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For a USDOT or state exemption registered commercial carrier, any driver - whether they're driving interstate or intrastate, MUST possess the appropriate class of CDL. The only exception for this are vehicles which are exempt from CDL licencing requirements, to include recreational vehicles, firefighting and first response vehicles, military vehicles when operated by military personnel, and registered farm vehicles. In those instances, the state of residence maintains jurisdiction of licencing requirements for those types of vehicles.

The FMCSR is very clear in stating that, if you do not possess a CDL or a CDL permit (while supervised by a fully licenced driver), you're not, at any point, supposed to be in any sort of actual physical control of that vehicle.

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Q: Can tractor semitrailer combination truck vehicles ever be operated on roads without a Commercial driver license?
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