On Sept. 5, CVSA, on behalf of the Commercial Vehicle Brake Manufacturers Council (CVBMC), submitted comments regarding the joint notice of proposed rulemaking (NPRM) from NHTSA and FMCSA proposing automatic emergency braking (AEB) and other related requirements for heavy duty vehicles. CVSA and CVBMC strongly support deployment of safety technology, like AEB, proven to mitigate the severity of crashes and save lives, and they applaud NHTSA and FMCSA for moving forward with this critical rulemaking. After reviewing the NPRM, however, CVBMC has identified a number of challenges with the proposed implementation, testing procedures and timeline that should be addressed prior to the agencies publishing their final rules. The comments include specific feedback to the proposal, responses to the questions posed by NHTSA and FMCSA and several general observations for NHTSA and FMCSA to consider.