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.

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 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 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.

Manuel de la Morena de Castro, representing SBS Smart Brake Lighting System, submits a comment to inform NHTSA of a patented dynamic brake signaling technology. He suggests that future regulations for automated and electrified vehicles should consider technologies that communicate actual vehicle deceleration rather than just conventional brake-pedal actuation.

The Texas Department of Transportation (TxDOT) supports the proposed modernization of FMVSS No. 135 to accommodate ADS-equipped vehicles. They recommend specific refinements regarding passenger-initiated stop functions, brake control definitions, fault management, and parking brake performance expectations to ensure safety and consistency.