Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

Memorandum by John Stanley Esq and Peter Jenkins Esq (TEA 03)




  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 result—closure 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 closure.

  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, unsound—even 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.


  1.1  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 Curtis-Thomas.

  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 being closed.

  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 Charter Mark?

  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.

November 2000

17 DSA letter to J Stanley 20 July 2000 / Reply to Gary Austin 25 July 2000.

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