News
3DLD Consultation
Dear All,
Please see below a communication from the MCIA regarding a consultation paper put out by the Driving Standards Agency concerning the implementation of the 3rd Driving Licence Directive. You may be aware of the recent 2nd Licence directive that has recently been introduced creating a two part test for motorcycles - part 1 off the road in a training area, and 2nd part on the road, which has already made it more challenging to obtain a full motorcycle licence not to mention the possibility of rising costs.
The 3rd Driving licence directive creates yet more barriers for new riders to cross before gaining a full motorcycle licence and it is vitally important that the motorcycle industry and all those with a vested interest in motorcycling take the time to respond to the DSAs consultation. The communication from the MCIA below sets out their concerns and attached is a PDF document that provides the answers you are required to make in the best interests of the industry.
Could I therefore ask that everyone takes some time to look at and respond to this consultation. A link to it can be found in the guidance notes attachment. We mustn't forget that this consultation is open to all categories of licence holder and if the motorcycle industry does not stand up and make its views heard, then there are plenty of others out there that may present an adverse view of motorcycling completely outside of our control to the detriment of our industry and ultimately our livelihood's.
This is important, please follow the advice attached and help our industry protect itself.
Thank you for your Support
Best regards,
Steve Manning
ART Motorcycle Training,
MCITA 3DLD guidance notes, the link to the consultation paper can be found Here or you can print and post if you prefer.
The DSA recently launched a Consultation into the UK implementation of the 3rd Driving Licence Directive (3DLD). We are asking members to take the time to respond to this Consultation as the changes proposed in this Consultation could have a massive impact on the motorcycle industry, at a time when stability is important. The motorcycle industry as a whole have been hit hard by the recent changes to testing with our trainer members reporting a 40-60% drop in business. We cannot afford to sit back and wait for more legislation to affect our market.
3DLD will introduce an extra step in the already complicated motorcycle licencing regime creating a new middleweight category. The age for Direct Access will rise from 21 to 24, and the UK has a choice as to whether riders taking the Progressive Access route can move from a lower licence category to the next category via a test or 7 hour training event.
The attached guidance notes have been formulated by the MCITA Committee, representing the views of the 191 Trainer members of MCITA. These trainers are a valuable resource for 3DLD issues. The trainers are on the ‘front line’ and would have to deal with each and every issue in the Consultation on a day to day basis. The MCI’s Chief Executive, Steve Kenward and the Safety Department staff are in complete agreement with these views and would encourage as many MCI members as possible to take part and respond to the consultation. If you have access to the dealer network, any encouragement you could offer them to reply to the Consultation would be very valuable.
The deadline for submissions is 5th February 2010
The Driving Licence Directive text and the Consultation itself are both detailed and complex, if there is anything you do not understand or you need any further advice or guidance, please do not hesitate to contact the MCIA on 02476 408032 or via e-mail. MCI staff and also Trainers will be on hand at Expo with the facility to complete the Consultation reply either on line or by paper copy.
MCITA Position Statement
Related to question 3 of the Consultation - In the matter of the implementation of 3DLD the motorcycle industry calls on DSA to adopt the progressive training option as an opportunity to improve long term rider safety with embedded progressive training processes, delivered to a common standard, quality controlled and wisely governed.
However industry recognises recent events, not least the implementation of 2DLD and the current economic circumstances, must be considered.
These events cause the motorcycle training providers, as the delivery agents to be:
a) Sceptical about DSA’s ability to introduce such a progressive training scheme, and
b) Concerned for their commercial viability if such a scheme where introduced at DSA’s indicative cost levels.
It is therefore with regret, and irrespective of the improved rider safety benefits available, that the training industry must reluctantly favour the 3DLD testing route in the short term as the only option available that provides a known, if less than perfect, stable environment that may offer a semblance of commercial survival for trainers, without barring access to motorcycling as a transport mode due to excessive cost of entry.
Industry calls for a standard to be introduced over time to ensure that all riders taking training prior to test presentation are trained to an equivalent level thus building the foundation of a national rider standard.
Industry will in the medium term, continue to press for the progressive training option recognising the opportunity to improve long term rider safety with embedded progressive training processes, delivered to a common standard, quality controlled and wisely governed,
and would not want to see this option excluded from legislation merely because it must act in the face of a short term expedient position.
Related to question 6 - Industry also strongly rejects the idea of familiarisation training for progressive access. This amounts to ‘gold plating of the directive as it requires mandatory training AND testing, when only one of these is required to comply with EU regulations. The idea of allowing progressive access riders who have taken this familiarisation training on the roads unaccompanied whilst using L plates on unlimited machines will not improve rider safety in the long term and will encourage perpetual learners on A2 and A category machines. We strongly urge the DSA to reconsider this proposal.
