Comment from Ryan Loken

I am submitting this comment as a blind resident of Arkansas, in support of NHTSA's proposal to modernize FMVSS No. 135 for vehicles designed without manually operated driving controls. I want to raise a consideration that I believe is underrepresented in the public record for this and related ADS modernization rulemakings: the removal of manual controls in fully autonomous vehicles is not only a technical or cost question for manufacturers — it is a prerequisite for a large population of Americans who cannot use manually operated vehicles at all. Roughly a third of U.S. adults do not hold a valid driver's license at any given time, including blind and low-vision people, people with medical conditions that preclude licensing, seniors who have stopped driving, and people without access to a second vehicle. For this population, a vehicle that retains manual controls "just in case" is not a safety feature — it is designed around an assumption of a sighted, licensed occupant that may never be met. I encourage NHTSA to treat this population as a primary constituency for ADS modernization rulemaking, not solely as a secondary "accessibility" concern. The stopping-distance and braking-performance requirements this rule preserves are the correct place to hold the line on safety; the manual-control requirements this rule proposes to remove are the correct place to remove unnecessary barriers, precisely because they assume a class of user that a growing number of Americans do not fit. I support the proposed removal of manual brake pedal and hand control requirements for vehicles with no manually operated driving controls, and the corresponding retention of stopping-distance performance requirements regardless of how the brakes are activated. I would also encourage NHTSA, in future ADS performance rulemakings, to formally solicit input from mobility-access stakeholders — including blind and low-vision riders — as a distinct category from general public comment, given how directly these standards affect independent access to transportation for people who cannot drive. Thank you for the opportunity to comment. Ryan Loken Centerton, Arkansas