Comment from Transtech Inc.

Docket No. NHTSA-2026-0728; RIN 2127-AN00 Federal Motor Vehicle Safety Standards; Modernization of FMVSS No. 135 To Accommodate ADS-Equipped Vehicles Comment of Tyrel Sulzer, TransTech CDL Training / Commercial Driver Services I own and operate TransTech CDL Training, with 13 locations across North Carolina, South Carolina, and Georgia, and Commercial Driver Services, with 4 locations in Virginia. Together our schools train roughly 5,000 new commercial drivers a year, and we are a member school of the Commercial Vehicle Training Association (CVTA). I am commenting as an operator whose business, staff, and graduates depend on how federal motor vehicle rules treat the human operator. We do not oppose modernizing FMVSS No. 135 for purpose-built, light-duty ADS vehicles. Keeping the stopping distance requirements while updating test procedures is a reasonable approach for vehicles that genuinely have no provision for human driving. Our concern is with the scope of the framework this rule establishes and what it will be cited to justify next. I offer four requests. 1. State the boundary of this framework in the final rule. This is NHTSA's first FMVSS amendment built on the premise "designed never to be operated by a human." Once that premise is in the CFR, it will be cited in future petitions and rulemakings covering commercial motor vehicles, including FMVSS No. 121 air brake systems on Class 7 and 8 trucks. Whatever the merits of driverless robotaxis, heavy commercial vehicles present a different safety case, a different operating environment, and a workforce of more than 3.5 million professional drivers, roughly 5,000 of whom our schools add each year in four states. I request that the final rule state expressly that this framework is limited to light vehicles under FMVSS No. 135, and that any application of the "no manually operated driving controls" concept to commercial motor vehicles will proceed through separate rulemaking with its own safety analysis and its own assessment of operator and workforce impacts. 2. The definitions need a bright line on remote operation. NHTSA requests comment on the proposed definitions. "Designed never to be operated by a human" carries the entire rule, and as written it describes manufacturer intent rather than a verifiable design fact. The final rule should answer two questions. First, how does a manufacturer certify that a vehicle can never be operated by a human, and what happens if remote operation or teleoperation capability is added later in the vehicle's service life? Second, is a vehicle that can be driven by a remote human operator from a control station "operated by a human" for purposes of this standard? If remote human driving does not count as human operation, the exception will cover far more than the purpose-built robotaxi the preamble describes. 3. If occupant intervention is removed as a safety layer, data reporting should replace it. The preamble counts as a benefit "removing the ability of an occupant to interfere with the safe operation of the vehicle by the ADS." Occupant intervention is today the last-resort safety layer in these vehicles. NHTSA withdrew the AV STEP program the same week this NPRM was published, citing low expected participation. That leaves less public performance data at the same time physical controls are removed. I request that NHTSA pair any final rule with mandatory ADS incident and performance reporting for vehicles certified under the new exceptions, so the safety record that used to come from a human in the vehicle still comes from somewhere. 4. Extend the comment period. Thirty days spanning the July 4 holiday is not enough time for small businesses in the commercial driving industry to review a structural change to a standard that has been in place since 1995. I request a 30-day extension of the comment period. We train people to drive trucks for a living. We are not opposed to automation research or to purpose-built ADS vehicles operating under sound rules. Our request is that the human-operator question, especially for commercial vehicles, be decided openly in dockets dedicated to it, not inherited quietly from a light-vehicle brake standard. Respectfully submitted, Tyrel Sulzer Owner, TransTech CDL Training (NC, SC, GA) and Commercial Driver Services (VA) Charlotte, North Carolina