When the Federal CMV came into existence about 20 years ago, it slightly changed what was commercial from what it had been in the past.
The result, because of licensing requirements many FORMER CMV owners have transitioned to P/U based vehicles + GN trailers to CIRCUMVENT being labeled a "commercial" vehicle (CMV).
I was not as involved as deeply in the industry well BEFORE the CDL/CMV changes as I became after/during the change, but it was always my understanding that if you were "For Hire" you needed a DOT# and "authority", they just looked the other way most of the time. We got caught in this, I told the owner we needed to letter our units with the DOT#s, City and state but he refused. We received nice fines on each unit to show for it too!
Now that the country has grown and the CMV/CDL rules of the early '90s have affected a major shift in how vehicles are used and by whom, the sheer numbers of those operating ILLEGALLY and UNSAFELY has grown to be a big problem.
This has been discussed many times before and I of course, do not have all the answers, but I am also not a lobbyist trying to gut necessary regulation or impose undue hardships. I believe the laws should generally be as follows (I believe I have logical and reasonable justifications for each):
CMV:
1) Any vehicle owned, leased, rented, or borrowed and used to further a business enterprise operated by a person other than the registered owner or immediate family member (parent/self/child). Not limited to powered units, (specifically excludes any vehicle owned by and used soley to transport family members "not for hire").
2) Any vehicle designed or built to transport passengers having a total capacity of 9 or greater persons, or any capacity if for compensation.
3) Any "combination vehicle" used to further a business enterprise (specifically INcludes: all towing or towed units and combinations regardless of GVW or GCVW rating(s) or vehicle type).
4) Any vehicle used to transport persons who are not related to the operator to or from school or on a school related/sponsored activity except by emergency.
5) Any vehicle identified as a type of "Bus" by VIN, design, construction, intended use, actual use, outward identification or FMVSS tag.
Safety:
1) All CMVs must undergo an annual safety inspection.
2) Must conform to Apdx "G"
3) Must supply evidence of current insurance meeting statutory minimums covering all units if a combination.
4) Cannot "self inspect" unless in the business of vehicle repair (as advertised) and can only inspect vehicle types consistent with their normal business activities.
5) Inspectors must be certified both by "ASE" and the Sate/Federal program for the vehicle types and systems they inspect.
6) Re-inspection fees apply only if: a) The vehicle(s) is/are removed from the premises of the inspecting facility for longer than 7 calendar days, b) The inspection(s) from the prior year has expired before the vehicle(s) is/are re-inspected, or c) The vehicle(s) are not re-inspected at the same inspecting facility as conducted the initial inspection.
7) In a combination, each towed unit(s) must have brakes meeting "Apdx G" requirements on all installed axles in the proportional amount that exceeds the towing vehicle's GVW.
8) "GCVW" will not be considered in any weight calculation.
CDL/DL:
1) A "CDL" is required to operate any "CMV", must pass "Road Test" in vehicle type applied for.
2) A "type test" is required to operate any vehicle other than: Single unit motor vehicle having at least three but no more than 6 tires (ie: Car, pickup, van) under 10,000lbs GVW and not used to further business interests (non-CDL requirements, but type test still required as appropriate for vehicle type).
2a) Motorcycle = type test required (M + RT)
2b) Bus, regardless of capacity or intended use = (P)
2c) Medium Motor Vehicle, any single unit MV regardless of design or intended use over 10,000lbs GVW = (B), (B+Air+RT if CDL)
2d) Combination, any motor vehicle used to tow another unit where the [towing unit GVW + towed unit GVW (actual, as measured)] is greater than the [towing vehicle GCVW] or 10,000lbs whichever is LOWER = (A+Air+RT for all)
2e) RV, any motor vehicle or towed unit designed, built, registered as an "RV" (having all of: interior toilet, refrigerator, heating system not requiring the running of an internal combustion engine) = (RVA or RVB, with Air if equiped - not a "CDL" license and does not require a road test).
3) Farm = DL with all appropriate type endorsements, does NOT need to meet CDL requirements (health card, background etc if vehicle is owned by self or immediate family AND used to transport owned, rented or leased farm related materials including animals).
3a) Farm employees must comply with CDL requirements.
The general theory of the above is: If you are operating a vehicle IN COMMERCE, you need the appropriate CDL. If you are driving something you are not trained on (non automobile), you need some basic knowledge on it. Whatever you are driving in commerce needs to be SAFE enough to operate. If you are a farmer, we won't break you, but relaxed rules apply to you as well.
