Driving licensing review call for evidence - summary of responses (accessible version)

Question 1

Overview

Accepted Answer

In 2022, the UK government launched a call for evidence about potential changes to the driver licensing regime. The call for evidence review opened on 5 August and ran for 12 weeks, closing on 28 October.

It focused on four areas:

To grant drivers who have a car (category B) licence entitlement additional entitlement to a HGV (category C1) licence.
To grant drivers who have a car (category B) licence entitlement to a minibus (category D1) licence.
To create a formalised instructor programme or training and how this could be made compulsory, to create a formal register of instructors and to publish pass rates for instructors.
Other minor driving licence changes.

The call for evidence includes seeking evidence on the economic benefits of widening the recruitment pool for medium-sized goods vehicles and minibus drivers, which may attract more people to the industry and support economic growth by further strengthening the supply chain.

This report provides a summary of the responses received. It covers the four areas above and includes verbatim comments and evidence received from those responding as individuals and those responding on behalf of a range of organisations, including schools, local authorities and community transport organisations.

Question 2

Introduction and background to the review

Accepted Answer

During the coronavirus pandemic and the subsequent HGV driver shortage crisis, the UK government rapidly put 33 actions in place to address the challenges. Eight actions related to the expansion of HGV driver testing capacity and improving the licensing process. The licensing improvements were achievable partly due to the fact that the UK had left the European Union and as such had the freedom to change legislation to improve the testing and licensing regime.

In 2022 the UK government wished to explore whether there would be any further opportunities that could be available and launched a call for evidence on 5 August. The call for evidence included seeking evidence on the economic benefits of widening the recruitment pool for medium-sized goods vehicles and minibus drivers, which may attract more people to the industry and support economic growth by further strengthening the supply chain. The call for evidence closed at 23:45 on 28 October.

Those who wished to provide evidence were asked to submit this online as part of an online survey. The survey was designed by the Department for Transport (DfT) and included 88 questions. Overall, 2,061 responses were received, including 1,742 responses from individuals and 319 from those representing organisations. As part of the call for evidence, a small number of the 2,061 responses submitted to DfT were done so offline (by post and email). These were anonymised by DfT before being securely transferred to Ipsos for analysis.

Question 3

Summary of the questions asked

Accepted Answer

DfT designed a survey questionnaire consisting of 88 questions, with Ipsos commissioned to analyse responses and prepare a summary reporting of the findings. Those responding to the review were not required to answer all of the questions, but only those they saw as relevant and dependent on whether they were responding as an individual or on behalf of an organisation.

The questions covered:

Background questions, including whether those responding to the call for evidence were doing so as individuals, or on behalf of organisations. Those responding on behalf of organisations were asked to indicate the type of organisation they were responding on behalf of (including schools, local authorities, or transport organisations).
Whether respondents (and employees of organisations) hold C1 driving licences and Category L entitlement. C1 permits the licence holder to drive vehicles between 3,500 and 7,500kg (with a trailer up to 750kg). Category L covers electrically propelled vehicles such as milk floats.
Since 1 January 1997 (due to the EU Second Driving Licence Directive), a separate test has been required to obtain C1 entitlement. However, the call for evidence wished to consider a proposal to allow most, if not all, car drivers to operate vehicles up to 8.25 tonnes and benefits and drawbacks of this.
Exemptions:
- Whether consultees think there are specific purposes of driving of C1 vehicles that should be exempted from Driver Certificate of Professional Competence (DCPC)* for driving in the UK.
- If there are specific purposes of driving of C1 vehicles that should be exempted from DCPC for driving in the UK.
Removal of D1 licence requirement, including if consultees would support the removal of the requirement to obtain a D1 licence test to drive a minibus, impact of the proposal if implemented and concerns raised from those who do not support this proposal.
Views on the possible introduction of a standardised training and qualification for HGV trainers. Whether it should be voluntary or mandatory for those who agreed with the proposal and whether there should be a mandatory register of HGV instructors managed by the Driver and Vehicle Standards Agency.
Other licensing changes, including potential changes to legislation to bring agricultural vehicles within the Category C or CE regime.
Data gathering on minibus services.

(*DCPC is a professional qualification required for drivers of lorries, buses, minibuses or coaches engaged in the commercial carriage of goods or passengers)

Question 4

Profile of those who responded

Accepted Answer

The following table provides a breakdown of the number of responses received. Of 2,061 responses received, 1,742 were from individuals and 319 were from those representing organisations.

Response category	Number of responses
Overall total	2,061
Individuals	1,742
Organisations	319
School	23
Local authority	28
Transport organisation	25
Commercial transport organisation	32
Community transport organisation	93
Another type of organisation*	117
Unspecified	1

(*Including charitable organisations, training organisations, driving schools and trade associations - self-defined.)

Question 5

Analysis methodology

Accepted Answer

Receipt and handling of responses

All responses submitted to the call for evidence were received directly by DfT. DfT removed personal and identifiable information from the responses (e.g. email addresses) before securely transferring the anonymised responses to Ipsos for analysis and reporting. The handling of responses at Ipsos was subject to a process of checking, logging and confirmation to ensure a full audit trail.

Analysis of responses

The online questionnaire included closed/tick-box questions and open/free-text questions. Closed questions were tabulated* and included in a set of computer tables alongside open question responses that were coded. The process of analysing the content of each open question (and offline) response was based on a system where unique summary ‘codes’ were applied to specific words or phrases contained in the text of the response. The application of these summary codes and sub-codes to the content of the responses allows systematic analysis of the data.

Ipsos developed an initial coding framework (i.e. a list of codes to be applied) based on the text of the first batch of responses received. This initial set of codes was created by drawing out the common themes and points raised. The initial coding framework was then updated throughout the analysis process to ensure that any newly- emerging themes were captured. Developing the coding framework in this way ensured that it would provide an accurate representation of what was said. A copy of the computer tables and finalised codeframe/topline are provided as separate documents.

Ipsos used a web-based system called Ascribe to manage the coding of all the text in the open question (and offline) responses. Ascribe is a system which has been successfully used on numerous large-scale consultation projects. Responses were uploaded into the Ascribe system, where members of the Ipsos coding team then worked systematically through the comments and applied a code to each relevant part(s) of them.

The Ascribe system allowed for detailed monitoring of coding progress and the organic development of the coding framework (i.e. the addition of new codes to new comments). A team of coders worked to review all of the responses as they were uploaded to the Ascribe system. The coding team were briefed on the scope of the consultation to aid their interpretation of the comments contained in the responses.

To ensure that no detail was lost*, coders were briefed to raise codes that reflected the exact sentiment of a response and these were then collapsed into a smaller number of key themes at the analysis stage to help with reporting. During the initial stages of the coding process, weekly meetings were held with the coding team to ensure a consistent approach in raising new codes and to ensure that all additional codes were appropriately and consistently assigned.

(*In some cases consultees were able to make comments relevant only to specific sections of the questionnaire. For example, some of those who did not run goods transport services by road made comments only relevant to those who run goods transport services. A decision was made by Ipsos to exclude some comments from the dataset if they were considered to be out of scope).

Question 6

Interpretation of findings

Accepted Answer

A call for evidence is a valuable way to gather opinions about a topic, but there are a number of points to bear in mind when interpreting the responses received. While the call for evidence was open to anyone, participants were self-selecting and certain categories of people may have been more likely to contribute than others. This means that the responses can never be representative of all individuals and organisations in Great Britain, as would be the case with a representative sample survey.

Typically, with any call for evidence, review or consultation, there can be a tendency for responses to come from those more likely to consider themselves affected and more motivated to express their views.

It must be understood therefore that a summary report of findings can only aim to cover the various opinions of those who have chosen to respond. It can never measure the exact strength of particular views or concerns amongst all organisations and individuals in Great Britain, nor may the responses have fully explained the views of those responding on every relevant matter. It cannot, therefore, be taken as a comprehensive, representative statement of opinion. A call for evidence is not a referendum.

It is also important to note that the aim of the call for evidence is not to gauge the popularity of any issues or topics raised in the responses; rather it is a process for identifying new and relevant information that should be considered. All relevant issues are therefore considered equally, regardless of whether they are raised by a single consultee or a majority. While this report cannot cover every response/issue raised in detail, a separate topline/codeframe has been produced which includes all responses to tick-box questions and coded responses to open responses and offline responses (i.e. those sent by post or email).

Question 7

C1 goods vehicle entitlement

Accepted Answer

Categories of licence held

Category C1 and Category L

Consultees were first asked if they had Category C1 and/or Category L on their driving licence. A C1 category allows those who have this on their licence to drive vehicles between 3,500 and 7,500kg maximum authorised mass (MAM) (with a trailer up to 750kg). Category L is a former category of driving licence which allowed a holder to drive any electrically-propelled vehicle, with no size or weight restrictions. It only exists as a grandfather right for some drivers and for a few who took a test on a Category L vehicle.

Individuals

Three in ten (30%) individuals indicated that they have C1 on their driving licence. However, most (68%) do not hold a C1 driving licence. Fewer than one in five (18%) indicated that they have full Category L entitlement on their driving licence. As with answers about C1, most (57%) do not have Category L entitlement. A further one in four (25%) were unsure.

Organisations

Around three-fifths of organisations (62%) indicated that one or more of their employees have C1, while one in four (25%) do not have this. A further one in seven (14%) were unsure. A fifth (19%) indicated that one or more employees have Category L entitlement, while for around one in three (36%) their employees do not have this entitlement. A sizeable minority (45%) were unsure.

Q2: Are you responding?

As an individual	85%
On behalf of an organisation	15%

Base: All consultees who answered the question (2,061)

Q3: Do you hold a C1 driving licence?

Yes	30%
No	68%
Don’t know	1%

Base: Individuals who answered the question (1,737)

Q4: Have you got a full category L entitlement on your driving licence?

Yes	18%
No	57%
Don’t know	25%

Base: Individuals who answered the question (1,732)

Q5: Your organisation is a:

School	7%
Local authority	9%
Transport organisation	8%
Commercial transport organisation	10%
Community transport organisation (section 19 or 22) permit holding organisation	29%
Another type of organisation	37%

Base: Organisations who answered the question (318)

Q6: Do any of your employees hold a C1 driving licences?

Yes	62%
No	25%
Don’t know	14%

Base: Organisations who answered the question (310)

Q7: How many have C1 driving licences?

1 to 5	45%
6 to 10	15%
11 to 99	22%
100+	8%
Don’t know	3%
Number unspecified	6%

Base: Organisations with one or more employees who hold C1 driving licences (192)

Q8: Have any of your employees got full category L entitlement driving licences?

Yes	19%
No	36%
Don’t know	45%

Base: Organisations who answered the question (314)

Q9: How many have L-category driving licences?

1 to 5	43%
6 to 10	22%
11 to 99	18%
100+	5%
Don’t know	2%
Number unspecified	7%
Not stated	3%

Base: Organisations with one or more employees who hold L-category driving licences (60*)

Question 8

Road transport services

Accepted Answer

Potential saving and costs if the C1 proposal was implemented

Those who responded to the call for evidence were asked if they ran goods transport services by road. Around one in fourteen consultees (7%) said they did this. It included 51 organisations and 101 individuals. These consultees were asked a series of questions about savings, if any, that they could potentially make from the C1 licence proposal, as well as any additional costs that could arise if the proposal was implemented.

Most of those who provided comments (98 consultees) indicated that they could make savings as a result of the proposal. Some of those who made comments indicated a monetary figure. For example, there were 29 comments that savings could be between £1,000 and £4,999 and six comments that savings could be between £5,000 and

£9,999. However, others who provided comments did not give a figure.

“As a small business we would save many thousands, plus it’s hard enough to find employees without then having to put them on C1 training too.”

There were 18 consultees who believed that there would be additional costs. Comments received about costs included that the proposal could increase insurance premiums (16 comments) and additional training costs (2 comments). There were also two comments that costs would increase in general and one comment that there could be additional CPC costs.

Insurance costs would likely rise by allowing untrained and untested drivers to drive large vehicles. This has not been thought through in my opinion, you only have to look at the way “white van man” drives to know this. Also CPC training would need to be completed before anyone could drive.

Savings that could be made from the C1 licence proposal - comments

Potential savings if C1 proposal was implemented – most frequently made comments

Comment	Number of times made
£1,000 to £4,999	29
Training costs	26
Training time	15
Savings (general)	14
Test fees	12
Recruitment	7
Under £1,000	7
£5000 to £9999	6
Drivers’ hours / wages	6
Transport costs	6
Vehicles needed in fleet	6

Base: 98 consultees who run goods transport services by road

Costs that may arise from the C1 licence proposal - comments

Comment	Number of times made
Insurance premiums	16
For training to expected standard	2
High costs	2
Extra costs for CPC	1

Base: 18 consultees who run goods transport services by road

Benefits / positive impacts of the C1 licence proposal

Those who run road transport services by road were asked to provide evidence of any benefits that could be realised from the C1 licence proposal, as well as positive or negative impacts, including upon road safety. In total, 114 consultees provided comments.

There were 97 consultees who made positive comments about the C1 licence proposal. The main comment received was that the proposal, if implemented, would help alleviate driver shortage (49 comments). Other comments included that there would be efficiencies as it would allow more single loads and/or bigger deliveries (25), that job opportunities would be created (23) and that there would be benefits with allowing more people to drive C1 vehicles in general (21).

“It would be much more efficient to run a single trip in a 4,600kg van than to be restricted to multiple trips in a 3,500kg van.”

Nineteen consultees provided positive comments around road safety. The most frequently cited comments were that there would be improvements in general (8), less overloading of vehicles (4), that heavier vehicles would have lower speed limits (3) and that C1 vehicles are safer than in the past (3).

“As it would require fewer journeys to transport the goods, this would mean less vehicles on the road, less trips and therefore quieter roads. Hence improving road safety and reducing chances of road traffic collision.”

Benefits – most frequently made comments

Comment	Number of times made
Will help with driver shortage / more drivers available	49
Will allow single loads / bigger deliveries	25
Will create job opportunities	23
Will allow me / my family / my employees to drive C1 vehicles	21
Will save money	15
Will boost the transport industry / benefit businesses	14
Will increase efficiency	10
Will boost the economy	9
Will reduce congestion / less vehicles on the road	7
Will reduce pollution / carbon footprint	7
Will save time	7

Base: All who provided comments about benefits of the C1 licence proposal (95 consultees who run goods transport services by road)

Positive impacts on road safety – most frequently made comments

Comment	Number of times made
Positive impact on road safety	8
Less overloading	4
Heavier vehicles have lower speed limit	3
C1 vehicles are safer than in the past	3
Better awareness	2

Base: All who provided positive comments about road safety as a consequence of the C1 licence proposal (19 consultees who run goods transport services by road)

Negative impacts of the C1 licence proposal

There were 33 consultees who provided negative comments about the impact of the C1 licence proposal. Most (30 consultees) who provided comments did so around road safety. There were 23 comments that that there would be negative impacts due to lack of training and/or driving inexperience and 18 comments that accidents could increase.

Having worked in the large vehicle rental market the worst drivers were the 7.5 ton users, because the entitlement is on their licence they think it’s like driving a car! It will have a negative impact upon road safety.

Other less frequently made comments included that there could be negative impacts on businesses, that it would be unfair to those who had already paid to obtain a C1 licence and that it could reduce productivity.

I think it is an insult to many a professional drivers and for all who hold a CPC. I have had to take a test, which had cost me hard earned money to pass…to let someone pass because they can drive a car is wrong.

Negative impacts on road safety – most frequently made comments

Comment	Number of times made
Inexperience / lack of training leading to road safety issues	23
Increased risk of accident	18
Lack of experience in general	13
Road congestion	2
Negative impacts associated with young drivers	2

Base: All who provided comments about negative impacts of the C1 licence proposal (33 consultees who run goods transport services by road)

Usage of C1 category vehicles if the C1 licence proposal came into force

Those who run goods transport services by road were asked if their use of C1 vehicles would increase, decrease or remain about the same as present if the C1 licence proposal was implemented. Of 145 consultees who answered the question, the majority (70%) indicated that their usage of C1 category vehicles would increase.

Very few (just 3%) said that usage would decrease, while for around a quarter (26%), their usage would not change.

Consultees were asked to explain the reasons for their answer. There were 68 consultees who said that their usage of C1 category vehicles would increase and provided reasons for this. The main reasons given were that the proposal would allow more individuals and employees to drive C1 category vehicles (19 responses), that more drivers would be available (18 responses), that it would facilitate the carriage of larger/heavier loads (13 responses) and would bring benefits to business by creating new opportunities (13 responses).

Because I’m finally allowed to do so without breaking the law…I could expand my business activities.

There were just four consultees who provided reasons why they believed their usage of C1 category vehicles would decrease. Reasons given included that they would not keep existing vehicles and also that usage of larger vehicles would reduce the need for so many smaller vehicles.

In total, 21 consultees said their usage would remain the same with a main reason given was that drivers already had C1 on their driving licence.

Amount of C1 category vehicles if the C1 licence proposal came into force

Those who run goods transport services by road were also asked if the amount of C1 category vehicles in their fleet would increase, decrease, or stay the same as present if the C1 licence proposal came into force. Of 135 consultees who answered the question, just over three-fifths (63%) indicated that their usage would increase. Very few (3%) indicated that the amount of C1 category vehicles would decrease. For around one-third (34%), the amount of C1 vehicles in their fleet would remain about the same as present

There were 45 consultees who provided reasons as to why the amount of C1 category vehicles in their fleet would increase. The main reasons given for this were that it would allow the purchase of more C1 category vehicles (23 responses), that more drivers would be available (11) and that it would allow more people, including employees to drive C1 category vehicles (6).

We have a business need for this type of vehicle but struggle to find staff with the right qualification on their licence. Employing the right staff will mean we can invest in the right size vehicle…

Just three consultees gave reasons as to why the amount of C1 category vehicles in their fleet would decrease with a reason given that fewer smaller vehicles would not be needed.

Of 14 consultees who provided reasons why the amount of C1 category vehicles would remain the same, responses included that there would be no need to purchase more vehicles (6), that they would still want/need drivers to pass training (3) and that the cost of insurance premiums would mean that purchasing more vehicles would be too expensive (2).

Q16: Should the C1 licence proposal come into force would your use of C1 category vehicles:

Answer	% responded
Increase	70%
Decrease	3%
Remain the same	26%

Base: All who run goods transport services by road (145)

Q17: Should the C1 licence proposal come into force would your amount of C1 category vehicles in your fleet:

Answer	% responded
Increase	63%
Decrease	3%
Remain the same	34%

Base: All who run goods transport services by road (135)

C1 entitlement

Should C1 entitlement be given to people at the same time as they pass their car (category B) test?

Consultees were asked if they thought that C1 entitlement should be given to people at the same time as they pass their car test. Of 2,053 consultees who answered the question, most (69%) said yes, while around a quarter (27%) said no. A small number (3%) did not know.

Those who did not believe that C1 entitlement should be automatic upon passing a car test were asked to explain their reasons. The main responses were that C1 vehicles are bigger or heavier than cars (216), that risk of accident could be increased (214), that more driving experience would be needed (197), or that more training would be needed (186).

These larger vehicles require a higher standard of driving and medical fitness to be in place. Without the requirement for further training there would be an increase in accidents and incidents including fatalities.

Consultees against automatic C1 entitlement were then asked if they wished to continue answering questions about C1 implementation, or to skip to the next section of the questionnaire about Driver Certificate of Professional Competence (DCPC). Of 553 consultees, most (73%) wanted to answer the remaining questions about C1 implementation. These questions are covered in the following sections of this report.

Q18: Should, in your view, C1 entitlement be given to people at the same time as they pass their car (category B) test?

Answer	% responded
Yes	69%
No	27%
Don’t know	3%

Base: All consultees who answered the question (2,053)

Reasons why C1 entitlement should not be given to people at the same time as they pass their car (category B) test - most frequently made comments

Answer	Number responses
C1 entitlement - disagree - C1 vehicles are larger / heavier than cars	216
C1 entitlement - disagree - will increase accidents / reduce road safety	214
C1 entitlement - disagree - C1 driving should require more driving experience / more skills	197
C1 entitlement - disagree - C1 driving should require more training	186
C1 entitlement - disagree - C1 vehicles are different from cars / different driving characteristics	169
C1 entitlement - disagree - C1 driving should be subject to a test / an assessment	120
C1 entitlement - disagree - standard of driving is poor	44
C1 entitlement - disagree - C1 driving should be subject to age restriction	44
C1 entitlement - disagree - C1 driving should be subject to a minimum amount of years of experience - 2 years	38
C1 entitlement - disagree - C1 driving should be subject to a minimum amount of years of experience	29
C1 entitlement - disagree - C1 driving should be subject to a minimum amount of years of experience - 5 years	28

Base: All who provided comments (547 consultees)

C1 implementation

Age restrictions

Consultees were asked if there should be an age restriction to being granted the C1 entitlement upon passing a Category B driving test. Of 1,900 consultees who answered the question, most (89%) agreed including two- thirds (65%) who thought it should be 21 years and above, while around one in eight (12%) thought it should be from age 18+. A further one in eight consultees (13%) specified a different age which ranged from aged 19 to over 30 years of age.

Minimum period of time

Consultees were also asked if there should be a minimum period of time that a driver should hold a car licence before being allowed to drive a C1 vehicle. Of 1,893 consultees who answered the question, most (90%) believed that there should be a minimum period of time. This included half (50%) who thought there should be a minimum period of time of two years and approaching one quarter (23%) thought it should be one year. Just one in ten (10%) did not think that there should be a minimum period of time.

Q21: Should, in your view, there be an age restriction to being granted the C1 entitlement?

Answer	% responded
No	11%
Yes, 21 years and above	65%
Yes, 18 years and above	12%
Yes although at this age and above (in years)	13%

Base: All consultees who answered the question (1,900)

Net yes = 89%

Q22: Should, in your view, there be a minimum period of time that the driver should hold the car licence before being allowed to drive a C1 vehicle?

Answer	% responded
No	10%
Yes, 6 months	4%
Yes, 1 year	23%
Yes, 2 years	50%
Yes, another time period (in years)	14%

Net yes = 90%

Base: All consultees who answered the question (1,893)

Requirement to pass a HGV medical to gain the C1 entitlement?

A final question about C1 implementation asked consultees if they thought that drivers should be required to pass a HGV medical to gain C1 entitlement. There were 1,894 who answered the question with the majority (63%) against this requirement. Three in ten (31%) thought that there should be and fewer (6%) didn’t know.

Those who said yes or no where asked to give reasons for their answer. There were 554 consultees who provided reasons why they felt that there should be a requirement to pass a HGV medical to gain C1 entitlement. The main comments received were that a HGV medical would ensure fitness to drive (312 responses), that as C1 vehicles are larger / heavier / more dangerous a medical should be a requirement (202 responses), to ensure safety in general (180 comments). Other, less frequently made comments included to test eyesight (44), to ensure standards are being maintained (14) or after a certain age (7).

This would rule out any drivers who are medically incapable of driving a 7.5 ton vehicle from posing a risk to other drivers on the road. A higher standard of concentration and strains on the human body are required when driving a larger vehicle and so whilst I believe category B drivers have the necessary skills, they must be of a higher medical standard in my opinion, given the larger weight of the vehicle.

Requirement to pass a HGV medical to gain the C1 entitlement?

There were 875 consultees who provided reasons why they did not think there should be a requirement to pass a HGV medical to gain the C1 entitlement. A number of reasons were provided for this including that as a HGV medical is not required for a Category B test, that it should not be required to gain C1 entitlement either (224 comments), that C1 vehicles are not HGVs (218 comments), opposition in general (170 comments) and that as it wasn’t required for those passing their car test before 1997, that it should not be required now (97).

I think there is a massive difference to driving HGVs to driving a much smaller vehicles like a mini bus or ambulance. I believe C1 shouldn’t need a test and should be given automatically (to) someone (who) is over 21 and has 2 years driving experience.

I don’t think a medical is needed. There is already a system in place to limit drivers with medical conditions.

I am a hopeful paramedic and the prices and procedures to go through with attaining a C1 licence are very off putting. Especially for a university student the price could be well over £1,000 taking everything into account.

Q23: In your view, should drivers be required to pass the heavy goods vehicle (HGV) medical to gain the C1 entitlement?

Answer	% responded
Yes	31%
No	63%
Don’t know	6%

Base: All consultees who answered the question (1,894)

Reasons why drivers should be required to pass the heavy goods vehicle (HGV) medical to gain the C1 entitlement – most frequently made responses

Response	Number of responses
To ensure drivers are healthy / fit to drive	312
C1 vehicles are larger / heavier / more dangerous	202
To ensure safety	180
To test eyesight	44
General support	30
To check medication	23
To ensure standards are being maintained	14
To help with drivers shortage	9
For commercial use	8
After a certain age	7
For licence renewal	7

Base: All who provided comments that drivers should be required to pass the heavy goods vehicle (HGV) medical to gain the C1 entitlement (524 consultees)

Reasons why drivers should not be required to pass the heavy goods vehicle (HGV) medical to gain the C1 entitlement – most frequently made responses

Response	Number of responses
Not needed for category B / other vehicles	224
C1 vehicles are not HGVs / not much different to cars	218
Is unnecessary / not needed	170
It wasn’t required pre-1997 legislation	97
HGV medical - oppose - is expensive	70
HGV medical - oppose - being fit to drive is a general requirement	70
HGV medical - oppose - additional red tape / bureaucracy	52
HGV medical - oppose - is unnecessary / not needed - for motorhomes / campervans	46
HGV medical - oppose - self- certification is sufficient	45
HGV medical - oppose - for personal use	43
HGV medical - oppose - will not improve road safety	32

Base: All who provided comments that drivers should not be required to pass the heavy goods vehicle (HGV) medical to gain theC1entitlement (875 consultees)

Question 9

Driver Certificate of Professional Competence (DCPC)

Accepted Answer

DCPC exemptions for specific purposes in relation to C1 vehicles

Consultees were asked if they thought there are specific purposes of driving C1 vehicles that should be exempted from DCPC for driving in the UK. Over two-fifths (43%) indicated that there should be, while around one-third (35%) did not think there were specific purposes. Around one in five (22%) did not know.

Those who indicated that there should be specific purposes of driving that should be exempted where asked to provide their reasons, of which 775 consultees did so. The main comment was that there should be DCPC exemption for private and non-commercial use of C1 vehicles (308 comments).

Other comments received included that motorhomes and campervans should be exempted (189), vehicles driven for leisure purposes (154), for emergency service ambulances (105) and emergency service vehicles in general (92) and horseboxes (87).

Non-commercial purposes (e.g. driving a C1 category vehicle for personal use, such as moving house, carrying personal equipment that may be used in a hobby, etc.). This would also allow more drivers to get behind the wheel of a C1 category vehicle and get experience in driving a C1 category vehicle whilst not in the transport industry.

Other less frequently made comments about exemptions included for delivery drivers (27), hired vehicles (25), farmers (21) and health professionals (18).

Q25: Do you think there are specific purposes of driving of C1 vehicles that should be exempted from DCPC for driving in the UK?

Answer	% responded
Yes	43%
No	35%
Don’t know	22%

Base: All consultees who answered the question (2,042)

DCPC exemptions for specific purposes in relation to C1 vehicles – most frequently made comments

Response	Number of responses
Pivate / non- commercial use	308
Motorhomes / camper-vans	189
Leisure	154
Emergency services - ambulances	105
Emergency services	92
Horseboxes / horse owners	87
All / any / scrap DCPC	70
Volunteers / charities / non for profit	66
Middle category vehicles [3.5t to 7.5t]	54
Commercial use	53

Base: All who think there are specific purposes of driving of C1 vehicles that should be exempted from DCPC for driving in the UK and provided comments (775 consultees)

DCPC exemptions for specific purposes in relation to C1 vehicles – evidence

Those who thought that there are specific purposes of driving of C1 vehicles that should be exempted from DCPC were asked to supply evidence at Question 27 on the questionnaire (for example business, road safety and C1 vehicle use). In total, 302 consultees provided comments.

The main comments received by frequency of response were that evidence would be unnecessary or not required (39), that it is expensive (37) and that advance training or blue light training should be sufficient (33).

CPC is a very onerous responsibility, requiring much time and expense. Only those engaged in commercial transport of other people’s goods have enough use of it to make undertaking CPC renewal economically viable.

Blue light drivers are already trained to a higher standard than the majority of the driving population. Emergency services also already engage with CPD so mandating CPC will either add a burden or remove them from more job specific ongoing training.

Other less frequently made comments included that in-house training and/or continuous training should be sufficient (25), that DCPC exemption should be mandatory for commercial use (15), or that DCPC was a money making scheme or tick- box exercise (14).

I gave up driving commercially as I, along with the vast majority of professional drivers considered it nothing more than a money making exercise. Drivers with experience know what they are doing without having to pay £90 to sit in a classroom and then fill out a questionnaire.

It does nothing to make you a better driver just another job creation scheme.

Supply evidence of your opinion about specific purposes (for example business, road safety and C1 vehicle use) – most frequently made comments

Response	Number of responses
Evidence - is unnecessary / not needed	39
Advanced training / blue light training is sufficient	33
C1 vehicles are similar to B category vehicles	30
DCPC is a waste of time	26
In house / continued training is sufficient	25
3.5t is restrictive for motorhome owners	23
Unnecessary red tape / bureaucracy	22
A waste of money	19
No benefits	18
Infrequent use / low mileage	16

Base: All who answered yes at question 27 (302 consultees)

DCPC exemptions for specific groups in relation to C1 vehicles

As well as being asked about purposes, consultees were also asked if they thought if there are specific groups of drivers of C1 vehicles that should be exempted from DCPC for driving in the UK. Of 2,309 consultees who answered the question, two-fifths (40%) believed that there should be and around one-third (35%) did not. One in four (26%) were unsure.

Those who believed that there were specific groups were asked to provide details of such groups. Of 755 consultees who provided a response, the most frequently cited comments were that there should be exemptions for non-commercial use (277), motorhomes and campervans (164), for those driving for leisure reasons (138) and for emergency services including ambulances (110) and emergency services in general (107).

Those not driving for hire and reward in a professional capacity.

Those drivers that are going into the NHS, such as NHS delivery drivers and Ambulance drivers.

Other less frequently made comments about groups included for horse owners and those towing horse boxes (84), charities and those providing voluntary services (56), minibuses (43) and experienced drivers (38).

Horse box users because they carry heavy loads.

Those that have undertaken a MiDAS assessment or a more focused detailed minibus qualification.

Those who believed that there are specific groups that should be exempted were asked to provide evidence at Question 30 on the questionnaire. There were 295 consultees who provided comments which were very similar to an earlier question (Q27) which asked about specific purposes. Please see the separate topline/codeframe for more details of the responses.

Alternative training requirements suggested and reasons for these

Consultees were asked if C1 was removed from DCPC should, in their view, alternative requirements (for example training or qualifications) be mandated. Of 2,036 consultees who answered the question, around one third (35%) thought that alternative arrangements should be mandated, while over two-fifths (44%) did not think so. A fifth (20%) were unsure.

In total, 600 consultees provided comments about alternative training requirements. The most frequently provided comments were centred on driver training in general (127), training specific to vehicle (84), road safety training (81) and training on loading and securing loads to vehicles (75).

At least a 30 or more hours of practise. Any practise is better because it’s a larger vehicle and that is quite different from a normal car.

Examples provided in relation to training specific to vehicles included improving awareness of the size of vehicles that people are driving, the need for improved understanding of the longer braking distance of larger vehicles and build broader competence in driving heavier vehicles.

I think there should be a short course of sorts that is relevant to the specific vehicle you are going to drive.

Of those who cited road safety training, this was raised due to risks of insecure loads, dangers of faulty vehicles and hazard perceptions associated with heavy goods vehicles, for example.

Drivers should be made aware of the dangers of being on the road. Dangers of insecure loads and dangers of a faulty vehicle.

Q31: If C1 were removed from DCPC should, in your view, alternative requirements (for example training or qualifications) be mandated?

Answer	% responded
Yes	35%
No	44%
Don’t know	20%

Base: All consultees who answered the question (2,036)

Question 10

Removal of D1 licence requirement

Accepted Answer

Consultees were asked if they would support the removal of the requirement to obtain a D1 licence test to drive a minibus. Of 2,052 who answered the question, most (73%) were supportive. This included three in ten (31%) who were supportive with additional stipulations. Around one in four (23%) were not supportive, while one in twenty (5%) were unsure.

Supportive with stipulations

Those who were supportive dependent upon unspecified additional stipulations were asked to indicate from a tick-list what those additional stipulations should be. Most of these consultees believed that there should be a minimum age requirement (86%). This was followed by around half (49%) who thought that there should be a mandatory requirement to undertake additional training such as MiDAS and two-fifths (41%) who believed that there should be compulsory medical requirements. Around three in ten (29%) believed that there should be compulsory conduct requirements and/or requirements at renewal stage (also 29%). Around one in six (16%) thought that there should be another stipulation.

Unsupportive

Those who were against D1 requirement removal were asked about their concerns. Of 461 consultees who answered the question, most (92%) raised safety concerns, three-fifths (61%) had concerns about poor driver skills and one-fifth (21%) indicated other concerns. Other concerns included worry about inexperience of younger drivers, impacts on driving standards and that it could be dangerous.

Those who raised safety concerns for not supporting removal of the requirement were asked to supply any views and evidence they had on whether the change would have a negative or positive impact upon road safety. There were 270 consultees who provided comments of which almost all (267) provided negative comments about impact on road safety.

The main negative comments received by frequency of response included negative impact on road safety risk to multiple passengers (132), negative impacts on road safety due to lack of training (97), that additional road safety training is needed (68) and that a safety test would be needed (67).

I am a qualified technician working for the ambulance service. I drive an ambulance (C1) every day in emergency conditions (blue lights) and non emergency conditions (normal C1 driving). I see the standards of every day drivers it is poor. I know the capabilities of the ambulance and how dangerous it could be. To give this licence to any typical driver is a mistake that will cost lives. There will be an increase in fatalities on the road.

Driving standards are generally deteriorating. Allowing people not fully trained can only have a negative impact on road safety.

Supply of minibus drivers

All consultees were then asked about impact on supply of minibus drivers if the requirement to obtain a D1 licence to drive a minibus were to be removed. Most (84%) believed this would increase the supply of such drivers.

Q33: Would you support the removal of the requirement to obtain a D1 licence test to drive a minibus?

Answer	% responded
Yes	42%
Yes with additional stipulations	31%
No	23%
Don’t know	5%

Base: All consultees who answered the question (2,052)

Answer	% responded
A mandatory requirement to undertake additional training such as MiDAS	49%
A minimum age requirement (above that of a B licence)	86%
Compulsory medical requirements	41%
Compulsory conduct requirements	29%
Renewal requirement (with medical and conduct requirements)	29%
Another stipulation or stipulations	16%

Base: All who support the removal of the requirement to obtain a D1 licence test to drive a minibus, but require additional stipulations (628)

Q35: Would you support these ‘additional stipulations’ applying to individuals?

This table shows levels of support at Q35 dependent on stipulations selected at Q34. Example, 69% of those who selected a mandatory requirement to undertake additional training such as MiDAS at Q34 would support this applying to individuals when driving a vehicle under a Section 19 or 22 permit.

	A mandatory requirement to undertake additional training such as MiDAS	A minimum age requirement (above that of a B licence)	Compulsory medical requirements	Compulsory conduct requirements	Renewal requirement (with medical and conduct requirements)
Total base (628)	308	543	256	181	184
When driving a vehicle under a Section 19 or 22 permit	69%	53%	55%	60%	63%
The commercial carriage of passengers under a Section 19 or 22 permit under a short distance exemption	1%	1%	1%	1%	2%
When driving a vehicle under a PSV Licence	46%	43%	48%	51%	51%
At other times when driving a minibus	9%	7%	8%	8%	9%
No	18%	32%	28%	26%	24%

Base: All who support the removal of the requirement to obtain a D1 licence test to drive a minibus, but require additional stipulations (628)

Q36: What are your main concerns for not supporting a removal of the requirement?

Answer	% responded
Safety	92%
Poor driver skills	61%
Another reason	21%

Base: All who do not support removal of the requirement to obtain a D1 licence test to drive a minibus (461)

Q38: In your view if the requirement to obtain a D1 licence to drive a minibus were to be removed, what impact to do think this would have on the supply of minibus drivers?

Answer	% responded
Significant increase in supply	46%
Increase in supply	38%
No effect	12%
Reduction in supply	2%
Significant reduction in supply	2%

Base: All consultees who answered question 38 (2,035)

Effect on cost of running taxis and PHVs

Consultees were asked about the impact of the removal of the D1 licence on the cost of running taxis and PHVs. Few (6%) believed that it would increase the costs of running such vehicles. Around one-third (32%) thought that running costs would decrease and a similar proportion (31%) believed there would be no impact. Three in ten (30%) were unsure about impact on running costs.

Consultees were then asked to explain their reasons. In total, 277 consultees provided comments about how they believed running costs would be reduced. The main comment was that there would be more drivers available (144), followed by lower training costs (61) and that the impact would generally reduce running costs without specifying further.

I think it would reduce the cost of running these services because more drivers would in abundance which would lower advertising costs and other potential costs involved in training.

There were 156 consultees who did not believe running costs would be impacted. The main comments received were that there would be no impact in general (46) and also that removal of the D1 licence requirement would not correlate with running costs (also 46 comments).

Of those who believed running costs would increase, the main comment was that insurance premiums would be higher (22 comments) as there could be a reduction in the standard of driving.

I expect insurance will become more expensive because the drivers are riskier and that will be passed on.

Q39: What effect do you think the removal of the D1 licence requirement would have on the cost of running taxis and PHVs?

Answer	% responded
Increase the cost of running taxis and PHVs	6%
Decrease the cost of running taxis and PHVs	32%
No impact on either taxis or PHVs	31%
Don’t know	30%

Base: All consultees who answered the question (2,037)

Impact on driver wages

Consultees were asked if they believed that driver wages could be affected if the D1 licence requirement was removed. As is seen in the following charts, around half or more consultees believed drivers wages would be unaffected. Slightly more consultees believed that driver wages would fall rather than increase.

Some of those who provided comments believed driver wages would increase as there would be demand for additional drivers.

Higher demand would likely mean more HR will be needed which means attracting i.e. increasing wages.

Of those who believed wages would remain static, reasons provided included that drivers would still be in demand given professional driving is a responsible job.

These are still responsible jobs with society and removing the licence restrictions wouldn’t change that. It would simply mean any shortages in drivers would disappear.

Reasons provided as to why wages could fall included a view of supply and demand with an increased number of drivers in the pool leading to supressed wages.

Greater supply, less demand, therefore a race to pay the lowest amount.

Q40a: In your view, what impact would the removal of the D1 licence requirement have on bus drivers?

Response	% responded
Increase driver wages	8%
Not alter driver wages	59%
Reduce driver wages	13%
Don’t know	19%

Q40b: In your view, what impact would the removal of the D1 licence requirement have on coach drivers?

Response	% responded
Increase driver wages	9%
Not alter driver wages	59%
Reduce driver wages	13%
Don’t know	19%

Q40c: In your view, what impact would the removal of the D1 licence requirement have on PHV drivers?

Response	% responded
Increase driver wages	9%
Not alter driver wages	59%
Reduce driver wages	15%
Don’t know	24%

Q40d: In your view, what impact would the removal of the D1 licence requirement have on minibus drivers?

Response	% responded
Increase driver wages	10%
Not alter driver wages	48%
Reduce driver wages	23%
Don’t know	19%

Question 11

Changes to raise the standards of HGV instruction and to improve pass rates

Accepted Answer

Introduction of a standardised instructor training and qualification programme

Two-thirds (64%) of consultees agreed with the introduction of a standardised instructor training and qualification programme. Around one in seven (14%) did not agree and a fifth (21%) were unsure. Those who agreed were asked if there should be a voluntary or mandatory requirement. The majority (72%) indicated that there should be a mandatory requirement.

List of instructors

All consultees were asked if there be a mandatory register of HGV instructors managed by the Driver and Vehicle Standards Agency. Most (74%) agreed that this should be in place compared to around one in eight (12%) who did not agree. One in seven (14%) consultees were unsure. Those who agreed that a mandatory register should be in place were then asked if it should include public service vehicles and/or passenger carrying vehicles (PCVs). Just over four-fifths (82%) believed it should include PCVs while approaching nine in ten (88%) thought it should include public service vehicles.

Pass rate publication

Just over half (55%) of consultees agreed with the publication of pass rates achieved by instructors. A fifth (20%) did not agree and one in four (25%) were unsure. Those who agreed or disagreed were asked to provide reasons.

There were 745 consultees who provided reasons in support of the publication of pass rates. The main comments received by frequency of response where it would allow informed choice (214), for quality control purposes (206), to ensure the information is in the open (140) and is transparent (131) and that training standards would be improved (114).

This will enable good instructors to earn a higher wage as they are ‘best’ of their trade. This will also allow students/candidates to better select a driving school & instructor.

On the other hand, there were 301 consultees who did not think that pass rates achieved by instructors should be published. A main comment was a belief that pass rates would not on their own reflect quality of training provided (138). Other less frequently made comments included it could lead to corruption and falsification of results (42) and that it could be discriminatory or unfair (33).

Pass rates tell you nothing useful about quality of instruction they only tell you whether the instructor is good at predicting when a student is capable of passing a test.

Q41: Do you agree with the introduction of a standardised instructor training and qualification programme?

Response	% responded
Yes	64%
No	14%
Don’t know	21%

Base: All consultees who answered the question (2,030)

Q42: This should, in your view, be?

Response	% responded
Voluntary	28%
Mandatory	72%

Base: All who agree with the introduction of a standardised instructor training and qualification programme (1,303)

Q43: Should, in your view, there be a mandatory register of HGV instructors managed by the Driver and Vehicle Standards Agency?

School	7%
Local authority	9%
Transport organisation	8%
Commercial transport organisation	10%
Community transport organisation (section 19 or 22) permit holding organisation	29%
Another type of organisation	37%

Base: All consultees who answered the question (2,037)

Q44: If the instructor register was introduced, in your view, should it include?

Response	% responded
Public service vehicles	88%
Passenger carrying vehicles (PCVs)	82%

Base: All who believe that there be a mandatory register of HGV instructors managed by the Driver and Vehicle Standards Agency.

Q45: Do you agree with the publication of pass rates achieved by instructors?

Response	% responded
Yes	55%
No	20%
Don’t know	25%

Base: All consultees who answered the question.

Question 12

Other licensing changes

Accepted Answer

Views on entitlement to drive PCVs on a HGV licence for maintenance and repair purposes

Consultees were asked if they would agree that entitlement should be changed to allow persons with category C entitlement to drive PCVs on their HGV licence for maintenance and repair purposes. Of 2,028 consultees who answered the question, most (75%) agreed. Around one in twelve consultees (8%) did not agree and a fifth (18%) were unsure.

Estimated costs and savings of the proposal

Consultees where then asked about estimated costs or savings to them or their business if HGV licence holders were to be entitled to drive PCVs. Most consultees did not provide a response to this question. Of 215 consultees who did provide a response, the most frequently cited comments were around savings on training costs (56), or test fees (54), or savings in general (42).

Clearly it is absurd that an HGV driver can’t drive an empty bus. Whilst I don’t have a transport business, it would clearly increase flexibility and reduce unnecessary expensive training.

It would save companies and individuals from undertaking training and tests that they do not need. An empty PCV has no people.

Evidence on positive or negative impacts upon safety of permitting HGV licence holders to drive PCVs for maintenance and repair purposes

Consultees were asked to provide their views and evidence about the proposal to allow HGV licence holders to drive PCVs for maintenance/repair purposes. There were 362 consultees who provided comments. The main comments received were that HGVs and PCVs are very similar (52), that it would help with driver shortages (47) and would create job opportunities (36).

HGV licences should be able to drive a D1 category vehicle as they have had the medical, exams and tests etc and have had further training.

I feel we have to trust in our younger generations that they will be safe upon operating a larger vehicle. If this means we can employ more people easily in the transport sector and opportunities for small scale businesses to emerge.

D1E entitlement to those holding C1, C1E and D1 licences

Consultees were asked if they believed D1E entitlement should be granted to those who are already entitled to drive smaller/lighter categories of vehicles. Over half agree with both C1 and D1 licence holders (56% and 58% respectively), rising to two-thirds (67%) of C1E licence holders.

There were 432 consultees who provided supportive comments with the most frequently cited comments being that drivers are already experienced (96), there are similar driving characteristics (87), it would help alleviate driver shortages (71) and provisional support provided additional training is undertaken (47).

I think anyone who has taken an assessment and passed for a B+E category should be permitted to have this class with any other entitlement for C1 or D1 up to MAX of 3500KG, tailers with airbrakes will require additional assessment on safety grounds.

There were 262 consultees who provided comments in opposition to the proposal. The main comments here were to do with different driving characteristics (81), that there should be additional training before entitlement to D1E (77) and that there should be a test or assessment (73).

Drivers need to prove their capabilities and their understanding of the responsibilities attached to driving vehicles that present a much higher risk to other road users.

D1E entitlement to those holding C1, C1E and D1 licences – costs / savings

Consultees where also asked about estimated costs or savings if the proposal was implemented. There were 225 consultees who provided comments of which the main comments revolved around savings. This included saving on test fees (56), training fees (42) and estimated savings in GB pounds (example, there were 29 comments above savings between £1,000 and £4,999).

I would personally save approximately £2,500 just in doing the test. Then save £100 a trip to pay someone to drive my horsebox.

Consultees were asked to supply any views and evidence they have on whether the proposed change would have a negative or positive impact upon road safety. There were 39 consultees who provided positive comments, while 130 consultees provided negative comments. A further 99 consultees believed that the proposal would not have any impact on road safety.

The main comments about negative impact were that the proposal would reduce safety levels overall (83), as well as concerns about lack of experience and training (50).

Q47: Do you agree that entitlement should be changed to allow persons with category C entitlement to drive PCVs on their HGV licence for maintenance and repair purposes?

Response	% responded
Yes	75%
No	8%
Don’t know	18%

Base: All consultees who answered the question.

Q48: What, in your view, would be the estimated costs or savings to you or your business would be if this was to be permitted and why?

Response	Number responses
Savings of PCVs entitlement - savings on training costs	56
Savings of PCVs entitlement - savings on test fees	54
Savings of PCVs entitlement - savings (general)	42
Savings of PCVs entitlement - a lot / significant savings	35
Savings of PCVs entitlement - £1000 - £4999	23
Savings of PCVs entitlement - thousands (not specified further)	19
Savings of PCVs entitlement - time saving	19
Savings of PCVs entitlement - savings on recruitment	10
Savings of PCVs entitlement - minimal savings	6
Savings of PCVs entitlement - savings on medical costs	5

Base: All who provided comments on specific purposes they felt were subject to DCPC exemptions in question 48 (215 consultees).

Q50a: Do you agree that the D1E entitlement should be granted to those drivers who hold C1 licences without taking an additional test?

Response	% responded
Yes	56%
No	28%
Don’t know	17%

Base: All consultees who answered the question.

Q50b: Do you agree that the D1E entitlement should be granted to those drivers who hold C1E licences without taking an additional test?

Response	% responded
Yes	67%
No	18%
Don’t know	16%

Base: All consultees who answered the question.

Q50c: Do you agree that the D1E entitlement should be granted to those drivers who hold D1 licences without taking an additional test?

Response	% responded
Yes	58%
No	25%
Don’t know	17%

Base: All consultees who answered the question.

Estimated costs or savings to consultees or their business if the D1E entitlement was permitted.

Response	Number responses
Savings on tests fees	56
Savings on training fees	42
£1000 - £4999	29
Thousands	28
A lot / significant savings	26
Time saving	23
Savings (general)	18
Savings on licence costs	15
Savings on drivers wage	12
£10000 - £100000	9

Base: All who provided comments on the estimated costs or savings to them or their business if the D1E entitlement was permitted at question 51 (225 consultees).

L category

Dependency of the L category entitlement

Category L is a defunct category of driving licence which allowed a driver to drive any electric vehicle original used when the only electric vehicles on the road were:

Milk floats
Vans operated by the old gas and electricity boards.

With electric HGVs and buses entering the market, DfT are researching if it is time to end Category L.

Of 2,013 consultees who answered the question, just 29 indicated that they were dependent on Category L entitlement.

Q53: Are you dependent on the category L entitlement?

Response	% responded
Yes	1%
No	91%
Don’t know	7%

Base: All consultees who answered the question.

Q56: In your view are there any road safety impacts to revoking these L-category licences?

Response	% responded
Yes	5%
No	60%
Don’t know	35%

Base: All consultees who answered the question.

Q58: You believe the L category licence should be?

Response	% responded
Revoked	68%
Maintained	32%

Base: All consultees who answered the question (1,669).

Agricultural vehicles

Consultees were asked if there should be changes to legislation to bring agricultural vehicles within the C category and also the CE category. Consultees were broadly split towards whether DfT should consider such changes as shown in the charts on the next slide.

Supportive comments

There were 489 consultees who provided comments in support of bringing changes to legislation to bring agricultural vehicles within the C and/or CE category. The main comments received were that agricultural vehicles are large/heavy vehicles and as such better suited to C or CE categories (257), for road safety reasons

(119) and that it would mean drivers would be trained in usage of such vehicles on the public highway (94) with resultant improvements in driving standards.

This change will bring drivers of agricultural vehicles in line with HGV drivers in that they will better understand the legal requirements of driving a larger vehicle and allow them to be held to a higher standard…

Opposing comments

On the other hand, there were 318 consultees who provided comments in opposition to the proposals. The most frequently cited comments were that there would be negative impacts on farmers (84) and/or on the farming industry (62) and that it could be expensive (44).

…significant extra costs…farms are family run and already suffering financially, the added stress, cost and waiting time to take a C/CE test would have huge impacts.

Q59a: In your view should we consider changes to legislation to bring agricultural vehicles within the C category?

Response	% responded
Yes	44%
No	34%
Don’t know	23%

Base: All consultees who answered the question (1,954).

Q59b: In your view should we consider changes to legislation to bring agricultural vehicles within the CE category?

Response	% responded
Yes	42%
No	33%
Don’t know	26%

Base: All consultees who answered the question (1,932).

Driving regulations and other issues

Review of the 2021 driving regulations

Part of the call for evidence involved a review of the 2012 driving regulations. Consultees were asked to supply evidence or comments with regard to these regulations. There were 46 consultees who made comments or supplied evidence. The main comments received were concerns about the safety of tractors on public highways (9), including concerns about young tractor drivers (8). There were also eight comments about the regulations being too strict and six comments that the regulations were in need of review.

Without guidelines it is not possible to comment other than, if the current rules are 10 years old, more regular reviews are needed.

I see 16 year olds tipping tractors over and causing road safety problems in the area I live in.

Other driving licence issues

Consultees were also asked to comment on what, if any, other driving licence issues they thought should be explored for improvement. In total, 675 consultees provided comments including:

Other licensing entitlements including giving Category C holders Category D entitlement and vice versa
Making improvements to Category B, C, D and F licensing
Training

Question 13

Minibus service provision

Accepted Answer

Should D1 entitlement be given to people at the same time as they pass their car (category B) test?

All consultees were asked if they provide minibus services. Of 2,016 consultees who answered the question, around one in seven (286 consultees) said that they did this. These consultees were then asked if they wished to answer questions about minibuses of which 215 said yes.

A small number of consultees said they did not run minibus services but wished to provide comments at one or more questions about minibus service provision. These consultees are also included in this section of the report if/where they answered the questions.

This section provides a number of metrics about minibuses for those who have these including:

number of minibuses
how many permits and operator licences held and how many drivers utilise them to provide transport services
percentage of organisation’s journeys operated using a Section 19, Section 22 and PSV operator licence
whether currently offer services and/or want to offer services within a number of areas including community transport, home to school and educational services and demand responsive transport.
average annual mileage
whether offer minibus services in urban, rural or both areas
number, age and status of volunteer and paid drivers
Minibus Driver Awareness Scheme (MiDAS)
number of services run per month and ability to meet demand
cancelling services / driver shortages / safety

Q62: Do you provide minibus services?

Response	% responded
Yes	14%
No	86%

Base: All consultees who answered the question (2,016)

Q64: How many minibuses do you use to provide passenger transport services?

Response	% responded
1 to 5 range	60%
6 to 10 range	10%
Above 10	30%

Base: All who provide minibus services (205).