[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-302892-105":3,"detail-sidebar-cat-0-en-105":81,"doc-detail-302892-en":131},{"code":4,"msg":5,"data":6},0,"ok",{"site_id":7,"language":8,"slug":9,"title":10,"keywords":11,"description":12,"schema_data":13,"social_meta":74,"head_meta":76,"extra_data":78,"updated_unix":80},105,"en","fmcsa-ca-response-10262026-1-1","FMCSA-CA-Response-10.26.2026-1-1","","Letter dated October 26, 2025 from Jesse Elison, Chief Counsel, U.S. DOT FMCSA, responding to a September 26, 2025 notice to California about preliminary non-compliance concerning commercial learning permits and commercial driver’s license issuance. The correspondence discusses California’s modernization efforts, an audit identifying technical limitations, and arguments that California’s licensing policies were substantially compliant despite asserted deficiencies. It also explains federal funding apportionment rules, statutory response timelines, and regulations governing non-domiciled CDL/CLP issuance, including validity period requirements and supporting citations.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/document/","Document",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/document/research-report/","Research & 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FMCSA?","Question",{"text":63,"@type":64},"It addresses FMCSA’s September 26, 2025 preliminary determination that California was not in substantial compliance with standards for issuing non-domiciled commercial learning permits and commercial driver’s licenses.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"How does the letter describe California’s actions after the notice of non-compliance?",{"text":68,"@type":64},"California explains that it initiated and responded through audit and modernization efforts, identifying technical limitations in its systems while maintaining that its policies and practices were substantially compliant with federal requirements.",{"name":70,"@type":61,"acceptedAnswer":71},"What federal funding condition is tied to a state’s substantial compliance?",{"text":72,"@type":64},"Federal highway trust fund apportionment can be withheld if, after considering the corrective action schedule, FMCSA still determines the state is not in substantial compliance with licensing requirements under the cited statutes and regulations.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},302892,1789798499,{"code":4,"msg":82,"data":83},"success",[84,88,92,96,101,106,111,115,120,123,127],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},"Story & 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Mail  \nJesse Elison, Chief Counsel  \nU.S. Department of Transportation Federal Motor Carrier Safety Administration 1200 New Jersey Avenue SE  \nWashington, DC 20590  \nRE:  Response to September 26, 2025, Letter Regarding Commercial Learning Permit and Commercial Driver’s License Issuance  \nDear Mr. Elison:  \nThis correspondence responds to your September 26, 2025, letter (Sept. 26 Letter) notifying the State of California of the Federal Motor Carrier Safety Administration’s (FMCSA) preliminary determination that the State is not insubstantial compliance with the standards for issuing non-domiciled commercial learning permits and commercial driver’s licenses. As discussed in detail below, the State of California seeks to ensure that commercial driver’s licenses and learning permits are issued according to state and federal requirements, and continuously reviews and refines its procedural systems accordingly. In fact, as FMCSA is aware, the California Department of Motor Vehicles (DMV) has been undergoing an extensive project to modernize its computer systems over the last few years, and the commercial drivers licensing system will be updated as part of this modernization project.  \nIn response to your letter, DMV initiated an audit that has revealed certain technical limitations in its systems, and it is duly working toward correcting those issues. However, DMV’s audit also revealed that, despite these technical limitations, its commercial driver’s license issuance policies and practices were substantially compliant with applicable federal requirements. Notably, in finding non-compliance, the September 26 Letter appears to rely on prohibitions that did not take effect until after the DMV actions at issue and, indeed, after the  \ndate of the letter itself. Moreover, FMCSA faults DMV and finds non-compliance for practices that were explicitly approved by the Department of Homeland Security. Accordingly, it is not appropriate for FMCSA to withhold federal highway funding or take any other adverse action at this time.  \nCalifornia’s guiding principle in issuing driving licenses is safety, for both CDL holders and the traveling public. DMV is proud of the safety record established in California. In 2023, the last year for which full data is available, California commercial driver’s license holders were involved in fatal crashes at a rate 39.4% lower than the national average. Building on this record of safety, California will continue to work to improve our systems and processes.  \n1. Federal Highway Trust Fund Apportionment  \nFunds are made available to States “to assist the State in complying with the requirements of section 31311 [commercial motor vehicle licensing requirements]; and   to improve the State’s implementation of its commercial driver’s license program.” 49 U.S.C. § 31313(a)(2) . To avoid withholding from this apportionment, States must be in substantial compliance with the licensing requirements outlined in section 31311. Id. §§ 31311-12. That statute permits commercial driver’s licenses to be issued to individuals not domiciled in the issuing State pursuant to regulations prescribed by the Secretary of Transportation. 49 U.S. C. § 31311(a)(12)(B) . Upon notice of a preliminary determination of non-compliance with such regulations, a State has thirty days to respond, and any corrective action taken in response to the notice must “be implemented on a schedule mutually agreed upon by the agency and the State.” 49 C. F. R. § 384.307(c) . If, after considering the corrective action“implemented or planned to be implemented in accordance with the mutually agreed upon schedule,” FMCSA still determines that a State is not in substantial compliance, funding may be withheld on the first day of the following fiscal year  \naccording to a schedule set by statute. 49 C. F. R. § 384.307(c)-(d); see also 49 U.S.C. § 31314; 49 C. F. R.","cbCainEM7AkYLHu5","https://ap.wps.com/l/cbCainEM7AkYLHu5","pdf",273908,16,"English","# Federal Highway Trust Fund Apportionment\n## Regulations Governing Issuance of Commercial Driver’s Licenses\n### Limitations on Validity Periods for CDLs and CLPs","[{\"question\":\"What is the purpose of the October 26, 2025 response letter to FMCSA?\",\"answer\":\"It addresses FMCSA’s September 26, 2025 preliminary determination that California was not in substantial compliance with standards for issuing non-domiciled commercial learning permits and commercial driver’s licenses.\"},{\"question\":\"How does the letter describe California’s actions after the notice of non-compliance?\",\"answer\":\"California explains that it initiated and responded through audit and modernization efforts, identifying technical limitations in its systems while maintaining that its policies and practices were substantially compliant with federal requirements.\"},{\"question\":\"What federal funding condition is tied to a state’s substantial compliance?\",\"answer\":\"Federal highway trust fund apportionment can be withheld if, after considering the corrective action schedule, FMCSA still determines the state is not in substantial compliance with licensing requirements under the cited statutes and regulations.\"}]","FMCSA-CA-Response-10.26.2026-1-1 | PDF"]