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.

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.

Persistence Analytics Group LLC supports the modernization of FMVSS No. 135 to remove requirements for human-driver controls in vehicles designed for automated driving systems. However, they argue that the new standards must require rigorous, transparent evidence regarding software reliability, failure modes, and cybersecurity to ensure safety without manual overrides.

The commenter argues against a mandatory physical brake pedal requirement for fully automated vehicles, asserting that pedal-free designs are already proven safe and achievable. They contend that a performance-based, design-neutral standard should be adopted to allow manufacturers engineering freedom while addressing software and connectivity issues rather than hardware mandates.

The commenter, a pedestrian and road user, opposes changes to vehicle driving control rules that would remove mandatory manual braking systems. They argue that manual overrides are critical for safety, drawing a parallel to mandatory emergency stops in industrial robotics.

The commenter expresses strong opposition to the proposed action, viewing it as a dangerous move that favors the development of autonomous vehicles like the Cybercab. They argue that AI should not be trusted with human lives and insist on a manual emergency brake that bypasses all computer systems.

Monica Jensen argues that removing the option for a manual emergency brake in autonomous vehicles is dangerous due to the potential for computer malfunctions and hacking. She contends that passengers must have the ability to override the vehicle's computer to ensure safety in unpredictable real-world scenarios.

The commenter argues that autonomous vehicles should be required to have a physical emergency brake that completely stops the vehicle and unlocks all doors. They suggest that deregulating safety features in these vehicles will negatively impact public opinion and hurt the businesses involved.