congestion seems naïve, even before addressing the Net Zero objective.

The model builders struggled to treat the complexities of urban traffic. It was accepted that a full link-based modelling of urban road capacity and related journey time responses could not be achieved, and therefore a simplified approach had to be applied. This involves assuming general fixed speeds on urban networks for the Base Year, which were reduced over time based on assumed growth of demand. (sections 4.7 and 11.4). This simplification has implications for projections of traffic in London, as recognised by the peer reviewers.

Peer Review

The DfT has published a Peer Review and an Audit of NTMv5. The 120-page peer review, led by the seasoned practitioners John Bates and Ian Williams, drew attention to a number of apparent shortcomings in the methodology (too technical for me to appreciate sufficiently to offer comment). These led to counterintuitive results when sensitivity tests were run, notably for London.

The reviewers advise caution in application of the model, primarily due to the focus of the NTMv5 being on the more strategic highway network, whereas many of the potential applications focus on urban travel policy and public transport interventions. In particular, the reviewers are critical of the treatment of urban traffic, observing that the assumed relation between traffic speed and demand growth lack validity, and that the range of policies aimed at reducing urban car use are not taken into account. Besides, it is noted that the DfT’s car ownership model has not recognised that ownership in dense urban areas has been declining for many years in response to increasing population density, notwithstanding rising incomes.

The reviewers find that for London, the model results are not convincing. The observed car (driver + passenger) trip mode share is 38% from the National Travel Survey in 2015/16, whereas that in the model in 2015 is 50%. Moreover, the model projects a future gain of car share, whereas over the period 2005-16 a major decline of 5.6% was observed (para 4.3.5). The reviewers concluded that the model could not be safely used to examine policies that relate specifically to London, and query whether this relates more generally to rapidly growing dense urban areas across England. They took the view that the model should be suitable for use in forecasting the growth of road traffic in most areas other than those adjacent to or within major urban areas (section 6.3.24), which is a pretty major qualification.

Audit

The 260-page audit of NTMv5, carried out by consultants Arup and AECOM, drew attention to a number of shortcomings in both documentation and substance, including that some of the model components and tools used to process the data are not owned by the Department, which limited access to some of the key processes and data used in model development – not consistent with the aim of transparency to external users. The auditors advised that users of model outputs should be cautious because of problems in reaching convergence to a stable outcome as the model is run through repeated iterations, a concern also of the peer reviewers.

What next?

The NTM documents recently published are two years old. No doubt, further development of the model has been taking place to respond to the issues raised in peer review and audit. In its Transport Decarbonisation Plan published last July, the DfT stated its intention to review the National Policy Statement on National Networks, the basis of strategic planning of road and rail investment, and to update the forecasts on which it is based. NTMv5 will presumably be used for this purpose. Yet the modellers will be stretched to meet the divergent needs of their client policy makers, between bullish forecasts of travel demand to justify continued infrastructure investment and bearish projections of transport carbon emissions. Given the uncertainties of the model illuminated by peer review and audit, it will be hard to be confident about the validity of carbon forecasts out to 2050 and 60-year investment appraisals.

While the DfT’s intention to make NTMv5 available for use beyond the Department is praiseworthy, this seems problematic in practice. Doubtless the large transport consultancies could master the software and data, but given their complexity, clients would need deep pockets to fund the work. That would rule out non-government bodies that might want to challenge particular schemes. Regional transport undertakings have their own bespoke models. I am not aware of any academics who would be likely to buy into the NTM, a situation unlike national energy modelling where government and a substantial group of university researchers work with the same model. The DfT would be well advised to support academic researchers and others wishing to use NTMv5 to explore a range of policy scenarios.   

This blog was the basis for an article in Local Transport Today of 11 March 2022.

The Law Commission has recently completed a review of the law relating to automated vehicles. The review had been requested by the Centre for Connected and Autonomous Vehicles, which reports to the Secretary of State for Transport. This was the first occasion in which the Law Commission had been asked to develop legal reforms in advance of future technological development. The government’s aim is to avoid regulatory barriers that might impede innovation while managing potential risks of harm.

The review process involved three rounds of consultation that fruitfully engaged a wide diversity of interested groups. It was a good example of how the need to capture policy intentions in legislation generates close scrutiny and clarification of the issues involved. The 300-page report is comprehensive, except that it does not consider V2V connectivity for AVs, a slight surprising omission given who commissioned it.

Because an automated vehicle (AV) will be able to drive itself for at least part of a journey, there are profound legal consequences. The human driver can no longer be the principal focus of accountability for road safety. Instead, new systems of safety assurance are needed, both before and after vehicles are allowed to drive themselves on roads.

The legal framework has to cover self-driving functions where a user has to be able to take over control when the vehicle cannot cope, for instance in poor visibility, as well as for more advanced automation when the AV is able to cope under all conditions.

The Law Commission proposes three new legal actors:

  • Authorised Self-Driving Entity (ASDE) – the vehicle manufacturer or software developer who puts an AV forward for authorisation to the regulator.
  • User-in-charge – the human in the driving seat while the vehicle is driving itself.
  • NUIC operator, responsible when there is no user in charge, to navigate obstructions and deal with incidents.

There will need to be regulators for new functions:

  • Vehicle type approval of an AV.
  • Authorisation of automated functions.
  • In-use safety regulation.
  • NUIC operator licencing.

The proposals of the Law Commission will need to be enacted in legislation to have effect. The government’s intention is to make the UK an attractive place for the deployment of AVs, even though the main development of the technology is taking place in the US, where there is considerable diversity of regulatory regimes across the states. However, the comprehensive legal framework may deter some prospective developers.

Ride-hailing operators such as Uber might hope to save the costs of the driver, but would need to own the vehicles and accept responsibility as the NUIC operator for oversight of operations, and possibly also to be the ASDE. This would be a large and costly change from the current capital-lite business model.

Tesla’s approach to automation has been to incorporate the hardware into existing privately-owned vehicles and to improve the software over time to get to the point of implementing what is being marketed as ‘Full Self-Driving’ capability. Taken literally, this would require Tesla to be licenced as a NUIC operatory, with oversight of its whole fleet of vehicles on the road.

Developing vehicle automation for general deployment is proving more difficult than the pioneering technology optimists had hoped. As well as getting the technology to the point of being publicly acceptable, there is an evident need to develop viable business models consistent with the expected regulatory regime.