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Like many agricultural supply chain partners, custom farmers struggle to find qualified CDL drivers. This is an ongoing problem that has been exacerbated by the pandemic and increased demand for drivers. Two years ago, during Dairy Day at the Capitol, WCO members discussed this issue with their elected leaders. Fast forward to today, with the pandemic hopefully in the rearview, WCO is working with fellow ag groups to address ongoing CDL challenges.

One potential solution would be to expand the existing Farm Service CDL
(F endorsement) to make it more useful to custom operators, cooperatives, farmers, and other agricultural supply chain partners. 

In full disclosure, making any changes could be a challenge. First because many of the current parameters are federalized, meaning we can’t easily change them, and second, because agribusiness partners are hesitant to disrupt something that is currently meeting their needs. To read more about the Farm Service CDL, google “WI Farm Service CDL”.

The Farm Service CDL is available for seasonal employees in various farm service sectors. It is currently underutilized and at times discouraged as a CDL option for custom operators because the current parameters do not fit the realities of custom work. However, ‘custom harvester’ is one of the user categories.

There are three aspects of the Farm Service CDL, that if broadened, could bring more drivers into the farm service industry, increase public safety, and improve efficiency and sustainability for Wisconsin farms. 

Time frame:

A Farm Service CDL is available for employees who work 180 days or less in a farm service industry. The recent federal bipartisan infrastructure package increased this to 210 days. The days can be divided into two separate time frames with two separate applications. Even with the extension, this time frame is prohibitive because the cropping season exceeds the 180 day calendar (or 210 days with the extension). Some users cannot break up the calendar days because they provide services throughout the summer.   
A seasonal employee should be defined by the demands of the season. WCO would favor a time frame that covers a complete and continuous season.

Definition of ‘custom harvester’: 

Farm Service CDL language describes custom harvesters as “a business that is engaged solely in the provision of for-hire harvesting services to farmers”. The word ‘solely’ suggests that a custom harvester may not engage in any other business. Given the seasonality of harvesting, many custom operators have secondary businesses. WCO suggests removing the word ‘solely’.

The term ‘custom harvester’ implies harvesting crops and excludes custom manure applicators, who are a very important part of Wisconsin agriculture, and who operate similar CMVs, during similar seasons. WCO suggests changing the term to ‘custom operator’.

Liquid fertilizer gallon limit:

Transport of hazardous materials is allowed with a Farm Service CDL, however the 3,000 gallons limit for liquid fertilizer excludes custom manure hauling because most tanker CMVs used to haul liquid manure are upwards of 7,000 gallons. The current limit is based on the federal Pipeline and Hazardous Material Agency’s rules restricting farm liquid fertilizers on a IOH transport to 3,000 gallons.

Amending the current Farm Service CDL parameters to be inclusive of modern agricultural best practice will encourage more custom operators and farm service providers to use this classification of CDL.

While a Farm Service CDL gives the driver the ability to operate Class B CMVs, it restricts drivers from operating a Class A (tractor/trailer combination) CMV. In addition, there is a 150-mile distance-to-farm requirement. 

More drivers with a Farm Service CDL will not increase competition for Class A CDL drivers; it will bring more talent to the agriculture profession, improve public safety, decrease road damage and increase efficiency. It could also act as a pipeline for additional Class A CDL drivers.

As previously mentioned, we haven’t gotten overly optimistic feedback from trade groups who represent other users of the Farm Service CDL, but we still think there is a case to be made for these changes and legislators who would be willing to look into it. 

During the legislative recess, we will continue to explore this and other solutions for WCO members struggling to find sufficient CDL drivers.