Transport Committee - DVLA and DSAWritten evidence from the Motorcycle Industry Trainers Association (MCITA) (DDA 19)

Summary

The Training Industry is pleased to submit a response into the work of the Driving Standards Agency (DSA) through the Motor Cycle Industry Training Association (MCITA).

The MCITA is the UK professional trade association representing motorcycle trainers who provide all types of motorcycle training. The views of the MCITA’s many members with pre and post test experience are particularly relevant for the purposes of this evidence. The policies and work programme of MCITA, a “sister” association to the Motorcycle Industry Association (MCI) are determined solely by motorcycle trainers. The MCI has submitted separate evidence to the Transport Select Committee on behalf of manufacturers and the supply side of the industry.

The MCITA has almost 200 DSA registered Approved Training Bodies (ATB’s) in membership and as such represent those delivering an estimated 60–70% of all pre-test rider training carried out in England, Wales and Scotland. This response represents the views of the MCITA, which are based on extensive experience of the motorcycle testing and training regime, as administered by the DSA.

The MCITA Committee who prepared this document is made up of seven highly experienced ATB owners, many of whom have been working with the DSA and DfT to improve the current test and its availability and also as part of the DSA’s Learning to Ride Program (LtRP) groups. This submission also reflects the issues raised in correspondence received by the MCITA Secretariat from MCITA members.

Many issues are raised, some of which appear minor when viewed in isolation, but taken together represent significant and ongoing concerns. Others issues are of major concern and cause immediate and obvious disruption and inconvenience to DSA registered ATB’s on a day to day basis. Major or minor, many of these issues affect all ATB’s and make it impossible for them to deliver the safest possible riders and to operate their businesses in a cost effective manner.

This evidence concentrates predominantly on the work of the DSA, as the agency most critical to the work of MCITA members.

Representatives will be available to give oral evidence to the Transport Select Committee should the Committee desire this.

1. Introduction

1.1 MCITA members believe that safety is of primary importance when dealing with vulnerable novice riders and expressed many of their concerns directly to the Transport Select Committee during 2009, when a very welcome Inquiry into the implementation of the Second Driving Licence Directive (2DLD) and the new motorcycle test was announced. The Inquiry found that the DSA “needs to give much greater priority to customer service and convenience for test candidates and trainers”. Many of the issues raised by the Inquiry have not been addressed. Others have been subject to a partial “quick fix”, which whilst appreciated by the training industry, is not seen as the permanent solution.

1.2 There are many plans to improve test booking, test availability, quality assurance, trainer registration and others but most of these measures are years away and MCITA members do not feel that they have the luxury of a long lead time available. The TSC announcement of 23 March 2010 read “if the new test brings financial ruin to the motorcycle training industry then we will have gone backwards”. This is what our members fear the most and are yet to be reassured. Paragraph 44 of the TSC report intuitively pointed out that 2DLD implementation had “damaged the trust of the motorcycling community in the DSA” and that it “would take a long time to mend what had been broken, but the Government and the DSA now need to take urgent action to establish a way forward in collaboration with the industry”. Urgent, but sustainable action is needed and although genuine collaboration is sometimes evident, it often appears that the DSA are paying “lip service” to the training industry.

1.3 The numbers of riders passing the motorcycle test have dropped dramatically since the implementation of 2DLD by the DSA in April 2009. The statistics show test passes are still way below the previous average of around 52–53,000 tests passed per annum even taking into account the extra 15,000 riders who rushed to take their test before the implementation of 2DLD.

1.4 Test passed by year 2000–11

Year

Tests Passed

2000–01

60,014

2001–02

48,566

2002–03

55,709

2003–04

53,826

2004–05

50,309

2005–06

51,132

2006–07

50,139

2007–08

58,494

2008–09

69,960

2009–10

25,760

2010–11

34,484

1.5 In contrast to this downward trend, 167,000 Compulsory Basic Training (CBT) certificates were sold to ATB’s in 2009–10. In the five months from January 2011 to the end of May 2011 alone, 105,000 CBT certificates were sold to ATB’s. This would suggest that as predicted by the industry, the changes to the test combined with all the associated inconvenience and cost to the novice rider have resulted in more riders choosing to ride on L plates with only the minimum basic training rather than following the safest and most comprehensive route of passing the motorcycle test. This will not only adversely affect motorcycle safety but has of course cut the revenue available to ATB’s.

2. Provision of Motorcycle Tests/Trainer Booking

2.1 Many ATB’s are facing extreme difficulties just trying to break even; making a reasonable profit appears an unattainable goal. The drop in the number of test candidates, combined with for most, the massively increased cost of travelling long distances with students to the inadequate number of Multi Purpose Test Centres (MPTC’s) available as well as the increase in riders wishing to progress only as far as CBT means that the loss to ATB’s has been extreme. Training fees vary substantially around the country but on average ATB’s charge novice riders somewhere in the region of £600 to get them to test standard. CBT courses average around £100, so it is easy to see why ATB’s are suffering when the increase in CBT training income is quickly offset by a massive drop in candidates willing to pay £600 for pre-test training. This sudden drop in revenue has caused many ATB’s severe hardship.

2.2 As evidenced in the previous TSC Inquiry, motorcycle tests are provided too far away, at unsuitable times and in numbers that make them uneconomic to use. There are still only 50 MPTC’s and although the DSA should be commended for the action taken to improve the numbers of tests available at these sites, the obstacles of distances travelled and unsuitable times remain the same.

2.3 As autumn approaches ATB’s are worried that as in the previous two years, many Module 1 tests (the off road part of the test carried out at MPTC’s) will be cancelled at short notice due to frost/ice. In addition the policy of allowing examiners to start early and finish early has wasted the opportunity to conduct hundreds of tests. Both issues have caused inconvenience and expense to many students and ATB’s who have ridden to the test centres only to find that ice on the MPTC has meant that test has been cancelled. The early nature of these tests combined with increased travel time, means ATB’s cannot ring the test centre ahead to check if the manoeuvring area is frost free. Many MPTC’s are clear of frost by around 11.00 but the test day starts at 8.30 regardless of the season. Trainers travelling significant distances to test centres often leave their premises on a frost free day only to find that the weather at the MPTC is considerably colder with heavy frost on the ground and their test cancelled. Commonsense should dictate that testing from around 10.30 during autumn and winter would better utilise Examiner resources and result in fewer short notice or in many cases no notice cancellations. This would also bring licence examination times in line with work day norms for motorcycle trainers and most other sections of working society. Refunding test fee’s to students is a waste of DSA’s resources, and ATB’s who have provided Instructors, motorcycles and fuel etc to get the student to the test centre are left out of pocket having to meet all the costs themselves as no compensation is available to them. This does not of course take into account the inconvenience of sometimes getting up before 6am to take a student to attend a cancelled test. This all leads to extreme frustration for students and extra expense for ATB’s with no mechanism available to them to mitigate this extra burden.

2.4 MCITA has also received complaints that recently one of the MPTC’s, developed to ensure the best possible drainage, has suspended tests due to heavy rain. In others high winds stop testing, all of these not uncommon weather conditions cause financial hardship to ATB’s and inconvenience to their customers.

2.5 The DSA trainer booking system has been in existence for around 15 years. It allows less scrupulous ATB’s to “play the system” and overbook tests, only to hand them back at only three days notice, too late for other ATB’s to use them. This is a waste of resources and actions to stop abuses of the system have been slow. Again the DSA must be congratulated for taking action against some ATB’s recently but this is long overdue.

2.6 In 2009 the DSA held a conference for ATB’s when they recognised the current booking system was flawed and they pledged to have a new improved computerised booking system implemented within 12 months. That system is still under development with a likely implementation of summer 2012. In the meantime the DSA’s blanket policy allowing the same limits for all trainers is anti-competitive. Allowing an ATB with 10 Instructors access to the same number of tests as an ATB with only 1 Instructor, is clearly going to restrict the business of the larger ATB. The new system should address this and will be fair to all, but again this is an example of how long it takes the Agency to address issues and implement change.

2.7 Despite constant requests from ATB’s the DSA have not been able to produce a receipt system that identifies the date and time of the test in question for trainer booked tests and refunds. This makes it extremely difficult for ATB’s to properly account for their expenditure, as many ATB’s book large amounts of tests at a time or book for several training sites at the same time. This causes problems with Inland Revenue inspections and makes it difficult to run a business efficiently. This is an example of a small problem causing a much larger issue for the ATB owner.

2.8 Many ATB’s also book Theory Tests; this system works better but does not cope with Community Licence Holder (CLH) licences. It is a very slow process for ATB’s trying to assist a European National wishing to take their motorcycle test. These three types of licence are reasonably common and likely to increase in future; there are no plans to cater for this.

3. Monitoring/Quality Assurance

3.1 Since the introduction of Direct Access in 1997 and CBT in 1990 the DSA have powers to quality assure only CBT training, leaving all other pre-test training to be delivered as an individual instructor sees fit. The DSA have recently taken steps to improve the quality assurance on CBT and progress has been made, but there is still a lot of dissatisfaction from MCITA members about the consistency of quality assurance and the lack of guidelines over what is acceptable practice, this makes misunderstandings more frequent. The DSA led Learning to Ride Project group are aiming to register and quality assure all types of motorcycle training but until regulations are passed the majority of pre test training is totally unchecked, and at present all of the stakeholder group (which includes trainers and the wider motorcycling community) considering the issue is at odds with the DSA over the proposals.

3.2 It appears to MCITA members that even when serious failings in CBT delivery are pointed out to the DSA they have been slow to tackle offenders and very few complaints appear to result in any punitive action. An MCITA Committee member was informed by a DSA manager that to their knowledge no more than five ATB’s have ever been closed down through malpractice since CBT began. This is worrying as it is well known in the industry that unscrupulous schools cut corners at the expense of safety and good ATB’s would wish to see this practice eliminated and best practice established. This apparent lack of sanctions leaves the way free for unscrupulous trainers to offer substandard but cheap training to novices who may well present a higher risk to both themselves and others, with little likelihood of sanctions against the offending ATB.

3.3 Trying to quality assure over 3,000 instructors individually has clearly not worked. Calls from the industry to quality assure the actual training delivered by the 600 registered ATB’s have so far been resisted.

4. Compulsory Basic Training (CBT)

4.1 Changes to the working practice of CBT delivery have been made without consultation or proper methods of communication. The results have been divisive, time consuming and confusing for trainers. For example, guidelines are available to help trainers assess the suitability of a site for CBT training, but rules and regulations change as time goes by and trainers have found themselves in a position where an existing approved site has been deemed unsuitable with very little notice to find an alternative. Other examples given to MCITA include changes to how CBT is conducted, with ATB owners only finding out what is required when their Instructors report back to them following a quality assessment by the DSA. ATB owners believe that the DSA should notify them of changes required and that they should be responsible for ensuring that all their instructors are training novices to the correct standards.

4.2 Manual ordering of CBT Certificate Books means a lack of audit trail which causes delays and waste when things go wrong. Manual recording of successful CBT candidates via these books is also fraught with difficulty and delay meaning that ATB’s are sometimes still being asked to verify names and addresses 12 months after the CBT took place. This task is clearly a burden for DSA and ATB’s, this could be handled much more efficiently using a computerised system. However the new trainer booking system mentioned in section 2 will not be utilised for this purpose and there are no plans for the future to improve this.

4.3 Site Inspections (to check sites are suitable for CBT) are carried out by the DSA but take too long to both inspect and process. There are plans to allow trainers to self authorise, but again ATB’s have waited many years and are paying an expensive levy on every CBT certificate sold to support this process, regardless of whether they need a new site inspecting or not. This is unfair on those businesses that do not require the service.

5. Testing

5.1 The current Module 1 test appears to be discriminating against females who are achieving a pass rate of around 20% lower than their male counterparts. This is not evident in either module 2 tests or to such an extreme in car tests. The DSA are aware of this anomaly but have been able to offer no explanation or assistance in resolving this. MCITA feels that there is value in further investigation.

5.2 Up until May 2011, (when in consultation with stakeholders, the DSA made some changes to the Module 1 test) almost one in every 150 candidates for a module 1 test experienced a reportable incident, some of which were very serious. We do not have access to incident figures since the test was amended but MCITA members are still advising us that the incident frequency remains alarmingly high.

6. DSA Communication and Engagement

6.1 Further to paragraph 5.2, ATB’s need access to statistics with regards to test passes and incidents; this could help for example, trainers with female candidates to concentrate on the areas that seem to cause them the most problems, and to ensure all candidates are as prepared as possible for the test to avoid more incidents. MCITA has access to very basic test pass information, but only by request to the CEO’s office. The training industry overall, not just MCITA members would benefit from more information, in a timely fashion enabling businesses to both plan and train effectively.

6.2 The DSA are making progress in improving short term corporate communication, and although the wider motorcycle training industry is still not entirely up to speed on all issues, most are at least aware of outline progress. However no progress at all has been made concerning local problems, for example an ATB phoned DSA to book tests as usual at their local testing site. The booking centre had no tests showing on the system for that week. The operator could not give the ATB any details regarding why this might be. The onus was on the ATB owner to establish that it had indeed been closed for remedial work and when it might reopen. To add to the problem the DSA were not able to re open the site on time, and provided no advance notice of this either. It appears to ATB’s that they are treated like a member of the public booking a test. However there is an important difference, if a single rider can’t get a local test, it is inconvenient to them, they do not lose money. To a training school with many candidates to organise, to lose your local test centre for several weeks could be catastrophic. In many test centres there are only one or two motorcycle examiners, if one is on long term sick leave or on holiday test provision will be affected, ATB’s need to know this in advance wherever possible to plan accordingly. To survive businesses must be proactive and not reactive. Local information is key to this and is currently not available to them.

6.3 In the longer term, 3DLD is due to be implemented in January 2013, it will require ATB’s to purchase a new specification of motorcycle and this further regime change introduces new licence categories; most ATB’s have no idea what is in the pipeline and the effect it may have on them. Again the DSA could help here by giving businesses useful information in clear and simple terms as far ahead as possible enabling ATB’s to begin to plan for the future more strategically rather than reacting to short notice notifications.

6.4 Specific changes to minimum clothing requirements for students presenting for test were rushed and did not reach many candidates who had booked a test before the announcement. Even now it is possible to book a motorcycle test online and have no idea what the minimum clothing requirements are. This is wasteful of public money as riders who are deemed to be dressed inappropriately are turned away without refund. The guidelines are also unclear and leave room for individual Examiner interpretation and we have heard of several cases which demonstrate standards are far from consistent. MCITA wish to encourage candidates to wear protective clothing but what constitutes “heavy” denim trousers (an example of what DSA lists as acceptable clothing)? How does one distinguish between heavy and light denim? We have heard of a case where a rider presented wearing “motorcycle gloves”, listed as acceptable by the DSA, however there was some skin showing at the wrist. This was deemed unsuitable, luckily for the rider their instructor could loan his gloves, otherwise the test would have been terminated. MCITA wish to encourage riders to be responsible but more prescriptive guidelines are needed if examples of this nature are to be avoided.

6.5 The TSC Inquiry into the implementation of the Second Driving Licence Directive made it clear that DSA needed to collaborate with the industry and the establishment of work groups involving participants from all areas of the motorcycle community has gone some way to developing this. MCITA Committee members have given their time freely to the DSA to attend these meetings, they do so despite losing money as they are unable to train on days that they attend meetings, for the good of the wider training industry. MCITA meets their travel expenses. Whilst their views always appear to be listened to, they often feel as though there is little point in expressing an opinion which is different to that presented to them by the DSA. As an example, the DSA’s Learning to Ride Project has a particular issue in that when proposals were made by the DSA for trainer registration and quality assurance at the first meeting stakeholders were unable to support them. The trainers amongst the stakeholder panel provided a universally supported alternative for consideration. The DSA appeared to agree, but several months later the original DSA proposals were again presented as the solution, and yet again rejected by all stakeholders present. We are still waiting for a response almost 8 weeks after the meeting. So far it appears to have taken about 12 months to get nowhere on this issue. This is very demoralising for the group and does little to show a will to make progress or to collaborate with the industry.

6.6 MCITA welcomed the announcement of the Test Review by the Transport Minister Mike Penning and have gladly accepted places on the groups established to find a solution. These DfT lead groups have a slightly different experience of working in partnership with Government and its Agencies. Ministers and the DfT appear keen to forge ahead with a can do attitude, whilst searching for a workable solution, whilst the DSA appear to be busy justifying why many suggested changes cannot be made.

September 2011

Prepared 1st May 2012