It will still be a few years before we will have autonomous buses driving city streets and squares without drivers. On the other hand, it should be possible to have autonomous buses in a depot at an early stage in order to ensure more efficient maintenance of the vehicles when they are not in service, while at the same time learning how to be part of future operations. Such buses would be type-approved for manual traffic (SAE level 0-2), but not approved for autonomous road operation (SAE level 4-5). During the span of a single day, the bus will therefore alternate between the regulations for enclosed (fenced depot) and non-enclosed (road) areas, between being autonomous and not autonomous.

The bus, which was previously a legal “static whole”, will now instead be tested based on two regulations depending on the environment it is in at any given time and level of autonomy. This is a completely new situation: that a bus is “dynamically divisible” from a regulatory perspective, which has significance in terms of who shall decide whether the vehicle is safe to use in a certain environment.

After analysing the challenges based on existing regulations, interviewing relevant authorities, arranging workshops with various stakeholders and meetings with experts in certification, our conclusion is that, in order to be considered safe in autonomous mode within the depot, the bus should be self-certified by means of CE marking according to the Machinery Directive1. This is the authors’ conclusion and not necessarily representative of the other parties involved in the project.

We predict that we will see more self-certification of autonomous vehicles in the future. Partly because there are such large international markets working in this way, such as in North America, and partly because it enables faster market introduction of dynamic vehicle concepts. With “dynamic vehicle concept” we mean vehicles that gain new areas of application by replacing the chassis or changing software settings and are thus converted from a bus to a truck or from a car to quadricycle. Maybe even several times a day.

Self-certification, however, will also increase the need for standardisation, both for processes and products. Processes may involve how a vehicle can be certified, particularly how the risk analysis should be carried out. In terms of products, standardised descriptions of the technology’s function will facilitate proprietary self-certification since operators know how to describe their own products, including how their certification should be structured based on the constituent certified components. Current regulations will also need to be updated if more vehicles are to be self-certified, such as the Machinery Directive.

Lastly, we would like to communicate the method used to reach our conclusions. The project has been carried out as a Policy Lab where we have brought together various stakeholders around a common challenge. This has enabled us to concretise both the challenge of autonomous vehicles within the enclosed area and our conclusions. The  method selected has also given relevant authorities the opportunity to familiarise themselves with how they should relate to tomorrow’s technology without having to present a view on how they will relate to a specific test or vehicle. In this way, Swedish authorities will be ready to adopt technical innovations once they are introduced to the market.

This report is structured so that Section 2 describes the current regulatory framework, particularly in terms of the distinction between the Machinery Directive and vehicle type-approval. Section 3 uses specific examples to describe business operations pertaining to autonomous buses in a depot. Section 4 presents the authors’ conclusions based on how the regulations relate to the specific details obtained from the depot pilot. Section 5 presents the full picture by relating our conclusions to what is happening internationally and how the national ordinance on autonomous vehicle trials on roads corresponds to international trends. Lastly, in Section 6, we provide a summary of what we consider to be the most important issues for which further work should be carried out.