UCTE is concerned about the recent announcement by Winnipeg Airport Authority to test driverless snowplows.  We wrote to the Minister of Transport Canada to express our concerns.  Below is the text from the letter we sent to the Minister.

October 23, 2018

Dear Minister Garneau,

As you may recall, the Union of Canadian Transportation Employees (UCTE), represents members at most federally regulated airport across Canada.  The recent announcement by the Winnipeg Airport Authority (WAA) to test driverless snowplows has raised some concerns.

Of primary concern is the safety of the travelling public and our members.  Autonomous vehicles are still in their infancy.  Companies such as Uber and Toyota have removed their driverless vehicles from the road and onto private property.  Recent reports of fatalities in North America demonstrate the need for strict regulations over its use. 

Similarly, we are concerned about WAA’s claim that the testing will be used in “low-risk areas”.  If it is within the definition of an aerodrome, any element of risk is too high to take with public safety.  

While a robotic snowplow can certainly move snow from one location to another, we have concerns that technology is still not up to standard for working within the conditions of a Canadian winter.  Some concerns include:

• GPS plotted routes –This technology is already implemented in a multitude of areas at Canadian airports. The fact remains it is not perfect and can never be made perfect.  GPS technology is exact for when everything is stable and constant however there is nothing constant when human beings are involved.  If technology alone could guarantee safety, then there would not be on average 350 runway incursions per year. 
• snow sensory deprivation – cameras or sensors can easily be covered-up by snow;
• snow sensory obfuscation for the remote controller – falling snow and glare can play tricks with sensors as well as distort any images as a result of snow on camera lenses.
• cold temperatures impact technology – much of the testing of driverless snow plows have been done in ideal winter conditions. There is concern that the sensory devices are vulnerable to the cold.

We need to remember that human snowplow operators do not just remove snow.  They are an extra set of eyes and ears on the ground at Canada’s busy airports.  They monitor the entire scope of runways, note other problems or potential dangers and can adapt to sudden changes in the weather conditions.  They provide an extra layer of security to ensure safe transportation.

Likewise, WAA asserts that the testing will be conducted consistent with “Transport Canada’s- regulated safety management system (SMS)”.  SMS is strictly dependent upon the service provider to maintain standards.  Currently there are no standards around driverless vehicles either within Civil Aviation Regulations (CARs) or TP312.  We do note that Transport Canada has set testing standards for trial organizations.   Your document entitled Testing Highly Automated Vehicles in Canada:  Guidelines for Trial Organizations, although a start, does not address issues around federally-regulated entities such as airports and rail yards.  We recommend that the government implement similar standards within TP312. 

For all of these reasons, we ask Transport Canada to review the testing and use of driverless snowplows at Canada’s aerodromes.  UCTE is not against innovation however the implementation needs to be done while maintaining the safety of the travelling public at all times.  At this moment in time, we believe that the technology is not up to the standards required to safely test at Canada’s airports.

Sincerely,

Dave Clark

National President