Comment from Paul McEachern

"Under Section 23010 of the Bipartisan Infrastructure Law, prior to prescribing the FMVSS, the Secretary is required to conduct a review of AEB systems in use in applicable commercial motor vehicles and address any identified deficiencies in those systems in the rulemaking proceeding, if practicable." The National Highway Traffic Safety Administration has not complied with this section of the law. This rulemaking does not in any way address the reasons why the same model radar sensor/AEB electronic control unit, used on multiple models of passenger car as well as multiple models of heavy trucks, results in a AEB system that functions very well on the cars and very poorly on the heavy trucks. As a master automobile and heavy duty truck mechanic with a great deal of experience with the AEB systems used on both passenger vehicles and heavy duty trucks I know the exact reasons why. This rulemaking does nothing to address any of those reasons in any meaningful way that will actually save lives. Class 6/7/8 heavy trucks and trailers, that meet current 2023 U.S. safety standards, use pneumatic brake control valves that are little changed from what George Westinghouse originally designed for steam trains, to signal brake application. Electronic Brake Signaling (EBS) is mature, decades old technology that is not even mentioned in this proposed rulemaking? Class 6/7/8 heavy trucks and trailers with air brakes, that meet current 2023 U.S. safety standards, have Antilock Brake Systems (ABS) that are good at saving the lives of tires but very poor at saving the lives of people. The fact that Class 6/7/8 heavy trucks and trailers with air brakes, that meet current 2023 U.S. safety standards, have brake systems that are so antiquated and dangerous that they are not allowed on the roads in many countries some people call part of the 'developing world' is not addressed in this rulemaking. This is all pretty simple, we are going to have class 6/7/8 air brake heavy trucks and trailers that signal brake application at near the speed of light or continue to allow the use of pneumatic valves that can't even signal brake application at the speed of sound. It's only a 1/5th of a second gain in brake response time but this 1/5th of a second is the most important 1/5th of a second during an Automatic Emergency Braking (AEB) event because it's the first 1/5th of a second. In short, as an informed citizen I would analogize this rulemaking as another regulatory attempt to paint lipstick onto a pig. National Highway Traffic Safety Administration's usual Luddite approach to setting heavy vehicle safety standards isn't going to work here. I'm getting tired of seeing my neighbors violently maimed and killed on public property unnecessarilly resulting in thousands of lives destroyed. Although the subject here is accidents, the grossly evident technology deficit in heavy duty vehicle safety system regulatory requirements is making the deaths we are talking about look more and more like murder for profit every day. My personal admonition to the National Highway Traffic Safety Administration is to follow the law as written because in this case doing so is entirely practicable and absolutely necessary in order to save my neighbor's lives.