Parting Shot: Why Is DOT On Our Back?

Sara Eastwood
Posted on December 1, 2005

It’s funny…you stick around a place long enough and you begin to see a thread of a story weave an entire tale. About nine years ago, a very upset New York operator called me and asked if I’d seen the latest United Motor Coach Association’s (UMCA) newsletter called The Docket. I said I had not, so he faxed it to me. On the front page was a victory editorial about how the UMCA had lobbied for and succeeded in getting a federal bill passed to reclassify the definition of a bus. Up to that point, a bus was defined as a commercial passenger vehicle with a seating capacity of more than 14. According to the UMCA newsletter, the regulators would amend that number to nine (eight passengers plus driver). That meant that the limousine industry, with its limo buses, vans and shuttles, would now be impacted by DOT regulation.

In June 1999 the bill became law. However, until this point, it went somewhat under the radar because there was no enforcement. Well folks, that’s changing right now. Again, thanks to the efforts of the UMCA, state and federal agencies are cracking down. If you read your NLA newsletters you already know that DOT check points are in place in New Jersey and other eastern states to nab operators that are not in DOT compliance. Our problem? Most of us don’t even know that we are operating buses! If a bus is a passenger vehicle of eight plus driver for a total of nine people, that makes all stretch SUVs buses and the DOT knows this. The agents are looking for these types of vehicles to inspect. They are also scouting for any extra-long limousines that are suspected to have more than nine seatbelts. Worse are the penalties for non-compliance. In New Jersey, LANJ Executive Director Barry Lefkowitz announced at the fall NLA board meeting that if an operator is pulled into a DOT check point and does not have the proper sticker in the right place on the outside of the vehicle, the driver isn’t carrying a commercial driver’s license and the vehicle doesn’t meet bus specifications (including roof hatches, kick-out windows and lighted exits), the operator may be fined $10,000. If the operator refuses the inspection, there is a mandatory $1,000 consequence.

So here’s some advice. First of all, be sure your vehicles that may fall under the “bus” category are DOT compliant. Second, make sure everyone on your staff who drives these vehicles (even if they are empty) has a CDL, and has the correct permits displayed where the DOT wants them. Finally, physically review the DOT safety specifications with your coachbuilder and be sure that any vehicle you buy has a DOT sticker on the inside of the driver door panel as required by law.

My assumption on why this is happening? The UMCA is an organization for big charter buses. That industry has been adversely impacted by the growing popularity of smaller charters and vans. I believe that the push to make this niche market more accountable was a defensive move by the big coach operators to level the playing field a bit. We seem to be the victims of circumstance.

P.S. There will be a comprehensive seminar on DOT at the International LCT Show in Las Vegas in February. I encourage everyone who is concerned about this to attend. For more information, go to and click on the show icon.

Sincerely, Sara Eastwood


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