Driving Instructors Branch of Unite the Union April 2014 | Page 8

I think there are just too many hurdles for DVSA to jump over to ever make this piece of legislation work. The topic of having compulsory display of licences on test has been discussed at meetings for the last decade. It’s going to carry on doing so for the next ten years too.

There’s only one possible reason the DVSA wants a licence to be displayed on test. It’s to allow it to legally tag the test data from the DL25 to an individual ADI’s file. Which would mean that it then supposedly has that ADI’s pass rate on file.

But there is a very big problem with that data.

It doesn’t show that the ADI has actually taught that candidate, it is simply showing who it was that accompanied them to the test centre. It gives no indication whatsoever who trained that candidate, so is useless as a guide for trying to assess the standard of an ADI based on how well or poorly the candidate performs on test, which is what a pass rate is supposed to be about.

What if the ADI who had trained the candidate was ill on the day of test and asked a colleague to take the pupil in the poorly ADI’s car. Whose licence would need to be on display? If the colleague was required to put his licence in the car, the DVSA would then be tagging that test data to his/her file, rather than the actual trainer, which then creates even more inaccurate records.

So it would seem that forcing the ADI to display a licence for test has too many problems attached, and no reasonable purpose, for it to work, and therefore cannot work.

Perhaps this regulation is going to specify that it is a car on test rather than the ADI which has to display an ADI licence?

What if the car is a private runner which doesn’t have an ADI licence? Will they be banned under the new rules? Maybe it will only apply to driving school cars? But that would rule out all the dual control car hire companies’ cars like Arnold Clarke, MSL etc. from test.

And what defines a driving school car? Will it only apply to cars which have driving school livery? My car is privately owned and privately registered and looks like any other private car, with removable L plates for when it is not being used for tuition.

No, having a regulation that applies to cars isn’t going to work is it. Whoever wrote that bit of legislation obviously didn’t do a lot of thinking and appears to have thought it up during a coffee break.

There’s another little bit in the legislation which also doesn’t make any sense.