[Archived]

Capt,

I am not a lawyer or DOT expert but based on some past research on the topic to be legal I do believe you will need to have DOT numbers and follow DOT procedures for the For Hire vehicle.

couple of questions:

Is the driver of the bus an employee of yours? or someones?

How is the Bus titled and licensed?

The Branding on the side is likely going to be a red flag… IMHO you wont’ have much ground saying your private not for hire when you have sponsors logos on the BUS and crew of PAX on board…

Definately worth checking out for sure….

Good Luck

Bill

[Archived]

Captain……Your intent is to use the coach for commercial purposes. It is as much a business tool as any other equipment you use in your business. But Bill has cited a lot of circumstances that come into play regarding licensing.

I am not a lawyer and the final answer might not come from a lawyer but from the police that regulate commercial vehicles. On a couple of occasions I have called the police at the local “scale house” with questions regarding proper licensing of me or one of my vehicles. These are the guys that are going to write the ticket and are very familiar with the laws in your state.

Our coaches are based on commercial vehicles, but as motorhome conversions they are owned and used personally. So we are exempt from the requirements of commercial licensing of the vehicle, but our driver license has to comply with state laws for our type vehicle. Some states allow us to drive with a regular driver license, others require a non-commercial Class B driver license.

Entertainer coaches, unlike motorhomes or seated coaches, are in a gray area. If it is owned by your company it is tough to not get a commercial registration, if it is owned by you personally and you call it a motorhome you will have no trouble getting a non-commercial license. But then if you get stopped by the police for any reason you might have a hard time convincing him you aren’t skirting the law. We used two of our coaches for commercial use in that we went to a lot of trade shows with the booth set-up in the bay of the bus. But the coach was personally owned, was clearly a motorhome with sleeping for two, and had nothing to indicate it was for other than personal use.

Your coach has bunks, is likely to look like an entertainer coach (no awnings, 5 or more roof airs, not towing a car, and a floor plan typical of an entertainer). That puts you into a gray area and you need to define how it will be titled and registered (presonal or company), and then check with your local DMV, with probably the best advice coming from the cops at the scales. Your insurance company may be part of this question also, so make sure they are aware of how you use the coach also.

Sounds like you are part 135 and want to play by part 91 rules. (That’s pilot talk)

[Corey]

Paul,

Once you cross the line from Private Motorhome to Commercial status, you have a whole new hosts of rules, liability exposure and regulations. Your driver (with Chauffeur License) now has to comply with DOT rules and regulations pertaining to hours of service, medical, etc. and your bus is also subject to all DOT rules as well. A big problem for you will be Insurance as a Commercial Entity. Yes, you will have to have a DOT number and that will require all of the above.

By your description of what you are doing, you are a Commercial entity.

[Jim]

Paul,

The first question that needs to be answered is about the branding on the outside. At first, this would seem to mean the bus is being used in support of whatever commercial business you are in. This might not be the case. There are times when commercial sponsors jump on the bandwagon of a personal and non commercial venture. The litmus test to this case is simple; are you getting paid by anyone in support of your venture?

If you are non-commercial you have to make sure your bus is not owned by a company and is registered as a motorhome. This one is a fine line many with Montana and South Dakota registrations should be concerned with. These tax-free states often require you to establish a business in those states and register your motorhome to your company. I’ve spoken to NM and VA state police about this and both say they generally look the other way. That’s fine until something bad happens. If you got into an accident the other driver may come after you.

FWIW, I have “Private Coach” decals on the front left and right sides of my coach. These aren’t necessary, but may help at toll booths and to alert law enforcement that you’re not commercial. When you’re towing a car it is sometimes hard to see what kind of tag you’re running.

I am not an attorney or work for the DoT.

[Mike & Brigitte]

I recently pulled into a Casino Parking lot near a number of seated charter coaches on a weekend. I noticed shortly after pulling in that there were 6 DOT dudes with their official hats and windbreakers trolling the parking lot in and out of the seated coachs. It was about two minutes after stopping I saw two of the dudes heading my way and about 15 paces out they stopped, paused, and made a U turn away from me. Obviously they saw I was a private coach and let me be.

Having read your post – I am glad I wasn’t hassled by the govment men, and I am glad I didn’t have any logos or banners strapped on the side of the bus to encourage them to hassle me.

[Bill]

The DOT guys saw that bumper sticker on the back of the King’s Liberty, “You can’t hide money!”

[Roger]

When we had our first coach there weren’t many that were motorhomes. We were in the VF outlet mall in Reading PA and the management had us park with the commercial buses. In a way that was a good deal because I had a special coupon book and a ticket for access to the driver’s lounge and free refreshments.

Anyway we were just getting ready to shop when two DOT folks knocked on the door and asked me for my papers. I had no clue what that meant and they got snippy explaining insurance, and others relating to my charter. I told them I wasn’t chartered and it was my motorhome. When they poked their head in and saw the living room and my wife, daughter and son-in-law drinking coffee they excused themselves and bothered someone else. I had Private Coach plaques on both sides, one right next to the door and they ignored them.

In today’s economy with every government agency hungry for money I don’t think it would be worth the risk of running a commercial coach as a private owned coach.