Comment from Fidel MORA ROSALES

In the name of justice and fairness I urge The Federal Motor Carrier Safety Administration to exempt DACA recipients from the restrictions imposed by the 2026 Non Domiciled Commercial Driver’s License (CDL) Final Rule. As drafted, the rule is operationally disruptive, and disproportionately punitive, functioning as a primitive and draconian measure that unjustly and collectively penalizes DACA recipients who possess a well documented record of safety, stability, and compliance. DACA recipients are not foreign operators unfamiliar with U.S. systems, they are were raised and educated through the American school system, completing K–12 curriculum, participating in state regulated educational environments, and integrating into the same civic and institutional frameworks that prepare U.S. citizens for professional licensure. Their ongoing participation in the DACA program requires continuous federal background vetting, biometric checks, and recurrent eligibility reviews — a level of federal oversight that exceeds the monitoring applied to most domestic CDL holders. By failing to create an exemption for DACA recipients The FMCSA will effectively weigh down a collective punishment on thousands of innocent CDL holders who have fervently followed the rigid institutional framework set before them. Additionally, from an operational standpoint, DACA recipients currently serve in high demand, safety critical transportation roles, including public transit operations and school bus services. These sectors are experiencing acute workforce shortages, with vacancy rates that threaten service continuity in multiple states. Removing DACA operators from eligibility would produce immediate negative externalities, including reduced route coverage, increased service delays, and heightened strain on municipal and school district transportation systems. The Final Rule also fails to account for the modern safety architecture of commercial transit fleets. Contemporary buses and commercial vehicles are equipped with: •Multi camera interior surveillance systems (commonly six or more cameras per vehicle) •AI enabled dash cam platforms capable of real time behavioral analysis •Automated event trigger reporting to carrier safety departments •Continuous telematics monitoring, including speed, braking, lane deviation, and operator attentiveness metrics These systems create a redundant, data driven safety environment that significantly mitigates operator related risk. DACA drivers operate under these same systems and, due to their federally monitored immigration status, are subject to additional layers of accountability beyond standard CDL holders. The combined effect of professional training, telematics oversight, and federal vetting produces a driver cohort that is demonstrably low risk from a safety and liability perspective. By imposing blanket restrictions on this population, the Final Rule introduces regulatory inefficiency and unnecessary operational harm without producing measurable improvements in roadway safety. The rule’s structure effectively removes vetted, monitored, and technologically supervised operators from a workforce already in crisis, creating a predictable and avoidable degradation of national transportation capacity. Lastly, the 2026 Final Rule would have severe and measurable consequences for DACA recipients who currently hold or seek to maintain commercial driving credentials. These individuals have built careers in transportation precisely because the sector offers stable employment, upward mobility, and a clear pathway to long term economic security. The rule would: •Eliminate primary income sources, forcing drivers out of established careers and into lower wage, less stable work. •Disrupt family financial stability, particularly for households where the CDL holder is the primary earner supporting children, elders, or extended family. •Invalidate years of training and investment, including state approved CDL coursework, employer provided safety certifications, and specialized endorsements. •Sever ties to community institutions, especially for DACA drivers employed in school districts, where they have longstanding relationships with students, parents, and staff. •Impose psychological and social harm, as individuals who were educated in American schools and raised in American communities are suddenly reclassified as unfit for the very jobs they have performed safely and professionally. •Create geographic displacement, as affected drivers may be forced to relocate or leave regions where transportation work is the primary available employment. In short, the Final Rule would not merely adjust licensing criteria — it would upend the lives of thousands of individuals who have complied with every federal requirement, contributed to their communities, and maintained exemplary safety records.