Motorcycle Real Road Racing Blog by Barbiegirl Northern Ireland
Right To Ride has replied to the madness contained in the Department of the Environment’s (DOE) consultation on proposals for implementing the 3rd EC Directive On Driving Licences.
This directive voted on and passed in the European Parliament in 2006 must be transposed into national legislation by 19th January 2011 and enter into force as of 19th January 2013.
The directive is designed to harmonize motorcycle licences across Europe, although the directive allows members states flexibility at what age they can allow a rider to access the licence categories.
The European Commission gave member states 3 choices in terms of progressive access from categories A1 to A2, and A2 to A:
To offer riders the choice of either training or a test
To impose training only
To impose testing only
The DOE has unfortunately moved well beyond the spirit of the directive.
Apart from the complexity of the DOE proposal which was put out to consultation, it offers no benefit to riders.
We strongly disagree with the consultation proposals which aim to introduce provisional licences granted for all categories of licence entitlement. In our opinion these proposals are prescriptive and convoluted and badly thought through. The irony is that these proposals will effectively undermine the EU directive on all counts and encourage riders to become “permanent learners”.
The DOE proposal wants to allow “novice” riders access to full power motorcycles and to undertake every two years an undefined “refresher course”, to ride indefinitely on a provisional licence. What this means is that the rider will have to take a mandatory refresher course (which the rider will have to pay for anyway), without the benefit of entitlement to a proper licence and a test if they wish to move to a bigger motorcycle.
The DOE has simply followed the Department for Transport’s (in Great Britain) recently completed consultation and subsequent report on the directive, which is to impose a provisional licencing system, using as a model, the GB based costs. But the DOE consultation proposals do not define what these “mandatory” refresher courses and tests will actually entail, nor how much they will cost the individual rider.
These proposals go against the EU directive which prescribes an option of 7 hours approved training between the categories.
Right To Ride calls on the DOE to:
Carry out a full cost benefit analysis and regular impact assessment should be carried out based on Northern Ireland calculations and how this affects the people of Northern Ireland.
That the training based arrangement should be reviewed and consideration given to the way in which other countries in the European Union are implementing the directive, especially regarding the training route.
The Motorcycle Industry in Europe - ACEM (Association des Constructeurs Européens de Motocycles) proposes training for progressive access for riders when stepping up between licence categories and agrees to the 7 hours training as prescribed in the directive.
Right to Ride’s, Trevor Baird says, “We recommend that the DOE investigates further the values of cost beneficial 7 hours structured, relevant and cost-effective basic training to give the rider moving between licence categories, the essential skills and knowledge capable of safely operating a motorcycle continuously in normal traffic situations on public roads.”
In our view, the DOE consultation has set out proposals which will effectively undermine the EU directive on all counts and encourage riders to become “permanent learners”, by being able to ride indefinitely on a provisional licence.
The DOE consultation has moved well beyond the spirit of a process of implementing the 3rd European Driving Licence Directive, which is in itself complicated (albeit understandable) into a prescriptive and unnecessarily difficult set of proposals, which will certainly not give riders any benefits and will not be unenforceable.
Acem says that, “Training should be designed to actually enhance motorcycle safety; and not merely be a check in traffic to demonstrate that the rider has the required skills to operate a motorcycle in traffic. Training should not merely be a refreshment course, but include specifically designed modules that address the main causes of accidents involving motorcycles. Training provides a tool to increase rider knowledge and experience, with the ultimate target to enhance motorcycle safety.”
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©2010 Motorcycle RealRoadRacing Blog by Barbiegirl Northern Ireland