Sorry about the confusion over the reg number. I was quoting from the INTERPRETATION page of reg 383.91 and at the top of THAT page, the actual reg # isn't listed. I mistakenly referenced the reg # that is SHOWING, which is actually the LINK to the previous reg.
I most certainly DO understand both GVWR and GCVWR. I also understand that the reg makes a distinction in class of CDL based on whether the "unit" being towed (either by tow truck OR bobtail) has a GVWR of 10,000 lbs or more, and that if it DOESN'T.... or if it is not THERE.... then the power unit requires ONLY a Class B providing IT has a GVWR of 26.001 lbs or more.... OR if it carries passengers or Hazmat.
If you look at the first 2 SUBsections of reg 383.91...
This is the ONLY section that mentions GCVWR, and it clearly means a COMBINATION of vehicles. A bobtail is NOT a combination. It ALSO sets the GVWR requirement for the trailer or "towed unit." IF said unit is rated LESS than 10,000 lbs (or by definition is not even THERE).... then it falls under the NEXT section.a)(1) Combination vehicle (Group A)—Any combination of vehicles with a gross combination weight rating (GCWR) of 11,794 kilograms or more (26,001 pounds or more) provided the GVWR of the vehicle(s) being towed is in excess of 4,536 kilograms (10,000 pounds).
This section would cover a bobtail truck with a GVWR of 26.001 lbs or more as well as a tow truck as discussed in the interpretations of this reg. It obviously also applies to most "straight trucks." It would also probably apply to a bobtail towing a POV.(a)(2) Heavy Straight Vehicle (Group B)—Any single vehicle with a GVWR of 11,794 kilograms or more (26,001 pounds or more), or any such vehicle towing a vehicle not in excess of 4,536 kilograms (10,000 pounds) GVWR.
I used the question about tow trucks for purpose of illustration (as it is a SINGLE vehicle - like a bobtail - until it picks up a tow) AND because the regs state that:
Gross COMBINED vehicle weight rating does not apply to a single unit that is NOT operated as part of a combination.For CDL purposes, the tow truck and its towed vehicle are treated the same as any other powered unit towing a non-powered unit.
Though a tow truck (like a bobtail) is clearly DESIGNED to tow non powered units, (usually with a GVWR of their own over 26,001 lbs,) the regs clearly state that only a CDL-B is required if it is NOT towing a unit with a GVWR of 10,000 lbs or more.... or NONE at all.
[ or migrant workers! ]![]()





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