Varnum LLP is requesting a 30-day extension of the public comment period for the proposed modernization of FMVSS No. 135. They argue that the technical complexity of the rulemaking requires more time for their client to conduct necessary engineering and safety analyses.

Advocates for Highway and Auto Safety opposes the proposed removal of brake pedal requirements for vehicles equipped with Automated Driving Systems (ADS) that lack manual controls. They argue that the technology is still unproven and that the agency should not eliminate safety standards until independent research demonstrates that such vehicles can operate safely without these controls.

Laura Chace, President and CEO of ITS America, expresses strong support for the proposed modernization of FMVSS No. 135. The organization argues that removing the requirement for manual brake pedals will allow for the deployment of innovative, purpose-built autonomous vehicles while maintaining existing safety performance standards.

Tyrel Sulzer, owner of TransTech CDL Training and Commercial Driver Services, supports modernizing FMVSS No. 135 for purpose-built, light-duty ADS vehicles but requests specific safeguards. He argues that the rule should explicitly limit this framework to light vehicles to prevent it from being used to justify similar changes for heavy commercial vehicles without separate safety analyses. He also requests clearer definitions on remote operation, mandatory ADS performance reporting, and an extension of the comment period.

An independent consultant specializing in autonomous systems safety opposes the proposal to remove manual brake control requirements. The commenter argues that removing this hardware safeguard without a mandated, verifiable safety mechanism shifts liability to manufacturers and creates a safety gap for passengers.