Autonomous Vehicle Brake Pedal Rules Proposed by NHTSA for Driverless Vehicles

The United States is moving toward adapting vehicle safety regulations for the next generation of fully autonomous transportation. On June 25, NHTSA proposed revisions to Federal Motor Vehicle Safety Standards (FMVSS) that would eliminate the requirement for manual brake pedals in vehicles specifically designed to operate without any human driver. The proposal recognizes that some autonomous vehicles are engineered to function exclusively through automated driving systems, making traditional driver-operated braking controls unnecessary while maintaining established safety expectations.

Proposed Changes to FMVSS No. 135

The proposed amendments to FMVSS No. 135 would remove mandatory hand-operated or foot-operated brake controls only for vehicles that are intentionally designed never to be driven by a person. Vehicles equipped with automated driving systems but still retaining conventional manual driving controls would remain fully subject to all existing regulatory requirements. This distinction ensures that the revised standard applies exclusively to purpose-built autonomous vehicles while preserving current safety obligations for vehicles capable of human operation.

Braking Performance Standards Remain Unchanged

Although the proposal removes the requirement for physical brake pedals in qualifying autonomous vehicles, it does not reduce braking performance expectations. Every applicable vehicle would still be required to satisfy the same stopping distance performance criteria through alternative testing methods appropriate for vehicles without manual controls. The proposal confirms that automated systems must reliably bring the vehicle to a stop when commanded, ensuring that safety performance standards continue to be enforced despite the absence of traditional driver interfaces.

Continued Oversight of Automated Driving Systems

Alongside the proposed regulatory revisions, NHTSA stated that it is separately developing safety performance requirements focused on how automated driving systems perform in real-world operating conditions. The agency also emphasized that it will continue exercising its broad defect investigation and enforcement authority to identify unsafe automated driving system behavior and oversee vehicle recalls whenever safety concerns arise.

Broader Regulatory Modernization

The proposal forms part of NHTSA’s broader effort to modernize vehicle equipment regulations for fully autonomous vehicles. The agency has been evaluating whether features traditionally required for human drivers, including windshield wipers and rearview mirrors, remain necessary in vehicles that will never be operated manually. Despite these changes, other braking performance requirements, including strict stopping distance standards, would remain fully intact. Furthermore, the proposal would not affect conventional automobiles, which would still be required to include manual brake pedals.

Frequently Asked Questions

Why is NHTSA proposing to remove brake pedal requirements for some vehicles?
NHTSA is updating safety regulations to better reflect vehicles designed exclusively for autonomous operation without any human driver. These vehicles rely entirely on automated driving systems rather than manual controls, making brake pedals unnecessary for their intended operation. However, the proposal does not reduce safety expectations, as qualifying vehicles must still demonstrate compliance with established braking performance standards through alternative testing procedures before they can satisfy federal safety requirements.

Will conventional vehicles still require brake pedals?
Yes. The proposed rule applies only to vehicles intentionally designed to operate without human drivers or manual driving controls. Passenger vehicles and other automobiles that allow human operation would continue to comply with all existing Federal Motor Vehicle Safety Standards, including the requirement for manual brake pedals. The proposal therefore does not change equipment requirements for conventional vehicles currently sold or operated on public roads.