pfarber, are you actually in the trucking business or just a self proclaimed expert. I operate as a private carrier as well as a contract carrier and a Texas specialized motor carrier. This can be verified: USDOT 272279 MC 590227 TXDOT 35687. I make my living with trucks and I have been doing this since 1964. I deal with Federal Motor Carrier regulations on a daily basis. I' m not sure that this thread has benefited the guy that first asked a question. Just for the record, commerce is not the entire premise of a CDL.