Comment from Burak Oktenli

This comment addresses Docket NHTSA-2026-0529 and responds directly to the agency's request, at item (e), for ways to streamline this collection through automated techniques and information technology. The notice estimates roughly two hours of combined engineering, legal, and data-management labor for each of approximately 9,574 annual responses. Several of the required fields, including engagement status, pre-crash movement, air-bag deployment, ODD status, and data availability, already exist in structured form within reporting entities' telematics and event-data systems. The notice itself observes that ADS-equipped vehicles typically maintain advanced data recording and telemetry. Much of the burden therefore reflects manual transcription of machine-available data into Form 1612, not the collection of new information. I respectfully offer two measures, both within the scope of this collection. First, a standardized machine-readable submission schema, for example JSON or XML mapped to the existing Form 1612 fields. This would let entities populate routine structured fields directly from existing systems and reserve manual effort for the narrative and judgment-based fields. It changes how existing data is transmitted, not what entities must build into vehicles, and could reduce the engineering and data-management labor the notice estimates. Second, event-keyed incremental updates under Request No. 3, allowing an entity to transmit only changed fields against a stable incident identifier rather than resubmitting a full report. Given the agency's own estimates of 9 percent for Level 2 ADAS and 4 percent for ADS update rates, a change-only mechanism could reduce update burden while preserving the full update history. Both measures advance the agency's stated goal of concentrating reporting on actionable safety information while lowering transcription burden, and both improve the consistency and machine-analyzability of the data the agency reviews. I would welcome the agency's consideration of a standardized submission schema as it continues to refine this collection and works toward codifying the General Order. Respectfully, Burak Oktenli