APTA Seeks Five Year Exemption from CDL “Under the Hood” Testing Requirement to Address Critical Transit Bus Operator Shortage

APTA Seeks Five-Year Exemption from CDL "Under-the-Hood" Testing Requirement to Address Critical Transit Bus Operator Shortage

• APTA seeks a five-year exemption from the Federal Motor Carrier Safety Administration's (FMCSA) Commercial Driver's License (CDL) "under-the-hood" testing requirement for transit bus operators, as 85 percent of agencies continue to face workforce shortages and 84 percent say these shortages impact their ability to provide critical services.
• The "under-the-hood" test is unnecessary for transit operators since they are not responsible for vehicle maintenance, and often prohibited by labor contracts from performing it. Trained mechanics handle all repairs and diagnostics.
• The CDL "under-the-hood" test also creates equity concerns and serves as a deterrent to certain individuals who would otherwise thrive in this career; it is also becoming obsolete with the industry's transition to zero-emission vehicles.
• The exemption would achieve an equivalent or greater level of safety for transit bus operations and would match similar accommodations already granted to school bus operators.

Washington, D.C. (November 4, 2024) - The American Public Transportation Association (APTA) submitted a formal request to the Federal Motor Carrier Safety Administration (FMCSA) requesting a five-year exemption from the Commercial Driver's License (CDL) "under-the-hood" testing requirement for public transit operators. The proposed exemption would allow states to waive the specific requirement for CDL applicants seeking to operate public transportation vehicles, including those involved in interstate transportation.

"This exemption is crucial for addressing the severe workforce challenges facing our industry while maintaining our unwavering commitment to safety," said APTA President and CEO Paul P. Skoutelas. "The current CDL 'under-the-hood' testing requirement has become a significant barrier to recruiting qualified transit operators, at a time when our industry desperately needs them."

The request comes as new APTA research reveals that 85 percent of public transit agencies continue to face worker shortages, with bus operator positions being particularly challenging to fill.

APTA's research shows that 84 percent of transit agencies cite CDL complexity as a hiring obstacle, with the "under-the-hood" requirement rated as the most challenging aspect of obtaining a license. The requirement is particularly burdensome as transit agencies transition to zero-emission buses, where traditional engine components are being replaced by electric powertrains.

"Public transit agencies employ dedicated maintenance professionals who are responsible for vehicle inspections and repairs," Skoutelas added. "Removing this unnecessary barrier will help us attract qualified candidates while maintaining our industry's exemplary safety record. The proposed five-year exemption would provide a runway for state authorities to update their training and credentialing programs, giving transit agencies the flexibility to meet pressing workforce demands."

Key points supporting APTA's exemption request include:

• Bus operators are not responsible for vehicle maintenance.
• Trained mechanics handle all "under-the-hood" repairs and diagnostics.
• The CDL "under-the-hood" requirement creates unnecessary barriers for otherwise qualified candidates.
• The industry's transition to zero-emission vehicles makes much of the testing obsolete.
• An exemption will provide an equivalent or greater level of safety.

FMCSA has granted a similar exemption to the school bus industry. If approved, the five-year exemption for the public transportation industry would give state licensing authorities adequate time to implement necessary changes while helping transit agencies address critical workforce needs.

The findings are based on a comprehensive report published by APTA in November 2024, which gathered responses from 117 public transit agencies of varying sizes across the United States. Participating agencies provided detailed information about their hiring practices, training procedures, and operational challenges through a standardized questionnaire. The response rate and sample size provide a confidence level of 95 percent with a margin of error of +/- 3 percentage points.

For more information, visit APTA Impact of CDL "Under-the-Hood" Testing Requirement.

Media Contact: Amy Thompson, [email protected] or 202-285-2997.

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