My name is Loz Williams and 2Wheelskool is a motorcycle training school in Bradford,
which employs 4 other instructors and trains around 300 students to test standard per annum.

“What aspects of the new test should be looked at is the review question?”
“All of it is the answer!”


We are in a quandary because at implementation of 2DLD it is reported our elected ministers
were not even present and failed to challenge and ask for derogation to the 50kph measurement.
This is what has caused the basis of most of the problems of the new test and should be the
start point of the review and changed! This fixation with achieving 50 kph causes just about
all the problems we have. The second main issue is gold plating directives. For some reason,
in this country, whatever directives come out of Brussels we seem to interpret them to the
extreme. 2DLD consisted of 4 manoeuvres our new test has 11.


1. The DSA created the Module 1 test without consultation. It decided the layout and
dimensions, allegedly trialled it and implemented it after two U turns and deferments.
This all smacks of a test not ready to be imposed on the country.

2. I believe the exercises should as far as possible represent real road situations,
so the case for conducting them on a road with undulations, cambers, Kerbs potholes etc….
is a very valid point. The slow ride exercises are sensible and could reflect real road
situations (albeit the figure of 8) A controlled stop is necessary and if the obstacle
avoidance is to be done it should be a straight line approach conducted at normal
acceleration. I think a review to conduct the test in real road situations should be the
way forward. The problem is the fixation with the speed element of the test. So unless
this is rethought, relaxed, or removed our hands are tied to an off road test,
with measuring equipment and a formal layout.

3. Assuming we stick with the current test the dimensions in my opinion are wrong
on two main points.

a.	This test has all but denied access to some groups of riders. The A1 category test 
and licence is now virtually impossible to achieve.  A low powered motorcycle with a 
heavy rider can not achieve the terminal speed required to pass. Manual change scooters 
are an example. I have had to train a scooter club to use my 125cc bikes for Module 1 
and then they switch back to their own machines for Module 2. This is a ludicrous 
situation where one part of the test is not allowing certain vehicles to be used 
albeit they can be used for the second part Module 2. Simple answer is to have 
different dimensions for the standard and A1 bike tests.

b.	The swerve and stop. This exercise which 2DLD set as obstacle avoidance has 
become a double swerve and challenging brake exercise. (Gold plating) The layout 
is wrong and this has come to light as this exercise is the one responsible for 
most of the crashes on test. It should be amended immediately. The requirement 
to swerve back and brake should be removed and students should be allowed to 
pull up in their own time and space as you would if this incident occurred on 
the road.


The claim that MPTCs can grip as well in the wet as they can in the dry is 
factually incorrect. I would challenge any academic to prove any road surface 
has the same grip properties when wet as dry. However the DSA assume this, as 
no allowance is given for the test when it is wet. Firstly the DSA must start 
to collect data, I would not be surprised if the crash rate and fail rate rose 
dramatically when it is wet. Simple answer is to have a wet weather layout. 
This has already been called for by the Transport select committee report but 
I see no action to address the situation by DSA.


There were over 240 test centres prior to the implementation of this test. 
There are now lees than 50. It does not take many brain cells to realise that 
coverage will be dramatically reduced after such a cull. At original consultation 
the training industry were promised up to 80 centres and no more than 20 miles 
or 45 minutes travel time. In West Yorkshire (my area) we were promised 2 centres 
however the DSA have reneged on that promise and ceased to search for a second 
MPTC. This leaves no service to the northern half of the county. I have been 
campaigning for a second MPTC since learning of their promise break and even 
offered simple solutions like re opening Dewsbury Road, Cleckheaton. This casual 
site was used to good effect for over a year and would be low cost and easy 
to re instate.

I do not understand the 45 minute 20 mile criteria. In response to my campaign 
supported by Terry Rooney (ex MP) The DSA conducted trials from Bradford and 
admitted that from every point of origin the MPTC at Wakefield took more than 
45 minutes to achieve but stated all points were within 20 miles. What I can’t 
get my head around is why have a time criteria if you are going to ignore it. 
There cannot possibly be a MPTC achievable that is more than 20 miles distance 
yet reachable in less than 45 minutes. What exactly is the dual criteria for? 

Coverage must be addressed. We had casual sites that brought the numbers up 
to a reasonable level and served poorly covered areas but the DSA has closed 
many of these causing a big rise in distances students have to travel. My 
question is WHY? and why not reopen them. (West Yorkshire a typical example)


The cost to individuals and the training industry has soared. I have analysed 
the increase to students since April 09 and it is over 30 %. Test fees alone 
have risen 34%. Extra training time and extra time to simply take the test all 
add to the cost (it is a 3 hour turn around to test from my location).

For training schools it is the same, I have had to pass on some of the extra 
fuel, running and test fee costs but to remain competitive I have had to absorb 
some. My profit margin and personal income has dropped markedly to the point 
where consideration to continue as a training school in this location is under 
question. That is wrong. I run a very efficient and well respected training 
school which is under threat due to lack of local testing facilities. 


To pass the new test we have to train students to ride in an unacceptable manner 
and one which would result in a fail on Module 2. The need to accelerate hard 
off a bend up to the rev limiter in the case of 125s is ridiculous. Again it 
is the combination of the bend exercise and Controlled stop/Obstacle avoidance 
being combined. If the whole test was conducted on the road we would be teaching 
students in the environment they use. Real life techniques for their riding future 
instead of the sterile incorrect practises we have to teach. 


The additional costs, lack of coverage, lack of areas available to train students 
and complexity of the whole process has lead to many training school closures. 
Whatever the cause the Government should be concerned about this problem. If 
members of the public cannot find local, value for money training schools they 
will either continue to ride on CBT and “L” plates or ignore taking the test 
and risk riding illegally.  Its not just the new test, training schools provide 
the CBT as well so riders may also ignore taking or renewing CBT if they can’t 
find somewhere local. This whole MPTC scenario is shrinking and focusing training 
availability to proximities around the centres. I always worried about this 
problem of “haves and have nots.” Training school survival is being dictated by 
where the DSA choose to site MPTCs Unfortunately in West Yorkshire my school is 
in the “have not category”.


This review has been called for due to some alarming statistics, a damning TSC 
report and general industry and media unrest at the new test imposed by 2DLD. 
My fear that lessons have not been learned and 3DLD is on the same catastrophic 
course seems to be realised. The consultation for it has closed and DSA has 
announced the results which are the usual gold plating. This will probably be 
the final nail in the coffin for training schools struggling to survive. It will 
involve a whole costly new purchase of a bike fleet necessary to provide for the 
tiered training and tests. Some of which the main manufactures don’t even build 
or import into the UK! The complexity is mind boggling, the consultation was 
almost impossible to understand and I still don’t think anybody knows exactly 
how 3DLD is going to impact.

My basic understanding is to introduce riders to more powerful machines in a 
controlled manner, thru age and capacity/power restrictions. It’s a novel concept 
and hard to argue against it, as a sensible idea to make motorcycling safer. 
But as with 2DLD is it going to do this?  I cannot see any benefit from the 2DLD 
as yet so why don’t we let the dust settle and analyse these changes before we 
rush headlong into other ones. 3DLD needs a lot more analysis, research and 
consultation (the one produced was not fit for purpose.) before any decisions are made.


It is refreshing to see a government and minister willing to listen and have a 
review. My points are my opinion and based on a life time of riding and 10 years 
of instructing in this industry. I am sure there are many counterpoints, 
considerations and other ideas from interested people and organisations. 
I love the phrase “if it aint broke don’t fix it”! In the current cost cutting 
environment I don’t think the MPTC project would have been allowed to happen it 
is gold plating to the extreme, My worry now is that the DSA have put so much, 
cost and reorganisation of test centres into this that change is almost impossible. 
I dread the thought that one day there will be a fatality while taking a Module 1 
Motorcycle test. In any Licence acquisition test that cannot be right, something 
must be done. 

Regards L S Williams