MACS response to the law Commission issues paper on remote driving


The Mobility and Access Committee for Scotland (MACS) is a non-departmental advisory public body.  Within the founding legislation the Scottish Ministers have defined the overall aim for MACS as follows:

“MACS will consider such matters relating to the needs of disabled persons in connection with transport as the Committee think appropriate and give advice to Scottish Ministers”

MACS Strategic Remit

  • To give Scottish Ministers advice on aspects of policy, legislation and practice affecting the travel needs of disabled people.
  • To take account of the broad views and lived experiences of disabled people when giving advice.
  • To encourage awareness amongst disabled people in Scotland of developments, which affects their mobility, choices and opportunities.
  • To work closely with SG and ensure our work programme complements the work being undertaken by the Inclusive Mobility and Transport Committee (IMTAC), the Disabled Persons Transport Advisory Committee (DPTAC), the Scottish Human Rights Commission, the Equality and Human Rights Commission (EHRC) and other organisations, voluntary and statutory.
  • To promote the travel needs of disabled people with designers including transport planners and operators so that these are fully taken into account in the development of vehicles and infrastructure (including the first and last mile) and delivery of services.
  • To monitor and evaluate the effectiveness of our work against the above aims and objectives in improving travel opportunities for disabled people in Scotland. 

As well as engagement with disabled people and collaboration with key stakeholders MACS takes opportunities to provide advice and guidance through using what we have heard and what we have learned and our shared knowledge within the Committee to respond to relevant consultations. We believe that the issues paper on remote driving fits within this scope.

Remote Driving – Issues Paper Questions

Q1: Do you agree with the following tentative definitions?

  1. A driver is an individual who performs all or any of the following tasks: 


    (a) steering (lateral control);

    (b) braking, removing a brake, or accelerating (longitudinal control); or

    (c) monitoring the driving environment with a view to responding to objects or events by exercising lateral or longitudinal control (provided that this activity is safety critical).

  2. A remote assistant is not a driver if they do not exercise direct longitudinal or lateral control, but only advise an automated driving system to undertake a manoeuvre.
  3. For the purposes of this project, a “remote driver” is a driver who is outside the vehicle and who uses some form of wireless connectivity to control the vehicle (covering both in or beyond line of sight).

MACS would agree with this definition in relation to a ‘remote driver’.

Q6: We have identified that any system to regulate beyond line-of-sight driving needs to consider the following:

  1. the adequacy of the communication network;
  2. cybersecurity;
  3. workstation layouts;
  4. staff training;
  5. staff health, fitness and vetting;
  6. staff attention and rest periods; and
  7. incident protocols.

Apart from the above, are there any additional challenges to consider?

  1. specify that regulation 104 is satisfied if the driver of a special vehicle has a view of the road ahead through a screen, provided that appropriate steps have been taken to ensure safety;
  2. specify that regulation 107 is satisfied by remote supervision, provided that the user has taken appropriate steps to prevent interference with the vehicle;
  3. make any exemptions contingent on the user obtaining written consent from the road authority to use the vehicle on a particular road; and
  4. permit trials and demonstrations with a commercial element to them?

MACS welcomes the value of new technology in helping to remove many of the daily barriers that disabled people face and the introduction of remote driving may introduce opportunities for some disabled people, and this is very much welcomed.

In terms of challenges / queries, MACS have the following comments to make;

  • Thinking about the technology and remote communication systems - Would there be anything within the legislation to preclude individuals who have certain conditions being employed in this field; for example individuals whose first language is British Sign Language?
  • A person who is classed as a ‘disabled driver’ currently – would there be anything within the new legislation preventing this person from being employed as a remote vehicle driver?
  • Referring to remote driving on roads in Great Britain from outside the UK, MACS would have concerns about operators not fully understanding the Highway Code; for example there may be different rules regarding the different types of crossings we have in Great Britain.  Would operators know the rules in relation to uncontrolled crossings where pedestrians step out onto the crossing etc?
  • Linked to this, how safe would some members of our communities be - for example Deafblind individuals - if they were unable to detect the vehicle whilst crossing the road – this is already an issue with Electric Vehicles where there is little or no noise.