Sent: 20th August 2021

Dear DVSA,

We are writing to you as The Driving Instructor and Trainers Collective – Signposting point for the industry and advocate for ADI benefits and support. Our reach includes 10,000+ ADIs and PDIs, and we wish to respond to the recent recovery related emails broadcast by the DVSA. We are pro-DVSA and value the working relationship we have but, as with all successful relationships, we need to be able to raise issues, concerns and objections.

Having canvassed many ADIs we know they are ranging from scared to helpless, to worried, but I do not know how to put these individuals emotions into words. I don’t think many can truly understand the process being felt by instructors at the moment, and we cannot stress how seriously this is affecting us all, or how the majority want to be part of the solution without the apparent threats of losing what they have fought to save. So many haven’t had the luxury of paid lockdown, financial support and even government grants. We genuinely cannot over-stress the individual suffering already being faced and how deeply recent communications have affected them. Having waited to hear from the NASP engagement over this matter, which has arrived today, we still feel it important and necessary to lodge an objection, disagreement and constructive thoughts regarding the targeted Standards Check plans. While the NASP Q&A publication answered some questions, there seems to be little being said to object to the plans – maybe they are in full support? We would find disappointing.

Firstly, we wish to acknowledge the incredibly challenging situation faced by the DVSA and its staff. We are under no illusion that we all face a gargantuan task of recovering from COVID/Lockdown delays and recognise the need to work together to resolve it. At DITC we are particularly aware of the mental health risk to ADIs and PDIs as a result of the last 18+ months and receive daily contact from ADIs struggling financially, emotionally and from the stress of being unable to help. Phones ringing, emails pinging and social media nagging for availability, support and guidance that we just can’t give. We are sure you will agree that the ADIs we want on the register are the diligent, caring and dedicated ones who want to help. These are often the ones being most affected by the struggles. The DVSA sometimes doesn’t acknowledge the fact that we, the trainers, are the front line. We act as an unpaid triage for the DVSA, providing primary support and guidance.

Secondly, to address the specific recent announcements from DVSA. We understand the logic, that increased pass rates will reduce the demand on capacity. However, we believe it is shortsighted, ill founded, and has been poorly put across to ADIs. Allow us to cover why, and provide some areas that need addressing.

A survey of ADIs by ‘The Instructor Podcast’ showed:

82% disagree with targeted Standards Checks to address the waiting list

13.5% agreed

4.5% Don’t care

The message from the DVSA has been taken by most ADIs as accusational. Pointing the finger of blame for ‘low’ pass rates firmly at ADIs. It has been met by fear and panic, and a stick to beat them with. There are a number of issues with this:

This ‘low’ pass-rate is the same (if not slightly better) as it has always been. Despite DVSA changing the criteria and format of the test in 2017. It mirrors practical pass-rates in many countries where different systems and standards are in play (e.g. Australia and Denmark). This seems to suggest that the test process is not solely about readiness. As ADIs we see social pressure, culture, beliefs, and environment, as well as examiner attitude and engagement.

All evidence points to experience being a key factor. If we wish to improve pass-rates then we need to maximise experience and learning opportunities. Yet, DVSA is continuing to prevent candidates from achieving this with early termination of tests after a serious or dangerous fault. If we are focussing on an ADIs skill to assess readiness, this is not exclusive to first-time passes. The ability to assess what needs work, what the test has caused by way of response and how to pass next time is essential.

Following on from the previous point, DVSA are preventing ADIs from assessing the readiness of the candidate in the test environment by not allowing them to sit in on tests, resulting in repeated fails that could have been prevented. The DVSA always seem reluctant to acknowledge the effect of the test itself, however well we prepare, assess and mock test our pupils, the test day has a different effect on everyone (see teaching test routes below). Also, PDIs are being prevented from learning what test standards and conditions are as they are not allowed to witness them occurring. Both of these factors are representative of the DVSA being a root cause of any alleged failings in the ADI/PDI ability to assess test-readiness.

Additionally, the inability to sit in on tests is undermined by it being apparently ok to have 3 in a car for a Standards Check. We know the DVSA justified response is that it is about necessary risk, but in our opinion to achieve adequate assessment of readiness and meet DVSA demands on ADIs, sitting in on tests is a necessary risk.

We are told by the DVSA to focus on ‘Safe Driving For Life’, yet time and time again the DVSA themselves encourage a test focus (examples of personal experiences available). Arguably, improving pass-rate (rather than post-test success) is better served by teaching test routes. While evidence points to this decreasing road safety and ‘Safe Driving For Life’-goals.

ADI Training – the DVSA have the ability to set the training requirements and haven’t. They dictate the test standards but not the training standards. Even ORDIT, a voluntary system, has no continuity in what is delivered. Training ranges from incredibly sub-standard test focus to the incredibly good, but there is little way of pre-PDIs identifying what ‘good’ is. You are only as good as the training you receive. If ‘test readiness identification’ is the issue, then where is the training from the experts in the test standards, the DVSA?

We welcome the 8-week prior call from ADI Enforcement IF it is constructive. In fact, as listed below, we view this opportunity as more beneficial to the ADI than a Standards Check. However, regarding the planned targeting of Standards Checks itself:

We know that DVSA test report figures are inaccurate and inadequate. They do not allow for SEN (Special/Specific Educational Needs) or anxiety specialists, badges not being displayed, support of private practice and own car use or tests covered by other instructors.

The assessment of ADI standards (pass-rate and fault analysis) is historic. Without test availability, we are unable to change it. Therefore ADIs are damned either way with no opportunity to improve.

The suggestion is that the DVSA have IDENTIFIED a fault that needs addressing, that of the assessment of ‘test readiness’. Their ANALYSIS suggests that a candidate failing is down to the ADIs assessment of their ability level. (It ignores the 6 month waiting list if the 50/50 candidate is prevented from attending, the financial and emotional pressures on the candidate AND ADI, and the increased chance of failure caused by a candidate and ADI knowing a fail will be faced by a potential 6-month waiting list…) Their REMEDY is that a Standards Check will address this. We would be interested to hear how taking (for example) a pupil with 2hr prior experience to a Check will demonstrate or improve an ADIs ability to assess test-readiness? It doesn’t. Apply these criteria to a Standards Check form and you would suspect it will result in a FAIL.

Language is something we will be highlighting in DITC messages and publications as we go forward. The focus on ‘pass rate’ over ‘success rate’ is one that seems to counter the ‘Safe driving for life’ message. Being ‘test-ready’ instead of ‘ready to drive independently’. The DVSA encouragement for test-focus shows the lip-service which is being paid to life-driving. This is reflected in the Standards Check plans. While we would like to think this is maybe a symptom of prioritisation – test passes are the solution for the current problem that DVSA are being judged on – we will have to wait for the responses and measures to come from Driver 2020 and other studies to see if DVSA can demonstrate their ‘Safe Driving For Life’ motto in practice.

Finally, there seems to be a DVSA opinion that while pupils with different needs (SEND pupils and those with anxiety and other challenges) will take longer to learn and may take more lessons, all are equal at the point of taking the test. We would be interested to hear if this is held up by test statistics? It seems to penalise the instructors that support those that find the test process challenging and will encourage ADIs to turn away those that need this support the most.


As we stated at the start, we are under no illusion of the severity of the task at hand. In fact, we possibly have a better idea than the DVSA as we know how many are NOT in the queue for tests, are struggling to take or re-take the theory due to lack of SEN support, and are unable to start their journey due to finding an instructor or even getting a provisional licence. However, there is only one thing worse than inaction, and that is making the wrong action.

Issue – ‘low’ test pass rates – Let’s look at why people fail. Yes, we have had excellent engagement with ‘Top 10 reasons of the test fails’, but what about a video of a ‘real’ test allowing the candidate to watch the process from beginning to end? Engage experts on dealing with stress and tests in a series of videos from DVSA with the DVSA stamp on them.

Issue – Identifying ‘good’ PDI/ADI training – Where is the list of what you should be being taught? GDE (Goals for Driver Education) matrix, CCL (Client Centred Learning) skills, test readiness identification, Roadcraft/advanced skills, the National Standards. Even real support and increased standards for ORDIT.

Issue – A better relationship between ADIs and DVSA – The employment of an ‘ADI Advocate’ on the side of the DVSA. Someone that is employed specifically to fight the corner of the ADIs inside the DVSA. This isn’t taking anything away from NASP and others that do a tireless job of protecting ADIs interests, but the need for an institutional counterbalance would provide a stronger working relationship.

Issue – Identifying test readiness – ADIs have not been taught this. We are traditionally taught fault identification under the scheme endorsed by the DVSA. We suggest education tools are provided for identifying readiness. You claim to be the experts in readiness, we welcome constructive sharing of these skills.

Issue – Inaccurate test data – Until the data is accurate ADIs will not have faith in the system. Improving data collection will improve both faith and the accuracy of any measures based on it.

Issue – Certified readiness – Change the theory certificate number, to an ADI certificate number. A certificate issued by an ADI stating the driver is ready to book a test. This doesn’t require enforced lessons with an instructor and can be done as a 2hr assessment. Triaging the booking process and improving management information for DVSA records.

Issue – Success vs Test focus – Rather than assess instructors on the test result, monitor the two year period (identified by the New Drivers Act) after they initially pass. Working with insurers to reduce road risk.

Issue – Candidate beliefs – (Initial idea by Terry Cook ADI) An email 2-3 weeks before their test in which they are required to self-certify their readiness.

There are numerous options including:

Simply signing to agree they are ready for the test.

Questionnaire – Which ADI/PDI have they completed training with if any? How many hours? Private practice? Confirmation of readiness. This way we can develop a better picture than the questionable staple 47hr lessons + 20hr practice.

Quiz-style – How do you rate yourself readiness? Listing core skills and manoeuvres, road types and situations. Using a scaling approach could lead to a tailored outcome response. “Your responses suggest you are/are not ready” and “People like you resulted in a 40% chance of passing first time” etc. Using behavioural psychology to influence their readiness.

We are also writing to NASP, its constituent parts (ADINJC, DIA, and MSA), and others, to ask their response to the announcements. Are they united behind the message and actions, or are they opposed to such an approach? We will be sharing their responses as we receive them. We invite you to do the same, and equally welcome ‘off record’ discussions to clarify further as we appreciate the need for congruency in such difficult times.

Yours Sincerely

Chris Bensted ADI

On behalf of The Driving Instructor and Trainers Collective

Posted by Chris Bensted

August 24, 2021

Categories: News