As noted on the Federal Motor Carrier Safety Administration (FMCSA) website, “FMCSA’s Entry Level Driver Training (ELDT) regulations set the baseline for training requirements for entry-level drivers.” These regulations govern how states issue commercial driver’s licenses (CDLs). However, current FMCSA requirements to obtain a CDL are focused on trucking. The needs of transit vehicle drivers were not a primary consideration in the development of these regulations, which focus on vehicle size, loaded weight, and seating capacity. In addition, the major differences between work assignments and mechanicals are ignored. Local and regional transit work assignments, unlike trucking, involve a collection of much shorter one-way trips with built-in break times between. While some transit vehicles are heavy-duty and diesel-powered—rated for a minimum 12-year life similar to trucks—many are smaller gasoline- or propane-powered vehicles.

There are several consequences to vetting job candidates for long-haul trips and training that require them to pass a CDL test on a vehicle they will never drive, and grouping those drivers into a queue that includes all long-haul trucking candidates. These include:

• A lengthy lead time to vet applicants before accepting them as training candidates and the expense of paying them during the training period while waiting for the police and driving records. Many desirable candidates find other work during that interval, which can be six weeks.
• The loss of applicants (and existing drivers) who fail CDL physical examinations designed for long-haul trucking, have serious difficulty procuring an examination in the first place, or leave positions due to frustration with the frequency of examination appointments.
• A focus on mechanical abilities that many transit drivers are forbidden to use. Transit systems have maintenance technicians who can come to the vehicle or meet the vehicle at the end of the route or at a transit hub.
• An excessive focus on the vehicle, in what is a primarily customer service career. Transit drivers are not loading and unloading the vehicle, seldom service the vehicle, and will never have to back a tractor-trailer into a loading dock.

The transit industry needs an honest assessment of issues, impediments, needless expenditures, and other challenges with the current CDL acquisition process and suggestions for improvements with return on investment (ROI), including for safety. While automated driving technologies have been promoted as a potential response to the public transportation labor shortage, the safety of these concepts, especially in mixed traffic, is still unproven. Trained and licensed drivers are necessary to safely negotiate mixed traffic at a reasonable speed, deal with unforeseen obstacles, assist riders with disabilities, respond to inquiries, and maintain order on board.

Can the vetting process before training commences be shortened and become more inclusive? What aspects of candidate backgrounds need to be reviewed for this combined customer service and driving position? How can citizens returning from incarceration become candidates? How can veterans be recruited when they leave the service? Should recruits receive paid classroom training while the motor vehicle and criminal record checks are in process? Overall, how can this process become more efficient while still safe?

Other issues to be examined include (1) should competencies be built into CDL training to ensure operators are proficient driving zero-emission buses/battery electric or hydrogen-powered buses (e.g., pre-trip inspection). (2)  Since transit assignments involve a collection of short trips with built-in breaks, what are the minimum health requirements for a transit driver? Do these real requirements for safety match current DOT physical examination components and requirements for frequency of assessment? (3) How can access to physical examinations be expanded, particularly in rural areas? (4) As driving a transit vehicle is primarily a customer service position, many riders have disabilities, and some customers display an unproductive attitude, are the minimum training requirements for a passenger endorsement adequate? Which customer service training topics should be covered? (5) How can the minimum English proficiency of a transit driver be assessed? Many candidates with lower English proficiency have the driving skills and customer service ethic to be good candidates. (6) What types of organizations, including workforce intermediaries and transit agencies themselves, are engaged in CDL training, and to what extent does training serve as a mechanism to advance equitable career pathways and DEIA goals within public transit? (7) Are additional grant funds needed to expand state CDL administrative capacity?