NHTSA-2026-1552National Highway Traffic Safety Administration
AV Framework Updates and Request for Comments on Interim Guidance for Commercial Deployment Exemptions
Cryptographic integrity and evidentiary correctness are different properties, and a record can hold the first while failing the second.
The comment addresses one narrow question inside the exemption pathway: what an applicant should have to show when it claims an automated driving system is governed, and how the agency can tell a real showing from a well formed one. It carries five recommendations, each traced to a specific defect found and reproduced in our own governance engine, in a codebase carrying 1,038 passing tests, 97 percent combined line and branch coverage, and 100 percent MC/DC in the covered-or-justified sense. None of the eleven was found by that suite. It proposes no mechanism for the agency to endorse, and states no safety rate, accuracy figure, or certification claim.
- Filed by
- Jonathan Luethke, Founder, Wayfinder Systems Group
- Date filed
- August 3, 2026
- Comment tracking number
- msd-cu4o-cty8
- Comment ID
- NHTSA-2026-1552-0003
- Posted to docket
- August 3, 2026
- Comments close
- September 30, 2026
NHTSA-2026-1520National Highway Traffic Safety Administration
Updating and Expanding Guidance on Safe Development and Deployment of Automated Driving Systems
A system that correctly narrows its own authority and therefore does not crash leaves no evidence at all, and looks identical to one that never built the mechanism.
This docket replaces Automated Driving Systems 2.0: A Vision for Safety, which has stood since 2017. ADS 2.0 includes Data Recording among its twelve safety design elements, but as written that element is retrospective: it establishes the cause of a crash. What the system was permitted to do at the moment it acted, and why, is a different question, and it is asked on every cycle including the very large majority where nothing goes wrong. The comment asks that decision evidence be treated as its own chapter, and offers five properties as candidate guidance text.
- Filed by
- Jonathan Luethke, Founder, Wayfinder Systems Group
- Date filed
- August 3, 2026
- Comment tracking number
- msd-cxfl-v974
- Comment ID
- NHTSA-2026-1520-0003
- Posted to docket
- August 3, 2026
- Comments close
- July 31, 2027
NHTSA-2026-1552National Highway Traffic Safety Administration
AV Framework Updates and Request for Comments on Interim Guidance for Commercial Deployment Exemptions, reply comment
Evidence about what a vehicle did can be checked from outside the vehicle. Evidence about what it was permitted to do cannot, and no instrument will ever close that gap.
Eleven comments were filed on this docket after ours, and the record converged on a single question: where did each piece of evidence come from. One commenter proposed labeling every material safety claim by evidence source and scoping independent physical evidence to realized motion. Another asked the agency to verify submitted information to the best of its ability. This reply states the consequence of putting those two together. The classes are not equally checkable. Trajectory, speed, and deceleration leave a trace in the world and can be measured by an instrument that is not part of the system under evaluation. The authority in force at the instant an action was issued is internal, leaves no physical trace, and cannot be recovered by any external observation in principle. So a recommendation about authority state is not satisfied by a recommendation about measurement independence, and the agency's ability to verify is bounded there by a property of the evidence rather than by a limit on the agency. What remains testable for that class is the record's own construction: whether it was generated at the moment the action was governed or assembled afterward, and whether its sealed values can be recomputed from the record plus a published specification. The comment supplies two technology-neutral provisions to that effect and names no mechanism and no vendor.
- Filed by
- Jonathan Luethke, Founder, Wayfinder Systems Group
- Date filed
- August 31, 2026
- Comment tracking number
- mth-ebms-oehj
- Comment ID
- Assigned when the agency posts
- Posted to docket
- Submitted, awaiting agency posting
- Comments close
- September 30, 2026
NHTSA-2026-1585National Highway Traffic Safety Administration
Temporary Exemption From Motor Vehicle Safety and Bumper Standards, Interim Final Rule
A record generated while a vehicle operated in a given configuration, and a summary composed at application time asserting that it did, are different documents that can be identical on their face.
The interim final rule lets the Administrator extend a temporary exemption to vehicles manufactured before the exemption took effect, including vehicles previously operated on public roads for testing or evaluation. Two comments already on that docket ask what such an applicant should have to submit. This comment is additive to both and takes no position on a third, which argues a procedural question. It raises three items neither addresses: whether each item of submitted evidence was generated contemporaneously with the operation it describes or reconstructed afterward; what the agency does when no record survives, given that a vehicle operated under 49 U.S.C. 30112(b)(10) was under no federal retention obligation; and that an incident history without exposure data is a numerator with no denominator, which cannot substantiate equivalency in either direction. It proposes no mechanism and states no safety rate or product claim.
- Filed by
- Jonathan Luethke, Founder, Wayfinder Systems Group
- Date filed
- August 31, 2026
- Comment tracking number
- mth-6xez-ua57
- Comment ID
- Assigned when the agency posts
- Posted to docket
- Submitted, awaiting agency posting
- Comments close
- September 30, 2026
