France already has a working legal framework for approving driverless public transport. Most of the industry has never heard of it. Aryldo Russo of GESTE Engineering takes it apart piece by piece.
Getting a vehicle type approved in Europe is one problem. Getting a driverless service running on a specific street, with a control room behind it and a city that has to agree, is a completely different one. France solved the second problem by writing its rules into the transport code rather than vehicle law, and handing the job to the national technical service that already oversaw metros and tramways.
That inheritance shapes everything. The system is assessed as a whole, not as a vehicle: six domains covering onboard safety, connectivity and positioning, cybersecurity, road infrastructure, vehicle behaviour and operations, plus a seventh that consolidates them into a single verdict. Three sequential dossiers carry a project from generic capability to a specific route. And the safety bar is inherited from rail: globally at least as safe as the service being replaced, measured against national statistics rather than one bus route.
Aryldo explains what happens when an operator calls, what counts as evidence, and why a million kilometres of driving proves less than teams expect. We also cover why the law refuses to name a vehicle-to-operator ratio for remote supervision, whether French cybersecurity rules duplicate UN R155, how you assess an end-to-end driving system you cannot decompose, where the seam sits between EU type approval and national authorisation, whether Brussels should use the French model as its template, and whether Europe's assurance layer is a safety asset or a competitive handicap against Waymo and Chinese operators.
Plus the number nobody publishes: roughly what the whole safety demonstration costs as a share of the project.
TIMESTAMPS
0:00 - Type approval is one problem. Running a service is another
1:09 - The French technical service, and its metro and tram origins
2:46 - What rail engineers see that automotive teams miss
3:45 - What actually happens when a project calls you
5:19 - The seven domains of the assessment
6:56 - Independence: assessor and engineering support at once
8:29 - What counts as an automated road transport system
9:35 - Built through the transport code, not vehicle law
10:46 - The remote intervener and the service organiser
12:02 - Predefined routes, zones, and whether Paris fits
13:36 - GAME: at least as safe as what it replaces
14:54 - National statistics, or one specific route
15:26 - Who signs: the operator, the mayor, the assessor
16:23 - Three dossiers: DCST, DPS, final safety case
19:17 - When to call an assessor, and the cost of calling late
20:45 - Remote supervision: why the law names no number
22:10 - Do remote operators have to sit in France
22:47 - French cybersecurity rules vs. UN R155
24:17 - Why a million kilometres proves very little
26:49 - Traceability when behaviour comes from data
28:26 - The seam between EU type approval and French rules
29:51 - Should Brussels use the French model
31:07 - What changes when it is a truck, not a shuttle
32:14 - How long it takes and what it costs
33:26 - Waymo, China, and whether assurance is a handicap
34:36 - The one thing he would change
LINKS
The AV Market Strategist (my weekly AV analysis) - https://avmarketstrategist.substack.com
Aryldo on LinkedIn: https://www.linkedin.com/in/aryldogrussojr/
#AutonomousDriving #Robotaxi #DriverlessVehicles #MobilityPolicy #AutonomyInsiders
