Commercial Driver’s License: Application for Exemption; National School Transportation Association

July 20, 2026 Re: Renewal of FMCSA Exemption for the Under-the-Hood Portion of the CDL Pre-Trip Inspection for School Bus Driver Applicants To Whom It May Concern: The American Bus Association (ABA) appreciates the opportunity to submit comments in support of the National School Transportation Association's request to renew the Federal Motor Carrier Safety Administration's (FMCSA) exemption related to the under-the-hood portion of the commercial driver's license (CDL) pre-trip inspection for school bus driver applicants. The commercial bus and motorcoach industry, like the school transportation sector, continues to face persistent driver shortages that challenge operators' ability to meet growing transportation demands. Reducing unnecessary barriers to CDL attainment while maintaining rigorous safety standards is critical to strengthening the nation's professional driver workforce. The under-the-hood portion of the CDL skills test requires applicants to memorize engine component identification that is largely unrelated to the day-to-day responsibilities of professional drivers. In practice, maintenance, engine diagnostics, and mechanical repairs are performed by trained technicians, while drivers are responsible for conducting operational safety inspections, identifying visible defects, reporting maintenance issues, and safely operating their vehicles. Eliminating this portion of the examination does not diminish a driver's responsibility for conducting thorough pre-trip inspections or operating safely. ABA also recognizes the value this exemption provides in supporting driver recruitment and retention within the school transportation industry. Because the exemption results in a restricted CDL limited to intrastate school bus operations, it helps retain qualified drivers in student transportation while expanding the pipeline of individuals entering the profession. Supporting a stable school bus workforce ultimately benefits the broader commercial transportation industry by strengthening overall workforce participation and reducing unnecessary obstacles to licensure. Importantly, the exemption has not compromised safety. School buses remain one of the safest forms of transportation in the United States, and drivers operating under this exemption continue to meet all applicable training, testing, and operational safety requirements. The exemption simply removes a testing element that does not meaningfully measure the knowledge and skills required for the safe operation of a school bus. For these reasons, the American Bus Association respectfully urges FMCSA to approve the requested extension of the exemption through 2031. Sincerely, Fred Ferguson President & CEO American Bus Association

Filed on regulations.gov — full text not in the inline record.