Comment from Jenifer Sanchez Vilchis

(B)To FMCSA Leadership: I am writing to provide information regarding the structural safety differences between Class B and Class A commercial vehicle operations. My goal is to highlight why Class B licensing—especially in the school transportation sector—results in safer outcomes compared to Class A combination-vehicle operations. This is not a criticism of any group of drivers. It is a clarification of the operational, regulatory, and training differences between these CDL classes. A Class B CDL, defined under 49 CFR 383.91(b), allows the operation of single-unit vehicles with a GVWR of 26,001 pounds or more and a trailer under 10,000 pounds. These vehicles include school buses, transit buses, dump trucks, straight trucks, and vocational vehicles. Because Class B vehicles are single-unit vehicles, they do not have articulation points and do not experience trailer swing or jackknife risk. This eliminates several of the highest-risk crash scenarios associated with Class A combination vehicles. Data from FMCSA and state sources consistently show that single-unit Class B vehicles are involved in significantly fewer fatal crashes than Class A combination vehicles. Class B operations are generally safer for several reasons. First, Class B vehicles have no trailer and therefore no pivot points, reducing loss-of-control scenarios. Second, most Class B drivers operate locally at lower speeds within city limits, follow structured routes, and face less severe weather exposure. Less highway exposure and shorter daily mileage significantly reduce the chance of high-speed or fatigue-related crashes. By contrast, Class A drivers may travel thousands of miles weekly across multiple states. School transportation, which uses Class B licensing, has the strongest safety oversight of any commercial driving sector. School bus companies and school districts follow Department of Education rules, district contracts, mandatory safety audits, annual inspections, ongoing training requirements, background checks, and drug and alcohol testing. No other commercial vehicle sector is subject to this level of dual state and federal scrutiny. School bus operations also maintain lower turnover, which means more experienced drivers remain in service. Class A long-haul trucking, by comparison, frequently experiences turnover rates exceeding 100 percent annually, placing many inexperienced drivers in the highest-risk vehicle class. Training for Class B operations, particularly school buses, is also significantly stronger. In addition to meeting Entry-Level Driver Training requirements under 49 CFR Part 380, school bus drivers must complete extensive state-level certification. This includes passenger endorsement and school bus endorsement training under 49 CFR 383.123. School bus drivers receive instruction on emergency evacuation procedures, student behavior management, railroad crossing protocols, mirror use, loading and unloading procedures, and child-safety requirements. Class A drivers are not required to complete these safety modules. Many states mandate more total training hours for Class B school bus drivers than some Class A programs require for combination-vehicle operation. Contracted school bus operations add further oversight. School districts require compliance with scheduled and random drug testing, background checks, annual medical exams, performance evaluations, route supervision, zero-tolerance safety violations, and documented corrective action plans. Districts can impose penalties, fines, or contract termination if operators fail to meet safety standards. This creates continuous accountability throughout the year. Class A freight operations do not operate under the same type of direct contractual supervision. Class B school bus operations also have lower crash rates due to the structured nature of the work. Drivers operate predictable routes at low speeds, under direct supervision of transportation coordinators. School bus fleets undergo daily pre-trip and post-trip inspections, emergency equipment checks, and documentation audits. These inspection routines exceed the practices used in many Class A fleets. In summary, Class B licensing—especially in school transportation—demonstrates significantly safer outcomes than Class A operations because Class B vehicles are single-unit vehicles without trailers, operate on shorter and slower routes, have stronger and more frequent training, and fall under extensive oversight from both state agencies and school districts. Class B sectors maintain more experienced drivers and more stable workforces. Class A operations involve greater risk because of vehicle weight, articulation, highway speeds, long-distance exposure, limited training programs, and wide variations in company enforcement. These differences show why Class A, B, and C crash data should be evaluated separately for accuracy and fairness. Thank you for your attention to these distinctions and commercial safety.