1.2 Knowledge Test, Skills Test, and ELDT
Key Takeaways
- 49 CFR 383.117(a) requires Passenger knowledge of loading/unloading; emergency exits including push-out windows; fires and unruly passengers; railroad-highway grade crossings and drawbridges; proper braking; and other operating practices.
- 49 CFR 383.117(b) requires a skills test in a passenger vehicle of that vehicle group — P is not a knowledge-only endorsement.
- First-time P applicants on or after February 7, 2022 must complete ELDT passenger curriculum (49 CFR Part 380 Appendix C) with a Training Provider Registry provider before the P skills test; ELDT is not retroactive for P issued before that date.
- ELDT theory has no required hour minimum but must cover all Appendix C units; behind-the-wheel training must demonstrate proficiency in a passenger vehicle of the same group.
- A CLP holder with P may not carry the public — only Federal/state auditors and inspectors, test examiners, other trainees, and the accompanying CDL holder (49 CFR 383.25).
Knowledge Test, Skills Test, and ELDT for the P Endorsement
Quick answer: Earn P by passing the Passenger knowledge test on the topics in 49 CFR 383.117(a), completing Entry-Level Driver Training (ELDT) passenger curriculum with a provider on FMCSA's Training Provider Registry if you are a first-time P applicant on or after February 7, 2022, then passing a skills test in a passenger vehicle of that vehicle group (383.117(b)). A commercial learner's permit (CLP) with P does not authorize carrying the public.
Walk the gates in order. Skipping ELDT, treating the CLP as a learner transit route, or showing up for a skills test in the wrong size bus is how applicants stall at the window. Medical certification, state application steps, fees, and retest waits sit beside these federal gates and are state-controlled.
Gate 1: Passenger knowledge (49 CFR 383.117(a))
All P applicants must have knowledge covering the following topics. State manuals usually place them in Section 4 — Transporting Passengers Safely, with backing from Section 2 — Driving Safely:
- Proper procedures for loading and unloading passengers — curb-side discharge when you can, riders clear of the stepwell before you move, standee limits, and not rolling with someone hanging in the doorway.
- Proper use of emergency exits, including push-out windows — every exit must work, stay unobstructed by luggage or coolers, and be something you can explain on a pre-trip.
- Proper responses to fires and unruly passengers — evacuate when the bus itself is the hazard; do not put a drunk or disruptive rider out in an unsafe place (dark shoulder, isolated stop) when a safer scheduled stop exists.
- Proper procedures at railroad-highway grade crossings and drawbridges — passenger CMVs have specific stop, look, listen, and no-shift-on-the-tracks rules; wait until a drawbridge is fully closed and locked before crossing.
- Proper braking procedures — smooth passenger stops, downhill control, and air-brake discipline if the bus is so equipped.
- Operating practices not otherwise specified — mirror use, backing with a spotter when possible, and handling a tall, long passenger CMV in traffic.
The state writes items from the federal/AAMVA pool. Passing is still at least 80% under 383.135. Exact length and time remain state-specific, as Section 1.1 explained.
Gate 2: CLP with P — who may ride (49 CFR 383.25)
After you pass the required knowledge tests, the state may issue a CLP with a class-specific P. 49 CFR 383.25 is strict:
A CLP holder with P is prohibited from operating a CMV carrying passengers other than:
- Federal or state auditors and inspectors
- Test examiners
- Other trainees
- The accompanying CDL holder required by 383.25(a)(1)
That list is exhaustive for federal purposes. Paying customers, charter groups, deadhead “friends and family” loads, and school pupils are not on it. The accompanying CDL holder must have the proper class and endorsements and occupy a seat close enough to take control. The P on a CLP is for supervised practice in a passenger vehicle empty of the public — not for revenue service and not for “just a few riders to make the practice useful.”
Federally, a CLP holder is also not eligible to take the CDL skills test in the first 14 days after initial CLP issuance. Some states impose a longer wait. H cannot be placed on a CLP. Do not analogize tank or hazmat CLP rules onto P: P on a CLP is real, but the allowed passenger list is tiny.
Gate 3: ELDT passenger curriculum (49 CFR Part 380, Appendix C)
For a driver obtaining P for the first time on or after February 7, 2022, ELDT is mandatory before the P skills test.
| ELDT element | Federal rule | What it is not |
|---|---|---|
| Who is covered | First-time P on or after February 7, 2022 | Not retroactive for a P already issued before that date |
| Provider | Listed on FMCSA's Training Provider Registry (TPR) | A random video playlist or unregistered school |
| Theory | No required hour minimum, but every unit in Appendix C must be covered | A short orientation that skips units |
| Behind the wheel (BTW) | Demonstrate proficiency in a passenger vehicle of the same group | Hours-only ride-alongs that never show proficiency |
| Sequence | Finish ELDT before the P skills test | Taking the road test first and training later |
| Theory assessment vs. state test | Provider theory assessment is separate | It does not replace the state P knowledge test |
Appendix C theory tracks passenger work: inspection, basic control, backing, passenger safety, loading, emergency equipment and exits, railroad crossings, and related CMV skills. Because there is no federal hour floor, a prepared student can finish theory faster than a weak one — but the provider must still certify that all units and BTW proficiency were completed and reported electronically.
If you already held P before February 7, 2022, the passenger ELDT mandate is not retroactive for that already-issued P. Upgrading class or adding S can trigger other ELDT appendices. Check FMCSA applicability for your exact path; do not assume “I drove a bus in 2019” covers a first-time P in 2026.
Gate 4: Skills test in a passenger vehicle of that group (383.117(b))
To obtain a P endorsement applicable to a specific vehicle class, you must take the skills test in a passenger vehicle that satisfies that vehicle group under 383.91. A Class B transit-bus test does not authorize Class A passenger combinations. Testing in a small Class C passenger vehicle can later produce an N restriction (no Class A or B passenger CMV). Testing a Class A driver in a Class B bus can produce an M restriction (no Class A passenger CMV). Chapter 7 covers those codes in full; choose the test vehicle for the job you actually want.
The skills test is the standard CDL three-part exam — pre-trip, basic control, and on-road — in a bus or other passenger CMV, including passenger-specific items such as emergency exits and passenger-door operation.
Medical certification, fees, air brakes, and state paperwork
Federal physical-qualification rules still apply: a valid medical examiner's certificate and the state's CDL self-certification for the type of commerce you will drive. Application forms, knowledge-test fees, skills-test fees, and retest waiting periods are state-controlled. Do not copy another state's price list or assume a failed knowledge test can be repeated the same afternoon everywhere.
If the bus has air brakes, complete Section 5 knowledge and take the skills test in an air-brake passenger vehicle. Failing the air-brake knowledge test, or testing in a vehicle without air brakes, can produce an L restriction (no air-brake-equipped CMV). Most transit and coach fleets are air-brake buses; an L restriction is a career problem, not a paperwork footnote.
Recommended sequence for a first-time 2026 applicant:
- Get medically certified and start the state CDL/CLP application.
- Pass general knowledge (and air brakes / combination tests if your class needs them) plus the P knowledge topics in 383.117(a).
- Receive a CLP with P and practice only with the allowed occupants.
- Complete Appendix C ELDT with a TPR provider.
- After the federal 14-day CLP wait (or the state's longer wait), pass the P skills test in a passenger vehicle of the group you need.
- Let the state issue the CDL with P — then, and only then, carry the public.
A first-time applicant who wants a Passenger (P) endorsement on or after February 7, 2022 must complete ELDT passenger curriculum. When must that training be finished?
Under 49 CFR 383.25, a CLP holder with a P endorsement may carry which passengers?
49 CFR 383.117(a) requires Passenger knowledge covering which set of topics?