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A federal agency wants to legally allow cars built without a way to stop them manually. The National Highway Traffic Safety Administration has opened a rule change that would let autonomous vehicles with no manually operated driving controls skip the foot-operated brake pedal entirely. The proposal targets one specific safety standard, and it could reshape what a car is required to have inside it.
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FMVSS No. 135 Has Required Foot Brakes Since 1995
The rule in question, FMVSS No. 135, sets the braking performance standards for every passenger vehicle sold in the United States and has required those brakes to be operated by a foot-controlled pedal. That made sense when every vehicle needed a human behind the wheel. For a car with no steering wheel and no pedals at all, the requirement becomes something else entirely: a wall.
Morrison Compares the Moment to the Invention of the Model T
NHTSA Administrator Jonathan Morrison did not undersell the moment. “We are at the cusp of the greatest technological revolution in vehicle technology since the innovation of the Model T,” he said, adding that America has to reimagine its regulatory framework to lead the way. He tied the effort directly to a broader agenda one level above him at the Department of Transportation.
Duffy’s AV Framework Has Already Rewritten Four Other Safety Rules
Morrison credited the push to Transportation Secretary Sean Duffy’s AV Framework, which he said is tearing down pointless barriers to innovative designs while holding developers accountable for safe performance. This is not an isolated move. NHTSA has already proposed updates to standards covering transmission shifting, windshield wiping and defrosting, and tire placards, all aimed at the same target.
The Rule Only Applies to Vehicles No Human Will Ever Drive
The proposal is narrower than it sounds. It would remove the requirement for a foot-operated brake pedal only for ADS-equipped vehicles that have no manually operated driving controls at all. Any vehicle that keeps a steering wheel or pedals, even one running self-driving software, stays fully bound by every existing rule on the books.
Stopping Distance Requirements Stay Exactly the Same
NHTSA insists that nothing about braking performance itself is loosening. The agency is not proposing any changes to stopping distance requirements, and every vehicle covered by FMVSS No. 135 would still need to demonstrate the same braking performance, regardless of whether a pedal or an onboard computer triggers it. Critics remain skeptical that removing the hardware carries zero risk.
Wipers and Mirrors Could Be Next on NHTSA’s List
The brake pedal is not the endpoint. NHTSA framed its own announcement as an effort to modernize safety standards for equipment that may become obsolete in fully autonomous vehicles, naming windshield wipers and rearview mirrors specifically. Morrison has since gone further in public, telling CNBC that even steering wheel mandates could disappear within years.
Robotaxi Makers Called the Pedal a Design Dead Weight
Companies building purpose-built driverless vehicles have pushed for this for years. General Motors cited this exact kind of regulatory hurdle when it halted its Origin autonomous shuttle project in 2024, arguing a pedal with no function still added cost and design constraints. For Tesla’s Cybercab and Amazon’s Zoox, the rule change could remove a major obstacle to scaling production.
A Footnote Admits NHTSA Has No Answer for Passenger Override
One gap remains unresolved. NHTSA acknowledged in its own filing that it is taking no position at this time on how a passenger should be able to direct a self-driving vehicle to stop, or how the system should respond to that request. The agency says it will address the question later through enforcement authority and future performance standards.
The Rule Bets Safety Lives in Software, Not a Passenger’s Foot
NHTSA’s proposal draws a clear line: the brake pedal was never the safety feature; the stopping distance was. By stripping away a control no rider in a fully driverless car could reliably use in time anyway, the agency is wagering that performance standards, not physical backups, are what actually keep people alive on the road.