The Washington Traffic Safety Education Association (WTSEA) P.O. Box 264 Olympia, WA 98507-0264
Sirena Walters PO Box 9027 Olympia, WA 98507
January 22, 2017
Dear Ms. Walters,
Below are WTSEA’s suggestions and comments regarding the proposed rule changes for the Washington Administrative Code (WAC), Chapter 308-108. We wish to submit them in advance of the hearing scheduled for January 26, 2017.
Our interest in these WAC changes are fourfold: 1) Our Constitution states that one of WTSEA’s purposes is “to promote best education and instructional practices in the state’s Traffic Safety Education (TSE) program.” In carrying out that purpose, we state specific objectives:
a. “To support legislation, administrative codes, instructional guidelines, and program management standards which promote safer drivers and roadways and which enhance the quality of Traffic Safety Education.” b. “To assist OSPI and the DOL in the periodic review and update of the Washington State Traffic Safety Education Curriculum Guide and to support other efforts which enhance the statewide TSE program.”
2) We support the recommendations for enhancing Washington’s traffic safety education program made by the NHTSA’s Washington Driver Education Assessment Final Report (WA DE Assessment), which are based on the Novice Teen Driver - Education and Training Administrative Standards (NTDETAS).
3) We support the goals of Target Zero, Washington State’s Strategic Highway Plan, and endorse any reasonable measures that advance us toward achieving that target. These rules potentially can improve our State’s traffic safety education program and we wish to see rules that promote improved quality.
4) Finally, as pending legislation proposes that public schools should come under the DOL’s administration and oversight, then these rules will directly affect our programs. WTSEA thus has great interest in assuring these proposed rules improve quality and adopt the recommendations of NHTSA’s WA DE Assessment.
With that in mind, we have included documented support for our suggestions from the most current standards available from NTDETAS and the American Driver and Traffic Safety Education Association (ADTESA), a key stakeholder in developing the national standards, as well as directly from the WA DE Assessment’s Final Report.
We encourage you to review the references as necessary and will be glad to provide the documents if you do not have copies. They are available on the Legislative page of our website at WTSEA.com.
WTSEA hopes that the timing of this hearing, coming after the WA DE Assessment, affords the DOL with the opportunity to adopt as many of the Final Report recommendations as possible.
In the Novice Teen Driver Education and Training Administrative Standards Strategic Plan, developed by NHTSA and the Association of National Stakeholders in Traffic Safety Education, two crucial challenges are identified: “Initiating and changing State policy for the delivery of DE; and the reluctance of states & administrators to require the Administrative Standards.” This current effort to upgrade the WACs is Washington’s best opportunity to ”change policy for the delivery of DE” and to implement many of the recommended Administrative Standards. Since the WA DE Assessment was initiated and supported by the DOL, WTSEA hopes these challenges will not become roadblocks in the way of Washington’s determined effort to improve the quality of our statewide Traffic Safety Education program, and move us closer to Target Zero.
WTSEA thanks the DOL in advance for your careful consideration of our suggestions to these proposed rules.
We intend to have representatives at the hearing, and will be available for questions and comment as necessary.