Comment from Jenifer Sanchez Vilchis

(A) Originally posted comment on 11/21/25 to the closed docket titled "Restoring Integrity to the Issuance of Non-Domeciled CDL." See below: To FMCSA Leadership: I am writing to share concerns regarding the current state of Class A commercial driver licensing and to respectfully request strengthened training, supervision, and oversight, especially in the areas of English proficiency and non-domiciled CDL issuance. I want to make it clear that I am not criticizing or discriminating against immigrant drivers. I am an immigrant myself, a DACA recipient married to a U.S. citizen, and I support immigrant workers. Immigrants make up a large portion of the national trucking workforce and are essential to the supply chain. The problem is not who receives a Class A license, but how the license is issued, trained, and supervised in certain jurisdictions. What is a Class A CDL? A Class A license is defined under 49 CFR 383.91. It authorizes operation of combination vehicles with a GCWR of 26,001 pounds or more and a trailer over 10,000 pounds GVWR. These include tractor-trailers, semi-trucks, tankers, flatbeds, and double or triple trailers. Class A vehicles have articulation points, long stopping distances, high centers of gravity, limited visibility, and complex air brake systems. Because of their size and speed, Class A crashes tend to be far more severe than incidents involving Class B single-unit vehicles such as buses or straight trucks. Safe operation requires strong English comprehension, extensive hands-on practice, and the ability to follow detailed safety instructions. Why problems have increased: 1.Rushed or insufficient training Entry-Level Driver Training (ELDT) requirements under 49 CFR Part 380 set minimum theory and behind-the-wheel standards. However, many training programs focus on passing the exam rather than real-world skills such as winter operations, mountain driving, backing long trailers, or jackknife prevention. As a result, new Class A drivers, both immigrants and non-immigrants, often enter high-risk routes without adequate preparation. 2.Weak English-language enforcement Under 49 CFR 391.11(b)(2), CMV drivers must read and speak English well enough to understand traffic signs, respond to law enforcement, and complete required reports. Enforcement has varied widely across states. This is a safety issue, not a nationality issue. Strong enforcement ensures immigrant drivers are properly trained and supported, and it protects all motorists on the road. 3.Oversight failures with non-domiciled CDLs 49 CFR 383.71 requires states to verify lawful presence when issuing non-domiciled CDLs and to ensure the CDL expires when the individual’s authorized stay ends. Federal audits found that some states, including California, issued or renewed non-domiciled CDLs without proper verification or timely cancellation. These issues stem from administrative oversight, not from the drivers themselves. 4.Company pressure and inadequate supervision Under 49 CFR Part 390, carriers must ensure safe operation. Yet many new Class A drivers are placed immediately into long-haul, nighttime, or hazardous routes without mentorship or gradual introduction. This creates fatigue, stress, and increased risk of error. Immigrant drivers may be especially vulnerable because they may hesitate to question dispatch or refuse unsafe loads. National safety comparison FMCSA crash data shows that combination trucks (covered by Class A under 49 CFR 383.91) are involved in more severe crashes than single-unit trucks or buses. This is due to physics, weight, speed, and operational complexity—not driver origin. Because combination vehicles travel more miles under more demanding conditions, they require stronger training and oversight. California’s role California has recently faced scrutiny regarding compliance with non-domiciled CDL requirements (49 CFR 383.71) and English-language enforcement. Although California has one of the lowest commercial-vehicle fatality rates per mile, the administrative issues identified through federal audits show the need for uniform national standards and consistent oversight. Request for action I respectfully encourage FMCSA to strengthen: •Oversight of non-domiciled CDL issuance under 49 CFR Part 383 and Part 384 •Enforcement of English proficiency under 49 CFR 391.11(b)(2) •Requirements for hands-on Class A training under 49 CFR Part 380 •Mentorship or supervised driving periods for new Class A drivers •Audits of CDL schools and employer training programs under 49 CFR 384.305 •Public transparency regarding state-level compliance findings These steps will improve safety for all drivers, immigrant and non-immigrant alike, and restore confidence in the Class A licensing process. I also ask that properly authorized immigrants, including DACA, TPS, and other recipients, receive their valid Class A licenses without delays or administrative barriers, consistent with 49 CFR 383.71.