Comment from Persistence Analytics Group LLC

Comment on NHTSA-2026-0529 Incident Reporting for Automated Driving Systems and Level 2 Advanced Driver Assistance Systems Persistence Analytics Group LLC / United Grid submits this comment regarding NHTSA’s information collection for incident reporting involving Automated Driving Systems and Level 2 Advanced Driver Assistance Systems. PAG / United Grid supports NHTSA’s objective of collecting safety-critical incident data while reducing unnecessary reporting burden. Automated driving and driver-assistance technologies are moving quickly from controlled deployment into public operating environments. Incident reporting must therefore produce timely, usable, and decision-grade evidence. The key issue is not only whether incidents are reported. The key issue is whether the reporting framework allows NHTSA, state agencies, manufacturers, operators, insurers, researchers, and the public to identify when safety assumptions are failing. NHTSA should evaluate the collection through an implementation-integrity standard: 1. Safety-critical data quality Reports should capture enough information to determine whether the incident reflects system design, operational design domain limits, driver interaction, foreseeable misuse, environmental conditions, software performance, sensor limits, or deployment assumptions. 2. Timeliness and follow-up Five-day reporting for higher-severity incidents is appropriate, but NHTSA should ensure that updated reports capture materially new information when crash facts, engagement status, vehicle damage, data availability, or narrative explanations change. 3. Engagement and handoff clarity The 30-second engagement window is important because automated and human control may overlap during handoff, disengagement, mode confusion, or delayed driver response. Reports should help distinguish whether the safety issue arose before, during, or after automated-system engagement. 4. Vulnerable road users Incidents involving pedestrians, cyclists, motorcyclists, wheelchair users, and other vulnerable road users should remain a high-priority reporting category. These incidents are especially important for public trust and deployment readiness. 5. Avoiding false confidence Streamlining reporting should not eliminate information needed to detect recurring safety patterns. A lower-burden system is valuable only if it continues to reveal defect signals, misuse patterns, ODD limits, and emerging risks. 6. Data comparability NHTSA states that the General Order is not primarily designed for apples-to-apples technology scorecards. Even so, the agency should continue improving public data presentation so incident trends, severity categories, system engagement, and follow-up actions can be understood without overstating what the data prove. 7. Public transparency and confidentiality NHTSA should protect CBI and PII, but public reporting should remain useful enough to support safety oversight, state coordination, public trust, and independent review. 8. Verification after reporting Incident reports should be treated as early-warning evidence, not final determinations. NHTSA should preserve the ability to request additional data, investigate recurring patterns, and identify when self-reported information is incomplete, inconsistent, or contradicted by other sources. PAG / United Grid recommends that NHTSA maintain the reporting framework with continued attention to: * safety-critical event capture; * data-quality metrics; * repeat-incident pattern detection; * vulnerable-road-user protection; * ODD and engagement-status clarity; * updated-report completeness; * public data usability; * and follow-up verification when incident patterns suggest assumption failure. The broader principle is simple: Automated-vehicle safety cannot rely on market claims, deployment narratives, or self-assessed readiness alone. It requires incident data that can reveal when technology, human factors, operating conditions, or deployment assumptions are not holding in the real world. Modern mobility should advance. But public-road deployment should be tied to decision-grade evidence, accountable reporting, and verified safety performance. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity SAM.gov registered UEI: D3VYU39H6DX9 D-U-N-S: 142849930 CAGE: 19T34 neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/