On May 28th, 2019 the National Highway Traffic Safety Administration (NHTSA) requested public comment on the near- and long-term challenges of testing and verifying compliance with existing crash avoidance (100-series) Federal Motor Vehicle Safety Standards (FMVSSs) for Automated Driving System-Dedicated Vehicles (ADS-DVs) that lack traditional manual controls necessary for a human driver to maneuver the vehicle and other features intended to facilitate operation of a vehicle by a human driver, but that are otherwise traditional vehicles with typical seating configurations. This document seeks comments on the suitability of various approaches that could be used to address compliance verification challenges that exist for crash avoidance standards that either require a manual control; or specify the use of manual controls in a compliance test procedure. NHTSA's long-term goal is to use what the agency learns from this ANPRM, as well as the agency's other research efforts, to develop a proposal to amend the crash avoidance FMVSSs in ways that address these and other compliance challenges with a continued focus on safety. This ANPRM builds on NHTSA's efforts to identify and address regulatory barriers to ADS technologies, including the request for comments (RFC) on this topic in January 2018. NHTSA intends to issue two additional documents to remove barriers in the crashworthiness FMVSSs (200-series standards) and address issues in the FMVSSs pertaining to telltales, indicators, and warnings in ADS-DVs. Comments on this advanced notice of proposed rulemaking are due no later than July 29, 2019.