A carrier-specific CLP request is open for comment
FMCSA published a notice on October 27 requesting public comment on PAM Transport’s application for a five-year exemption from part of 49 CFR 383.25(a)(1). PAM wants qualifying commercial learner’s permit holders who have passed the CDL skills test, but have not yet received their CDL credentials from their state of domicile, to drive a commercial motor vehicle without the accompanying CDL holder seated in the front passenger seat. The proceeding is docket FMCSA-2026-3466.
The qualified CDL holder would still remain in the vehicle
PAM is not asking to operate these trips without a CDL holder aboard. Under the proposal, a person holding the proper CDL class and endorsements would remain physically present somewhere in the CMV while the CLP holder drives, but would not necessarily sit next to the driver. PAM says this would let a newly tested driver participate in a revenue-producing trip back to the state of domicile to obtain the physical CDL credential.
The request could cover 500 to 700 drivers each year
PAM estimates that approximately 500 to 700 CLP holders would operate annually under the requested exemption. The company argues that waiting for a state to issue the CDL delays employment, creates financial hardship and may weaken newly acquired driving skills. Those statements are the applicant’s rationale; FMCSA must still evaluate the application, safety analysis and public comments before deciding whether the proposal would provide an equivalent or greater level of safety.
PAM proposes eight eligibility checks and required documents
Before using the exemption, PAM says it would verify that a driver has a valid CLP and underlying driver’s license from the state of domicile, has passed the applicable CDL skills test and has proof of completion, holds the endorsements required for the vehicle, is medically qualified, is not subject to an out-of-service order or suspension, satisfies PAM’s driver-qualification requirements and has a properly licensed CDL holder in the CMV. The driver would carry the license, CLP, skills-test evidence and a copy of the exemption, if one is ultimately granted. PAM also proposes documenting each use and monitoring the driver’s safety performance.
Passing the skills test does not change today’s supervision rule
The notice is an application, not an exemption decision. Under the current rule, a CLP holder must be accompanied by a CDL holder with the proper class and endorsements who is physically present in the front seat next to the CLP holder; the regulation specifies a different seating position for passenger vehicles. FMCSA states that it will grant or deny PAM’s request only after reviewing the record. The public comment period runs for 30 days after publication, and comments become publicly searchable unless properly submitted as confidential business information.
Driver and fleet takeaway
A skills-test pass does not by itself authorize a CLP holder to drive as though a CDL has already been issued. Until FMCSA publishes a final decision—and unless the driver and carrier fall within every stated term—continue following the existing CLP supervision rule. Dispatchers should verify the driver’s active credential, class, endorsements, medical status and restrictions before every assignment and should not rely on an exemption application or a test receipt as operating authority. Drivers should keep proof of testing but decline a dispatch that conflicts with their current credential. Stakeholders commenting in docket FMCSA-2026-3466 should provide specific evidence about supervision, training continuity, enforcement verification and post-test safety rather than assuming the proposed exemption is already effective.
Federal Register — PAM Transport CDL Exemption Application
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