Under normal circumstances, the terms automated driving systems (ADS) and artificial intelligence (AI) sound off alarm bells for the general public because they represent a venture into the unknown.

In the student transportation world, however, we sit at the intersection of safety and technological improvement, so as these concepts continue to be discussed, concern over usage of these technologies is elevated as vehicle manufacturers get closer to implementing these cutting-edge applications in the real world.

Right now, we see automatic braking and collision avoidance systems being deployed in passenger and commercial vehicles. These technologies enhance the driving experience by coming close to eliminating some human elements that can cause motor vehicle collisions.

So the questions arise: can or will automated driving systems eliminate the need for drivers in the commercial vehicle space?

Integrating Automation Technology in School Transportation?

Recently, the National School Transportation Association (NSTA) filed comments in response to a filing by the Federal Motor Carrier Safety Administration (FMCSA) entitled, “Safe Integration of Automated Driving Systems (ADS)-Equipped Commercial Motor Vehicles (CMVs).”

If you are of the mindset that that driverless vehicles are a sci-fi concept that likely will not come to fruition in our lifetime, you’ll be surprised to see FMCSA’s response to being asked whether amending the safety regulations to establish a regulatory framework for ADS-equipped CMV operations makes sense at this time.

In its filing, the agency confirmed timing is correct and stated:

“ADS developers are actively engaged in the development, testing, and limited deployment of ADS-equipped CMVs, and promoting their use in commercial motor carrier operations.”

The agency added: “To mitigate potential safety risks associated with in-service use of ADS-equipped CMVs, FMCSA is developing an appropriate regulatory framework.”

As a quick backdrop to this acronym heavy discussion, the Department of Transportation previously adopted SAE International's definitions for the levels of driving automation. The six levels of automation range from Level 0 (driver support features but no driving automation) to Level 5 (full driving automation), and this request for comments centered around Levels 4 and 5.

As FMCSA noted: “The focus of this notice is Level 4 and 5 ADS-equipped CMVs, because it is only at those levels that an ADS can control all aspects of the dynamic driving task without any expectation of an intervention from a human driver.”

Concerns About Unproven Tech and Student Safety

NSTA comments to the agency voiced concern that overall ADS technology appears largely unproven at this time, and we want to ensure that, when deployed, ADS technology proves capable of interacting with the start and stop patterns of school buses.

In our comments, NSTA said:

“At this stage, it remains crucial during this part of technological development that the Agency continues to recognize the importance of Automated Driving Systems-Equipped Commercial Motor Vehicles (ADS-CMVs) being functionally able to clearly identify and properly interact with school transportation vehicles.”

In addition, NSTA highlighted the fact that school buses operate routes that include frequent stops with students entering and exiting our vehicles. As such, school buses are equipped with flashing amber and red lights along with stop signs that alert other motorists of pickup and drop off activity, and these lights signal the need for other motorists to stop their vehicles.

NSTA emphasized that ADS-CMVs must be able to recognize these lighting systems and properly engage when school buses stop to pick up or drop off student-passengers. Additionally, ADS-CMVs must be able to detect the presence of school children around the perimeter of the bus at pick up and drop off. Illegal passing of school buses is already a top concern for student transportation providers, this technology only heightens that caution.

Clearly, there is much ground to cover before we reach the point where these regulations would need to be implemented, and currently these technologies remain a work in progress. NSTA sees our role not only as a monitor of these changes so that we can inform our members, but also as a strong advocate on behalf of all yellow bus operators for the greatest safety standards through all evolutions of commercial motor vehicles.

I believe we agree that these technologies can be embraced, but only if adequate safeguards protecting our student-passengers can be assured.

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