Before the Transportation Subcommittee of the House Finance Committee Testimony on HB 53 February 12, 2015 Chair Grossman, ranking member Reese, and members of the subcommittee, my name is Mike Morgan of AAA East Central and I am here today representing the Ohio Conference of AAA Clubs. The Ohio Conference consists of the seven AAA clubs in the state and collectively represents over 2 million Ohio motorists, your constituents. It is with great excitement and hope that AAA responds herein to the request for input on the Drive Toward a Safer Ohio initiative. As a public advocate for motorist safety and a long-time provider of driver education in Ohio, AAA greatly appreciates the opportunity to provide input to the plan. AAA’s comments are informed by its leadership in the NHTSA-funded Association of National Stakeholders in Traffic Safety Education (ANSTSE), its past and ongoing research into driving safety issues, and its 80 year history of providing educational materials and support to the driver education community. This document is intended to summarize AAA’s input on the Drive Toward a Safer Ohio initiative. Of the whole set of initiatives, AAA wholly supports some as they are currently written, supports others conditionally, and views others as not supportable as currently written. As always, AAA staff stands ready to provide any additional details which might be useful for the state’s consideration and deliberations. AAA Supports as Written: A. Increasing Behind-the-Wheel (BTW) time from eight to 10 hours This would position Ohio as one of the only states to meet the Novice Teen Driver Education and Training Administrative Standards for the amount of Behind-the-Wheel training (10 hours) B. Increasing ODPS’s regulatory authority This would securely position the ODPS to more effectively sanction noncompliant programs, thus raising the overall quality of DE throughout Ohio C. Integrating the behind-the-wheel and classroom portions of driver education This would position Ohio to meet Standards 1.1.22 of the Novice Teen Driver Education and Training Administrative Standards: “Ensure that the instruction of novice teen drivers is complete using concurrent and integrated classroom and in-car instruction…” D. Expanding nighttime driving restrictions This would be expected to enhance teen driving safety through effective Graduated Driver Licensing E. Enhancing penalties for driving-related offenses This would be expected to increase the deterrent against unsafe driving AAA Conditionally Supports: A. Use of simulators to test teens in advance of taking the Ohio On-Road driving test Such use of simulators should be fully informed and guided by recent research detailing how simulators can be both (a) validly and (b) reliably utilized to assess students’ driving skills (See Evaluation of Beginner Driver Education Programs: Studies in Manitoba and Oregon, Sept. 2014) B. Establishment of consistent Instructor Training Ohio should adopt the forthcoming, full-scope National Driver Education Instructor Training Curriculum, to be released by ANSTSE C. Driver Education Requirement for People Age 19+ Ohio should require a six-to-eight hour driver education program for all new drivers, regardless of age; the program should initially launch utilizing classroom instruction, with exploration of allowing online programs to follow at a later date, once the program is established D. Allowing non-state entities to conduct the Ohio State Driving Test AAA supports Ohio expanding the capacity to conduct the Ohio State Driving Test by allowing qualified “third-party” testing. However, the ability to offer such testing should not be restricted only to Advance Driver Training (ADT) Programs. If Ohio’s goal is to reduce the number of tests conducted by state-employed examiners, the solution that would accomplish the greatest increase in capacity and access, and ensure state-wide availability, is to allow Ohio statecertified Driving Schools to conduct such testing o Limiting conduct of the state Driving Test only to ADT programs would result in greatly minimized capacity and reduced convenience for students, and would inappropriately support only a narrow segment of Ohio businesses involved in driver training o There are many more state-certified driving schools than ADT programs, maximizing students’ access and convenience AAA supports this move only under the following conditions: o Both state-certified driving schools and ADT programs can offer the Driving Test o o o o o o o State-certified driving instructors are far more qualified to conduct the Driving Test than ADT instructors, some of whom have never even taken driver education, and have never taught novice students in an on-road assessment environment If the test is conducted by a state-certified driving school, the school cannot test students that have completed its own driver education program (i.e., Driving School A can test students who have completed Driving School B’s driver education program (and vice versa), but A cannot test its own students). If the test is conducted by an ADT program, the student shall not be required to also take any other instruction offered by the ADT program i.e., the ADT must offer just the Driving Test, exclusive of any other offerings There is no research or safety basis for allowing an ADT program to “count as” the state Driving Test; not only have ADT programs not proven effective in reducing crashes in the U.S., there is no indication that ADTs would be an effective substitute for a state-administered driving test (See NHTSA Report No. DOT HS 811-609: Examination of Supplemental Driver Training and Online Basic Driver Education) Neither state-certified driving schools nor ADT programs shall not be required to offer the state Driving Test Any person wishing to conduct the Driving Test at either a statecertified driving school or an ADT program must complete a stateapproved Evaluator Training Program, and be certified by the state Ohio could simply use its existing protocol/curriculum for training its existing state-employed examiners- no need to create new standards, rules or training The Driving Test is conducted on public roads, as has successfully been done in Ohio for decades Ohio builds on the “third-party” testing systems successfully used by Michigan, Texas and other states in creating its own model- Ohio can benefit from understanding how other states have successfully integrated “third-party” testing Ohio may also wish to consider limiting the range of fees that any testing entity could charge students for the Driving Test AAA Does Not Support: Supporting or otherwise investing in a “state” curriculum There are plenty of high-quality driver educations available to Ohio, and the state’s efforts toward achieving “a safer Ohio” would be better accomplished in other areas (See the Novice Teen Driver Education and Training Administrative Standards for an abundance of opportunities to enhance driver education) Additionally, AAA recommends that Ohio’s Drive Toward a Safer Ohio initiative be fully informed and guided by the Novice Teen Driver Education and Training Administrative Standards, which should form the basis for any state’s effort to enhance the delivery of quality driver education. These standards can be viewed at nhtsa.gov/drivereducationprogram. Lastly, AAA recommends that Ohio conduct a state-wide Peer Review State Assessment, as has been done by other states pursing a stronger driver education program. Coordinated by NHTSA, state assessments are invaluable in improving driver education, and have been conducted by MD, OR, VT, ND, KS, DE and others (See nhtsa.gov/drivereducationprogram for more information and review State Assessments). AAA remains fully supportive of Ohio’s efforts to improve teen driving safety, and would be happy to answer any questions or provide additional information at the state’s request. Respectfully submitted, Mike Morgan On behalf of the Ohio Conference of AAA Clubs