The Queensland Government has opened an inquiry into road safety and vehicle modifications, it closes on 15 April.
- Remote vehicle engine immobiliser technology, which has been lobbied by Queensland Police Union to remotely control and slow vehicles involved in high speed pursuits, in order to combat youth crime; and
- Vehicle modification reform in order to improve options for vehicle modification standards, including ADR and national alignment, which has been lobbied extensively by ARMA and 4WD Queensland Association, as well as many other recreational motoring groups and after-market associations.
This correspondence is aimed to inform you of the Government inquiry and seek you provide input / engage to the Queensland Government, as both of these items affect the future of vehicle modifications, not only in Queensland, but across Australia.
Vehicle Modification Regulations:
Australian Recreational Motorists Association (ARMA) and 4WD Queensland Association have been lobbying federal and state governments for several years, in order to improve vehicle modification options for our motoring communities, and allowing modifications to be undertaking against any Australian Design Rule / Australian Standard, as long as the modifications comply and are appropriately certified by an approved auto-mechanical Chartered Professional Engineer (CPE).
For example, a brand new vehicle can be modified and certified “pre-registration” against the ADRs using the federal Second Stage Manufacturing (SSM) process. However, installing the exact same modifications on the exact same type of vehicle “post-registration” is most likely impossible, as the state / territory vehicle modification regulations prevent this; the only difference is whether the modifications are installed and certified before or after the vehicle is first registered; this is a bureaucratic issue.
Additionally, the current National Code of Practice (NCOP, aka VSB-14) only allows a maximum increase in 4WD ride height of 150mm, comprising of 50mm tyre diameter (25mm lift), 75mm of suspension, and 50mm of body blocks. These measurements are explicitly set and are mandatory across all MC category post-registration 4WD vehicles, regardless of each vehicle’s size. This one-size-fits-all standard causes a lot of issues within the 4WD community, and if law enforcement inspects a vehicle which is slightly over these mandatory limits, it will be defected as a Type 2 Illegal Modification under the anti-hooning legislation. This issue only exists with post-registration vehicles, as SSM / ADRs do not impose set limits on ride height. Approved auto-mechanical CPEs should be able to certify increased ride height limits as needed, to meet a vehicle owner’s requirements, and maintain safe, practical and affordable framework for modifications… i.e. limits should be variable as required.. 100mm tyre diameter (50mm lift), 70mm of suspension, and no body blocks.
If the Queensland / Australian post-registration vehicle modification standards are too restrictive and don’t allow motorists to undertake the modifications people want in a safe, practical and affordable manner, then people will bypass the certification processes entirely, and purchase cheap (and sometimes) counterfeit products from overseas for their vehicles, which puts other road users at risk, as many of these imported products are inferior and do not meet the standards Australians want. The current cost for Electronic Stability Control (ESC) testing for modified ESC equipped 4WD vehicles is in excess of $15,000 per assessment, as state regulators mandate a steering-robot must be used to assess the ESC, and don’t allow alternate testing methods, so people bypass the testing and certification, and fit their cheap components anyway.
The Australian post-registration vehicle modification regulations and certification processes need to be remodelled in a fashion that brings the motoring community’s requirements and automotive after-market industry experience together in order to provide safe, practical and affordable modification and engineering processing, in order to drive post-registration vehicle modification regulations. It should have a mechanism for CPE to operate against other Australian and International standards, a mechanism for appeal, and should be reviewed often by all stakeholders.
Remote Engine Immobiliser Technology:
The Queensland Police Union have been pushing for the mandatory introduction of remote engine immobilisation technology to be fitted to all new cars, enabling police officers to remotely shut down the engines or de-activate throttles of vehicles involved in high-speed pursuits. This is certainly a concept that has good merit, however there are considerable issues with the proposed technology and implementation strategy.
Firstly, ADR 82/00 – Engine Immobilisers (8 August 2006), only covers engine immobilisers as an anti-theft mechanism, it doesn’t cover any type of remote control to vehicle subsystems. To enable remote access and management to every vehicle’s engine / throttle management system across Australia, every single vehicle must have a communications link of some form, to a central management facility, in order for the vehicles to be tracked, and for an authorised operator to send a specific vehicle the necessary code to de-activate throttle control.
In brief, this presents many questions:
- Vehicles need to be connected to a communications link 100% of time for the technology to be effective;
- Communications networks must be secured, to prevent unauthorised access;
- The monitoring and operational control centre must also be secured from Internet hacking;
- The CAN Bus and OBD2 have no security mechanisms, they don’t support confidentiality, identification, authorisation, or prevent injected messages being sent to other CAN Bus devices;
- People can use simple tools to read / interpret CAN Bus and OBD2, and even inject their own codes into the bus;
- If remote management control center is compromised, CAN Bus will be fully accessible to unauthorised threat actor;
- Threat actors could control all drive-by-wire systems connected to CAN Bus, throttle, breaks, steering for self-park vehicles, and even update any firmware / flash / code modules without gaining physical access;
- There are already many examples, cases and articles on the Internet about remote hacking of vehicles, and the requirement for fleet wide recalls;
- All vehicles will be tracked by GPS and logged in real time, there will be no privacy for vehicle owners;
- It would be possible for the Government to then issue speeding fines and other traffic infringements, as they would have access to all vehicle GPS telemetry;
- If the control system and vehicles are targeted by a hacking group, or national state, how do we recover ECUs which have been over-written remotely;
- How will it all be secured, and who will be responsible?
The current proposal suggests each vehicle will cost approximately $10 per month for the mandatory technology, and the insurance companies may play some part in covering the costs of the program. However, for $120 per annum per vehicle, this is not going to be a free ride from an insurance company’s perspective, this will be pushed back on to consumers. And what if you don’t have insurance for your vehicle? If this is a mandatory technology, who will be covering the costs for the uninsured. As every vehicle in Australia would be connected to a centralised monitoring and management system, the Australian government will need to build the operational system and implement a significant Cyber Security Management Framework to provide security in order to protect it, as it would be classed a nationally critical infrastructure.
Offenders will use several counter-measures to disrupt the remote engine immobiliser technology (briefly):
- Remove, or change the number plate on the stolen vehicle, preventing the police from identifying and remotely de-activating throttle control (what if incorrect vehicle is remotely de-activated);
- Use a communications jammer to stop any mobile phone, satellite, LoJack frequencies / signals, so remote deactivate is prevented; and
- Connect to OBD2 port with mini compute device, which detects the remote signal code to deactivate it, and inject own code into OBD2 / CAN Bus to resume throttle activation
Will this technology prevent future vehicle modifications, or updating the vehicle with a new / custom tune or flash? Similar to how ESC equipped vehicles currently have restricted modification regulations, affecting a whole community. Does Australia really need to mandate this technology in order to combat youth justice, given all the uncertainty with the technology? Can’t we look at properly punishing youth offenders first?
We encourage all motoring groups / industry representatives to review the TOR using the link above, review our discussion points, and please make a submission to this inquiry, in order to advance vehicle modification regulations.
Inquiry submissions can be easily submitted by forwarding this webpage, or create a new email, to firstname.lastname@example.org and details all the current issues you’re experiencing with vehicle modification regulations in Queensland and Australia, issues you face between different jurisdictions, your engagement / relationship with Department of Transport and Main Roads, problems with fair enforcement of regulations, and how you believe vehicle modification regulation reform should be undertaken.
Australian Recreational Motorists Association