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Old 02-15-2018, 11:29 PM   #1
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Do I or do I not need a CDL?

The issue of whether or not you will need to have a CDL seems to be a continuing question.

As someone who has been training drivers to drive school buses in WA state before the CDL rules came into practice I think I am in a position to answer that question.

One caveat, the rules to which I refer are the rules in WA state and apply pretty much the same way in OR.

The rules are really simple. If it is yellow and has black stripes and it says School Bus on the front and rear of the bus you will be required to have a CDL with a school bus endorsement. If you have driven a church bus, motorcoach, charter bus, or a transit bus and you have a CDL with a passenger endorsement you still can't drive a school bus. And the opposite side of the coin applies as well that if you have a school bus endorsement you can't drive any other sort of bus.

If your bus is no longer a school bus (the crossover lights are inoperable, the top paddle is removed, and it no longer says school bus on the front and rear of the bus) it would fall under the category of bus which would require you to have a CDL with a passenger endorsement if the bus has seating positions for more than 15-passeners in addition to the driver. Here on the left coast it doesn't matter if you are driving the bus empty, for hire, for free, or just for fun you will still need to have a CDL with a passenger endorsement.

If however after you have removed or disabled all of the school bus equipment and removed enough seating positions so that there are no more than 14 seating positions in addition to the driver you can then go through the process of changing the title, registration, and license from school bus/commercial bus to recreational vehicle (some states will change the designation to motor home or house car or some other classification that is not a commercial or school bus classification). If however you don't remove enough seating positions your bus will still be classified as a bus (see entertainer coaches for example that have kitchens, bathrooms, and sleeping berths for 20 people).

The fact your bus may have a GVWR in excess of 26,001 won't matter if it is classified as an RV. In fact, the only time GVWR comes into play in regards to buses is anything under 16,000 GVWR requires only a class 'C' CDL but anything heavier requires a Class 'B' CDL.

Here in WA state the weight cops have gotten together with the licensing people and you can no longer renew a vehicle license on any vehicle with seating positions for more than 15-passengers in addition to the driver or a vehicle over 16,000 GVWR without proving why you do not need a USDOT number to operate said vehicle. The exemptions are farmers and fire departments. In other words, in WA state if you don't change the classification you will have a difficult time renewing the license.

There are some work arounds that you can do but they are only good for a trip or two. I have been involved with buses since 1976. In all that time I can count on one hand how many times I have ever seen a yellow bus pulled over for a traffic infraction. The odds of you getting pulled over to have your license, registration, and proof of insurance checked are virtually zero. It isn't legal but moving your bus home from wherever you purchased it will rarely catch the eye of any cop unless you are blatantly violating traffic codes.

WA driver's licenses do not have any classifications for any non-commercial operation. A normal run of the mill driver's license that allows you to drive your family mini-van is the same license that will allow you to drive a 45' converted motorcoach pulling a three axle enclosed trailer with a GVWR of 20,000 lbs. If you were to try and pull that same trailer behind any truck on which you pay tonnage you would be required to have a Class 'A' CDL because the trailer GVWR is greater than 10,000 lbs.

I suppose what I am saying is you need to know what you have to have in regards to driving legally in the jurisdiction in which you live. There are a lot of variables across the country and the enforcement is greater or lower depending on a lot of factors with revenue generation being high on the list for motivation to enforce laws.

Good Luck and Happy Trails as you embark on a great adventure with a bus!
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Old 02-15-2018, 11:38 PM   #2
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good info. gonna throw this in case anyone else from tx looks here

For TX ive come to understand that any bus under 26,001 can be driven with a normal class c license, but anything higher requires a class b cdl, while the vehicle is registered as a bus. Seems to be similar case in some other states as well. To get the bus registered as an RV though, you have to meet certain steps (4 out of 6 i think), and bring the vehicle in for inspection
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Old 02-16-2018, 12:21 AM   #3
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good info. gonna throw this in case anyone else from tx looks here

For TX ive come to understand that any bus under 26,001 can be driven with a normal class c license, but anything higher requires a class b cdl, while the vehicle is registered as a bus. Seems to be similar case in some other states as well. To get the bus registered as an RV though, you have to meet certain steps (4 out of 6 i think), and bring the vehicle in for inspection

I think the 4 out of 6 steps are pretty standard around the country:
  1. Stove--this can be as simple as an old Coleman stove set up on a table or one of the new camping stoves that has legs
  2. Toilet--this can be as simple as a toilet seat on a bucket
  3. Bed--this can be as simple as a mattress thrown on the floor
  4. On board water system--this can be very simple but requires a storage vessel and some sort of delivery system to a sink
  5. On board 110-VAC electrical system--It has to be something more than a drop cord stuck out a window
  6. Refrigerator/ice box--this can be as simple as a cooler mounted to the floor
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Old 02-16-2018, 05:07 AM   #4
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spot on cowlitz.

I only have my class A for work purposes. When I first had the bus I didnt have it and people would ask me in person "dont you need your CDL for that?" and i'd reply with a "No, not if....etc and go on a big ramble" and they'd still be a little skeptical. Now all i say is "No, but i have it anyway." was so tired of explaining to people i see why you dont.
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Old 02-16-2018, 09:19 AM   #5
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Thank you Cowlitz,

Very well put!
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Old 02-16-2018, 10:36 AM   #6
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There is something odd going on in Washington State that appears to be at odds with most of the country.

What Cowlitzcoach said above, I wouldn't even begin to dispute in any way at all.

However, that description of the process doesn't match the rules in other places.

Do I Need A CDL?

To determine whether or not you need a CDL you have to ask yourself one question:

Am I driving for a commercial purpose? This includes ferrying kids to church, boy scout camp, etc.

If the answer is "No", then generally you do not need a CDL. This is because the CDL rules are Federal rules imposed under the Commerce Clause of the constitution. The CDL rules are predicated entirely on their opening that states that the rules apply only to those driving for a commercial purpose.

The rules are about driving, not about vehicles. The rules go on to impose restrictions on the vehicle you may drive, but the premise remains the same.

Driving is an activity regulated by the states, with the sole exception of commercial driving.

So you then have to go to your state to see what restrictions are placed on your regular state drivers license. In my case I was good to go, because Oklahoma imposes no additional restrictions. Vehicles are not regulated either by weight or type in my state so all I had to do was ensure that I was driving for personal reasons only (moving a bus, my bus, from Nebraska to Oklahoma. Moving it for my personal use, not for any reason connected with commerce).

Not all states are as loosely regulated. In Texas, and in common with many others, your driving privileges are restricted usually by weight. In that state I would have needed a Non-Commercial Class B added to my license before I was entitled to drive. So if Texas issued your license, or any one of a number of states, then you too would need the extra Class or Classes adding before you drive. In Oklahoma everything is a car, unless you are driving commercially.

The outlier in all of this is Washington State. I haven't looked at the rules there and have zero reason to dispute someone with a deep knowledge of his own state. This is not the first time someone has said that you need a CDL in WA to drive a bus for personal reasons.

I don't really know what I would do if faced with that. It's clearly not lawful to make that requirement, and probably not enforceable, but who wants to be the guy who challenges it?

WA is perfectly entitled to incorporate the provisions of the federal regs into their codes, but they are not entitled to modify federal regulations in the way they seem to have done. They can't, for example, insist on a CDL for non-commercial driving, because those regulations do not cover non-commercial driving, and states don't get to amend federal rules.

I don't know the answer. Maybe they have changed state law and I have missed it, but insisting on a CDL is wrong ... and I'm glad I don't have to worry about it.

I don't want to enter any kind of dispute about this, please feel entirely free to tell me I'm wrong, provide examples, etc. I am not personally invested in this matter. I know the rules in my state and I understand that the rules vary frome state to state.

As with all things, check the rules that apply to you, yourself. Be aware that the people in your Tag Office, or local DMV might not know the answers, and that the state will only give you accurate information if you ask them the correct questions.

It's a minefield, the saving grace being that big yellow buses are almost invisible to law-enforcement. Do your very best to comply with the laws, drive carefully and don't be a dick and the chances are good that you will get home completely unscathed.
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Old 02-16-2018, 10:49 AM   #7
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How do you get around the 26000GVWR? Here in Ga. you would need a class B CDL. on the mere weight alone, no matter the use of the vehicle.
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Old 02-16-2018, 10:54 AM   #8
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In Washington RV'S, used for non-commercial purposes, are exempt from the CDL requirements.
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Old 02-16-2018, 10:59 AM   #9
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How do you get around the 26000GVWR? Here in Ga. you would need a class B CDL. on the mere weight alone, no matter the use of the vehicle.
In Georgia I believe you need a Non-Commercial Class E or F.

They are one of the states that uses different letters.
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Old 02-16-2018, 11:02 AM   #10
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In Washington RV'S, used for non-commercial purposes, are exempt from the CDL requirements.
its the same in texas. no cdl at all once its registered as an RV. all i can advise is check what limitations georgia has on RV
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Old 02-16-2018, 11:06 AM   #11
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Nearly all states (note I said "nearly all") have a caveat stating that RV's or Motor Homes are exempt from any "Commercial" license requirement. Often it is buried in the legalese, but "usually" there to be consistent with Fed Regs.
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Old 02-16-2018, 11:12 AM   #12
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Nearly all states (note I said "nearly all") have a caveat stating that RV's or Motor Homes are exempt from any "Commercial" license requirement. Often it is buried in the legalese, but "usually" there to be consistent with Fed Regs.
Yup, this ^^^

That doesn't mean that all RVs are exempt from state weight restrictions though.

A heavy RV might still need a Non-Commercial Class adding to a license. You'd have to check.
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Old 02-16-2018, 11:17 AM   #13
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Roger that. All the state weight regs I have ever heard of are (as you note) outside any "Commercial" requirement. Simply an upgrade to any standard issue license. Therefore...no "C" required.
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Old 02-16-2018, 11:25 AM   #14
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Roger that. All the state weight regs I have ever heard of are (as you note) outside any "Commercial" requirement. Simply an upgrade to any standard issue license. Therefore...no "C" required.
It seems that the response of the states, to the feds requiring licensing for commercial vehicles, differed for state licenses.

Some did nothing (Oklahoma)

Some added Classes to state licenses to cover private use

It was to cover the fact that the CDL simply doesn't apply to private use, but that states felt that drivers of heavy vehicles should require extra testing (a good thing, in my view).

WA isn't the only outlier, PA has an odd requirement too.

PA says that you need a Non-Commercial Class A or B, but that you must also pass the Class B test if your vehicle has air-brakes, whatever the weight of the vehicle.
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Old 02-16-2018, 12:01 PM   #15
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WA doesn’t have non-commercial license classes for heavy vehicles. They also don’t seem to specify (in legalese that I can find) that an RV must be registered in any particular way. The legalese seems to define RV by use. There is a motorhome registration available but the legalese uses the term RV when talking about cdls. There is also a broad exemption for vehicles pulling horse trailers for personal use that seems to allow any weight vehicle without a cdl for that purpose.

Due to the VIN error on the only title that had ever been issued for our 1987 bus, we basically got to register it all shiney and new for the first time, as a private passenger vehicle because it only had 7 seats. LOL. It was along visit to the DOL with many calls to the main office.
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Old 02-16-2018, 12:19 PM   #16
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TN has no "list" , register it as a personal vehicle and get ins. And drive, easy as that

And put regular TN or personalized plates on it,as long as you do not use it for commercial use
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Old 04-11-2018, 12:54 AM   #17
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What exactly does the "passenger vehicle" term designate. I tried to push for rv classification and the lady gave me a sly look and said "let me do my job" and now i have passenger vehicle on the title
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Old 04-11-2018, 12:32 PM   #18
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What exactly does the "passenger vehicle" term designate. I tried to push for rv classification and the lady gave me a sly look and said "let me do my job" and now i have passenger vehicle on the title
I think it all depends upon how your individual state classifies vehicles.

I know here in WA state the class of vehicle determines the tax code for vehicle license renewal. Passenger vehicle is the lowest cost tax code for vehicles in WA.
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