How will the transport manager’s role change when fleets become automated?

For transport managers, automated vehicles might appear to promise a fairly obvious change: take the driver out of the equation and a large part of the transport manager’s job disappears with them.

The reality is likely to be almost the opposite.

The Automated Vehicles Act 2024 creates the legal framework for self-driving vehicles in Great Britain. As automated vehicles move into commercial fleets, transport managers are unlikely to become less important. Their role will change.

Instead of managing only drivers, maintenance and conventional vehicle compliance, transport managers are likely to find themselves increasingly responsible for the systems around the technology: when a vehicle can be deployed, whether it is fit to operate, whether its software and sensors are working properly, how warnings are dealt with and what happens when something goes wrong.

Automation may remove some of the driving task, but it does not remove the need for effective fleet management.

First: understand who is responsible for what

The new regime introduces some unfamiliar terminology, but the basic distinction is straightforward.

The Authorised Self-Driving Entity (ASDE) is the organisation legally responsible for the authorised self-driving feature and the way the vehicle drives when that feature is engaged.

That does not mean the fleet operator can simply hand responsibility for the vehicle to the technology provider. There will still be operational responsibilities around the vehicle and the way it is used.

There are broadly two types of automated operation.

With a User-in-Charge (UiC) feature, a person remains in the vehicle and can be required to take control. While the authorised feature is engaged, the UiC is generally not responsible for the way the vehicle drives itself. However, the UiC retains other responsibilities and must be able to respond when the system requires them to take over.

A No-User-in-Charge (NUiC) operation is different. The vehicle can undertake a journey without somebody inside who is expected to take over the driving. The 2024 Act provides for a separate licensing regime for operators overseeing these journeys.

Roadworthiness isn’t going away

The familiar parts of the transport manager’s role will remain. Tyres will still wear out. Brakes will still need maintaining. Loads will still need securing. Vehicles will still need inspecting.

But automated vehicles add another layer. Cameras, radar, lidar and other sensors may be safety-critical equipment. Their condition and calibration could determine whether the automated driving system can safely operate.

That means the defect-reporting system of the future may need to capture much more than a damaged mirror or worn tyre.

Worked example: the muddy sensor

An automated HGV returns to the depot in filthy winter conditions. A forward-facing sensor is heavily obscured by road dirt. The vehicle is scheduled to leave again at 5am.

Who checks the sensor? What constitutes an acceptable condition? Can it simply be cleaned, or does it require inspection or recalibration? Does a warning prevent automated operation? Who has authority to take the vehicle out of service?

Suppose nobody checks. The vehicle is dispatched and subsequently fails to detect another vehicle correctly.

The investigation will not necessarily stop at asking whether the automated driving system malfunctioned. Investigators are also likely to ask why the vehicle was allowed out of the depot in that condition in the first place.

That is classic transport-management territory.

Software becomes a maintenance issue

Transport managers are accustomed to preventative maintenance inspections and defect rectification. Automated vehicles introduce something less familiar: software maintenance.

A safety-critical software update may be every bit as important as a physical repair. Someone therefore needs responsibility for receiving update notifications, assessing their significance, ensuring updates are installed, verifying successful installation and preventing deployment where an outstanding issue makes operation unsafe.

That cannot simply disappear into the IT department.

Worked example: “We’ll update it at the weekend”

At 10am on Wednesday, the fleet receives notification of an important software update. The vehicles are busy. Somebody decides not to take them off the road and to install the update over the weekend.

There is an accident on Friday.

One of the first questions will be: what did the notification actually say?

If it identified an immediate safety issue, the decision to continue operating could become highly significant. The transport manager therefore needs a system for distinguishing routine updates from information requiring an immediate operational response.

Know where and when automation can be used

A vehicle being capable of self-driving does not mean it can lawfully operate as self-driving everywhere. The authorisation identifies the circumstances in which the relevant feature is authorised for self-driving use.

For a commercial operator, that can turn journey planning and dispatch into compliance issues.

Worked example: the wrong route

An automated HGV is operating on a motorway. A closure creates a substantial delay and the fleet planner identifies a diversion that will save 45 minutes.

But the alternative route would take the vehicle outside the circumstances in which its automated feature is authorised to operate as self-driving.

The fact that the vehicle might technically be capable of navigating the road is not the point.

The operator needs procedures ensuring that commercial pressure does not push automated vehicles beyond the limits within which they are authorised to operate autonomously.

Drivers will need different training, not less training

Where a user-in-charge remains in the vehicle, the driver is not redundant. Their role changes.

A UiC feature may issue a transition demand requiring the user-in-charge to resume control. Drivers will therefore need to understand when automation may be used, what they may do while it is operating, how a transition demand will be communicated, what the transition period means and what they are expected to do when one occurs.

Worked example: the ignored transition demand

An automated HGV is travelling on a motorway. The system identifies that it is approaching circumstances in which it cannot continue operating autonomously and issues a transition demand.

The user-in-charge does not respond. There is subsequently an incident.

The investigation is unlikely simply to ask: “Who was driving?” It may require a second-by-second reconstruction: when was the demand issued, was it properly communicated, when did the transition period end, what was the user-in-charge doing, had they been properly trained, and had there been previous failures to respond?

Transition-demand training and monitoring could therefore become an important part of fleet management.

Warnings and disengagements become management information

Transport managers already understand the danger of normalising defects. Automated fleets could create a new version of the same problem: normalising system warnings.

One vehicle repeatedly reports sensor degradation. Another regularly disengages automation at the same location. A third generates intermittent faults which disappear when restarted.

Individually, each event may look minor. Collectively, they may reveal something important.

The operator therefore needs an escalation system. At what point does an automated-driving warning become a fleet safety issue requiring the vehicle to be withdrawn, investigated or referred to the ASDE? The answer cannot simply be left to whoever happens to be using the vehicle that day.

When something goes wrong, preserve the evidence

Following a serious conventional HGV collision, operators already know the importance of preserving evidence. With an automated vehicle, the evidence base expands considerably.

An operator may need quickly to establish whether an automated feature was engaged, which feature was operating, whether a transition demand had been issued, the relevant timings, sensor condition, software version, system warnings, previous faults, maintenance history and the operational decisions surrounding the journey.

That evidence may be crucial to determining whether an incident arose from the way the automated technology drove the vehicle or the way the operator managed and deployed it.

Transport managers therefore need AV-specific incident procedures before the first serious accident occurs, not afterwards.

Operator licensing: some familiar concepts return

For HGV and PSV operators, one of the most striking features of the Automated Vehicles Act 2024 is how familiar parts of the new NUiC operator-licensing regime sound.

Section 12 requires the future licensing requirements to aim to ensure that a licensed NUiC operator is of good repute, of good financial standing and competent.

Those concepts will immediately be recognisable to anyone familiar with the existing operator-licensing regime.

The detail of the NUiC licensing system will be set out in future regulations, so it would be premature to assume that the new licence will simply replicate an HGV or PSV operator’s licence. But Parliament has deliberately created an operator-level regulatory role around driverless operation rather than treating the ASDE as the answer to every operational question.

What does the Act say about Traffic Commissioners?

The link with the existing operator-licensing world is even clearer when it comes to Traffic Commissioners.

Section 13(3)(e) of the Automated Vehicles Act 2024 expressly allows the Secretary of State, through regulations, to confer functions under the NUiC operator-licensing scheme on Traffic Commissioners. The Government’s Explanatory Notes say that this is intended to provide flexibility to align the regulation of licensed automated-vehicle operators with the regulation of conventional vehicle operators where appropriate.

The Act also goes beyond licensing functions. Paragraph 8 of Schedule 1 allows regulations to give Traffic Commissioners functions in relation to civil sanctions, including compliance notices, redress notices, monetary penalties and costs notices.

That does not mean that every automated HGV will automatically fall into a Traffic Commissioner regime identical to today’s goods vehicle operator licensing system. The detailed allocation of functions depends on future regulations.

But the direction is important: Parliament has deliberately built the possibility of Traffic Commissioner oversight into the automated-vehicle regulatory architecture.

Worked example: repeated warnings

An operator has ten automated HGVs. Over several months, one vehicle repeatedly generates warnings relating to its automated-driving sensors. The warnings are reported, but they disappear when the vehicle is restarted and no consistent action is taken.

Eventually the vehicle is involved in a serious collision.

Whatever the technical cause of the collision ultimately proves to be, the management question is obvious: did the operator have an effective system for identifying, investigating and acting upon recurring safety information?

If Traffic Commissioners are given functions under the new regime, that type of systems-and-controls question will be extremely familiar territory.

The transport manager of the future

Transport managers already operate through systems and controls. They make sure vehicles are roadworthy. They make sure drivers are competent. They establish defect procedures. They monitor compliance. They keep records. They identify problems and escalate them.

Automated vehicles do not remove that philosophy. They extend it.

• Authorisation: where and when can this vehicle actually drive itself?

• People: are users-in-charge and operational staff properly trained?

• Vehicle: are conventional components and automated-driving sensors properly maintained?

• Software: are updates, warnings and system faults properly controlled?

• Deployment: should this particular vehicle undertake this particular journey in these particular circumstances?

Far from reducing the importance of the transport manager, automation is likely to make the role broader, more technical and even more important than it is today.