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.

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.

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 opposes the proposed action because it does not require a physical foot brake pedal for new autonomous vehicles (AVs). They argue that a manual fallback plan is essential for human safety and that AVs should be required to accommodate human drivers rather than the other way around.

Ryan Loken, a resident of Arkansas, supports the proposal to modernize FMVSS No. 135 to remove manual control requirements for vehicles without manual controls. He argues that removing these requirements is essential for providing mobility to people who cannot operate manual vehicles, such as the blind or those with medical conditions.

The commenter opposes the proposed change, arguing that it reduces the ability for humans to maintain ultimate control over automated vehicle systems. They express concern that the change could compromise safety by making it harder for drivers to intervene during malfunctions or misuse of autonomous technology.

The commenter opposes the removal of manual brake pedals in vehicles, arguing that manual controls are necessary for safety in emergencies. They also advocate for decreasing the lumens and coverage area of LED headlights to prevent blinding other drivers.

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.