Tips for Hotels Operating Vans and Vehicles to Transport Customers to Airports and Other Destinations
Many hotels provide van and bus service for hotel guests between the hotel and airports and surrounding businesses. See the Tip Sheet on Multi-Modal Passenger Transportation for airport related information.
What Determines If Passenger Transportation is Regulated?
Generally, Federal safety regulations apply when you operate a “commercial motor vehicle” in interstate commerce. To determine whether your bus or van is a commercial motor vehicle, it is necessary to consider vehicle size, passenger capacity, and in some cases whether the operations are for-hire. If you are transporting passengers in any size vehicle interstate and for-hire, the operating authority registration and other commercial regulations also generally apply. There are specific exemptions, however, for certain operations.
Am I Conducting For-Hire Passenger Transportation?
If you transport passengers across a State line, even occasionally, and you accept any type of payment for the transportation, you are for-hire and operating in interstate commerce.
An Example of Hotel Related For-hire Passenger Transportation
Sometimes payment for transportation is not obvious. For example, a hotel transports its customers with a hotel-owned van to and from various locations. The hotel does not have a special charge for its van service, but the hotel is viewed as receiving indirect compensation for the passenger transportation because its collected fee (payment for the room and other services) is also considered payment for transportation.
Unless exempted, for-hire motor carriers transporting passengers in interstate commerce must comply with FMCSA’s commercial regulations, including operating authority registration requirements. Depending upon the nature and scope of the passenger transportation provided by a hotel, an exemption from operating authority registration for transporting passengers, who have just traveled by air or will travel by air immediately after being transported on a highway, could be utilized. See the Tip Sheet on Multi-Modal Passenger Transportation for more information about this airport related exemption. Note also that transportation of hotel customers to and from cruise ship piers and other local stations of water carriers is also exempt from the commercial regulations.
Unless excepted, motor carriers transporting passengers in commercial motor vehicles must comply with FMCSA’s safety regulations. Again, to determine whether your bus or van is a commercial motor vehicle, it is necessary to consider vehicle size, passenger capacity, and in some cases whether the operations are for-hire.
The required level of financial responsibility (insurance or other acceptable security) for for-hire, interstate passenger transportation is determined by the highest seating capacity of your vehicles. Vehicles with a seating capacity of 15 or fewer passengers (including the driver) require $1.5 million of coverage, and $5 million is required for vehicles with a seating capacity of 16 or more passengers (including the driver).
For More Information
FMCSA has a website with information about Federal regulations for passenger transportation. You can get additional assistance by:
- Calling the FMCSA Information Line at 1 (800) 832-5660
- Contacting your local FMCSA field office www.fmcsa.dot.gov/mission/field-offices
Note: Nothing in this “Tip Sheet” document affects the rights and duties of any person under applicable provisions of law and regulation. This Tip Sheet is not intended, and should not be construed, to create any right, benefit, claim or defense, whether substantive or procedural, enforceable at law by a party against the United States, its agencies, its officers, or its employees.