Consultation outcome

Changes to HGV and bus driving tests and allowing car drivers to tow a trailer without an extra test: response to consultation

Updated 25 April 2022

1. Executive summary

The Driver and Vehicle Standards Agency (DVSA) sought views on proposed amendments to driving licence acquisition and driving test arrangements for various categories of vehicle. These vehicles are articulated lorries (C+E), buses or coaches with trailers (D+E), medium-sized lorries and minibuses (C1 and D1) and car/trailer combinations (B+E). The consultation was held between 10 August and 7 September 2021.

There was an overall level of support for the proposals in the online consultation, with benefits identified by many of those who responded. Among the benefits highlighted were the freeing up of examiner resources to conduct more HGV tests, opportunities for businesses, along with reduced costs and a more streamlined qualification process for those seeking a vocational driving licence. There was, however, significant opposition from some, primarily as a result of road safety concerns and the economic impact on some trainers.

Following careful consideration of the responses received, ministers decided to introduce the amendments as proposed, taking into account concerns expressed, along with introducing effective mitigation measures and making the necessary legislative changes.

2. Introduction

On 10 August, DVSA published an online consultation: HGV Driver Shortage - Proposals to amend driving licence acquisition and testing arrangements. The consultation was available via GOV.UK. The closing date for responding was 7 September. This involved proposals regarding:

• removing the staging requirements^{[footnote 1]} for licence acquisition, allowing drivers to take a test in an articulated lorry or lorry and trailer combination (C+E) or a bus / coach and trailer (D+E), without first having passed a test in a rigid lorry (C) or bus / coach (D)
• considering alternative arrangements for the conduct of the reversing and un-coupling manoeuvres in the C1+E, D1+E, C+E and D+E test, with these conducted separately from the on-road event, perhaps being assessed by a third party assessor
• allowing car drivers to tow a trailer (weighing over 750kg or in combination with the car being over 3500kg maximum authorised mass) without the need for an additional B+E test

3. Responses to the consultation exercise

The consultation attracted significant interest, with 9,541 responses being received online. Those responding included driver trainers, driving instructors, vehicle operators and members of the public. We also received letters from Members of Parliament, stakeholders and industry representatives.

The larger stakeholder organisations who commented on these proposals included the Road Haulage Association (RHA), the Royal Society for the Prevention of Accidents (RoSPA), IAM Roadsmart, the Approved Driving Instructor National Joint Council (ADINJC), the National Farmers Union Cymru, the National Farmers Union Scotland, the National Association of Strategic Partnership (NASP), the National Vocational Driving Instructor Register (NVDIR) and the National Towing and Trailer Association (NTTA), DHL and Brakes, the wholesale foodservice provider. A number of trainers and companies responded including J Coates, Drivex, NxtGen training, 1st Class Training and Wincanton.

Ministers would like to thank everyone who contributed to this consultation.

4. Summary of views

The proposals received overall support from the majority of those who responded to the consultation.

It was considered the revised arrangements would lead to greater driving examiner productivity and free up availability to conduct tests, which would help address the current HGV driver shortage. Removing staging would streamline the licence acquisition process and make it more straightforward, and less expensive, to obtain a vocational driving licence. Allowing trainers to conduct manoeuvres would add significant additional resource to the testing process, which would give scope for DVSA to conduct more on-road tests. Removing the requirement to take a B+E test would allow those with a car licence greater opportunities for driving car and trailer combinations for leisure and offer potential employment and business opportunities for work in the construction, agricultural and delivery industries.

Additional areas were, however, identified where action is needed to address the HGV driver shortage. These involve longer-term factors affecting driver recruitment, such as driver’s pay, working conditions, the loss of EU nationals, slow bureaucracy and long hours. Such issues are outside the scope of these proposals and associated consultation. Other suggestions are more directly within DVSA’s remit but are not part of the proposals under consideration. For example, some respondents suggested increased delegated testing (where a haulage or bus operator is permitted to conduct driving tests for its own employees) might help to deploy new drivers.

There were also some strong opinions about the possible effect on road safety of some of the measures, in particular from those with a road safety interest and from driver trainers.

Some felt removing the staging requirement between categories C and C+E and D and D+E might take out an important stage in the learning process, especially regarding the practical experience of driving a rigid lorry, bus or coach, before moving to an articulated lorry or towing a trailer with a bus or coach.

It was suggested the revised arrangements for taking the ‘manoeuvres’ part of the test must be accompanied by standards assurance, approval of assessors and a certification scheme. These would provide confidence the system will be fit for purpose and ensure road safety standards will be maintained.

Road safety concerns were also expressed on the proposals for removing B+E tests. There was concern that driving a car and driving a car and trailer combination required different competences. Some said there is a significant difference in the length of vehicles and the manoeuvring skills required. Competence in coupling and uncoupling trailers was also said to be essential. In view of this, respondents said it should be necessary for drivers to at least undertake some training, together with an assessment by a trainer to ensure the driver has gained the necessary skills. This could be achieved using a similar system to compulsory basic training (CBT) for motorcyclists, for example.

5. Stakeholder comments

Separate to the online consultation, responses were also received from larger stakeholder organisations, including road safety organisations and trainers such as Logistics UK, RHA, RoSPA, ADINJC, NASP, NVDIR and NTTA. A number of trainers and companies commented including J Coates, Drivex, NxtGen training, 1st Class Training and Wincanton.

5.1 Removal of staging

This measure was cautiously supported by some, with reservations. It was considered it would reduce costs to candidates, barriers to accessing the occupation and strains on vocational testing capacity. But it could increase the costs for single “stage” and reduce volumes of training per candidate so lesson costs could increase, possibly leading to a decline in pass rates.

Others questioned the safety aspects of the proposal. It was noted many potential drivers had no background with large vehicles. Therefore training – signed off by a qualified trainer – should take place in a C vehicle before a test on a C+E. If the training in C was with an unqualified instructor, a C test should take place. A C test should be passed where a category C is the final aim.

Organisations with a particular interest in road safety also expressed strong reservations. Whilst they understood the need to recruit drivers, and this proposal would help to make more tests available, there were concerns about the impact on road safety. The argument made was the skills needed to drive category C vehicles were significantly higher than to drive a car and learning to operate a larger vehicle, at the same time as a trailer, was too demanding. There was concern intensive training courses, typically lasting one or two weeks, would reduce the amount of training being undertaken by learners and it was queried whether there could be any provision to revert back to previous test arrangements if future evidence showed an increase in road traffic collisions involving those who acquired a vocational licence in this manner and whether there would be additional requirements made, such as through Driver Certificate of Professional Competence (CPC), for those who gained their licence in this way.

It was suggested some employers could be more confident if a driver had qualified by passing both the C and C+E test. It might prove beneficial for those asked to accompany a learner driver, if the learner has taken their category C test before their category C+E. It did not seem acceptable for a driver who had not taken their category C test to supervise and accompany a driver who would be taking the category C test.

However, there was support for the proposal that a driver who passed a C+E or D+E test, should be given entitlement in the lower category. There was no reason why, if someone had passed a test in the higher category, they should not be able to drive a category C.

Others in the industry, including representatives of the haulage industry, did not consider there to be significant safety implications and some saw staging as unnecessary. They said the change would involve a simpler and quicker qualification to C+E, simplify the system and remove unnecessary bureaucracy, whilst ensuring driving and safety standards were maintained. Some felt this could cause a knock-on impact on C and C1 vehicles. It could distort the market and intensify the shortage of C and C1 drivers.

It was noted that currently a driver received on average 10 days training, with a staged introduction in a smaller HGV going into a larger HGV. Training courses would be likely to continue to be the same length as drivers would need to familiarise themselves with a category C, with tests in larger vehicles needing 10 days to reach the standard to pass the test. Some felt category C vehicles would still be needed for training and those who wished to train to C only were free to continue to do so. Trainers would need to purchase more C+E vehicles which were readily available. It would be acceptable for those with a category C+E licence to supervise a C learner driver as they would have the competence to do so and there should not be an age restriction with regard to larger vehicles. It was, however, commented that removing staging could move the shortage away from operators of C+E vehicles to those who just operate category C vehicles, moving the problem from one sector of the transport industry to another.

5.2 Manoeuvres

Again, there was cautious support for this proposal, which could lead to an increase in available tests. It was suggested assessment of manoeuvres could be undertaken by qualified instructors, perhaps in the same way as CBT for motorcycles to determine a skillset before the next stage of training. One large representative body suggested this could include HGV trainers with an assessor qualification, End Point Assessor organisations, training organisations with IS9001 accreditation, or any experienced driver trainer. Another proposed extending this to delegated examiners.

Some said any such scheme should be quality controlled so driving standards continue to be maintained. Others considered there should be a scheme that is as light touch as possible for authorisation, with provision for assurance checks, removal of authorisation if not managed properly by the examiners and an appeal mechanism. There was already a duty of care to ensure trainers and instructors are competent and over-regulation would not be beneficial, nor enhance road safety. Assurance could be achieved, for example, by random inspections by either independent or by DVSA inspectors. And, to ensure quick and accountable implementation, manoeuvres could be recorded for audit purposes.

However, some road safety interests opposed this proposal, one driver trainer on the grounds it could be hazardous and unsafe. There was concern the manoeuvres are a critical part of operating the vehicle safely and it was questioned whether standards would be reduced if it was not part of the driving test and assessed by a third party.

It was suggested there could be a potential conflict of interest, with trainers assessing candidates and also possibly being under pressure to pass them. It was also commented DVSA examiners were best qualified to assess the manoeuvres.

It was suggested that a scheme should be fully regulated so driving standards were maintained. It could present a business opportunity for training organisations with access to manoeuvring areas. However, conversely, this could negatively affect trainers without access to such an area.

5.3 B+E tests

Some acknowledged removing the car and trailer (B+E) test would free up resources. One representative body saw the supply of additional HGV drivers as a priority and considered this measure had potential to increase examiner capacity to conduct HGV tests, with benefits for drivers such as reduced costs, increased employment opportunities and a simplifying of rules governing trailers. Another reported its members were divided between those who considered the B+E test an unnecessary business expense and those who considered the test should be retained for road safety reasons. It was suggested the same could apply to C1 vehicles, which would increase opportunities for younger drivers holding just a B licence, adding to the pool of driver availability.

There was, however, concern about the removal of the B+E test, mainly for reasons of road safety, with the view expressed there could be an increase in accidents by allowing any driver to tow a heavy B+E combination. It was argued car drivers were unaware of the effects a trailer can have in respect of handling, steering and speed and it was suggested they should not experience this for the first time in uncontrolled conditions. Concern was also expressed this proposal could increase the frequency of trailers parting company from the towing vehicle as they had not been correctly coupled.

One representative organisation, which agreed with the proposal to end the B+E test because it would have the potential to significantly increase examiner capacity to carry out HGV tests, nonetheless took the view a strong focus on road safety should be maintained through training. Some, such as agricultural workers, would have gained competence of driving vehicle and trailer combinations off road prior to gaining on-road qualifications so would be likely to have greater competence compared with other road users.

Road safety interests were strongly opposed for safety reasons, citing the skills required, that towing needed to be taught and assessed and that the “show me, tell me” questions were also currently included along with checking the overall security of the vehicle and trailer. Pass rates indicated one in three drivers did not pass and did not meet the requirement to safely tow a trailer. Whilst training could be encouraged, it would not be mandatory. Some might wish to continue to take training but there was no guarantee of this and there might need to be incentives, such as insurance discounts.

It was felt this measure might also reduce the need for training in the eye of the public. The proposals could increase incidents involving trailers up to 3500kg. There might also be a rise in litigation over health and safety legislation. Work had been undertaken on towing safety, involving police, Highways England and the National Crime Intelligence Service and this should continue. The view was expressed this could put some trainers, who specialise in this training, out of business. Some did say this could be covered by mandatory training, perhaps akin to CBT or CPC, or be carried out by authorised trainers.

Some road haulage representatives were also opposed to the removal of the B+E test on the grounds of road safety. Car drivers might be unaware of the effects a trailer can have on handling, steering and speed and it was suggested they should not experience this for the first time in uncontrolled conditions. Drivers must be trained to tow and demonstrate they had the skills to handle trailers safely. Many would not take training, some might check online videos for guidance. There would be no benefit to drivers from the proposal, they would be a risk to themselves and other road users if they had not been trained and required to reach a defined standard.

As a solution to the driver shortage issue, it was suggested trainers could be authorised to conduct tests on behalf of DVSA (along the same principle as car and van MOTs and in the same was as CBT). However, there would need to be rules and assurances in place for this.

5.4 Other suggestions

It was also suggested there were other measures that could be introduced. It was proposed to extend CPC validity for the rest of 2021 to April 2022 and to allow drivers whose CPCs had expired in last three years, or who had a valid CPC, to obtain CPC validity for 12 to 24 months if they undertook one or two CPC training modules. One respondent also recommended a review of CPC to improve the quality, effectiveness and operation of the system.

It was recommended a category C lorry driving apprenticeship should be authorised as soon as possible. Also proposed were temporary worker visas for lorry drivers, reform of shortage occupation educational level rules and use of the Youth Mobility Scheme. It was important industry gave attention to promotion of the occupation, improving productivity and treatment of drivers at collection and delivery points and flexible working.

6. Decisions taken

Ministers would like to thank all those who responded to the consultation. The proposals elicited many interesting comments and these have proved helpful in the decision-making process. The suggestions on issues outside the scope of this consultation have also been gratefully received.

Ministers have carefully considered the views expressed. They acknowledge there are concerns about some of the implications, particularly with regard to road safety. This is regarded with utmost concern and an initial review date of three years has been set, with reviews every five years thereafter, so the impact of the legislation on all road users can continue to be assessed.

The change in legislation will, however, allow the HGV driver shortage to be addressed more quickly by increasing driver testing capacity and the benefit to the haulage industry is expected to extend beyond the current acute shortage. Limiting the review to a shorter than three-year period might mean there are insufficient statistics, and an inadequate length of time, for the changes to be reviewed with any confidence. With regard to the B+E test, there also needs to be assurance for car drivers, who wish to tow a trailer, they are able to acquire legal entitlement to do so.

On the package of measures, ministers are confident the issues raised can be addressed and continue to urge drivers to take the necessary training when driving larger and unfamiliar vehicles or vehicle combinations. The development of an accredited training scheme will ensure drivers can access accredited training to help them tow safely whether this be for work of for leisure purposes. The plans for this training are progressing well and the government plans to make further announcement on this training scheme soon. A Council will be set up to provide oversight and light-touch governance for the accredited training scheme. The council will be known as National Council for Accredited Trailer Training or NCATT. We are working with the industry to finalise details of how the Council will be organised and run.

Ministers believe it is important to take action to ensure the driver shortage is overcome to support the economy and protect supply chains. They decided the proposals should be implemented urgently and the legislative changes to do so were introduced on 15 November 2021 for staging and manoeuvres and 16 December 2021 for B+E tests.

7. Next steps

The practical arrangements to introduce and oversee the changes are in the process of being implemented.

8. Responses

There were a variety of comments made about the proposals. The following are the main points made.

8.1 General questions

Question 1

Please tell us in what capacity you are responding to the consultation.

9,480 respondents answered this question, with the breakdown of responses as follows.

Profession	Number of respondents
A professional driver	2,586
A member of the public	4,772
A HGV or bus operator	909
An industry representative organisation	144
One of the LGV voluntary registers	36
An insurance provider	6
A road safety organisation	60
A leisure interest organisation	90
A training organisation or trainer	877

Question 2

Please tell us about the size of your business.

6,801 respondents answered this question, with the breakdown of responses as follows.

Size of business	Number of respondents
1 to 9 employees	4,022
10 to 49 employees	963
50 to 249 employees	655
250 or more employees	1,161

Question 3

Have you encountered any problems in driver recruitment in the past 24 months?

7,441 respondents answered this question, with the breakdown of responses as follows.

Have you encountered any problems in driver recruitment in the past 24 months	Number of respondents
Yes	3,158
No	2,604
Do not know	1,680

Many respondents, who ran transport businesses, had encountered problems with driver recruitment. There were a variety of reasons for this. Some pointed to the long-term driver shortage, over a number of years, and that a large number of drivers have left Britain over recent months. Others felt it was difficult to attract young people to the profession because of the cost of qualifying, unsocial hours and poor working conditions. Others referred to difficulties in employing agency drivers, prohibitive costs of insurance, the need for drivers to hold a CPC, and delays in obtaining licences.

Comments included:

We are having problems finding suitable drivers. Many fail to attend interview or attend interview then fail to report for work. Some are totally unsuitable when they apply.

I work in the food retail industry and there is a massive shortage of drivers implicating our stock and supplies coming into stores and depots.

The insurance requirements disallows the recruitment of young drivers, there is no point in having British trained drivers who will only be hired if there is 2 years experience. The insurance industry is at fault, if the driver is good enough to pass a British road test then he/she is good enough. Usually these drivers have been on the roads for at least 2 years.

There are plenty of people who hold HGV driving licenses but I can say 100% they are all leaving due to wages. Shocking work conditions and away from home and no social life and you will be lucky to get paid more an hour compared to someone who works 9am to 4pm stacking shelves in a supermarket.

Since the removal of the right of EU nationals to work in the UK there has been a marked decrease in the number of drivers available. Drivers are quite rightly waking up to the fact that pay and conditions are low, and have been depressed by the availability of workers prepared to accept these conditions.

It hasn’t just been the last 12 months though this shortage has been coming for a very long time the industry has struggled to gain new blood for the last 10 years or more the last 12 months has been down to the IR35 and Brexit therefore fewer foreign drivers.

Question 4

Are there any other areas related to driving test rules and licensing arrangements which may act as a barrier and discourage people from considering professional lorry driving as a career choice?

8,094 respondents answered this question, with the breakdown of responses as follows.

Are there any other areas related to driving test rules and licensing arrangements which may act as a barrier and discourage people from considering professional lorry driving as a career choice?	Number of respondents
Yes	372
No	2,062
Do not know	2,312

Respondents pointed to the cost of entering and re-entering the industry, mainly of training, including the need to obtain CPC and undertake ongoing training, but also of the test and increased insurance. Low wages, poor professional recognition, hours and working conditions were also important in discouraging drivers and adversely affecting retention. Waiting for driving licences, and test availability, with long waiting times, could also cause difficulties. The staging requirement, with the need to take a category C test before a C+E test was also mentioned as discouraging new drivers. The need to take a theory test could be off-putting to less academically minded people who might traditionally have become drivers.

Comments included:

The often long and unsociable hours required by the industry. The lack of affordable, safe, quality rest areas available to drivers throughout the road network. The cost of attaining and up-keeping a HGV licence. The pay terms offered by many haulage companies, for the manual aspects of the work are not comparative to other industries.

Yes, the protracted and largely poorly understood protocol for procuring the various vocational entitlements. This industry, to many, is shrouded in mystery and fails to promote the potential advantages of a personal commitment to and an investment in such a vocation.

The cost of training if it comes out of their pockets personally some people want to career change but have too many financial commitments to fork out for training costs first hand.

Most drivers retirement age has gone up past the old norm of 65 however from this date you have to reapply to renew your vocational licence every year this need to be moved to 70 in my opinion.

I have always fancied being a truck driver but the thought of having to take multiple tests to include a regular CPC test is very off-putting especially when I’d have to take a pay cut to enter the industry. There must be a way to reduce testing requirements without compromising safety. As a result of current measures, I only took one lesson in a rigid truck before deciding to go back to my office job.

Cost of training for individuals and insurance requirements for new drivers. Insurance companies will not insure new drivers except at high cost and is a major deterrent to companies as is cost of CPC.

8.2 Questions on amendment 1 – removing the current staging requirements for licence acquisition.

Question 5

To what extent do you agree or disagree with the proposal to remove the staging requirements for vocational driving licences?

9,056 respondents answered this question, with the breakdown of responses as follows.

Do you agree with the proposal to remove the staging requirements for vocational driving licences?	Number of respondents
Strongly agree	4,432
Agree	1,958
Disagree	545
Strongly disagree	1,719
Do not know	402

There was a significant level of support for this measure from those who responded to the consultation. Some felt it could be good for drivers and business as it would ease the process of entering the profession. It was pointed out that, prior to introduction of the current arrangements, drivers went straight to a C+E test without any problems.

Others took the view there are risks associated with removing the staging requirement. They said drivers who had only previously ever driven cars would have no experience in a lorry of this size and would therefore need to have familiarisation of driving a rigid (category C) vehicle first. Some expressed concern there were road safety implications, if drivers had not formally completed training, and been assessed on, category C vehicles. They also expressed concern the standards required of HGV drivers in the longer term might diminish.

However, it was noted safety would be promoted by effective induction training by haulage companies, who have a keen interest in safety as it is their equipment and employees who are at risk.

Comments included:

There should still be a system of driver and vehicle familiarisation when a newly acquired CE licenced driver is asked to drive Cat C. The rigid vehicle responds different to turning circles without the fifth wheel and manoeuvring and reversing is not easy just because it is smaller than a CE.

Each of these vehicle categories takes a completely different set of skills to operate. If you remove the staging requirements you’re going to end up with a lot of crashes, deaths and incidents from drivers who cannot operate their vehicle properly.

There are already too many drivers who have been allowed on the road after just passing a test, without actually learning how to drive. Removal of staging requirements will result in even more poorly trained road users and therefore RTC’s and deaths.

Removing the stages will open up opportunities for those who want to be involved in the industry but can not afford the cost or time of multiple training and test sessions.

Road safety is paramount and drivers will be classed as professional drivers and therefore should expect to be trained in stages for the categories they require.

Due to current shortage of delivery drivers this would open up fixed term opportunities for the short term unemployed. Provide an opening for the long term unemployed, as it is expensive to train and honestly right now most working class families like mine are struggling to meet the weekly bills and seeking opportunities in new areas of work.

Question 6

To what extent do you agree or disagree that a driver who successfully passes a category C+E or D+E test should also be granted entitlement to drive a vehicle in categories C, C1+E and C or D1, D1+E and D respectively?

9,075 respondents answered this question, with the breakdown of responses as follows.

Do you agree that a driver who successfully passes a category C+E or D+E test should also be granted entitlement to drive a vehicle in categories C, C1+E and C or D1, D1+E and D respectively?	Number of respondents
Strongly agree	4,910
Agree	2,144
Disagree	496
Strongly disagree	1,052
Don’t know	474

Again, there was a significant level of support for this proposal. Some respondents said having passed a test in the higher category, you should be considered capable of driving any of the other ‘lower’ categories; the skills to drive the larger vehicles would be sufficient to equip drivers in the smaller ones. Other responses indicated driving and manoeuvring C+E and C vehicle were different as they handle and react differently. As such, there are different skill sets involved, with driving a rigid vehicle being valuable experience before moving on to an articulated one. It was suggested there should be a minimum of a year driving rigid vehicles before moving onto articulated. Another suggestion was those with a C1 licence could be upgraded to a C if the driver was over 25-30.

Comments included:

Sorry I know it asks for explanation only if disagree, but I have to say once again that it is down to the employer to ensure that a driver is competent. As part of interview process they should establish experience of vehicles driven. If it is discovered that candidate went straight to C+E, but there is a requirement to also drive Class C vehicles, then the employer should offer guidance and extra training if required by an internal driver trainer/assessor.

Automatically upgrade those who have c1 licence to c if over 25-30 this would free up a lot of useful drivers to bigger vehicles opening the door for others to fill.

The driving method and manoeuvring of these vehicles is totally different. I think this would cause excessive stress to a newly qualified person, and also present a possible danger to other road users.

If one test can be passed to prove you can drive a large vehicle whether it a coach or lorry should be good enough based on the handling and size of the vehicle. I would also expect grandfather rights for those who have already held a class 1.licence to also have or be entitled to the same entitlement.

Question 7

What benefits, costs, risks or dis-benefits do you think would result from this flexibility?

(a) Do you think any benefits would result in this flexibility?

8,929 respondents answered this question, with the breakdown of responses as follows.

Do you think any benefits would result in this flexibility?	Number of respondents
Yes	5,994
No	1,495
Do not know	1,443

Respondents said this would allow prospective drivers to gain entitlement for the largest vehicles more quickly. If they passed one test, in an articulated lorry they would also gain entitlement to drive a rigid lorry. This would reduce the time and costs involved in licence acquisition.

It would allow drivers to complete training more quickly and reduce the backlog of driving tests, which would help address the shortage currently experienced across the industry.

It should be noted the removal of staging is likely to assist the logistics industry more than the passenger carrying sector as the use of D+E is typically limited to coach and trailer combinations. In comparison to the number of drivers who want to acquire an articulated lorry licence, which of course is key in the logistics sector, the number of bus or coach drivers who would find a trailer entitlement useful is very small.

Those opposed were concerned about the standards of driving and road safety, including the point that driving a rigid vehicle is a different skill from driving an articulated vehicle. Some felt the proposal would mean drivers could drive a large vehicle without full training and this would affect road safety.

Comments included:

Making it easier for professional drivers to transition to other professional driving areas at no cost with minimal extra learning would open up the industry not only for existing drivers who want to try something else but bring new drivers into the industry like never before.

One lot of class 1 training and test would encourage people to take up this career. Quicker for the student and employer and reduce test waiting times and reduce upfront costs to the student. Reducing emissions to the environment as well.

Far more drivers available, and less expense in pointless tests.

It would make the process easier to afford only doing 1 lot of training and test. This will encourage more people to get on the ladder as many in our view have been put off by the amount of training etc.

Would make qualification quicker but not necessarily safer.

(b) Do you think any costs would result in this flexibility?

8,770 respondents answered this question, with the breakdown of responses as follows.

Do you think any costs would result in this flexibility?	Number of respondents
Yes	2,459
No	3,644
Do not know	2,670

Some respondents said there could be a disadvantage for those trainers who specialise in training for rigid lorries which would now be obsolete, and they would need to buy larger vehicles. One trainer gave a cost of £150,000 for new tractor units. They also said training for C+E alone might take longer than it does under current staging arrangements, and said this would increase training costs. It was suggested there could be a student loan-type scheme to cover the cost.

Some respondents continued to point towards increased road safety risks, for reasons already discussed. That might lead to increases in insurance premiums.

Comments included:

Training costs will always be a factor. If you take away the need of graduate training, the training companies will need to extend the training on the C+E/D+E to give the trainee more time to become confident with the vehicle. Therefore prices will either stay the same or increase.

If a company needs a C+E driver they will not need to pay for a C licence.

Impact on the training industry, who will either increase the C+E cost or lose on training funds.

If a person can take one test for all categories this will reduce costs and allow direct flow of new drivers to whatever class of vehicle they have passed on.

Newly qualified UK drivers not eligible to drive in the EU, restricting competitiveness.

(c) Do you think any risks would result in this flexibility?

8,739 respondents answered this question, with the breakdown of responses as follows.

Do you think any risks would result in this flexibility?	Number of respondents
Yes	2,972
No	3,983
Do not know	1,787

Some felt the main risk involved road safety. Risks involved with inexperience of new drivers would increase without staged licensing. Experience needed to be established with smaller vehicles before moving onto the largest. The opposing view was if drivers had experience with an articulated lorry, driving a rigid lorry would present no more risk than usual.

Some respondents said there is a possibility drivers might be exploited by poor employers who could make them drive vehicles they are not familiar with.

However, the main point made was it would be beneficial to speed up licence acquisition and help to address the current driver shortage.

Comments included:

Realistically there is no extra risk whether you drive a rigid or artic, same training applies to both and this extra line of training has always been seen as a bureaucratic action rather than a safety inspired one.

Trucks are much larger these days. To train someone in an 18.5 metre draw bar or 16.5 metre artic, could be dangerous. I certainly would be training candidates in the C vehicle initially and would only step up to CE when I felt the candidate was ready for the challenge!

More accidents as drivers won’t have the skills. Driving class 2 first was the best idea the UK government brought in.

Skills are transferred don’t see any increased risk.

It runs the risk of drivers agreeing to drive vehicles they may not have experience with, putting them at higher risk of making mistakes and accidents happening, but this could be avoided by employers providing additional training where required.

(d) Do you think any dis-benefits would result in this flexibility?

8,572 respondents answered this question, with the breakdown of responses as follows.

Do you think any dis-benefits would result in this flexibility?	Number of respondents
Yes	1,468
No	4,296
Do not know	2,811

A little over half felt there would be no negative effect from this proposal. Reduced training costs, by taking one test rather than two, might encourage drivers to enter the industry. Both haulage and bus and coach industries might have a bigger pool of drivers to recruit from. This could help to address the driver shortages.

Road safety was again considered to be important with the proposal having the potential to reduce the amount of training undertaken by new HGV drivers and for them to be able to drive vehicles they have not passed a test in.

Others suggested some trainers could see a fall in demand, with the potential for them to go out of business, which would damage the vocational training industry.

Some respondents suggested there is a possibility the pass rate could fall if a candidate has less HGV experience beforehand and some drivers, who could have acquired a category C licence, would be unable to pass a C+E test. (To clarify – the C test will continue to be available). Those who had acquired a C+E licence might be less willing to take a job driving a lower category vehicle. This could, potentially, have implications for recruitment of drivers of C vehicles with a detrimental effect on those areas of the industry.

Comments included:

More road users who have inadequate experience potentially leading to fatal repercussions.

The risk in rushing through the process is huge we are talking about giving inexperienced young drivers a license that for the most part takes years to gain the experience needed to hold.

Divergence from EU driving standards, potentially meaning the transfer of licences between European countries is negated.

More accidents. Higher insurance costs.

Cost of insurance and repairs may go up with a higher number of incidents.

Question 8

To what extent do you agree or disagree that drivers should still be able to take a category C test even if they have been granted entitlement to drive by passing a C+E test?

8,859 respondents answered this question, with the breakdown of responses as follows.

To what extent do you agree that drivers should still be able to take a category C test even if they have been granted entitlement to drive by passing a C+E test?	Number of respondents
Strongly agree	2,017
Agree	2,440
Disagree	1,370
Strongly disagree	1,335
Do not know	1,697

Many respondents felt there would be little reason for a driver to take a category C test if they had already acquired this entitlement by virtue of passing a C+E test. Many felt if a driver was able to drive a vehicle combination in category C+E, they should be able to drive a category C vehicle. Others suggested the skills needed are different and they should have to take the C test or at least undertake some training in a C vehicle.

Comments included:

Would be absolutely pointless if they have entitlement. People won’t spend money for the training and test if it’s not needed.

There should be no need to take a Cat C test if you have passed a C+E test. It’s obviously easier to drive a Cat C than it is to drive a Cat C+E.

If they have successfully received a C+E, a C test should be still undertaken to ensure they can use and operate a rigid axle vehicle. The only benefit should be a reduced number of training hours required prior to test.

Question 9

How much additional demand would you expect there to be if the staging requirement is removed?

5,569 respondents answered this question.

There was no consensus about how much extra demand there would be for a large vehicle test. Estimates ranged from very little, to a large surge in demand, with figures between 20% and 100% increase being mentioned. Some respondents said new drivers would be enthusiastic about taking the C+E test if it was possible to go straight to that category without taking C first. It was noted the issues affecting recruitment were not the test itself, but around working conditions. But the lack of respect for the profession, poor terms and conditions and too much “red tape”, with the need to obtain CPC also being mentioned as a disincentive.

Comments included:

Less than expected as trailers are very expensive to buy and store.

Considerable as you would be removing a significant financial investment to gain training.

Honestly, until wages and hours are regulated and fair I don’t think it will attract demand with these changes.

If backed by a proactive campaign of careers education for pre-leavers.

Large demand, many are willing to fill the gap but are prevented by costs.

Question 10

As a prospective employer, do you agree or disagree that drivers should continue to demonstrate competence by taking a category C or D test before a C+E or D+E tests?

8,154 respondents answered this question, with the breakdown of responses as follows.

Do you agree that drivers should continue to demonstrate competence by taking a category C or D test before a C+E or D+E tests?	Number of respondents
Strongly agree	1,893
Agree	1,299
Disagree	1,746
Strongly disagree	1,529
Do not know	1,687

Opinion on this issue was evenly split. It was considered important, with the current driver shortage, for new drivers to enter the industry quickly. Respondents said if this measure allows more drivers to be trained and to be available to work, then it is highly beneficial. In these circumstances, there was no specific need to pass a test in category C or D. It was suggested there is a great deal of similarity in the training and assessment for the different categories and so familiarisation training should be adequate.

It was suggested the HGV driver force had been marginalised, under-represented and over-pressured for a number of years. This was an opportunity to rectify that. Whilst some saw taking a category C first as supporting road safety, many others felt if the driver was competent in C+E they should be able to drive a category C vehicle. Such respondents considered it to be unnecessary to take a C+E test, when entitlement had already been obtained for an articulated lorry.

Comments included:

For us a waste of time, we want C+E drivers, not C, so not concerned about C competence, C+E is what we need.

If a driver is trained properly and meets the test standard there should be no reason to insist on a lower category vehicle test.

There is a shortage of drivers so lets speed them into service.

More pupils would join the industry if straight to C+E as wages are better so they can recover the cost of the training sooner. Also the demand is for C+E drivers.

Question 11

Do you consider there to be any concerns for road safety should the government implement this measure?

8,753 respondents answered this question, with the breakdown of responses as follows.

Do you consider there to be any concerns for road safety should the government implement this measure?	Number of respondents
Yes	2,812
No	4,832
Do not know	1,109

The majority of those who responded did not consider there to be a significant road safety issue with this proposal. If a driver had demonstrated competence in C+E or D+E, they would already have been tested and had the skills to drive a vehicle of this size which would be transferred to other vehicles.

Others, however, felt the staging requirement gave drivers training and experience in driving a smaller vehicle which was valuable in moving up to the higher category. This experience equipped drivers in vehicle handling and awareness skills which had a benefit in road safety. It was preferable to have to pass a test for each category of licence. It was suggested accident rates might increase if staging is removed.

Comments included:

We are professional driver for each category. Skipping these tests is dangerous and irresponsible. It would be like putting a cyclist straight away into a car. Other road users should you are a competent driver for that category.

Better social media adverts & TV adverts to educate the public on driving behaviour around HGV’s, also include this more in car tests.

Straight to class one 44 tonnes with no experience compromises road safety.

With the right amount of training and assessment I don’t see any issues regards road safety.

As long as the test standards are maintained and consistent there should be minimal risk.

Question 12

Do you think this would impact trainers, in terms of their existing fleet of training vehicles and costs?

8,597 respondents answered this question, with the breakdown of responses as follows.

Do you think this would impact trainers, in terms of their existing fleet of training vehicles and costs?	Number of respondents
Yes	3,504
No	3,016
Do not know	2,077

The current fleet of category C and D vehicles could still be used for training new drivers who want to drive these vehicles, as part of training for larger vehicles, or sold to fund the purchase of the larger ones. For some trainers who were equipped to undertake training in C and D vehicles, these comprised the majority of their fleet. One benefit from the change might be category C+E trainers would increase revenue from training in larger vehicles.

C and D vehicles would, however, be under-used compared with now. A number of trainers considered the proposals might result in loss of revenue, which could affect the viability of their business. They said category C training vehicles might be underused, and perhaps obsolete, redundant or unsaleable. Others said they would have to invest in new vehicles, which would come at a cost. They also mentioned the additional space required to park longer C+E and D+E vehicles.

Comments included:

Possibly more people going straight to C+E so will be demand for these vehicles only and less so on the C class vehicles.

Yes maybe it would make some of their vehicles redundant. but i think you should still have an option for class c.

It will make companies like mine close and make me fire trainers as I wont have any work for them. This will destroy many small businesses who are just starting to recover from the pandemic.

The demand for Class 2 would decline massively which would result in a lot of trainers selling their Class 2 vehicles. This would therefore mean trying to acquire Class 2 training would be expensive and very hard to come by.

As I was a trainer previously, there was a cost to the company when the vehicles presented for test had to have 8 forward gears. This meant having to purchase a new fleet of vehicles. If this proposal gets the go ahead, it would mean training bodies may need to purchase additional class 1 vehicles to meet demand. It could also mean that they would need to find additional space to park larger vehicles, which may not always be possible.

Question 13

To what extent do you agree or disagree that the rules for qualified drivers accompanying provisional licence holders need to allow a C+E or D+E qualified driver to supervise a C or D provisional licence holder, without having taken a C or D test?

8,616 respondents answered this question, with the breakdown of responses as follows.

Do you agree that the rules for qualified drivers accompanying provisional licence holders need to allow a C+E or D+E qualified driver to supervise a C or D provisional licence holder, without having taken a C or D test?	Number of respondents
Strongly agree	1,996
Agree	2,447
Disagree	860
Strongly disagree	930
Do not know	2,384

Opinion was split on this issue. Some respondents felt if a trainer held a full entitlement in the higher category, they would have the skills to train drivers in smaller vehicles. Others considered the characteristics of a rigid vehicle were different from an articulated one and the trainer should be experienced in the vehicle he was training on. It was also acknowledged not all category C+E or D+E drivers had the necessary training skills to impart driver safety knowledge. In addition, insurers might need some type of training or supervision for them to be covered.

Comments included:

Qualified to drive larger vehicles, so should have ability to supervise provisional licence holders in smaller vehicles.

Cat C vehicles drive very differently from C+E turning circles and trim characteristics would require a supervising driver to have driven that vehicle and understand this.

I feel that on paper this is a problem but in reality it will have a very small impact.

They have already demonstrated suitable ability by passing a C+E or D+E.

Question 14

To what extent do you agree or disagree that the restriction which prevents a category C licence holder who is under 21 from holding provisional C+E entitlement until they have held their C licence for 6 months should continue?

8,651 respondents answered this question, with the breakdown of responses as follows.

Do you agree that the restriction which prevents a category C licence holder who is under 21 from holding provisional C+E entitlement until they have held their C licence for 6 months should continue?	Number of respondents
Strongly agree	2,737
Agree	2,466
Disagree	1,227
Strongly disagree	980
Do not know	1,241

The majority of respondents agreed the restriction should remain in place. However, a variety of views were expressed. Some said it ensured young drivers had some experience of on-road driving before being able to apply for category C+E entitlement. This could be beneficial as a certain degree of maturity was appropriate when driving a larger vehicle. Others said the level of maturity an individual has is not that strongly related to their age. For example, some drivers, who were younger than 21, had sufficient maturity to accept the level of responsibility to drive the largest vehicle. In any case, 18 was the legal age for most other rights. Age should not be a barrier to acquiring these skills and it was important to attract young people to the profession.

Comments included:

I do believe that drivers need to be 21+ before considered for C+E.

If they are competent, then they are competent. It seems ageist to me.

Young people are the most unemployed in the UK and opening this avenue would be beneficial to all aspects of the UK industries.

Age should not be a factor. If they are good enough to pass C at 18, they are good enough to learn C+E.

8.3 Questions on amendment 2 – considering alternative arrangements for the conduct of the reversing manoeuvres

Question 15

To what extent do you agree or disagree with the proposal to enable the reversing manoeuvres and the coupling exercise to be conducted by an authorised third party?

8,768 respondents answered this question, with the breakdown of responses as follows.

Do you agree with the proposal to enable the reversing manoeuvres and the coupling exercise to be conducted by an authorised third party?	Number of respondents
Strongly agree	2,845
Agree	2,790
Disagree	890
Strongly disagree	1,205
Do not know	1,038

More than 63% of respondents agreed the manoeuvres and coupling parts of the test could reasonably be conducted by a third party. It was suggested training might be more realistic as a result. Respondents commented training centres would be able to teach in more realistic situations than a test centre and conduct more realistic scenarios relevant to the job. It would allow more driving tests to be conducted and many training sites already had in place this facility.

Some were more cautious, considering it important for new arrangements to be supported by clear and robust regulation, quality assurance and registration, with rigorous inspection and monitoring. This was an integral part of the test and revising the way it was delivered should not result in any change to its effectiveness.

Comments included:

This is an important part of the DVSA test which deems competency to award a licence.

3rd party should be trained to assess at test standard not simply authorized.

Most trainers are fantastic in their job with plenty of experience in the field.

It’s an essential part of the test and therefore should be conducted by a qualified examiner.

Question 16

Do you consider there to be any barriers for training organisations to provide an assessment?

8,606 respondents answered this question, with the breakdown of responses as follows.

Do you consider there to be any barriers for training organisations to provide an assessment?	Number of respondents
Yes	1,486
No	4,827
Do not know	2,293

It was considered a competent trainer would be able to undertake the assessment of a driver’s competence. However, the ability to do so depended on access to an appropriate reversing area, which might not be available to all training organisations. This arrangement would need to be in place so the test, or assessment, can be conducted in accordance with the regulations. Overall, it was felt the costs of delivering training and tests might rise as a result of accessing such sites and there would potentially be a need for additional audits and quality procedures.

In addition, some respondents considered if the same person undertook the training and then conducted the test, there could be a potential conflict of interest. It was suggested a quality control process should be in place, with regular quality assurance.

Comments included:

Training organisations want high pass rates to uphold their reputation - could lead to below standard drivers passing these assessments.

Lack of qualifications, lack of suitable testing facilities.

Training organisation train to a very high standard as trainers are scrutinised and have their own personal targets set by their own organisations so the candidate should be of a high standard unless they having had the required hours and are trained in 1 week. A minimum number of hours behind the wheel should be introduced to stop this.

Only very large driving schools have DVSA approved reversing areas at their own sites. This will be an unfair advantage and goes against fair competition.

Question 17

Who do you think is best qualified to be authorised to assess the manoeuvres?

8,041 respondents answered this question, with the breakdown of responses as follows.

Who do you think is best qualified to be authorised to assess the manoeuvres?	Number of respondents
Existing or new HGV trainers being authorised	3,229
Only those trainers who are members of either of the two voluntary HGV training registers	1,114
Trainers who hold specific professional qualifications	3,700

Many respondents indicated any trainer who holds specific qualifications could perform an assessment role. Some considered those who are on one of the official registers of HGV driver trainers could be deemed competent. Others preferred only qualified examiners should conduct the manoeuvres part of the test. It was suggested a level of experience, as indicated by a period of time being a trainer, could be a qualifying criteria.

Comments included:

I feel anybody assessing this part of a test needs to be trained and on a register with periodic refresher assessment/training forming part of the registration.

Experience personnel who have done the job for a living not someone who has done a training course.

Only authorised trainers should authorised to assess manoeuvres.

Only qualified DVSA examiners should assess this element as fully independent verification of standard achieved by a candidate.

Question 18

What sort of scheme do you think would best support this arrangement?

8,073 respondents answered this question, with the breakdown of responses as follows.

What sort of scheme do you think would best support this arrangement?	Number of respondents
A scheme that is as light touch as possible for authorisation and ongoing assurance, with minimal involvement from DVSA.	3,797
A fully regulated scheme with provision for formal quality assurance checks, removal of authorisation and an appeal mechanism.	4,276

Opinion was divided, with a slight majority in favour of a fully regulated scheme.

Whilst some felt a light touch scheme could be appropriate; others considered it was preferable for it to be accompanied by formal quality assurance and ongoing audits. Some respondents again commented on road safety and the need for drivers of potentially dangerous vehicles to be properly trained and assessed, at least to the present standard.

Comments included:

If brought in would need to be strictly regulated.

If you go for light touch it will be abused and will increase KSIs on our roads.

It needs to remain as it is. DVSA examiners need to assess the test and manoeuvres as they are now.

I would use something similar to the Driver CPC arrangement with JAUPT and the DVSA. This works well and requires standards and qualification.

Question 19

Do you consider there to be any concerns for road safety should the government implement this measure?

8,651 respondents answered this question, with the breakdown of responses as follows.

Do you consider there to be any concerns for road safety should the government implement this measure?	Number of respondents
Yes	2,255
No	5,205
Do not know	1,191

Most respondents did not think road safety would be compromised by this proposal.

It was observed standards of training in the industry are high and some considered the system would operate successfully, provided an effective system for supervision was established and the necessary controls are put in place. Respondents referred to drivers’ experience and competency and the need to maintain quality of training and assessment, which could be achieved if properly regulated.

Comments underlined the need for drivers to be competent in reversing and uncoupling. Some respondents felt there could be a risk to road safety if the current standard of testing is reduced.

Comments included:

Needs to be a professional body with no financial gain from the company otherwise you will have people driving lorries who are not capable which causes me major concerns for road safety.

Getting people on the road quicker wouldn’t help the population. There will be more road accidents - hold ups- ambulance- clean up- medical assistance etc needed due to inexperience with these drivers. Long term, this doesn’t work.

If this is managed and conducted professionally there will be no downside.

I think that there will be more accidents both on and off the road if these proposals are seen through. There could be an increase in KSI statistics both on site and on road.

8.4 Questions on amendment 3 – allowing car drivers to tow a trailer without the need for an additional test

Question 20

To what extent do you agree with the proposal that car drivers should be allowed to tow a trailer without the need for passing a B+E test?

9,475 respondents answered this question, with the breakdown of responses as follows.

Do you agree with the proposal that car drivers should be allowed to tow a trailer without the need for passing a B+E test?	Number of respondents
Strongly agree	5,216
Agree	932
Disagree	702
Strongly disagree	2,437
Do not know	188

Around 60% of respondents agreed with the proposal to grant a trailer towing entitlement on passing a car test, with 25.7% strongly disagreeing.

Some felt many drivers tow a trailer using a licence entitlement that was granted without taking a test. They considered it unfair for younger drivers to have to take this test to acquire the same entitlement.

A key concern was, however, road safety. It was important for car drivers to have the necessary handling and manoeuvring skills to tow a trailer. Some considered the test was introduced to increase road safety and this rationale still applied. It was observed many car drivers have difficulty towing and reversing with a trailer, and there was a need for training and assessment to be undertaken. There would also be a significant risk to road safety if drivers were not competent in coupling and uncoupling their trailer.

Some B+E trainers said if the test was abolished, it would also have an effect on their businesses.

Some suggested one option was for a B+E assessment to be carried out by trainers, which would maintain standards and allow examiners to be freed up to conduct vocational tests.

Comments included:

No need for a test. But signed off by regulated body.

The increase of drivers towing trailers in the outside lane of motorways and at speeds well in excess of 60mph shows the absolute need for training/enforcement.

If the national pass rate is around 60% then that shows a test is needed otherwise the rate would be much higher, too many accidents from unlicensed B+E drivers.

Trailers can be very dangerous and I believe that training should be given before being allowed on the road. How many drivers could reverse a trailer without proper training.

Question 21

How much, on average, does a B+E training course cost a driver?

7,571 respondents answered this question.

There were a variety of costs quoted for a B+E course, ranging from below £100 to some £3,500. Taking all these into account a reasonable overall assessment was around £750.

Question 22

What benefits or dis-benefits are there for a driver if they don’t need to take a B+E test?

6,824 respondents answered this question

Respondents said the rules would be less confusing and drivers would save money. Some pointed out drivers often want to tow a large trailer only occasionally, so the cost of lessons and of taking the test is disproportionately high.

Others suggested drivers would still be able to take training if they were concerned about towing. They could improve their competence, whether for personal or professional reasons. For example, for towing a caravan, or for a horse box, or to help businesses with delivery needs.

However, the main benefit for DVSA is it would also free up examiner resource to help reduce waiting times for HGV tests.

Road safety concerns, of the type previously discussed were noted. Drivers who did not take a test or training might not have the necessary skills to drive such a vehicle with safety – for example in reversing, observation and positioning – which would be likely to lead to more road accidents and be a greater risk to themselves.

Comments included:

Removal of requirement to take a further driving test.

Less red tape. I cant see a major need for this as towing a trailer is rare for deliveries, unless off size equipment, such as a large lawn-mower, etc.

Benefits for the agriculture industry, horses, builders, gardeners etc. All would benefit form taking younger staff on who can transport good, take material away and much more without the need of a test and training which fees are only increasing putting people off.

Benefits are that they don’t have to pay for training/test or try to get a test date. Dis-benefits will be an increase in accidents which will lead to road closures, delays, and potential injuries/fatalities!

Question 23

Please explain how this will impact your business.

4,561 respondents answered this question

Some who ran businesses in relevant areas saw opportunities in the proposal. They said it would allow them to undertake deliveries more easily, employ more drivers and some would be able to expand their business. Individual drivers considered this would improve their options, allowing them access to driving employment and, in relation to the proposal for cars and trailers, said it could improve the range of activities available during leisure time.

Some people who operate private clubs or voluntary organisations saw an opportunity in having more drivers being available to tow vehicles as part of their activities. Others said businesses would lose less time when drivers were attending training.

Conversely, trainers who focused on B+E training would be affected by a loss in business. For some this was a significant part of their business – 80% was quoted – and some trainers said they might go out of business as a result.

Finally, some people said increased accident rates could indirectly affect businesses by causing delays, for example in deliveries.

Comments included:

This will be beneficial to our business in every aspect and will be put less stress on demand for all these services.

Part of our business will have to close. Our B+E trainer will be out of work.

This will make it easier to employ drivers but may cost money to ensure drivers are confident and well trained in towing a trailer.

I would have a bigger pool of drivers to drive vehicles with trailers, that currently don’t have the rights to.

I would need to close down.

Question 24

Do you think drivers would continue to want to take some training, even if a test is not required?

9,341 respondents answered this question, with the breakdown of responses as follows.

Do you think drivers would continue to want to take some training, even if a test is not required?	Number of respondents
Yes	5,126
No	2,992
Do not know	1,223

Most of those who indicated a preference considered drivers would continue to take some training before towing a large trailer. For example, organisations might require employees to do so when driving professionally.

Other than this, it would depend on individual preferences. Some, who had not towed a trailer for some time, might consider it prudent to take a refresher course. Where there were specific skills required, such as towing a trailer with horses or other livestock, drivers might also decide this was a sensible course of action. In addition, insurers might offer financial benefits to those who took some training.

Others felt it unlikely many drivers would undertake training before towing a vehicle if they were not mandated to do so.

Comments included:

I believe most sensible people without prior experience would look for ways to make themselves aware of the risks and procedures.

I suspect some drivers may want some additional training but I think take-up would be similar to the number choosing to take advanced driving courses, with only a minority wanting this.

A caravan is often a significant investment and most people recognise the value of training before towing it.

I don’t know but if they did and required it, we would be happy just to give them that little bit of training extra.

Some may, depending on personal integrity and professionalism.

Some will - the more responsible ones. I do not this its a good idea to remove the test requirements for car drivers & towing.

Question 25

Do you consider there to be any implications for the insurance industry?

9,138 respondents answered this question, with the breakdown of responses as follows.

Do you consider there to be any implications for the insurance industry?	Number of respondents
Yes	3,557
No	3,943
Do not know	1,638

Some respondents felt the insurance industry might increase premiums for drivers who chose to drive a vehicle combination in category B+E, whilst others queried whether this would be an issue. They were more likely to rise if accidents increased. However, the risk, and premiums, could conceivably be reduced if drivers voluntarily took training and assessment.

Some, however, considered insurance premiums would be likely to increase for all drivers.

Comments included:

Risks increase, premiums will rise for all.

They will put insurance up surely as the risk will go higher. This is highly unfair on already professional HGV drivers.

Possibly for younger drivers as higher premiums would be imposed on the industry.

More accidents are inevitable I think. And then costs will go up across the industry.

Question 26

Do you consider there to be any concerns for road safety should the government implement this measure?

9,198 respondents answered this question, with the breakdown of responses as follows.

Do you consider there to be any concerns for road safety should the government implement this measure?	Number of respondents
Yes	3,421
No	4,957
Do not know	820

Most of those who responded indicated they did not have concerns about road safety from this proposal. It was considered drivers would need to take personal responsibility, taking training if they felt this would help them drive safely. Some, felt this could, in fact, improve safety.

However, for the reasons already discussed, many were worried about the possibility of a detrimental impact on road safety. Concerns about the skills of driving a car and trailer being different from simply driving a car, and not intuitive, the length of the combination being greater and the manoeuvrability being different. It was also important trailers were secured and loaded properly. Whilst some drivers might take training voluntarily, others would be unlikely to, if there was no test. It was also suggested there could be an increase in legal claims if there were more accidents following the introduction of the change proposed.

Comments included:

Untrained drivers would present a risk.

Before 1998 people were not required to sit a test for this and there was no concerns then.

Many accidents will be caused by drivers who don’t understand the difference between driving styles when towing a trailer.

Inexperienced drivers cause fatal accidents, it doesn’t matter what category of vehicle they are driving. We should be doing more to encourage more training and testing not looking at ways of reducing the training that people currently require.

9. Conclusion

Ministers have considered the views expressed by those who responded to this consultation carefully. In light of the urgent need to tackle the shortage of HGV drivers, and also to reduce waiting times across the test categories affected by these proposals, they have decided the proposals should be implemented at the earliest opportunity.

It is considered any increased road safety risk will be mitigated by in-house training, the accredited trainer scheme and through assessments, as it is clearly in the interest of the logistics sectors to act in a responsible and professional manner in regard to driver training. The changes will also be reviewed in three years to assess any road safety impacts.

It is recognised individuals in some parts of the driver training industry might be affected adversely by this decision. However, it is considered introducing these measures, which are already in force, will help in the ongoing national recovery from the initial impacts of the pandemic. Most importantly, it is considered these developments will help to ensure the key logistics sector is supported in its recruitment and deployment of drivers.

1. C+E - lorry over 3,500kg with a trailer over 750kg.

   C - lorry over 3,500kg with a trailer up to 750kg.

   D+E - bus with more than eight passenger seats with a trailer over 750kg.

   D - bus with more than 8 passenger seats with a trailer up to 750kg. ↩