WASHINGTON -- The United Motorcoach Association has roundly criticized a proposed federal rule establishing training requirements for new-entrant bus and truck operators, saying the rule would be at cross purposes with the governments goal of increasing highway safety.

In rejecting the Federal Motor Carrier Safety Administrations proposed rulemaking, titled "Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators," UMA also said the proposal would compound the national driver shortage that plagues the motorcoach industry.

Ken Presley, author of the comments and UMAs vice president for industry relations, argues that FMSCA sought no counsel from the passenger transportation industry in drafting the rule and as a result the proposal is barely relevant to the training needs of future bus drivers.

According to UMA, FMCSA persists in a "continued inclination to combine passenger transportation operations with long-haul trucking issues and solutions and disregards the enormous disparities in operations and responsibilities."

The rule draws from the Professional Truck Driving Institute and affiliated programs and uses the Model Truck Driver Training Curriculum as a sample training format while ignoring the Model Motorcoach Driver Training Curriculum entirely.

As a result, says Presley, critical "passenger transportation issues such as compliance with the Americans with Disabilities Act, lift and tie-down operations, bus and motorcoach fires and evacuation procedures" are not included in the training requirements.

The proposed rule also ignores the reality of bus driver training as it exists in the United States today.

The FMCSA could identify 130 truck driver training schools, but the agency could not identify even one independent facility for bus and motorcoach drivers. Yet, somehow in the next three years, bus driver schools are expected to rise up fully accredited and ready to take over the training that has been the sole responsibility of motorcoach operators for decades.

In addition, the rulemaking does not include guidelines on the one outside source of bus driver education currently available -- the online coursework provided by the accredited Bus and Motorcoach Academy administered by the College of Southern Maryland.

UMA contends that many of the current bus driver trainers, which are owners or employees of motorcoach companies, will be unwilling to bear the expense of becoming accredited, especially since the 58 hours of classroom training and 32 hours of behind-the-wheel training stipulated by the rule may fall short of the standard that they have established for their own purposes.

Motorcoach operators train drivers to meet their own business needs. This education can be quite specific to the job at hand. A statewide certification would mean a more generic curriculum, one less likely to suit the needs of the motorcoach company providing the training, Presley notes.

The motorcoach operators currently training drivers may be equally reluctant to bear the liability of certifying bus drivers for the state. The FMCSA has not taken this liability into account, says Presley.

A motorcoach company would take on a large risk by certifying bus drivers trained at its facility, since such certification would be required prior to the states granting a CDL. The liability would remain throughout the drivers career, which could be much longer than the term of the drivers employment at a particular company. This kind of certification should fall, instead, under the authority of the state, Presley contends.

And, there is the tricky situation of intrastate bus drivers (school bus and transit drivers, for example), exempted from the proposed rule and yet able to attain a CDL despite the required entry-level training.

"The United Motorcoach Association concludes this likely creates an unintended path for CDL holders to progress to interstate driving, thus creating a significant number of drivers who may not have received adequate or required training."

Putting the cart before the coach

While UMA supports the FMCSAs overarching goal of strengthening entry-level driver training and is ready and willing to assist in the development of higher standards for bus and motorcoach drivers, the association asserts that FMCSA has the process backwards.

"An 'accredited'/comprehensive classroom/behind-the-wheel training program with rigorous testing is simply inconsistent with the general low thresholds most states require for obtaining a CDL."

Meanwhile, FMCSA also is revising CDL testing and learners permit standards (Docket No. FMCSA 2007-27659). Implementation of this rule could have significant implications for entry-level driver training, notes Presley.

"UMA suggests that further consideration of the proposed entry-level training rule be delayed until the effects of changes in CDL requirements are known."

The proposed rule sets up more comprehensive training as a prerequisite to obtaining a CDL. You wouldnt get your masters degree before you got your bachelors. The "mandated and documented minimum training requirements" should be a "post-CDL attainment," not vice versa.

For the full text of the United Motorcoach Association comments, go to www.regulations.gov., FMCSA Docket No.-2007-27748, RIN 2126-AB06.