Comment from Jenifer Sanchez Vilchis

(H) 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 provide information comparing school bus (Class B) safety to the higher crash rates seen in Class A combination-vehicle operations. My intention is not to criticize any group of drivers but to clarify why these vehicle classes should not be grouped together in safety discussions. They operate with different vehicle designs, different risk levels, and very different regulatory structures. National data show school buses are among the safest vehicles on the road. NHTSA reports a fatality rate of about 0.2 fatalities per 100 million vehicle miles traveled (VMT) for school buses. Cars, by comparison, have about 1.5 fatalities per 100 million VMT. From 2014 to 2023, there were 971 fatal school-bus-related crashes nationwide with 1,079 deaths, or about 108 per year, and most victims were not bus passengers but occupants of other vehicles or pedestrians. These numbers highlight the exceptional safety performance of Class B school bus operations. In contrast, Class A combination vehicles show significantly higher fatal crash rates. Large trucks account for about 5 percent of registered vehicles and 10 percent of VMT, but are involved in 9 percent of all vehicles in fatal crashes nationally. NHTSA data show fatal crash involvement rates of roughly 1.3 to 1.7 fatal crashes per 100 million large-truck miles. FMCSA’s 2022 Large Truck and Bus Crash Facts report shows that combination trucks, which fall under Class A operations, consistently have higher fatalities per 100 million VMT than single-unit trucks. Although school bus and truck statistics measure slightly different things, the scale difference is clear: Class A combination vehicles have many times the fatal crash risk per mile that school buses do. California data reflect the same pattern. According to the UCI Institute of Transportation Studies, in 2020 large trucks represented only 2.5 percent of vehicles and 5.6 percent of VMT, yet accounted for 9.1 percent of fatal crashes, resulting in 372 deaths and 8,350 injuries. This shows that large trucks, especially Class A freight operations, cause a disproportionate share of fatal crashes relative to their exposure. California’s school bus safety structure, however, is among the strongest in the nation. CHP administers a specialized School Bus Program involving the School Bus Certificate (DL-45), DOJ background checks, written tests, first-aid training, and a behind-the-wheel examination with a CHP school bus officer. Before being tested, drivers must complete behind-the-wheel instruction through the California Department of Education (CDE) or a school district. California school bus training requirements are extensive. CDE’s Bus Driver Instructor Certification Course is a three-week full-time program covering 44 subject areas on laws, liability, safety, and instruction. School bus drivers must receive at least 40 hours of initial training, including 20 hours of classroom instruction and 20 hours behind the wheel, plus 10 hours of annual refresher training. These requirements exceed what many Class A drivers receive in total before operating 80,000-pound vehicles on interstate highways. Additional safeguards apply to school bus drivers in California. They must hold a Class A or B CDL with passenger and school bus endorsements, maintain a School Bus Certificate, complete regular DOT medical exams, pass DOJ/FBI fingerprint clearance, undergo pre-employment and random drug and alcohol testing, and participate in ongoing safety meetings and performance reviews. In California, school bus companies typically operate under formal contracts with school districts. These contracts require strict compliance with safety audits, CHP terminal inspections, driver qualification file reviews, documentation checks, and mandatory training. Districts can impose penalties or terminate the contract if a company fails to meet safety standards. This level of contractual oversight does not exist in the Class A freight industry, which relies mainly on FMCSA enforcement, insurance requirements, and carrier policies. These differences explain why school buses (Class B) are safer than Class A freight operations. School buses are single-unit vehicles without articulation, operate on predictable low-speed routes, and run under the most layered regulatory oversight in commercial transportation. Class A operations involve heavier vehicles, articulation risk, long-distance travel, higher speeds, more miles, greater fatigue exposure, and less comprehensive training or direct supervision. For these reasons, Class A, B, and C crash statistics should be evaluated separately to ensure accuracy and fairness in safety discussions. Link to original docket:https://www.regulations.gov/document/FMCSA-2025-0622-0001