BIBA response to driver testing, training, examining and licensing, implementation new European Union requirements. The Third Directive on driving licenses

5th February 2010

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


BIBA membership includes 1700 regulated firms. Insurance brokers and intermediaries distribute nearly two-thirds of all UK general insurance. In 2007, insurance brokers and intermediaries generated £1.5 billion of invisible earnings and they introduce £22 billion of premium income into London ‘s insurance market each year.


BIBA is the voice of the industry, advising members, the regulators, the Government, consumer bodies and other stakeholders on key insurance issues.  BIBA provides unique schemes and facilities, technical advice, guidance on regulation and business support and is helping to raise, and maintain, industry standards. BIBA works closely with the Chartered Insurance Institute to provide training to those working in the industry and actively participates in helping the industry and its customers deal with some of the major issues of the day.


BIBA members provide professional advice to businesses and consumers, playing a key role in identification, measurement, management, control and transfer of risk.  They negotiate appropriate insurance protection tailored to individual needs and operate to a very high standard of customer service with the aim of ensuring peace of mind, security, financial protection and the professional advice required.


Our responses to the 12 questions set out are as follows:



 


 


 


Riders of mopeds and motorcycles


 



  1. Do you agree with our proposals for moped licensing?

 


Yes, BIBA agree
 



  1. Do you agree with our proposals for special provision for moped riders with a physical disability?

 


Yes, BIBA agree
 



  1. Do you consider that a training route should be offered to allow motorcycle licensce upgrades?

The provision of a training route would surely improve road safety, however the majority of riders qualify using the direct access route and we would question whether putting in place training courses is viable bearing in mind the “significant complexity and costs for both the trainers and trainees” outlined in the consultation document.



  1. If you believe that wider considerations support a training route for progressive access, do you agree with our proposals as set out in Annex B for the standards and registration arrangements that should be operated for that training and those delivering it?

Yes, BIBA agree.



  1. Do you agree with our proposals for a familiarisation training course within progressive access arrangements?

 


The familiarisation course proposals appear to be a natural and sensible step, and more economically viable than the training route.



  1. Do you agree with our approach to provisional licensing for mopeds and motorcycle learners?

 


Yes , BIBA agree



  1. Do you agree with our proposals to make special provisions for motorcycle riders with a physical disability?

 


Yes, BIBA agree


 


Drivers of cars and light vans


 


       8.   Do you agree that we should cease to issue separate category B1 licences
             to new drivers?


Yes, BIBA agree


 


 


 


       9.   Do you consider that a training route should be offered for entitlement to tow a medium sized trailer with a car or light van?


 


No. It seems unnecessary to spend 7 hours training on towing a medium sized trailer and the costs are too high

      10.  If you support a training route for entitlement to tow a medium-sized trailer


             do you agree with our proposals for the standards and registration
             arrangements that should be operated for that training?


N/A

Driving examiners


 


      11. Do you agree with our proposals to amend the conditions of approval for  


            Organizations with examiners as regards the maintenance of records of


            Supervised tests and undertaking periodic training?


Yes, BIBA agree



Driving licence administration
     


      12. Do you agree with the approach being taken to implement the
            administrative provisions of the new directive?   


 


Yes, BIBA agree                                     
   


Thank you for taking the time to consider our response. If you have any further queries please contact Graeme Trudgill, BIBA’s Technical and Corporate Affairs Executive for further information on 02073970218 or on trudgillg@biba.org.uk or Peter Staddon, Head of Technical Services on 0207 397 0204 or staddonp@biba.org.uk


 


Yours sincerely



 


Eric Galbraith


Chief Executive


 


Direct Tel:  020 7397 0201


Direct Fax: 020 7626 9676


Email: galbraithe@biba.org.uk