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.

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.

An individual expresses strong opposition to the proposed measure, arguing that it prioritizes cost-cutting over human safety. They contend that car manufacturers should be required to install emergency brakes on all vehicles to prevent unnecessary deaths and injuries.

The commenter argues that the proposed removal of manual brake controls for ADS-dedicated vehicles creates a safety gap by not requiring a reliable, passenger-accessible emergency stop mechanism. They request that NHTSA mandate a physical emergency trip-interruption control to ensure occupants can stop the vehicle in urgent situations, regardless of the ADS state.