Memorandum by The Motor Schools Association
of Great Britain (TEA 06)
1.1 The Motor Schools Association of Great
Britain (MSA) is pleased to respond to the invitation from The
Transport Sub-committee of the Environment. Transport and Regional
Affairs Select Committee to provide comments for the inquiry into
the administration and expenditure of those Executive Agencies
of the Department of the Environment, Transport and the Regions
which relate to transport.
1.2 The MSA is the national trade association
for driving instructors and schools founded in 1935. Members of
the association are in the main Driving Standards Agency Approved
Driving Instructors (ADI) following our merger with the Institute
of Large Goods Vehicle Driving Instructors (ILGVDI), earlier this
year, we also represent their interests together with those of
a small number of bus/coach instructors and motorcycle instructors.
2. GENERAL COMMENTS
2.1 We have been asked to give our views
on the parts of the enquiry relevant to the association, particularly
the Driving Standards Agency (DSA). However, under section 15
we make some brief points about the work carried out by the Vehicle
2.2 In order to collect as wide a range
of views as possible before submitting the association's views
to the committee, we have invited all MSA members to contribute,
in writing, details of their best and worst experiences with the
DSA over the past twelve months, Members of the association's
Board of Management have also consulted members through regional
meetings and the association's network of branches and associated
local ADI groups. (Throughout this submission we have placed edited
quotes "in italics" that we have received from MSA members.
Where they have requested anonymity, we have given only their
general location. We have reproduced only a representative sample
of the material received).
3. DSA AT ITS
3.1 Almost without exception, the views
we have received from members about their best experiences of
dealing with the DSA concern the co-operative and friendly attitude
displayed by all levels of staff within the DSA. In particular,
they stressed the helpful attitude displayed by staff at the practical
driving test booking call centre. The ADI section based at the
DSA HQ in Nottingham and by examining staff at all levels.
3.1.1 "Booking staff always cheerful
and helpful in the face of farcical new computer system."
Jane Simpson, Wickham Market.
3.1.2 "When I was going through
the qualifying process to become an ADI I was beset by all sorts
of problems in my personal life and in my relationship with my
trainer. The ADI section was always helpful, compassionate an
efficient," ADI Greater Manchester.
3.1.3 "Examiners at Sevenoaks and
Tunbridge Wells very helpful, courteous and considerate. They
do an excellent job of assuring nervous pupils." Michael
Bassett, Tunbridge Wells.
3.1.4 "I was impressed by the speed
that DSA's Technical Standards Branch, responded to queries about
the use of an unsuitable road on a driving test route."
John Lomas, Blackburn.
DSA CALL CENTRES
4.1 In order to book a practical or theoretical
driving test by telephone, callers have to ring one national telephone
number. We recently carried out a mystery shopper exercise on
the DSA booking system and wanted to make fifteen calls to the
4.2 According to DSA service standards95
per cent of calls to booking offices will access the call handling
system without receiving an engaged tone. We did not receive the
engaged tone once whilst carrying out this exercise. However,
on two occasions we received BT announcements and failed to make
a connection and on a further three occasions we were cut off
whilst connected to the DSA call handling system and before we
could speak to an operator.
4.3 The DSA therefore fulfilled their service
standard of 95 per cent of calls connected without receiving an
engaged tone. However, we were only successful in reaching an
operator with 75 per cent of our calls!
4.4 The length of time taken to navigate
through the call handling system to reach an operator is, we believe,
unacceptable. The average time of five attempts to contact a theory
test booking clerk was one minute 19 seconds. Whilst there is
a fast track route through the call handling system it often does
not work properly and it is easy to press one wrong number and
have to redial.
4.4.1 "Could not DSA have their
telephone answered by a human being?" ADI South Staffordshire.
4.5 Because of difficulties with the DSA
computer system, discussed below, some members have experienced
extremely long telephone calls with the DSA booking service, this
invoices very high telephone charges because the DSA booking number
is an 0870 telephone number. This means that all calls are charged
at national rate and the DSA receive a commission on call charges.
It is therefore in the financial interest of DSA to extend the
length of calls in order to increase their revenue.
4.6 The MSA objected to this system when
it was introduced and continues to be against it. We believe that
the booking service should be contacted by an 0800 freephone number
or at the least by a 0345 local rate number. We believe this might
encourage the DSA to improve their response speeds and at the
least would stop them profiting from their own inefficiency.
4.7 We request the Select Committee to recommend
the scrapping of the national number for driving test bookings.
Replacement of that number with separate 0800 freephone numbers
for theory and practical test bookings. Together with the replacement
of the call handling system with a human response system.
DSA CALL CENTRES
5.1 The DSA also run a fax application service,
the number is of course a profit making 0870 number. However,
it seems that even this piece of technology defeats them as shown
in this letter sent by an ADI to DSA Customer Services at Newcastle
in July. To date the writer has not received an acknowledgement
or a reply.
5.1.1 Please find enclosed a fax journal
as proof of a fax transmission sent to your booking office on
12 July 2000.
This is the third fax I have sent this year,
which the bookings office has no record of receiving.
I have on each occasion had to call the bookings
to confirm receipt and had to be put through to a supervisor who
demanded proof of the fax. Each time I do this, it costs me time
and money. The last call on 17th July lasted 15 minutes at peak
I would like you to investigate why it is
possible for a fax confirmed as sent not be received by you. I
and many other DIs have little faith in this system; there is
no point in sending a fax if your office denies receipt. I also
have little time to hang on the phone waiting for an answer. It
is to both our benefits that the fax application system is working
efficiently and I can think of no reason why this should not be.
Please confirm receipt of this letter and
advise me of what action you intend to take to ensure this does
not happen again. Jamie Waddell, Exmouth.
5.2 We request the Select Committee to recommend
the scrapping of the national number for driving test bookings
by facsimile transmission. Replacement of that number with a 0800
free phone number. Further, to recommend that DSA instigate an
efficient fax handling service.
6. DSA DRIVING
6.1 The DSA prior to the launch of their
new Driving Test Control System in 1999, (it was due to have been
launched in 1998) made much of the benefits that it would bring
in increased efficiency, improved call times and better deployment
of staff. It is unlikely that any organisation has ever been proved
more wrong in their pre-launch statements.
6.2 We offer some extracts from DSA Press
Release 54/97 issued 26 September 1997 and titled Driving Test
Administration Goes High Tech along with comments received from
6.3 "a new practical driving
test booking system which will offer a range of better service
facilities for customers". One of the "better service
facilities" was supposed to be an ability to prevent the
situation where an ADI had two pupils booked at the same time.
As this extract from a letter to the DSA Chief Executive sent
on 26 September 2000 shows this is clearly not the case.
6.3.1 Re: Driving Test Booking System
and the case of Mrs R.
Mrs R passed her theory test, and having
done so was given a practical driving test application form. Without
reference to me she telephoned and booked a practical test. Because
she had not spoken to me first she did not give the booking clerk
my ADI number which could (may be) prevent a double booking problem.
In order that a double booking could not arise, I telephoned the
booking section to insert my ADI number into her application.
However, I was told that although the computer would accept my
ADI number on her application, it would make no difference to
the double booking problem.
I find it inconceivable that the DSA has
a system that will not accept such a procedure. I would have thought
that this would have been one of the functions that would have
received priority when the computer system was being designed.
This means that an ADI who inherits a pupil
who has already booked a practical test with another ADI, cannot
have that test date protected by the system which should prevent
I look forward to hearing your views on this
matter. Rod Came, East GrinsteadAs at 6 November 2000
Mr Came had not received a reply to his letter.
6.4 It might be thought that another of
the "better service facilities" would be a proper back
up system in case of problems. This following comment would suggest
that this is clearly not the case.
6.4.1 It appears that on 11 July the
Test Booking Computer "crashed" so that all the applications
processed on that day were lost.
It was not until three weeks later that I
became aware of this. A pupil wanted to change her driving test
appointment only to discover that there was no record of the date.
There was, however, an entry showing that there had been an attempt
to book a test.
I am now aware of 12 similar cases. These
tests were re-booked for dates 11 to 12 weeks after the original
When I telephoned, the customer services
section, after some tests had been rebooked, they claimed to be
unaware of the situation.
This situation led to a disruption for candidates
planning up to their driving tests. Colin Lilly, Western-super-Mare.
6.5 "The new system should result
in a great improvement in the service we can offer our practical
test customers when they contact any of our booking offices to
arrange a test," said DSA Chief Executive Bernard Hardan.
"Due to be operational by late 1998 customer calls will be
shorter, so reducing their phone bills." One could reasonably
assume that "a great improvement in the service" might
include an efficient method of passing information from the booking
centre to the local Driving Test Centre. As this report from a
driving instructor shows this is clearly not the case.
6.5.1 My pupil applied for her practical
test, telling the booking clerk about her problem with dyslexia.
I also informed the senior examiner at the local centre, he said
he would be informed officially beforehand.
The day of the test came, her examiner knew
nothing about giving her hand directions as the senior examiner
had indicated would happen. My pupil, who could not tell left
from right, failed. A week later the senior examiner spoke to
me and said that he was off work ill and the examiner had not
been informed of her special needs. ADI, Leicestershire.
6.6 It might also be the case that "a
great improvement in the service" might mean that system
would not book more tests than there were appointments available.
As this report from a driving instructor shows this is also clearly
not the case.
6.6.1 My worst experience with the DSA
in the last 12 months has been when a candidate had a test booking
for an a.m. test to be telephoned on the morning of the test by
someone at the Newcastle booking office to say that the test had
been cancelled because there was an examiner ill.
This was one and a half hours before the
test was due. On investigation at the test centre it transpired
that it was an overbooking problem not an examiner ill.
Then no test was available until three weeks
later. The parent of the candidate who was extremely annoyed,
spoke to the Newcastle office, and managed to rebook the test
for two days later but only after creating a stink! Karl Satloka,
6.7 The Technical specifications that were
attached to the press release stated"The system will
be configured ready for connection to the Internet." Two
years later still no sign of an interactive on line booking service
and DSA best estimates suggest it could be another two years before
this service is available. Whilst we are unsure of the demand
we do not think it unreasonable in the 21st Century for the DSA
to be able to accept test bookings by E-mail. It would certainly
be a cheaper alternative to those currently available.
6.8 We request the Select Committee to recommend
the introduction of an E-mail booking service immediately. Further
that the DSA explain exactly what their computer booking system
can and cannot do and what their programme is for getting it right.
7.1 The DSA Service Standards for practical
driving test waiting times revolve around average waiting times
for tests across the country. Whilst it is obviously important
that waiting times should be kept to a reasonable level we feel
that there should also be some consistency in the waiting times
across the country. Waiting time figures published by the DSA
show for the third week in November 2000 that the test centre
waiting times range from one week to 14 weeks.
7.2 The DSA seem unable to deploy staff
in a way that equalises the waiting times across the country,
the chart below shows a small selection of centres all with about
30 minutes driving time between them but vastly differing waiting
|Ashford, Kent||4 weeks
||Gillingham, Kent||8 weeks
||4 weeks||32 minutes
|Brentwood, Essex||9 weeks
||4 weeks||30 minutes
|Crewe, Cheshire||4 weeks
||Cobridge, Stoke on Trent
||8 weeks||4 weeks
|Preston, Lancashire||5 weeks
||9 weeks||4 weeks
7.3 The experience of trying to book is still you
may get through or you may not and when you do get through you
might get a test in a week or it could be two months. I find it
very hard to judge when to put someone in for his or her practical
test. ADI, Northamptonshire.
7.4 The DSA tend to respond to criticism about long waiting
times at certain centres by suggesting that candidates travel
to a centre with a shorter waiting time. We believe that as a
monopoly service provider the DSA should ensure the correct level
of staff at each centre in order to ensure consistent waiting
times rather than asking their customers to fit in with their
staff deployment plans.
7.5 We request the Select Committee to recommend the
introduction of a DSA service standard that concentrates on across
the board consistency in practical driving test waiting times
rather than average waiting times.
8. DRIVING TEST
8.1 Over the last 10 years, the DSA has embarked upon
a programme of driving test centre closures. Whilst some of these
may have been necessary because of a lack of suitable driving
test routes others have been closed in order to save relatively
small amounts of money.
8.2 In most cases when a centre is threatened with closure
local instructors, members of the public, local councillors and
MPs object because they see it as a diminution of a local service.
On a number of occasions, quite bitter battles have taken place
between the DSA and local communities. In our view the amount
of resources expanded by the DSA in promoting these closures probably
uses up any saving made if the centre eventually closed.
8.3 There is also an inconsistency in the criteria for
closing centres as they are not closed solely on the business
case put forward by the DSA. Each closure has to be ratified by
a government Minister and it has been suggested to us that whether
or not a centre closes depends on the profile of the MP in whose
constituency the centre is located.
8.4 A number of centres are currently being considered
for closure. DSA Press Release 34/00 issued 14 November 2000 states
"The Macclesfield Driving Test Centre will temporarily close
for business on 30 November 2000, due to the lease expiring on
the property". DSA have assured us that this is only a temporary
closure and that they are looking to secure new premises in Macclesfield
at the earliest opportunity. However, it is worth noting that
DSA said Crosby test centre was only going to be closed temporarily
in 1998 but it has never re-opened.
8.5 We request the Select Committee to recommend the
immediate end of the driving test centre closure programme and
that in future centres should only be closed where routes become
unsuitable or a majority of local driving instructors agree with
9. DRIVING TEST
9.1 The physical condition of many driving test centres
is poor both from the customer's perspective and from the examiner
point of view. Instead of closing centres the DSA should be renovating
and modernising the existing estate. It is somewhat shocking to
realise that many driving test centres do not have toilet facilities
available for candidates.
9.2 We request the Select Committee to recommend an improvement
programme for DSA test centres targeting the provision of toilet
facilities for candidates at every test centre by 2002.
10. DRIVING TEST
10.1 Much comment is made about pass rates on driving
tests, the figures for the year ended March 2000 show a national
pass rate of 43.7 per cent this represents the number of tests
passed against the number of tests taken. The DSA do not collate
statistics on first time, second time etc pass rates which would
be a much more realistic measure of the test readiness of candidates
10.2 We request the select committee to recommend that
DSA commence collection and collation of first time pass rates
10.3 The figure 43.7 per cent is the one often discussed
and against which individual driving instructors are often judged.
However, it is only a national average figure and little comment
is ever made of the huge variations in pass rates across the country.
10.4 For the same period the test centres in Leeds and
at Wood Green in London shared the distinction of the lowest pass
rate in Britain at 28 per cent whilst top spot went to the occasional
centre at Kingussie in Scotland where the pass rate was 79.2 per
cent. A pass rate difference of 51.2 per cent.
10.5 This difference can be explained in part by differences
between those likely to come forward for testing in an inner city
area as against those in an extremely rural area where the number
of tests taken are much lower. However, other variations whilst
less dramatic are more difficult to understand.
10.6 Comparison of the pass rates at the test centres
highlighted above that are within 30 minutes of each other show
the following differences.
|Ashford, Kent||51.2 per cent
||Gillingham, Kent||40.5 per cent
||10.7 per cent|
|Brentwood, Essex||36.2 per cent
||Barking||36.8 per cent
||0.6 per cent|
|Crewe, Cheshire||48.2 per cent
||Cobridge, Stoke on Trent
||41.9 per cent||6.3 per cent
|Preston, Lancashire||40.1 per cent
||35.0 per cent||5.1 per cent
10.7 Wide variations of pass rates can also be found
in the same conurbation. The pass rates for the six test centres
in Birmingham vary from 32.8 per cent to 46.6 per cent, a difference
of 13.8 per cent.
10.8 If it was possible to understand the reasons why
the pass rates were so much higher at some centres than others
it may be possible to take actions that would bring the lower
rate centres up to the standard of the higher rated ones.
10.9 We request the Select Committee to recommend an
independent survey of driving test pass rates aimed at understanding
and explaining why there are such wide differences in pass rates
at various centres.
11. DRIVING TEST
11.1 Over the last couple of years, the DSA has started
to collect data regarding the pass rates of individual instructor's
pupils. It is suggested that at some time in the future these
could be published as an indication to the public of the quality
of individual driving instructors. At the moment the DSA are sending
copies of the data they collect on an annual basis to ADIs. Most
of the data collected and sent out is very inaccurate.
11.1.1 When I initially received my Driving Test Fault
Analysis for 1999-2000, it showed 62 tests and a pass rate of
50 per cent. This compared with a true figure of 51 tests and
a pass rate of 58.82 per cent.
In fairness, the DSA did correct the figure after I sent
details of my record.
In view of the ultimate plan to publish driving test pass
rates this degree of inaccuracy is unacceptable.
ADI, West of England.
11.2 With the variations in pass rates at different test
centres shown above and the fact that a person's ability to pass
their driving test can be affected by a wide variety of factors
including age, gender, number of lessons, number of test attempts
and amount of private practice, we believe this exercise is flawed.
11.3 We request the Select Committee to recommend the
suspension of data collection concerning the pass rates of individual
instructor's pupils, until such time as DSA can produce a system
that will adjust the pass rates to take account of individual
pupil differences such as age, gender, number of lessons, number
of test attempts and amount of private practice.
12. DRIVING EXAMINER
12.1 There is a growing feeling amongst driving instructors
that a certain amount of inconsistency is appearing amongst driving
examiners. We appreciate that it is impossible to have every examiner
mark every fault in exactly the same way. However, it is suggested
that more and more examiners are examining to slightly different
standards and looking for slightly different styles and skill
levels. This makes it much harder for instructors to prepare candidates
for driving tests.
12.2 We suspect that the reason for this drift in standards
has come about because of DSA cutbacks in supervisory staff together
with involvement in non-statutory activities.
12.3 We request the Select Committee to recommend that
the DSA take immediate steps to maintain examiner standards and
13. DRIVING TEST
13.1 Many driving instructors believe that DSA driving
test fees are excessive. The standard fee for a week day car test
for a learner driver is £36.75 (the fee earning period relates
to one hour). In comparison on average, a driving lesson of one
hour's duration costs less than half that price and the price
includes the use of a car.
13.2 We request the Select Committee to recommend an
immediate investigation into the DSA pricing policy to ensure
that the public is not paying excessive amounts for driving tests.
14. ADI FEES
14.1 Each year the DSA publish their Annual Report and
Accounts. Each year the ADI section shows a surplus. As we understand
it ADI fees can not be used for any other purpose yet no redistribution
of over paid fees is ever made to ADIs, we wonder what the money
is used for.
14.2 We request the Select Committee to recommend an
immediate investigation into the DSA accounts to ensure that ADIs
are not paying excessive amounts for their registration.
15. ADI STANDARDS
15.1 To give driving instruction in a motor car for money
or monies worth a person must have their name entered into the
Register of Approved Driving Instructors maintained by the DSA.
To enter the register a person must pass a theory test and a three
part practical examination (the qualifying examinations). Once
on the ADI Register instructors must submit themselves to occasional
checks of their ability to give instruction (check tests).
15.2 Until a few years ago, the practical qualifying
exams and the check tests were conducted by a senior grade of
examiner called a Supervising Examiner. Then DSA decided that
they would provide specialist training to a selection of basic
grade driving examiners to allow them to conduct the practical
qualifying exams allowing the Supervising Examiners to concentrate
on check testing.
15.3 Accordingly, the number of Supervising Examiners
was allowed to fall as part of their work was going to be carried
out by other examiners. However, because of various factors, including
a lack of examiner recruitment by the DSA, the pressure to keep
ordinary driving test waiting times under control, together with
other non-statutory duties that the agency have taken on (see
below) most practical qualifying exams are being conducted by
an ever-decreasing number of Supervising Examiners.
15.4 This means that only a few check tests are being
conducted. It is reported that the DSA check test programme may
be as much as two years behind. Whilst few instructors like being
check tested we feel it is vital that these checks are carried
out if ADI standards are to be improved as set out in the Governments
Road Safety Strategy.
15.5 We request the Select Committee to recommend that
the DSA take immediate steps to recover the ADI check test programme
within six months.
16. ENFORCEMENT OF
16.1 Enforcement of the laws and regulations concerning
Driving Instruction is the responsibility of the Driving Standards
Agency. However, they sub-contract the work of evidence collection
and prosecution for those carrying out driving instruction illegally
to the Vehicle Inspectorate (VI). Very few prosecutions are ever
successfully brought against those giving instruction illegally
because the VI refuse to use agent provacateurs to trap
those instructing illegally. As one of the principal purposes
of the Register of Approved Driving Instructors is to protect
the public from unqualified tuition we fail to understand why
this form of evidence gathering, comon amongst trading standards
officers, can not be used to protect the public from unregistered
16.2 We request the Select Committee to recommend the
use of agent provocateurs by the Vehicle Inspectorate in
order to obtain evidence against those instructing illegally and
to protect the public from unregistered driving instructors.
17. DSA NON STATUTORY
17.1 Over the last few years, the DSA has ventured into
a number of non-statutory activities, in particular the testing
of taxi/private hire drivers and the monitoring of bus/coach drivers.
As we understand it any surpluses made from this commercial activity
are channelled into their schools programme (discussed below).
MSA members have mixed feelings about the DSA venturing into this
field. Most would like to see the driving standards of these groups
improved, but not at the cost of ever increasing driving test
17.2 As we understand it the DSA are entering into commercial
contracts with a number of companies and these contracts have
built in service levels with penalty clauses. We feel this creates
a conflict of interest for the DSA in whether they prioritise
their statutory or commercial duties. If an examiner who was due
to undertake commercial activity on a particular day is off sick
will the DSA move an examiner from statutory duties to ensure
they do not incur a penalty under their commercial contract? If
this does happen, it will mean disappointed driving test candidates
and ever lengthening driving test waiting times. We have discussed
above the effect on ADI check testing of an examiner shortage,
we believe DSAs non statutory activities will increase the problems.
17.3 We request the Select Committee to recommend the
suspension of all DSA commercial contracts until such time as
they can demonstrate that they have more examiner resource available
than is needed to run their statutory services to the highest
18. DSA SCHOOLS PROGRAMME
18.1 The DSA run a programme that entails driving examiners
visiting schools to talk about driver training and the driving
test. We believe that this is a job that could be better undertaken
by driving instructors. There are a variety of reasons for thismany
ADIs have classroom teaching certificates such as the C &
G 730. There is spare capacity within the ADI work force whereas
there is clearly a shortage of examiners as discussed above. Another
reason is value for money. The DETR has just announced that it
will pay DSA £250,000 towards its schools programme. This
represents extremely poor value for money at £36.75 per hour,
as driving instructors would undertake twice the number of hours
for the same amount of money. The most compelling reason for stopping
examiners doing this type of work is to allow them to concentrate
on their statutory duties. Clearly, these are not currently being
18.2 We request the Select Committee to recommend that
the DSA schools programme use driving instructors rather than
19. DSA PUBLICATIONS
19.1 The DSA publish a number of books and last year
took over the publication of the Highway Code. On publication
of the new version it was immediately realised that there were
mistakes in some of the advice given, in particular the advice
on use of roundabouts. This matter was discussed by MSA officials
with a DETR Minister over a year ago. We understood that the first
reprint would contain corrections. There have been several reprints
and a consultation paper on the matter but still nothing seems
to have been done.
19.2 My worst experience of the DSA is to witness
the continued sale of the highway code despite the fact that the
DSA are aware that rule 162 is potentially dangerous. Graham
19.3 We request the Select Committee to recommend the
immediate correction of the Highway Code.
DSA INDEPENDENT COMPLAINTS
20.1 If all goes wrong at the DSA there is an Independent
Complaints Advisor (ICA) that customers can turn to. Sadly, details
of the complaints dealt with and the findings of the ICA are not
published. Perhaps because a number seem to be against the ICA!
20.2 On 11 September 2000 I sent to you a copy of
a complaint about the DSA. I note that in the DSA leaflet regarding
your function it states "ICA will immediately acknowledge
receipt of your complaint." I have received no such acknowledgement.
Please immediately confirm that you have received my complaint.
ADI, South East England. An acknowledgement has now been received
dated 14 October. Hoewever, up to 16 November no reply had been
received over two months after the complaint had been made.
20.3 We do not know who appoints or pays the ICA or what
proportion of complaints are found in favour of the complainant
and what proportion in favour of the DSA.
20.4 We request the Select Committee to recommend that
the DSA Independent Complaints Advisor publish every three months
brief details of the complaints received and the outcome of those
21.1 Recently MSA officials visited DSA headquarters
at Nottingham for a meeting. Whilst waiting in the entrance hall
they spotted the DSA Charter Mark Trophy in a display cabinet.
On closer inspection, they noted that the metal nameplate attached
to the trophy was tarnished. They were not surprised.