JRC Response to the Department for Transport Proposal for an offence of using a hand-held mobile phone while driving

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1. JRC welcomes the opportunity to comment on this important consultation.

2. JRC has consulted with its constituent members in the UK Gas and Electricity industries and responded to the specific questions posed in the consultation document.

3. Our general view is that provided communications devices are used in an appropriate manner, they should be no more distracting than passengers or entertainment devices. It is important that driver training and education should include references to appropriate use of ancillary equipment in the same way as drivers are taught to use essential controls in the proper manner, eg whenever possible, to have both hands on the steering wheel; to avoid operating ancillary controls when conducting a driving manoeuvre, and to avoid any distractions while driving.

4. Utility companies have specific concerns about the provision that any hand-held communication device or 2-way data device should only be used when the vehicle is parked and with the engine switched off (Annex A: para 4.) We agree with the intention of this regulation, but as worded it would have unintended consequences. Utility vehicles will frequently have their engines running when parked to provide power for ancillary devices, especially lighting bars to warn other motorists of their operations. In such circumstances, where there may be substantial noise from road breakers, etc, they may need to use a hand-held device. This would become an offence.

5. Some utility vehicles are adapted to enable the driver to use a laptop computer from the driver's seat. In these circumstances, it is usual for the vehicle to be incapable of being driven with the computer in use, but it is usual for the engine to be capable of operation to provide electrical power and heat or cooling. This would be contrary to the provisions proposed in Annex A para 6.

6. It could be argued that in the circumstances quoted above, the driver should move to the passenger seat and therefore cease to be the 'driver'. We believe it would be better for the regulations to permit drivers to use hand-held and data devices when seated in the driving seat, but where the vehicle is genuinely parked as this may be the most convenient location for the driver, and he or she will still have access to other information and controls relating to the use of the vehicle as a power source.

Adrian Grilli
Managing Director
JRC Ltd
30 Millbank, London SW1P 4RD

12 September 2002

Background

1. The Joint Radio Company Ltd. (JRC) is a joint venture company owned by Transco, the UK national gas pipeline operator, and the Electricity Association on behalf of the UK electricity generation, transmission and distribution companies.
2. JRC manages 4 MHz of UK radio spectrum on behalf of the UK Fuel and Power utilities. 2.8 MHz is for Private Mobile Radio (PMR) applications and 1.2 MHz for telemetry and telecontrol services. JRC created and manages a national cellular plan for co-ordinating frequency assignments for some of the largest PMR networks in the UK.
3. In addition to voice traffic, the private mobile radio networks carry data transmissions and status alerts to allow the mobile work force to make requests and acknowledgements using a single command.
4. JRC manages VHF and UHF allocations. These networks keep the electricity and gas industries in touch with their field engineers throughout the country. The networks provide comprehensive geographical coverage to support the installation, maintenance and repair of plant in all weather conditions.
5. There are some 14,000 PMR units deployed in the UK Gas and Electricity industry, mostly in fixed vehicle installations. Estimates for mobile phones are more difficult to assess, but are thought to be 26,000 in the electricity industry and 7,000 in the gas industry. (Some users may have both PMR and a mobile phone installed in their vehicle.)
6. JRC represents gas and electricity interests on government committees addressing radio issues. These include cellular telephones and radio safety, microwave fixed links and remote meter reading by radio.