I'm planning on doing a full write up of everything I've learned, but I'll share the gist of it all now. For the record, I ended up going with a shortie that doesn't require any type of special license at all. We'll be starting our build thread shortly!
As far as the whole CDL thing goes, its REALLY complicated, to the point that there isn't a straight answer. CDL rules and licensing are actually based on federal standards that are enforced by each state. If you look at the actual wording of the legislation, FMCSA Standard 383
, you'll see that the definition of a commercial vehicle includes three qualifications and if any are met, the vehicle counts as needing a license. Read carefully though, because the definition also states that the vehicle must be "used in commerce to transport passengers or property".
By the letter of the law, this means that as Roadrunner was pointing out, a vehicle with over a 26000 GVWR doesn't necessarily need a CDL. In PA, it technically needs a class b non-commercial license, but VERY few people actually get them. To be fully legal, you would need one though.
Heres where things get really complicated. From my understanding, a vehicles registration is basically your statement of intended use. Your options for how you can register a vehicle are connected to how it is titled. If your bus is titled as a bus when you get it, then your option for registering it seems to be as a bus and only as a bus. I'm not sure if you could get away with it being a truck or not. If you are stuck registering it as a bus, then it seems you're stating that you plan on using it as a bus (even though they forced you to choose that option). If you're registered as a bus over 26000 lbs, then you may be in a danger zone as far as what license they expect you to have if you were to be pulled over.
In order to retitle a bus as an RV (and by extension be able to register it as one as well), PA has a set of requirements you must meet. First you have to have at least 4 of the following:
• Cooking appliance
• Self-contained toilet
• Heating/Air conditioning
• Portable water supply
• Faucet and sink
• Separate 110/125 or LP gas supply
Once you have that, you have to have a special inspector come and take photographs with initials to verify everything. At that point, you would also need an enhanced vehicle inspection done at a special inspection station.
This is only to complete the RV retitling in PA. If you buy a bus already retitled, then it appears as though you are lucky and get to skip all these steps. Many states have very lax laws and if you declare an intention to use it as an RV, then that is good enough. (Side note: if you find a bus in a state that has easy title change rules, you may want to pay the owner to retitle it before you buy it. Just a thought and please verify that this will work ahead of time. Don't just rely on some random guy on the internet).
If you are buying a bus titled as a bus, then what you need to figure out is how to register it in a way that avoids special licenses. What ends up working for you will depend on who you talk to and what they are willing to do. According to my local notary/tag service, I can declare any GVWR between the one listed in the vehicle and the curb weight. The declared GVWR would become the maximum I'm allowed to use on public roadways and if caught exceeding that weight, hefty fines could ensue. This could be an interesting way to get a vehicle below the 26000 threshold until you complete the conversion and retitle as an RV.
Sorry if thats confusing. Like I said, I'll go back through and try to write a more thorough and thought out account of what I have learned. I spent several weeks discussing the matter with literally every person I could contact within PennDOT. This was essentially everyone, as I got a hold of their internal directory and just called every president, vp, and other bigwig on the list in the various departments. Most people directed me to one of a handful of people who I narrowed my focus to. They did not even know the answers and these are the people that are supposed to be making/enforcing/educating about these laws! What I laid out above is the basic account of what they shared, but when I tried to get more details or specifics it always came back to "I don't know, I'll check and call back tomorrow." Eventually they gave up and stopped calling back
Let me know if you want me to clarify anything!