Public Comments

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May 4, 2026
Docket Management Facility, M-30
U.S. Department of Transportation
1200 New Jersey Avenue, SE, West Building, Room W12-140
Washington, DC 20590-0001
RE: Comments of the American Association of Motor Vehicle Administrators on the Agency Information
Collection Activities; Incident Reporting for Automated Driving Systems (ADS) and Level 2 Advanced
Driver Assistance Systems (ADAS) [Docket No. NHTSA-2026-0529 / OMB Control No. 2127-0754]
The American Association of Motor Vehicle Administrators (AAMVA) represents the motor vehicle
administrators of the United States and Canada, whose members administer driver licensing, vehicle
registration and titling, and motor vehicle safety enforcement on behalf of the public. State motor vehicle
agencies interact with ADS-equipped and ADAS-equipped vehicles every day — in crash investigations,
roadside enforcement, and emergency response.
AAMVA supports extending OMB Control No. 2127-0754 for three years. Standing General Order 202101 (SGO 2021-01) is the primary structured mechanism by which NHTSA receives timely, mandatory
incident data on ADS and Level 2 ADAS performance in the field. Its continuation is not merely
administratively appropriate — it is the only such mechanism currently operative. Given NHTSA authority
to amend the SGO, AAMVA provides comments as described in the ICR to the effectiveness of NHTSA
to perform oversight functions related to ADS-equipped vehicles which may extend beyond the normal
limitations of an ICR.
Importance of Data Collected
Changes to the administration of data inputs are not uniform in their safety effect. Some expand safety
coverage; others narrow the scope of reportable crashes.
The addition of vehicle tow-away as a five-day ADS reporting trigger is a genuine expansion of the
collection's safety coverage and is fully supported. Tow-away is a reliable severity proxy that does not
depend on whether occupants were present or transported — a gap that matters as ADS-dedicated
vehicles carrying no human occupants become more prevalent. This change appropriately reflects the
greater oversight warranted for vehicles where the ADS performs the full DDT.
Eliminating mandatory null monthly reports, removing fixed-interval update requirements, and
consolidating duplicate reports from entities sharing identical information are straightforward burden
reductions with minimal safety cost. AAMVA defers to NHTSA on the utility of eliminating these
requirements.
Under the SGO, any ADS crash not meeting the five-day criteria required a monthly report — no
minimum damage threshold, no at-fault filter. Under the modified SGO, a monthly report is required
only if property damage exceeds $1,000 and the subject ADS vehicle was either the sole vehicle
involved or the striking party. This means:
A crash in which an ADS vehicle was struck by another vehicle — and where the ADS failed to detect
the approaching vehicle and execute an evasive maneuver — may fall entirely outside the reporting
universe if property damage is below threshold.
Low-speed ADS failures that do not produce significant property damage but do reflect systematic
detection or response deficiencies that will go unreported under the modified framework.

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The at-fault filter implicitly assumes that crashes where the ADS vehicle was not the primary at-fault
party are not safety signals. An ADS that fails to avoid a foreseeable collision — even one initiated by
another party — may be exhibiting a defect in its object detection, event response, or DDT execution
that could yield important safety benefits in terms of long-term detection and remediation of safety
issues. The value of this collection lies in aggregate pattern detection — and patterns of low-severity
ADS failures at specific thresholds, road types, or conditions can be precisely the leading indicators of
systemic defects.
Potential for Additional Inclusion on ODD Operation Within Confined Limits
Within the scope of this ICR, AAMVA recommends one data field enhancement to Form 1612 that
would materially improve the collection's defect-detection utility: an indication of whether the ADS was
operating within or outside its Operational Design Domain (ODD) at the time of the crash.
This field is directly relevant to NHTSA's core purpose in collecting this data. An ADS operating outside
its ODD when a crash occurs — in weather, geography, or road conditions for which it was not
designed — presents a qualitatively different safety signal than a crash within a validated domain. ODD
exceedance is probative of whether a crash reflects a design defect, a deployment decision, or an
operator failure. It is information manufacturers possess and can be expected to report.
Cian Cashin
Vice President, Government Affairs
[email protected]