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Comment from Raymond Biscocho Duculan Sr.
Posted by the National Highway Traffic Safety Administration on Apr 27, 2026

Docket (/docket/NHTSA-2026-0529) / Document (NHTSA-2026-0529-0001) (/document/NHTSA-2026-0529-0001)
/ Comment

Subject: Technical Comment on Incident Reporting for Level 2 ADAS and ADS - High-Impact Mechanical
Fail-Safes
Comment Body:
I am submitting this technical comment to highlight a critical gap in the current incident reporting framework
for Level 2 ADAS and Automated Driving Systems (ADS).
While current reporting focuses on the cause of incidents, there is insufficient data collection regarding postcrash occupant extraction in high-impact scenarios (\bm{35G} and above). In severe collisions where
electronic systems (including electronic door latches and high-voltage batteries) are compromised or
intentionally disconnected for fire safety, occupants are frequently trapped due to the lack of a standardized
mechanical override.
As the inventor of the Active Mechanical Extraction System (AMES), my research into high-impact
diagnostic data suggests that:
1.
Electronic Failure is Certain at High-G: Systems relying on ADAS sensors and electronic actuators
often lose structural or electrical integrity during \bm{35G}+ impacts.
2.
Reporting Requirement: NHTSA should require manufacturers to report the "Status of Occupant
Extraction" (Manual vs. Tool-Assisted) for all reportable incidents.
3.
Mandatory Mechanical Standards: Reporting alone is insufficient without a requirement for a
mechanical extraction fail-safe that operates independently of the vehicle’s primary electrical architecture.
I urge the NHTSA to consider mandating a mechanical extraction force standard (specifically targeting the
\bm{50,000} Newton threshold) to ensure that even when the most advanced ADAS fails to prevent a crash,
the vehicle does not become a sealed environment for the occupants.
Respectfully submitted,
Raymond Biscocho Duculan Sr.
Master Automotive Diagnostic Technician
Lead Inventor, Project 123 AMES
Patent Applicant (No. 19/629,416)
https://www.regulations.gov/comment/NHTSA-2026-0529-0006

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Comment ID
NHTSA-2026-0529-0006

Tracking Number
moh-9e25-t2zy

Comment Details

Submitter Info

Document Subtype
Comment(s)
Received Date
Apr 27, 2026

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