BIBA response to the Driving Standards Agency Consultation paper on Learning To Drive

6th October 2008

The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance intermediary organisation. We represent the interests of insurance brokers, intermediaries and their customers.


 


BIBA represents more than 2,300 insurance intermediaries including 98 of the UK’s top 100 firms. Our members handle about half the value of all UK home, contents, motor, travel, commercial and industrial insurance policies. Independent insurance intermediaries distribute nearly two-thirds of all UK general insurance, of which BIBA members account for more than 80%. They also introduce £22 billion of premium income into London’s insurance market each year.


 


BIBA is pleased to have the opportunity to respond to the Driving Standards Agency consultation paper on learning to drive on behalf of its collective membership.


Our responses to the 29 questions set out are as follows:


 


 


Q1. What views do you have about our explanation of the high accident rate among newly-qualified drivers? Please explain your reasons: [related text chapter 1]


 


The current format for passing the driving test needs to be more relevant to ‘real life’ driving scenarios. It focuses heavily on vehicle control and fails to cater sufficiently for key driving experience like night driving, bad weather driving, motorway driving, attitude, consideration of others, awareness and judgment.


 


 


Q2. Do you have any comments about the contents of the partial Impact Assessment published alongside this Paper?


BIBA’s preferred option form the impact assessment is option B – the changes to driver training and testing system. We agree with DSA. This option represents a combination of voluntary education and mandatory testing arrangements to encourage drivers to encompass a broader range of knowledge, skills, attitudes and behaviour to driving on the roads. BIBA believe that this also represents the best option financially.


 


 


Q3. What are your views about our analysis that improved training and testing is the best way of improving the safety of newly-qualified drivers? Please include any evidence supporting your views: (related text chapters 3 & 4) 


 


We do not believe a minimum learning period or raising the minimum age for a provisional or full licence (or both) will create any ‘scientific’ improvement. The maturity and preparedness for driving should be judged on the individual learners’ ability and readiness. There is little difference in someone’s attitude between 17 and 18. We believe that simply delaying people from obtaining their full DL is not the answer and it will also create problems for younger people in rural areas who need to transport relatives or travel to work.


 


We also recognise that people learn at differing speeds. What is needed is for the driving test to be a fit for purpose ‘hurdle’ that only a competent, prepared driver can pass, irrespective of age or number of lessons taken.


 


A prohibition on night driving, passenger limitations is unenforceable and impractical, e.g. a young nurse working a shift at a hospital who carries her colleagues with her. We do NOT support this view. We also know that in Northern Ireland, graduated licencing was not effective however the learner driver should be educated on the heightened risk of being distracted by passengers and it should be part of the learning to drive theory work.


 


 


Q4. Which do you think would be most helpful to improve the educational value of the theory test? (related text in paragraph 5.20)  (please tick one option)


 


·         Continue to publish the theory test question bank in its current form


·         Continue to publish the questions but without the answers


ü       Publish a practice question bank


·         Stop publishing the question bank altogether


 


Please explain your reasons:


 


The questions are a key part of the learning process and should be published to encourage involvement and provide thought about key areas of learning to drive. Answers should be included to give the student a ‘steer’ and understanding of the correct answer. A practice question bank would resolve any concerns over memorizing of answers.


 


 


Q5. Do you agree or disagree that case studies could have a role in helping assess whether learners have understood driving theory better? (related text in paragraph 5.21)


 


BIBA strongly agree


 


Please give reasons for your views:


 


Case studies relate more to the real world, so we strongly agree with their role in helping drivers better understand the theory. 


 


Q6. What other methods could be used to assess whether learners understand driving theory? Please include any information relating to your views: (related text in paragraph 5.21)


 


BIBA have nothing to add.


 


 


Q7. How can we improve road safety using the hazard perception test? Please include any information relating to your views: (related text in paragraph 5.26)


 


To improve hazard perception testing learner driver should be taught by a combination of 3D animation, similar tests and real life involvement in driving lessons and the driving test.


 


 


Q8. Do you agree or disagree that the marking system for the practical test should focus more on evidence of competence than on evidence of weakness? (related text in paragraph 5.29-5.33)


 


BIBA neither agree nor disagree


 


Please explain the advantages and disadvantages that you see:


 


It needs to be a sensible balance, if over all the driver was competent in all areas but only made some minor omissions that on the whole they were compliant with e.g. looking in mirrors. Then they should be given a pass. However repeated minor errors or major errors should still result in a fail.


 


 


Q9. Do you agree or disagree with the introduction of independent driving into the practical test? (related text in paragraph 5.34-5.36)


 


BIBA strongly agree


 


Please explain the advantages and disadvantages that you see:


 


This will prove a learner has the mental capacity to drive safely and navigate at the same time.


 


 


Q10. Do you agree or disagree with the introduction of Situational Judgment exercises into the practical test? (related text in paragraph 5.37-5.38)


 


BIBA strongly agree


 


Please explain the advantages and disadvantages that you see:


 


This is a vital requirement of future tests as it is often bad judgment of a situation that causes incidents.


 


  


Q11. Do you have any comments on the way in which we test specific maneuvers in the practical test? Please explain the advantages and disadvantages that you see: (related text in paragraph 5.39-5.42)


 


The experience of ‘real driving’ is vital; however certain maneuvers e.g. parking must still be tested. Perhaps the maneuver chosen by the candidate could be conducted at the beginning of the test and then the maneuver that has yet to be conducted could then be completed as normal later in the test.


 


 


Q12. Do you agree or disagree that: (related text in paragraph 5.44-5.48)


 


(a) The theory test should be uncoupled from the hazard perception test?


 


BIBA strongly agree


 


Please explain your reasons:


 


It is a more focused approach.


 


(b) The specified driving maneuvers should be tested separately from the general driving part of the practical test?


 


BIBA strongly agree


 


Please explain your reasons:


 


Can ensure specific focus and ensure no key competencies are missed.


 


 


Q13. What are your views about providing more comprehensive feedback to all candidates at the end of each assessment, regardless of the result? Please explain your reasons: (related text in paragraph 5.49-5.51)


 


There is no easy way of telling someone they have failed but it is important to give a full and frank explanation directly after the test so the candidate knows exactly what they need to deal with.  We do not see third parties adding any value or benefit.


 


 


Q14. What are your views about the proposed student workbook? How useful would a voluntary document be for all learners when they start learning to drive? Please explain your reasons: (related text in paragraph 6.3-6.9)


 


The student workbook should be a very useful practical document.


 


 


Q15. Do you support the idea of progress being recorded in a student workbook? Please explain your reasons: (related text in paragraph 6.10-6.14)


 


Yes, the driving instructor would be best placed to assist. 


 


Q16. What sort of information should be considered in creating a star rating system to help learners in choosing their instructor? Please explain your reasons: (related text in paragraph 7.1-7.5)


 


Instructor ratings could be skewed by the type of candidates on their books. This is an unnecessary waste of resource.


 


 


Q17. What are your views on the usefulness of publishing the pass rates for different instructors? Please explain your reasons: (related text in paragraph 7.4-7.5)


 


BIBA believe that this is unnecessary as the over-riding factor is the candidate and their commitment to apply themselves. Is a bit like the old adage ‘you can lead a horse to water……


 


 


Q18. Do you agree or disagree that learners should be required to have a ‘test readiness’ certificate signed by a supervising driver or driving instructor, before they can take a practical test? (related text in paragraph 7.6-7.8)


 


BIBA strongly disagree


 


Please explain your reasons:


 


Instructors should know whether the driver is ready before proposing their test application. This is unnecessary red tape.


 


 


Q19. Do you agree or disagree that practical test candidates and their supervising drivers would benefit if the supervising driver were to sit in on the test? (related text in paragraph 7.9)


 


BIBA neither agree nor disagree


 


Please explain your reasons:


 


It would probably make them even more nervous! Providing the tester gives comprehensive feedback this should be sufficient.


 


 


Q20. Do you agree or disagree that practical test candidates and their supervising drivers would benefit from the supervising driver sitting in on the debrief at the end of the test? (related text in paragraph 7.9)


 


BIBA strongly agree


 


Please explain your reasons:


 


Yes, then the instructor can focus on the specific areas requiring attention.


 


 


Q21. Do you think an Attitude Advisor is likely to offer benefit by:


 


(a) providing useful guidance to students to help their learning programmes? (related text in paragraph 8.6-8.10)


 


BIBA agree


 


Please explain your reasons:


 


The issue of attitude is an important one, making an advisor voluntary may defeat the object as those requiring it will probably refuse to use it and a PC based system may have little effect. More thought is required in this area.


 


(b) providing useful guidance to their supervising drivers? (related text in paragraph 8.6-8.10)


 


BIBA strongly agree


 


Please explain your reasons:


 


Yes, the wrong attitude can cause accidents.


 


 


Q22. How much do you think that learners would benefit from attending driver discussion groups? (related text in paragraph 8.11)


 


BIBA feel that learners would benefit a lot


 


Please explain your reasons:


 


This is where the attitude advice can be given. Perhaps it could take place at the same place / time as the simulation training.


 


 


Q23. Are you aware of any evaluated road safety education programmes which could inform our work with pre-drivers, and that you would like to make us aware of? Please provide us with details:


 


No, but road safety education should start in schools.


 


 


Q24. As well as the subjects mentioned in this Paper, what else should be covered in the pre-driver qualification in safe road use? Please explain your reasons: (related text in text box under paragraph 8.20)


 


Excessive speed is a major concern and a contributor to the severity of an accident influencing the extent of injuries, deaths and the costs of claims, therefore we would like speeding to be highlighted as a major issue in all aspects of the reformed driving test.


 


 


 


 


 


Q25. How can we make this qualification appeal to as wide a range of people as possible? How can it be made engaging, and where should it be made available? Please explain your reasons: (related text in paragraph 8.21-8.22)


 


Attitude, awareness, consideration of others and judgment.


 


 


Q26. What are your views on a pre-driver qualification in safe road use? Do you think young people would benefit from participating in it? Please explain your reasons: (related text in paragraph 8.16-8.22)


 


Yes, it would be a very constructive step that should be encouraged.


 


 


Q27. How do you think we can use additional qualifications to encourage a culture of lifelong learning? Please include any evidence that you can provide: (related text in paragraph 8.24-8.28)


 


For commercial vehicle drivers it would ensure continuing professional development and professionalism.


 


 


Q28. How can motorway driving be taught more effectively? Please explain your reasons:


(related text in paragraph 8.29-8.31)


 


Dual carriageways are similar. They could be used for the more advanced learners to learn while under professional supervision in limited amounts. In Northern Ireland there are particular problems as new drivers are restricted to 45 mph after passing their tests. Drivers need to be better prepared for motorways and sufficient experience should be gained before they are ‘unleashed’. Simulators can add extra support to this.


 


 


Q29. How can we best apply our reforms for learning to drive to those who want to ride a motorcycle? Please explain your reasons: (related text in paragraphs 1 – 4 annex B)


 


The reforms apply equally to bikers as well as car drivers.


 


There have been a number of changes recently for motorcyclists to try to make them safer on the road, for example licences are restricted for a period of 2 years. However, not many brokers actually see the restriction certificate so bikers are probably not complying and it is far too easy for them to get around this rule. The test centre / DVLA should be doing more to ensure this rule is enforced which in turn would make the roads slightly safer. The MC test is also changing next month, only time will tell if this has an impact on the accident rate. 


 


We would like to point out that it is often the bike rider that is blamed for the bad motorcycle accident statistics where in fact it is car drivers that cause the majority of accidents because they do not see the biker coming. Therefore, it may be better for car drivers to be taught about other users of the road, particularly bikers.


 


 


 


 


 


ADDITIONAL COMMENTS 


 


The insurance industry would like to offer incentives for young drivers that make the effort to be a safer driver. We suggest further discussion around the foundation qualification and pass plus facility.


 


We would also like to see compulsory questions in the theory test about insurance, ensuring they will be asked at some stage.


 


 


Thank you for taking the time to consider our response. If you have any further queries please contact BIBA’s Technical and Corporate Affairs Executive Graeme Trudgill on 02073970218 or trudgillg@biba.org.uk for further information.


 


Yours sincerely


 



 


 


Eric Galbraith


Chief Executive


 


Direct Tel:  020 7397 0201


Direct Fax: 020 7626 9676


Email: galbraithe@:biba.org.uk