Under current law, drivers with a commercial driver license (CDL) must obtain a hazmat endorsement to transport jet fuel. The Federal Motor Carrier Safety Administration (FMCSA) has waived the hazmat endorsement for the transportation of 1,000 gallons or less of diesel fuel. Due to the extremely similar chemical makeup of diesel and jet fuel, NAAA has submitted a petition for an amendment to have this exemption extended to jet fuel as well.

In its petition, NAAA explained that Jet A has a flashpoint of between 100 ºF and 150 ºF, and diesel has a flashpoint of between 100 ºF and 130 ºF.  Additionally, both diesel fuel and Jet A have the same autoignition temperature of 410 ºF.  The properties between diesel fuel and jet fuel are so similar that diesel engines can, and often do, run on jet fuel.

NAAA also explained that it is a costly burden for aerial application operators, almost all of them exclusively small businesses, to obtain or pay for the training of a hazardous materials endorsement for a driver who already has the knowledge and skills associated with a CDL. Difficulties also arise in finding Department of Motor Vehicle (DMV) locations and scheduling testing times to take the knowledge and skill tests required for a hazmat endorsement. Operating in rural areas, the closest DMV could be several hundred miles away.

Additionally, the retention of drivers with a CDL and hazmat endorsement is extremely hard due to the seasonal nature of aerial application work. When an individual has this much training, they are more likely to opt for consistent, non-seasonal work, leaving aerial application operations without the necessary drivers during the application season.

NAAA also explained the benefit that comes with using commercial vehicles to assist with aerial application work, explaining that commercial motor vehicle drivers are needed to operate vehicles with aircraft fuel and crop protection products to satellite airstrips nearer to the field(s) that need to be sprayed. This saves on the quantity of fuel consumed by ag aircraft and saves aircraft flight time between the loading facility and the application site. A shortage of available drivers may prevent use of a satellite airstrip closer to the application site. This results in an aircraft having to travel back to its home base for each load instead of using a closer landing area. In this case more fuel is burned to travel to the application site and more time elapses, resulting in fewer application jobs performed during the day.

Finally, NAAA explained aerial application operations typically take place in rural areas with minimal traffic and are always conducted during fair weather conditions. It was noted that in many cases, driving is done only once or twice a week to a satellite facility. These factors, combined with a driver who already has a CDL, create extremely low-risk safety conditions.