Comment from Jenifer Sanchez Vilchis

(G) Originally posted comment on 11/20/25 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 conducted research on national and California crash statistics to better understand differences between Class A and Class B operations. The data consistently show that Class A combination-vehicle operations are involved in more severe crashes and have higher fatality rates than Class B or Class C vehicles. According to FMCSA’s Large Truck and Bus Crash Facts 2022 report, combination trucks were involved in 3,408 fatal crashes in 2022, compared to 2,032 fatal crashes involving single-unit trucks. Combination trucks include tractor-trailers and vehicles pulling trailers and align most closely with Class A CDL operations. FMCSA also reports higher fatality rates per 100 million vehicle miles traveled for combination trucks, reflecting their higher inherent risk. NHTSA’s Traffic Safety Facts for 2023 reported 5,472 fatalities in crashes involving large trucks. A substantial portion of these crashes involve combination vehicles, further supporting the elevated risk profile of Class A operations. Nationally, the most severe crashes consistently involve the vehicle configurations typically operated under a Class A license due to their weight, speed, and operating conditions. California data show the same pattern. The University of California, Irvine reported that in 2020, large trucks represented only 2.5 percent of vehicles and 5.6 percent of vehicle miles traveled but were involved in 9.1 percent of fatal crashes. These crashes caused 372 deaths and 8,350 injuries. Caltrans data similarly show that large trucks are overrepresented in fatal collisions relative to their share of traffic. This indicates a higher risk per mile for heavy combination vehicles in California. These statistics do not separate drivers by immigration status, English proficiency, or domicile category. The increased risk is due to vehicle type and operating environment. Combination vehicles weigh up to 80,000 pounds, have articulation points, longer stopping distances, and large blind spots. These factors make severe crashes more likely compared to single-unit Class B or Class C vehicles. Several systemic factors contribute to higher Class A crash rates. First, Class A vehicles are inherently more dangerous due to weight, length, articulation, and braking dynamics. A minor mistake can become catastrophic. Second, Class A drivers generally travel more miles at highway speeds across multiple states and through severe weather, increasing exposure to risk. Training deficiencies also play a major role. Although 49 CFR Part 380 establishes Entry-Level Driver Training requirements, many schools teach only what is needed to pass the exam. New Class A drivers often lack real-world instruction in mountain grades, winter driving, jackknife prevention, backing 53-foot trailers, and night operations. Many programs last 10 to 14 days instead of several weeks, leaving major skill gaps for both immigrant and non-immigrant drivers. Enforcement of the English-language requirement under 49 CFR 391.11(b)(2) has also been inconsistent. Drivers must read and speak English to understand signs, communicate with law enforcement, read placards, and complete reports. When states do not consistently enforce this rule, drivers may operate without fully understanding critical safety information. This is a safety issue, not a nationality issue. State-level failures related to non-domiciled CDLs also contribute to inconsistent oversight. Under 49 CFR 383.71, states must verify lawful presence and ensure non-domiciled CDLs expire with authorized stay. Federal audits found that some states issued or renewed non-domiciled CDLs without proper verification, creating regulatory gaps unrelated to driver behavior. Industry structure adds further risk. Many carriers assign new Class A drivers to long-haul, nighttime, or hazardous routes without proper supervision. High turnover rates in the Class A sector result in many inexperienced drivers operating the most dangerous vehicle class. By contrast, Class B and Class C sectors such as transit, school buses, and waste management have more stable and experienced workforces. In summary, national and California statistics clearly show that Class A combination vehicles account for more severe crashes than Class B or Class C vehicles. The reasons include vehicle physics, higher mileage exposure, limited training quality, inconsistent enforcement, state administrative failures, company pressure, and high turnover. These factors—not immigration status—explain why Class A crashes occur more frequently and with greater severity. Class A operations require stronger training, supervision, and consistent regulatory attention to ensure public safety. Link to original docket: https://www.regulations.gov/document/FMCSA-2025-0622-0001