It’s Tricky Hauling Livestock in California

Several of our friends in California have been in contact about Commercial Driver’s License laws in their state. Because of these requests we put together this information for our supporters in California.
There is a lot of confusion surrounding Commercial Driver’s License issues as the state laws in California are very different and much more restrictive than the Federal laws and the laws of most other states. California also, does not offer their residents some of the exemptions found in other states.
It is important to note; if you are NOT a resident of California, these laws do not apply to you, even if you periodically drive in California per Section 12502(a) of the California Vehicle Code (CVC). However, even if you are traveling to California from out of state, in some circumstances, it may be wise to carry proof of exemptions with you. For example, some states consider living quarters horse trailers to be a recreational vehicle (RV) and some states may exempt drivers of RVs from Commercial Driver’s License (CDL) requirements.
Please use this information as a guide only. The Electronic Logging Device Mandate (ELD Mandate) and other licensing and hours of service requirements for hauling livestock have become a very complex issue over the last several years. We encourage everyone to do their own research and California residents should call the California Highway Patrol (CHP) with questions about their specific situation. We cannot stress enough how important it is that each driver fully understand the licensing laws for their state of residence.

California Residents:
Horse & Stock Trailers – Business Related Use
Examples: Commercial horse haulers, horse trainers, those with sponsorships, any use for the furtherance of a commercial enterprise or business without any type of Covered Farm Vehicle designation.
Operation of a combination of vehicles when the TOWED UNIT has a
GVWR (Gross Vehicle Weight Rating) or GVW (Gross Vehicles Weight) less than 10,000 pounds
• REQUIREMENTS:
 Class C Driver’s License
 Need DOT & CA #’s
 Need to meet any other state and federal requirements for a Commercial Motor Vehicle (CMV)

GVWR or GVW more than 10,001 pounds – YOU ARE CONSIDERED A COMMERCIAL DRIVER
• You must comply with all federal and California laws that govern Over-The-Road professional tractor trailer drivers including any future changes to the ELD Mandate and its HOS requirements.
• REQUIREMENTS:
 California Class A CDL
 Medical Certification
 Subjected to Random Drug Tests and more

Recreational Horse and Livestock Hauling
Operation of a combination of vehicles when the TOWED UNIT has a;
GVWR or GVW less than 10,000 pounds
• REQUIREMENTS:
• Regular Class C Driver’s License

GVWR or GVW more than 10,001 pounds
• REQUIREMENTS:
 Regular Class A CDL – Written and Driving Tests & Medical Certification required.
• Living Quarter Horse Trailers are considered horse trailers, not RV’s or travel trailers.
• FMCSA’s non-commercial horse hauling exemptions for the group do not exempt these drivers from a CDL as the California laws must be followed.

Fifth Wheel Travel Trailers & Trailer Coaches in a Not-for-Hire Capacity
• Class C DL with an endorsement (shown as a restriction 41):
 Operation of combinations of vehicles when towing a trailer coach exceeding 10,000 pounds GVWR, and a fifth-wheel travel trailer NOT exceeding 15,000. Section 12804.9(b)(3)(F)(ii) CVC
 IMPORTANT NOTE: Not applicable to horse, stock, or living quarters horse trailers

• Class A Restricted (noncommercial) Driver’s License:
 When towing a trailer coach exceeding 10,000 GVWR or a fifth wheel travel trailer exceeding 15,000 pounds GVWR. Section 12804.12(a) CVC
 IMPORTANT NOTE: Not applicable to horse, stock, or living quarters horse trailers

Farmers and Ranchers – EXCLUSIVE Agriculture Use Only in a Not-For-Hire Capacity
• Class C Driver’s License:
 Combination vehicles weighing less than 26,000 pounds operated by farmers, ranchers, their families and employees exclusively in a not-for-hire capacity for agriculture operations only. Section 12804.9(b)(3)(G) CVC
 This California Driver’s License is not applicable for recreational use.

• Class A Restricted (noncommercial) Driver’s License:
 Allows the operation of combinations of vehicles when towing a livestock trailer exceeding 10,000 pounds, but not exceeding 15,000 pounds GVWR or GVW, as long as the vehicle is operated by a farmer (their family or employee); the vehicle is used to transport livestock to or from a farm. This is only for use within 150 miles of the person’s farm. Section 12804.14(a) CVC
 This DL is not applicable for recreational use.
 Over 15,001 GVWR or GVW needs a Class A CDL – no information found as to other Commercial Motor Vehicle Laws and if those would be required.

• Operation of a combination of vehicles when the TOWED UNIT has a GVWR (Gross Vehicle Weight Rating) or GVW (Gross Vehicle Weight) of 10,001 pounds or more and OUTSIDE the 150-mile radius:
 YOU ARE A COMMERCIAL TRUCKER and all that entails including a Class A CDL, DOT #, Drug Testing, possible ELD and HOS requirements.

Like Riddles? Here’s a California Scenario:
Combination Vehicle Used By A Rancher
• Truck: 2003 Dodge Dually pickup (11,500 GVWR)
• Trailer – Designed for Livestock (14,000 GVWR)
• Meets all criteria needed
 Not-for-hire
 To & from owner’s ranch only in the process of agricultural operation
 Within 150 miles of farm/ranch

Which class of Driver’s License does the rancher need for a very common sized combination?
A: Class C DL – the combination is less than 26,000 pounds per Section 12804.9(b)(3)(G) CVC
B: Class A Restricted DL – the towed unit is between 10,001 & 15,000 GVWR per Section 12804.14(a) CVC.

Want the answer to the riddle?
Answer: Your guess is as good as ours, there seems to be conflicting information. It might depend on what cargo is in the trailer. Hay bales to feed cattle or the cattle themselves. Are livestock owners being singled out with these California laws?

Ask the CHP (see number below). Those calling could also ask another important question. Do the officers at the roadside trailer checkpoints base license requirements on the GVWR or the GVW of the towed unit? Those numbers will be different for every trailer and are not interchangeable. One is a weight rating set by the manufacturer, the other is an actual weight (curb weight and cargo weight added together). However, adding further confusion to the situation, in the California Vehicle Code, the numbers are used as if they are interchangeable or at least the same # for each trailer.

Newer trailers, even smaller models, now have heavier rated axles to improve handling and safety. A smaller 2-3 horse gooseneck trailer with (2) 7000 lb axles has a GVWR of 14,000 pounds. Actual gross vehicle weight or GVW often won’t get anywhere near that GVWR. Further separating the GVWR and GVW numbers and putting a higher number of drivers into the questionable need of obtaining a California Commercial Driver’s License (CDL). If taking your loaded trailer to a scale is an option, it seems like a good idea, especially for those drivers that have smaller trailers that may straddle the GVWR vs GVW line.

Just for reference the GVWR of this 1991 3 horse trailer below is 11,800 pounds and it’s empty weight (before horses and other cargo) is approximately 5500 pounds.

Information and Resources:

Source Information:
2/5/2019 CHP Information Bulletin, California Vehicle Codes, and Phone Interview with CHPhttps://www.chp.ca.gov/CommercialVehicleSectionSite/Documents/IB_DLHorseStockTrailers.pdf

Excerpt from the bulletin:
“Additional questions involving medical exam certificates; specific vehicle configurations; scale or roadside inspection requirements; log books (hours-of-service and electronic logging devices); for-hire and private carrier information related to motor carrier of property permits; and display of California carrier assigned (CA) or Department of Transportation (DOT) numbers and company name or trademark may be addressed on a case-by-case basis.”

Resources for Drivers:https://www.chp.ca.gov/Programs-Services/Programs/Commercial-Vehicle-Section

CHP offers a Commercial Industry Education Program
More info here: https://www.chp.ca.gov/programs-services/programs/commercial-vehicle-section/commercial-industry-education-program

California Highway Patrol – Commercial Vehicle Section – (916) 843-3400

Federal Definition of a Class A CDL
For those interested, below is the definition for a Class A CDL from the Federal Motor Carrier Safety Administration. Most states stick close to this for the state definitions.
https://www.fmcsa.dot.gov/registration/commercial-drivers-license/drivers
“Class A: Any combination of vehicles which has a gross combination weight rating or gross combination weight of 11,794 kilograms or more (26,001 pounds or more) whichever is greater, inclusive of a towed unit(s) with a gross vehicle weight rating or gross vehicle weight of more than 4,536 kilograms (10,000 pounds) whichever is greater.”

If you would like to see changes to these state laws, we would encourage writing and calling your California state representatives and informing them of your concerns.

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