| Justification or Need | CVSA: this is a copy of an email that I am currently sending to the 3,800+ registered ELDT organizations in the country. I have included it here as it summarizes the justification for this change.....
I am a teamster in New York and hold the following CDL credentials:
• Class A license (no Manual Transmission or Air Brake restrictions)
• Passenger and School Bus Endorsements (among others)
• M Restriction (see below)
Vehicle Definitions and Descriptions
Class B Passenger Vehicle examples (16+ pass):
• Straight motor coach
• Straight school bus
• Articulating bus
Articulating Bus:
• In New York, an Articulated bus is a two-unit bus with flexible coupling connection between the units.
• Wikipedia describes Articulated Buses or Trailer Buses.
• FMCSA Guidance: A driver of an articulated bus with a GVWR of 26,001 pounds or more is required to possess a Class B CDL with the proper endorsement(s).
Class A Passenger Vehicle:
• I cannot find any official definition for this vehicle type anywhere on the FMCSA (Federal Motor Carrier Safety Administration) Website or any state DMV for that matter, but commonly called a “trailer bus” or trailer vehicle designed specifically for the transportation of passengers (a bus). Trailer buses typically comprise one of two forms … (see Wikipedia)
• California makes reference to a trailer bus, but not a Class A Passenger Vehicle per se;: A “trailer bus” is a trailer or semitrailer designed, used, or maintained for the transportation of more than 15 persons, including the driver, and includes a connected towing motor vehicle that is a motor truck, truck tractor, or bus.
• Class A Passenger vehicles are like unicorns in the United States, whose use seems to be limited to a few theme parks and military bases.
The Problem – Class Specific Passenger Restrictions Cause Confusion and Hurt Drivers
• The FMCSA, and every state, slaps needless restriction on Commercial Drivers Licenses if they hold a License Class (A) higher than their Passenger Endorsement vehicle Class (B).
• (e) Group A passenger vehicle. If an applicant applying for a passenger endorsement performs the skills test in a passenger vehicle requiring a Group B CDL, the State must indicate on the CDL, if issued, that the person is restricted from operating a passenger vehicle requiring a Group A CDL. (RH note: This is the M Restriction – See below)
M
If a driver possesses a Class A CDL, but obtains his or her passenger or school bus endorsement in a Class B vehicle the State must place an "M" restriction indicating that the driver can only operate Class B and C passenger vehicle or school buses.
• (f) Group A and B passenger vehicle. If an applicant applying for a passenger endorsement performs the skills test in a passenger vehicle requiring a Group C CDL, the State must indicate on the CDL, if issued, that the person is restricted from operating a passenger vehicle requiring a Group A or B CDL. (RH note: This is the N Restriction – See below)
N
If a driver possesses a Class B CDL, but obtains his or her passenger or school bus endorsement in a Class C vehicle; the State must place an "N" restriction indicating that the driver can only operate Class C passenger vehicle or school buses.
• When it comes to CDLs, Endorsements are good and Restrictions are bad, especially when you can’t get rid of them.
• In 2015 the FMCSA decided amended its Passenger vehicle regulations to restrict what you can’t drive rather than endorse what you can.
• Many people, even law enforcement, DMVs and even the FMCSA themselves are confusted about the difference between Class A and Class B passenger vehicles.
• This upside-down regulatory approach also negatively impacts commercial drivers when potential employers mandate that applicants have restriction-free CDLs.
• It doesn’t have to be this way.
Endorsements Demonstrate Knowledge of Different Vehicle Types, Not Restrictions
• The FMCSA should treat Class A Passenger Vehicles the same way they treat School Buses, as an endorsement, not a restriction
• Ex: Class B license holders that earned a Passenger endorsement (P) in a motor coach do not get slapped with a School Bus Restriction
• Instead, a School bus Endorsement (S) is added to the Class B license when the driver passes the road and written test for that vehicle type.
The Solution – Class Specific Passenger Endorsements
• Since there are three types of Passenger vehicle, A, B, and C, the FMCSA should use two-letter symbols to denote the specific Passenger endorsement(s) earned,
• Ex: PA would denote a Class A Passenger (combination) vehicle, PB, Class B Passenger (straight and articulating) vehicles, and PC for Class C Passenger vehicles.
• M and N restrictions would be eliminated.
• This regulatory approach would align with how the FMCSA handles other Endorsements and Restrictions, be easier to understand and not negatively impact drivers.
Can you Help?
• I am working with the FMCSA on getting these changes implemented through their Petition for Rulemaking procedure.
• While I am making some progress but it’s obvious that they need to hear that this is a problem from other folks in the industry.
• What are your thoughts on the matter? (besides the obvious conclusion that I must have too much time on my hands?)
• Your emailed response will be a great help!
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