Grassroots Alert: Your Comments to DOT Needed to Support Proposal Allowing Ag Aviators HM Endorsement Exemption to Transport up to 1,000 Gallons of Jet A
Agricultural aviation operators could see both cost savings benefits and a greater supply of drivers due to a new NAAA advocated CDL exemption proposed by the Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA). The proposed exemption would amend FMCSA safety regulations to allow states to waive the hazardous materials (HM) endorsement requirement for Class A CDL holders of agricultural aviation operators that haul no more than 1,000 gallons of aviation-grade jet fuel. FMCSA’s proposal was initiated by an application submitted by NAAA, which pointed out that the agency already waives the CDL hazmat endorsement requirement for drivers of other agricultural entities hauling diesel fuel—a fuel with nearly identical chemical properties and a flashpoint similar to Jet A.
The proposal is presently available for public comment in support of or in opposition of the proposed rule until February 3, 2025. NAAA is urging aerial applicators and state and regional ag aviation associations nationwide to comment in favor of this proposed rule. To review the proposed rule go to: https://www.regulations.gov/document/FMCSA-2024-0121-0012. To comment go to: https://www.regulations.gov/document/FMCSA-2024-0121-0012/comment and follow the prompts to either directly write comments or upload them. Please reference: Docket Number FMCSA – 2024-0121 in your comments. A draft of NAAA’s comments may be found by clicking here. Follow the NAAA format in drafting your own comments, such as using your own personal or company letterhead. Emphasize the following points:
- Personalize your comments and elaborate on the geographical area in which you treat crops aerially in your location, including acres treated, crops treated, number of farmer customers, etc.
- If you transport fuel to a satellite strip emphasize how important this proposed rule is to your operation, acknowledge the FMCSA for proposing the rule and state that you support the rule.
- State safety measures you take to ensure the competency of your drivers, the safety of your vehicles and how that translates to the safe operation of your trucks transporting fuel on the highways in which you utilize.
- State difficulty you have in finding, training and retaining CDL drivers with an HM endorsement.
- Provide real world examples of the distance you travel between your main strip and satellite strip per year transporting jet fuel and what the extra cost in fuel and time to treat your contracted cropland would take if you were unable to use a satellite strip by not having a CDL drivers and how exempting the HM endorsement will increase the availability of drivers.
- Feel free to utilize NAAA’s points in its comments to the FMCSA within your own comments. Those can be found by clicking here.