Comment from Jenifer Sanchez Vilchis

(G) Originally posted comment on 11/21/25 to the closed docket titled "Restoring Integrity to the Issuance of Non-Domeciled CDL." Please see copied and pasted comment below: To FMCSA Leadership: I am writing to highlight the major safety differences between Class B school bus operations and Class A combination-vehicle trucking. These CDL categories are often grouped together in policy discussions, yet their risks, training requirements, vehicle characteristics, and oversight structures differ substantially. Recognizing these distinctions is essential for accurate rulemaking and for avoiding broad assumptions about immigrant drivers, many of whom work safely and professionally in the school transportation sector. Under 49 CFR § 383.91, Class B vehicles include single-unit vehicles such as school buses, while Class A vehicles include articulated tractor-trailers that can weigh up to 80,000 pounds. School buses are rigid, have low centers of gravity, and are built with compartmentalization to protect passengers. They do not articulate and cannot jackknife. These characteristics eliminate many catastrophic crash types that occur in Class A operations. Class A vehicles, governed by the same section of CFR, include articulation points that create jackknife, trailer swing, and wide-turn hazards. Their greater mass and higher speeds increase crash severity. Exposure also differs significantly. School buses operate on predictable, local routes, mostly during daytime hours. They do not regularly travel interstate highways, mountain grades, or severe weather corridors. Class A drivers, by contrast, travel thousands of miles weekly across varying terrain and conditions, increasing exposure to risk. FMCSA data under 49 CFR Parts 390–396 emphasize the importance of vehicle maintenance and operational safety, but exposure alone creates inherent differences in crash likelihood. Training requirements for school bus drivers are far more extensive than those required under the Entry-Level Driver Training rule (49 CFR Part 380) for Class A drivers. School bus drivers must complete a minimum of 40 hours of instruction (20 classroom and 20 behind-the-wheel) in many states, including California. They must also meet specialized requirements for student safety, loading procedures, railroad crossings, mirror systems, and emergency evacuation. In contrast, many Class A ELDT programs focus on minimum proficiency and allow trainees to complete programs in a matter of days, without real-world experience in high-risk environments such as mountain driving or night operations. Oversight of school bus drivers is one of the strongest in commercial transportation. School bus drivers are supervised by school districts, safety coordinators, and state agencies. In California, drivers must obtain a School Bus Certificate under California Vehicle Code § 12517, pass DOJ/FBI background checks, and complete CHP-approved training programs. They undergo daily pre-trip and post-trip inspections, strict drug and alcohol testing, and are held accountable to school district safety contracts. This level of layered oversight exceeds the typical monitoring structure for Class A carriers, which rely largely on carrier policies and FMCSA enforcement under Parts 390–396. Workforce stability further improves safety outcomes. School bus drivers often remain in their positions for years due to predictable schedules and community-based work environments. Experience reduces crashes. The Class A trucking sector, however, experiences turnover rates exceeding 100 percent annually, resulting in many inexperienced drivers operating the most dangerous type of commercial vehicle. Immigrant drivers in school transportation are among the safest and most professional commercial drivers. School bus companies employ DACA recipients, TPS holders, permanent residents, naturalized citizens, and other work-authorized immigrants who undergo repeated federal background checks under 8 CFR § 274a.12. Many have lived in the United States for decades, speak fluent English as required by 49 CFR § 391.11(b)(2), and complete state-mandated school bus driver training. Immigrant school bus drivers consistently demonstrate strong safety compliance, professionalism, attendance, and communication—contributing to the fact that school buses are the safest mode of road transportation in the nation. In conclusion, school bus (Class B) driving is far safer than Class A trucking due to vehicle design, crash physics, lower exposure, stronger training requirements, extensive oversight, workforce stability, and the high performance of immigrant drivers who take pride in transporting children. These differences should be considered in FMCSA policy discussions to ensure CDL categories and driver groups are evaluated accurately. Link to original docket: https://www.regulations.gov/document/FMCSA-2025-0622-0001