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November 2009
DRIVER TESTING, TRAINING, EXAMINING AND
LICENSING
IMPLEMENTING NEW EUROPEAN UNION REQUIREMENTS
(Directive 2006/126/EC – the third Directive on driving licences)
A consultation by: The Department for Transport in partnership with
the Driving Standards Agency and the Driver and Vehicle Licensing
Agency
Driver and Vehicle
Licensing Agency
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Contents of consultation paper
1. Introduction
2. Executive Summary
3. Changes affecting training and testing for riders of mopeds and
motorcycles
3.1 Topic 1: New EU moped category
3.2 Topic 2: New categories of motorcycles – A1, A2 and A
3.3 Topic 3: Access for physically disabled drivers
3.4 Topic 4: Areas where we propose no change
4. Changes affecting training and testing for drivers of cars and light
vans
4.1 Topic 5: Changes affecting light cars, tricycles and quadricycles
4.2 Topic 6: Changes affecting cars and light vans towing trailers
5. Changes affecting driving examiners
5.1 Topic 7: Changes affecting driving examiners
6. Changes affecting driving licence administration
6.3 Topic 8: Mandatory changes to procedures for car and light van
drivers
6.4 Topic 9: Mandatory changes to procedures for goods vehicles, buses and
coaches
Annexes
Annex A - Glossary of terms
Annex B - Training route to driver qualification - considerations
Annex C- Provisional licensing and the third Directive
Annex D - New standards for training learners using powered two-wheelers
Annex E - Light quadricycles and tricycles – new arrangements
Annex F - New requirements for driving examiners – considerations
Annex G - Other administrative provisions for which no changes are currently proposed
Annex H - Impact assessments
Consultation response form
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1. Introduction
1.1 Background
1.1.1. UK rules on driver licensing and driving tests currently operate within the framework of
the second European Directive on Driving Licences (Directive 91/439/EEC), adopted in 1991.
In essence, this provides for mutual recognition of driving licences between member states of
the European Union (EU) and the European Economic Area (EEA), and harmonisation of the
licence categories and driving test standards.
1.1.2. The third Directive on Driving Licences (Directive 2006/126/EC) was adopted at the
end of 2006. Its provisions must be transposed into national law by mid-January 2011 and
come into practical effect by mid-January 2013. It goes a stage further than the second
Directive, by harmonising definitions of vehicle sub-categories and rules on the duration of
the validity of a licence. Further, it introduces minimum standards for driving examiners and
attempts to ensure that no one can at any one time possess more than one licence issued by
an EU or EEA state. Details of the third Directive can be found at www.eur-lex.europa.eu
1.1.3. Most of the provisions of the new Directive are consistent with current UK practice or
with measures we anyway intended to take. But provisions requiring formal testing or training
for younger motorcyclists wishing to progress to larger and more powerful machines are less
readily accommodated within our existing practice. We propose to implement these
provisions taking so far as practicable a cost-effective and evidence-based approach.
1.2 Our approach
The new Directive contains several provisions where Member States are given options. For
example, Member States can reduce the minimum age for moped riders to 14, or have a
minimum age of 18 for drivers of cars and light vans. In general, our approach is where
possible to exercise those options which allow us to continue current practice. Where we
cannot avoid change, we plan to accommodate our own priorities and otherwise to do the
minimum amount necessary, at the least possible cost, to comply with the Directive.
1.3 Changes we cannot avoid
1.3.1. The most significant changes required by the Directive to current UK practice are:
Changes to the size categories of motorcycles, including a new medium-sized
category;
An increase from 21 to 24 in the minimum age for motorcyclists gaining direct access
to the most powerful motorbikes;
A new formal test or a training programme for younger motorcyclists wishing to
progress in stages to the larger and more powerful machines (currently, unlimited
access to all motorcycles is gained automatically after two years’ experience on less
powerful machines);
Drivers of medium and large buses and lorries must renew their licences and
demonstrate continuing medical fitness every five years (the present UK requirement
is five-yearly renewal only after age 45);
A formal test or a training programme for car and light van drivers wishing to tow a
medium-sized trailer.
1.3.2. Driving entitlements obtained prior to 19 January 2013 are not removed or restricted
by the new Directive 1 . However, other changes, in particular those relating to licence validity
1
Article 13(2) of Directive 2006/126/EC
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periods and mandatory medical assessments, will apply also to existing licence-holders who
require a new licence on or after 19 January 2013. Full details of these and other smaller
changes, and of options that we are choosing not to take up, are given in the body of this
paper.
1.4 Related considerations
In this paper we also address some aspects of training, testing and provisional licensing
which are not specified in the new Directive but which need to be determined for the
provisions of the new Directive to operate effectively in the UK.
1.5 Impact Assessments
The Impact Assessments attached at Annex H form part of a full public consultation process
carried out in accordance with the ‘Code of Practice on Written Consultations’ issued by the
Cabinet Office. They outline the costs and benefits of the proposals under consideration and
should be read with the corresponding chapters of this consultation document. The Impact
Assessments will be developed further in the light of relevant comments received in response
to this consultation paper.
1.6 Legislative and administrative framework
1.6.1. This consultation deals with proposed arrangements in Great Britain only.
The Secretary of State for Transport has responsibility for driver training and testing in
Great Britain. Driver training and testing are matters reserved to the UK Parliament as
regards Scotland and Wales.
The Driving Standards Agency (DSA) and the Driver and Vehicle Licensing Agency
(DVLA) are executive agencies of the Department for Transport (DfT). DSA is
responsible for driving tests within Great Britain (GB) and for introducing the new
requirements concerning training and testing processes and the new criteria for driving
examiners. DVLA is responsible for the issue of driving licences and for maintaining
the records of driving licences.
1.6.2. We envisage that most, if not all, of the implementation of those provisions of the
Third Directive which are not already implemented will be achieved by amending the Road
Traffic Act 1988 or the Motor Vehicles (Driving Licences) Regulations 1999 (S.I. 1999/2864).
1.6.3. Legislative responsibility within Northern Ireland is devolved to the Northern Ireland
Assembly under the Northern Ireland Act 1998. Responsibility for driver training, testing and
licensing within Northern Ireland is with the Driver and Vehicle Agency (DVANI). A separate
consultation paper will be issued by DVANI about implementation arrangements there.
1.7 Further views and comments invited
DfT and its Agencies have already engaged with key interest groups to explain the content of
the third Directive, to listen to their views and concerns, and to explore with them the best
way to implement the changes. This consultation paper asks for responses on a number of
specific questions. In addition, if there are aspects which you believe to be important and not
so addressed then please let us have any relevant views which you may wish to express on
the content of this Consultation Paper, including the legislative changes proposed, and/or on
the associated Impact Assessments.
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How to Respond
1.8 The consultation period began on 11 November 2009 and will run until 5 February
2010. Please ensure that your response reaches us by that date. This document can be
found in pdf format at http://www.dft.gov.uk/consultations/open/thirddirective and may be
downloaded freely. If you would like a printed copy of this consultation document you can
contact Christopher Curson at the address below. Enquiries and requests for the document in
alternative formats (Braille, audio CD,etc) should be sent to the same address.
Christopher Curson
Zone 2/09
Department for Transport
Great Minster House
76 Marsham Street
London SW1P 4DR
Tel: 0207 944 6650
3rdDirectiveConsultation@dft.gsi.gov.uk
1.9 If you wish to respond you are invited to make use of the online response form at
http://www.dsa.gov.uk/consultation/3D_questionnaire/adv/KeyPointWebform.html.
If you are not able to access the online booking form a pdf version is available at
http://www.dsa.gov.uk/Documents/Consultation/DfT_3rd_Dir_Quaire_200910/3rd_Dire
ctive_Questionnaire.pdf.
This can be printed off and completed and then either scanned and sent to the e-mail
address above or sent by post to the above postal address.
1.10 When responding, please state whether you are responding as an individual or
representing the views of an organisation. If responding on behalf of a larger
organisation please make it clear who the organisation represents, and where
applicable, how the views of members were assembled.
Freedom of Information
1.11 Information provided in response to this consultation, including personal information,
may be subject to publication or disclosure in accordance with the access to information
regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the Data
Protection Act 1998 (DPA) and the Environmental Information Regulations 2004).
1.12 If you want information that you provide to be treated as confidential, please be aware
that, under the FOIA, there is a statutory Code of Practice with which public authorities must
comply and which deals, amongst other things, with obligations of confidence.
1.13 In view of this it would be helpful if you could explain to us why you regard the
information you have provided as confidential. If we receive a request for disclosure of the
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information we will take full account of your explanation, but we cannot give an assurance
that confidentiality can be maintained in all circumstances. An automatic confidentiality
disclaimer generated by your IT system will not, of itself, be regarded as binding on the
Department.
1.14 The Department will process your personal data in accordance with the DPA and in
the majority of circumstances this will mean that your personal data will not be disclosed to
third parties.
The Consultation criteria
1.15 The consultation is being conducted in line with the Government's Code or Practice on
Consultation. A full version of the Code of Practice on Consultation is available on the Better
Regulation Executive web-site at:
http://www.berr.gov.uk/files/file47158.pdf
1.16 If you consider that this consultation does not comply with the criteria or have
comments about the consultation process please contact:
Giada Covallero
Consultation Co-Ordinator
Department for Transport
Zone 2/25
Great Minster House
London SW1P 4DR
Email address consultation@dft.gsi.gov.uk
What will happen next?
1.17 A summary of responses, including the next steps will be published on the
Department's website at http://www.dft.gov.uk/consultations/closed/thirddirective. Paper
copies will be available on request.
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2. Executive Summary
2.1 Mopeds, motorcycles, tricycles and quadricycles
2.1.1. From 19 January 2013 mopeds will be subject to EU driver licensing rules for the first
time, bringing all other Member States closer to our existing practice in this respect. New
vehicle categories relating to mopeds, motorcycles (with or without a sidecar), motor tricycles
and quadricycles will be introduced, as shown in the table immediately below. To protect our
long standing road safety arrangements, the minimum driving ages will be those shown in the
column on the right.
Category Specification GB minimum driving age
AM Mopeds. This category also includes small tricycles and 16 years
light quadricycles
A1 Light motorcycles. This category also includes light 17 years
tricycles
A2 Mid range motorcycles. 19 years
A Unrestricted large motorcycles. This category includes 21 years (24 years if Direct
large tricycles Access)
2.1.2. We seek views about our proposals
to create special provisions for access to category AM and A for physically disabled
riders;
not to grant further additional categories of entitlement.
2.1.3. We also seek views on whether we should continue to grant new licences for a
separate category for quadricycles (B1), with associated qualification arrangements.
2.2 Testing and training
2.2.1. The new Directive provides that, to drive a car towing a medium-sized trailer or to
qualify at age under 24 to ride a more powerful motorcycle,, a candidate should either pass a
practical driving test or undertake a minimum seven hour training course. Member States can
decide which route (test or training) they wish to offer in their territory, or they can decide to
offer candidates both options.
2.2.2. We do not expect many motorcyclists to use the new progressive route to larger
machines, as it is also possible, for those aged 24 and over, to qualify directly for the most
powerful motorcycles by passing a test. From current experience, we estimate that about
80% of riders will obtain direct access (via a test) to their preferred motorbike category. We
estimate that only about 12,000 mostly younger riders a year will want to progress to a more
powerful category through the progressive test or training route (the main benefit of this route
is that riders can progress to the most powerful category of motorcycle by age 21, rather than
24).
2.2.3. DSA will anyway need to develop suitable test systems for direct access to all three
categories of motorcycle 2 , and practical tests will also be available to those seeking to
progress through the categories.
2.2.4. The main question therefore is whether we should, in addition, offer the training option
for progressive access.
2
motorcycles up to 11kw; motorcycles between 11 and 35kw; motorcycles above 35kw
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Motorcycling interests are strongly in favour of the training option to upgrade licences
because they consider it could be more effective in improving young riders’ skills and
attitudes than the practical test of skills and behaviour which the EU has prescribed,
leading to fewer casualties. It might be considered as being more in line with our wider
approach to improving driver and rider training and testing supported by lifelong learning
as set out in the Learning to Drive consultation.
However, the training option would be expensive for DSA to introduce and administer
– we estimate over £9m over the first seven years (mainly on IT to support data
collection and transfer, and on quality assurance arrangements). DSA would need to
recover that cost, meaning an annual fee of around £800-£1,300 for participating
trainers. They would recoup this fee from the trainees. The likelihood is that, for
trainees, the training course would be significantly more expensive than the test.
There is also a risk for DSA in that, if trainer participation is lower than foreseen, DSA
would not be able to recover all its set-up costs. DSA’s fees would have to rise to
cover the shortfall.
2.2.5. It might, however, be possible to gain the benefits of enhanced training within
progressive access whilst retaining the assurance on standards provided by the practical
test.
We could provide that, rather than take a normal compulsory basic training (CBT)
course course when they reached the minimum age for access to the next-larger
category of machine, progressive access trainees should take a familiarisation course
for riders to validate their provisional licence entitlement to the higher category.
This sort of course would not need the same expensive IT support or quality
assurance systems that would be needed for a training event to validate a full licence.
2.2.6. We seek views both about the possibility of a training option for progressive access to
the larger motorcycles, and about the idea of substituting for CBT in the test-based
progressive access route a familiarisation course with the larger category of machine.
Cars towing medium trailers
2.2.7. We seek views on the question of whether to offer a training option for drivers of cars
and light vans towing medium trailers 3 . There is already a test for drivers wishing to tow
heavy trailers, and in practice any test for medium trailers would be the same. We therefore
propose not to have a separate test for medium trailers but to continue to offer only the heavy
trailer test, which when passed will allow drivers to tow both medium and heavy trailers.
2.2.8. Given that we expect very few drivers to seek an entitlement to tow medium trailers,
offering a training route would carry even greater cost and risk implications for DSA as the
motorcycle training route described above.
2.3 Driving examiners
The new Directive introduces EU standards for the initial qualification, quality assurance and
periodic training of examiners conducting practical tests for licence acquisition. Although the
new EU provisions are very largely in accordance with DSA practice, some changes will be
required to the future arrangements for driving examiners. The new standards will apply to
3
“Medium” and “heavy” refer to the total weight of the vehicle plus trailer. To illustrate, a Ford Mondeo towing a
standard caravan (e.g. Sprite Musketeer) would fall below the “medium” threshold and could be driven with an
ordinary licence; a Landrover Discovery towing the same caravan would be caught by this new “medium”
category; a Ford Transit towing the same caravan is in the existing “heavy” category.
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all driving examiners, not just those employed by DSA. We seek views on the proposed
changes.
2.4 Driving licence issue and renewal
New EU-wide requirements are introduced for the administration of the driving licence
system. These include mandatory issue from January 2013 of all licences in photocard form,
with specified periods of administrative validity. Our existing practice is largely in accordance
with the new EU requirements, but some adjustments and changes will need to be made, on
which we seek your views.
2.5 Cost of implementation
2.5.1. The estimated cost of implementing the Directive is £10 million for developing the
necessary systems and annual operating costs of £2.1 million thereafter. These figures would
rise to £14.9 million and £3.1 million respectively if the training options were taken up (2009
prices). There are some uncertainties, in particular in respect of the new regime envisaged
by the Directive for international licence checks, which cannot yet be fully costed. We plan
to continue current practice in this respect until such time as the EU driving licence network
set up for these purposes is operational. The European Commission has yet to produce a
technical specification for this network, and the number of enquiries DVLA will receive from
other States cannot yet be predicted. More information on costs (taking account of forecast
inflation) is contained in the Impact Assessments at Annex H.
2.5.2. We touch briefly in this consultation document on other more far reaching options for
implementation. For instance, it is possible to require a medical report for each 5 yearly
administrative renewal for drivers of large vehicles – an option which would cost more than
£14m per annum overall. We are clear that such costs, in return for limited benefits, are
disproportionate and not viable.
2.5.3. DSA envisages absorbing, through its value for money efficiency programme, the cost
of changes to driving examiner training (equivalent to 33p per practical test from 2013) and
the cost related to the practical motorcycle test changes (equivalent to £3 per test from
2013). DVLA’s costs will be funded either through increased fees for driving licence
applicants or efficiency savings or both.
2.5.4. DVLA pools the costs of running the driver registration/licensing system and the
vehicles registration system, and it covers both those costs from the total fee income. We
intend that costs incurred from implementing this Directive will be funded from the total fee
income. This consultation is based on the current fee structure and any changes to that
structure would be the subject of separate consultation exercises.
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3. Changes affecting training and testing for riders of mopeds and
motorcycles
3.1 Topic No.1: New EU moped category
Requirements of the new Directive
3.1.1. The Directive brings mopeds into the common European driver licensing regime for the
first time. The EU definition of a moped is shown below. 4 .
EU definition of a moped
The Directive defines a moped as follows:
a 2-wheeled vehicle with a maximum design speed over 25km/h (15.5 mph) but not more
than 45km/h (28 mph); or
a 3-wheeled vehicle with a maximum design speed over 25km/h (15.5 mph) but not more
than 45km/h (28 mph) – and up to 50cc and below 4kW or
a light quadricycle - unladen mass under 350 kg and up to 45km/h (28 mph).
3.1.2. The Directive sets:
a standard minimum driving age for category AM at 16 years 5 , and
a minimum standard for a test of competence to ride a moped which involves passing
a theory test 6 .
Options allowed in the new Directive
3.1.3. Individual Member States may:
require applicants to pass a test of skills and behaviour (ie a practical driving test) and
meet medical standards for accessing this category 7 ;
introduce a domestic category comprising light tricycles and quadricycles within
category AM and impose a distinctive test of skills and behaviour for access to this
category, and put a national code on the driving licence to show these restricted
entitlements 8 ;
lower to 14 years or raise to 18 years the minimum age for a rider in this category9 .
Our proposed implementation
3.1.4. We have no plans to dilute our current arrangements which are designed to protect
the safety of moped riders and others. We propose to maintain our existing minimum age of
16 years as well as the requirements to successfully complete a CBT course to validate the
provisional licence so as to allow the learner to train on the road; and to pass a driving test
before obtaining a full moped licence. The driving test includes passing a theory test (with a
hazard perception-test) and a two-part test of skills and behaviour (an off-road test of specific
manoeuvring skills and a general on-road riding skills test).
4
Article 4(2)
5
Article 4(2)
6
Article 7(1)(b)
7
Article 7(1)(b)
8
Article 7(1)(b)
9
Article 4.6(a)
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3.1.5. Our current driver licensing arrangements include all mopeds with a design speed up
to the EU limit of 45 km/h (28 mph) and do not distinguish between those with a design
speed under or over 25 km/h (15.5 mph). We propose to continue to require driver licensing
for these light mopeds by introducing a new domestic category for mopeds with a design
speed of up to 25 km/h alongside the new EU category AM covering those between 25km/h
and 45km/h. Entitlement to ride these light mopeds will be granted together with category
AM entitlement.
3.1.6. We see no road safety or customer service reasons for having a qualification process
for the domestic category separate from that for category AM or for issuing a licence with just
the domestic category of moped entitlement. This would increase the complexity and cost of
the driver licensing system with no significant benefit. The costs would have to be recovered
from a very small number of applicants. Keeping a unified licensing and qualification
procedure will be easier to understand and cheaper for users.
3.1.7. Learners seeking a full category AM licence will be able to take their practical test
using any two-wheel vehicle within the AM category, akin to our current minimum test vehicle
(MTV) standards for a practical moped test.
3.1.8. We see no significant road safety advantages in introducing a domestic sub-category
with its own test for light tricycles and quadricycles as the new Directive obliges us to grant
full entitlement to ride such machines to those who pass their test using a two-wheel moped.
3.1.9. Nor do we see a persuasive customer service case for introducing such a sub-
category. We envisage that the demand for the relevant test would be very low. Alterations
would have to be made to IT systems and administrative arrangements. Recovering those
costs from the customer would make a bespoke test very expensive.
Question 1: Do you agree with our proposals for moped licensing?
3.1.10. We propose, however, that in line with legal obligations 10 and our approach to equal
opportunities and social inclusion, riders with a physical disability that limits their use of a
moped to a machine with three or four wheels should be allowed to take their test using a
vehicle that comes within new EU category AM. We have approached the European
Commission about this 11 .
3.1.11. The full licence issued subsequently would not entitle the holder to ride a two-wheel
moped, and a national code would be placed on the licence to denote the restricted
entitlement granted. This entitlement would apply only within the UK. The costs of making a
special provision would be covered across the cost of the service generally and recovered
from all moped test fees.
Question 2: Do you agree with our proposals for special provision for moped
riders with a physical disability?
10
Disability Discrimination Act 2005
11
Under Article 5(2)
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3.2 Topic No.2: New categories of motorcycles – A1, A2 and A
Requirements of the new Directive
The new EU motorcycle categories
category A1 –
o motorcycles up to 125cc/11kW with a power/weight ratio not exceeding 0.1 kW/kg (including
motor tricycles up to 15kW);
o a standard minimum age of 16 years, with an option to raise to 17 or 18 years;
o a qualifying process involving passing theory and practical tests.
category A2 –
o motorcycles up to 35kW a power/weight ratio not exceeding 0.2kW/kg and not derived from a
vehicle of more than double its power;
o a standard minimum age of 18 years, with an option to raise to 19 or 20;
o those seeking a full category A2 licence having previously held a full category A1 licence for a
minimum of 2 years (ie progressive access), must demonstrate competence to ride the larger
machine via a practical test or approved training;
o those seeking a full category A2 licence without previously holding a category A1 licence (ie
direct access), or held such a licence for less than 2 years (ie accelerated access), must
satisfy the minimum age requirements for category A2 and pass the relevant theory and
practical tests;
category A –
o unrestricted motorcycles above 35kW (including tricycles over 15kW)
o a standard minimum age of 20 years, with an option to raise to 21 or 22
o minimum age 24 years for direct access
o those seeking a full category A licence must satisfy the minimum age requirements for
category A, have held a full category A2 licence for a minimum of 2 years (ie progressive
access), and demonstrate competence to ride the larger machine via a test or approved
training.
3.2.1. The Directive:
redefines categories of motorcycles (with or without a sidecar) for driver licensing
purposes, amending the types of vehicles contained within those categories;
requires for young riders a staged, progressive access to progressively more
powerful machines having regard to:
age;
previous experience gained riding less powerful machines; and
competence demonstrated riding the higher category.
offers applicants who satisfy the minimum age requirement direct access to a full
category A2 licence;
raises the minimum age for direct access to a full unrestricted (category A) licence
from 21 to 24 years.
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Options allowed in the new Directive
3.2.2. Member States may:
raise the minimum age for category A1 to 17 or 18 12 . However a Member State must
impose a two year period between the minimum age for categories A1 and A2, and a
two year period between the minimum age for categories A2 and A 13 ;
determine the qualifying event (passing a practical test or completing a period of at
least seven hours training) for those riders wishing to upgrade their full motorcycle
entitlement from A1 to A2, or from A2 to A, by a progressive access route 14 ;
allow those seeking a full category A licence without previously holding a full category
A2 licence for two years to do so from a minimum age of 24 years 15 . Such Direct
Access learners must pass a relevant theory and practical test;
allow special provisions for the armed forces 16 .
Our proposed implementation
(i) Minimum driving ages
3.2.3. We have no plans to change our general principles for novice motorcyclists which, to
protect their safety, have been for many years that the minimum age for riding motorcycles is
17 and the youngest riders should not normally ride a machine with an engine capacity of
more than 125cc. Since 1996 our engine capacity for a learner motorcycle has been aligned
with the upper limit for EU category A1. This remains true, so we do not plan to alter the
minimum age of 17 for access to category A1.
Category Specification GB minimum driving
age
A1 motorcycles up to 125cc/11kw with a power/weight ratio not 17 years
exceeding 0.1 kW/kg (including tricycles up to 15kW)
A2 motorcycles up to 35kw a power/weight ratio not exceeding 19 years
0.2kW/kg and not derived from a vehicle of more than double its
power
A unrestricted motorcycles above 35kW (including tricycles over 21 years (24 years if
15kW) Direct Access)
3.2.4. Within progressive access, the Directive’s rule of a minimum two years experience
(with a full licence) at each successive stage can be waived provided the applicant:
satisfies the relevant minimum driving age; and
passes the direct access theory and practical tests.
This process is described as “accelerated access”.
3.2.5. We make special allowances for the armed forces in our application of existing EU law
on driver licensing, recognising their special operational requirements. Armed forces
personnel are allowed to ride the largest motorcycles from age 17 years. We have no plans
to amend this provision.
(ii) Direct access to higher entitlements
12
Article 4(6)(c)
13
Article 4 (6) (c) & Article 7(1)(c)
14
Article 7(1)(c) and Annex VI
15
Article 4(3)(c)(i)
16
Article 4(5)
16
3.2.6. Medium sized machines. A learner who is aged 19 years or over and who wishes to
obtain a full licence to drive medium-sized machines (category A2) without following the
progressive access route will be able to do so by passing the specified theory and practical
tests.
3.2.7. Unrestricted machines. Under the new Directive, Member States will still be permitted
to introduce direct access arrangements allowing riders to obtain unrestricted motorcycling
entitlement (i.e. category A) without going through progressive access, provided those riders
pass the appropriate theory test and practical test. But the Directive imposes two conditions:
applicants must be aged at least 24 years 17 ; and
the motorcycle used for the test must be at least 600cc and 40kW power output) 18 .
3.2.8. Our existing direct access scheme under current EU law is the major route to obtain a
full motorcycle licence in GB. Around 80% of motorcycle candidates qualify using that route
as
shown in the following table. We expect this pattern to continue.
Age of practical motorcycle test candidates: 01/04/2008 – 31/03/2009
Age Range Category A1 Learner Sub-Total Direct access Total
motorcycle
(max 125cc)
17 – 19 203 8891 9094 9094
20 – 21 63 2768 2831 4200* 7031
22 – 23 24 774 798 6962 7760
Sub total < 24 290 12433 12723 11162 23885
24 > 680 385 1065 67812 68877
Total all ages 970 12818 13788 78974 92762
*Figure relates to candidates aged 21 only
3.2.9. We shall therefore continue to allow a direct access route to unrestricted category A
entitlement. The new Directive permits Direct Access to medium-sized machines (Category
A2) for those aged 19 years or over. However, the minimum age for Direct Access to an
unrestricted machine will be raised to 24 years in accordance with the new EU requirement.
(iii) Progressive access to higher entitlements
3.2.10. The new EU progressive access rules impose minimum ages on persons under the
age of 24 years who wish to ride more powerful motorcycles. These younger riders will be
obliged to qualify and gain experience first of all riding a less powerful machine.
3.2.11. Though the motorcycle market may change, we do not envisage that the progressive
access route will be used by most motorcyclists in GB. Nevertheless we must provide for
appropriate qualifying events for upgrade. These qualifying events must satisfy two key
conditions.
we must be confident that persons are granted a full licence for a category only when
they have clearly demonstrated appropriate competence; and
we need to be confident that any arrangements will be supported by an adequate
nationwide service to which the public can have access.
3.2.12. Practical test for progressive access.
our standard process for ensuring applicants for a full licence have the relevant
competence is by passing a suitable test conducted to fair and consistent levels 19 .
17
Article 4.3(c)
18
Annex II B. point 5.2
17
DSA will, as the competent authority, provide practical test arrangements for
candidates wishing to obtain full motorcycle licences under the Directive, including
those upgrading their motorcycle entitlements.
this will ensure that there is service availability for progressive access.
current arrangements for booking and taking tests will apply where practicable, subject
to the Directive’s minimum test vehicle (MTV) standards for practical tests 20 .
3.2.13. Training option for progressive access. Member States are permitted to offer
training alone as the qualifying event, using a suitably sized motorcycle. Such an alternative
would involve undertaking at least seven hours of approved training.
3.2.14. Motorcycling representative organisations have indicated a wish that we should make
a training route available for upgrade by progressive access. DSA has investigated what a
training route for licence upgrades could entail.
A training course as a qualifying event?
We envisage that the training course offered as a route for obtaining a motorcycle licence upgrade
would :
be competence-based, focussing on providing riders with the knowledge and skills to handle
a more powerful motorcycle;
be delivered in modular format with particular emphasis on the various key differences such
as machine type, handling characteristics and additional safety features that exist;
last a minimum seven hours which could be organised in smaller units, though to protect
training validity each session would have a minimum duration of two hours;
follow an initial assessment of a trainee’s skill level, that enabled the instructor to tailor a
course to the needs of the individual;
be successfully completed within six months of commencement of the training programme;
and that
provide an auditable record to ensure that the trainee has demonstrated each element of
competence.
3.2.15 In Annex B1 we set out some relevant considerations. Our working conclusion is
that, purely on the considerations arising from the implementation of the Third Directive, a
training option as the qualifying event under the terms of the Directive is unlikely to be
economically viable.
3.2.16. However, we recognise that a route involving progressive stages of training could
offer greater benefits in improving young riders’ skills and attitudes than simply relying on the
validation of standards provided by a practical test of skills and behaviour. This is in line with
our wider approach to improving driver and rider training and testing, supported by lifelong
learning, as initially set out in the Learning to Drive consultation in 2008 and our broader
plans to improve motorcycle training.
19
our driving tests have been developed to underpin higher standards. From 30 April 2009 the practical motorcycle test is
conducted in 2 modules and contains new and more demanding manoeuvres. From 28 September 2009 the theory test
contains case studies providing a more thorough assessment of understanding of driving theory and road safety.
20
category A1: motorcycle without sidecar, with an engine capacity of at least 120cm3, and capable of a speed of at least
3
90km/h. Category A2: motorcycle without sidecar, with an engine capacity of at least 400cm , and an engine power of at
least 25kW. Category A: motorcycle without sidecar, with an engine capacity of at least 600cm3 and an engine power output
of at least 40kW.
18
3.2.17. We could therefore provide for a familiarisation training course at each level within
progressive access. As well as offering potential safety benefits, these courses could
validate provisional entitlement to ride a larger motorcycle at each stage. They would help
provide a simple and user-friendly way of granting provisional entitlement at different levels 21 .
Attaching a two-year validity to course completion certificates would encourage trainees to
become fully qualified within that time and not remain permanent learners indefinitely. Such
familiarisation courses might serve as first modules in training courses satisfying a qualifying
event for a full licence within progressive access, were the training option for upgrading within
progressive access to be introduced at any stage.
Question 3: Do you consider that a training route should be offered to allow
motorcycle licence upgrades?
Question 4: 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?
Question 5: Do you agree with our proposals for a familiarisation training
course within progressive access arrangements?
Provisional entitlement and training
3.2.18. Provisional licensing arrangements will be needed to enable riders to prepare for their
direct access test or progressive access upgrade. We plan to put in place arrangements that
minimise the cost and inconvenience to riders. to continue driving as a learner. Annex C
sets out in detail how we envisage provisional licensing will operate for the different
categories of powered two-wheelers.
Question 6: Do you agree with our approach to provisional licensing for
moped and motorcycle learners?
3.2.19. We are separately committed to improving the training arrangements for all learner
riders. During the informal discussions whilst preparing this consultation paper, motorcycle
interest groups indicated that they wished this paper to signal how the training aspects of the
Directive would fit within our wider approach toward improved arrangements for motorcycle
training. This goes beyond the immediate implementation of the Directive. We have,
however, set out our initial thinking in Annex D.
21
Like all provisional entitlements, it will appear on the licence counterpart 3.2.19
19
3.3 Topic No.3: Access for physically disabled riders
Options allowed in the new Directive
3.3.1. The Directive allows a Member State, with the agreement of the European
Commission, to make special provisions to meet the needs of physically disabled persons 22 .
Our proposed implementation
3.3.2. Stakeholders have advised that motorcycles and motor tricycles designed or adapted
to accommodate a wheel chair for a person with a physical disability are often heavier and
more powerful than the specifications for motorcycles in categories A1 and A2.
3.3.3. In line with our policies for equal opportunities and social inclusion, we propose to seek
the agreement of the Commission to use the flexibility offered by the Directive to allow a
minimum driving age of 17 years for physically disabled persons to ride suitably adapted
tricycles or motorcycle sidecar combinations. This will involve:
setting a lower-than-normal minimum driving age for these vehicles;
waiving the normal staged access arrangements for such vehicles; and allowing such
vehicles to be used for the practical test, rather than two-wheeled motorcycles as
normally.
3.3.4. Persons who obtain this restricted entitlement will have it noted by the entry of a new
domestic code on their driving licence restricting them to riding certain types of vehicles - i.e.
a tricycle or a motorcycle and sidecar with adaptations.
3.3.5. This special provision would not be recognised in other Member States until the rider
had attained the minimum age for the category of tricycle/motorcycle set out in the Third
Directive.
Question 7: Do you agree with our proposal to make special provisions for
motorcycle riders with a physical disability?
3.4 Topic No 4: Areas where we propose no change
In several areas concerned with mopeds and motorcycles, the new Directive opens up
possibilities for change which we do not propose to exercise, either because we see no road
safety benefit, or because we believe that the costs would outweigh any marginal benefit
achieved. These are as follows:
Riding mopeds using a licence for another category of vehicle;
Introducing a distinctive practical test for tricycles and quadricycles (the new EU
arrangements for tricycles and quadricycles are set out at Annex E); and
Riding motorcycles using a car driving licence.
22
Articles 4(5) and 5(2)
20
4. Changes affecting training and testing for the drivers of cars and
light vans
4.1 Topic No. 5: Changes affecting category B1 (light cars, tricycles and
quadricycles)
Requirements of the new Directive
4.1.1. Under current EU law three-wheel motor vehicles and quadricycles form category B1.
However, under the new Directive, only full powered 23 quadricycles would fall into
category B1. Small tricycles and light quadricycles fall into category AM, light tricycles
into category A1, and more powerful tricycles into category A.
4.1.2. The new Directive sets the standard minimum age for driving vehicles in category B1
at 16 years.
4.1.3. A theory and practical test must be passed to qualify for a full category B1 licence.
Options allowed in the new Directive
4.1.4. As with current EU law, the Directive gives each Member State a flexibility 24 whether
or not to issue separate licences for category B1, Where a Member State chooses not to
issue B1 licences then access to driving vehicles in category B1 will be, as now, by obtaining
a category B licence.
4.1.5. The Directive allows Member States to set the minimum driving age for category B1 up
to 18 years.
Our proposed Implementation
4.1.6. In 1996, when the existing EU law came into force, we chose to introduce sub-category
B1 as a separate driving licence category. At that time, vehicles that met the special needs
of physically disabled drivers were often lightweight three-wheel cars (and so fell within the
current category B1). Users wanted a full licence for such vehicles but not for a full-sized car
(i.e. category B). Representatives of these interests have advised that this is no longer so –
and modern vehicles used by physically disabled people are four-wheel and sufficiently
heavy that they fall into category B, not category B1.
4.1.7. In these circumstances, we see no reason to retain category B1 as a separate
category. Drivers who already hold full B1, but not full B, entitlement will have their B1
driving entitlement preserved.
Question 8 Do you agree that we should cease to issue separate category B1
licences to new drivers?
23
Quadricycles with a mass of at least 350kg and a power output in excess of 4kW
24
Article 4(4)(a)
21
4.2 Topic No 6: Changes affecting cars and light vans towing trailers
Requirements of the new Directive
4.2.1. The new Directive amends the rules for driving cars and light vans towing trailers 25 :
new conditions have to be satisfied in order to acquire entitlement to tow medium-
sized trailers on a Category B licence. Category B entitlement automatically includes
towing small trailers. To tow a large trailer, a Category B+E licence is still required.
But an intermediate trailer-size has been introduced (restricted to combinations not
exceeding 4250kg) - referred to in this consultation as category B96 26 ;
an upper limit is placed on the combined Maximum Authorised Mass (MAM) of
category B+E entitlement of seven tonnes 27 ;
a standard minimum age to drive category B+E is set at 18 years.
Cars and light vans towing trailers
The new rules provide that:
motor vehicles in category B are allowed a maximum authorised mass (MAM) not exceeding
3500kg and may be combined with a trailer having a MAM which does not exceed 750kg;
subject to type approval rules motor vehicles in category B may be combined with a trailer
exceeding 750kg as long as the MAM of the combination does not exceed 3500kg:
motor vehicles in category B may tow a trailer with a MAM exceeding 750kg provided the
combined MAM of the vehicle + trailer does not exceed 4250kg and the driver has qualified
for B96 entitlement;
if the combined MAM of the motor vehicle in category B plus trailer exceeds 4250kg then the
driver needs category B+E entitlement;
an upper limit is placed on the combined weight of category B+E entitlement of 7000kg
MAM (category B vehicle up to 3500kg plus a trailer up to 3500kg):
the standard minimum age for category B+E is set at 18 years.
Options allowed in the new Directive
4.2.2. A Member State may
require that to qualify for B96 entitlement a driver must, using a suitable vehicle-trailer
combination:
o pass an appropriate practical test; or
o complete a period of approved training of minimum duration of 7 hours; or
o complete the training and pass the test. 28
lower the minimum age for a category B+E licence to 17 years 29 .
Our proposed implementation
(i) Qualification arrangements for B96 entitlement
4.2.3. Under the new Directive, new drivers seeking B96 entitlement will have to demonstrate
competence, and the Directive allows each Member State to choose the nature of the
qualifying event..
25
Article 4(4)(b) and (c)
26
drivers who obtain this category of entitlement will have an EU code 96 entered on their driving licence as set out in Annex
I to the new Directive, paragraph 3(d) 9(a) 12.
27
To drive larger combinations, a C1 + E or C + E licence will be required
28
Article 7(1)(d) and Annex V
29
Article 4(6)(d)
22
4.2.4. We expect very few drivers will seek B96 entitlement. It offers relatively little in
addition to Category B entitlement. Our expectation is that any person willing to invest in
seeking more entitlement than allowed under category B will seek entitlement to drive the
much larger range of trailer combinations offered by a category B+E licence.
4.2.5. DSA will, as the competent authority, have practical test arrangements available for
drivers wishing to have B96 entitlement, ensuring that there is service availability. Current
arrangements for booking and taking tests will apply as relevant. Provisional entitlement for
B96 will be issued along with provisional entitlement for B+E when a full category B licence is
granted.
4.2.6. DSA does not propose to provide a test solely for category B96 entitlement. It would
be indistinguishable from the practical test that must be passed for a full category B+E
licence. Therefore it will be better customer service for the test offered for B96 entitlement to
be the practical test for B+E entitlement.
4.2.7. Some stakeholders have indicated a wish that we should make available a training
option for those drivers who wish to upgrade to B96 entitlement.
4.2.8. We have investigated what a training route for B96 entitlement could entail and would
welcome wider views. Currently, training to drive B+E vehicle combinations is unregulated.
Training services are often offered by providers who train drivers of lorries and lorry plus
trailer combinations, as they have off-road training facilities. We outline in Annex B2 some
of the considerations around providing a training-only route for obtaining entitlement to tow a
medium-sized trailer behind a car or light van.
A training course offered as a qualifying event for obtaining B96 entitlement would be as follows;
competence-based, focussing on providing drivers with the knowledge and skills to drive a car or
light van towing a larger trailer;
the minimum seven hours could be organised in smaller modules, though to protect training
validity each session would be a minimum of two hours in duration;
the training would include an auditable record to ensure the trainee had demonstrated each
element of competence before moving onto the next;
the course would have to be successfully completed within six months of commencement of the
training programme;
at the successful conclusion of the course, the trainer would certify that the trainee had
demonstrated the necessary competences which will entitle the trainee to upgrade their licence.
4.2.9. We should need to be confident of the standards of training and trainers before
allowing a training course to be a qualifying event granting licence entitlement. Such
systems are not currently in place. To protect road safety, appropriate standards assurance
arrangements would need to be introduced. Trainers and courses would be approved by
DSA.
4.2.10. Because of these considerations, the cost aspects of a “training only” route to qualify
to tow a medium sized trailer behind a car or light van would be similar to those outlined at
2.2.4 above in relation to progressive motorcycle access. DSA costs incurred in installing
and operating the new arrangements would be recovered through user charges. We estimate
that cost recovery over the first seven years of operation would, depending on the delivery
details, be equivalent to an annual registration fee in a range between £800 - £1300 for each
instructor authorised to undertake qualifying events. Those costs would be factored into the
charges to trainees for training services. Further information about indicative costs is included
in the relevant Impact Assessment attached at Annex H.
4.2.11. We have no plans that entitlement to drive B96 combinations would require the
candidate to undertake both training and a test.
23
Question 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?
Question 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?
(ii) Minimum driving age for driving vehicles in category B+E
4.2.12. Raising the minimum driving age for category B+E to 18 years might affect the
employment opportunities of young people seeking jobs that involve towing plant. We have
no plans to make this change in GB. The minimum age for obtaining a provisional or full
category B+E licence in GB will therefore remain at 17 years.
24
5. Changes affecting driving examiners
5.1 Topic No 7: Changes affecting driving examiners
Requirements of the new Directive
5.1.1. The new Directive introduces European standards for the initial qualification, quality
assurance and periodic training of examiners authorised to conduct practical tests for licence
acquisition 30 . These are broadly in accordance with our existing practice.
5.1.2. Examiners already working in that capacity before 19 January 2013 will not be subject
to its requirements for initial qualification.
5.1.3. The new Directive requires 31 the competent authority in the jurisdiction (DSA in GB) to
ensure that these standards are met for all examiners conducting licence acquisition tests,
whether the examiners are employed by the competent authority or by other organisations 32 .
The main provisions:
establish standard criteria for all examiners entering the occupation;
o setting a minimum age of 23 years for examiners;
o requiring applicants to have held a category B licence for a minimum of 3 years;
o completed a vocational education to at least Level 3 33 (i.e. completed their secondary
school education);
specify an initial qualification process for all examiners;
set additional standards for those conducting practical tests for licences to drive motorcycles,
lorries and buses;
allow acquired rights for existing examiners in respect of the Directive’s entry requirements;
specify quality assurance arrangements for all examiners to ensure they are supervised at
work (minimum half a day every 5 years);
specify periodic training requirements for all examiners to:;
o maintain and refresh examining skills (at least 4 days in two years);
o develop and maintain the necessary practical driving skills (at least 5 days in 5 years).
prohibit an examiner from also being active in commercial driving instruction.
5.1.4. Annex F sets out considerations relevant to our proposed implementation of the new
requirements. Broadly, practice will remain much as at present.
5.1.5. We intend that the current DSA quality assurance scheme for delegated examiners –
those employed by organisations other than the DSA itself - will be expanded to include the
inspection of periodic training records. The Directive does not specify a format or system for
recording this training and we propose that each organisation employing examiners will hold
its own records and that these will be made available for inspection by DSA as necessary.
5.1.6. Regarding examiners employed by the Ministry of Defence (MoD), we shall keep
under review DSA’s existing quality assurance arrangements as set out in the relevant
memorandum of agreement, but we have no current plans to alter them.
5.1.7. We propose therefore to make it a condition of approval for all organisations that
appoint examiners that are authorised to conduct licence acquisition tests that:
30
Annex 4
31
Annex 4.1.1.
32
Practical examiners also employed by MoD, police and fire authorities and bus and coach operators to conduct practical
driving tests for staff in their organisations
33
Level 3 as defined by Decision 1065/2008/EEC
25
each examiner for which they are responsible receives the appropriate amount of
periodic training;
they maintain the relevant training records; and
those records of periodic training for each examiner are complete and readily available
for inspection by DSA.
5.1.8. Enforcement would operate in the way it does for existing conditions of appointment.
Powers are already contained in domestic legislation 34 for DSA to take action concerning
those bodies which do not meet the conditions of approval.
Question 11: Do you agree with our proposal to amend the conditions of
approval for organisations with examiners as regards the
maintenance of records of supervised tests and undertaking
periodic training?
34
The Motor Vehicles (Driving Licences) Regulations 1999
26
6. Changes affecting driving licence administration
6.1. The following chapter explains our proposals for implementing the licence
administration provisions of the third EU driving licence Directive. Please read in conjunction
with the relevant Impact Assessments in Annex H, and please answer Question 12.
6.2. As a general approach, we shall take up those options that are in line with current
practice in Great Britain, reduce the impact of the Directive on our customers, and continue
practices which support road safety strategies.
6.3 Topic No 8: Mandatory changes to the administrative validity periods
of Group 1 photocard licences
Scope: drivers of small vehicles (2, 3 and 4 wheeled mopeds motorcycles,
tricycles, quadricycles, cars and light vans)
Current position
6.3.1. Licences (including photocard licences) for Group 1 drivers give an entitlement to drive
up to the driver’s 70th birthday, unless a short period licence is issued for medical reasons.
The photocard licence also contains an administrative validity period, the start and end dates
of which are shown at fields 4a and 4b on the front of the card. The administrative validity
dates are currently determined as follows:
a driver is granted a first British provisional (learner) photocard licence with a ten
year administrative validity period;
on passing a driving test, the subsequent full photocard licence issued is valid for
the remainder of the original ten years;
replacement full driving licences issued during the ten-year lifetime of the card, e.g.
because the person changes address or misplaces their licence, are always issued
for the remainder of the original ten years;
on expiry of the ten-year period, the driver is invited to make an application
submitting a new photograph and a new ten-year full photocard licence is then
issued;
the administrative processes do not impact on the entitlement to drive, which is
shown on the reverse of the photocard licence.
6.3.2. 10-year licences are issued continuously until the driver reaches age 70, when a driver
has to renew his driving entitlement. Thereafter, drivers have to renew their licences every
three years.
6.3.3. Drivers confirm their compliance with medical standards for fitness to drive when they
take out their first licence. Thereafter, they have an ongoing requirement to notify DVLA if
they develop a condition that could affect their ability to drive safely. Making a false
declaration on the application form or failing to notify relevant conditions are both offences for
which drivers could be prosecuted.
6.3.4. Drivers with certain medical conditions may be issued licences for short periods (one
to three years) so that the condition can be kept under periodic review by qualified medical
advisers.
27
New EU provision
6.3.5. From 19 January 2013, licences issued must have an administrative validity period of
ten years. Full licences issued within the existing ten-year lifespan of an existing photograph
(for instance, that supplied for a provisional licence) would need to be valid for ten years,
from the date the full licence is granted, not ten years from the date of issue of the original
provisional licence, as now. Licences already in circulation, which do not have to be renewed
or altered for any reason which requires a new licence to be issued, do not have to conform
to this new requirement until 2033.
6.3.6. The Directive offers an option to issue licences for up to 15 years and also allows for
short period licences:
to apply medical checks or other measures;
for novice drivers;
for drivers aged over 50.
6.3.7. There is also an option to require all drivers to undergo medical examinations before
renewing their licences.
Our proposed implementation
6.3.8. Medical Examinations - we do not propose to require all drivers to undergo medical
examinations to prove fitness to drive when they renew their photocard licence every 10
years. To adopt such a stringent measure would burden drivers with significant costs (as
examinations are performed by GPs for an average fee of £100) without there being any
evidence that there would be significant road safety benefits.
6.3.9. We have already been reviewing the system in place in Great Britain for ensuring
drivers are fit to drive. This initiative has focussed on general procedures. It has not
considered specific medical conditions, age groups or the criteria and standards that are
used to determine fitness to drive but rather the way in which the standards are applied and
options for change. Any changes to the procedures for notifying medical conditions will be the
subject of a separate DVLA consultation exercise.
6.3.10. Novice Drivers – we do not propose to introduce short period licences for new
drivers, as road safety measures already exist in Great Britain. Drivers who offend within the
first two years of passing their test have their licences automatically revoked if they build up
six or more penalty points. They have to reapply for their provisional licence and retake the
driving test. Also, the Driving Standards Agency’s consultation ‘Learning to Drive’ favours
proper education and training prior to taking a driving test, as the best way to improve road
safety for newly qualified drivers.
6.3.11. Ten year Administrative Validity We propose to retain a ten year administrative
validity period for UK photocard licences issued in Great Britain until the driver reaches age
70. We do not propose taking up the Directive option of reducing validity after age 50. We
propose also to continue to issue short period licences after age 70 and for medical
purposes, as allowed by the Directive.
6.3.12. To avoid imposing a burden on drivers changing entitlement (e.g. going from
motorcycles to cars or from a provisional to a full licence), we propose to make use – when
issuing a new licence – of the existing photograph, provided this photograph is no more than
five years old. Applicants will be required to make a declaration that the photograph is still a
current likeness of them.
6.3.13. Drivers will still be required to renew their licence at the end of the ten-year period
shown on the licence.
28
Examples – example A shows how our current validity period business rules do not meet the
Directive requirements for ten-year licence administrative validity. Example B shows how we
could meet the Directive requirements with minimum impact on the customer but retaining
security of the licence system.
A – Current rules B – Proposal (re-using photograph already on DVLA
database)
Sarah applies for her provisional driving licence on 1
February 2010, supplying her photograph. The Sarah applies for her provisional driving licence on 1
photocard licence she receives shows the issue date as February 2013, supplying her photograph. The
2 February 2010 and expiry date as 1 February 2020. photocard licence she receives shows the issue date as
(Her driving entitlement until age 70 is shown on the 2 February 2013 and expiry date as 1 February 2023.
reverse of the card.) (Her driving entitlement until age 70 is shown on the
reverse of the card.)
She passes her car driving test on 1 February 2011.
DSA sends the test pass details to DVLA and a full She passes her car driving test on 1 February 2014.
photocard licence is issued to Sarah automatically, DSA sends the test pass details to DVLA and because
without the need for her to complete an application form Sarah declares that the photograph she supplied the
or supply a new photograph. The issue date shows 2 previous year is still a current likeness of her, a full
February 2011 but the expiry date remains as 1 photocard licence is issued to Sarah automatically,
February 2020 – a validity period of nine years. without the need for her to complete an application form
or supply a new photograph. The issue date shows 2
February 2014 and the expiry date shows 1 February
2024 – a validity period of ten years.
6.4 Topic No 9: Mandatory changes to the administrative validity periods of
Group 2 photocard licences
Scope: drivers of medium and large buses and lorries (from 19 January 2013
this includes cars towing large trailers)
Current Position
6.4.1. Licensing requirements for this group of drivers are already more stringent than for
drivers of small vehicles. They must submit a medical report with their provisional licence
application, completed by a qualified medical practitioner, to show that they meet the required
health standards. Unlike drivers of small vehicles who get driving entitlement until they reach
age 70, they have to renew their driving entitlement at age 45 and every five years after that
until age 65, then annually. With each application to renew driving entitlement, they must
produce up-to-date medical reports.
6.4.2. Those aged under 45 who hold a paper licence do not have to renew it until they reach
age 45. The number of Group 2 drivers still holding paper licences is diminishing. For those
with a photocard licence, photocard renewal is dealt with in the same way as for other drivers
(i.e. every ten years). However, when they reach 45 they also have to renew their
entitlement on a five-yearly basis, providing medical evidence of their fitness to drive. Drivers
29
with certain medical conditions may be issued licences for short periods (one to three years)
so that the condition can be kept under periodic review by qualified medical advisers. Any
changes to the procedures for notifying medical conditions will be the subject of separate
consultation.
6.4.3. Like other drivers, the expiry dates for the photocard licence are shown on the face of
the card, with driving entitlement validity dates shown on the reverse.
New EU Provisions
6.4.4. Photocard driving licences issued from 19 January 2013 for this group of drivers must
have an administrative validity of five years only, from the date the driving entitlement is
obtained. Administrative renewal of the photocard licence every five years will be subject to
the driver’s continuing compliance with the minimum standards for physical and mental
fitness for driving. In Great Britain, this will affect drivers under the age of 45.
6.4.5. Replacement photocard licences issued within the five-year timeframe, e.g. because
of change of address, would retain the same expiry date as the original. This is to ensure that
compliance with medical standards is checked every five years.
6.4.6. The Directive allows for short period licences to apply medical checks or other
measures, for novice drivers to aid road safety and to drivers aged over 50, to apply certain
measures (such as medical checks or refresher courses).
Our proposed implementation
6.4.7. We would start issuing five-yearly photocard licences to this group of drivers as soon
as they obtained the relevant entitlement to drive. Where applicable, we would continue to
issue short period licences for medical purposes, as allowed by the Directive.
6.4.8. Health related data (Department of Health statistics) show increasing risk of relevant
medical conditions from middle age onwards indicating that there is no need to provide
medical examinations before the age of 45. DVLA Medical Advisers believe that such a
requirement would not improve road safety and the procedure would therefore place an
unnecessary burden on drivers at disproportionate cost. In addition to this, key stakeholders
representing the road transport industry have indicated that the industry itself already takes
responsibility for assessing the fitness of its drivers. Many employers have their own
procedures in place to ensure medical fitness to drive.
6.4.9. We propose that the general procedure in Great Britain for Group 2 drivers under the
age of 45 should be that they self-declare their compliance with the medical standards on the
five-year renewal application. Making a false declaration and failing to notify a relevant
medical condition would continue to be offences liable for prosecution. Existing rules for
providing medical reports to renew driving entitlement after age 45 would continue as now.
6.4.10. There are no security reasons for insisting that this group of drivers should renew
their photographs more regularly than for other drivers. Therefore, we propose to continue
the present rules for renewing the photograph every ten years. We propose to align the
administrative renewal date and photograph renewal date to ensure that no photograph is
more than ten years old on our database and once the dates are aligned, a new photograph
will only be required for every other five-year renewal application. This is to prevent drivers
having to renew their photograph at different times to renewing card validity. Drivers would be
legally required to surrender their licence for renewal every five years even if the photograph
30
would not need to be renewed at that time. At age 45, the existing rules in Great Britain for
renewing Group 2 driving entitlement would be engaged and as now, DVLA would offer
drivers the opportunity to align entitlement and photograph renewal practices as far as
possible, for customer convenience.
Examples – example C shows how our current business rules work in respect of this group of
drivers. Example D illustrates how the rules would work after 2013, if we allowed drivers to
prove that they comply with medical standards through a self-declaration scheme rather than
a full medical examination and to provide a new photograph every ten years, rather than five.
C - Current rules D – Proposal
James passed his test for driving lorries on 1 February David passes his test for driving lorries on 1 February
2003. Because the photograph he supplied for his 2013. He receives a photocard licence automatically (re-
licence to drive cars did not expire until 1 August 2009, using his original photograph which had been on our
his new licence was issued automatically and expired database for three years). It expires on 1 February 2018
on that date (more than five years later). (five years). (If David’s photograph had been on our
database for more than five years, he would have
Several weeks before the photocard licence expired, needed a new photograph to upgrade his licence to
James applied to renew it. He completed the relevant drive lorries.)
form and supplied a new photograph. He was not
required to provide a medical report at this stage Several weeks before the photocard licence expires,
because he was under the age of 45 and was not David applies to renew it. Because he is under age 45,
suffering from a medical condition that barred him from he completes the relevant renewal form which asks him
driving. His new licence expires 1 August 2019 (ten to declare that he continues to meet the required
years later). medical standards for driving large vehicles, and he
supplies a new photograph of himself even though his
existing photograph is only eight years old (this is to
begin the alignment of photo and card expiry date). He
is issued with a new licence which expires on 1
February 2023 (five years).
When he renews the licence in 2023, he completes the
medical declaration once again (every renewal until age
45), but does not have to supply a new photograph (until
the next renewal in 2028).
6.4.11.We have no wish to introduce short period licences specifically for novice drivers or for
drivers aged over 50, as appropriate road safety measures already exist in Great Britain and
the period of validity of a Group 2 licence already reduces to one year after age 65.
6.4.12. The UK already can and does issue shorter period licences in certain medical
circumstances. This flexibility is preserved by the Third Directive and we do not propose to
change it.
Question 12: Do you agree with the approach being taken to implement the
administrative provisions of the Directive?
6.5 Further administrative provisions
The new Directive makes several other provisions as to the way the driver licensing system
should be administered. These are not the subject of our current proposals for change.
Some are not mandatory; others are in accordance with our current practice; others could
arise in future but require no change in the short term. These are set out for information at
greater length in Annex G.
31
32
List of our consultation questions
Riders of mopeds and motorcycles
Question 1 Do you agree with our proposals for moped licensing?
Question 2 Do you agree with our proposals for special provision for moped riders
with a physical disability?
Question 3 Do you consider that a training route should be offered to allow
motorcycle licence upgrades?
Question 4 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?
Question 5 Do you agree with our proposals for a familiarisation training course
within progressive access arrangements?
Question 6 Do you agree with our approach to provisional licensing for mopeds
and motorcycle learners?
Question 7 Do you agree with our proposals to make special provisions for
motorcycle riders with a physical disability?
Drivers of cars and light vans
Question 8 Do you agree that we should cease to issue separate category B1
licences to new drivers?
Question 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?
Question 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?
Driving examiners
Question 11 Do you agree with our proposals to amend the conditions of approval
for organisations with examiners as regards the maintenance of
records of supervised tests and undertaking periodic training?
Driving licence administration
Question 12 Do you agree with the approach being taken to implement the
administrative provisions of the new Directive?
33
34
Annex A
Glossary of terms
EU licence Driving licence issued by the authorities in a Member
State of the European Union or of the European
Economic Area
Non-EU licence Driving licence issued by the authorities in a country
outside the European Union or the European Economic
Area
Group 1 Small two, three and four-wheeled vehicles, including
mopeds, motorcycles, tricycles, quadricycles, cars and
light vans up to 3,500kgs and towing trailers up to
3,500kgs
Group 2 Medium and large buses with more than 9 seats,
medium and large goods vehicles over 3,500kgs
maximum authorised mass and towing trailers of any
weight. Also cars/light vans towing trailers heavier than
3,500kg
The second Directive Directive 91/439/EEC – existing European law on
standards for issuing driving licences
The third Directive Directive 2006/126/EC – new European law on
standards for issuing driving licences
Abbreviation Definition
AT Authorised Trainer
ADI Approved Driving Instructor
CBT Compulsory basic training for learner moped and motorcycle riders
DAS Direct Access Scheme
DSA Driving Standards Agency
DE Driving Examiner
DVANI Driver Vehicle Agency Northern Ireland
DVLA Driver Vehicle Licensing Agency
MAM Maximum Authorised Mass
MTV Minimum Test Vehicle
IA Impact Assessment
RPMT Register of Post Test Motorcycle Trainers
RSIS Road Safety Information System
TARS Training and Registration System
35
36
Annex B
Training route for upgrade to larger categories of motorcycle, and/or to tow medium
sized trailers behind a car or light van –
Considerations
B1. Motorcycles and progressive access
B1.1. The adoption of a training option for upgrade of entitlement in progressive motorcycle access
to the new arrangements would depend on:
the availability of public funds for building and operating the supporting systems and
the value-for money represented by the likely take-up.
Any arrangements would need to operate on a self-financing basis, with costs recovered by user-
charges.
B1.2. We have considered how we might provide such new arrangements building on the existing
statutory provisions that support the current CBT courses for learner motorcycle and moped riders,
plus the certified instructors authorised to deliver that training, and we should welcome views on this.
B1.3. The standard required from CBT training is that a rider is safe to be allowed on the road as a
learner. The standards required of training and trainers to serve as a qualifying event for granting a
licence would be more demanding. Trainers and courses would be approved by DSA. However, if
the standards required of training organisations and trainers were suitably adjusted, perhaps drawing
on currently unused powers in the Road Traffic Act 1988 35 , this training infrastructure might provide a
route for attesting that a rider has reached a standard to qualify for a full licence. This might be linked
to a wider reform of the standards of motorcycle training – see Annex D.
B1.4. If the Approved Training Bodies (ATBs) that provide CBT satisfied appropriate standards they
might be authorised to deliver the training courses to serve as qualifying events. Individual trainers
would have to meet criteria broadly similar to those required for professional car driving instructors 36
which relate to both technical competence and conduct, with a continuing requirement to comply with
standards assurance arrangements and remaining a “fit and proper” person. The Agency would
retain authority to de-register, subject to an independent appeals process, any training bodies or
individual trainers who ignored or contravened their conditions of approval.
B1.5. An initial qualification for instructors to give approved training could include suitable theory
tests plus practical tests of driving and instructional ability. DSA would offer these tests on a cost-
recovery basis 37 . We envisage offering acquired rights to the initial qualification for instructors who
had already demonstrated suitable competence as part of qualifying either:
as Certified Instructors in the Direct Access Scheme with additional modules; or
for the Register of Post Test Motorcycle Trainers (RPMT).
B1.6. The service costs relating to practical moped/motorcycle test developments will be recovered
from users via the relevant test fees charged to those candidates from the date of introduction of the
new suite of tests in January 2013. We estimate that the costs of implementation and operation 38 over
the first 7seven years of operation would, subject to fee-reduction effects of the Agency’s value-for-
money programmes, be the equivalent to a £3 increase in all fees 39 for practical moped/motorcycle
tests, or £6 for a candidate over the two practical test modules. Further details are contained in the
Impact Assessment at Annex H.
35
Section 99Z (compulsory training courses), as introduced by section 257 of the Transport Act 2000 and the new Part 5
(registration of driving instructors) as introduced by section 42 and Schedule 6 of the Road Safety Act 2006.
36
the Approved Driving Instructor (ADI) scheme, under Part V of the Road Traffic Act 1988.
37
an estimated £100 for the theory test and £120 for the practical tests.
38
largely IT development and operating costs, plus staff costs including staff training.
39
the module 1 test fee increasing from £10 to £13 and the module 2 test fee increasing from £70 to £73.
37
B1.7. DSA’s costs incurred in installing and operating the new arrangements 40 would be recovered
through user charges. We estimate that cost-recovery over the first seven years of operation would,
for viable data transfer options, be equivalent to an annual registration fee in a range £800 - £1,300 41
for each instructor authorised to undertake qualifying events. Those costs would be factored into the
charges to trainees for training services. The unit cost for each trainer would vary depending on the
numbers that participated 42 . More information about indicative costs is included in the Impact
Assessment at Annex H.
B1.8. The provision of a training route would involve commercial decisions by suppliers. DSA could
not guarantee the number of suitable training organisations coming forward, though the availability of
a test route would mitigate the risk to service availability
B1.9. The operation of progressive access arrangements will require systems to be in place to
enable, in a secure manner, information about the completion of qualifying events to be recorded and
passed to DVLA to enable the Drivers Record to be updated and DVLA to issue an upgraded licence.
B1.10. Such data transfer and data security requirements present relatively few challenges for a test-
based route to licence upgrades as robust systems are already in place though they would need
amending. But implementing a training option would require a new data transfer system between
trainers, DSA and DVLA to advise of qualifying training events. We have identified a number of viable
options for achieving this data transfer. More detail on the estimated cost of this option is shown in
the attached Impact Assessments.
B1.11. We stress that a training option will involve significant complexity and costs, for both trainers
and trainees. There are also risks for DSA, if lack of interest by trainers leads to DSA being unable to
recover its set-up costs. Any decision on the training option will need to take these costs and risks
into account, together with the availability of public money at the appropriate time.
B2. Medium sized trailers behind a car or light van
B2.1. Some stakeholders have expressed reservations about the practicalities of a training option as
a qualifying event for “B96” entitlement.
Although the Directive specifies a minimum of seven hours training, some stakeholders have
expressed the view that at least 14 hours training would be necessary for the trainee to reach
the same standard as is required to pass a practical driving test.
Some stakeholders have expressed concerns about the amount of quality assurance that
would be required for this option, and
whether providers would see a small market offering a commercial prospect.
B2.2. A training route could be acceptable provided it delivered consistent and comparable
standards. Completion of training would lead only to full B96 entitlement.
B2.3. We envisage that the prospective trainer would apply to the DSA, and pay a fee to cover
DSA’s costs. The trainer would have to meet certain criteria broadly similar to those currently
required for professional car driving instructors, including standards supervision arrangements and
being a “fit and proper” person. The Agency would take action against any trainers who ignored or
contravened these conditions. There would be an independent appeals body to review decisions
made by the Agency on a case by case basis.
40
in particular, the data transfer systems and administration needed for issuing licences, and the quality assurance
arrangements for trainers.
41
if manual systems were used for data transfer the amount could rise to £1.300.
42
also, the unit cost might be lower if this arrangement was part of a more general reform of the quality assurance of
motorcycle training – Annex C contains more discussion.
38
B2.4. Instructors might qualify to give approved training by satisfying one of the following criteria:
successfully complete a series of examinations set by DSA which will include a theory test, a
practical test of driving ability and a practical test of instructional ability;
be registered with DSA as a member of the Register of Fleet Driving Instructors;
be registered as an Approved Driving Instructor;
have defined relevant experience to carry out such training (to be determined).
B2.5. DSA costs incurred in installing and operating the new arrangements would be recovered
through user charges. We estimate that cost recovery over the first seven years of operation would,
depending on the delivery details, be equivalent to an annual registration fee in a range between £800
- £1300 for each instructor authorised to undertake qualifying events. Those costs would be factored
into the charges to trainees for training services. Further information about indicative costs is included
in the relevant Impact Assessment attached at Annex H.
B2.6. The provision of a training route would involve commercial decisions by suppliers. DSA could
not guarantee that sufficient suitable training organisations would come forward to offer a nationwide
service. Neither could the DSA guarantee minimum numbers of drivers opting to take training.
However, the availability of a test alternative would mitigate the risk to service availability
B2.7. B96 access will require systems to be in place to enable, in a secure manner, information
about the completion of qualifying events to be recorded and passed to DVLA to enable the Drivers
Record to be updated and an upgraded licence carrying the B96 code to be issued. Implementing a
training option would require a new data transfer system involving trainers. We have identified a
number of viable options for achieving this data transfer. More details on the estimated costs are
shown in the attached Impact Assessments.
B2.8. Drivers will need access to provisional entitlement to be able to prepare for the qualifying
event for B96. When drivers are granted a full licence for category B they will be granted provisional
entitlement for category B+E which will also include provisional entitlement to drive B96 vehicle
combinations. Learner B96 drivers will have to display L plates, have an accompanying driver with
B+E or B96 entitlement and will not be allowed to drive on motorways.
B2.9. We stress that a training option will involve significant complexity and costs, for both trainers
and trainees. There are also risks for DSA, if lack of interest by trainers leads to DSA being unable to
recover its set-up costs. Any decision on the training option will need to take these costs and risks
into account, together with the availability of public money at the appropriate time.
39
40
Annex C
Provisional licensing and the third Directive – how we foresee it might
work
C1. EU law on driving licences does not regulate provisional driving licences. This is true
both of the existing Directive (Directive 91/439/EEC) and of the new one. A driving licence in
EU law equates to a full driving licence in our law. Provisional licences are not driving
licences for the purposes of EU Directives and they confer no entitlement to drive outside the
United Kingdom. Therefore we retain some freedom to arrange provisional licence rules in a
manner that supports sensible learning arrangements and our road safety goals. We must,
however, ensure that our provisional licence rules are not contrary to provisions in EU law.
C2. Our provisional driving licence arrangements are an important element in the way
people learn to drive. They create an environment in which people can learn to drive and
gain experience in a safe manner.
Provisional licences – creating a safe environment to learn
Provisional licences are granted for all categories of driving entitlement. Their use is subject to
conditions that are appropriate for the category.
All learners must display L plates on the vehicles they are using.
Learner drivers (other than learner lorry, bus or coach drivers) are not allowed to drive on a
Motorway.
When driving most types of vehicle a learner must be supervised by an accompanying person,
and that supervisor must hold an appropriate full driving licence and satisfy age or experience
conditions.
Learner motorcyclists in the current GB Direct Access scheme are subject to an accompanying
person rule, and that person must be a motorcycle instructor approved for that purpose.
C3. We already ensure that our provisional licence rules do not undermine the existing
minimum driving age requirements in EU law. We set minimum driving ages for provisional
driving entitlements that respect the minimum ages for granting EU licences. We also use
the conditions attached to the use of provisional licences to prevent their use undermining the
EU qualifying arrangements for entitlement to drive.
C4. In our transposition of the new Directive we propose to achieve these objectives, as well
as supporting our efforts to improve road safety, by building on our current arrangements for
provisional licensing.
C5. We want our provisional licensing arrangements for mopeds and motorcycles to be user-
friendly, proportionate and cost-effective, but not to:
undermine the EU minimum driving age and experience requirements for progressive
access to full motorcycle entitlement;
undermine the EU minimum driving age requirements for direct access to full
motorcycle entitlements;
undermine the EU qualifying arrangements for obtaining a driving licence;
encourage riders to become “permanent learners”, who ride indefinitely on a
provisional licence.
41
Moped (Category AM) provisional licensing
C6. Currently very few riders seek a full moped licence 43 . Our plans are to implement the
new EU category retaining the same fundamental safety provisions. To ride a moped on the
road a learner will have to:
obtain a provisional AM licence (which will include all those light mopeds already
subject in the UK to driver licensing);
satisfy the minimum age of 16 years;
satisfactorily complete CBT to validate the provisional licence to ride on the road.
C7. Provisional licence holders will be able to ride unaccompanied any moped on L plates
during the two year validity period of the training certificate. If a learner does not qualify for a
full category AM licence (by passing a relevant theory and practical test) during those two
years and wishes to continue riding a moped afterwards, the learner will have to take a
refresher training course to re-validate the provisional licence for a further two years..
Small motorcycle (Category A1) provisional licensing
C8. Currently few motorcyclists in Great Britain choose to seek a full licence to drive a light
motorcycle 44 . This may change under the Directive. For persons aged under 19 seeking a
full motorcycle licence, a category A1 licence will be the only option.
C9. We plan to retain the same fundamental safety provisions as operate at present. To
drive a category A1 motorcycle on the road a learner will have to:
obtain a provisional A1 licence;
satisfy the minimum age of 17 years;
satisfactorily complete CBT to validate the provisional licence to ride on the road.
C10. These learners will then be able to ride unaccompanied any A1 motorcycle on L plates
during the two year validity period of the training course certificate. If a learner has not
passed the relevant theory and practical tests by the end of that two year period, and wishes
to continue riding the A1 motorcycle, the learner will have to take a refresher training course
to re-validate the provisional licence for a further two years.
C11.The initial training requirement will be waived for the new category A1 learner if the
person has previously qualified for a full moped licence having passed the relevant theory
and practical tests. If such a category A1 learner has not obtained a full A1 licence by the
end of a two year period and wishes to continue driving an A1 motorcycle, the learner will
have to take a refresher training course to re-validate the provisional licence for a further two
years.
Medium-sized motorcycle (Category A2) provisional licensing for a rider taking the direct
access route
C12. A person will be eligible to apply for a provisional category A2 entitlement any time
after the applicant satisfies the minimum driving age for category A2 of 19 years. The rider
will need to satisfactorily complete initial training to ride on the road. The rider will then be
able to ride any A2 machine on L plates during the two year validity period of the initial
training certificate. The person will not be allowed to ride a category A2 motorcycle on a
motorway or carry a pillion passenger on an A2 machine until qualified to hold a full category
A2 licence.
43
In 2008/9 DSA conducted 33 category P practical tests
44
Fewer than 15% of the 92,776 practical motorcycle tests undertaken by DSA in 2008/09 were for a category A1 licence
42
C13. As with the current Direct Access Scheme for category A, we propose that these A2
learners will need to be accompanied by an authorised motorcycle instructor, on another
motorcycle in radio contact with the learner, with a maximum trainee/trainer ratio of 2:1. The
learner will have to satisfactorily complete the full syllabus before taking the practical test for
an A2 licence. If a learner has not qualified for a full A2 licence (passing the relevant theory
and practical tests) within two years, the person will have to take a refresher training course
to re-validate for two years the provisional licence.
Medium-sized motorcycle (Category A2) provisional licensing for a rider taking the
progressive access route
C14. A person granted a full category A1 licence will also be granted a provisional category
A licence. This avoids the cost and inconvenience of the person subsequently having to
apply to DVLA for a new licence with provisional category A entitlement.
C15. However, the provisional entitlements to Category A2 (and A) will not immediately
become “live”. The provisional category A2 entitlement to drive on the road will become “live”
only when the person has held a full category A1 licence for a minimum of two years and
then passed a suitable training course. Similarly, the provisional category A entitlement to
drive on the road will become “live” only when the person has held a full category A2 licence
for a minimum of two years and then passed a suitable training course.
C16. The rider will not be allowed to carry a pillion passenger or ride on the motorway or in
another EU State on an A2 motorcycle until qualified for a full category A2 licence. The
licensing rules would be explained in the official documentation, in the same way that it is
done currently for the initial two-year restricted entitlement for new category A licences
(outside Direct Access) to ride large motorcycles.
C17. If the provisional A2 entitlement had not been upgraded to a full category A2 licence
within two years of the provisional entitlement becoming live, the person would have to take a
refresher training course in order to revalidate the provisional category A2 licence for a
further two years.
Unrestricted motorcycle (Category A) provisional licensing for a rider taking the direct access
route
C18. The current Direct Access Scheme (DAS) arrangements will apply, subject to a higher
minimum age (24 years). A person will be eligible to apply for a provisional category A
licence any time after the applicant has reached the age of 24. The rider will need to
satisfactorily complete initial training to ride on the road. The rider will then be able to drive
any category A vehicle on L plates during the two year validity period of the initial training
certificate. The learner will not be allowed to ride a category A vehicle on a motorway or in
another EU State or carry a pillion passenger on a category A vehicle until qualified to hold a
full category A licence.
C19. Category A learners will need to be accompanied by an authorised motorcycle
instructor, on another motorcycle in radio contact with the learner, with a maximum
trainee/trainer ratio of 2:1. The learner will have to satisfactorily complete the direct access
syllabus before taking the practical test for a category A licence. If a learner has not qualified
for a full category A licence (passing the relevant theory and practical tests) within two years,
the person will have to take a refresher training course to re-validate the provisional A licence
for a further two years.
Unrestricted motorcycle Category A provisional licensing for a rider taking the progressive
access route
43
C20. We propose that this will be similar to the progressive access arrangements for a
learner A2 rider. A person holding a full category A2 licence will have provisional category A
entitlement to ride on the road when the person:
has held a full category A2 licence for a minimum two years; and
has satisfactorily completed the familiarisation training course. (This course might
serve as a first module in a training course satisfying the qualifying event for a full
licence within Progressive Access if the training option were introduced).
C21. The rider will not be allowed to carry a pillion passenger or ride on the motorway or in
another European Economic Area State on a category A motorcycle until qualified for a full
category A licence.
44
Annex D
New standards for training learners using powered two-wheelers
D1. Since 1990 learner riders of mopeds and motorcycles have been required to satisfactorily
complete a compulsory basic training (CBT) course in order to validate the entitlement granted by a
provisional licence to ride on the road 45 . The CBT course completion certificate has a two-year life. If
a learner has not qualified for a full licence by the end of the two years and wishes to continue riding,
the learner must retake CBT. This provides learners with an encouragement to achieve the full
qualification rather than stay as permanent learners for an indefinite period. It also provides a
safeguard in circumstances where, for whatever reason, a person holding a provisional licence is not
in fact practising and developing their skills.
D2. CBT is widely accepted by motorcycling and road safety interests as having helped improve the
safety of motorcycling. It has also encouraged trainees to undertake further training as they seek to
qualify for a full licence.
D3. Some 80% of applicants for a full motorcycle licence are seeking to ride the full range of
motorcycles using the provisions of the current Direct Access Scheme. Learners in that scheme must
be accompanied by an authorised professional instructor. Trainers have advised DSA that it has
become the norm for learner riders in the current Direct Access Scheme to take a five or six day
training course (including the time spent on the CBT course) with a motorcycle instructor authorised to
act as an accompanying rider.
D4. However, recent audits by DSA undertaken with the cooperation of the motorcycle training
industry have identified weaknesses with the existing arrangements. In a sample of 56 CBT courses
and 277 DAS training events observed by the DSA, 41% of CBT events and 31.4% of DAS courses
provided training at a level below a standard expected of professional trainers. In addition, there were
injuries to trainees during observed training events.
D5. In GB motorcycles make up around 1% of road traffic but are involved in incidents that result in
around 20% of serious injuries and fatalities on the road 46 .
D6. The Government Motorcycling Strategy 47 foresees improved standards for motorcycle training
and motorcycle instructors to help address this. The revised Action Plan 48 published in 2008 commits
DSA to:
Consult on improvements to compulsory basic training and implement as appropriate
45
The CBT requirement is waived where a learner has already fully qualified for a licence to drive a smaller category of
powered 2 wheeler i.e. where a learner rider for any category of motorcycle already holds a full moped licence having
passed the moped test, or where a learner rider for a category A motorcycle already holds a full licence for category A1
motorcycle – regulation 69 of the Motor Vehicles (Driving Licences) Regulations 1999 SI No. 2864 refers
45
DfT Annual Report for Road Casualties Great Britain 2007
46
DfT Annual Report for Road Casualties Great Britain 2007
47
Government Motorcycling Strategy DfT 2005, following commitments in Tomorrows Roads – safer for everyone the
Government’s Road Safety Strategy DETR 2000
48
Government’s Motorcycling Strategy Revised Action Plan published in July 2008
45
D7. Ministers have set the following key target for the Agency for 2009-10 49 :
Introduce a syllabus for the Direct Access Scheme (DAS) and pre test training by 31 March 2010
that will improve standards of training and contribute to the Governments Motorcycling Strategy.
D8. Motorcycle interest groups have asked that the changes required to transpose the Directive
should be taken as an opportunity to improve motorcycle training arrangements more generally, and
that we should set out our proposals for this. This topic goes beyond the scope of the Directive but
the following sets out our initial thoughts.
Modernising the training for learner riders
We envisage improving the training and safety for users of powered two-wheelers by
modernising the current arrangements for the training undertaken by learner riders.
updating CBT, by providing for initial basic training courses for new learners to validate
a provisional licence to ride on the road, recognising that the riders may be entering
motorcycle licensing at different stages. The content for the courses will be based on
the DSA’s Learning to Ride syllabus, which is currently being developed, and will place
greater emphasis on developing young and novice riders understanding of risk and
self-awareness. Like CBT, initial training will have a two year life.
providing a Learning to Ride syllabus to be satisfactorily completed before the
candidates attempt the practical test.
providing a version of the DSA Learning to Ride syllabus for category A2 and A direct
access trainees to be satisfactorily completed before those trainees attempt the
practical test. This version of the syllabus will be broadly the same as that delivered to
novice drivers entering lower categories but will addresses the particular knowledge
and skills required to ride a larger or more powerful motorcycle.
specifying a familiarisation training course for progressive access learners to validate
their provisional entitlement to ride on the road.
specifying refresher training events to be undertaken by learner riders who have not
qualified within two years in order to revalidate the provisional licence for a further two
years.
The content of the courses will be informed by the competence framework for safe
motorcycling that the Agency is having prepared.
D9. We propose to discuss further with interested parties the content and structure of arrangements
to deliver better training and safety to users of powered two-wheelers.
49
DSA Business Plan 2009-2010 April 2009
46
Annex E
Light quadricycles and tricycles – new arrangements under the new Directive
E1. As shown in the table below the new Directive puts light quadricycles into category AM,
tricycles into categories AM (moped), A1 (small motorcycle), or A (unrestricted motorcycle) depending
on their power (rather than in category B1 as under current EU law) and puts larger quadricycles in
category B1 (as currently).
EU Specification Standard minimum Minimum driving age in GB
Category driving age in the (largely unchanged, see
Directive (years) footnote)
AM Small tricycles (up to 16 16
50cc and below 4kW)
Light quadricycles 50
A1 Tricycles up to 15kW 17 17
A Tricycles over 15kW 21 21
B1 Quadricycles (up to 16 17
15kW)
“Minimum driving age in GB” shows the position after implementation of the new Directive.
This is in most instances unchanged. However for tricycles over 15kW the present minimum
driving age in GB is 17 years: for drivers gaining entitlement from 19 January 2013 it will be 21
years.
50
As defined Article 1(3)(a) of Directive 2002/24/EC
47
48
Annex F
New EU requirements for driving examiners - considerations
Options allowed in the new Directive
F1. Before a Member State may authorise a person to operate as an examiner authorised to
conduct practical tests for licence acquisition, the person must successfully complete a training
programme approved for the purpose by the Member State. The Member State may determine
whether this training relates to conducting tests for one licence category or more than one 51 .
F2. Member States must operate an examination process which applicants must pass before
being authorised as an examiner. The examination must consist of a theoretical element and a
practical element and require an applicant to demonstrate a satisfactory standard of knowledge and
skills in examiner competences. Member States may determine whether this examination conveys
authorisation to conduct driving tests for one driving licence category or more than one 52 .
F3. Before a Member State may authorise an examiner to conduct practical tests to drive
motorcycles, lorries and buses the applicant must have been a qualified examiner for category B tests
for at least three years, though Member States may waive this requirement 53 provided that the
examiner:
can provide evidence of five years of driving in the category concerned; or
has satisfied a theoretical and practical assessment of driving ability of a standard higher than
that needed to obtain a driving licence.
F4. The general principle in the Directive is that an examiner needs to be qualified in respect of
each main category of vehicle for which he or she is authorised to conduct practical tests. However,
the Directive allows 54 Member States to authorise an examiner to:
conduct driving tests for categories AM, A1, A2 and A upon passing the initial qualification for
one of these categories; and
conduct driving tests for categories C1, C1+E, C+E , D+E, D1, D1+E and D+E upon passing
the initial qualification in one of these categories.
In the Directive these are described as equivalences.
Our proposed implementation
Acquired Rights
F5. When we transpose the Directive into domestic law we shall ensure that examiners authorised
to conduct classes of practical driving test immediately before the Directive comes into force will not
have their authorisation disrupted. Other organisations with authority to appoint examiners have
indicated to DSA the importance they place on this.
General Observations
F6. DSA’s recruitment, training and quality assurance practices already comply with many of the
provisions of the new Directive. Where they do not they will be aligned no later than January 2013.
The Agency will amend its recruitment practice to reflect the minimum age criterion in the Directive.
F7. As regards equivalences, DSA’s long-standing practice is to issue warrants for examiners to
conduct practical tests identifying separately four main groups – mopeds/motorcycles, cars, lorries,
buses/coaches. This satisfies the Directive.
F8. Paragraphs F.9 to F.29 below provide an analysis of how we envisage the various
requirements could be met.
51
Annex 3.2.3.
52
Annex 4.1.4.
53
Annex 4 2.2. (c)
54
Annex 4.2.3.
49
Initial Qualification
F9. The initial training course which all DSA examiners successfully complete before they can be
appointed already satisfies the Directive’s requirements - both the content (driving and instructional
ability) and the standard (level 3 educational attainment).
F10. As well as the continuing assessment undertaken during the training course, the training
outcomes are validated by theory and practical examinations. The arrangements in place already
meet the requirements of the Directive.
F11. When appropriate, the Agency delivers consolidated training programmes so that by the end
of a course an examiner is qualified to conduct tests for more than one type of licence category.
F12. The training courses and supporting examinations for examiners authorised to conduct
motorcycle, lorry and bus driving tests are of a significantly higher standard than those to be passed
for driving licence acquisition. We are therefore able to use the flexibility in the Directive and not
require an examiner to work as a category B examiner for three years before seeking to qualify as an
examiner for the other categories of vehicle.
F13. As regards non-DSA examiners, those working for fire and police authorities and bus and
coach companies take the same initial qualification process as DSA-employed examiners. This
common induction process helps to establish fair and uniform national standards of assessment.
F14. The arrangements for examiners employed by the MoD are different, taking account of the
much larger numbers of MoD examiners and the operational needs of the armed services. A cadre of
MoD personnel share the same initial qualification process as DSA-employed examiners. Those MoD
examiners then train other MoD staff as examiners.
Quality Assurance
F15. The new Directive requires Member States to have quality assurance arrangements in place
to ensure that the standards of driving examiners are maintained.
these arrangements must include the supervision of examiners, their training and development
and the outcomes of the driving tests that they have conducted;
each examiner must be observed conducting tests once every five years for a minimum period
of half a day and several tests must be observed during this period;
the work of driving examination must be monitored and supervised by a body authorised by
the Member State;
Member States must have in place the appropriate measures for ensuring that remedial
training is given promptly to substandard examiners.
F16. Existing driving examiners as well as newly qualified examiners will have to comply with the
Directive’s training and supervision requirements, whether employed by DSA or other organisations.
F17. DSA already has in place a comprehensive quality assurance scheme for examiners directly
employed by the Agency, and these satisfy the quality assurance requirements in the Directive.
F18. As the competent authority responsible for the standards of driving tests within GB, DSA also
has oversight responsibilities for the monitoring and supervision of other examiners authorised to
conduct licence acquisition tests.
F19. The Agency has engaged with representatives for those other groups of examiners about their
quality assurance arrangements to ensure that these will meet the Directive’s requirements, with
adjustments to include suitable reporting arrangements and the inspection of the relevant training
records. Paragraphs F20 to F29 below give further details.
Periodic Training
F20. The new Directive requires Member States to ensure authorised driving examiners undertake,
cumulatively, a minimum of 15 days training per examiner every five years. This training may be in
50
the form of a briefing, classroom, conventional or electronic based learning and may be taken on an
individual or group basis.
F21. Driving examiners must undertake a minimum four days training every two years in order to;
maintain and refresh the necessary knowledge and examining skills;
develop new competences that have become essential for the exercise of their profession:
ensure that they continue to conduct tests to a fair and uniform standard.
F22. Examiners must undertake a further minimum five days training over a period of five years in
order to develop and maintain the necessary practical driving skills.
F23. DSA already operates an extensive training regime for examiners employed by the Agency.
The Agency will adjust these arrangements to ensure that all the Agency’s examiners receive the
appropriate amount of training 55 . We shall assure transparency and accountability by including
relevant information in the DSA Annual Report and Accounts.
F24. The Directive’s quality assurance and periodic training obligations will equally apply to other
organisations with driving examiners. At informal consultation seminars, representatives of examiners
employed by fire, police and bus and coach organisations expressed concerns about the robustness
of arrangements on which continued authorisation would depend. They expressed a preference for
DSA to make available to them the periodic training courses for DSA-employed examiners rather than
have to rely on local in-house arrangements or services offered by commercial providers, on the basis
that the cost impact for them would not be materially affected by whether DSA or another organisation
carried out periodic training.
F25. The onus for ensuring that the appropriate amount of meaningful training has been completed
will lie with the body authorised to appoint delegated examiners. As the competent authority DSA will
undertake risk based assurance audits based on relevant records and supported by direct
observation of periodic training being undertaken as appropriate
F26. In particular, we intend that the current DSA quality assurance scheme for delegated
examiners – those employed by organisations other than the DSA itself - will be expanded to include
the inspection of periodic training records. The Directive does not specify a format or system for
recording this training and we propose that each organisation employing examiners will hold its own
records and that these will be made available for inspection by DSA as necessary.
F27. Regarding examiners employed by the MOD, we shall keep under review DSA’s existing
quality assurance arrangements as set out in the relevant memorandum of agreement, but we have
no current plans to alter them.
F28. We propose therefore to make it a condition of approval for all organisations that appoint
examiners that are authorised to conduct licence acquisition tests that:
each examiner for which they are responsible receives the appropriate amount of periodic
training;
they maintain the relevant training records; and
those records of periodic training for each examiner are complete and readily available for
inspection by DSA.
F29. Enforcement would operate in the way it does for existing conditions of appointment. Powers
are already contained in domestic legislation 56 for DSA to take action concerning those bodies which
do not meet the conditions of approval..
55
We estimate that this will cost some £750k pa (including the costs of back-filling those examiners taking training
56
The Motor Vehicles (Driving Licences) Regulations 1999
51
52
Annex G
Other Administrative Provisions of the new Directive
G1. This Annex explains additional changes to the driving licence system which are made
obligatory by the new Directive. It also explains options which could arise in the future. This
is for information only.
Rule changes to definitions and minimum ages (Mandatory)
Scope: drivers of medium and large vehicles
Current practice
G2. Descriptions of the categories of vehicles for which driving licences are issued are
listed in the Motor Vehicles (Driving Licences) Regulations 1999 (SI 2864). They stem from
(but are not worded the same as) current European legislation (Directive 91/439/EEC).
G3. Minimum ages for driving all medium and large buses and lorries apply to non-
professional drivers only. Those wishing to drive professionally must comply with the
requirements of The Certificate of Professional Competence (CPC) Directive (Directive
2003/59/EC) (implemented by Vehicle Drivers (Certificates of Professional Competence)
Regulations 2007 (SI 2007/605), which was implemented in Great Britain in 2008/9 and
which allows driving at a younger age if the driver holds a CPC qualification.
G4. The age for obtaining entitlement to drive buses (without a CPC) is 21 unless the
prospective driver is in the armed forces where entitlement can be obtained earlier.
G5. Certain vehicles are exempted from the requirements of the second Directive on
driving licences (i.e. from the need to hold the entitlement and/or from the minimum ages for
obtaining entitlements). These categories of exemption have been agreed with the European
Commission.
New EU provision
G6. Category definitions: small changes are made to the definitions of medium and large
buses and lorries, to clarify the seating capacity allowed for in such vehicles.
G7. Minimum Ages: the minimum age for obtaining entitlement to drive large buses
(category D) for non-professional purposes increases to 24 years from 21 years (see Article
4.4 (k)).
G8. Derogations from minimum age requirements: Member States may lower the
minimum age for category C to 18 years and for category D to 21 for:
(a) vehicles used by the fire service and vehicles used for maintaining public order: and
(b) vehicles undergoing road tests for repair or maintenance purposes.
G9. Exemptions: vehicles used by, or under the control of, the armed forces and civil
defence, are excluded from the requirements of the Directive, i.e. they may be driven without
the usual driving entitlement. This option allows for the continuance of existing arrangements
in Great Britain.
53
G10. Also, with the agreement of the Commission, Member States may also exclude other
specific types of power-driven vehicles.
Way forward
G11. Domestic legislation will be altered to reflect the new minimum ages and category
definitions, where necessary.
G12. Where the minimum age derogations and exemptions match our present national
rules, the options in the Directive will be taken up to maintain the status quo.
G13. The Department is presently liaising with the EU Commission to confirm which
existing exemptions, previously agreed under the second Directive, can be continued. We
will provide an update on the position in the analysis of responses, to be published after the
consultation period.
Minimise the risk of more than one licence being in force for the same
driver (Mandatory)
Scope: all drivers
Current Position
G14. No person may hold a driving licence from more than one Member State. Where
DVLA has suspicions that an applicant for a UK driving licence who has passed the British
driving test, already holds a driving licence issued by another EU Member State and is
therefore attempting to obtain fraudulently a second EU licence, we liaise with other Member
State licensing authorities to investigate the matter. We reject the application if our
suspicions are well founded.
G15. Also, where drivers apply to exchange an existing EU licence for a UK one (without
having to pass a British driving test), DVLA is able to make certain electronic checks with
some countries using a network called EUCARIS (European Car and Driving Licence
Information System), to confirm that each licence surrendered is valid for driving. Several EU
Member States are not linked to the EUCARIS system and licences from those countries
undergo only visual/manual checks to identify validity and authenticity. In addition, there is a
requirement to return the licence being exchanged to the Member State of issue.
New EU Provision
G16. The “one EU licence only” rule is strengthened by provisions in the third Directive
stating that Member States must carry out checks on new licence applications, when there
are “reasonable grounds to suspect” that the applicant already holds an EU licence. This
reflects current practice in Great Britain.
G17. There are separate provisions that relate to applications to exchange existing EU
licences for UK licences. The requirement to return the licence presented for exchange to the
country that issued it remains, but there is a new requirement that the licence must not be
exchanged if it is invalid or is subject to disqualification/withdrawal of the right to drive in the
country that issued it. This new rule applied earlier than the rest of the Directive and had to
be implemented by January 2009. This was done by supplementing our existing practices
with a new declaration to be signed on application forms to exchange a licence, to help DVLA
identify fraudulent attempts to exchange an invalid licence.
54
G18. To help Member States comply with the new rules explained above, a European
driving licence network will be set up to exchange certain driving licence information
electronically before issuing a UK licence. The specification of this network is yet to be
determined but would conform to agreed standards of security and data protection. It is
envisaged that the network will send requests from licensing authorities to other Member
States to search their driving licence databases to establish if applicants are trying to obtain
more than one EU licence and/or to check that a licence presented for exchange has not
been withdrawn and is not a forgery. The European Commission hopes to develop the
specification for the network in time for Member States to begin using it by 19 January 2013.
Way forward
G19. Work on this is being taken forward separately. This includes liasing with Member
States and the EU Commission to agree a technical specification for the network. In the
meantime, existing GB practices meet the requirements.
Driving licence card security and card format (Mandatory by 2013)
Scope: all drivers
Current position
G20. DVLA has issued driving licences in the form of photocards since 1998 – paper
licences are no longer issued. In 2007, DVLA redesigned its photocard licence to make it a
more secure document.
New EU provisions
G21. The third Directive specifies that all driving licences issued after 19 January 2013 must
be in the photocard format. It also specifies certain new mandatory and optional security
requirements to add to the security of the driving licence. The format of the licence is
specified in Annex I to the Directive.
Way forward
G22. These provisions have been implemented already and no further work is needed.
Smart card licence (optional)
Scope: all drivers
Current position
G23. There is currently no microchip on the UK driving licence.
New EU option
G24. To further improve the security of the driving licence and the data it holds, the third
Directive provides Member States with the option of placing a microchip on the licence. The
requirements/specification for the microchip must be formally agreed and published by the
European Commission before Member States can take up this option. These requirements
55
must provide for an EC type approval, which will be granted only when the ability to resist
attempts to tamper with or alter data on the microchip is demonstrated.
Way forward
G25. Work on this is being taken forward separately. This includes direct contact with
Member States to consider the business benefits of a microchip on the driving licence and to
agree a specification so that Member States could upgrade to a smart card licence when and
if they chose to do so. Any proposal for Great Britain to move to a smart card licence would
be considered in a separate public consultation. There are no current plans to introduce
such a licence.
Early exchange of EU licences for UK licences
Scope: EU licence holders living in Great Britain
Current position
G26. Holders of EU driving licences who move to live in this country do not have to
exchange their licences. Instead, they may drive on the strength of their EU licences until
they become subject to British renewal at age 70 (or at age 45 for drivers of medium and
large buses and goods vehicles). Alternatively, they may voluntarily apply to exchange them
for UK licences at any time.
New EU provisions
G27. We could choose to require the exchange of an EU licence if:
the holder had been resident in Great Britain for two years, and
the licence they held did not have the administrative validity required by the
Directive.
Way forward
G28. There would be few licences falling in the scope of this option as most Member States
already issue 10-year licences and the new rules on administrative validity periods for
licences issued after January 2013 would apply to all EU Member States. It would be difficult
for the police to enforce unless they could determine easily the length of time a driver had
been resident here. DVLA could enforce any new obligation to exchange only when a
relevant licence came into its possession, for example as a result of disqualification.
G29. DVLA statistics show that 64% of drivers who exchange their non-UK licence do so
within the first two years of becoming resident anyway. For these reasons, we do not propose
to take up this option.
Recall of pre-Directive licences (Mandatory by 2033)
Scope: all drivers
Current practice
56
G30. There are 43 million UK licences in circulation at present. 29 million of these are in the
photocard format – the rest are paper licences. There are two valid versions of the UK
photocard licence and four valid versions of the UK paper licence.
New EU provision
G31. The third Directive requires Member States to ensure that by 19 January 2033, all
driving licences in circulation fulfil all the provisions of the Directive, i.e. are in the photocard
format with the new security features as specified in the Directive. Those licences that do not
comply would have to be recalled and replaced. This would include both paper and
photocard licences which are not in the format specified in the third Directive.
Way forward
G32. We consider that for licence security and road safety issues, old format licences
should be replaced with the more secure licence card, as they are a real risk to the security
of the system. Legislative powers in the Road Safety Act 2006 provide the ability to do this.
Decisions to recall old style UK licences issued by DVLA will be considered in due course.
There would be a separate consultation on this at the appropriate time.
Validity of non-EU licences for driving in Great Britain
Scope: holders of non-EU licences living in Great Britain
Current practice
G33. Holders of valid non-EU licences who live in Great Britain may drive small vehicles for
12 months on the basis of their non-EU licence. To continue to drive beyond that period, they
must obtain a UK driving licence. If their non-EU licence originated from a country that DSA
and DVLA have agreed has satisfactory driver licensing and testing arrangements, they may
exchange it for a UK driving licence without having to pass another driving test. Otherwise,
they must pass a British driving test to obtain the UK driving licence.
New Directive rules
G34. EU Member States may continue to issue driving licences in exchange for those
issued in non-EU countries, if the licence holder has become resident there. Member States
may continue to choose which non-EU countries’ licences to exchange – there is no
harmonisation across Europe on this matter. The EU licence issued must identify the country
from which it stemmed i.e. the non-EU country in which it was issued. If the holder of that EU
licence then moves to another EU Member State, there is no requirement for the authorities
there to recognise the licence.
Way forward
G35. These options were provided for under the second Directive and Great Britain has
already taken them up.
G36. If another EU Member State exchanges a non-EU licence and the holder then comes
to live here, we shall recognise and exchange the EU licence only if the previous non-EU
licence is prescribed as an “exchangeable licence” in domestic legislation. Otherwise, the
licence holder would (after 12 months residence in the UK) have to pass a British driving test
in order to obtain a UK licence and drive lawfully here.
57
G37. For purposes of road safety, we intend to continue to take up these options as they
are in line with current practices. We have established that our domestic provisions on this
should be amended slightly to clarify the rules. This will be done with the rest of the changes
needed to implement the Directive into the law in Great Britain.
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IMPACT ASSESSMENTS ANNEX H
1. The following pages are the Impact Assessments (IAs) covering the implementation
proposals included in this consultation document.
2. The IAs form part of a full public consultation process carried out in accordance with the
‘Code of Practice on Written Consultations’ issued by the Cabinet Office. They outline
the costs and benefits of the proposals and should be read with the corresponding
chapters of this consultation document. They will be developed in the light of any
comments received in response to this consultation paper.
3. The basis, including the time periods, on which the DSA and DVLA Impact Assessments
have been made differ from one another for the following reasons.
As regards DSA
o DSA costs have been worked out over a seven year time period because this is
consistent with the life of assets purchased, eg IT system software for changes
to the motorcycle and car plus trailer tests. This time line is also the standard
period over which we expect IT to operate and cost recovery to take place from
fee income before depreciation kicks in and a system refresh is required. We
also consider that 7 years provides transparency for customers as it is a
realistic time period for the project to show the full impact of operating costs
versus any realised benefits.
o The seven-year time period starts in the 2014/2015 planning year, one year
after the Directive will have been implemented. This will allow for operating
costs and benefits to be seen over a period of time, both for the changes to the
car plus trailer regime (starts in 2014) and for motorcycle changes which will
start to be seen from 2015 when progressive access takes effect for the first
time.
As regards DVLA
o In common with all policy developments, DVLA carries out a review after 3
years to see if expected costs and benefits have been achieved. On this basis
DVLA Impact Assessments have been made over three years.
o The changes that have to be made to DVLA IT systems to accommodate the
Directive rules have been assessed as costing £6.25 – 7.5m. The majority of
this estimate reflects changes that must be made to support new rules on which
we have no choice – for example to change business rules for driving licence
validity periods; and to accept new driving licence categories and changes to
minimum age rules.
o The rest of the DVLA estimate covers system changes that would be needed to
support the implementation proposals covered by the Annexes.
o Each DVLA IA explains the costs for the individual option being considered. It
includes a cost, where appropriate, for:
any DVLA IT system change needed;
DVLA staff resource and guidance needs; and
costs attributed to the driving population (for example to supply
photographs and complete application forms).
the costs and benefits have been assessed over three years from
2013 in the Summary: Analysis and Evidence.
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Annex G explains additional changes to the driving licence system
which are made obligatory by the new Directive and mandatory
requirements which will arise in the future, such as use of the
European driving licence network, some of which we cannot include
costs for at present. It also explains options which could arise in
future. This is for information only.
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Summary: Intervention & Options ANNEX H1
Department /Agency: Title:
DfT/DSA Impact Assessment of the implementation of the third
EU directive on driving licences
Stage: Consultation Date: September 2009
Related Publications: EU third Directive on driving licences 2006/126/EC
Available to view or download at:
http://www.dft.gov.uk
Contact for enquiries: Steve Nelson Telephone: 0115 9366100
What is the problem under consideration? Why is government intervention necessary?
Transposition of the UK Government obligations relating to driver training and testing arising under a new EU
Directive.
Implementation of the qualification arrangements for revised EU motorcycle licence categories including
upgrading between the categories (A1, A2 and A), plus a new category for motor car/light van plus trailer
combinations (category B96).
As the competent authority, DSA will be statutorily responsible for ensuring that GB complies with these
requirements, setting and oversight of standards and, in some cases, service delivery.
What are the policy objectives and the intended effects?
Policy objective is to implement successfully the requirements of the Directive;
(a) in a way that supports the Government’s road safety, mobility and social inclusion policies,
(b) in line with the Hampton Better Regulation principles,
(c) cost effectively,
(d) with stakeholder support, and
(e) in a manner that facilitates compliance.
The intended effect is that GB complies with the Directive whilst taking account of the above aims.
What policy options have been considered? Please justify any preferred option.
1. Not to implement (rejected)
2. Training only for upgrade of motorcycle entitlement within progressive access and for B plus trailer (rejected
on grounds of lack of resilience)
3. Test only for upgrade of motorcycle entitlement within progressive access and for B plus trailer.
(Low cost compared to the alternative and relatively simple to implement).
4. Test and training routes for upgrade of category A and B entitlements.
Some stakeholders expressed a wish for training routes to be available for both Category A and B upgrades.
(This option also offers greater choice to the public when upgrading).
When will the policy be reviewed to establish the actual costs and benefits and the achievement of the
desired effects?
The policy will be reviewed in 2016. Health & Safety issues will be assessed before implementation and
monitored as soon as the service is operational.
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Summary: Analysis & Evidence
Policy Option: Option Description: Practical Test event as the only qualifying route in
3a progressive access (with bespoke B96 test)
ANNUAL COSTS Description and scale of key monetised costs by ‘main
affected groups’ Please see option 3a for detailed breakdown of costs
One-off (Transition) Yrs
Associated DVLA development costs £3,750,000
£ 6,410,000
DSA staffing £1,000,000
COSTS
Average Annual Cost
(excluding one-off, over 7 years) DSA IT development of scanning £470,000
£ 1,000,000 Total Cost to end yr 7 of operations (PV) £ 6,500,000
Other key non-monetised costs by ‘main affected groups’
ANNUAL BENEFITS Description and scale of key monetised benefits by ‘main
affected groups’ economic value put on 1% reduction in numbers
One-off Yrs of motorcyclists killed, seriously injured and slightly injured in
£ 0.00 2008.
BENEFITS
Average Annual Benefit
(excluding one-off)
£ 20,827,670 Total Benefit to end yr 7 of operations (PV) £ 110,980,000
Other key non-monetised benefits by ‘main affected groups’ As shown on evidence page.
Key Assumptions/Sensitivities/Risks As shown on the evidence page.
Price Base Time Period Net Benefit Range (NPV) NET BENEFIT (NPV Best estimate)
Year 2009 Years 7 £ £ 107,350,000
What is the geographic coverage of the policy/option? GB
On what date will the policy be implemented? Jan 2013
Which organisation(s) will enforce the policy? DSA
What is the total annual cost of enforcement for these organisations? £ 0.00
Does enforcement comply with Hampton principles? Yes
Will implementation go beyond minimum EU requirements? No
What is the value of the proposed offsetting measure per year? N/A 57
What is the value of changes in greenhouse gas emissions? N/A
Will the proposal have a significant impact on competition? No
Annual cost (£-£) per organisation Micro Small Medium Large
(excluding one-off)
57
N/A = Not Applicable
62
Are any of these organisations exempt? No No N/A N/A
Impact on Admin Burdens Baseline (2005 Prices) (Increase - Decrease)
Increase £0 Decrease £0 Net £0
Key: Annual costs and benefits: Constant Prices (Net) Present Value
63
Summary: Analysis & Evidence
Policy Option: Option Description: Practical Test event as the only qualifying route in
3b progressive access (with B96 grouped with the B+E test)
ANNUAL COSTS Description and scale of key monetised costs by ‘main
affected groups’ Please see option 3b for detailed breakdown of costs
One-off (Transition) Yrs
Associated DVLA development costs £3,750,000
£ 6,210,000
DSA staffing £1,000,000
COSTS
Average Annual Cost DSA IT development of scanning £470,000
(excluding one-off, over 7 years)
£ 850,000 Total Cost to end yr 7 of operations (PV) £ 6,210,000
Other key non-monetised costs by ‘main affected groups’
ANNUAL BENEFITS Description and scale of key monetised benefits by ‘main
affected groups’ economic value put on 1% reduction in numbers
One-off Yrs of motorcyclists killed, seriously injured and slightly injured in
£ 0.00 2008.
BENEFITS
Average Annual Benefit
(excluding one-off)
£ 20,827,670 Total Benefit to end yr 7 of operations (PV) £ 110,980,000
Other key non-monetised benefits by ‘main affected groups’ As shown on the evidence page.
Key Assumptions/Sensitivities/Risks As shown on the evidence page.
Price Base Time Period Net Benefit Range (NPV) NET BENEFIT (NPV Best estimate)
Year 2009 Years 7 £ £ 107,550,000
What is the geographic coverage of the policy/option? GB
On what date will the policy be implemented? Jan 2013
Which organisation(s) will enforce the policy? DSA
What is the total annual cost of enforcement for these organisations? £ 0.00
Does enforcement comply with Hampton principles? Yes
Will implementation go beyond minimum EU requirements? No
What is the value of the proposed offsetting measure per year? N/A 58
What is the value of changes in greenhouse gas emissions? N/A
Will the proposal have a significant impact on competition? No
Annual cost (£-£) per organisation Micro Small Medium Large
(excluding one-off)
Are any of these organisations exempt? No No N/A N/A
58
N/A = not applicable
64
Impact on Admin Burdens Baseline (2005 Prices) (Increase - Decrease)
Increase £0 Decrease £0 Net £0
Key: Annual costs and benefits: Constant Prices (Net) Present Value
65
Summary: Analysis & Evidence
Policy Option: Option Description: Test Plus Training routes for upgrading in progressive
4 access (with B96 test grouped with category B+E test)
ANNUAL COSTS Description and scale of key monetised costs by ‘main
affected groups’ Please see option 4 for detailed breakdown of costs.
One-off (Transition) Yrs
Associated DVLA development costs £3,750,000
£ 8,610,000
DSA Operational QA and approval of trainers £4,800,000
COSTS
Average Annual Cost
(excluding one-off over 7 years)
£ 8,100,000 Total Cost to end yr 7 of operations (PV) £ 13,880,000
Other key non-monetised costs by ‘main affected groups’
ANNUAL BENEFITS Description and scale of key monetised benefits by ‘main
affected groups’ economic value put on 1% reduction in numbers
One-off Yrs of motorcyclists killed, seriously injured and slightly injured in
£ 0.00 2008.
BENEFITS
Average Annual Benefit
(excluding one-off)
£ 20,827,670 Total Benefit to end yr 7 of operations (PV) £ 110,980,000
Other key non-monetised benefits by ‘main affected groups’ As shown on the evidence
page.
Key Assumptions/Sensitivities/Risks As shown on the evidence page.
Price Base Time Period Net Benefit Range (NPV) NET BENEFIT (NPV Best estimate)
Year 2009 Years 7 £ £ 100,960,000
What is the geographic coverage of the policy/option? GB
On what date will the policy be implemented? Jan 2013
Which organisation(s) will enforce the policy? DSA
What is the total annual cost of enforcement for these organisations? £ 0.00
Does enforcement comply with Hampton principles? Yes
Will implementation go beyond minimum EU requirements? Yes
What is the value of the proposed offsetting measure per year? N/A
What is the value of changes in greenhouse gas emissions? N/A
Will the proposal have a significant impact on competition? No
Annual cost (£-£) per organisation Micro Small Medium Large
(excluding one-off)
Are any of these organisations exempt? No No N/A N/A
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Impact on Admin Burdens Baseline (2005 Prices) (Increase - Decrease)
Increase £0 Decrease £0 Net £0
Key: Annual costs and benefits: Constant Prices (Net) Present Value
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Evidence Base (for summary sheets)
Background
1. The Third EU Directive (2006/126/EC) introduces new requirements that Member States
must operate concerning their driver/rider training, testing and licensing arrangements. The
Directive imposes for younger persons a staged access to entitlement to ride more powerful
motorcycles. The Directive allows Member States to establish a test or a training route for
riders who wish to upgrade their motorcycle entitlement within progressive access.
2. The Directive also introduces a new category of entitlement (B96) for those drivers of cars
and light vans (category B) who wish access to a heavier vehicle/trailer combination than
otherwise allowed for category B. The Directive allows Member States to establish a test, a
training, or a test plus training, route for drivers who wish to qualify for category B96
entitlement.
Issue: Motorcycles
3. Current domestic arrangements allow riders from age 17 years access to a full licence to
ride small motorcycles (category A1) or medium-sized motorcycles (category A restricted)
after successfully completing a theory and practical test.
4. Riders who pass their practical test on a motorcycle of at least 120cc are granted category
A (restricted) entitlement. After two years their licence upgrades automatically to full
category A (unrestricted). About 1% of candidates in GB obtain a full category A1 licence
and 19% obtain a full category A (restricted) licence.
5. Most rider candidates in GB do neither. They are aged 21 years or older. The current EU
law allows Member States to operate direct access arrangements for riders of this age which
enables them to obtain a full category A (unrestricted) licence by passing their practical test
on a machine of 35kW power-output or above. GB operates a Direct Access Scheme and
80% of candidates qualify via that route.
6. The new Directive enhances the concept of staged access for younger riders and imposes
a qualification event for each stage. The Directive gives Member States the option of
determining as a qualifying event a training event (at least 7 hours) or a practical test. The
Directive does not prevent a Member State from offering both. In progressive access, a rider
must gain two years experience holding a full licence at each stage before attempting to
qualify for the next stage.
7. The Directive requires Member States to operate direct access arrangements for medium-
sized motorcycles (category A2) and allows them to operate direct access arrangements for
the most powerful motorcycles (category A). In these cases qualification is by passing the
relevant theory and practical tests Riders must satisfy the specified minimum age
requirements for direct access to these categories. The minimum age requirements for
category A2 in any Member State must be two years older than the minimum age set for
category A1 by that State. The minimum age requirements for category A (direct access) is
24 years.
8. This means that, having qualified for category A1 (by passing the relevant theory and
practical tests), the rider may within progressive access upgrade to A2 by gaining two years
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experience holding a full category A1 licence and then satisfactorily completing a category A2
qualifying event. Alternatively the category A1 rider could, providing they satisfy the
appropriate minimum age for that Member State, choose to take a theory and practical test to
obtain category A2 entitlement without waiting for two years (ie accelerated access). Having
obtained a full category A2 licence the rider may, within progressive access, upgrade to
category A by gaining two years experience holding a full category A2 licence and then
satisfactorily completing a category A qualifying event.
9. The minimum driving ages in GB for the new categories are shown in the table below:
Category Specification GB minimum age
A1 motorcycles up to 125cc/11kw with a power/weight ratio not 17 years
exceeding 0.1 kW/kg (including tricycles up to 15kW)
A2 motorcycles up to 35kw with a power/weight ratio not exceeding 19 years
0.2kW/kg and not derived from a vehicle of more than double its
power
A unrestricted motorcycles above 35kW (including tricycles over 21 years (24 years if
15kW) direct access)
Issue: Cars and Trailers
10. The new Directive allows for a trailer with a theoretical maximum allowable weight
(Maximum Authorised Mass - MAM) not exceeding 750kg to be towed by a car or light van
(MAM not exceeding 3.5 tonnes) on a category B licence.
11. The new Directive introduces a new category of trailer-towing entitlement (B96). It
allows motor vehicles in category B to be combined with a trailer with a MAM exceeding
750kg provided that the MAM of this combination falls between 3,500kg - 4250kg. Drivers
must satisfy a qualifying event to access this entitlement. The Directive allows Member
States to determine that the qualifying event is a period of training (at least 7 hours) or a
practical test of skills and behaviour, or both.
Policy Objective
12. To implement successfully the new requirements of the Third Directive in a way that
supports the Government’s road safety, mobility and social inclusion policies, with
arrangements that are:
simple and easy to follow, facilitating compliance
cost effective
risk based
supported by stakeholders
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Cost Estimates Applicable To All Options
13. All estimated costs should be read as indicative only. DSA has taken the median option
for the cost of each item or service for the purposes of this Impact Assessment. The actual
costs may be lower or higher. The cost information provided is based on the best estimates
the Agency can make at this time. These estimates will be revised once delivery decisions
have been made post-consultation and in the light of purchasing outcomes.
14. DSA operates as a Trading Fund, with almost all of its revenue derived from fees
charged to users for the services they consume. If the implementation and operating costs
are less than those estimated in this Impact Assessment then customers will benefit from
lower fees than otherwise. If the actual costs are higher than these estimates, then this will
have an impact on the fees. As a Trading Fund any additional costs will have to be passed
on to our customers in the form of higher fees, subject to any efficiency savings that might be
possible at the time.
15. In the implementation of the new Directive it has been agreed within DfT that DSA will
arrange for the finance and cost-recovery of the training and testing aspects and that DVLA
will arrange for the finance and cost-recovery of the licence aspects. In line with Treasury
guidance that public services should be financed on the user-pays principle, DSA’s testing
costs will be recovered from test fees. Costs relating to supervising a training system would
be recovered from the participating trainers (in practice, trainers would seek to recover that
cost from the charges they levied on trainees for training courses). DVLA has not yet
determined the proposed recovery route for its costs. DVLA faces other issues and costs
concerning driving licences in transposing this Directive. These matters are the subject of a
parallel consultation by DVLA.
Assumptions Applicable To All Options
16. That:
the number of examiners employed by the DSA will not increase on those forecast in
the DSA Business Plan 2009/10
all costs and benefits have been rounded up to the nearest £50k
training costs for DSA examiners owing to staff turnover over the 7 year business case
period will be absorbed by the Agency as business as usual
the number of practical motorcycle tests will not be significantly different from the
volume forecast in the DSA Preliminary Business Case (PBC)
there will be an increase of approximately 9,000 upgrade attempts in 2015 as the first
tranche of riders who obtained a full licence in 2013 reach age of 19 (DSA PBC)
in 2017 a second tranche of riders aged 19 (from 2015) and 21 (from 2015) increase
the number of upgrade attempts to 12,000 (DSA PBC)
demand for car/van plus large trailer (B+E) will not be significantly different to the
number in the DSA PBC (8,000)
demand for B96 qualifying events will increase the number of car plus trailer tests
(including tests for persons seeking category B+E) to 24,000 per annum. (DSA PBC)
It will not be possible to specifically attribute any reduction in casualties that may result
from implementing the Third Directive as other external influences may have a
contributory factor to reducing casualties in the affected group
However given the high levels of casualty involvement of motorcyclists, modest
improvements in relative safety (1%) would generate significant economic, social and
health benefits
70
our estimates of monetary benefits are based on a 1% reduction in motorcycle
casualty figures as the group most affected by the training/testing changes in the new
Directive
in 2008 there were 493 fatalities, 5,555 seriously injured, and 15,501 slightly injured
riders as a result of road traffic incidents. Source Dept for Transport Road Traffic
Casualties in Great Britain 2007
the economic valuations used are as follows: fatality = £1,648,390, serious injury =
£185,220, slightly injured = £14,280. Source Dept for Transport Road Traffic
Casualties in Great Britain 2007
There will also be a benefit in road safety to those users who have to prove
competency in a larger car/trailer combination by qualifying for B96. However casualty
figures are not available for sub categories of vehicles and for the purposes of the
Impact Assessment this benefit is non monetised
Volume of Tests
2015/16 2016/17 2017/18
Motorcycles
Forecast of Practical
Tests 182,000 182,000 182,000
(A1 & A)
Staged A2 & A Tests 18,000 18,000 24,000
Total Tests 200,000 200,000 206,000
Car Plus Trailer
Normal Car plus
13,000 13,000 13,000
Trailer
B96 New Demand 11,000 11,000 11,000
Total Tests 24,000 24,000 24,000
Sensitivities/Risks Applicable To All Options
17. If requirements are too complicated to be readily understood, or felt to be too onerous,
there is a high risk of non compliance.
Option 1: Not to implement
18. This is not a viable option. This would involve ignoring our Community responsibilities. It
is the UK Government’s policy to implement EU Directives in a timely and efficient way. Not
to implement the requirements of the Directive would probably result in infraction proceedings
being taken by the European Commission. This could result in significant financial penalties
and embarrassment for the UK government. Our proposals as to how we could meet the EU
requirements in an efficient manner that supports road safety are detailed below.
Option 2: Training event as the only qualifying route in progressive access
19. This Option imposes higher costs than a test option. This is because it involves (i)
designing, building and operating new secure data transfer arrangements and (ii) operating
new quality assurance arrangements for trainers before it would be safe to allow training
events to serve as the basis for granting full licences.
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20. Regardless of whether GB provides in legislation for a training route, the offering of those
services involves commercial decisions by suppliers. There is no guarantee that sufficient
training organisations will come forward to offer a nationwide service. We have accordingly
discounted this Option on the grounds of service resilience.
Option 3(a): Practical Test event as the only qualifying route in progressive access
(with bespoke B96 test)
Assumptions for this Option
21. These are that:
the availability of funds given the economic climate at the relevant time is such that a
least cost solution must be adopted even if it restricts choice;
the result of the consultation shows, that overall, there is little or no real appetite to
supply or the demand for, a training route to upgrade driving licence entitlements.
Cost-recovery in respect of the practical motorcycle test service is the equivalent of a
£3 supplement for every practical motorcycle test
Cost-recovery in respect of a bespoke B96 test service is the equivalent of a £5
supplement on the fee charged for a car/van plus trailer (category B + E) test, currently
£115.
Sensitivities/Risks For This Option
22. This Option would be unpopular with some motorcycle stakeholders and providers of
training for vehicles towing trailers, who have expressed a wish for a training option to be
included as part of the implementation package.
23. DSA will need a suite of suitable tests anyway to cope with all the tests providing direct
access to the licence entitlement sought, which we estimate to be some 75% of the total.
The data transfer infrastructure is in place though links will need amending. We do not
foresee any significant financial risks associated with implementing this option.
Positive
Cost effective method of implementation
Simple to administer, current arrangements for practical tests will apply
Minimal IT development.
Negative
Some IT set up costs
Removes customer choice from upgrade route
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Costs
£k
IT development of test booking including internet and telephone systems = 135
Upgrade to current DSA/DVLA electronic notification route = 235
IT development of scanning = 470
Additional IT costs for bespoke B96 test = 200
Additional operational costs for bespoke B96 test = 150
Staffing (including project costs, design and development) = 1,000
Legal costs = 50
IT implementation support = 170
IT operating costs (arising over 7 years) = 850
Training examiners = 100
Communications = 300
DSA costs – (sub-total) = 3,660
DVLA costs = 3,750
Total Cost = 7,410
Benefits
24. It is not possible to know in advance the casualty savings that will result from
implementing the provisions of the new Directive in GB. But on the assumption that our
implementation of the measures in the new Directive will contribute to improved riding
standards and lead to an 1% saving in the current annual total of casualities amongst
motorcycle road users the value would be:
5 fewer fatalities @ £1,648,390 = £8,241,950
56 fewer serious injuries @ £185,220 = £10,372,320
155 fewer slight injuries @ £14,280 = £2,213,400
Total = £20,827,670
Non monetised benefits
The provisions of the Directive are implemented.
Car plus medium trailer users (B96) will have to prove competence to drive which should
generate some road safety benefits.
Minimal disruption to DSA business.
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Option 3(b): Practical Test event as the only qualifying route in progressive access
(with B96 grouped with the B+E test)
25. DSA will offer a practical test for upgrades of driving licence entitlements for motorcycles.
On successful completion of the practical test the Agency will advise DVLA via secure
electronic link to issue a full driving licence for the relevant category.
26. DSA will group B96 tests with category B+E tests to upgrade category B entitlements.
There will be no bespoke B96 test. This is on the basis that any practical test for category
B96 would in all respects be identical to the current B+E test. It would not be cost effective to
develop and operate a bespoke B96 test. Nor would it represent good customer service -
category B+E gives a broader range of entitlement to tow large trailers. This avoids costs of
£350,000 and means the fee for the B96 entitlement would be unchanged from the fee for
category B+E tests, currently £115.
27. On successful completion of the practical test the Agency will advise DVLA via secure
electronic link to issue a full driving licence for the relevant category.
Sensitivities/Risks For This Option
As at 3(a)
Positive
Most cost effective method of implementation
Simple to administer, current arrangements for practical tests will apply
Minimal IT development.
Negative
Some IT set up costs
Removes customer choice from upgrade route
Costs
£k
IT development of test booking including internet and telephone systems = 135
Upgrade to current DSA/DVLA electronic notification route = 235
IT development of scanning = 470
Staffing (including project costs, design and development) = 1,000
Legal costs = 50
IT implementation support = 170
IT operating costs (arising over 7 years) = 850
Training examiners = 100
Communications = 300
DSA costs – (sub-total) = 3,310
DVLA costs = 3,750
Total Cost = 7,060
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Benefits
28. As Option 3(a)
Non monetised benefits
29. As at 3(a)
Option 4 Test and Training offered qualifying routes in progressive access (with B96
grouped with the B+E test)
Key Assumptions For Option 4
30. That
the demand for upgrades for motorcycle and category B (B96) will be split fifty/fifty
between the test and training routes
trainers will be charged by DSA an annual registration fee (in the range £800 - £1,300)
to recover the Agency’s costs.
there will be approximately 1,350 individuals who would wish to be registered as
motorcycle upgrade trainers by the DSA up to the year 2015 (Source DSA PBC)
there will be approximately 650 individuals who would wish to be registered as category
B upgrade trainers (Source DSA PBC)
any quality assurance scheme set up by the Agency would also cover DAS and RPMT
registered trainers to avoid duplicate visits.
Sensitivities/Risks for Option 4
31. Registration fees are thought by trainers as being too high to make participation in a
scheme a commercial proposition. Meanwhile DSA has developed a new data transfer
system and there is little interest from trainers/candidates to upgrade licences via the training
route leaving unsupported public sector cost.
Test and Training Details
32. DSA will continue to offer the practical test for upgrades of driving licence entitlements
for motorcycles and upgrade category B entitlements as set out in Option 3(b).
33. The DSA also introduces a training route to upgrade category A and category B
entitlements:
The training event would be competency based and focused on providing drivers with the
skills to handle a more powerful motorcycle/category B plus trailer combination.
The course could be broken down into smaller blocks of training but each session must be
at least two hours in duration and a minimum of 7 hours training must be completed in
total.
At the successful conclusion of the course, the trainer would certify that the trainee had
demonstrated the necessary competences which will entitle them to upgrade their licence.
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Costs
34. For practical test as option 3(b)
35. For the training option:
We have estimated the costs of the data transfer based on the information available to us
at the moment. Final costs will be dependent on identification of the the most appropriate,
cost effective system.
The costs range from approximately £15 million to £18 million. For the purposes of this
Impact Assessment we have assumed a cost of £16.710 million which is broken down as
follows;
£’k
Staffing = 1,050
IT including booking system = 2,650
Legal = 50
Communications = 300
IT Support = 600
Training for QA regimes and approved trainers = 210
Operational QA and approval of trainers (7 years) = 4,800
Operational IT support (7 years) = 3,300
DSA costs (sub-total = 12,960
DVLA development costs = 3,750
Total = 16,710
Benefits
36. As in Option 3(a) and (b).
Non monetised benefits
37. The provisions of the Directive are implemented.
Car plus medium trailer users (B96) will have to prove competence to drive which should
generate some road safety benefits.
Enhanced customer choice for upgrade of driving licences.
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Summary: Intervention & Options ANNEX H2
Department /Agency: Title:
DfT/DVLA Impact Assessment for revised administrative validity
of driving licences (drivers of small vehicles)
Stage: consultation Date: September 2009
Related Publications: DVLA consultation on Third EU Driving Licence Directive
Available to view or download at:
http://www.dft.gov.uk
Contact for enquiries: Natalie Amphlett Telephone: 01792 384589
What is the problem under consideration? Why is government intervention necessary?
The third European Directive on driving licences limits the administrative validity of licences issued to
Group 1 drivers after 2013. To align the new rules for a 10-year validity period with current domestic
rules relating to the renewal of the photograph would require a new photograph of the driver with every
application. This would increase direct costs and make transactions impossible to conduct
electronically.
Intervention is required to implement the Directive whilst maintaining customer service and the security
and integrity of drivers’ records.
What are the policy objectives and the intended effects?
To issue licences in compliance with the Directive, with a sufficiently up-to-date image of the licence
holder without requiring him/her to submit a photograph with every application. To maintain electronic
customer transaction services.
What policy options have been considered? Please justify any preferred option.
Allow the image already captured on the DVLA database to be re-used to support an application in
certain circumstances, if it has been held for 5 years or less.
DVLA considers that this would strike an appropriate balance between the requirement for the driving
licence to show a current likeness of the holder and limiting the burden imposed on applicants.
When will the policy be reviewed to establish the actual costs and benefits and the achievement of the
desired effects? The Directive must be in national legislation by 19 January 2011, and put into
practice by 19 January 2013. The intention is to review it after 3 years as part of a wider EU review.
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Summary: Analysis & Evidence
Policy Option: 1 Description: Re-use photographs already captured (within 5 years)
ANNUAL COSTS Description and scale of key monetised costs by ‘main
affected groups’
One-off (Transition) Yrs
DVLA system changes and staff resource.
£ 320,428 3
Customer leisure time and photograph expenses.
Average Annual Cost
IT running costs.
COSTS
(excluding one-off)
£1,621,302 Total Cost (PV)
£ £ 4,396,017
Other key non-monetised costs by ‘main affected groups’
Customer inability to transact electronically with DVLA for applications where the photograph had
been supplied to DVLA more than 5 years previously.
ANNUAL BENEFITS Description and scale of key monetised benefits by ‘main
affected groups’
One-off Yrs
£ nil
BENEFITS
Average Annual Benefit
(excluding one-off)
£ nil Total Benefit (PV) £ nil
Other key non-monetised benefits by ‘main affected groups’
Electronic channel still available for customers whose photographs had been supplied up to 5
years previously.
Key Assumptions/Sensitivities/Risks New photograph cost - £5. Application form takes 17 minutes to
complete. 80% test passes update licence automatically.
Price Base Time Period Net Benefit Range (NPV) NET BENEFIT (NPV Best estimate)
Year 2009 Years 3 £ N/A £-
£ - 4,396,017
What is the geographic coverage of the policy/option? GB
On what date will the policy be implemented? 19/1/2013
Which organisation(s) will enforce the policy? DVLA
What is the total annual cost of enforcement for these organisations? £ N/A
Does enforcement comply with Hampton principles? Yes
Will implementation go beyond minimum EU requirements? No
What is the value of the proposed offsetting measure per year? £ N/A
What is the value of changes in greenhouse gas emissions? £ N/A
Will the proposal have a significant impact on competition? No
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Annual cost (£-£) per organisation Micro Small Medium Large
(excluding one-off)
Are any of these organisations exempt? Yes/No Yes/No N/A N/A
Impact on Admin Burdens Baseline (2005 Prices) (Increase – Decrease)
Increase £0 Decrease £ Net £
Key: Annual costs and benefits: Constant Prices (Net) Present Value
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Evidence Base (for summary sheets)
Revised driving licence entitlement: Group 1 drivers
Proposal
1. To establish a means of implementing the provisions of the third Directive, whilst
minimising the burdens on customers and stakeholders.
Background
2. As part of the third Directive changes, there will be an EU-wide system of administrative
validity periods for driving licence cards. The aims are to tighten the overall security of
driver licensing across the EU by enabling relevant details of the driver to be updated
regularly and by facilitating the incorporation of the most up-to-date security features on
the licence card itself.
3. The overall cost for changes to DVLA IT systems and administration to facilitate the new
rules covered by Revised Licence Entitlement (that is, the matters dealt with in both
Annex H2 and Annex H3) have been estimated as approximately £2.5m. This cost
includes all system changes needed for mandatory rules relating to the licence validity
periods and renewal requirements, for example changing business rules to mandate 10-
year validity for Group 1 licences and 5-year validity for Group 2 licences.
4. The costs identified in the tables include:
additional staff resource costs
expense to the customer (for photographs and leisure time).
Current practice
5. A driver is granted a first British photocard licence for a 10-year period. The licence card
is designed to expire when the image of the driver becomes 10 years old on the DVLA
database. When that happens, the driver must renew the licence and provide an up-to-
date photograph.
6. Licences issued to the driver within the 10-year lifetime of the photograph (e.g. after a test
is passed or a change of address) are valid for the remainder of the initial 10 years and
will show the original photograph and expiry date. These arrangements facilitate the use
of electronic channels to upgrade licences after test pass and allows customers to make
applications on-line and by telephone.
New provision
7. The third Directive requires all Group 1 licences to have an administrative validity of 10 (or
11-15) years from the date it was issued. This means that applications made during the
currency of the licence must result in another 10-year licence. Rules are needed to
ensure the photograph of the driver remains a current likeness but does not become out-
of-date through continual re-use.
Implementation proposal for consideration
8. DVLA would re-use the photograph already held on the DVLA record provided it has
been supplied no more than five years previously, meaning that the photograph could be
up to maximum of 15 years old.
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9. Estimates of costs and benefits have been based on the following information and
assumptions:
80% of driving test pass results are notified to DVLA by DSA electronically and a new
licence issued automatically (DVLA statistics).
DVLA offers a web-based service with an in-house estimate that in 2008/2009
870,000 customers would have completed their entire transaction on line, with no
need for additional documentation (i.e. a new photograph).
DVLA issues around 2,400,000 replacement driving licences every year to applicants
who have notified a change of details, such as change of address (DVLA statistics).
It takes around 17 minutes to complete an application form (DVLA on-line completion
statistics).
For the 1,500,000 duplicate licences issued by DVLA each year (after a licence has
been lost or stolen), DVLA would change its business rules to ensure those applicants
would be unaffected by the new requirements. This would allow 400,000 of these
applicants to continue to obtain a duplicate licence from a telephone application
(DVLA statistics) and the remainder who choose to make a manual application would
not have to supply a new photograph.
Customers would not make specific journeys to obtain application forms and new
photographs, but would obtain them during existing journeys.
There would be no administration burdens on business as it expected that
responsibility for the application process falls to individual applicants.
Staff resource estimates include salary and office infrastructure (desk, equipment etc)
per person.
Option : a new photograph with every application
10. The option to request a new photograph with every application was considered.
Based on the above information and assumptions, this option would affect customers
in the following way.
During 2005-06, DSA statistics show that 836,000 drivers passed a Group 1 driving
test. If the same number pass a Group 1 driving test after the new rules come into
force in 2013, 668,800 (80%) of them would have to submit an application to DVLA for
their new licence and supply a new photograph, rather than receiving their new licence
automatically.
870,000 customers presently completing their application on-line would have to supply
a paper application form and new photograph, as the electronic service would not be
available to them.
2,400,000 replacement licence customers would have to supply a new photograph
with their application, where they do not have to do so now.
11. Therefore, a requirement to submit a photograph with every licence application would
affect as many as 3,938,800 applicants each year, with around 1,538,800 of these
also having to complete an application where they do not have to now.
12. This would result in one off costs for IT systems developments and production and
distribution of new forms and guidance, estimated to be £350,000. Annual costs for
this option would be £24,942,905 based on the driving population providing
photographs (at £5) to support applications, impact on customer leisure time for
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completing application forms and DVLA employment costs for extra administration
staff. Therefore, we do not propose to implement this option.
Proposal – re-use photograph already on DVLA record
13. Based on the above assumptions, this proposal would affect customers in the
following way.
During 2005-06, around 568,000 drivers between 17-22 passed a Group 1 driving test
(DSA statistics). We can assume that these drivers would have a photograph on
DVLA’s database that was provided within the previous 5 years. They would be
unaffected by this option.
In the same period, 268,000 drivers over the age of 22 passed the Group 1 test.
214,400 (80%) of these who previously would have received their new licences
automatically, would now have to make an application and provide a new photograph.
Of the £2.5m IT costs for Revised Licence Entitlement, the majority of the cost is for
changes over which we have no option i.e. 5 year renewals. £250k of the costs arise,
for example, from adjustments to photograph validity.
Summary of Costs
One-off costs £
IT systems developments 250,000
Production and distribution of new forms and guidance (estimate for 100,000
purposes of this assessment)
TOTAL 350,000
Annual costs DVLA £
DVLA employment costs (99.5 extra administration staff) 287,500
TOTAL 287,500
Additional annual costs paid by driving population
For driving population: photographs to support additional 214,000 1,072,000
applications @£5
For driving population: additional 214,400 customer leisure time for
completing application forms. (Values of non-working time per person 270,930
is calculated at £4.46 an hour – taken from Transport Analysis
Guidance.)
TOTAL of all costs 2,080,430
14. There are no monetary benefits to record.
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Summary
15. DVLA considers that this proposal would strike an appropriate balance between
the requirement for the driving licence to show a current likeness of the holder and
limiting the burden imposed on applicants. The option to request a new photograph
with every application is considered to be a disproportionate measure that would
implement the Directive beyond minimum EU provisions .
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84
Summary: Intervention & Options ANNEX H3
Department /Agency: Title: Third EU Driving Licence Directive – Revised driving licence
entitlement
DfT/DVLA
Impact Assessment: 5 year administrative renewal &
medical compliance for drivers of medium and large
vehicles at licence renewal.
Stage: Consultation Date: September 2009
Related Publications: DVLA consultation on Third EU Driving Licence Directive
Available to view or download at:
Http://www.dft.gov.uk
Contact for enquiries: Natalie Amphlett Telephone: 01792 384589
What is the problem under consideration? Why is government intervention necessary?
The Third European Directive on driving licences requires all Group 2 licences to have an
administrative validity period of 5 years, and all drivers must demonstrate compliance with higher
medical standards at each renewal.
Government intervention is necessary to implement the Directive into British law.
What are the policy objectives and the intended effects?
To implement the Directive into British law in such a way that licence holders are able to demonstrate
compliance with higher medical standards, without imposing a disproportionate burden on drivers and
the medical profession.
What policy options have been considered? Please justify any preferred option.
DVLA considers that requiring drivers under the age of 45 to complete a medical declaration at each
5-year renewal provides the most appropriate and effective balance in respect of the burdens on
drivers and improvements to road safety.
When will the policy be reviewed to establish the actual costs and benefits and the achievement of the
desired effects? The Directive must be in national legislation by 19 January 2011, and put into
practice by 19 January 2013. The intention is to review it after 3 years as part of a wider EU review.
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Summary: Analysis & Evidence
Policy Option: 1 Description: Applicants to complete a self-declaration of medical
compliance under age 45
ANNUAL COSTS Description and scale of key monetised costs by ‘main
affected groups’
One-off (Transition) Yrs
DVLA forms, guidance, staff , office infrastructure and IT running
£ 91,551 3 costs.
COSTS
Average Annual Cost
(excluding one-off)
£ 72,158 Total Cost (PV) £ 756,023
Other key non-monetised costs by ‘main affected groups’
ANNUAL BENEFITS Description and scale of key monetised benefits by ‘main
affected groups’
One-off Yrs
£0
BENEFITS
Average Annual Benefit
(excluding one-off)
£0 Total Benefit (PV) £0
Other key non-monetised benefits by ‘main affected groups’
Key Assumptions/Sensitivities/Risks Risks DVLA expects to receive about 130,000 Group 2 licence
renewal applications each year.
Price Base Time Period Net Benefit Range (NPV) NET BENEFIT (NPV Best estimate)
Year 2009 Years 3 £ N/A £ - 756,023
What is the geographic coverage of the policy/option? GB
On what date will the policy be implemented? 19/1/2013
Which organisation(s) will enforce the policy? DVLA
What is the total annual cost of enforcement for these organisations? £ N/A
Does enforcement comply with Hampton principles? Yes
Will implementation go beyond minimum EU requirements? No
What is the value of the proposed offsetting measure per year? £ N/A
What is the value of changes in greenhouse gas emissions? £ N/A
Will the proposal have a significant impact on competition? No
Annual cost (£-£) per organisation Micro Small Medium Large
(excluding one-off)
Are any of these organisations exempt? Yes/No Yes/No N/A N/A
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Impact on Admin Burdens Baseline (2005 Prices) (Increase - Decrease)
Increase £0 Decrease £ Net £
Key: Annual costs and benefits: Constant Prices (Net) Present Value
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Evidence Base (for summary sheets)
Compliance with Group 2 medical standards for 5-year administrative renewal
Proposal
1. To implement the requirement that holders of Group 2 driving licences must demonstrate
compliance with minimum standards for physical and mental fitness for driving when they
apply to renew the administrative validity of their photocard licence.
Current Practice
2. At present, entitlement to drive medium and large lorries, minibuses or buses is valid until
the person reaches age 45, after which the driver needs to renew the licence every five
years until age 65. Thereafter, entitlement must be renewed yearly. The administrative
validity of the card itself lasts for 10 years.
3. To obtain a provisional Group 2 licence, an applicant must undergo a medical
examination and submit a medical report. Further examinations and reports are required
with each entitlement renewal after the age of 45. There is an on-going requirement for
drivers to notify DVLA of any medical condition that might prevent them from complying
with the required health standards.
New Provision
4. All Group 2 licences will have a 5-year administrative validity. The effect of the change in
Great Britain is that drivers under the age of 45 will have to renew their licence every five
years instead of 10 years as now. Alignment measures would need to be used to
synchronise the photograph validity with the renewal validity. To be able to renew, drivers
must demonstrate compliance with minimum medical standards.
Proposal
5. DVLA proposes that the procedure for Group 2 drivers under the age of 45 should be that
they self-declare their compliance with medical standards. In addition, we propose that
the driver renew their photograph every 10 years, as now, and not with every 5 year
administrative renewal.
6. Estimates of costs and benefits have been based on the following information and
assumptions:
Based on the number of renewals required for drivers under the age of 45, and the
distribution of the ages of Group 2 licence holders, DVLA can expect to receive about
130,000 Group 2 licence renewal applications each year. (We would maintain the status
quo on photograph renewal, every 10 years).
DVLA will spend an estimated £100,000 on staff training and the replacement of existing
forms and guidance notes.
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DVLA will need to employ 4 extra administration staff at a cost of £80,000pa. Staff
resource estimates include salary and office infrastructure (desk, equipment etc) per
person.
Option: medical report with every administrative renewal
7. The option to require a medical report with every administrative renewal was considered.
Based on the above information and assumptions, this option would affect customers in
the following way.
8. One off costs for production and distribution of new forms and guidance would be
estimated at £100,000. Annual costs are estimated at £14,239,600 of which £14,159,600
will be an additional cost to the driver (medical examinations and reports and loss of
leisure time) and £80,000 will be an additional costs in DVLA’s budget for extra
administrative staff.
Proposal - Self-declaration of medical compliance
9. Based on the above information and assumptions, this option would affect customers in
the following way.
Summary of Costs
One-off costs £
Production and distribution of new forms and guidance (estimate for 100,000
purposes of this assessment)
TOTAL 100,000
Annual costs £
DVLA employment costs (4 extra administration staff) 80,000
TOTAL 80,000
10. DVLA considers that this proposal provides the most appropriate and effective balance in
respect of the burdens on drivers and improvements to road safety.
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Impact Tests: Checklist
Use the table below to demonstrate how broadly you have considered the potential impacts of your
policy options.
Ensure that the results of any tests that impact on the cost-benefit analysis are contained
within the main evidence base; other results may be annexed.
Type of testing undertaken Results in Results
Evidence annexed?
Base?
Competition Assessment No Yes
Small Firms Impact Test No Yes
Legal Aid No Yes
Sustainable Development No Yes
Carbon Assessment No Yes
Other Environment No Yes
Health Impact Assessment No Yes
Race Equality No Yes
Disability Equality No Yes
Gender Equality No Yes
Human Rights No Yes
Rural Proofing No Yes
Regulatory Enforcement and Sanctions Test
Specific Impact Tests
Small firms impact test
There should be low overall impact from the proposed changes to small business. For
changes that lead to an increase in driving licence fees the assumption is that the cost of the
licence is likely to be met by the applicant unless specific arrangements for reimbursement
have been agreed with the employer. Also, applicants are expected to complete their own
application forms and provide supporting evidence themselves.
Competition assessment
Employers may choose to meet the costs for the individual. The markets affected by these
proposals are broad based and it is unlikely that any single business would be affected to a
greater degree than competitors of a smaller size. Costs that may fall to specific sectors
would be directly related to the size of the business.
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Enforcement, sanctions and monitoring
There will be no new enforcement implications or sanctions needed directly as a result of
implementation of these proposals. Driver checks would be made in relation to the current
drivers licensing regime.
Environmental issues
It is considered that the options put forward are unlikely to have any adverse environmental
impact. Improved driving and riding standards should improve fuel efficiency and reduce
carbon and other emissions.
Health impact assessment
Improved driving and riding standards should reduce road traffic casualties and improve
health.
Legal aid
There would be no increase in requests for legal aid as a direct result of the implementation
of these proposals.
Sustainable development
In view of the above, it is considered that there would be insignificant impact to sustainable
development.
Equality/Human Rights impact assessment
The Department does not consider that the options being put forward in this document will
have any adverse impact on the grounds of race, gender or disability etc. Special
arrangements will be made for practical tests for physically disabled citizens.
Trainers and the DSA will hold the same data on clients as is the case at present. The DSA
will upgrade driving licence entitlements with the same electronic system utilized currently.
There are no indications that the amount of data stored on individuals will increase or that
there will be a significant amplification of data traffic as a result of implementation.
Nevertheless the DSA carried out the initial screening process for a Privacy Impact
Assessment (PIA) which showed that a PIA was not necessary.
Rural communities
We do not anticipate that there will be an adverse impact on rural communities.
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Ministerial Sign-off For Consultation Impact Assessments:
I have read the Impact Assessments and I am satisfied that, given the available
evidence, they represent a reasonable view of the likely costs, benefits and impact of
the leading options
Signed by the responsible Minister:
Date:
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