Comment from Ron Berndt
Ron BerndtSupportIndividual
Summary: The commenter supports regulatory changes that encourage the availability of autonomous vehicles, arguing that they are safer than human-operated vehicles. They also suggest that regulations should account for the fact that driverless vehicles lack a human operator to interact with traditional controls like brake pedals.
The core purpose of FMVSS is to improve the safety of the motoring public. The statistics are clear: while rare incidents gain disproportionate media attention, in reality, the number of accidents, serious and otherwise, per mile driven is far lower with vehicles operated by autonomous systems such as those by Waymo, Tesla and others. Changes to regulations should therefore encourage availability of autonomous vehicle options, as accident reduction will be proportionate to the increase in autonomous vehicles as a percentage of the fleet.
Plus, as a matter of common sense, a driver-less vehicle has no one in position to operate a brake pedal. Therefore, any operation of such a pedal would be inadvertent and could easily pose a safety hazard, as it would abruptly interfere with vehicle operation.