The Driver and Vehicle Standards Agency (DVSA) Consultation

The Department for Transport (DfT)

The Driver and Vehicle Standards Agency (DVSA) Consultation

Allowing learner drivers to take lessons on motorways

Response from:

The Approved Driving Instructors National Joint Council (ADINJC)

16 Grosvenor Close, Lichfield, Staffordshire, WS14 9SR

01543 256578 www.adinjc.org.uk

Email:

February 2016

We are members of The National Associations Strategic Partnership (NASP) and fully support their collective statement. This document expands on that statement to include the views of ADINJC members.

WHO ADINJC REPRESENTS

The ADINJC is a national association of driving instructors formed in 1973 and currently has approximately 7,500 members nationwide in local associations and groups. These members are DVSA approved driving instructors and potential driving instructors. We also have members who are motorcycle instructors and LGV instructors.

GATHERING ADINJC VIEWS

We sent details of the consultation to members via our monthly newsletter and as email news flashes. We have sent details to our 55 member groups and local associations and have collated the responses. Members hold local association meetings where they gather views and the consultation was also discussed on our social media sites.

PUBLICATION OF ADINJC COMMENTS

We give approval for our response to this consultation to be published.

QUESTIONS WE HAVE ANSWERED

We have responded to all the questions raised in the consultation.

CONSULTATION QUESTIONS

1.  Do you think that learner drivers should be allowed to take lessons on motorways, subject to certain safeguards?

Yes

The positives we see are that it will:

·  Widen the learners experience and the new skills will transfer well into other driving environments

·  It is an introduction to all types of road pre-test

·  New drivers will be better prepared for motorway driving

·  New drivers will use motorways in preference to the statistically more
dangerous rural roads

2.  Do you think that lessons on motorways should be optional for learner drivers?

Yes

However, we believe that where motorways are within a reasonable distance of the learners base they should be actively encouraged to drive on them. We are aware that some learners in parts of Scotland, for example, may have to travel for 200 miles to reach a motorway. For this reason it has to be optional.

3.  Do you think that motorway lessons for learner drivers should only be provided by a fully qualified approved driving instructor?

Yes

4.  Do you agree that trainee driving instructors (potential driving instructors) should not be allowed to provide learner driver motorway lessons?

Yes

However this question raised many issues from our members, and a minority were against it.

Most who agreed appeared to be reflecting on how they would have felt at that stage of their training whilst on a pink licence. Answers are not evidence based. Others considered that it would be discrimination not to allow trainee driving instructors to take learners on motorways. Some stated there was no justifiable evidence as to why they shouldn’t be allowed to train learners on a motorway and that they need to practice all aspects of their job. One of our members currently working in Sweden knows of no evidence to suggest that trainee instructors teaching on motorways cause any issue at all on motorways in other European countries.

If the qualification process to becoming an ADI and the trainee licence are both improved then more members would consider it being allowed for trainees.

It may be worth noting that some members thought this question was badly worded.

5.  If you are an ADI, do you feel that the current training and testing system provides sufficient grounding for you to provide pre-test motorway lessons? If not, where should it be strengthened?

Yes

Members believe that experienced ADIs should be able to deliver motorway tuition. Most teach dual carriageways regularly so see this as a natural extension. The current ADI qualification process doesn’t include motorways other than as a theory element or in some areas of the country it can be included on the Part 2 driving ability examination. Possible future changes to the Part 3 could improve this area.

6.  Are there any specific issues you think should be included in guidance to ADIs?

Yes

We support the advice being prepared by NASP and have contributed to it. NASP are the National Associations Strategic Partnership. Whilst many members are confident as regards their knowledge concerning motorways we have been made aware by members that they would like guidelines to refer to and see it as part of their CPD. They recognise that motorways are changing.

7.  Do you agree that ADIs should exercise their discretion in providing a motorway lesson to a learner driver with whom they have had no previous contact?

Yes

ADIs would not take a learner onto a motorway unless they believe they are at a suitable stage of their learning. An ADI would make a practical assessment of the driver’s ability judged against the competencies required for safe motorway tuition on appropriate road types before entering a motorway.

8.  Do you agree that learner driver motorway lessons must only take place in a car where the accompanyingADIhas a dual control brake (and clutch in manual vehicles)?

Yes

We would suggest that in the interest of road safety, learners on motorways must be in dual controlled vehicles as an ADI is experienced and competent in their correct use and an accompanying driver hiring a dual controlled vehicle, may not be.

9.  If people learning to drive in specially adapted vehicles wish to take motorway lessons, should those vehicles be fitted with dual controls? If yes, should this be advisory or mandatory?

The majority of the answers we have received have stated YES and Mandatory to this question. Specially adapted driving school vehicles are fitted with dual controls and the ADIs who train learners in these vehicles are usually specially trained ADIs. If a learner is having lessons in a specially adapted driving school car without dual control(s) they should not be allowed on the motorway.

However we have members who teach disabled motorists in their own adapted vehicles and we have a working relationship with Disabled Motoring UK (DM UK). In reality we don’t feel all our members have sufficient expertise in this area to answer this question. Many respondents have stated that it should be answered by those who regularly deal with these types of learners.

The comment from Graham Footer CEO at DM UK is below:

“We feel that allowing learner drivers to experience motorway driving as part of their driver training would be a good thing. We feel it is important to give learner drivers experience of driving on all types of roads if possible so they can gain some experience with a qualified ADI next to them who can talk them through the road layout, signage, driving techniques etc., in a safe way and be there in the car with them in case they are needed, but also to help the learner have more confidence of driving on the motorway network”. DM UK has stated they will also make their own response to this consultation.

Our understanding from some of our ADIs who teach disabled motorists is that a provisional licence holder that becomes eligible for Motability will get the vehicle equipped with duals, as well as their adaptations.

10.  Do you agree that motorway lessons for learner drivers who are provisional licence holders should only be permitted in motor cars?

Yes

We feel this would be the safest option and that it would not be appropriate to allow learner motorcyclists to ride on motorways as they cannot be accompanied in the same way that learner drivers are. Members commented that they didn’t understand this question and which groups it referred to. We have taken it as meaning motorcycles.

11.  Do you agree that there is an increased risk using a top box on a motorway lesson and they should therefore be removed?

We have reservations regarding this matter. A high number of our members disagreed with this question and stated that they regularly use top boxes on national speed limit road dual carriageways without problem. Indeed, many test centres use these roads on test on a daily basis. We had very little anecdotal evidence of members having lost top boxes.

If they are not safe at motorway speeds then they are not safe for us on dual carriageways either.
We suggest manufacturers are consulted properly before any decision is made: this answer should not be based just on the perceptions of instructors. Some designs for top boxes may be safer than others.

ADINJC have consulted with 3 suppliers of top boxes and they would not guarantee they would stay on at 70mph. High winds, ice, hot temperatures and wear and tear can all make the roof box unsafe at times. Whilst we would recommend roof boxes are changed every 4-5 years some are much older and not well looked after.

If only L plates are used, these must be securely fastened to the vehicle as some magnetic Ls blow off at speeds lower than 70 mph.

However we do feel it is vital that the learner can be seen and identified and a top box would seem the best way to do this.

12.  Do you have any comments on the potential impact of the proposal to allow learner drivers to take lessons on motorways? If yes, please specify who you consider will be affected and provide examples of any costs where applicable.

We consider it could have an impact for the ADI if there is an accident where the motorway is closed or the lesson is held up for any length of time. Members have commented that clients could be late for work, appointments and this is all stressful.

If an accident is caused we believe the cost of a serious injury is £1,500,000 and a fatality is £1,900,000.

Signs at the start of the motorway will need changing at a cost, as will the Highway Code.

Additional mileage on the ADIs car

IN CONCLUSION

We welcome the introduction of learner drivers on motorways with an ADI and in a dual controlled car. ADINJC has been part of a campaign for this change for many years.