APTA requests five-year exemption from CDL ‘under the hood’ testing requirement for public transit operators

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. 

According to APTA, its 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 association says 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 said. “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. 

APTA notes 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 association says the findings are based on a comprehensive report published by APTA in September 2024, which gathered responses from 117 public transit agencies of varying sizes across the U.S. 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 +/- three percentage points.