I, Cynthia Hites, a citizen of the Commonwealth of Virginia, pursuant to Virginia Code §2.2-4007, do humbly submit this petition for the following amendment to Virginia Administrative Code 24VAC35-60-80. Currently, interlock devices are implemented contrary to the \\"Visual-Manual NHTSA Driver Distraction Guidelines for Portable and Aftermarket Devices.\\" This publication states, \\"Driver distraction is a specific type of inattention that occurs when drivers divert their attention away from the driving task to focus on another activity.\\" \\"Phase 1 Guidelines are based upon a number of fundamental principles.  These principles include that: the driver\\'s eyes should usually be looking at the road ahead; the driver should be able to keep at least one hand on the steering wheel while performing a secondary task (both driving-related and non-driving related); the distraction induced by any secondary task performed while driving should not exceed that associated with a baseline reference task (manual radio tuning); any task performed by a driver should be interruptible at any time; the driver, not the system/device, should control the pace of task interactions; and  displays should be easy for the driver to see and content presented should be easily discernible.\\" These data show that many drivers continue to engage in visual-manual distraction activities with their portable devices while driving. IID rolling retests are very concerning because research by NHTSA shows \\"visual-manual manipulation of devices while driving dramatically increases crash risk.\\" Installed in any vehicle, I believe ignition interlock is an inherent, significant cognitive distraction, but to install IID in a vehicle that is exclusively hand-foot-operated is extraordinarily dangerous to the driver, and to overall public safety. The mandated use of the in-car Breath Alcohol Ignition Interlock Device is the epitome of visual-manual, and cognitive driver distraction, and I submit no IID shall be installed on any vehicle with a non-fully-automatic transmission. In the interest of offender and public safety, please add the following language to the statute: \\"N.  Under no circumstances shall an ignition interlock device be installed on a vehicle having manual transmission.\\" I totaled my 5-speed \\'07 Mustang while retrieving a dropped IID handset, and attempting to simultaneously shift into second gear in order to pull over. Thank you for considering the public safety hazard posed by ignition interlock devices. Cynthia Hites

The Commission on VASAP plans to consider this petition at its October 30, 2020 meeting.