Kentucky Division of Driver Licensing/CDL Management - Comments

In reviewing FMCSA’s CLP requirements KY feels we are ahead of FMCSA on the security and fraud issue. Our CLP is more secure now than it will be under FMCSA’s new ruling. Kentucky’s CLPs are laminated and includes a photo and signature. Because both documents (base license and CLP) have a photo and signature it is much easier to validate that the CLP and the base license holder are one and the same. That fact alone helps minimize fraud vulnerabilities. Kentucky will have to take several steps backward, if FMCSA’s Final Ruling for issuing the CLP remains as it is. The front of our CLP specifies that it is a CDL permit therefore; Kentucky doesn’t understand how the CLP can be confused with a CDL license (reference to “one driver/one license” regulation) or how another person other than the driver whose photo and signature is on the document could use the CLP without detection? The photo and signature alone would identify ownership of the document and alert clerks, law enforcement, etc… of possible fraudulent activity. Also, now that FMSCA is requiring states to record CLPs in CDLIS it should alleviate the problem of drivers holding a CLP and using it for other purposes. Another issue KY wishes FMCSA would consider is the thousands of dollars that will be spent modifying our CLP computer programs when the end result will leave us more vulnerable. This final ruling is a costly setback for Kentucky. Kentucky disagrees with FMCSA on this issue and requests reconsideration.