Entry Level Training Rule, I found it called 15 different bureaucrats today no one knew what this is

Federal Register :: Commercial Driver's License Upgrade from Class B to Class A

Implementation and Enforcement National Registry Training Provider

Basically put this already exists and the USDOT and FMCSA didn't seem to be aware of it. I called FMCSA and they stated my state's DOT should do this. WRONG And yes I audio recorded all calls and thankfully it was only an hour spent.

§380.709 Facilities.
The training provider's classroom and range facilities must comply with all applicable Federal, State, and/or local statutes and regulations.

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§380.711 Equipment.
(a) All vehicles used in the behind-the-wheel training must comply with applicable Federal and State safety requirements.

(b) Training vehicles must be in the same group and type that driver-trainees intend to operate for their CDL skills test.

Basically these commercial truck driving schools need to be registered with the department of education (which explains why state DOTs seem to have no awareness of any of these FMCSA rules yet the FMCSA claims to have no jurisdiction at all):

Training institution means any technical or vocational school accredited by an accrediting institution recognized by the U.S. Department of Education. A motor carrier's training program for its drivers or an entity that exclusively offers services to a single motor carrier is not a training institution.


What bothers me is I am only allowed to train on one, aspect the pre-trip. I have recieved no instruction except for a brief overview in the classroom which was 2 month ago. Because the rule by the WISDOT came into effect and all the students who sat on their arses over the last 6 months and didn't ask for training schedules and didn't come to either training location. They need to complete their training in February and March in order to test by April 1st..... The instructors at both training locations have had 4-6 1 hour instruction hours with different students each day for 2 months solid. There hasn't been a 'spare' instructor for pre-trip inspection open classes in 2 months, nor has there been an available complete tractor trailer combination for that 2 months. The school is trying to cram in as many students into is business week that its having students take the road test with a 3rd party examiner on saturdays so it doesn't eat up instructor times during the week. A tractor trailer has been left at a wisconsin DMV testing site for weeks now to cut down on the amount of time instructors have to use to shuttle the tractor truck from the training location to the road test location.

And its a general rule for good reason that a student who isn't schedule for instructor led training time not interfere with the training time that has been scheduled for other students. Therefore this claim the school has offered 2 different days of 3 hour blocks of time that an unscheduled student can access instructors to ask questions on the pre-trip inspection is patently false. According to FMCSA rules the school that is f@cking me over is not in compliance, let alone not making tractor trucks available to students who are not scheduled.

I have instructors #####ing and complaining about having 4-6 hours a day with students and not enough time to log their instructor notes (which students are not allowed to see) this is audio recorded (the instructors feel free enough to complain about their packed schedule because they don't care how this appears to students). If the instructors sit around and ##### about being over scheduled and needing to leave early then I have ample opportunity for me to audio record these rants to make available for the correct agency personel to review.

They have been closing the satellite training location down early to allow instructors to leave before the end of the business day because they are over worked. then I am expected to drive another 25 miles to another state to use equipment that is not available at a location. I am not notified in advance that equipmemnt like a tractor trailer won't be available at one location before I show up.

This is why folks schools shouldn't have more students than instructors and equipment can handle. FMCSA needs to ensure that there is a ratio between students and instructors/equipment.

This school also has 3 different hour level packages, I choose the package with the least hours, there are two other packages with more hours one more than the other. All three packages are supposed to have the same training schedule until the road test and the same aptitude success for each section of the training before moving on to the next section of training.

Problem with this is the 2 other packages the students dont come back afterward they pass the road test to take advantage of the "enhanced" training. Instead the enhanced training is put back into the skill levels before the road test. listed before is how its set up:

Classroom & Online

Backing (simulator and vocational instructor-indoors)

Pre-trip inspection (self taught)

Behind the wheel (Instructor led training hours)

Road test

Enhanced professional training for 2 programs with more hours than basic.

Now this is the reality since the enhanced professional training is removed.

classroom and online

backing (for basic is mainly simulator) (for enhanced programs, which are two of them they get access to instructor led range backing outside with real tractor trucks)

pre-trip inspection (basic program you train yourself and then you get evaluated to move onto backing range and behind the wheel) (for enhanced programs you get instructor led training hours on pre-trip combined with on the road behind the wheel training aka they skip ahead )

behind the wheel (basic program you get 2-4 hours max of instructor led training and no pre-trip instruction because you should have passed the evaluation by this point for pre-trip) (the two other enhanced programs get behind the wheel, pre-trip inspection recoaching and some extra hours on a backing range)

This is folks how the students who had to choose the basic end up dropping out and getting not getting a refund because they don't get past the pre-trip inspection and if they do they fail the road test a few times before they pass.

The enhanced program students don't come back after passing the road test so they reorganized the training schedule to ensure they pass the road test and the school doesn't have to refund the students the money for the enhanced hours.

Its quite a bit of nonsense, moreso when tractor trucks set aside for pre-trip inspection self study aren't available consistently at both locations and you are expected to drive 25 miles one way and not be told in advance where the tractor trucks used for pre-trip training.

Nor are the instructors actually available for questions for these pre-trip inspection classes that are scheduled but the instructors are out teaching other students behind the wheel in the tractor trucks on the road.

I would suggest to the FMCSA that entry level driving students be allowed to take the classroom from a ELT school and get the behind the wheel portion from a CMV rental that has a LCV license. If you pay by the hour for behind the wheel training then you get what you pay for, pay a school for a program they will not make the resources available to the students so they can get through the program to test without waiting 4-6 months.