[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-447901-105":3,"detail-sidebar-cat-0-en-105":80,"doc-detail-447901-en":130},{"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":73,"head_meta":75,"extra_data":77,"updated_unix":79},105,"en","georgia-department-of-driver-services-comments-on-commercial-drivers-license-testing-nprm-fmcsa-docket-no-fmcsa-2007-27659-june-6-2008","Georgia Department of Driver Services - Comments on Commercial Driver's License Testing NPRM (FMCSA Docket No. FMCSA-2007-27659) - June 6, 2008","","Georgia Department of Driver Services (DDS) provides comments to the Federal Motor Carrier Safety Administration on a Notice of Proposed Rulemaking for Commercial Driver's License (CDL) testing and Commercial Learner's Permit (CLP) standards under Docket No. FMCSA-2007-27659. DDS supports FMCSA’s safety goals, reviews 17 proposed issue areas, and discusses Real ID prerequisites, CDL renewal verification, social security validation, reciprocity language, out-of-state training concerns, and CLP testing, issuance, and reporting obligations.",{"@graph":14,"@context":72},[15,34,55],{"@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/exam/","Exam",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/document/georgia-department-of-driver-services-comments-on-commercial-drivers-license-testing-nprm-fmcsa-docket-no-fmcsa-2007-27659-june-6-2008/447901/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/georgia-department-of-driver-services-comments-on-commercial-drivers-license-testing-nprm-fmcsa-docket-no-fmcsa-2007-27659-june-6-2008/447901.png","ImageObject",300,407,{"name":42,"@type":43},"Nguyễn Văn Học","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-10-03","2026-09-29",true,{"@type":52,"interactionType":53,"userInteractionCount":30},"InteractionCounter",{"@type":54},"ViewAction",{"@type":56,"mainEntity":57},"FAQPage",[58,64,68],{"name":59,"@type":60,"acceptedAnswer":61},"What is the purpose of the DDS letter addressed to FMCSA on June 6, 2008?","Question",{"text":62,"@type":63},"The letter submits Georgia DDS comments on the proposed rulemaking related to Commercial Driver's License testing and Commercial Learner's Permit standards under FMCSA Docket No. FMCSA-2007-27659.","Answer",{"name":65,"@type":60,"acceptedAnswer":66},"How does DDS describe the current Georgia approach to proof of lawful presence and residency for driver licensing?",{"text":67,"@type":63},"DDS states Georgia law already requires proof of lawful presence and residency before issuance of driver’s licenses, including CDLs, with renewal requirements applying particularly to non-citizens.",{"name":69,"@type":60,"acceptedAnswer":70},"What concerns does DDS raise about requirements tied to CLP issuance and Real ID compliance?",{"text":71,"@type":63},"DDS notes a conflict created by proposed CLP issuance rules with Real ID-related limitations, arguing the result would force costly and cumbersome mechanisms for issuing compliant and non-compliant permits and licenses.","https://schema.org",{"og:url":32,"og:type":74,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":76,"canonical":32},"index,follow",{"doc_id":78,"site_id":7},447901,1790812773,{"code":4,"msg":81,"data":82},"success",[83,87,91,94,99,104,109,114,119,122,126],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":84,"show_sort_weight":85,"slug":86},"Story & Novel",90,"story-novel",{"id":26,"doc_module":4,"doc_module_name":25,"category_name":88,"show_sort_weight":89,"slug":90},"Literature",80,"literature",{"id":33,"doc_module":4,"doc_module_name":25,"category_name":29,"show_sort_weight":92,"slug":93},70,"exam",{"id":95,"doc_module":4,"doc_module_name":25,"category_name":96,"show_sort_weight":97,"slug":98},5,"Comic",60,"comic",{"id":100,"doc_module":4,"doc_module_name":25,"category_name":101,"show_sort_weight":102,"slug":103},6,"Technology",50,"technology",{"id":105,"doc_module":4,"doc_module_name":25,"category_name":106,"show_sort_weight":107,"slug":108},7,"Healthcare",40,"healthcare",{"id":110,"doc_module":4,"doc_module_name":25,"category_name":111,"show_sort_weight":112,"slug":113},8,"Research & Report",30,"research-report",{"id":115,"doc_module":4,"doc_module_name":25,"category_name":116,"show_sort_weight":117,"slug":118},9,"Religion & Spirituality",20,"religion-spirituality",{"id":117,"doc_module":4,"doc_module_name":25,"category_name":120,"show_sort_weight":117,"slug":121},"World Cup","world-cup",{"id":123,"doc_module":4,"doc_module_name":25,"category_name":124,"show_sort_weight":123,"slug":125},10,"Lifestyle","lifestyle",{"id":127,"doc_module":4,"doc_module_name":25,"category_name":128,"show_sort_weight":95,"slug":129},19,"General","general",{"code":4,"msg":81,"data":131},{"doc_id":78,"user_id":132,"nickname":42,"user_avatar":133,"doc_module":4,"category_id":33,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":30,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":95,"language":139,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":12,"update_tm":143,"read_time":144},1374402739827,"https://ap-avatar.wpscdn.com/avatar/14000c97e7351f1a627?x-image-process=image/resize,m_fixed,w_180,h_180&k=1787885694763230660","# Georgia Department of Driver Services\n\n2206 East View Parkway·Conyers,Georgia 30013·678.413.8650  \nGregory C.Dozier  \nSonny Perdue  \nCommissioner  \nGovernor  \n## June 6,2008\n\nU.S.Department of TransportationDocket Operations(M-30)West Building Ground FloorRoom W12-140  \nDEPL OF TRANSPORTATION  \n1200 New Jersey Avenue,SEWashington,DC 20590  \nA:b  \nRE:  Docket No.FMCSA-2007-27659  \nDear Sir or Madam:  \nThe following is intended to serve as the Georgia Department of Driver Services'(hereinafterreferred to as the “DDS”)comments regarding the above-referenced Notice of Proposed RuleMaking pertaining to Commercial Driver's License Testing and Commercial Learner's PermitStandards from the Federal Motor Carrier Safety Administration (hereinafter referred to as the“FMCSA”).First,the DDS applauds the FMCSA’s efforts in promulgating the new regulations.Safety for the motoring public is a paramount concern for the DDS.  \nNotwithstanding the foregoing,the DDS makes the following comments to the FMCSAregarding the seventeen(17)issues addressed in the proposed rule changes:  \nGeorgia law already requires proof of lawful presence and Georgia residency as pre-requisites to the issuance of any driver's license(DL),including commercial driver's licenses(CDL),and similar requirements are found in the Real ID¹Act.The DDS does not currentlyrequire existing customers who are citizens to re-prove their citizenship to renew a CDL,butproof of lawful presence is required anytime a non-citizen renews a DL,CDL,or identificationcard(ID).O.C.G.A.§§40-5-21.1 and 40-5-21.2.The DDS questions the need to re-verify a CDLholder's citizenship on each application for renewal as would be required by the language in49CFR §383.71(d)(5)as it is extremely unlikely that a CDL holder who was a citizen at the time ofinitial issuance is no longer a citizen at renewal.Similarly,the DDS questions the need to re-verify a customer's residential address so long as he or she certifies that he or she still lives inthe same place as it would be required to do under 49 CFR S383.71(d)(6).The DDS would askthat the FMCSA re-consider these requirements.  \n## www.dds.ga.gov\n\nLetter to FMCSA(Docket No.FMCSA-2007-27659)June 6,2008Page 2  \n2.   The DDS already verifies each customer's social security number through the SocialSecurity On-Line Verification and has no objection to the procedure proposed in 49 CFR§383.73(g).  \n3.The DDS already requires surrender of all previously issued CDL's in order to issue aCDL to a customer from another state or to upgrade an existing CDL as required by the existinglanguage in 49 CFR §384.11.O.C.G.A.§40-5-20(c).  \n4.Although the DDS has no objection to the revision of 49 CFR §383.23 and the enactmentof 49 CFR S383.25,the DDS asks that the FMCSA reconsider its decision regarding CDL testingrequirements for out-of-state driver training school students.Having experienced such asignificant probleri with fraud that the state stopped allowing third party testing in for-hiredriving schools,the DDS has grave concerns about the possibility of allowing Georgia residentsto travel to other states for training and testing,which could include third party testing asproposed in Issue 4.  \n5.The DDS has no objection to the proposed reciprocity language in 49 CFR §383.73(1).  \n6.   (a)  The DDS has no objection to the proposed requirement that anyone applying fora CLP must past the applicable knowledge tests as this is already the practice in the State ofGeorgia.  \n(b)  The verbiage in 49 CFR S§383.25(b)and 383.151 requires the states to issue aseparate commercial learner's permit(CLP)from the subsequently issued commercial driver'slicense(CDL)or non-commercial driver's license(DL).This requirement creates a conflict withthe verbiage recently enacted by the United States Department of Homeland Security(DHS)in 6CFR §37.29,which prohibits a customer from simultaneously holding more than one(1)Real IDcompliant driver's license or identification card.It also conflicts with t","cbCaimXsRQZ4itXL","https://ap.wps.com/l/cbCaimXsRQZ4itXL","pdf",286117,"English","# Georgia Department of Driver Services\n## Comments to FMCSA (Docket No. FMCSA-2007-27659)\n## Real ID and CDL/CLP renewal verification considerations\n## Testing, reciprocity, and CLP requirements\n## CLP validity period and retesting proposals","[{\"question\":\"What is the purpose of the DDS letter addressed to FMCSA on June 6, 2008?\",\"answer\":\"The letter submits Georgia DDS comments on the proposed rulemaking related to Commercial Driver's License testing and Commercial Learner's Permit standards under FMCSA Docket No. FMCSA-2007-27659.\"},{\"question\":\"How does DDS describe the current Georgia approach to proof of lawful presence and residency for driver licensing?\",\"answer\":\"DDS states Georgia law already requires proof of lawful presence and residency before issuance of driver’s licenses, including CDLs, with renewal requirements applying particularly to non-citizens.\"},{\"question\":\"What concerns does DDS raise about requirements tied to CLP issuance and Real ID compliance?\",\"answer\":\"DDS notes a conflict created by proposed CLP issuance rules with Real ID-related limitations, arguing the result would force costly and cumbersome mechanisms for issuing compliant and non-compliant permits and licenses.\"}]","Georgia Department of Driver Services - Comments on Commercial Driver's License Testing NPRM (FMCSA Docket No. FMCSA-2007-27659) - June 6, 2008 | PDF",1790723919,13]