Re: Proposed Amendments to…

Re: Proposed Amendments to Ontario Regulation 306/15: Pilot Project -
Automated Vehicles and Revised Regulations of Ontario 1990,
Regulation 628: Vehicle Permits – Summary

Regarding the topic "6) Develop a pilot framework for the testing of automated micro-utility devices", I have two points or alternative suggestions to be considered regarding related topics on the original text published at

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1-) "A 10 km/hr maximum speed on sidewalks and a 20 km/hr maximum speed on
shoulders of roads or bike lanes;"

Remarks:
- I believe that the proposed speed limit would be too arbitrary for a too wide range of situations. For a downtown core in a populous area, 10Km/h is simply too much/too risky, especially for a 100Kg+ machine competing with a kid or anyone with a fraction of the machine's weight and accrued momentum/energy.

- Since the situations are too varied and complex to enclose in a few words of a single provincial standard, possibly the redaction could state the maximum speeds and introduce that the Municipal opt-in would govern that in the by-laws as well. Possibly Cities will choose certain areas to allow for pilots or even create areas in which pilots can evolve in complexity while keeping safety up starting in sandbox environments with restricted pedestrian access, to less crowded areas, like collector road sidewalks or farther urban clusters to then move to highly population-dense/downtown cores.

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2-) "Mandatory operator oversight, capable of creating a safe stop;"

I also believe that the redaction here could be that but with a provision that the City can govern different setups in its by-laws. Tele-operation has a wide range of situations with different implications for the operational envelope. For example, there are dramatically different risks associated with two extreme use-cases: a small robot just traversing a block for delivering a parcel or a 120Kg robot crossing a street in a given intersection. Two wildly different situations. Also, the supervision done by a supervisor in the field is completely different from oversight from an operator or supervisor present at the location in which the robot is operating.

Again, the spectrum of situations is high to enclose all of them in a single redacted provincial-level doc.

I am inclined to believe that operator oversight is a big a requirement when

Best regards,

Joel.