Perspectives: Tyrel Sulzer from CVTA Member TransTech - First the Pedal, Then the Seat
- CVTA Staff
- 1 day ago
- 2 min read
Continue the conversation on autonomous vehicle policy, driver requirements, and the future of CDL training at the: 2026Fall Conference
On June 26, NHTSA proposed deleting the brake pedal requirement for vehicles built to drive themselves. FMVSS 135, the brake standard passenger cars and light trucks have lived under since 1995, would no longer require a hand or foot brake control in a vehicle designed to operate without a human driver. The stopping distance requirements stay. The pedal goes, because there's nobody in the seat to press it.
Read past the headline and the rule is narrower than it sounds. It covers light vehicles only. Waymo, Zoox, whatever Tesla ends up shipping as the Cybercab. Nothing in it touches FMVSS 121, the air brake standard on the trucks we train people to drive. So why bring it up to member schools at all?
Because of how the logic runs. For three decades the federal rulebook assumed a human operator, and the hardware requirements flowed from that assumption. This proposal runs it the other way. Build the vehicle without a driver and the driver-facing requirements get struck to match. Nobody at the agency is asking whether that vehicle should have a human. The question on the table is what else can be deleted once it doesn't.
It wasn't a one-off, either. The same week, NHTSA withdrew AV STEP, the program that would have traded FMVSS exemptions for public safety reporting from AV companies. The agency's own explanation was that companies found the reporting burden heavier than the benefit, so almost nobody would have signed up. One news cycle. Hardware requirements loosened, transparency program shelved.
The comment window is 30 days and closes July 27. A rewrite of a 31-year-old safety standard, put out for comment across the July 4th holiday.
Three things for member-school operators:
File a comment before July 27. Search "FMVSS 135" on regulations.gov and it takes twenty minutes. That docket is going to be wall-to-wall AV lawyers, and it needs a few people who train drivers for a living.
Argue the template, not the robotaxi. On its own terms the rule is defensible. The precedent is the problem. When the "designed without a driver" logic reaches Class 8 rulemaking, the human-operator question will already feel settled unless operators contested it here, on the record.
Point at CVTA's Require A Driver position. One association letter plus fifty operator comments reads a lot louder than either alone.
Next week: what AV STEP's withdrawal means for the safety data fight, and why less public reporting hurts the pro-driver side most.
— Tyrel
TransTech CDL Training / Commercial Driver Services
Sources:
Commercial Carrier Journal, "Feds move to eliminate brake pedals in fully autonomous vehicles," available at: https://www.ccjdigital.com/regulations/article/15828679/feds-move-to-eliminate-brake-pedals-in-fully-autonomous-vehicles
National Highway Traffic Safety Administration, Press Release on FMVSS Brake Pedal Requirement Updates, available at: https://www.nhtsa.gov/press-releases/fmvss-updates-brake-pedal-requirements
Crowell & Moring, Client Alert: "NHTSA Proposes Updates to Federal Brake Standards for Autonomous Vehicles and Withdraws AV STEP Program," available at: https://www.crowell.com/en/insights/client-alerts/nhtsa-proposes-updates-to-federal-brake-standards-for-autonomous-vehicles-and-withdraws-av-step-program
