EU Proposals On 3rd Driving Licence Directive
BMF Response to Department for Transport Consultation
Note: The form has been reformatted since it has not been possible to provide a simple 'yes' or 'no' answer to most of the questions.
Additional comments on the European Commission’s proposals have been added including extensive alternative suggestions in relation to the Category A (motorcycle) proposals.
BMF Government Relations Executive,
8th April 2004
The BMF has carefully examined and considered the proposals by the European Commission from the documentation attached to the consultation. Through our membership of the Federation of European Motorcyclists’ Associations we have been enabled to extensively discuss issues related to the Third EC Driving Licence Directive with our European partners.
We have used the opportunity offered by the stakeholders’ meeting held at the Department for Transport, where Herald Ruyters gave a presentation and answered questions, to further discuss and clarify the aspects of the draft Directive which affect motorcyclists.
The BMF also took part in a more recent meeting at the Driving Standards Agency premises at Cardington to more deeply consider questions raised by the European Commission’s proposals and the UK Government’s point of view. We have concluded that the proposals in the draft Directive are difficult to justify except as ‘busy work’ on the part of the European Commission.
When the Second EC Driving Licence Directive was developed and agreed by the EC Institutions, it was intended to harmonise licensing practice throughout the European Community but signally failed to do so.
In introducing the alien concept of a stepped driving licence for motorcycles to the UK, far from improving motorcycle safety, the Directive instead created more bureaucracy, no improvements to motorcycle safety that were not already taking effect and particular problems associated with the Direct Access Scheme.
The proposals in the Third EC Driving Licence Directive have continued on this path in which more bureaucracy is to be introduced for questionable benefits. Yet, the issues of mandatory pan-European eyesight checks and serious consideration of progressive access to more powerful cars has been ducked - presumably because the Commission does not wish to take on the powerful motoring lobby.
Instead, obtaining a full motorcycle licence is to be made yet more complex and probably more expensive, while the proposal fails to make clear precisely how the changes are expected to lead to improvements in road safety, although this is presumably the primary objective.
The real problem in the UK, that of the safety of riders significantly older than 24 who gain a motorcycle licence via the Direct Access Scheme, is emphatically not addressed. We consider that motorcycle licensing has been singled out for this treatment for no other reason than "because the European Commission can" since the motorcycle lobby has less clout than the motoring lobby and is not as well empowered to fight its corner.
Increasing the complexity of the motorcycle licensing process will result in confusion among the motorcycling and enforcement communities leading to less compliance and poorly applied enforcement. This, in turn is expected to lead to a diminution of motorcycle safety rather than the anticipated (by the European Commission if no one else) improvements.
We note that the covering letter for this consultation encourages us to think that somewhat more than mere tinkering with some of the detail of the proposals may be possible in the Government’s negotiating position. For this reason, we have responded frankly and have made a number of recommendations that are not strictly in the spirit of the proposals as intended by the European Commission.
The BMF recommends that the Government should strive to reject the draft Directive and return it to the Commission for redrafting to produce a simple understandable system which will improve safety. The revised proposals should then be subject to full consideration by the enlarged European Union.
Last reviewed/updated 23/09/04