The Federal Motor Carrier Safety Administration receives exemption requests all of the time. Typically, these requests ask the agency to allow a carrier to avoid hours-of-service restrictions in certain situations or to use an alternative technology to what’s mandated.
But in November 2025, a charity asked for a different type of exemption. The group wanted their drivers to be able to operate without a CDL.
Diamond Excursions Ladies Edition, which does business as Project Gap, said it is a non-profit organization that delivers donated goods to underserved communities and areas affected by natural disasters.
In addition to the CDL exemption, the charity asked to be exempted from the ELD mandate, saying that both rules posed a “significant burden” on its ability to help communities in need.
“Our commercial motor vehicle is used exclusively for charitable purposes,” Diamond Excursions Ladies Edition Executive Director Iliana Oscar wrote in the application. “All transportation is conducted by unpaid volunteer drivers and vehicle use is strictly limited to donation collection, community distribution events and disaster relief missions. These trips are infrequent, mission-specific and carefully coordinated based on donation availability and community needs.”
Public comments
FMCSA received 81 comments in response to the exemption request. Seventy-five of the 81 comments opposed granting the CDL portion of the exemption.
Meanwhile, 12 of the commenters who opposed the CDL exemption said they supported exempting the group from the ELD mandate, which requires carriers to use an electronic logging device to track hours of service.
“This is a safety issue,” Tim Kyner wrote. “Anyone driving a commercial motor vehicle should be properly trained and licensed to operate the vehicle. It doesn’t matter how often or how far. In my opinion, it’s unsafe to allow anyone to drive a truck that doesn’t hold a valid commercial driver’s license, regardless of reason or frequency. The paper logs should be allowed. Everyone knows the HOS regulations are bull anyway.”
FMCSA’s response
In a notice that was published in the Federal Register on Friday, July 17, FMCSA said the requests fell short of the agency’s exemption requirements.
Although FMCSA provides some regulatory relief for carriers responding to emergencies, the agency determined “there was not a sufficient basis to include relief from ELD and CDL requirements in response to emergencies and natural disasters.”
FMCSA suggested that the charity consider operating in vehicles that don’t require a CDL.
“Applicants are encouraged to carefully review the regulations to determine whether there are any practical alternatives already available that would allow the applicant to conduct its motor carrier operations,” FMCSA wrote in the notice. “Project Gap did not address the alternatives that are available, including the option to use smaller CMVs that do not require a CDL and the option to use existing exceptions to the ELD requirement.” LL
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