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Lance has touched the other "issue".
Commerce is the key, and yes ANYTHING or combination of ANYTHING over 10,001 pounds GVWR or GCWR is commercial, BUT no (except for possibly state requirements) no CDL required, BUT, must have a medical, logs (or 150 mile rule and time sheets), and pre/post...
I do not think there is any reference to air brakes in the fed requirement for CDL. If so please show us.
Some states have those requirements, and some just ignore the non-commercial trucks.
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