“Highway Safety Under Threat: Examining Non-Domiciled CDL Issuance to Illegal Aliens”

1[House Hearing, 119 Congress]2[From the U.S. Government Publishing Office]34             HIGHWAY SAFETY UNDER THREAT: EXAMINING5              NON-DOMICILED CDL ISSUANCE TO ILLEGAL6              ALIENS7=======================================================================89                                HEARING1011                               BEFORE THE1213                            SUBCOMMITTEE ON14                       OVERSIGHT, INVESTIGATIONS,15                           AND ACCOUNTABILITY1617                                 OF THE1819                     COMITTEE ON HOMELAND SECURITY20                        HOUSE OF REPRESENTATIVES2122                    ONE HUNDRED NINETEENTH CONGRESS2324                             SECOND SESSION2526                               __________2728                             MARCH 4, 20262930                               __________3132                           Serial No. 119-413334                               __________3536       Printed for the use of the Committee on Homeland Security3738[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]3940        Available via the World Wide Web: http://www.govinfo.gov4142                               __________4344                  U.S. GOVERNMENT PUBLISHING OFFICE4564-200 PDF                WASHINGTON : 202646=======================================================================4748                     COMMITTEE ON HOMELAND SECURITY4950                Andrew R. Garbarino, New York, Chairman51Michael T. McCaul, Texas, Vice       Bennie G. Thompson, Mississippi,52    Chair                                Ranking Member53Michael Guest, Mississippi           Eric Swalwell, California54Carlos A. Gimenez, Florida           J. Luis Correa, California55August Pfluger, Texas                Shri Thanedar, Michigan56Tony Gonzales, Texas                 Seth Magaziner, Rhode Island57Morgan Luttrell, Texas               Daniel S. Goldman, New York58Dale W. Strong, Alabama              Delia C. Ramirez, Illinois59Josh Brecheen, Oklahoma              Timothy M. Kennedy, New York60Elijah Crane, Arizona                LaMonica McIver, New Jersey61Andrew Ogles, Tennessee              Julie Johnson, Texas, Vice Ranking62Sheri Biggs, South Carolina              Member63Gabe Evans, Colorado                 Pablo Jose Hernandez, Puerto Rico64Ryan Mackenzie, Pennsylvania         Nellie Pou, New Jersey65Brad Knott, North Carolina           James R. Walkinshaw, Virginia66Vince Fong, California               Troy A. Carter, Louisiana67Matt Van Epps, Tennessee             Al Green, Texas68Vacant69                     Keighle Joyce, Staff Director70                  Hope Goins, Minority Staff Director71                       Sean Corcoran, Chief Clerk72                                 ------7374     SUBCOMMITTEE ON OVERSIGHT, INVESTIGATIONS, AND ACCOUNTABILITY7576                   Josh Brecheen, Oklahoma, Chairman77Dale W. Strong, Alabama              Shri Thanedar, Michigan, Ranking78Andrew Ogles, Tennessee                  Member79Brad Knott, North Carolina           Delia C. Ramirez, Illinois80Matt Van Epps, Tennessee             Troy A. Carter, Louisiana81Andrew R. Garbarino, New York, (ex   Al Green, Texas82    officio)                         Bennie G. Thompson, Mississippi83                                         (ex officio)84           Grayson Westmoreland, Subcommittee Staff Director85           Lisa Canini, Minority Subcommittee Staff Director8687                           C O N T E N T S8889                              ----------90                                                                   Page9192                               Statements9394The Honorable Josh Brecheen, a Representative in Congress From95  the State of Oklahoma, and Chairman, Subcommittee on Oversight,96  Investigations, and Accountability:97  Oral Statement.................................................     198  Prepared Statement.............................................     499The Honorable Shri Thanedar, a Representative in Congress From100  the State of Michigan, and Ranking Member, Subcommittee on101  Oversight, Investigations, and Accountability:102  Oral Statement.................................................     6103  Prepared Statement.............................................     7104The Honorable Bennie G. Thompson, a Representative in Congress105  From the State of Mississippi, and Ranking Member, Committee on106  Homeland Security:107  Prepared Statement.............................................     7108109                               Witnesses110111Mr. Tim Tipton, Commissioner, Oklahoma Department of Public112  Safety:113  Oral Statement.................................................     9114  Prepared Statement.............................................    10115Mr. Richard R. Del Toro, Jr., Sheriff, St. Lucie County Sheriff's116  Office:117  Oral Statement.................................................    15118  Prepared Statement.............................................    16119Ms. Wendy Liu, Attorney, Public Citizen Litigation Group:120  Oral Statement.................................................    18121  Prepared Statement.............................................    20122123                             For the Record124125The Honorable Shri Thanedar, a Representative in Congress From126  the State of Michigan, and Ranking Member, Subcommittee on127  Oversight, Investigations, and Accountability:128  Letter From the AFL-CIO........................................    34129130                                Appendix131132Questions From Honorable Al Green for Wendy Liu..................    45133134 HIGHWAY SAFETY UNDER THREAT: EXAMINING NON-DOMICILED CDL ISSUANCE TO135                             ILLEGAL ALIENS136137                              ----------138139                        Wednesday, March 4, 2026140141             U.S. House of Representatives,142                    Committee on Homeland Security,143                Subcommittee on Oversight, Investigations,144                                        and Accountability,145                                                    Washington, DC.146    The subcommittees met, pursuant to notice, at 2:57 p.m., at147Room 310, Cannon House Office Building, Hon. Josh Brecheen148(Chairman of the subcommittee) presiding.149    Present: Representatives Brecheen, Strong, Van Epps, Fong,150Thanedar, Carter, and Green.151    Mr. Brecheen. Good afternoon. The Committee on Homeland152Security Subcommittee on Oversight, Investigations, and153Accountability will come to order. Without objection, the Chair154may declare the committee in recess at any point.155    The purpose of this hearing is to examine how the issuance156of non-domiciled commercial driver's licenses to individuals157who are unlawfully present in the United States endangers158public safety. We are pleased to have an expert----159    Mr. Thanedar. Mr. Chairman, I have a parliamentary160question. Under clause 2(k)(1) of rule XI, the Chair shall161announce in an opening statement the subject of the hearing and162under clause 2(k)(8) of rule XI, the committee is the sole163judge of the pertinence of testimony and evidence adduced at164its hearing. In order to judge if these rules could possibly be165satisfied today, could the Chair please tell us how the topic166of this hearing and the testimony of these witnesses accords167with the committee's rule X jurisdictional statement?168    Mr. Brecheen. You know, overall you are asking about the169jurisdiction of this committee relative to this subject. Given170the Homeland Security's oversight of the immigration171naturalization elements and how that pertains to ICE, how that172pertains to a number of different issuances, this falls within173our jurisdiction as a committee.174    Mr. Thanedar. Mr. Chair, per rule X, the Transportation and175Infrastructure Committee has jurisdiction over transportation176regulatory agencies and roads and safety thereof, and177transportation safety and transportation labor. Any bills to178improve highway safety would need to be considered and voted on179by that committee. I want it on the record before we start that180this hearing is really about nothing more than scapegoating181immigrants for the President's economy, which is running off182the road.183    Mr. Brecheen. In response, I am going to just read to you184something so everyone can be clear why we have jurisdiction.185``While DOT is the primary Federal regulator of CDLs, DHS plays186a critical role in granting work authorizations and immigration187benefits through U.S. Citizenship and Immigration Services,188working with DOT to verify lawful presence in the country, and189tasking ICE to arrest and remove deportable aliens who are190encountered in the course of commercial vehicle enforcement. In191particular, through 287 agreements with State and law192enforcement, since September 2025, ICE has partnered with State193highway patrol agencies in several States, can conduct joint194enforcement operations targeting illegal aliens operating195commercial motor vehicles, resulting in significant arrests and196taking unsafe drivers off the road.197    ``Additionally, compliance with Real ID requirements is198also a major security concern. As some States have issued CDLs,199clearly fail basic verification safeguards, including the200instance where the ID listed its holder as, ``no name given,''201in my home State of Oklahoma, this was discovered, ``for a202license that allowed the holder to operate a commercial203driver's license. The Real ID Act of 2005, passed on the204recommendations of the 9/11 Commission, established new205standards for identification documents such as a driver's206license as a way to verify the identities and check the207backgrounds of individuals entering vulnerable facilities,208especially in the transportation system.''209    As someone, myself, who has a class A CDL, I understand the210danger when someone has a hazmat endorsement and 80,000 pounds211used as a chemical bomb. This is absolutely under the212jurisdiction of this committee.213    Mr. Thanedar. Well, Mr. Chair, if I may----214    Mr. Brecheen. The gentleman has not been recognized. If the215gentleman has a follow-up, I will recognize him. You are216recognized.217    Mr. Thanedar. Thank you, Mr. Chair. Chairman, the DOT alone218regulates licenses regardless of immigration status. Look,219every collision is a tragedy, but it is already illegal and220undocumented--that for undocumented immigrants to hold a CDL.221Nothing the Trump administration is proposing, which will take222lawful drivers off the road, will improve highway safety. DOT's223rules and GOP bills will actually do the opposite, resulting in224more lives lost.225    Mr. Brecheen. All right. To the Ranking Member, this is226going to be my last statement on the subject. I am citing from227rule X of clause 1, the rules of the House, number 3,228Functions--Committee on Homeland Security. Number 3, part of229its functions, ``Functions of the Department of Homeland230Security relating to the following: border/port security; B,231customs; C, integration; E, research development; 5--or F,232transportation security.''233    All right. With that, we will continue.234    I now recognize myself for an opening statement.235    Good afternoon again. Thank you for joining us today. Today236the subcommittee will examine a serious growing threat to237public safety and the rule of law: the issuance of non-238domiciled commercial driver's license to illegal aliens239unlawfully present in the United States.240    Commercial truck drivers are the backbone of the American241economy. Every day they transport food, fuel, medicine, and242other critical supplies all across the United States and enable243everyday life to continue without disruption. Currently,244Federal law, individual States are responsible for issuance of245CDLs, but they must do so in strict compliance with the246standards set by the Federal Motor Carrier Safety247Administration. The FMCSA requires that for a State to issue a248non-domiciled CDL, they must require the individual be legally249present in the United States and meet minimum standards for250testing, identity, and verification. The FMCSA also recognizes251that noncitizens have a basic understanding of the English252language to read and understand road signs. Yet recent253Department of Transportation audits have revealed alarming254failures by many States to comply with these requirements.255    For example, in Illinois, 1 in 5 non-domiciled CDLs failed256to meet Federal standards. Last November, the Department of257Transportation found that California had illegally issued25817,000 non-domiciled CDLs. California had illegally issued25917,000 non-domiciled CDLs. A 2025 audit by FMCSA found that260over 50 percent of the non-domiciled CDLs issued by the State261of New York were in violation of Federal law.262    As President Trump highlighted in his State of the Union263address last week, this issue has seen real and devastating264consequences. In 2025 alone, at least 17 fatal crashes265resulting in 30 deaths were caused by illegal aliens driving266commercial vehicles with CDLs. One of the most tragic examples267was a crash in St. Lucie County, Florida. Lucie County,268Florida, am I saying that correctly? Sheriff, is that correct?269Thank you. An illegal alien from India failed the CDL test 10270times in the span of 2 months. I want to repeat that. This271accident occurred in your county. An illegal alien from India,272who failed a CDL test 10 times in the span of 2 months in the273State of Washington, managed to obtain his license, however, in274California, then drove his 18-wheeler to Florida and caused a275serious vehicle incident after making an illegal U turn,276instantly killing 3 people.277    These are not paperwork errors. Rather they represent278systematic breakdowns and oversight that put American families279at risk. These tragic incidents were caused by drivers who280should never have been entrusted with commercial driver's281licenses in the first place. These individuals were unfit to282hold that credential and if States would follow through with283standards and laws, they would not qualify them to receive one.284    The human cost of these failures is painful. In 2024, 5-285year-old Dalilah Coleman was nearly killed when a tractor-286trailer driven by an illegal alien carried a fraudulent non-287domiciled CDL, directly collided with the vehicle she was in.288Following this incident, Dalilah endured a coma and months of289hospitalization and had to relearn how to walk, talk, and eat.290Her recovery was nothing short of a miracle. While I am291grateful that Dalilah is making progress and her recovery must292be clear, this tragedy should never have happened. When the293rules that protect the public are treated as optional by294certain States, innocent people like Dalilah pay the price.295    You do not have to be a scholar to understand what a bad296actor could do with a 40-ton tractor-trailer, especially one297hauling hazardous cargo onto highways. In the wrong hands, that298vehicle is not just a truck, it is a weapon capable of299threatening public safety and national security.300    This trend is a direct consequence of former President301Biden's open border policy. President Biden claimed to have302created more than 870,000 new CDL holders in his first year in303office. The non-domiciled element absolutely a part of that,304870,000 in 1 year. In contrast, the Trump administration has305been working diligently to combat this issue, taking several306critical steps in recent months to restore accountability and307compliance with Federal laws. This includes a final rule issued308in February by the Department of Transportation, significantly309tightens eligibility standards for receiving non-domiciled310commercial driver's licenses. Additionally, the Department of311Homeland Security has increased its coordination with many312States looking to crack down on illegal aliens driving313commercial vehicles, launching several successful operations in314Indiana and my home State of Oklahoma, also Texas and Wyoming,315to name a few.316    Finally, some States, like Oklahoma, have taken steps to317introduce legislation to combat this problem. Model legislation318in May of last year, Oklahoma passed the Oklahoma Secure Roads319and Safe Trucking Act, authored by State Senator Kendal320Sacchieri and State Representative Jonathan Wilk, which321increases the threshold of non-domiciled CDLs and requires that322an individual provide proof of foreign citizenship and valid323work visa and demonstrate English language proficiency. It is324my hope that all States follow the footsteps of Oklahoma as325they look to solve this issue.326    Just as a side note, as Mr. Tipton is going to testify here327shortly, 500 people were positioned to be removed, found in a328September analyzation of weigh stations, Western Oklahoma I-40,329of being in violation of FMCSA. Five hundred in Oklahoma in a330very short time frame, showing how people come in through our331State. Following suit of this change of statute is something332that every State ought to be looking to replicate, every333Governor, because of the tens of thousands of these commercial334truck drivers that are on the roads coming through your State.335    Although we are righting previous wrongs, we must remain336vigilant. We must make sure the States enforce the law, keep337licenses out of the hands of unqualified people who are338unlawfully present. It is not a matter only of public safety,339but a matter of national security.340    Again, I want to thank our witnesses for being here today,341and I now yield to Ranking Member Thanedar.342    [The statement of Chairman Brecheen follows:]343                  Statement of Chairman Josh Brecheen344                                March 4345    Good afternoon and thank you for joining us today.346    Today, this subcommittee will examine a serious and growing threat347to public safety and to the rule of law: the issuance of Non-Domiciled348Commercial Driver's Licenses to illegal aliens unlawfully present in349the United States.350    Commercial truck drivers are the backbone of the American economy.351Every day, they transport food, fuel, medicine, and other critical352supplies all across the United States and enable every-day life to353continue without disruption.354    Currently, under Federal law, individual States are responsible for355the issuance of CDLs, but they must do so in strict compliance with356standards set by the Federal Motor Carrier Safety Administration.357    The FMCSA requires that in order for a State to issue a non-358domiciled CDL, they must require that the individual be legally present359in the United States, and meet minimum standards for testing, identity,360and verification.361    The FMCSA also requires that non-citizens have a basic362understanding of the English language to read and understand road363signs.364    Yet recent Department of Transportation audits have revealed365alarming failures by States in compliance with these requirements.366Unsurprisingly, sanctuary States are at the root of this problem.367    A 2025 audit found that over 50 percent of non-domiciled CDL's368issued by New York were in violation of Federal law.369    In Illinois, 1 in 5 non-domiciled CDL's failed to meet Federal370standards. And last November, the Department of Transportation found371that California had illegally issued 17 thousand non-domiciled CDL's.372    These are not paperwork errors. Rather, they represent systemic373breakdowns in oversight that put American families at risk.374    As President Trump highlighted in his State of the Union address375last week, this issue has had real and devastating consequences. In3762025 alone, at least 17 fatal crashes, resulting in 30 deaths, were377caused by illegal aliens driving commercial vehicles with CDLs.378    These tragic incidents were caused by drivers who should never have379been entrusted with a commercial driver's license in the first place.380    These individuals were unfit to hold that credential and, if381sanctuary States would follow existing standards and laws, would not382qualify to receive one.383    The human cost of these failures is painfully real. In June 2024,3845-year-old Dalilah Coleman was nearly killed when a tractor trailer385driven by an illegal alien carrying a fraudulent non-domiciled CDL386directly collided with the vehicle she was in. President Trump387recognized her story during last week's address as a sobering reminder388of what is at stake.389    Following this incident, Dalilah endured a coma and months of390hospitalization and had to re-learn how to walk, talk, and eat. Her391recovery is nothing short of a miracle.392    While I am grateful Dalilah is making strong progress in her393recovery, we must be clear: this tragedy should never have happened.394    When the rules that protect the public are treated as optional,395innocent people like Dalilah pay the price.396    You do not have to be a scholar to understand what a bad actor397could do with a 40-ton tractor trailer, especially one hauling398hazardous cargo onto highways.399    In the wrong hands, that vehicle is not just a truck; it's a weapon400capable of threatening public safety and our national security.401    The Trump administration has been working diligently to solve this402issue, taking several critical steps in recent months to restore403accountability and compliance with Federal laws.404    This includes a final rule issued in February by the Department of405Transportation that significantly tightens eligibility standards for406receiving non-domiciled commercial driver's licenses.407    Additionally, the Department of Homeland Security has increased its408coordination with many States looking to crack down on illegal aliens409driving commercial vehicles, launching several successful operations in410Indiana, Oklahoma, Texas, and Wyoming, to name a few.411    Finally, some States, like my home State of Oklahoma, have taken412steps to introduce legislation to combat this problem. In May of last413year, Oklahoma passed the Oklahoma Secure Roads and Safe Trucking Act414of 2025, which increases the threshold of non-domiciled CDLs and415requires that an individual provide proof of foreign citizenship and416valid work visa, and demonstrate English language proficiency.417    It is my hope that all other States follow in the footsteps of418Oklahoma as they look to solve this issue.419    Although we are righting previous wrongs, we must remain vigilant.420We must make sure that States enforce the laws and keep these licenses421out of the hands of unqualified people who are unlawfully present in422this country, instead of recklessly endangering the American public who423are just trying to go about their daily lives.424    This is not only a matter of public safety, but also a matter of425national security.426    Again, I want to thank our witnesses for being here today and I now427yield to Ranking Member Thanedar.428429    Mr. Thanedar. Thank you, Chairman. Good afternoon to all.430    This past weekend a convicted felon with bone spurs431illegally attacked Iran, launching a protracted war of regime432change. President Trump callously said, and I quote, ``We may433have casualties, that often happens in wars,'' dismissing the434over 1,000 lives lost thus far, including 6 American service435members and 175 at a girls school. The Republican-run Congress436sat idly by rather than returning to Washington to claim the437war powers granted to it in the Constitution. This438subcommittee, rather than focusing on how Trump's war threatens439the homeland, is holding yet another hearing on demonizing440hard-working immigrants.441    I am an immigrant who came to this country with very little442and worked hard to achieve the American Dream. Our country is443built on the promise that anyone, regardless of their444background, can come here, work hard, and succeed. That is why445I am disturbed and offended that the Trump administration is446responding to American Truckers United's call to eliminate447trucking operators from foreign lands.448    The Department of Transportation is actively trying to449strip refugees, asylees, and DACA recipients of their450commercial driver's license under the false pretense of highway451safety. If DOT is successful, 200,000, or 5 percent, of452commercial drivers will be removed from the road. We are all453highly dependent upon these drivers to move goods across the454country, take our children to school, transport commuters,455maintain and repair roads, and clear streets after the storm.456Over 70 percent of the Nation's freight moves by truck.457Reducing the number of commercial drivers will disrupt the458economy and deepen the affordability crisis that already459plagues America.460    The U.S. economy is running out of road. Americans are461already struggling to afford groceries, medicine, and other462goods because of Trump's tariffs. Fewer drivers also means463fewer school buses, mass transit services, and snowplows. Daily464life will get harder except for the men in the Epstein files465who fly in luxury jets to private islands.466    Replacing 200,000 experienced CDL drivers with less467experienced drivers, who statistically are more prone to468accidents, will reduce safety. Rather than pursuing sensible469solutions to prevent collisions, such as requiring speed-470limiting technologies in trucks, the Trump administration would471rather punish immigrants who have a safer driving record than472U.S. citizens.473    Immigrants with non-domiciled CDLs have invested474significant resources to satisfy the training, skills,475knowledge tests, and requirements applicable to all individuals476seeking to hold CDLs. It is already illegal to issue CDLs to477undocumented migrants and Federal law requires commercial478motorway operators to be proficient in English, including479highway traffic signs and signals. Enforce the existing laws,480but do not strip immigrants who are here legally of their481livelihood, which will harm the U.S. economy and reduce public482services.483    I thank Ms. Liu for joining us today and look forward to484her explaining how she is fighting the Trump administration's485illogical attempts to change the eligibility rules for CDLs.486    Thank you, Mr. Chair. I yield back.487    [The statement of Ranking Member Thanedar follows:]488               Statement of Ranking Member Shri Thanedar489                             March 4, 2026490    This past weekend, a convicted felon with bone spurs illegally491attacked Iran, launching a protracted war of regime change. President492Trump callously said, ``we may have casualties, that often happens in493war,'' dismissing the almost 600 lives lost thus far, including 6494American service members and 175 at a girls' school.495    The Republican-run Congress sat idly by rather than returning to496Washington to claim the war powers granted to it in the Constitution.497And this subcommittee, rather than focusing on how Trump's war498threatens the homeland, is holding yet another hearing on demonizing499hard-working immigrants.500    I am an immigrant who came to this country with very little and501worked hard to achieve the American Dream. Our country is built on the502promise that anyone, regardless of their background, can come here,503work hard, and succeed. That is why I am disturbed and offended that504the Trump administration is responding to American Truckers United's505calls to eliminate ``trucking operators from foreign lands.''506    The Department of Transportation (DOT) is actively trying to strip507refugees, asylees, and DACA recipients of their commercial driver's508licenses (CDLs) under the false pretense of highway safety. If DOT is509successful, 200,000--or 5 percent--of commercial drivers will be510removed from the road.511    We are all highly dependent upon these drivers to move goods across512the country, take our children to school, transport commuters, maintain513and repair roads, and clear streets after a storm. Over 70 percent of514the Nation's freight moves by truck. Reducing the number of commercial515drivers will disrupt the economy and deepen the affordability crisis516that already plagues America.517    The U.S. economy is running out of road. Americans are already518struggling to afford groceries, medicine, and other goods because of519Trump's tariffs. Fewer drivers also means fewer school buses, mass520transit services, and snowplows. Daily life will get harder except for521the men in the Epstein files who fly in luxury jets to private islands.522Replacing 200,000 experienced CDL drivers with less experienced523drivers--who statistically are more prone to accidents--will reduce524safety.525    Rather than pursuing sensible solutions to prevent collisions, such526as requiring speed-limiting technologies in trucks, the Trump527administration would rather punish immigrants who have a safer driving528record than U.S. citizens.529    Immigrants with non-domiciled CDLs have invested significant530resources to satisfy the training, skills, knowledge tests, and531requirements applicable to all individuals seeking to hold CDLs. It is532already illegal to issue CDLs to undocumented migrants, and Federal law533requires commercial motor operators to be proficient in English,534including highway traffic signs and signals.535    Enforce the existing laws, but do not strip immigrants who are here536legally of their livelihood, which will harm the U.S. economy and537reduce public services. I thank Ms. Liu for joining us today and look538forward to her explaining how she is fighting the Trump539administration's illogical attempts to change the eligibility rules for540CDL holders.541542    Mr. Brecheen. All right. I thank the Ranking Member.543    Other Members of the committee are reminded opening544statements may be submitted for the record.545    [The statement of Ranking Member Thompson follows:]546             Statement of Ranking Member Bennie G. Thompson547                             March 4, 2026548    I find it disappointing that my Republican colleagues have called549this hearing to discuss a topic solely in another committee's550jurisdiction when we could be discussing how Kristi and Corey have551weaponized the Department of Homeland Security (DHS) against the552American people.553    My colleagues must know that no State is legally allowed to issue554non-domiciled commercial driver's licenses (CDLs) to undocumented555migrants. Only lawful immigrants, proficient in English, can obtain556commercial driver's licenses. This has been Federal law long before557Trump stepped foot in the White House the first time. And despite the558racist and nativist tropes blaming non-domiciled commercial drivers for559truck crashes, the truth is they are underrepresented in fatal560collisions, accounting for less than 1 percent.561    If Republicans really cared about highway safety, they would562consider recommendations grounded in crash data studies such as563requiring side guards for 18-wheelers and automatic braking systems.564The Department of Transportation's (DOT) new rule depriving asylum565seekers and refugees of commercials licenses is nothing more than566another cruel and spiteful plan, driven by white nationalism, to hurt567immigrants trying to make a better life for themselves. But no mistake,568it will also hurt all Americans.569    Depriving immigrants of CDLs will disrupt the U.S. economy. DOT's570rule would force 200,000 commercial drivers off the road, straining571supply chains and causing lengthy delays in delivering food and goods.572These drivers are the same ones who provide essential public services,573including driving our children to school, operating snowplows during574chilling blizzards, and running the mass transit system. Removing575experienced truckers from the road makes our roads less safe, not more576safe.577    This hearing is a distraction from the chaos and corruption578occurring at DHS daily. This subcommittee should be conducting579oversight of DHS's occupation of American cities that resulted in the580murder of U.S. citizens by masked law enforcement and the arrest of581protesters exercising their First Amendment right. The crackdown in582Minneapolis was so egregious that it was a relief to see Tom Homan--the583father of family separation--replace ``Commander at Large'' and Nazi584fashion aficionado Greg Bovino.585    That's the same Tom ``Bags of Cash'' Homan who has lots of company,586just not good company, when it comes to grifting off DHS. Contracts587worth millions for planes, cars, and media campaigns have all been588awarded to Trump megadonors or those with ties to senior DHS officials.589What isn't being spent is billions in disaster aid the Trump590administration is unlawfully withholding from State and local591governments.592    Although our communities are being denied flood assistance, they593are being flooded with 10,000 unqualified immigration officers hired by594DHS and pushed into the field without adequate training. But you won't595find a job at the Department's cybersecurity agency even though it lost596one-third of its total workforce since Trump took over, significantly597weakening its ability to defend critical infrastructure from cyber598attacks while we are at war with Iran.599    There is so much chaos and corruption within DHS that there is no600need for Republicans to conduct oversight of topics outside this601committee's jurisdiction.602603    Mr. Brecheen. I am pleased to have a distinguished panel of604witnesses before us today on this critical topic. Pursuant to605committee rule VIII(C), I ask our witnesses to please rise and606raise their right hands.607    [Witnesses sworn.]608    Mr. Brecheen. Let the record reflect that the witnesses609have answered in the affirmative. Thank you. Please be seated.610    I would now like to formally introduce our witnesses. Mr.611Tim Tipton is the commissioner of my home State of the Oklahoma612Department of Public Safety. He is a nationally-recognized613expert on police training practices and with nearly 38 years of614experience at the department.615    Mr. Richard Del Toro, Jr. is the sheriff of St. Lucie616County, Florida. Prior to his election as sheriff, Mr. Del Toro617served his 26 years with the Port St. Lucie Police Department,618retiring as chief of police. Foreign Affairs Chairman Mast was619going to try to be here to do a special introduction, but he620got held up in other activities.621    Ms. Wendy Liu is an attorney at Public Citizen Litigation622Group. I thank each of our distinguished witnesses for being623here today.624    I now recognize Commissioner Tipton for 5 minutes to625summarize his opening statement.626627 STATEMENT OF TIM TIPTON, COMMISSIONER, OKLAHOMA DEPARTMENT OF628                         PUBLIC SAFETY629630    Mr. Tipton. Thank you, Chairman Brecheen and Ranking Member631Thanedar and esteemed Members of the subcommittee. I appreciate632the opportunity to share with you the Oklahoma Highway Patrol's633experience with the shocking amount of transnational freight634being transported by illegal aliens.635    The month after President Trump took office, ICE announced636its Task Force Model Agreements. These agreements allowed State637and local officers to become credentialed to enforce638immigration laws during routine law enforcement encounters. OHP639immediately joined and rapidly sent all 730 of its officers640through the ICE credentialing process. With every Oklahoma641trooper now having an ICE credential, we've been given a unique642and first-hand view of the prolific problem of illegal aliens643operating CMVs on our national interstate and defense highway644system.645    By way of a quick example, last September, OHP and ICE646conducted a joint emphasis in Western Oklahoma along the647Interstate 40 corridor. During this emphasis, OHP took 90 CMV648operators into custody for immigration violations, aliens from649all over Eastern Europe, Asia, and Africa. This means that in650an approximate 24 hours of shift work on a random weekday in651the middle of our heartland, roughly 50 percent of OHP CMV652encounters resulted in the arrest of an illegal alien. In fact,653since late summer of '25-- 2025--OHP has taken over 450 CMV654operators into custody for immigration violations. Many of655these drivers struggle with even basic English language656proficiency and likely receive their licenses from an657unscrupulous CDL mill.658    Through this experience, OHP has learned of several659concerning problems with the Federally-regulated system for660issuance of CDLs. I will share an account of one OHP661immigration arrest that highlights these problems. During a662joint OHP-ICE emphasis, OHP encountered a driver operating an66380,000-pound semi-truck traveling from California to Missouri.664As our trooper was performing a standard CMV inspection, the665driver presented a Real ID-compliant CDL with the first name666listed as ``No name given.'' After discovering the driver was667an illegal alien, our trooper used his ICE 287(g) credential to668arrest him for immigration violations.669    On many similar occasions, we've encountered illegal aliens670operating with facially valid CDLs, CDLs with expiration dates671far exceeding the alien's temporary immigration status, CDLs672not being labeled non-domiciled as required by FMCSA673regulations, and Real IDs being issued to illegal aliens,674including Real IDs listing only a first or last name. OHP's675experience corroborates the FMCSA's recent policy position that676an employment authorization document, or an EAD, is an677inadequate qualifier for an alien to operate in this highly678regulated critical infrastructure industry.679    FMCSA's recent rule-making on non-domiciled CDLs represents680a practical and effective solution to many of these problems.681However, challengers have already filed suit to upend FMCSA's682new rules. I urge Congress to support this rule-making effort683and to pass any legislation that may be necessary to respond to684judicial challenges.685    That leaves the concerns about Real IDs being issued to686aliens with a tenuous immigration status. I'm surprised and687concerned about the temporary aliens being granted Real IDs. As688you are aware, the purpose of a Real ID is to serve as a689gatekeeping function into Federal facilities, commercial690airline travel, and even nuclear facilities. However, the act691authorizes issuance of Real IDs to aliens with nothing more692than temporary visas, pending applications for asylum, or693temporary protected status, or even a deferred action status,694which is merely a parole into the United States. In view of the695gatekeeping function of Real IDs, I urge reconsideration of the696qualifiers for aliens to receive these credentials.697    Let us not forget that a CDL with a hazardous materials698endorsement permits a driver to drive a liquid bomb to699virtually any location in America. Nine-eleven should remind us700how critical it is to safeguard our transportation network. A701coordinated nationwide enforcement effort is critical to702protecting our Nation not only from dangers to the motoring703public of unqualified alien drivers, but also from potential704terrorist threats.705    Thank you again, Chairman Brecheen, Ranking Member706Thanedar, and Members of the subcommittee for permitting me to707share with you the experience of the Oklahoma Highway Patrol.708    [The prepared statement of Mr. Tipton follows:]709                    Prepared Statement of Tim Tipton710    Thank you Chairman Brecheen, Ranking Member Thanedar, and esteemed711Members of the subcommittee. I appreciate the opportunity to share with712you the Oklahoma Highway Patrol's (OHP) experience with the shocking713amount of transnational freight being transported by illegal aliens.714    The month after President Trump took office, ICE announced its Task715Force Model agreements. These agreements allow State and local officers716to become credentialed through ICE to enforce immigration laws during717routine law enforcement encounters. OHP immediately joined and rapidly718sent all 730 of its officers through the ICE credentialing process.719With every Oklahoma trooper now having an ICE credential, we have been720given a unique and first-hand view of the prolific problem of illegal721aliens operating commercial motor vehicles (CMVs) on our National722InterState and Defense Highway system.723    By way of quick example, last September OHP and ICE conducted a724joint emphasis in western Oklahoma along the I-40 corridor. During this725emphasis, OHP took 90 CMV operators into custody for immigration726violations--aliens from all over Eastern Europe, Asia, and Africa.\1\727This means that in approximately 24 hours of shift work, on a random728weekday in the middle of our heartland, roughly 50 percent of OHP's CMV729encounters resulted in the arrest of an illegal alien.730---------------------------------------------------------------------------731    \1\ Exhibit 1, Highlights from Joint OHP-ICE Emphasis in Beckham732County, OK; Sept. 23-24, 2025.733---------------------------------------------------------------------------734    In fact, since late summer 2025, OHP has taken over 450 CMV735operators into custody for immigration violations. Many of these736drivers struggle with even basic English language proficiency and737likely received their licenses from unscrupulous CDL mills.\2\ Through738this experience, OHP has learned of several concerning problems with739the federally-regulated system for issuance of Commercial Driver740Licenses (CDLs). I will share an account of one OHP immigration arrest741that highlights these problems.742---------------------------------------------------------------------------743    \2\ Trump's Transportation Secretary Sean P. Duffy Moves to Shut744Down Hundreds of CDL Mills Violating Federal Regulations. (Feb. 18,7452026). https://www.transportation.gov/briefing-room/trumps-746transportation-secretary-sean-p-duffy-moves-shut-down-hundreds-cdl-747mills.748---------------------------------------------------------------------------749    During a joint OHP-ICE emphasis, OHP encountered a driver operating750an 80,000-pound semi-truck traveling from California to Missouri. As751our trooper was performing a standard CMV inspection, the driver752presented a REAL ID-compliant CDL with the first name listed as ``No753Name Given.'' After discovering the driver was an illegal alien, our754trooper used his ICE 287(g) credential to arrest him for immigration755violations.\3\ On many similar occasions, we have encountered:756---------------------------------------------------------------------------757    \3\ Exhibit 2, ICE Arrest Illegal Alien Driving an 18-Wheeler with758New York Commercial Driver's License Issued to ``No Name'' (Oct. 10,7592026). https://www.dhs.gov/news/2025/10/10/ice-arrest-illegal-alien-760driving-18-wheeler-new-york-commercial-drivers-license.761---------------------------------------------------------------------------762    1. Illegal aliens operating with facially valid CDLs,763    2. CDLs with expiration dates far exceeding the alien's temporary764        immigration status,765    3. CDLs not being labeled ``Non-Domiciled'' as required by FMCSA766        regulations, 44 49 C.F.R.  383.153(c), and767    4. REAL IDs being issued to illegal aliens, including REAL IDs768        listing only a first or last name.769    OHP's experience corroborates the FMCSA's recent policy position770that an Employment Authorization Document (EAD) is an inadequate771qualifier for an alien to operate in this highly regulated critical772infrastructure industry. FMCSA's recent rulemaking on Non-Domiciled773CDLs \5\ represents a practical and effective solution to many of these774problems.\6\ However, challengers have already filed suit to upend775FMCSA's new rule.\7\ I urge Congress to support this rulemaking effort776and to pass any legislation that may be necessary in response to777judicial challenges.778---------------------------------------------------------------------------779    \5\ 91 Fed. Reg. 7044 (Feb. 13, 2026).780    \6\ Non-Domiciled CDL 2026 Final Rule FAQs. https://781www.fmcsa.dot.gov/regulations/non-domiciled-cdl-2026-final-rule-faqs.782    \7\ Lujan v. Federal Motor Carrier Safety Administration, No. 26-7831032 (D.C. Cir. Feb. 12, 2026).784---------------------------------------------------------------------------785    That leaves the concerns about REAL IDs being issued to aliens with786a tenuous immigration status. Though I am not an expert on REAL IDs,787other high-ranking authorities share my surprise and concern about788temporary aliens being granted REAL IDs. As you are aware, the purpose789of a REAL ID is to serve a gatekeeping function into Federal790facilities, commercial air travel, and even nuclear facilities.\8\791However, the Act authorizes issuance of REAL IDs to aliens with nothing792more than temporary visas, pending applications for asylum or temporary793protected status, or even a deferred action status, which is merely a794parole into the United States. In view of the gatekeeping function of795REAL IDs, I urge reconsideration of the qualifiers for aliens to796receive these credentials.797---------------------------------------------------------------------------798    \8\ Real ID Act of 2005,  201, Title II of Division B of Public799Law 109-13, codified at 48 U.S.C.  30301 note.800---------------------------------------------------------------------------801    Let us not forget that a CDL with a hazardous materials endorsement802permits a driver to drive a liquid fuel bomb to virtually any location803in America. Nine-eleven should remind us how critical it is to804safeguard our transportation network. A coordinated nationwide805enforcement effort is critical to protecting our Nation, not only from806the dangers to the motoring public of unqualified alien drivers, but807also from potential terrorist threats.\9\808---------------------------------------------------------------------------809    \9\ Maj. Staff of H.R. Subcomm. on Immigration Integrity, Security,810and Enforcement of the Comm. on Judiciary, 118th Cong., Terror at Our811Door: How the Biden-Harris Administration's Open-Borders Policies812Undermine National Security and Endanger Americans (Aug. 5, 2024).813---------------------------------------------------------------------------814    Thank you again, Chairman Brecheen, Ranking Member Thanedar, and815Members of the subcommittee for permitting me to share with you the816experience of the Oklahoma Highway Patrol.817[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]818819    Mr. Brecheen. Thank you. I now recognize Honorable Del Toro820for his 5 minutes.821822        STATEMENT OF RICHARD R. DEL TORO, JR., SHERIFF,823               ST. LUCIE COUNTY SHERIFF'S OFFICE824825    Sheriff Del Toro. Good afternoon, Chairman Brecheen,826Ranking Member Thanedar, and distinguished Members of the827subcommittee. I appreciate the opportunity to appear before you828today for your leadership in examining this important public829safety issue.830    I'm honored to serve as sheriff of St. Lucie County,831Florida, and I come before you today with more than 25 years of832law enforcement experience dedicated to protecting the833communities I serve. I'm here today because of a tragedy. On834August 12, 2025, 3 innocent people in my county lost their835lives in a catastrophic crash on the Florida Turnpike involving836a commercial motor vehicle. The investigation revealed that the837driver of that vehicle had previously entered the United States838illegally and was operating with a commercial driver's license839issued by another State earlier that same year. For the840families of those victims, this is not a policy debate. It's a841permanent loss.842    Commercial motor vehicles can weigh up to 80,000 pounds.843When operated unsafely, they have the potential to cause844devastating consequences in a matter of seconds. That is why845strong, consistent, and reliable safety standards for846commercial driver's licensing are essential to protecting the847public. Florida has taken important steps to strengthen848verification, improve coordination with Federal authorities,849and ensure compliance with Federal standards. However, when850these standards vary between States, those inconsistencies can851create vulnerabilities that place our communities at risk.852    My purpose in appearing before you today is not to assign853blame, but to share the reality that I've witnessed as sheriff854and to support efforts that enhance public safety, strengthen855accountability, and prevent future tragedies. Highway safety is856not a partisan issue. It is a public safety responsibility. The857American people expect and deserve confidence that every858individual operating a commercial motor vehicle on our roadways859has met the highest standards of qualification, training, and860verification. As sheriff, my oath is to protect life, and I'm861here today to help ensure we do everything possible to uphold862that responsibility.863    Thank you for your time, and I look forward to answering864your questions, sir.865    [The prepared statement of Sheriff Del Toro follows:]866                 Prepared Statement of Richard Del Toro867                             March 4, 2026868    Chairman Brecheen, Ranking Member Thanedar, and Members of the869subcommittee, I want to thank you for convening this important hearing870on highway safety and the serious risks associated with non-domiciled871commercial driver licensing. This dangerous problem requires attention,872so I thank you for your attention.873    I was elected sheriff of St. Lucie County in November 2024 after874serving 25 years with the Port St. Lucie Police Department. Shortly875after being sworn-in as sheriff in January 2025, the Florida876Legislature held a special session to establish new laws to enable877local law enforcement to work responsibly with the Trump administration878as they enforce Federal laws prohibiting illegal immigration.879                        florida leading the way880    Thanks to the leadership of House Speaker Danny Perez, Senate881President Ben Albritton and members of both chambers, Governor Ron882DeSantis signed SB 2-C into law on February 13, 2025.883    SB 2-C is a comprehensive piece of legislation. I would like to884highlight only a few of the key sections.885   Requiring a county detention facility to provide, upon886        request from a Federal immigration agency, a list of all887        inmates booked into a county detention facility and any888        information regarding each inmate's immigration status.889   Banning sanctuary policies by ensuring a State entity, local890        governmental entity, or law enforcement agency may not prohibit891        or in any way restrict a law enforcement officer from executing892        or assisting in the execution of a lawful judicial warrant.893   Requiring a Florida law enforcement agency to use its best894        efforts to support the enforcement of Federal immigration law.895   And finally, requiring for purposes of proof of identity,896        that a driver license record or identification card record from897        another jurisdiction must comply with the Federal REAL ID Act.898    In total, the legislation was a thorough and well-thought-out way899for our State to assist the Federal Government with their duty to900enforce our immigration laws. However, we can have all the best laws in901our own home State, but if we are all not working together, tragedy can902strike. That is certainly what occurred in my county on August 12,9032025, when an illegal immigrant operating a commercial motor vehicle904caused a fatal crash on the Florida Turnpike.905    On that afternoon, a semi-truck pulling a trailer attempted to906cross the northbound travel lanes near mile marker 171 in St. Lucie907County in order to make an illegal U-turn through the center median. A908minivan traveling lawfully in the left lane collided with the mid-909section of the trailer and became lodged underneath the semi-truck. Two910occupants of the minivan were pronounced deceased at the scene, and a911third victim later died from injuries sustained in the crash.912    Nothing during the investigation showed a need for the truck driver913to make such a maneuver. During the investigation authorities quickly914learned that the driver had previously entered the United States915illegally in 2018 after crossing the Southern Border and had been916issued a Notice to Appear in immigration court. At the time of the917crash, he possessed a commercial driver's license issued by another918State earlier in 2025. Based on the totality of the evidence, the919driver was charged with 3 counts of vehicular homicide.920    The issuance of non-domiciled Commercial Driver's Licenses (CDLs)921to illegal aliens poses a grave threat to homeland security and public922safety on our roadways. These licenses, granted by certain States to923individuals lacking lawful permanent domicile or verified U.S.924residency, enable unauthorized migrants to operate massive commercial925vehicles, bypassing critical vetting processes.926    For my community, this was not an abstract policy issue. This was a927preventable and devastating tragedy.928                        national security risks929    Non-domiciled CDLs create vulnerabilities that have been930continuously exploited by illegal aliens, allowing them access to the931commercial trucking industry--a sector critical to national supply932chains and infrastructure. Foreign nationals without U.S. driving933records can obtain these licenses using minimal documentation, like934Employment Authorization Documents (EADs), which do not verify foreign935crash histories, DUIs, or other violations. In 2025, the Federal Motor936Carrier Safety Administration (FMCSA) documented 17 fatal crashes937involving such drivers, resulting in 30 deaths; these drivers lacked938the consular screening applied to U.S. citizens. This loophole further939endangers critical infrastructure, as commercial trucks routinely940transport hazardous materials and goods across borders. States like941California have issued thousands of these licenses to undocumented942individuals, correlating with interdiction operations uncovering943illegal activity, such as Indiana's Midway Blitz arresting 146944unauthorized truck drivers. Without Federal mandates, sanctuary945policies undermine homeland security by prioritizing access over946accountability. Without consistency, differing State policies undermine947highway safety and national security.948                           public safety data949    Fatal incidents underscore the dangers. As I previously mentioned,950the tragedy that occurred in my county when an illegal alien with a951non-domiciled CDL caused a Turnpike crash killing 3, was attributed to952another State's lax issuance of the license. Indiana reported multiple953fatalities from illegal aliens operating semi-trucks, prompting954Governor Mike Braun to mandate revocations.955    English proficiency gaps only exacerbate the risks; non-domiciled956drivers often struggle with U.S. signage and instructions. Nationally,957non-domiciled CDLs surged under prior administrations, with FMCSA958estimating 200,000 affected by reforms--yet safety incidents persist.959               h.r. 5688: non-domiciled cdl integrity act960    H.R. 5688, introduced by Rep. David Rouzer (R-NC) in October 2025,961directly addresses these threats by tightening eligibility for non-962domiciled CDLs. The bill limits issuance to foreign-domiciled963individuals with lawful status, job-linked visas (e.g., H-2A/H-2B), and964verified immigration via SAVE systems; Puerto Rican/U.S. territory965applicants must prove citizenship. States must retain records for 2966years, aligning with U.S. Department of Transportation's safety push967post-President Trump's Executive Order on trucking rules. With 15968cosponsors, H.R. 5688 responds to FMCSA identified crashes where969improper vetting enabled ineligible drivers. Enactment would970standardize protections, closing State-level gaps.971                                closing972    At the conclusion of my testimony, I have provided updates from973Florida's Department of Highway Safety and Motor Vehicles regarding the974overview of the process for issuing non-domiciled CDLs as well as975changes to the Florida CDL issuance process resulting from new FMCSA976rules.977    I applaud this committee for taking a serious look at this public978safety issue and would ask you to also focus your energy on the sources979of this problem. Highway safety depends on strong, consistent standards980that protect citizens. Together, we can keep commerce moving forward,981but not at the expense of the safety of our communities.982    Thank you.983Overview of Florida's Existing Processes for Issuing Non-Domiciled CDLs984   Florida only issues licenses to drivers who are in the985        country legally.986   Licenses issued to non-citizens with temporary legal987        presence (non-domiciled) are valid for a year, or the last date988        of the customer's legal status, whichever comes soonest.989   For each license issued to non-citizens, Florida verifies990        electronically with DHS/USCIS' SAVE system that the customer991        had legal presence in the United States.992   Florida scans and maintains all documents presented by the993        driver to establish their identity and legal status. Those994        documents are available in DAVID.995   All issuances involving drivers with temporary legal996        presence (non-domiciled) are conducted in person.997   If a non-citizen is only allowed to be in the United States998        on a temporary basis, we place the words ``TEMPORARY'' on the999        front of driver license. (Note: Due to Federal Motor Carrier1000        Safety Administration (FMCSA) rule updates, Florida will also1001        begin printing the words ``non-domiciled'' on the license1002        moving forward.)1003   The written CDL knowledge test was previously provided in1004        Spanish and English with the prior approval of FMCSA. However,1005        Florida recently changed its policy and all driver license1006        testing, including Class E, must be taken in English only.1007   The behind-the-wheel CDL skills test is provided in English1008        only as required by FMCSA regulations. Skill testing in Florida1009        is outsourced to third parties with oversight by the State.1010   At the request of FMCSA, Florida paused all issuances of1011        CDLs to non-domicile drivers on November 24, 2025, and plans to1012        resume issuances after the new FMCSA rules become effective in1013        mid-March.1014 changes to the florida cdl issuance process in florida resulting from1015                            new fmcsa rules1016   Only individuals in H-2A, H-2B, or E-2 nonimmigrant visa1017        statuses and individuals domiciled in a U.S. territory (under1018        specified conditions), are eligible for a non-domiciled CDL1019        license. It is anticipated that the number of non-domiciled CDL1020        license holders will decline sharply because of this1021        restriction.1022   As mentioned above, Florida will begin printing ``non-1023        domiciled'' on the face of the CDL once we resume issuance.10241025    Mr. Brecheen. Thank you, Sheriff.1026    Ms. Liu, for your opening statement.10271028  STATEMENT OF WENDY LIU, ATTORNEY, PUBLIC CITIZEN LITIGATION1029                             GROUP10301031    Ms. Liu. Good afternoon, Chairman Brecheen, Ranking Member1032Thanedar, Members of the subcommittee. Thank you for the1033opportunity to testify today.1034    I am Wendy Liu, an attorney with Public Citizen Litigation1035Group, the litigating arm of the nonprofit consumer advocacy1036organization Public Citizen, which was founded in 1971. The1037litigation group represents the petitioners challenging the1038rule recently issued by the Trump administration that would1039prohibit documented immigrants from holding commercial driver's1040licenses even though they have legal authorization from the1041Federal Government to work jobs in the United States.1042    As we all agree, highway safety is of critical importance.1043Trucking crashes on the Nation's roads cause serious injury and1044take many lives, each one a tragedy for family and friends. For1045that reason, Public Citizen has for decades advocated for1046strong rules addressing the hours of service that truckers may1047drive each day or week and for meaningful truck driver1048training. Limitations on driving hours and requirements for1049training are proven measures to improve highway safety.1050    But barring people with lawful work authorization, who have1051obtained their commercial driver's licenses by completing the1052required training and passing the required tests, including1053tests administered in English, will not make our roads safer.1054Doing so will replace more experienced drivers with less1055experienced ones and potentially increase the number of1056fatigued drivers on the road. It will exacerbate a well-1057documented need for truck drivers in the industry. It will harm1058the economy by increasing costs during an affordability crisis1059and it will harm State and local governments and the people1060they serve who depend on these drivers for essential public1061services, including public transportation, school buses,1062highway and road maintenance, utility services, and disaster1063response.1064    Importantly, under current law, no undocumented person, no1065illegal alien can hold a commercial driver's license. Every1066DACA recipient, asylee, asylum seeker, person with temporary1067protected status, or refugee who holds a non-domiciled1068commercial driver's license has been issued a work permit by1069the Department of Homeland Security's U.S. Citizenship and1070Immigration Services authorizing that person to work in the1071United States. Every person issued a commercial driver's1072license in this country, noncitizens and citizens alike, must1073go through the exact same training and pass the exact same1074tests. Every truck driver with a commercial driver's license1075must demonstrate English proficiency. They must be able to read1076and speak English sufficiently to converse with the public,1077understand highway traffic signs and signals, and respond to1078official inquiries.1079    These requirements likely explain why the Trump1080administration has no data showing that noncitizens cause more1081crashes than U.S. citizens. Although the Department of1082Transportation has identified 17 examples of crashes in 20251083that it says likely involved a noncitizen, there are on average10844,000 fatal crashes every year. Seventeen is less than 11085percent of that number, meaning that over 99 percent of fatal1086crashes are caused by U.S. citizens and lawful permanent1087residents according to the Department of Transportation's own1088data.1089    Every fatal crash is a tragedy. But prohibiting documented1090immigrants from driving trucks and buses will not improve1091highway safety. It will harm our economy. It will disrupt and1092curtail essential public services provided by State and local1093governments, and it will destroy the livelihoods of thousands1094of individual drivers and their families who depend on these1095licenses to pay for groceries, utilities, and other basic1096expenses.1097    My organization has been inundated with emails and messages1098from people across the country who are terrified because losing1099their license would mean losing their sole or primary source of1100income and their ability to continue providing for themselves1101and their family. These are people who have lived in the United1102States for years or decades and who have built careers based on1103their ability to have a commercial driver's license. They1104include DACA recipients who have been living in the United1105States ever since they were small children, who have no memory1106of any other country, who have driven trucks safely for years,1107and who have met every single requirement that has been asked1108of them. They are workers, small business owners, dedicated1109family members, and contributors to the U.S. economy. All they1110ask for, as one DACA recipient put it, is the opportunity to1111continue working, to continue providing, and to continue living1112productively in the only country that they have ever known as1113home.1114    Thank you for the opportunity to testify today.1115    [The prepared statement of Ms. Liu follows:]1116                    Prepared Statement of Wendy Liu1117                             March 4, 20261118    Dear Chairman Brecheen, Ranking Member Thanedar, Members of the1119subcommittee: Thank you for the opportunity to testify today. I am1120Wendy Liu, an attorney with Public Citizen Litigation Group. Public1121Citizen Litigation Group is the litigating arm of Public Citizen, a1122consumer advocacy organization with members in every State. We1123represent the petitioners challenging the rule recently issued by the1124Federal Motor Carrier Safety Administration that would prohibit1125documented immigrants, with legal authorization to work in the United1126States and legal authorization to be present in the United States, from1127holding commercial driver's licenses.1128    As we all agree, highway safety is of critical importance. Trucking1129crashes on the Nation's roads take many lives, each one a tragedy for1130family and friends. For that reason, Public Citizen has for decades1131advocated for strong rules addressing the hours of service that1132truckers may drive each day or week, and for meaningful truck-driver1133training. Limitations on driving hours and requirements for training1134are proven measures to improve highway safety.1135    But barring people with lawful work authorization, who have1136obtained their commercial driver's licenses by completing the required1137driver training and passing the required tests, including skills tests1138administered in English, will not make our roads safer. Doing so will1139replace more experienced drivers with less experienced ones and1140potentially increase the number of tired drivers on the road. It will1141exacerbate a well-documented truck-driver shortage, thereby harming our1142economy. And it will harm State and local governments, and the people1143they serve, who depend on these drivers for essential public services,1144including public transportation, school buses, highway and road1145maintenance, utility services, and disaster response.1146    We all need to understand that, under current law, no undocumented1147person--no ``illegal alien''--can hold a commercial driver's license.1148Every DACA recipient, asylee, or refugee who holds a non-domiciled1149commercial driver's license has been issued an Employment Authorization1150Document, by the Department of Homeland Security's U.S. Citizenship and1151Immigration Services, authorizing that person to work in the United1152States. And every person issued a commercial driver's license in this1153country--noncitizens and citizens alike--must go through the exact same1154training and pass the exact same tests. And every person issued a1155commercial driver's license must demonstrate English proficiency and1156pass driving tests administered in English.1157    These requirements likely explain why the Department of1158Transportation has no data showing that noncitizens cause more crashes1159than U.S. citizens. And although the Federal Motor Carrier Safety1160Administration has identified 17 examples of crashes in 2025 that it1161says likely involved a noncitizen, there are on average 4,000 fatal1162crashes each year. Seventeen is less than 1 percent of that number.1163    Every fatal crash is a tragedy. But prohibiting noncitizens from1164driving trucks and buses will not improve highway safety. It will,1165however, destroy the livelihoods of thousands of individual drivers and1166their families, who depend on these licenses to pay for groceries,1167utilities, and other basic expenses. It will harm hundreds of thousands1168of people across the country, harm the economy, and harm the public.1169  i. no evidence supports the assertion that barring immigrants from1170       holding commercial driver's licenses will improve safety.1171    No studies or empirical data show that noncitizens cause more1172crashes than citizens. The Federal Motor Carrier Safety Administration1173(FMCSA) has conceded that it cannot ``estimate quantitatively the risk1174associated with non-domiciled [commercial driver's license]1175holders.''\1\ To quote the agency: ``There is not sufficient evidence .1176. . to reliably demonstrate a measurable empirical relationship between1177the Nation of domicile for a [commercial driver's license] driver and1178safety outcomes in the United States such as changes in frequency and/1179or severity of crashes or changes in frequency of violations.''\2\1180---------------------------------------------------------------------------1181    \1\ FMCSA, Final Rule, 91 Fed. Reg. 7044, 7099 (Feb. 2026).1182    \2\ FMCSA, Interim Final Rule, 90 Fed. Reg. 46509, 46520 (Sept.11832025).1184---------------------------------------------------------------------------1185    FMCSA has identified 17 examples of crashes that it says likely1186involved drivers with non-domiciled commercial driver's licenses.\3\ To1187do so, FMCSA ``review[ed] reports of fatal crashes that occurred in11882025 individually, cross-reference[d] driver information from these1189databases along with other available information, and reach[ed] out to1190the [State licensing agencies] for details about each driver to1191determine whether each crash was in scope''--that is, whether the1192driver had a non-domiciled commercial driver's license--and then asked1193the Department of Homeland Security for information about the driver's1194immigration category.\4\ In other words, FMCSA apparently perused a1195list of thousands of fatal crashes involving trucks in 2025, and1196identified only 17 with a ``substantial likelihood'' of involving a1197driver with a non-domiciled commercial driver's license.\5\1198---------------------------------------------------------------------------1199    \3\ 91 Fed. Reg. 7065.1200    \4\ 91 Fed. Reg. 7065 & n.35.1201    \5\ 91 Fed. Reg. 7065.1202---------------------------------------------------------------------------1203    The most recent publicly-available statistics show that there were1204approximately 4,000 fatal large truck and bus crashes involving drivers1205with commercial driver's licenses in 2023.\6\ So, the 17 crashes that1206FMCSA has identified comprises less than 1 percent of crashes involving1207people with commercial driver's licenses.1208---------------------------------------------------------------------------1209    \6\ FMCSA, Crash Statistics, https://ai.fmcsa.dot.gov/1210CrashStatistics?tab=Driver&type=-1211&report_id=36&crash_type_id=1&datasource_id=2&time_period_id=2&report_da1212te=-12132023&vehicle_type=1&State=AllStates&domicile=ALL&measure_id=1&operation_1214id=null (Driver License Status Crash Statistics). FMCSA statistics for1215calendar year 2025 state that there have been 3,996 fatal crashes1216involving large trucks and buses, but these statistics do not provide1217breakdowns by CDL status. FMCSA, Crash Statistics, https://1218ai.fmcsa.dot.gov/1219CrashStatistics?tab=Summary&type=&report_id=1&crash_typesource_id=4&data1220_id=1-1221&time_period_id=2&report_date=0&vehicle_type=2&State=NAT&domicile=ALL&me1222asure- _id=1&operation_id=null.1223---------------------------------------------------------------------------1224    That no empirical evidence supports the notion that noncitizens are1225less safe is not surprising because the testing and training processes1226to obtain commercial driver's licenses are identical for U.S. citizens1227and noncitizens alike. The standards for commercial driver's licenses1228(for U.S. citizens and permanent residents) are identical to the1229standards for non-domiciled commercial driver's licenses (for1230documented immigrants who are authorized to work in the United States).1231And the requirements to obtain commercial driver's licenses are1232extensive: Applicants must demonstrate English-language proficiency;\7\1233demonstrate 30 different vehicle inspection, control, and driving1234skills;\8\ demonstrate their knowledge in ``20 general areas'';\9\ and1235consent to alcohol testing.\10\1236---------------------------------------------------------------------------1237    \7\ See 49 C.F.R.  383.133(c)(5); id.  391.11(b)(2).1238    \8\ 49 C.F.R.  383.113.1239    \9\ 49 C.F.R.  383.111.1240    \10\ 49 C.F.R.  383.72.1241---------------------------------------------------------------------------1242    Of course, every fatality or serious injury in a crash is a1243tragedy. But again, the evidence presented by FMCSA shows that taking1244commercial licenses away from non-citizens cannot be justified based on1245highway safety.1246    To the contrary, prohibiting documented immigrants from holding1247commercial driver's licenses will harm highway safety.1248    According to FMCSA's own estimates, restricting commercial driver's1249licenses to U.S. citizens, permanent residents, and people with H-2A,1250H-2B, and E-2 visas will force 194,000 current commercial drivers to1251exit the freight market.\11\ As the American Trucking Association has1252reported, though, the industry was short by 80,000 drivers in 2021,\12\1253with a predicted doubling to 160,000 drivers by 2030.\13\ Prohibiting1254documented immigrants from holding commercial driver's licenses will1255eliminate roughly 5 percent of commercial drivers, exacerbating this1256shortage.1257---------------------------------------------------------------------------1258    \11\ 91 Fed. Reg. 7096.1259    \12\ Press Release, Am. Trucking Ass'n, ATA Chief Economist Pegs1260Driver Shortage at Historic High (Oct. 25, 2021), https://1261www.trucking.org/news-insights/ata-chief-economist-pegs-driver-1262shortage-historic-high.1263    \13\ Hugh Cameron, America's Trucking Industry is in Deep Trouble,1264Newsweek (Oct. 13, 2025), https://www.newsweek.com/us-trucking-1265industry-deep-trouble-10861497.1266---------------------------------------------------------------------------1267    A depleted workforce will harm road safety. Drivers will have to1268drive for longer hours or more frequent hours, increasing driver1269fatigue and decreasing safety.\14\ Driver fatigue is a well-documented1270``[commercial motor vehicle] safety problem,'' with ``[s]tudies1271show[ing] that driver fatigue is a factor in up to as many as 131272percent of truck crashes.''\15\ In addition, losing experienced drivers1273may put less-experienced drivers on the road, but data shows that less-1274experienced drivers are involved in a higher rate of crashes.\16\1275---------------------------------------------------------------------------1276    \14\ See, e.g., Christine Brittle & Julie Van Keuren, Am. Pub.1277Transp. Ass'n, Impact of CDL Under-the-Hood Testing Requirement on1278Public Transit Agencies' Ability to Hire Bus Operators 3 (2024),1279https://www.apta.com/wp-content/uploads/APTA-Impact-of-CDL-Under-the-1280Hood-Testing-Requirement-Nov-2024.pdf; see also FMCSA, CMV Driving1281Tips_Driver Fatigue, https://www.fmcsa.dot.gov/safety/driver-safety/1282cmv-driving-tips-driver-fatigue.1283    \15\ Advocates for Highway & Auto Safety, Large Trucks Fact Sheet1284(Sept. 2022), https://saferoads.org/wp-content/uploads/2022/09/Large-1285Truck-Fact-Sheet-FINAL-9-16-22.pdf (citing FMCSA, ``Large Truck Crash1286Causation Study Summary Tables,'' 2007.FMCSA_2004_19608-3971).1287    \16\ Nat'l Surface Transp. Safety Ctr. for Excellence, Commercial1288Motor Vehicle Driver Risk Based on Age and Driving Experience 371289(2020), https://vtechworks.lib.vt.edu/server/api/core/bitstreams/1290a5800006-4b00-4854-bd5c-1f3e76f5d5c1/content.1291---------------------------------------------------------------------------1292ii. prohibiting documented immigrants from holding commercial driver's1293 licenses will destroy the livelihoods of thousands, harm the economy,1294                 and reduce essential public services.1295    After FMCSA issued a rule that would prohibit most categories of1296noncitizens who are legally authorized to work in the United States1297from holding commercial driver's licenses, more than 8,000 members of1298the public submitted comments. Nearly 90 percent of those comments1299opposed the rule.\17\ The comments made several points.1300---------------------------------------------------------------------------1301    \17\ Alex Lockie, FMCSA issues Final Rule banning non-domiciled1302CDLs almost entirely, Overdrive (Feb. 11, 2026), https://1303www.overdriveonline.com/business/article/15816996/fmcsa-issues-final-1304rule-banning-nondomiciled-cdls-almost-entirely.1305---------------------------------------------------------------------------1306    First, the new prohibition will destroy the livelihoods of1307thousands of people across the country. Individual drivers would face1308losing their licenses, their employment, their ability to pay for1309groceries and other basic expenses, and their access to employer-1310provided benefits like health insurance.\18\ Thousands of drivers have1311explained that they will default on loans and be unable to cover basic1312expenses.\19\ Owner-operators similarly have explained that ``th[e]1313rule places [their] livelihood and business at immediate risk.''\20\1314These harms would extend to the drivers' families, and to the employers1315and communities that depend on their work.1316---------------------------------------------------------------------------1317    \18\ See, e.g., Teamsters Cal. Comment 2, available at https://1318www.regulations.gov/docket/FMCSA-2025-0622/comments; Asylum Seeker1319Advocacy Project Comment 3-5, available at https://www.regulations.gov/1320docket/FMCSA-2025-0622/comments; see also Asylum Seeker Advocacy1321Project and Nat'l Employment Law Project Amicus Brief, Jorge Rivera1322Lujan v. FMCSA, Dkt. No. 25-1215 (D.C. Cir. Oct. 30, 2025),1323    \19\ See, e.g., Singh Comment, FMCSA-2025-0622-2028, available at1324https://www.regulations.gov/docket/FMCSA-2025-0622/comments; Drozdek1325Comment, FMCSA-2025-0622-1037, available at https://1326www.regulations.gov/docket/FMCSA-2025-0622/comments; Ponyrko Comment,1327FMCSA-2025-0622-0532, available at https://www.regulations.gov/docket/1328FMCSA-2025-0622/comments; Andreiev Comment, FMCSA-2025-0622-0231,1329available at https://www.regulations.gov/docket/FMCSA-2025-0622/1330comments.1331    \20\ Anonymous Comment, FMCSA-2025-0622-0743, available at https://1332www.regulations.gov/docket/FMCSA-2025-0622/comments; see also Cervantes1333Comment, FMCSA-2025-0622-1215, available at https://1334www.regulations.gov/docket/FMCSA-2025-0622/comments.1335---------------------------------------------------------------------------1336    The prohibition will also harm the economy: 194,000 (or 25 percent1337of) motor carriers in this country will be impacted by the1338restriction.\21\ The change thus will exacerbate a critical shortage of1339truck drivers and disrupt supply chains. With a depleted trucking1340workforce, delivery of goods and materials will be delayed, and1341increased rates for freight operations will result.\22\ For example, a1342California-based broker who helps coordinate shipping across the State1343has reportedly said that ``the cost of a single freight trip from New1344Jersey to Texas has gone up by more than 35 percent because of a1345national shortage of immigrant drivers.''\23\1346---------------------------------------------------------------------------1347    \21\ 91 Fed. Reg. 7100.1348    \22\ Local Gov'ts Comment at 5-6, FMCSA-2025-0622-7894, available1349at https://www.regulations.gov/docket/FMCSA-2025-0622/comments.1350    \23\ A. Echelman, California must let immigrant truck drivers keep1351their licenses, judge rules, Reuters (Feb. 26, 2026), https://1352apnews.com/article/general-news-california-donald-trump-donald-trump-1353es-transportation-16821336aaf6b8fa2f6699c295b5f9e5.1354---------------------------------------------------------------------------1355    As described in the attached comment letter from local governments1356throughout the country, local governments will also suffer in several1357ways. To start, they will lose the money that they have invested in1358recruiting and training drivers to operate commercial motor vehicles1359used for public services. For example, Martin Luther King, Jr. County1360in Washington explained that it stands to lose 50 bus drivers and an1361additional 4 recent trainees, which represent an investment of over1362$800,000 in training costs. The need to replace these drivers will1363increase costs to local governments and potentially force them to1364redirect funding from other critical services.\24\1365---------------------------------------------------------------------------1366    \24\ Local Gov'ts Comment at 5-6.1367---------------------------------------------------------------------------1368    In addition, State and local governments' ability to provide a wide1369range of essential public services will be impaired. ``Public and1370private employers--including State and local governments--depend on1371commercial drivers to drive the buses that bring children to school, to1372run the mass transit systems that transport people to work, to operate1373the construction vehicles that maintain and repair public roads, to1374drive the trucks that transport food and goods to businesses, and to1375provide many other indispensable services.''\25\ In addition, State and1376local governments rely on these drivers for essential seasonal1377services, such as roadway clearance during inclement weather and1378natural disaster response--which ensures safe access to roads for1379emergency services.\26\ For example, ``a local government facing a1380shortage of snowplow operators is unlikely to be able to pre-treat or1381treat roadways as early or as frequently, resulting in more hazardous1382conditions. This will increase the number of crashes and their1383consequences.''\27\1384---------------------------------------------------------------------------1385    \25\ 19 State Attorneys Gen. Comment at 2, FMCSA-2025-0622-7571,1386available at https://www.regulations.gov/docket/FMCSA-2025-0622/1387comments.1388    \26\ Local Gov'ts Comment at 8.1389    \27\ Local Gov'ts Comment at 8.1390---------------------------------------------------------------------------1391                               conclusion1392    Prohibiting documented immigrants who are authorized to work in the1393United States from holding commercial driver's licenses would harm1394highway safety, destroy the livelihoods of thousands of people, harm1395the economy, and disrupt and reduce essential Government services1396across the country. Thank you for the opportunity to testify on this1397important topic.1398                               EXHIBIT A1399                                 November 28, 2025.1400Federal Motor Carrier Safety Administration,1401U.S. Department of Transportation, 1200 New Jersey Avenue, SE1402        Washington, DC 20590.14031404SUBMITTED VIA REGULATIONS.GOV14051406RE: Docket No. FMCSA-2025-062214071408    Dear Docket Clerk: The below-signed local governments and1409individual local government leaders (``Local Government1410Signatories'')\1\ offer the following comments and questions regarding1411the U.S. Department of Transportation's (DOT) Interim Final Rule (IFR)1412entitled ``Restoring Integrity to the Issuance of Non-Domiciled Drivers1413Licenses (CDL),'' published in the Federal Register at 90 Fed. Reg.141446509 (Sept. 29, 2025). The Local Government Signatories' comments1415focus on Sections V(C), V(D), VI(A), VI(B), and IX(A) of the IFR,1416specifically, the Federal Motor Carrier Safety Administration's1417(FMCSA's) failure to consider the IFR's on-the-ground harms or1418appropriately tailor the rule to the harm it seeks to address.1419---------------------------------------------------------------------------1420    \1\ Local Government Signatories hail from across the country, and1421their jurisdictions differ in size, demographics, and policy1422priorities. Local Government Signatories also differ in the way in1423which they provide transportation-related services--including public1424transportation, school buses, and critical safety-related services like1425highway maintenance and snow plowing--to their communities. Some1426provide these services directly; others provide them indirectly, as1427funders or members of public authorities; yet all rely on these1428services as part of a broader network of public services.1429Notwithstanding these variations, all local governments share a1430fundamental interest in providing effective and reliable public1431services to their constituents and keeping their communities safe,1432including by ensuring road safety. That is especially true for local1433governments like these Signatories, who often act as first responders1434to vehicular accidents and have unique interests in protecting their1435residents.1436---------------------------------------------------------------------------1437    A number of critical local government services depend upon licensed1438commercial motor vehicle drivers, including school buses, road1439maintenance and repair, utility service, disaster response, and1440infrastructure construction. Drivers employed by the Local Government1441Signatories who provide these services are required to have valid1442commercial driver's licenses (``CDLs'') to operate the necessary1443commercial motor vehicles. To appropriately provide such services, the1444Local Government Signatories depend on access to a sufficient pool of1445licensed, commercial drivers whose licensing status is both stable and1446predictable. Even prior to the IFR, local governments faced substantial1447shortages of qualified CDL drivers.1448    By issuing the IFR, FMCSA immediately altered a program that had1449been in place for nearly 15 years, without input from those most1450impacted by the changes. The IFR failed to account for the way in which1451it would directly and substantially impact local governments' ability1452to provide essential services, thereby reducing affordability, harming1453families who depend on school busing and other services, and impairing1454public safety. By FMCSA's own estimates, of the 200,000 non-domiciled1455CDL holders in the country, 194,000 of them will exit the freight1456market because they lose their CDLs as a result of the IFR.\2\ That1457means approximately 5 percent of all active CDL holders, based on 20241458numbers, risk losing their licenses.\3\ Such individuals will no longer1459be able to perform their essential jobs. Local governments, such as the1460Signatories, that rely on these commercial drivers to provide essential1461services will be left understaffed. The depleted pool of potential CDL1462candidates resulting from the IFR will make it even harder to replace1463these drivers and drive up costs for public and private entities1464employing CDL drivers or using their services.1465---------------------------------------------------------------------------1466    \2\ Restoring Integrity to the Issuance of Non-Domiciled Commercial1467Drivers Licenses, 90 Fed. Reg. 46509, 45619 (Sept. 29, 2025).1468    \3\ Id. at 46520.1469---------------------------------------------------------------------------1470    The Local Government Signatories and the essential services they1471provide will suffer needless tangible harm despite the purely1472speculative safety benefits of the IFR. By FMCSA's own acknowledgement,1473there is no evidence that the IFR will result in any safety benefits,1474because there is no evidence that the immigration status of a non-1475domiciled CDL holder, or even the domiciled or non-domiciled status of1476a CDL holder, has an impact on road safety.\4\ FMCSA therefore1477implemented a new regulation without any demonstrated need, in1478contravention of Department of Transportation policy.\5\ Moreover,1479given the significant adverse impacts and minimal benefits, the IFR is1480inconsistent with a recent Department of Transportation order requiring1481the use of ``sound economic principles and analysis supported by1482rigorous cost-benefit requirements and data-driven decisions,'' the1483avoidance of adverse impacts to families and communities including a1484reduction in transportation services, and the administration of1485statutes in a manner that enhances safety and access to jobs.\6\1486---------------------------------------------------------------------------1487    \4\ Id.1488    \5\ DOT Order 2100.6B, ``Policies and Procedures for Rulemaking'' 14896(a) (Mar. 10, 2025).1490    \6\ DOT Order 2100.7, ``Ensuring Reliance Upon Sound Economic1491Analysis in Department of Transportation Policies, Programs, and1492Activities''  5 (Jan. 29, 2025).1493---------------------------------------------------------------------------1494    The Local Government Signatories strongly agree with the importance1495of ensuring that ``only individuals who have been determined by1496relevant State licensing agencies--in accordance with Federal1497standards--to be qualified to operate large commercial vehicles are1498allowed to drive such vehicles on the Nation's roadways.''\7\ The Local1499Government Signatories recognize FMCSA's interest in ensuring that all1500State licensing agencies adhere to these requirements. The IFR in its1501present form, however, does not address those compliance issues. The1502IFR also does not show any impacts to safety specifically associated1503with the domiciled or non-domiciled status of a CDL holder, nor does it1504account for the real harms that would result from reducing the1505availability of qualified CDL holders performing a variety of safety-1506critical and essential public services.1507---------------------------------------------------------------------------1508    \7\ 90 Fed. Reg. at 46511.1509---------------------------------------------------------------------------1510    The Local Government Signatories respectfully request that FMCSA1511withdraw the IFR given that there is no data to support its causal1512benefit to road safety. In the alternative, before issuing any final1513rule, FMCSA should collect data to better study and understand the1514underlying drivers of road safety, after which the agency can revise1515the IFR, accounting for public comments, as required by the1516Administrative Procedure Act. FMCSA can take less burdensome measures1517while it carefully and expeditiously considers these issues. Through1518collaboration and data collection, those tasked with implementing1519changes to CDL eligibility can do so in a manner that promotes wide-1520spread compliance, enhances the safety of commercial vehicle1521operations, and is workable for those local governments that rely on1522commercial drivers to provide critical services. That approach is also1523more likely to improve road safety and prevent fatal crashes.1524    The Local Government Signatories appreciate the opportunity to1525provide comments on the IFR. It is especially critical that FMCSA1526seriously consider the IFR's on-the-ground impacts before deciding1527whether to move forward with issuing a final rule. Given these impacts1528and the lack of evidence that the IFR will result in any safety1529benefits, the Local Government Signatories urge FMCSA to withdraw the1530IFR. But should FMCSA decide to proceed, the recent stay of the IFR1531indicates significant changes are necessary before FMCSA publishes a1532final rule.\8\ The Local Government Signatories look forward to1533continued collaboration and engagement on these important issues.1534---------------------------------------------------------------------------1535    \8\ Lujan v. Fed. Motor Carrier Safety Admin., 25-1215, 2025 U.S.1536App. LEXIS 29835 (D.C. Cir. Nov. 13, 2025).1537---------------------------------------------------------------------------1538    i. fmsca must account for the ifr's real-world impacts and the1539         substantial reliance interests the ifr would disrupt.1540    Fewer licensed commercial drivers and a smaller pool of potential1541drivers will translate directly into disrupted and curtailed government1542services. Accordingly, the IFR will not only impact those who rely on1543these services, but harm those local governments that rely on the1544availability of CDL holders to provide these services and who now will1545be forced to expend additional resources to respond to this sudden1546disruption. The Administrative Procedure Act requires agencies to1547``assess whether there were reliance interests [in their previous1548policies], determine whether [those interests] were significant, and1549weigh any such interests against competing policy concerns.''\9\1550Although the IFR lacks supporting data of any causal safety benefits in1551the first place, should FMCSA choose to proceed, FMCSA must consider1552the following impacts and reliance interests before finalizing the1553rule.1554---------------------------------------------------------------------------1555    \9\ Dep't of Homeland Sec. v. Regents of the Univ. of Cal., 5911556U.S. 1, 33 (2020).1557---------------------------------------------------------------------------1558    Core Local Government Services.--Local governments rely on workers1559licensed to operate commercial motor vehicles for a wide range of1560critical services. These include: public transportation; school buses;1561highway and road maintenance and repair; response to inclement weather;1562gas, electricity, and other utility service; and disaster response,1563mitigation, and recovery. In addition, the construction of necessary1564infrastructure (e.g., roads, electrical transmission and generation,1565airports, housing, ports, water, sewer, data centers) depends on having1566CDL holders on-site to aid in construction, to supply materials, and to1567haul fill. Those services will suffer directly because the IFR reduces1568the availability of CDL holders.1569    For example, one Signatory reports it already has extreme1570difficulty hiring and retaining CDL drivers. Fourteen of its 531571positions that require a CDL (26 percent) are currently open and have1572been for an average of 3 months. These unfilled jobs undermine the1573jurisdiction's ability to provide government services such as trash1574clean-up and emergency response. The IFR will further reduce the1575already limited number of CDL holders in the job market and thus make1576it harder for the Signatory to deliver these important services to its1577people.1578    Similarly, the IFR will impede local governments and associated1579entities in their ability to prepare for and recover from natural1580disasters, like Hurricane Helene in North Carolina, the Guadalupe River1581floods in Texas, tornado outbreaks in the South, or the Los Angeles1582wildfires. Disaster response heavily relies on the timely receipt of1583equipment and workers. Thinning forests; protecting coastlines;1584supplying food, fuel, and water to residents who have lost their homes;1585clearing flood zones; and ensuring road access for other emergency1586responders involve heavy hauling, which requires heavy trucks and1587commercially-licensed drivers. During the Guadalupe flood response, for1588example, local tow truck drivers became essential for ``clearing the1589way for emergency crews, recovering submerged vehicles and delivering1590life-saving supplies.''\10\ Commercially-licensed drivers are also1591utilized ``when electric utilities send trucks, equipment, and staff to1592restore energy infrastructure after a hurricane.''\11\ And when serious1593thunder or winter storms knock out the electricity, commercial trucks1594play a crucial role in clearing debris and getting the power back on1595for thousands of people.\12\ With a diminished workforce of licensed1596commercial drivers, local governments may no longer be able to rely on1597drivers to aid in disaster response.1598---------------------------------------------------------------------------1599    \10\ Alicia Neaves, The Unseen First Responders: Tow Crews Fuel1600Hope After Hill Country Floods, Kens5 (July 10, 2025 at 10:23 PM CDT),1601https://www.kens5.com/article/news/State/texas-news/texas-flood/texas-1602floods-first-responders-tow-crews-fuel-hope-hill-country/273-a2f3-1603f29b-b69f-4734-830a-48633149e274.1604    \11\ See U.S. Dep't of Transp. Fed. Highway Admin., Resources for1605Commercial Vehicles Involved in Emergency Response 1 (2021), https://1606ops.fhwa.dot.gov/publications/fhwahop21009/fhwahop21009.pdf.1607    \12\ National Grid Restores Power to More Than 57,900 Customers in1608Mohawk Valley and Northern New York After Damaging Thunderstorms,1609National Grid (June 22, 2025 at 6 o'clock PM), https://1610www.nationalgridus.com/News/2025/06/National-Grid-Restores-Power-to-1611More-Than-57,900-Customers-in-Mohawk-Valley-and-Northern-New-York-1612After-Damaging-Thunderstorms-/ (severe thunderstorms in northern New1613York impacted 94,300 electricity customers and crews were mobilized to1614clear debris and repair widespread damage and downed power lines);1615Edgar Sandoval, Sophie Kasakove, & Maggie Astor, Winter Storm Disrupts1616U.S. With Power Outages and Icy Roads, N.Y. Times (Feb. 03, 2022),1617https://www.nytimes.com/live/2022/02/03/us/winter-storm-snow-1618ice?bcrFallback=bcrFallback (300,000 homes and business lost power1619following a winter storm).1620---------------------------------------------------------------------------1621    Transit, Motorcoach, and School Bus Services.--Without sufficient1622drivers, transit systems, which are already facing substantial driver1623shortages and serious fiscal constraints, will be forced to further cut1624back on services to families, whether by limiting hours or frequency of1625service or suspending certain service routes.\13\ Driver shortage1626impacts are not limited to large, urban transit systems, but also1627impact rural communities, where motorcoaches and school buses can play1628a role in bridging service gaps.\14\ Fewer school bus operators1629similarly raise the likelihood of reduced or less reliable service or1630entire cuts to bus routes, impacting students, parents, and teachers,1631and reducing access to critical school resources, such as school meals1632and extracurricular programs.\15\ These changes impact the reliance1633interests not only of the people who depend on these services, but also1634the local governments who have designed the bus routes and made certain1635planning decisions with the assumption that there would not be1636substantial changes to their commercial driver workforce without1637reason.1638---------------------------------------------------------------------------1639    \13\ See, e.g., Matthew Dickens, Am. Pub. Transp. Ass'n, Policy1640Brief: Workforce Shortages Impacting Public Transportation Recovery 31641(2022), https://www.apta.com/wp-content/uploads/APTA-SURVEY-BRIEF-1642Workforce-Shortages-March-2022.pdf (showing 71 percent of 117 agencies1643delayed or cut services due to staffing shortages); Laura Bliss,1644There's a Bus Driver Shortage. And No Wonder, Bloomberg (June 28, 2018,1645at 8 o'clock AM ET), https://www.bloomberg.com/news/articles/2018-06-164628/there-s-a-bus-driver-shortage-and-no-wonder (noting significant1647shortages in Seattle, New Jersey, Denver, Los Angeles, Toledo,1648Gainesville, and New Hampshire, many of them leading to delays and cuts1649in service).1650    \14\ U.S. Dep't of Transp. Climate Change Center, Climate1651Strategies that Work: InterCity Buses 3 (2025), https://1652www.transportation.gov/sites/dot.gov/files/2024-10/1653Intercity%20Buses%20- PDF%20%282%29.pdf (bus services ``connect rural1654residents to major urban centers, offering connections to essential1655services and economic opportunities'').1656    \15\ See Cindy Long, School Bus Driver Shortage Persists, neaToday1657(Dec. 14, 2023), https://www.nea.org/nea-today/all-news-articles/1658school-bus-driver-shortage-persists.1659---------------------------------------------------------------------------1660    These consequences are not theoretical.--The Nation has experienced1661recent driver workforce shortages that illustrate the impact of1662insufficient drivers on local government services. For example, a 20221663survey from the American Public Transportation Association found that166496 percent of transit agencies faced workforce shortages, with 841665percent of agencies reporting impacts on service.\16\ These impacts hit1666bus operations most severely, with 94 percent of agencies reporting1667that bus operator positions were the most or second-most challenging to1668fill.\17\ Due to these workforce shortages, public transit agencies1669reported cutting, delaying, and canceling transit service.\18\ One-1670third of agencies stated that these impacts to their services were1671having a negative effect on the reliability of their service.\19\1672---------------------------------------------------------------------------1673    \16\ Am. Pub. Transp. Ass'n, Transit Workforce Shortage 1 (2023),1674https://www.apta.com/wp-content/uploads/APTA-Workforce-Shortage-1675Synthesis-Report-03.2023.pdf.1676    \17\ Dickens, supra note 13, at 2.1677    \18\ Id.1678    \19\ Id.1679---------------------------------------------------------------------------1680    The IFR will only further exacerbate these shortages and ensuing1681reliability issues. This unreliability then disrupts the lives of1682people who depend on these services to get to their jobs, school,1683health care appointments, and visit friends and family. Such disruption1684also plainly runs counter to a DOT order that requires, to the extent1685practicable, administration of DOT policies to maximize benefits1686including economic opportunities, such as ``increased access to jobs,1687health care facilities . . . commercial activity, or any actions or1688project components that will . . . enabl[e families and communities] to1689participate more fully in our economy.''\20\ Decreased and unreliable1690transit service will make it far more difficult for the people who rely1691on these services to access job opportunities, commercial centers, and1692other economic activities.1693---------------------------------------------------------------------------1694    \20\ DOT Order 2100.7,``Ensuring Reliance Upon Sound Economic1695Analysis in Department of Transportation Policies, Programs, and1696Activities''  5(d) (Jan. 29, 2025).1697---------------------------------------------------------------------------1698    Economic Impacts.--Local governments may face broader economic1699effects due to the IFR. For example, governments typically spend money1700to recruit and train employees. Funds already spent on drivers who are1701stripped of their licenses by the IFR cannot be recouped. For example,1702under the IFR, Martin Luther King, Jr. County in Washington stands to1703lose 50 active, non-domiciled bus drivers and an additional 4 recent1704trainees, which represent an investment of over $800,000 in training1705costs.\21\ The need to replace these drivers, thereby spending1706additional funds on recruitment and training, further compounds these1707costs. Applicable laws, regulations, or policies often impose1708substantial training requirements, lengthening the time and increasing1709the cost of replacing drivers.\22\ Likewise, with a limited pool of1710licensed drivers, localities may need to address critical needs by1711relying on increased overtime or temporarily relocating workers, which1712increases the cost of services.\23\1713---------------------------------------------------------------------------1714    \21\ Emergency Mot. for Stay Pending Judicial Review 37, Lujan,17152025 U.S. App. LEXIS 29835, Dkt. No. 2142094.1716    \22\ See Am. Pub. Transp. Ass'n, supra note 16, at 2, 18-22; Bob1717Costello & Alan Karickhoff, Am. Trucking Ass'n, Truck Driver Shortage1718Analysis 4 (2019), https://www.trucking.org/sites/default/files/2020-171901/ATAs%20Driver%20Shortage%20Report%202019%20with%20cover.pdf.1720    \23\ See, e.g., Christine Brittle & Julie Van Keuren, Am. Pub.1721Transp. Ass'n, Impact of CDL Under-the-Hood Testing Requirement on1722Public Transit Agencies' Ability to Hire Bus Operators 3 (2024),1723https://www.apta.com/wp-content/uploads/APTA-Impact-of-CDL-Under-the-1724Hood-Testing-Requirement-Nov-2024.pdf (transit agencies report that1725worker shortages increase the amount of overtime the agencies pay);1726Mark Heinz, `Logistical Nightmare': Short on Plow Drivers & Hammered By1727Weather, WYDOT Had Harrowing Winter, Cowboy State Daily (May 6, 2023),1728https://cowboystatedaily.com/2023/05/06/a-logistical-nightmare-short-1729on-plow-drivers-and-hammered-by-weather-wydot-had-a-harrowing-winter/1730(plow operator shortages caused extra work and wear and tear on1731equipment that put the Wyoming Department of Transportation $9.71732million over its expected budget).1733---------------------------------------------------------------------------1734    Moreover, because most local governments operate on fixed budgets,1735they are limited in their ability to address the effects of the IFR1736through increased expenditures.\24\ They may not be able to, for1737example, raise salaries, offer recruitment bonuses, or support1738additional overtime pay, forcing cuts to critical services. When local1739governments reached their budgets for the year and allocated funding,1740they relied on the availability of their current pool of commercial1741drivers and could not know to account for significant losses to that1742pool and the need to train replacement drivers. Furthermore, if local1743governments are forced to expend additional resources on addressing1744commercial driver shortages, they may also be forced to redirect1745funding away from their other critical services.1746---------------------------------------------------------------------------1747    \24\ Jed Herrmann & Teryn Zmuda, Tough Challenges for Counties in a1748New Era of Fiscal Federalism, Governing (Aug. 15, 2025), https://1749www.governing.com/management-and-administration/tough-challenges-for-1750counties-in-a-new-era-of-fiscal-federalism.1751---------------------------------------------------------------------------1752    Trucking and Supply Chain Impacts.--Local governments also depend1753on the transportation of goods into their communities to perform many1754of their vital functions. The Nation's supply chain for these goods1755depends in large part on truck drivers, as became evident in recent1756years when the country experienced truck driver shortages.\25\ The IFR1757will almost certainly disrupt supply chains, which will further impede1758local governments' ability to deliver vital services. Without an1759adequate trucking workforce, local governments will struggle with1760shortages of materials to support construction projects, increased port1761congestion, and delays in procurement of critical goods and projects1762like housing or electrical infrastructure.\26\ More than just impacting1763the delivery of goods, driver shortages can also lead to increased1764rates for freight operations and higher prices, which will particularly1765affect cash-strapped local governments and their residents who are1766already stressed by the cost of goods and services.\27\1767---------------------------------------------------------------------------1768    \25\ Hugh Cameron, America Doesn't Have Enough Truck Drivers,1769Newsweek (July 10, 2025, at 02:01 PM ET), https://www.newsweek.com/1770america-trucking-shortage-logistics-supply-chain-2097123; Madeleine Ngo1771& Ana Swanson, The Biggest Kink in America's Supply Chain: Not Enough1772Truckers, N.Y. Times (Nov. 9, 2021), https://www.nytimes.com/2021/11/177309/us/politics/trucker-shortage-supply-chain.html; Costello &1774Karickoff, supra note 22, at 1; Catie Edmonson, `What Does a Trucker1775Look Like?' It's Changing, Amid a Big Shortage, N.Y. Times (July 28,17762018), https://www.nytimes.com/2018/07/28/us/politics/trump-truck-1777driver-shortage.html.1778    \26\ Peter S. Goodman, The Real Reason America Doesn't Have Enough1779Truck Drivers, N.Y. Times (Feb. 9, 2022), https://www.nytimes.com/2022/178002/09/business/truck-driver-shortage.html (``[A] shortage of truck1781drivers is frequently cited as an explanation for shortages of many1782other things--from construction supplies to electronics to1783clothing.''); Jack Kelly, There Is A Massive Trucker Shortage Causing1784Supply Chain Disruptions and High Inflation, Forbes (Jan. 12, 2022, at178511:51 AM ET), https://www.forbes.com/sites/jackkelly/2022/01/12/there-1786is-a-massive-trucker-shortage-causing-supply-chain-disruptions-and-1787high-inflation/; Ngo & Swanson, supra note 25.1788    \27\ Edmonson, supra note 25.1789---------------------------------------------------------------------------1790    With nearly 200,000 current non-domiciled CDL holders exiting the1791freight market as a result of the IFR,\28\ supply chains will almost1792certainly be disrupted on a scale similar to the workforce shortages1793experienced in the aftermath of the pandemic. In 2021, the American1794Trucking Association reported that the industry was short by 80,0001795drivers, an all-time high for the industry.\29\ The American Trucking1796Association further estimated that shortage could double to 160,0001797drivers in 2030.\30\ Already, 69 percent of freight businesses are1798struggling to meet demand as a result of these shortages,\31\ and ``to1799keep up with demand over the next decade, trucking will need to recruit1800nearly 1 million new drivers.''\32\ The IFR will instead narrow the1801available pool of drivers and seriously impact the interests of local1802governments who rely on the reliable, cost-effective delivery of these1803goods. For the same reasons, FMCSA's claim that motor carriers will be1804able to adjust their hiring and limit the economic impact on the1805freight market \33\ is based on unfounded assumptions: The experience1806of freight businesses demonstrates that there is not a pool of1807potential CDL holders who are not affected by the IFR that could easily1808take the place of the drivers who stand to lose their credentials as a1809result of this rule.1810---------------------------------------------------------------------------1811    \28\ 90 Fed. Reg. at 46519.1812    \29\ Press Release, Am. Trucking Ass'n, ATA Chief Economist Pegs1813Driver Shortage at Historic High (Oct. 25, 2021), https://1814www.trucking.org/news-insights/ata-chief-economist-pegs-driver-1815shortage-historic-high.1816    \30\ Id.1817    \31\ Hugh Cameron, America's Trucking Industry is in Deep Trouble,1818Newsweek (Oct. 13, 2025, at 5:40 AM ET), https://www.newsweek.com/us-1819trucking-industry-deep-trouble-10861497.1820    \32\ Press Release, Am. Trucking Ass'n, supra note 29.1821    \33\ 90 Fed. Reg. at 46520.1822---------------------------------------------------------------------------1823   ii. the ifr will have adverse impacts on safety, while failing to1824   address the safety risks fmcsa identified and sought to mitigate.1825    The Local Government Signatories acknowledge and support the1826importance of FMCSA's goal to enhance the integrity of commercial1827licensing and the safety of commercial motor vehicle operations. The1828IFR, however, does not address any lapses in compliance with commercial1829licensing requirements by CDL-issuing entities, but rather is a blanket1830ban on certain classes of non-domiciled drivers holding CDLs. Broadly1831stripping CDLs from those classes of drivers does not correlate with1832improved safety outcomes. As the IFR itself acknowledges, there is1833insufficient evidence ``to reliably demonstrate a measurable empirical1834relationship between the Nation of domicile for a [commercial driver's1835license] driver and safety outcomes.''\34\ By contrast, the failure to1836appropriately tailor the IFR will result in a significant reduction in1837the availability of commercial drivers, which will translate into1838increased risk of harm to the public.1839---------------------------------------------------------------------------1840    \34\ Id.1841---------------------------------------------------------------------------1842A. The IFR Imposes New Burdens That Will Harm Road Safety.1843    Local governments rely on employees with CDLs to provide critical1844services designed to improve the safety of public roads. By reducing1845the pool of eligible commercial drivers available to support these1846safety services, the IFR will result in fewer safety services and1847increased risks of harm. Accordingly, the Local Government Signatories1848urge FMCSA to consider the increased risk of harm to the public from1849the diminishment of local government services that promote safety.1850    Maintenance of local roads, in particular, is critical for overall1851roadway safety because although ``local roads are less traveled than1852State highways, they have a much higher rate of fatal and serious1853injury crashes.''\35\ Local governments provide services such as1854regular repair and maintenance of roads and improvement of road design1855to enhance safety.1856---------------------------------------------------------------------------1857    \35\ Fed. Highway Admin., U.S. Dep't of Transp., FHWA-SA-21-033,1858Local Road Safety Plans, https://highways.dot.gov/sites/fhwa.dot.gov/1859files/Local%20Road%20Safety%20Plans_508.pdf.1860---------------------------------------------------------------------------1861    Local government safety services also include essential seasonal1862services, such as clearing road ways of snow and ice and natural1863disaster response. Snow- and ice-clearing services ensure safe and1864reliable access to roads for emergency services and the public alike,1865which further promotes safety. By way of illustration, a local1866government facing a shortage of snowplow operators is unlikely to be1867able to pre-treat or treat road ways as early or as frequently,1868resulting in more hazardous conditions. This will increase the number1869of crashes and their consequences. In some cases, they may be forced to1870close roads entirely and for a longer time until they can be1871plowed.\36\ Doing so risks stranding people at home and delaying1872emergency response services from reaching people in need.\37\ Every1873minute counts for health, fire, and police emergencies, and less snow1874and ice removal capacity will increase those minutes at the cost of1875human lives. And, snow and ice control is already very expensive.1876Winter road maintenance accounts for roughly over 24 percent of State1877DOT budgets for highway and traffic services.\38\ Each year, State and1878local agencies spend more than $4.6 billion on snow and ice control1879operations.\39\ Driver shortages will likely further drive up these1880costs and add to the burden on local governments to maintain these1881critical services.\40\ A smaller pool of commercially-licensed drivers1882therefore risks community safety by limiting local governments' efforts1883to mitigate natural disasters in advance and respond to them when they1884strike.1885---------------------------------------------------------------------------1886    \36\ Heinz, supra note 23.1887    \37\ See Michelle Bandur, `It's a Hiring Problem': Tahoe Basin1888Resident Fear Snow Plow Driver Shortage Will Leave Them Stranded at1889Home, KCRA3 (Nov. 12, 2024, at 7:12 PM ET), https://www.kcra.com/1890article/tahoe-basin-snow-plow-driver-shortage/62888030.1891    \38\ U.S. Dep't of Transp. Fed. Highway Admin., How Do Weather1892Events Affect Roads?, https://ops.fhwa.dot.gov/weather/roadimpact.htm.1893    \39\ Id.1894    \40\ See, e.g., Brittle & Keuren, supra note 23 (transit agencies1895report that worker shortages increase the amount of overtime the1896agencies pay); Heinz, supra note 23 (plow operator shortages caused1897extra work and wear and tear on equipment that put the Wyoming1898Department of Transportation $9.7 million over its expected budget).1899---------------------------------------------------------------------------1900    Federal Highway Administration (FHWA) data show that the risks and1901impacts of snow and ice are already large.\41\ On average (based on19022019-2023 data), freezing precipitation each year causes 219,9421903crashes, injures 34,206 people, and kills 407 people.\42\ Reductions in1904the availability of CDL drivers to apply deicers, plow snow, and manage1905debris will further increase these crashes, injuries, and fatalities.1906Weather also has a major impact on road mobility. Travel time delay on1907high-capacity roads can increase by 11 to 50 percent depending on the1908severity of the weather event.\43\ Heavy snow can cause freeway free-1909flow speed to decrease by 35 to 40 percent and road capacity to reduce1910by 30 percent.\44\ Light snow can decrease flow rates by 5 to 101911percent.\45\ The decreased availability of CDL drivers to manage these1912road conditions will further exacerbate delays and costs for public,1913private and commercial persons and entities. The causality is clear, as1914opposed to the purely speculative safety benefits claims by FMCSA for1915the IFR.\46\1916---------------------------------------------------------------------------1917    \41\ How Do Weather Events Affect Roads?, supra note 38.1918    \42\ Id.1919    \43\ Id.1920    \44\ U.S. Dep't of Transp. Fed. Highway Admin., Emperical Studies1921on Traffic Flow in Inclement Weather 2-8, 2-11 (2006), https://1922ops.fhwa.dot.gov/publications/weatherempirical/weatherem- pirical.pdf.1923    \45\ Id. at 2-3.1924    \46\ According to FHWA, each year trucking companies or CVOs lose1925an estimated 32.6 billion vehicle hours due to weather-related1926congestion in 281 of the Nation's metropolitan areas. How Do Weather1927Events Affect Roads?, supra note 38. Adverse weather conditions affect1928freight traffic 4.6 percent of the time at a national average. Daniel1929Krechmer et. al., U.S. Dep't of Transp. Fed. Highway Admin., Weather1930Delay Costs to Trucking 3 (2012), https://rosap.ntl.bts.gov/view/dot/19313384. Nearly 12 percent of total estimated truck delay is due to1932weather in the 20 cities with the greatest volume of truck traffic. How1933Do Weather Events Affect Roads?, supra note 38. The cost of weather-1934related delay to the freight industry was estimated at $8.659 billion1935or 1.6 percent of the total estimated freight market of $574 billion1936when the study was conducted in 2012. Krechmer, supra note 46, at 3.1937---------------------------------------------------------------------------1938    Reducing the pool of eligible commercial drivers will directly1939impact the safety of residents in the Local Government Signatories'1940jurisdictions. The IFR decreases the number of drivers available to1941support these services, resulting in fewer safety efforts and increased1942risk of harm. Furthermore, a depleted work force increases risk by1943requiring drivers to work longer or more frequently, which decreases1944safety due to driver fatigue. Longer shifts can also contribute to1945driver burnout, further exacerbating work force shortages.\47\1946Moreover, losing experienced CDL drivers may put new CDL drivers on the1947road, when local governments are able to find replacements at all. But1948newly-trained drivers are involved in more accidents, on average, than1949their more experienced colleagues.\48\ The rate of preventable crashes1950is also significantly higher on average for drivers with less1951commercial driving experience.\49\ Driving experience, as compared to1952age, is a greater indicator of crash rates and crash involvement.\50\1953Replacing a non-domiciled CDL driver with any driver who has just1954received their CDL or who has yet to even receive one will decrease1955safety and increase the incidence of crashes and moving violations. Not1956only does the IFR lack a persuasive safety justification, it will1957actively contribute to decreased safety on the roads.1958---------------------------------------------------------------------------1959    \47\ Brittle & Keuren, supra note 23.1960    \48\ Decl. of David Eldred, Chief Administrative Officer (``CAO'')1961for the Metro Transit Dep't of Martin Luther King, Jr. Cnty., Wash. 16,1962Lujan, 2025 U.S. App. LEXIS 29835, Dkt. No. 2142094; Naomi Dunn, Susan1963Soccolich, & Jeffrey Hickman, Nat'l Surface Transp. Safety Center for1964Excellence, Commercial Motor Vehicle Driver Risk Based on Age and1965Driving Experience, 37 (2020), https://vtechworks.lib.vt.edu/server/1966api/core/bitstreams/a5800006-4b00-4854-bd5c-1f3e76f5d5c1/content.1967    \49\ Dunn, Soccolich, & Hickman, supra note 48, at 21, 23, 37.1968    \50\ Id. at 37, 38.1969---------------------------------------------------------------------------1970    Pursuant to the Administrative Procedure Act and for the purpose of1971discharging its statutory duties, FMCSA must consider the implications1972for roadway safety that may arise from limiting the availability of1973commercial driver's license holders to perform these safety-critical1974functions.1975B. The IFR Does Not Address the Problems that FMCSA has Identified.1976    FMCSA has not demonstrated that there is any link between the1977problem it has identified and its chosen solution. In the IFR, FMCSA1978``uncovered systematic procedural and computer programming errors,1979significant problems with staff training and quality assurance, and1980policies that lack sufficient management controls in the issuance of1981non-domiciled CLPs and CDLs by multiple SDLAs,'' and ``identified at1982least five fatal crashes involving non-domiciled CDL holders.''\51\ But1983restricting eligibility for CDLs addresses none of these problems.1984---------------------------------------------------------------------------1985    \51\ 90 Fed. Reg. at 46512.1986---------------------------------------------------------------------------1987    First, restrictions on eligibility for non-domiciled CDLs will not1988help address any of the deficiencies in States' administrative1989processes identified by FMCSA. The eligibility restrictions cannot1990address procedural or programming errors, will not address gaps in1991training or quality assurance, and do nothing to improve management1992controls. The IFR does not include any regulatory changes that would1993address those problems or any issue relating to States' administration1994of CDL licensing. To the contrary, FMCSA's indictment of State1995practices suggests that any claimed safety benefits from the IFR will1996fail to materialize. Moreover, FMCSA does not explain why States'1997failure to enforce existing standards demonstrates that the standards1998themselves must change. The IFR provides no reason to think that1999States' errors relating to programming, training, quality assurance,2000and management controls would not apply equally to a State's handling2001of both domiciled and non-domiciled CDLs.2002    Nor does the occurrence of 5 fatal crashes justify FMCSA's revision2003of the standards for CDL holders. The IFR fails to draw a connection2004between the immigration status of the CDL holders involved in the fatal2005crashes it cites and the fact that those crashes occurred. FMCSA admits2006that it has no evidence to demonstrate any ``relationship between the2007Nation of domicile for a CDL driver and safety outcomes in the United2008States.''\52\ Without such evidence, FMCSA cannot rule out the2009possibility that holders of non-domiciled CDLs are safer, on average,2010than their domiciled counterparts. There are vastly more fatal crashes2011associated with domiciled CDLs, but that does not justify restricting2012their ability to hold a CDL just based on their domiciled status.2013---------------------------------------------------------------------------2014    \52\ Id. at 46520.2015---------------------------------------------------------------------------2016    That problem also undercuts FMCSA's cost-benefit analysis. FMCSA2017claims that the IFR would have positive net benefits if it results in20180.085 fewer fatal crashes per year, or in other words, if it prevents20191.3 percent of the 5 fatal crashes involving non-domiciled CDL holders2020this year.\53\ But FMCSA assumes that those crashes would not have2021occurred, or at least not all would have occurred, if the non-domiciled2022CDL holders had not been driving. That presupposes that: (1) the2023domiciled CDL holders who replaced those non-domiciled CDL holders2024could be expected to practice safer driving habits and avoid a greater2025number of crashes; (2) the fatalities were in any way correlated with2026the driver's domicile; or (3) the trips that resulted in those five2027crashes would have been eliminated, instead of shifted to domiciled CDL2028holders. The first two premises are obviously incorrect, as seen from2029the many fatal crashes caused by U.S.-domiciled CDL holders. As noted2030above, newer CDL drivers have more accidents than those with2031experience, so replacing existing non-domiciled CDL drivers with new2032CDL drivers will cause more accidents.\54\ Again, there is no data to2033support any conclusions that domiciled versus non-domiciled CDL drivers2034are safer or less likely to be involved in an accident. The third2035presupposition is plausible, but not reflected in FMCSA's analysis,2036because elimination of these trips would necessarily and significantly2037impact the freight market or government services. FMCSA's analysis2038significantly undercounts the real risk of accidents involving2039domiciled CDL holders or the costs of disruption to the freight market2040and is therefore fundamentally flawed.2041---------------------------------------------------------------------------2042    \53\ Id. at 46521.2043    \54\ Dunn, Soccolich, & Hickman, supra note 48, at 37.2044---------------------------------------------------------------------------2045    The agency should redo its cost-benefit analysis to determine the2046actual market disruption and the number of additional crashes that2047would result from replacing non-domiciled CDL holders with additional2048domiciled CDL holders on the roadways. FMCSA cannot premise its cost-2049benefit conclusions on flawed assumptions without evidence that the2050benefits it assumes actually would occur.2051    The IFR also ignores that driving history is readily available for2052current holders of non-domiciled CDLs. Applicants who have been driving2053commercial motor vehicles in the United States pursuant to existing2054standards have a demonstrated history of either safe or dangerous2055driving, which is as easily available to State licensing authorities as2056the history of a domiciled-CDL holder. Nonetheless, FMCSA prevents CDL2057renewals for every holder of a non-domiciled CDL, without regard for2058their past driving history. FMCSA has no reason to forbid nondomiciled2059CDL holders with a demonstrated history of safe driving on U.S. roads2060from renewing their CDLs indefinitely. As drafted, the IFR forces the2061Local Government Signatories to use the services of untested seasonal2062workers or novices rather than long-time, proven employees.2063    At bottom, the IFR depends on the existence of a correlation2064between domicile status and safety that is unsupported by the record.2065That makes the burdens FMCSA imposes indefensible and unjustifiable.2066                               conclusion2067    In summary, the Local Government Signatories ask FMCSA to consider2068the harms to a number of critical government services that rely on2069commercially-licensed drivers and the safety implications of those2070effects on safety-critical local government services. We urge FMCSA to2071withdraw or materially revise the IFR to account for these harms and to2072adopt regulatory policy that more closely aligns to the best available2073safety data and evidence.2074    The Local Government Signatories further strongly urge FMCSA to2075consider collecting additional data to better understand the problem2076facing it. The IFR's cherry-picking of 5 incidents in a single year out2077of likely thousands \55\ suggests that, despite FMCSA's extensive data2078collection, it does not have sufficient data to link domicile status to2079the safety and fitness of CDL holders. FMCSA could have required2080States, employers, or other entities to report data about crashes to2081determine what factors actually jeopardize roadway safety and to2082analyze if any correlation exists. Data collection is a natural next2083step. If, on the other hand, FMCSA already has data that it can use to2084better understand how a CDL holder's domicile status impacts road2085safety, then it should disclose and rely on that data instead of2086speculating.2087---------------------------------------------------------------------------2088    \55\ In 2022, 6050 large trucks and buses were involved in fatal2089crashes. There is little reason to think that number has changed so2090drastically since then that 5 represents a significant fraction. See2091U.S. Dept. of Transp. Fed. Highway Admin., Large Truck and Bus Crash2092Facts 2022, https://www.fmcsa.dot.gov/safety/data-and-statistics/large-2093truck-and-bus-crash-facts-2022-1 (last updated Oct. 10, 2025).2094---------------------------------------------------------------------------2095    We look forward to working with you to address these concerns and2096appreciate the opportunity to provide these comments.2097            Respectfully submitted,2098                                     Local Governments and2099           Local Government Leaders (listed in Appendix A).2100                    Appendix A--List of Signatories2101Local Governments2102    City of Albany, New York2103    Albany City Attorney's Office, New York2104    City of Alexandria, Virginia2105    City of Cambridge, Massachusetts2106    Montgomery County, Maryland2107    City of New York, New York2108    Portland City Attorney's Office, Oregon2109Local Government Leaders2110    Celina Benitez, Mayor, City of Mount Rainier, Maryland2111    Jesse Brown, Councilmember, City of Indianapolis, Indiana2112    Chelsea Byers, Mayor, City of West Hollywood, California2113    Chris Canales, Councilmember, City of El Paso, Texas2114    Michael Chameides, Supervisor, County of Columbia, New York2115    John Clark, Mayor, Town of Ridgway, Colorado2116    Alison Coombs, Councilmember, City of Aurora, Colorado2117    Christine Corrado, Councilmember, Township of Brighton, New York2118    Nikki Fortunato Bas, Supervisor, Alameda County, California2119    Brenda Gadd, Councilmember, Metropolitan Nashville and Davidson2120County, Tennessee2121    Caroline Torosis, Mayor Pro Tempore, City of Santa Monica,2122California2123    Terry Vo, Councilmember, Metropolitan Nashville and Davidson2124County, Tennessee2125    Ginny Welsch, Councilmember, Metropolitan Nashville and Davidson2126County, Tennessee2127    Robin Wilt, Councilmember, Township of Brighton, New York21282129    Mr. Brecheen. Thank you, Ms. Liu.2130    I am now going to--instead of going through ranking order,2131I want to recognize Representative Fong given a time limitation2132on his part. Representative Fong, you are now given 5 minutes.2133I think you may have a special guest, also, as a part of your2134opening statement.2135    Mr. Fong. Thank you, Mr. Chair.2136    This is a very important hearing that we are having and it2137is very personal to me. I have the honor of introducing--I know2138they have to catch a flight later this afternoon, but we have,2139I think the Chair read the story of Dalilah Coleman, who was in2140a horrific car accident with someone who was here illegally,2141who obtained an illegal CDL in California. But Dalilah here is2142now 7 years old. She is in the audience here with her father2143Marcus and her mother Ileana, who I think they just got engaged2144at the White House last week, if you saw the video. So they are2145from Bakersfield, California, my home town. So I just wanted to2146make sure to recognize them and put a face to this issue and2147the families of this issue as well.2148    Mr. Brecheen. Will the gentleman just yield quickly? Thank2149you all for taking the time to be here. We are so grateful to2150see her in such good health.2151    Please continue.2152    Mr. Fong. So I want to applaud the Coleman family. They2153have taken a preventable tragedy and horrific situation that2154has affected them and made it their cause to make our roadways2155safer.2156    It is worth noting again, and I will reread the details2157that the Chair mentioned in his opening statement, in June21582024, in San Bernardino County, California, 5-year-old Dalilah2159Coleman and her stepfather Michael were seriously injured in a2160multi-vehicle pile-up caused by an illegal immigrant driving a2161commercial 18-wheeler who sped through a construction zone and2162failed to stop for traffic. Dalilah suffered life-long2163injuries, including cerebral palsy, developmental delays, and2164loss of speech, and she has now worked very hard to relearn how2165to walk. The driver who illegally entered the United States in2166October 2022, was released under the Biden administration and2167held a California-issued CDL.2168    This preventable tragedy forever altered Dalilah's bright2169future. I had the chance to meet with Dalilah and her family to2170discuss Dalilah's Law, the legislation that they are working to2171introduce and to pass, that would require States to limit2172trucking licenses to U.S. citizens and lawful permanent2173residents and certain work visa holders and, No. 2, revoke all2174trucking licenses currently issued to illegal migrants as a2175condition of receiving funding from the Department of2176Transportation.2177    I did want to ask Mr. Tipton, what is your assessment on2178the role States have in preventing future tragedies by non-2179domiciled CDL drivers?2180    Mr. Tipton. So I think it's a multifaceted role that the2181States can play. One is working with ICE and these 287(g) task2182force models which allow for State and local law enforcement to2183be able to verify immigration status. The problem that we run2184into on roadside is that the person that we're talking to may2185have a facially-valid CDL end date. When you run that CDL2186through our law enforcement network system, it comes back as2187valid. But then when we check on the immigration status,2188they're not here legally.2189    Now, they may have originally crossed the border. I'll tell2190you my experience. I've interviewed many of these folks as2191we've taken them into custody. They've--under the former2192administration, they would cross the border, be detained, be2193released, and given, you know, an employment authorization2194document at that time. So now that they've got this document in2195hand, they can then go to a truck driving training school, one2196of these CDL mills, get a certification, in many instances2197obviously not be able to pass the certification because they2198can't speak English efficiently to be able to pass, and then go2199get a CDL.2200    So on its face value, it looks like they're valid. But2201unless you have the authority and the ability to work with ICE2202and verify their immigration status, you don't realize that2203they're here illegally. So I think working--that's step one.2204States have to work with the Federal Government in order to be2205able to take adequate enforcement.2206    Mr. Fong. So that leads to my next question and it refers2207to sanctuary State policies. In California, unfortunately, we2208are a sanctuary State. I opposed it when it was moving through2209the State legislature. So I think what you have outlined is2210when a CDL is issued in one State, that driver is allowed to2211operate across all 50 States. So if California applies a weaker2212CDL standard, that creates a public safety risk for the other2213States. Is that correct?2214    Mr. Tipton. Absolutely, across the board. You know, we--2215and, of course, I live in a State that we call it the2216crossroads of America. I-35, it runs from Mexico to Canada, I-221740 East and West Coast, and then I-44, and those all2218interchange in Oklahoma City. So the amount of nationwide over-2219the-road trucking that comes through our State is a massive2220number. So we see it routinely that other States that don't2221apply the same type of standard, yes, those drivers are going2222to be coming right through Oklahoma.2223    Mr. Fong. Thank you. I appreciate the Chair's flexibility.2224Thank you. Thank you, Dalilah and the Coleman family, for being2225here. You are all inspiration to us. Thank you.2226    Mr. Brecheen. The gentleman yields.2227    I now recognize Representative Thanedar for his 5 minutes2228of questioning.2229    Mr. Thanedar. Thank you, Chairman.2230    Truckers move nearly three-quarters of the country's2231freight, making them an indispensable part of U.S. supply2232chain. Without truckers, there would be no food on grocery2233store shelves, products at big box stores, or fuel at gas2234stations. Nearly 20 percent of truck drivers in the United2235States are immigrants, just as they make up 20 percent of2236overall U.S. work force. They often do the demanding and dirty2237jobs no one else will.2238    These drivers have invested significant time and resources2239into their careers as commercial drivers, and many of them have2240accumulated decades of experience. But now the Trump2241administration is unlawfully attempting to strip some of these2242immigrants of their commercial licenses and their livelihood.2243This will not only create undue hardship on their families, but2244it will also further harm the U.S. economy.2245    President Trump's economy is not the greatest ever in2246history as he claims. Much like his tariffs, the President's2247immigration dragnet is fueling affordability crisis.2248    Ms. Liu, can you please explain how the Department of2249Transportation's actions to restrict immigrants' eligibility2250for commercial driver's licenses will harm the U.S. economy?2251    Ms. Liu. Thank you for your question. Prohibiting2252documented immigrants from having commercial driver's licenses2253will increase costs in the middle of an affordability crisis.2254Trucks are the main way goods are moved across this country.2255Approximately 73 percent of freight by weight is moved along2256America's highways, from consumer products to food to2257construction materials.2258    There is a well-documented need for truck drivers in this2259country. Industry has reportedly estimated a shortage of tens2260of thousands of truck drivers. The Trump administration's2261exclusion of documented immigrants from the truck driver work2262force would force 200,000 experienced drivers out of the2263market, shrinking the existing work force by 5 percent. That2264will disrupt supply chains, delay the delivery of goods and2265materials, and increase rates for freight operations. Already2266news reports say that the cost of a single freight trip from2267New Jersey to Texas has gone up by more than 35 percent because2268of a national shortage of immigrant truck drivers.2269    Mr. Thanedar. Thank you. Thank you so much.2270    Mr. Chair, I seek unanimous consent to add to the record a2271letter from Teamsters California opposing DOT's rule2272prohibiting most noncitizens from obtaining or renewing their2273CDLs.2274    Mr. Brecheen. Without objection, so ordered.2275    [The information follows:]2276                        Statement of the AFL-CIO2277                        Wednesday, March 4, 20262278    The AFL-CIO is a federation of 64 affiliated unions representing2279more than 15 million workers across all sectors of our economy. Our2280members work in every State in the Nation and they come from every2281region of the world. Like the workforce as a whole, our membership2282consists of people with all types of immigration status. Together, we2283strive to ensure that every person who works in this country receives2284decent pay, good benefits, safe working conditions, and fair treatment2285on the job.2286    Workers with commercial drivers licenses (CDLs) make our country2287run and provide a wide range of important services. They carry children2288to and from school. They drive millions of people to and from work on2289buses. They ensure our communities are clean through sanitation and2290recycling pickup. They support our Nation's utility infrastructure,2291manufacturing plants and airports. And they carry commercial freight2292across U.S. highways and along our roads and city streets so that we2293can get the things we need to live and support our families.2294    Unfortunately, the Department of Transportation (DOT) has twice2295tried to prohibit nearly 200,000 workers with lawful work2296authorization, including many union members, from renewing their CDLs2297and will prohibit thousands more from obtaining new licenses. This will2298be devastating for lawful immigrant drivers all around the country,2299many of whom, in reliance on the prior rules, invested thousands of2300dollars into training for careers requiring a CDL. It will also create2301needless disruptions in public services in our communities and critical2302supply chains that make our economy work.2303    DOT's first attempt at issuing this rule failed because the U.S.2304Court of Appeals for the D.C. Circuit found that it was likely2305procedurally flawed. The court also found that the rule was likely2306unlawful because while DOT premised its rule on safety, its own data2307indicated that the CDL holders excluded by the rule (immigrant drivers)2308were involved in fatal crashes at a lower rate than CDL holders who are2309not excluded, meaning the rule would worsen, and not improve, safety.2310    But DOT has continued to pursue this unlawful agenda. The agency2311began using their annual program review process to demand that States2312immediately cease issuing non-domiciled CDLs, in essence achieving what2313Federal courts said they could not do.\1\ And, despite thousands of2314comments opposing the rule, including comments from the AFL-CIO,2315AFSCME, AFT, ATU, IBEW, Teamsters California, and USW, on February 13,23162026, DOT issued nearly the identical rule that had been previously2317stayed, which has again been challenged in the U.S. Court of Appeals2318for the D.C. Circuit.2319---------------------------------------------------------------------------2320    \1\ The full list of States that have received a preliminary2321determination of substantial noncompliance for their issuance of non-2322domiciled CDLs is available here.2323---------------------------------------------------------------------------2324    Throughout this process, DOT has cherry-picked, from the tens of2325thousands of fatal accidents per year, a handful of examples caused by2326people with a single characteristic of having noncitizen status. But2327there is no evidence showing a correlation between immigration status2328and unsafe driving, a fact that DOT admitted in their initial rule2329issuance that ``[t]here is not sufficient evidence, derived from well-2330designed, rigorous, quantitative analyses, to reliably demonstrate a2331measurable empirical relationship between the Nation of domicile for a2332CDL driver and safety outcomes in the United States such as changes in2333frequency and/or severity of crashes or changes in frequency of2334violations.''2335    We call on Congress to hold DOT accountable and to demand that it2336not issue rules that discriminate arbitrarily. Instead, DOT should2337focus on lifting standards for all workers and making our roads safer.23382339    Mr. Thanedar. In addition to the vital role truckers play2340in the U.S. supply chain and economy, they also play a crucial2341role in providing public services to our communities. They2342drive the school buses that take our kids to school, operate2343plows to clear snow during blizzards, and run the mass transit2344system commuters rely on to get to work, just to name a few.2345    Ms. Liu, 19 attorney generals oppose Trump administration's2346efforts to take commercial driver's licenses away from2347immigrants because of the negative impact on public services in2348their States. Several local governments and government leaders2349who support the on-going litigation shared similar concerns.2350Can you please walk us through how the Department of2351Transportation's rule would reduce and degrade essential public2352services?2353    Ms. Liu. Thank you for your question. Prohibiting2354documented immigrants from having CDLs will disrupt and curtail2355essential public services. These governments depend on drivers2356to drive buses for schools, mass transit systems to transport2357people to work, to operate construction vehicles to maintain2358and repair roads. With fewer drivers, these services will be2359disrupted and public safety will be harmed. For example, a2360shortage of snowplow operators means that a local government2361will not be able to treat the roads, resulting in more2362hazardous driving conditions and increasing crashes. Thank you2363for your time.2364    Mr. Thanedar. Thank you, Ms. Liu.2365    I am out of time, so I yield back.2366    Mr. Brecheen. Thank you. The gentleman yields.2367    I now recognize Representative Van Epps for his 5 minutes2368of questioning.2369    Mr. Van Epps. Thank you, Mr. Chairman, for holding this2370immensely important hearing and to our witnesses for joining2371us.2372    Highway safety impacts Americans every day. States like2373California that refuse to enforce driver's license standards2374are putting every driver and passenger on the road in danger.2375When even one unqualified driver is handed a commercial2376driver's license, the danger does not stop at a State line. It2377puts every highway and every family on the road at risk. The2378reality is this is not about a single reckless driver. It is2379about tens of thousands operating nationwide.2380    Last year in my home State of Tennessee, the Biden2381administration granted a non-English speaking illegal alien2382work authorization, allowing him to obtain a commercial2383driver's license. This man went on to cause a multi-vehicle2384crash killing 1 and injuring 2 others. These senseless deaths2385must stop.2386    I am extremely proud of what the Tennessee Highway Patrol2387has accomplished working with DHS to get dangerous illegal2388aliens off our roads and keep our communities safe. But this2389issue has to be fixed across the board. Whether it be fraud or2390sheer negligence, we cannot tolerate sanctuary cities giving2391licenses to unsafe drivers.2392    Sheriff Del Toro, we have heard about the tragic vehicle2393incident in St. Lucie County, Florida, involving an illegal2394alien from India carrying a non-domiciled CDL killing 3 people.2395While we recognize this remains an active and on-going2396investigation, can you share any further details with us and2397how this incident has impacted your county?2398    Sheriff Del Toro. So it's impacted our county in a very2399tragic way by the loss of 3 lives. It was an illegal U-turn in2400the middle of our Florida turnpike and really for no reason.2401There was no emergency that was ahead. It was just an illegal2402U-turn where a completely unsafe maneuver caused 3 people who2403were traveling close to 80 miles an hour to go underneath the2404back of that truck and lose their lives. So it's impacted our2405community in a big way.2406    It was a national story, obviously, because of the fact of2407the non-domicile CDL issue by an illegal immigrant that came2408over the border, I believe in 2018, was issued a notice to2409appear for that violation, and then, as the Chairman stated,2410had failed a test in the State of Washington, I think, I2411believe 10 times before obtaining it in California. So it shed2412a big light on things.2413    I think one of the things that we have to do as public2414servants and elected officials is identify problems and come up2415with ways to solve those problems. I believe the Chairman2416mentioned there was 200,000 CDLs issued to illegal immigrants2417and we all agree that illegal immigrants by the law are not2418allowed to obtain these non-domiciled CDLs. So what can we do2419to solve that problem?2420    I think Florida has taken a big step toward that and I'd2421like to just share with you a few key components to some2422changes that they've made regarding non-domiciled CDLs.2423    Mr. Van Epps. Please.2424    Sheriff Del Toro. So Florida only issues licenses to2425drivers who are in the country legally. Licenses issued to2426noncitizens with temporary legal presence, non-domiciled, are2427valid for a year or the last date of the customer's legal2428status, whichever comes soonest. For each license issued to2429noncitizens, Florida verifies electronically with DHS and the2430SAVE system that the customer had legal presence in the United2431States. We then scan and maintain all documents presented by2432the driver to establish their identity and legal status and2433these documents are available in our DAVID system.2434    All issuance involving drivers with temporary legal2435presence non-domiciled are conducted in person. If a noncitizen2436is only allowed to be in the United States on a temporary2437basis, we place the words ``Temporary'' on the front of that2438driver's license and that is due to Federal Motor Vehicle2439Carrier Safety Administration Rules updates and Florida will2440also begin printing the words ``Non-domiciled'' on the license2441moving forward.2442    The written CDL knowledge test was previously provided in2443Spanish and English with prior approval from the FMCSA.2444However, Florida recently changed its policy that all driver's2445license testing includes Class C--or Class E, correct, must be2446taken in English only. The behind-the-wheel CDL skills test is2447also provided in English as required by FMCSA regulations. At2448the request of FMCSA, Florida paused all issuance of CDLs to2449non-domiciled drivers on November 24, 2025, and plans to resume2450issuances after the new FMCSA rules become effective in mid-2451March, this month.2452    So this isn't to hurt anybody that's here legally in our2453country. It's just a way to vet it out, increase our standards,2454which I think is our responsibility as elected officials to2455protect the public and enhance roadway safety.2456    Mr. Van Epps. Thanks, Sheriff, and thanks for being here2457today.2458    Mr. Chairman, I am out of time. Yield back.2459    Mr. Brecheen. The gentleman yields.2460    I now recognize Representative Strong for his 5 minutes of2461questioning.2462    Mr. Strong. Thank you, Chairman Brecheen. I thank each of2463our witnesses for being here today for the work that you do to2464keep America safe.2465    This hearing is about a simple issue. When Americans share2466the road with a commercial vehicle, they should be confident2467that people behind the wheel are properly vetted, lawfully2468authorized, and qualified to operate a commercial vehicle. I2469speak first-hand. I held a commercial driver's license with a2470passenger endorsement because my family owned a fleet of 45-2471foot Prevost buses that traveled throughout this country for2472more than 40 years without a chargeable accident.2473    Last year, you would think the last thing you would want is2474someone behind the wheel of a commercial vehicle that doesn't2475understand the laws of the land, don't understand turning2476radiuses, don't understand stopping distances, and they have2477got to respect the laws of the land. That is assimilation to2478the United States of America.2479    Under the previous administration, enforcement gaps allowed2480fraudulent documents and stolen identities to slip through the2481cracks, leaving States to deal with drivers who never should2482have been behind the wheel of a commercial vehicle. In my home2483State of Alabama, joint enforcement actions recently removed2484dozens of unsafe truck drivers from the highways, including2485individuals with no valid license at all. Unfortunately, not2486all States share the same sense of urgency in taking action.2487    Commissioner Tipton, in your testimony you confirmed that2488States are encountering fake documents, identity fraud, and2489completely invalid license being used to obtain or attempt to2490obtain CDLs. Alabama's experience shows that targeted2491coordination between State law enforcement and Federal partners2492is crucial to identifying and removing unsafe commercial2493drivers from the roads. You have described a similar effort in2494Oklahoma. How essential is that kind of strong routine2495coordination between State law enforcement and Federal partners2496to effective CDL oversight and highway safety?2497    Mr. Tipton. Thank you for the question. Again, it goes to2498every area of State coordination with the Federal Government at2499the issuance, at the certification of schools who put on this2500training, and the ability to ensure that the training is of2501quality and that the people who pass that training do2502understand the rules of the road and can read road signs and2503all the things that you just explained.2504    On the enforcement side of it, we would not be able to do2505this work if it wouldn't be for the partnership that we have2506with the Federal Government. I'll tell you what we're seeing2507now. We've ran, I believe, 5 special emphasis at our ports of2508entry over the past 9 months--or one of our--so we did one out2509west that I spoke of earlier. We then went to the eastern side2510of the State on I-40 at the Oklahoma-Arkansas border. Within2511minutes of us setting up and starting our operation, my intel2512analysts were seeing social media posts all the way out to the2513North and South Carolina coast telling people Oklahoma's doing2514it again. Go around Oklahoma. Don't go through Oklahoma if2515you're driving a truck and you're not here legally because they2516knew that we were working with ICE.2517    So now we're combating it to where they're going to either2518divert around our State or they're going to hold in another2519State until we're not out working. So I believe it's incumbent2520upon us to work in a coordinated effort across multiple States2521at the same time, same type of operations if you really want to2522get a true enforcement and make some true action on this.2523    Mr. Strong. The greatest compliment your State can get is2524that they are enforcing the laws.2525    Sheriff Del Toro, when your deputies stop a commercial2526vehicle and discover licensing or identity issues that doesn't2527just raise paperwork concerns, it creates a real safety risk on2528the roads. Is that a true statement?2529    Sheriff Del Toro. Yes, sir.2530    Mr. Strong. One theme we have heard today is that2531verification matters, whether it is verifying identity, legal2532eligibility, or basic qualifications before someone is trusted2533with a serious responsibility. The House has twice passed the2534SAVE America Act, which focuses on requiring voter ID to ensure2535only U.S. citizens participate in Federal elections. I was2536proud to vote in favor of that legislation.2537    Sheriff Del Toro, from a public safety standpoint, do you2538agree that the same common-sense principles apply here, that2539verifying identity and eligibility before granting access2540whether to a ballot or an 80,000-pound commercial vehicle is2541far safer than trying to fix the problem after the fact?2542    Sheriff Del Toro. Yes, sir.2543    Mr. Strong. Mr. Chairman, my time has expired. I yield2544back.2545    Mr. Brecheen. The gentleman yields.2546    I now recognize myself for my 5 minutes of questioning.2547    I want to say how excited I am that the Trump2548administration has taken this issue very seriously and, on2549February 13, 2026, how the Department of Transportation did2550issue a final rule that will restrict the issuance of non-2551domiciled CDLs to foreign drivers and it will raise the2552eligibility standards to prevent these unqualified drivers and2553these bad actors. We are not talking about those that are here2554legally. We are talking about those that are in violation of2555FMCSA Federal guidelines.2556    The CDL issuance is not to be taken lightly. Again, you can2557weaponize, especially with the hazmat endorsement, you can2558weaponize an 80,000-pound rig. For those in the trucking2559industry, for those of us that had to learn to drive a semi and2560downshift, and now that the innovation of automatic2561transmissions are out there, it is making the type of driver2562that is sitting in a semi not as educated on downshifting and2563how far you have to pace off of someone in front of you. If you2564are a truck driver, you know exactly what I am talking about.2565    So there is a heightened safety element that has to be2566adhered to. The fact that we are hearing about these CDL mills2567that may be lacking not only basic instruction to make sure2568people can read in English the road signs and know that there2569is a sign that says your speed in a work zone, and they would2570otherwise if they didn't--the ability to read, that would only2571see a number flashing at them. There are some real critical2572elements that being able to read in English is going to create2573havoc if we don't understand this. It is much, much, much far2574and surpassing of that.2575    What can we be doing? Any of the witnesses. I am going to2576zero in with you, Mr. Tipton, because you have been paying2577attention to other States, like Oklahoma. What can we be doing2578on a Federal level outside of what the President, his2579administration has been doing? I know that Representative2580Rouzer has a measure that could be codified. What else can we2581be doing on the Federal level?2582    Mr. Tipton. Again, as I mentioned earlier, you know, I2583think that already suits have been filed against the new2584upcoming rules that FMCSA is going to implement this month. I2585think it's such a critical area that an employee authorization2586document is not sufficient to be able to then turn around and2587go get a CDL. It does not--and it's obvious that the crackdown2588on the CDL mills, the schools that are supposedly safely2589training these folks, when I encounter--when our troopers2590encounter someone who has supposedly passed a test, has their2591CDL, and obviously can't read and speak English and understand2592the rules of the road, those schools have to be shut down.2593    Mr. Brecheen. Absolutely.2594    Mr. Tipton. I'll tell you, and this is in my experience2595with what I've seen in interviewing these people who are2596driving these trucks as we take them into custody, I believe2597there's been coordinated effort to bring people to the Southern2598Border under the last administration, get them through the2599border, get them an EAD issued.2600    Mr. Brecheen. Yes.2601    Mr. Tipton. They go to the school and get this certificate2602and then go to a State.2603    Mr. Brecheen. Eight hundred and seventy thousand new CDLs2604issued under Biden's first year. The fact that we know 502605percent of those who have obtained a CDL in the State of New2606York are fraudulently--they are illegally here, they are not in2607compliance, 50 percent of what New York has issued. Seventeen2608thousand people with CDLs have been granted them in violation2609of Federal statute in the State of California.2610    What else can we be doing on the State levels? What I am2611excited about is the opportunity for Governors, State lawmakers2612to have heard this hearing, understand what the Trump2613administration is doing. These thousands of commercial truck2614drivers, as you said, they are getting on social media saying2615bypass Oklahoma, bypass Indiana. They are taking this thing2616seriously because they are working with ICE.2617    What would be your message? Because you are going to have2618the sanctuary-type States that are going to--and I am grateful2619to the administration saying you are going to do this in2620violation? Get ready. Federal highway funds could be your loss.2621That is the right thing to do. The Federal law has to be2622followed because national security is at risk here as well.2623    What would be your comments to any State Governor in a red2624State that would be willing to bring ICE in? Let them work with2625their OHP, their highway patrolmen, like you all did, and2626making sure that they were--an education, but making sure the2627database of who is here illegally, that if 20 States were doing2628this, what could that do to expedite getting these people2629caught and off the road?2630    Mr. Tipton. It could be done in such a short amount of time2631because they're moving every day across the country. I think2632Oklahoma is a model example of when State and local law2633enforcement work with ICE. There's not chaos, there's not all2634of this uproar.2635    Oklahoma, across the year 2025, we ranked in the top 32636month-to-month on how many illegal criminal aliens we removed2637from our State, from the country. We ranked in the top 3. You2638don't see all the chaos and it's due to that cooperation.2639    So for the safety of everybody involved, both the motoring2640public on the CMV issue, the potential terrorist-type threat,2641you know, you and I come from a State, we understand what truck2642bombs can do and for the safety of everybody involved, the2643cooperation with ICE is critical and can be done in a calm,2644legitimate, legal way.2645    Mr. Brecheen. With that, my time has expired.2646    I want to just because we have had--I think we have come in2647under time, is there anyone else? Representative Thanedar,2648Representative Van Epps, would you have an additional question2649that you would like to ask given our panelists are still here2650and either one of you?2651    Mr. Van Epps. I will ask one more, Mr. Chairman----2652    Mr. Brecheen. Go ahead.2653    Mr. Van Epps [continuing]. If that is OK. Just to follow up2654on that last point to Commissioner Tipton and Sheriff.2655Commercial drivers have access to ports, energy facilities,2656military bases, and hazardous materials routes. How does your2657State conduct enhanced vetting for sensitive cargo?2658    Sheriff Del Toro. I can't speak to how they vet out cargo2659at ports. I've never worked down near one. But I can tell you,2660though, as far as the vetting of drivers, that needs to happen2661and that's why it's so important that Florida's taken the step2662to vet these drivers that are getting these non-domiciled CDLs2663are done in person. They verify with our Federal partners.2664We're no longer working in silos and I'm sure they're doing2665that as well with cargo as well. So I think it's just an2666important thing to recognize the changes we've made in Florida.2667    Moving forward, I think we need to see more of that,2668especially with--can I just touch real quick on the Real ID----2669    Mr. Van Epps. Please.2670    Sheriff Del Toro [continuing]. And the 2005 act? Where the2671States still have the right to issue licensing, but in order to2672meet Federal standards, they have to meet certain standards to2673be recognized federally to get on a commercial aircraft,2674transporting hazardous materials. That's why I think it's so2675important just that simple act itself could really help in2676raising the standards up for these States where they can still2677do the license issuing, but they have to meet some Federal2678standards, which could include in-person vetting, their2679immigration status, working with the States, working with our2680Federal partners to ensure that--to ensure safer roadways.2681    Mr. Van Epps. Thank you.2682    Sheriff Del Toro. Thank you, sir.2683    Mr. Brecheen. Following the theme of allowing additional2684questioning, Representative Thanedar, are you recognized.2685    Mr. Thanedar. Thank you, Chair.2686    Is it true that the standards for commercial driver's2687licenses for U.S. citizens and permanent residents are2688identical to the standards for non-domiciled commercial2689driver's licenses, that is documented immigrants who are2690authorized to work in the United States?2691    Sheriff Del Toro. Can you repeat the question, sir?2692    Mr. Thanedar. It is just a yes-or-no question. Are the2693standards the same as they are for the U.S. citizens drivers or2694permanent residents?2695    Sheriff Del Toro. Yes, correct.2696    Mr. Thanedar. Yes, OK. Is it also true that the2697requirements to obtain a commercial driver's license are2698extensive in that applicants must demonstrate English language2699proficiency, demonstrate 30 different vehicle inspections,2700control, and driving skills, and demonstrate their knowledge in270120 general areas, and consent to alcohol testing?2702    Sheriff Del Toro. I can only speak for the State of2703Florida, but that's correct in the State of Florida.2704    Mr. Thanedar. All right. Given the standards and2705requirements are the same across the board, can you please2706explain to me how the Department of Transportation's rules2707restricting commercial driver's licenses to people with H-2A,2708H-2B, and E-2 visas and stripping it from refugees, asylees,2709and DACA recipients improves highway safety?2710    Sheriff Del Toro. Because there's obviously gaps in these2711standards because people that are here illegally have obtained2712these licenses as well. So I'm not trying to shed any negative2713light on anybody here that's here legally obtaining these or2714differences between whether you're a citizen, permanent2715resident. Those standards, I think, are the same in the State2716of Florida. But the one thing we're not seeing in the State of2717Florida is licenses being issued to illegal immigrants because2718of our vetting process. I think that's where we can close the2719gap federally from State to State to improve highway safety.2720    Mr. Thanedar. Ms. Liu, what is your answer to that?2721    Ms. Liu. Thank you for the question. That's right. The2722standards are identical for U.S. Citizens, lawful permanent2723residents, documented immigrants alike. Regardless of2724citizenship or immigration status, all drivers must demonstrate2725English language proficiency, demonstrate 30 different vehicle2726inspection, control, and driving skills, demonstrate their2727knowledge in 20 different areas.2728    It would not improve highway safety to prohibit documented2729immigrants from holding these licenses. In fact, forcing2730200,000 drivers out of the market and depleting the work force2731by 5 percent will make our roads less safe by replacing2732experienced drivers with less experienced ones and increasing2733driver fatigue for the drivers remaining on the road.2734    Moreover, there is no data, the Trump administration has no2735data showing that noncitizens cause more crashes than U.S.2736citizens. They have conceded that there is no empirical2737relationship between a person's nation of domicile and safety2738outcomes. According to the Trump administration's own data,2739there are approximately 4,000 crashes on average in a year, of2740which 17 were caused by a documented immigrant. That means more2741than 99 percent of crashes are caused by U.S. citizens and2742lawful permanent residents.2743    If the concern is that States are improperly issuing2744licenses to people who do not, in fact, already meet the2745existing requirements about training, English, testing, then2746the solution is to tighten the administrative steps to make2747sure that licenses are going to people who, in fact, do satisfy2748all of the requirements. But excluding documented immigrants2749from being truck drivers altogether would harm highway safety,2750destroy the livelihoods of thousands, increase costs during an2751affordability crisis, and disrupt essential public services.2752    Mr. Thanedar. Thank you so much. So it looks like we can2753look at the statistical data. We can look at total number of2754commercial drivers. We can see what percent of them are the2755immigrants that this law is trying to change. If you look at2756all of the, you know, fatal accidents that happen, what percent2757of those are committed by the immigrants? From what you're2758telling me, it seems like, you know, most of--99 percent of the2759collisions, accidents are as a result of--by U.S. citizen2760drivers or permanent resident drivers. Is that true?2761    Ms. Liu. Thank you for the question. The Trump2762administration has identified 17 examples, as I said, of2763documented immigrants who've caused fatal crashes. But there2764are over 4,000 in a year, so that's less than 1 percent,2765meaning the other--the vast majority is caused by U.S. citizens2766and lawful permanent residents.2767    Mr. Thanedar. Thank you.2768    Mr. Brecheen. The gentleman's time has expired. He yields.2769    So I just want to follow up and this is more than2770anecdotal, again going to the theme of allowing additional time2771for question.2772    This is a tragic example. Sheriff Del Toro, is the2773individual who made the U-turn, he was here illegally. He2774failed his commercial driver's license 10 times in a matter of27752 months. Then yet goes to the State of California, obtains his2776commercial driver's license, and immediately within a very2777short-term time frame leads to the tragic end that you know of2778in your county.2779    Sheriff Del Toro. Correct.2780    Mr. Brecheen. So if someone is not willing to concede that2781the lack of speaking English, the lack of skill is evident.2782Really zeroing in on California and Pennsylvania and New York,2783New York, who is failing 50 percent of their CDL non-domiciled2784we know are here illegally, our attention needs to be really be2785focused there. Again, carrot and stick, Federal highway2786transportation funding, I am so grateful to an administration2787who means what they say and is willing to follow suit when2788there is a lack of adherence.2789    Mr. Tipton in Oklahoma, I find it interesting that when you2790all began to lead on this issue, we were not just talking about2791limited to the border of with Mexico shared by the United2792States. These are the individuals you all found that were2793operating with these commercial truck drivers: India,2794Uzbekistan, Georgia, Kyrgyzstan, China, Pakistan, Russia,2795Belarus, Ukraine, Turkey, Cuba, Guatemala, Venezuela. Is that2796accurate?2797    Mr. Tipton. Yes, sir. It was from around the globe.2798    Mr. Brecheen. It is not just the national security element.2799It is also if you are willing to skirt the law, it tells you2800something about your character. If you are willing to2801compromise in one area, you will compromise in another area. So2802I am grateful.2803    I see in the audience another person from Oklahoma who made2804me heightenly aware. Cole Stevens, thank you for making me2805heightenly aware of what we are also seeing potentially of2806insurance that is being moved around. It is not just CDL mills2807that they are gaming and how you can actually obtain a CDL. It2808is also the potential of when you go to a weigh station, which2809I have had to do, to present your insurance verification. Did2810you all see in the time period that you were there of insurance2811being moved around on one vehicle or another?2812    Mr. Tipton. Absolutely.2813    Mr. Brecheen. Can you explain that? Can you expound upon2814that?2815    Mr. Tipton. It's--I don't know how else to explain it other2816than it looks like a well-organized method of circumventing,2817whether it be insurance, you know, how they got the job, how2818they were brought into the country.2819    Mr. Brecheen. OK.2820    Mr. Tipton. So it's a well-organized--and let me also say2821this, I'll use this as an example. While one of my troopers is2822out with a truck doing an inspection at a weigh station on one2823of our emphasis, at the same time another trooper has a van, a2824passenger van, stopped with, I believe, 8 people inside of it,2825none of whom could speak English. None of them had their--any2826type of identification on them. The driver in the semi that was2827stopped behind them had all of the passports of the folks that2828were in the van. We've found people who have active2829investigations and warrants for human smuggling, drug2830trafficking, money laundering, assault, driving under the2831influence, and failure to appear in court. So this is an even2832larger public safety issue when we let unvetted, untrained,2833unskilled people in these, operate these vehicles.2834    Mr. Brecheen. I would just say this and I am going to land2835the plane. This is not just public safety. It is not just2836national security. It is also for those in the trucking2837industry understand how expensive insurance is. It is also2838those that would game the system, that would undermine legal2839process of being legally operational and find foreign actors to2840work with them, whether it is to modify their logs, their time2841logs, to make insurance, to obtain insurance fraudulently,2842moving insurance from one vehicle to another, therefore2843undercutting someone, a U.S. citizen, someone who has been2844established for years, trying to operate legally, now they are2845having to compete with that full measure of someone operating2846underhanded and under the table. There is a full can of worms2847here that is yet to be fully explored.2848    I am grateful to you, witnesses, for helping us get a2849greater look. I am grateful to President Trump mentioning this2850to his State of the Union address. This is something that has2851to be uncovered to a greater level.2852    I want to thank our witnesses for your testimony, Members2853for their questions. Members of the committee may have some2854additional questions for the witnesses. We would ask the2855witnesses to respond to these in writing. Pursuant to committee2856rule VII(E), the hearing record will be open for 10 days.2857    Without objection, this committee stands adjourned.2858    [Whereupon, at 3:58 p.m., the subcommittee was adjourned.]28592860                            A P P E N D I X28612862                              ----------28632864            Questions From Honorable Al Green for Wendy Liu2865    Question 1. The interim final rule issued by the Department of2866Transportation's (DOT) Federal Motor Carrier Safety Administration2867(FMCSA) on September 29, 2025, would strip asylum seekers, refugees,2868and DACA recipients of their commercial driver's licenses despite being2869legally present and authorized to work in the United States. This issue2870is being framed by my colleagues on the right as a ``safety'' concern,2871seemingly implying that non-citizens, who are lawfully present in the2872United States, are somehow a threat simply because of their immigration2873status. One's immigration status alone is not a valid safety concern,2874and it is not coincidental that the groups affected by the September2875rule are the same ones being targeted by President Trump's deportation2876efforts.2877    Ms. Liu, is there any data to support the argument that documented2878immigrants cause more crashes than U.S. citizens or permanent2879residents?2880    Answer. No. The Trump administration's Federal Motor Carrier Safety2881Administration (FMCSA) stated in February that it cannot ``estimate2882quantitatively the risk associated with non-domiciled [commercial2883driver's license] holders.''\1\ This statement mirrors its earlier2884concession that ``[t]here is not sufficient evidence . . . to reliably2885demonstrate a measurable empirical relationship between the Nation of2886domicile for a [commercial driver's license] driver and safety outcomes2887in the United States such as changes in frequency and/or severity of2888crashes or changes in frequency of violations.''\2\2889---------------------------------------------------------------------------2890    \1\ FMCSA, Final Rule, 91 Fed. Reg. 7044, 7099 (Feb. 2026).2891    \2\ FMCSA, Interim Final Rule, 90 Fed. Reg. 46509, 46520 (Sept.28922025).2893---------------------------------------------------------------------------2894    Question 2. Is the data that the Department of Transportation cites2895to justify excluding documented immigrants from obtaining licenses2896adequate?2897    Answer. No. As noted above, FMCSA has conceded that it has no2898empirical data showing that documented immigrants cause more crashes2899than other drivers.\3\ And, as explained in my written testimony, of2900the approximately 4,000 fatal large truck and bus crashes on average in2901a year,\4\ the Trump administration's own data identifies only 17 that2902were likely caused by a documented immigrant.\5\2903---------------------------------------------------------------------------2904    \3\ See 91 Fed. Reg. 7099; 90 Fed. Reg. 46520.2905    \4\ FMCSA, Crash Statistics, https://ai.fmcsa.dot.gov/2906CrashStatistics?tab=Driver&-2907type=&report_id=36&crash_type_id=1&datasource_id=2&time_period_id=2&repo2908rt_-2909date=2023&vehicle_type=1&State=AllStates&domicile=ALL&measure_id=1&opera2910tion_- id=null (Driver License Status Crash Statistics). FMCSA2911statistics for calendar year 2025 state that there have been 3,9962912fatal crashes involving large trucks and buses, but these statistics do2913not provide breakdowns by CDL status. FMCSA, Crash Statistics, https://2914ai.fmcsa.dot.gov/2915CrashStatistics?tab=Summary&type=&report_id=1&crash_type_id=4&datasource2916_id=1&-2917time_period_id=2&report_date=0&vehicle_type=2&State=NAT&domicile=ALL&mea2918sure- _id=1&operation_id=null.2919    \5\ 91 Fed. Reg. 7065.2920---------------------------------------------------------------------------2921    Question 3. Are all Non-Domiciled CDL applicants required to2922provide documentation demonstrating lawful presence and authorization2923to work in the United States?2924    Answer. Yes. The regulation in effect before the Trump2925administration's rule required every non-domiciled commercial driver's2926license (CDL) applicant to present an unexpired Employment2927Authorization Document, issued by the Department of Homeland Security's2928U.S. Citizenship and Immigration Services, authorizing that person to2929work in the United States, or an unexpired foreign passport and2930approved I-94 form.\6\2931---------------------------------------------------------------------------2932    \6\ 49 C.F.R.  383.71(f)(2)(i) (2021).2933---------------------------------------------------------------------------2934    Question 4. Are these applicants required to pass the same2935knowledge and skills examinations as any other CDL applicant to2936demonstrate competency behind the wheel?2937    Answer. Yes. Non-domiciled CDL applicants must pass the same2938knowledge and skills examinations as all other CDL applicants.\7\ And2939the knowledge and skills requirements to obtain commercial driver's2940licenses are extensive: Applicants must demonstrate English language2941proficiency,\8\ demonstrate 30 different vehicle, inspection, control,2942and driving skills,\9\ demonstrate their knowledge in 20 different2943areas,\10\ and consent to alcohol testing.\11\2944---------------------------------------------------------------------------2945    \7\ See 49 C.F.R.  383.73(f)(2).2946    \8\ See 49 C.F.R.  383.133(c)(5); id.  391.11(b)(2).2947    \9\ 49 C.F.R.  383.113.2948    \10\ 49 C.F.R.  383.111.2949    \11\ 49 C.F.R.  383.72.2950---------------------------------------------------------------------------2951    Question 5. If States were to issue these licenses improperly, are2952there Federal mechanisms in place to establish corrective action plans2953with the State to ensure compliance?2954    Answer. Yes. FMCSA can conduct program reviews of each State's CDL2955program \12\ to ensure that the State is in substantial compliance with2956the Federal minimum standards.\13\ States can then take corrective2957action to correct deficiencies.\14\2958---------------------------------------------------------------------------2959    \12\ 49 C.F.R.  384.307.2960    \13\ See 49 C.F.R.  384.301(a); 49 U.S.C.  31311.2961    \14\ 49 C.F.R.  384.307.2962---------------------------------------------------------------------------29632964                                 [all]