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The letter argues the challenged FMCSA rule is arbitrary, lacks evidence, and unlawfully exceeds statutory authority, noting affected drivers undergo the same medical screening, background checks, testing, and training as other CDL holders. It further contends removing qualified experienced drivers endangers road safety and community well-being, while the requested exemption and petition would enhance safety for drivers, passengers, and the public.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/teamsters-california-comment-in-support-of-jenifer-sanchez-vilchiss-application-for-exemption-to-permit-daca-holders-to-obtain-class-b-cdls-fmcsa-docket-no-fmcsa20250886/298756/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/teamsters-california-comment-in-support-of-jenifer-sanchez-vilchiss-application-for-exemption-to-permit-daca-holders-to-obtain-class-b-cdls-fmcsa-docket-no-fmcsa20250886/298756.png","ImageObject",300,407,{"name":92,"@type":93},"Anda","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-31","2026-09-18",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",11,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What is Teamsters California supporting in this submission?","Question",{"text":113,"@type":114},"Teamsters California supports a request by Jenifer Sanchez Vilchis for an exemption to allow DACA recipients to obtain and hold a Class B passenger-vehicle CDL, and it supports a petition to amend FMCSA regulations to let SDLAs issue CDLs to DACA recipients with valid work authorizations.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"Why does the letter argue the FMCSA rule should be denied?",{"text":118,"@type":114},"The letter contends the rule fails to advance legitimate safety interests because excluded drivers undergo the same screening, testing, and training as those allowed under the rule, and FMCSA cannot identify evidence that the excluded drivers are less safe.",{"name":120,"@type":111,"acceptedAnswer":121},"How does the letter claim the requested exemption would affect safety?",{"text":122,"@type":114},"The letter argues granting the exemption and the regulatory amendment would enhance safety for CDL holders, passengers, other road users, and communities by keeping qualified experienced drivers in the workforce rather than removing them.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},298756,1789764823,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":29,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":130,"read_time":144,"preview_page_count":4},962075006959,"https://ap-avatar.wpscdn.com/avatar/e0002397efbe92a78e?_k=1776741047341049297","July 1, 2026  \n[Via Electronic Submission to Regulations.gov](Via Electronic Submission to Regulations.gov)  \nDerek D. Barrs Administrator  \nFederal Motor Carrier Safety Administration 1200 New Jersey Avenue SE  \nWashington, D.C. 20590  \nLarry W. Minor  \nAssociate Administrator, Office of Policy Federal Motor Carrier Safety Administration 1200 New Jersey Avenue SE  \nWashington, D.C. 20590  \nRe: Docket No. FMCSA–2025–0886: Teamsters California Comment in Support of Jenifer Sanchez Vilchis’s Application for Exemption to Permit DACA Holders to Obtain Class B CDLs  \nTeamsters California represents 250,000 workers across dozens of industries that power the state’s economy and keep our communities running. Teamsters in California with commercial driver’s licenses (“CDLs”) do critical work day in and day out—delivering food, packages, and other goods, driving our children to school and our neighbors to work, and ensuring our communities are safe and clean. Our members have invested substantial time, training, and resources into becoming skilled drivers in reliance on being able to hold and use their CDL to support their families, and they have fought to maintain the highest possible safety standards in their workplaces.  \nTeamsters California members include many Deferred Action for Childhood Arrivals (“DACA”) recipients with valid work authorization under federal immigration programs. These workers have long utilized their CDLs to perform essential work in package delivery, passenger transport, sanitation, and other key sectors. Their careers were abruptly halted earlier this year when the U.S. Department of Transportation (“DOT”) Federal Motor Carrier Safety Administration (“FMCSA”) issued a final rule prohibiting most noncitizens from obtaining or renewing their CDLs. See 91 Fed. Reg. 7044 (Feb. 13, 2026) (“Rule”) . In effect, the Rule arbitrarily cuts short these drivers’ ability to continue using their CDLs to provide for their families and contribute to their communities, all while conferring no safety benefit on the general public.1 To the contrary,  \n1 For more detailed discussion ofwhy the Rule is arbitrary and capricious and exceeds FMCSA’s statutory authority, see Brief of Teamsters California as Amicus Curiae in Support of Petitioners’  \nthe Rule—and the resulting removal of thousands of qualified and experienced drivers from an already strained labor pool—directly compromises road safety and endangers the well-being of our broader communities.  \nTeamsters California writes in support of a request submitted by DACA recipient Jenifer Sanchez Vilchis for an exemption to obtain and hold a Class B passenger-vehicle CDL under the same conditions as other lawfully work-authorized individuals (“Exemption Request”) . Teamsters California also writes in support of Ms. Sanchez Vilchis’s petition to amend FMCSA regulations to allow state driver’s licensing agencies (“SDLAs”) to issue CDLs to DACA recipients with valid work authorizations (“Petition to Amend”) . As discussed below, granting the Exemption Request and the Petition to Amend would enhance, not jeopardize, the safety of CDL holders, passengers, other drivers on public roadways, and all of those who depend on the critical services these drivers provide.  \nI. The Exemption Request Should Be Granted Because There Is No Legitimate Reason to Deny CDLs to DACA Recipients.  \nAs Teamsters California explained in its prior comment opposing FMCSA’s interim final rule,2 the Rule fails to advance any legitimate safety interest. The CDL holders impacted by the Rule—including Teamsters California members who have since lost their CDLs—undergo the same rigorous screening and extensive testing and training as their counterparts who remain eligible for a CDL under the Rule. For example, in order to obtain their CDL, drivers in California must submit to significant vetting processes, where they provide extensive documentation on their 10-year driving history, a medical examination, fingerp","cbCain09W8FHAE4Q","https://ap.wps.com/l/cbCain09W8FHAE4Q","pdf",336087,"English","# Background and Support\n## Who is impacted by the FMCSA rule\n## The requested exemption and petition to amend","[{\"question\":\"What is Teamsters California supporting in this submission?\",\"answer\":\"Teamsters California supports a request by Jenifer Sanchez Vilchis for an exemption to allow DACA recipients to obtain and hold a Class B passenger-vehicle CDL, and it supports a petition to amend FMCSA regulations to let SDLAs issue CDLs to DACA recipients with valid work authorizations.\"},{\"question\":\"Why does the letter argue the FMCSA rule should be denied?\",\"answer\":\"The letter contends the rule fails to advance legitimate safety interests because excluded drivers undergo the same screening, testing, and training as those allowed under the rule, and FMCSA cannot identify evidence that the excluded drivers are less safe.\"},{\"question\":\"How does the letter claim the requested exemption would affect safety?\",\"answer\":\"The letter argues granting the exemption and the regulatory amendment would enhance safety for CDL holders, passengers, other road users, and communities by keeping qualified experienced drivers in the workforce rather than removing them.\"}]","Teamsters California Comment in Support of Jenifer Sanchez Vilchis’s Application for Exemption to Permit DACA Holders to Obtain Class B CDLs - FMCSA Docket No. FMCSA–2025–0886 | PDF",15]