Memorandum by John Stanley Esq and Peter
Jenkins Esq (TEA 03)
THE TRANSPORT-RELATED EXECUTIVE AGENCIES
OF THE DETRDRIVING STANDARDS AGENCY
DRIVING TEST CENTRE CLOSURES
In its latest Business Plan10, the DSA proposes
a further change to its policy affecting the closure of driving
test centres. Mrs Dunwoody asked a question in the House about
the policy and was given an incomplete reply11.
Our concerns are to do with the effects of the
policy on access to the driving test, its timetable, the reasons
for the change and its overall reliability. In addition, we are
concerned about the overall effect the policy will have on local
test centre provision and if it is likely, in the longer term,
to contribute to an increase in unlicensed drivers.
The DSA has offered reductions in demand as
a main reason for closing a test centre in the past. However,
as was witnessed in Crosby, such arguments could not be sustained
by the Agency and it moved the goalposts to achieve its desired
resultclosure of the test centre. In doing this, it acknowledged
the intense volatility of demand and the difficulties this created
in terms of accurate measurement. Nevertheless, it continues to
use demand reduction as a key argument in favour of a test centre
The DSA fails to balance its demand argument
against the potential demand which exists in the market place
as a result of unlicensed drivers (800,000 and rising), not to
mention the group of people who passed the theory test but failed
to apply for the practical (some 300,000). Until research on both
is complete might it not be wise for an organisation to act cautiously
before implementing a policy that might feasibly decimate the
only resource it has for coping with such demand?
10 DSA Business Plan 2000-01 Page 27.11 Parliamentary
Question 125585/20 June 2000.
We are concerned that the policy is cost driven
and that mechanisms exist and are used by the DSA to give it an
unfair advantage over those who might oppose its views. In our
opinion, some of these mechanisms are prejudicial, unsoundeven
unreliable. To use them as a means through which the Agency reduces
a valuable public service calls into question the validity of
the whole process.
1. THE POLICY
1.1 The change referred to earlier is encapsulated
in the following statement:
". . . the Minister has accepted that a
smaller estate could satisfy demand for tests and that over the
five year period it will be necessary to close centres that are
no longer viable. In rationalising the driving test centre estate
we will carry out reviews of groups of centres rather than individual
centres. Closures will be announced as a package, including those
centres where test routes are unsatisfactory." (Business
Plan 2000-01 p 27.)
1.2 In an earlier paragraph, the DSA sets
itself new targets for the disposal of all vacant space over a
five-year period. As a matter of principle, the DSA will "hand
back vacant space to the major occupier of the building at the
earliest opportunity (where the building is occupied by another
government department), relocating to smaller properties or combining
driving test centres, and either disposing of the freehold interest
or handing the property back to the landlord". (Business
Plan 2000-01 p 27.)
1.3 We are not told how many test centres
fall into the category of "shared premises", where the
Agency is not the major occupier of the building, nor is there
any indication of the criteria to be used to determine when test
centres are likely to be combined or relocated. In short, we don't
know to what extent the test centre estate is likely to be affected
by the change, nor are we told what arguments were used by the
DSA to convince the Minister that a smaller test centre estate
could satisfy demand for tests.
1.4 What does emerge is that the DSA is
using a much broader brush to review the test centre estate than
hitherto and is adopting an area-wide approach to determine if
fewer test centres are able to cope with falling levels of demand.
1.5 The problem with this is that demand
is volatile. The DSA has found it difficult to predict with any
real accuracy, apparently ignoring the potential problems inherent
in the increasing levels of uninsured drivers, not to mention
the 300,000 successful theory test applicants who failed to present
themselves for the practical test. Whilst the Agency points to
demand reductions of the order of 1.2 million fewer tests from
1998-99, a potential market exists for at least a further 1.1
million test candidates (800,000 unlicensed drivers, 300,000 "missing"
practical test candidates). It is wise to reduce the means by
which the Agency would cope with this additional demand if it
materialised at some point? Has any of this formed part of the
DSA's assessment when putting its case to the Minister?
1.6 The first evidence of the implementation
of the new policy comes from a letter from the DSA referring to
the Inverness area12. This speaks of "property zones",
demand within the zone and income versus costs of providing a
service in that zone. It speaks of reducing costs without an unacceptable
deterioration in service levels, including waiting times and travel
distances to test centres. The DSA has not defined its terms clearly
and must state what it means by "unacceptable deterioration"
and whether it will actively listen to is customers' concerns
about waiting times and travelling distances. There is little
reliable evidence so far to show that it does.
2.1 The DSA's consultative template, used
in the process of closing a test centre, has long been the focus
of criticism in some quarters. The main focus of attention has
been the Agency's insistence on Chief Executive and Ministerial
consultation prior to the whole process being opened up to other
interested and affected parties13. From these, it can be seen
that the Agency has still retained the right to obtain approval
in principle of a closure from the Chief Executive and the Minister.
2.2 This is the most objectionable aspect
of both documents because it lays the DSA open to accusations
of bias and prejudice and does not give those who oppose the DSA
the chance to participate in a fair and open consultative process.
Unfortunately, in referring to the Minister at such an early stage
in the process, the DSA can invoke the protection afforded by
the Code of Practice on Access to Government Information. If it
is asked to disclose the nature and extent of its "pre-consultations"
it can safely refuse, as it has already done, because the process
involves Ministerial advice! No one, apart from a privileged few
on one side, has any idea what happens at this stage. The DSA
has attempted to explain why it feels the need to do this and
has only muddied the waters with contradictions. The most worrying
of these is a reply to a Parliamentary Question14 in which the
DSA states it is seeking permission from the Chief Executive and
Minister to consult! Senior officers have sought to explain it
away in different and more confusing terms and, in doing so, have
created even greater mistrust of the whole process!
2.3 A further concern is the reassurance
given by the Agency that it will fairly and accurately present
all opposing views to the Minister. One would hope that this should
provide the Minister with a balanced view upon which he can reach
an informed decision. This pre-supposes that the DSA does a fair
and accurate job of representation to the opposition but unless
those whose views are represented are given access to the DSA's
report to the Minister, they will never know how their case was
presented. Furthermore, access to the report can be denied to
those people as it constitutes Ministerial advice under the Code
of Practise on Access to Government Information. The DSA took
this view in the case of Crosby, even though criticised by the
Ombudsman and the Chairman of the Public Administration Select
Committee for doing so!
12 DSA letter to DIA regarding DTC provision in Inverness
area 25 September 2000.13 Two templates: (a) 10/98 and (b) 01/00.14
Reply to Parliamentary Question 111695 / 29 February 2000 / C
2.4 This situation is unfair and unnecessarily
secretive and it gets worse! How is it in the interest of fairness
and natural justice to allow an Agency with a declared vested
interest in one outcome, to represent its own case and that of
the opposition to the Minister? How and why is such a situation
tolerated within a government that declares itself committed to
openness and to a fair deal for its citizens?
2.5 Still worse is to come! There are no
avenues to appeal against a decision to close a test centre. Any
complaints that may arise find their way back to their source
within the DSA, even when referred to a Minister! There does exist
an Independent Complaints Advisor within the Agency. However,
the lady in question is subsidised and paid for by the DSA and
even she has admitted there are problems in conceiving her role
as genuinely objective and independent. The public perception
is of an Agency "investigating" itself.
2.6 There are serious problems with the
consultative process, in that it is perceived as biased, objectionable
and prejudiced. It requires urgent revision if the DSA wants to
retain the trust and confidence of its customers.
3.1 These have been the subject of considerable
change and fluidity since first appearing in Agency Business Plans
in the early to mid 1990s. As one example the DSA referred to
the "Despatch" of Winter 199815. A further example is
contained in the DSA's reply to a Parliamentary Question from
Claire Curtis-Thomas on 27 March 200016.
3.2 There is no question here of saying
that every test centre in the country should remain open, regardless!
There is enough evidence to show the need for some "rationalisation"
as long as it is carried out in a professional and reliable manner.
The piece in the "Despatch" states that: "The Agency
has no plans for a one-off, wholesale cut in the number of practical
test centres . . .". At the time the Select Committee last
questioned the DSA, 61 test centres had closed, representing almost
one fifth of the total test centre estate. More are under review
but no precise figures are available from the DSA to confirm the
extent of the current "rationalisation" programme.
15 Copy of "Despatch" Winter 1998 p 14.16
Reply to Parliamentary Question 115776 / 27 March 2000.
3.3 When the criteria are examined in detail,
some are seen to be eminently practical and sensible, especially
where waiting areas, car parks and toilets are discussed.
3.4 However, when the distance criteria
are examined, they raise a number of questions. How did they originate?
Why are they used? What is the scientific basis for their implementation?
What demographic principles can the DSA invoke in support of their
use? Even more questions arise when the DSA justifies their use
because of results gleaned from customer surveys! This, the Agency
says, is what the customer finds agreeable and acceptable!
3.5 We have asked many times for more details
of such surveys believing that if the Agency was confident that
the results were statistically sound, it would be equally confident
in defence of their use. Surprisingly (and worryingly) the Chief
Executive ignores the request for supporting data and merely states
he is satisfied that the surveys provide a reliable basis upon
which to build the policy!17. This is hardly the response one
genuinely convinced of the robustness of such surveys. It should
be an easy matter to dispose of concerns about them if the research
had been carried out effectively and reliably.
3.6 Customer surveys can be fickle and unreliable,
particularly if representative samples are not taken or insufficient
proportionate returns received. Why is the DSA so reluctant to
provide comprehensive, verifiable data on the customer surveys
used to implement the distance criteria?
There is one obvious conclusion from the foregoing:
The DSA believes it must reduce the test centre
estate. It fails to say by how much, although the policy change
described certainly implies the use of a much broader brush than
has been used so far. This, in turn, means that the Agency will
target more centres in a wider area than before, a measure that
could feasibly lead to increases in the numbers of test centres
The Business Plan for 2000-01 makes no mention
of the effect this will have on the public service that test centres
provide. There is no quantification of additional costs borne
by the customer who loses a local facility and has to travel miles
to learn and test elsewhere. What of the inequalities and unfairness
such a policy will produce among the DSA's customer base? Access
to the test will be considerably easier for some than for others.
Is the DSA moving away from the provision of local facilities
to more regionally based ones in an effort to save itself money
and because it finds it increasingly difficult to live within
its fee income?
The DSA should be asked to clarify the aims
and objectives of its policy and provide both the government and
the general public with more detail of how it believes these aims
and objectives will be achieved and, at what cost to its customers
in the industry and to the public in general.
We suspect that the policy has not been thought
through in such detail and that the DSA is unable to add further
meat to the bones because the work may not have been done. May
we remind the committee that when the Chairman asked the previous
Chief Executive, Bernard Herdan, how much longer the public would
have to endure the fiasco of the revised and "improved"
telephone booking system, he stated "three to six weeks".
Problems persist even today! Even the theory test has not escaped
the inefficiencies of the Agency and there are genuine concerns
at the apparent tolerance of such failures in some sections of
government. How can an organisation with such a disastrous track
record of customer service possess or even retain a prestigious
The committee is urged to look again at the
Driving Standards Agency and to ask it to account in detail for
its driving test centre closure policy before the test centre
estate is irrevocably reduced.
17 DSA letter to J Stanley 20 July 2000 / Reply to
Gary Austin 25 July 2000.