WTSEA’s Statement to the DOL regarding the hearing on 1-26-17 for proposed changes to WAC 308-108 and WAC 308-110.
For the record, my name is Alex Hansen, President-elect and Legislative Liaison of the Washington Traffic Safety Education Association.
WTSEA submitted detailed comments and suggestions to you regarding these proposed rules, so we will make brief remarks, and address specific concerns or answer any questions you have for us as necessary during today’s hearing.
WTSEA represents members who teach in both public and commercial driver training schools. We have two interests in these proposed WAC changes. First, we want to advocate for policy and standards that promote a quality Traffic Safety Education in Washington State, including any measure that will move our state closer to the goals of Target Zero. Secondly, as there is legislation pending, HB 1481, which proposes to move public school TSE programs under the oversight of DOL, we are very interested in having a voice in shaping the rules which will affect public school programs. We anticipate that the DOL will testify in favor of HB 1481, as it supported HB 2770 last session.
Last May, the Washington Traffic Safety Commission and the DOL jointly invited NHTSA to assess Washington’s driver education program and to make recommendations for improving our program by complying with the Novice Teen Driver Education and Training Administrative Standards. In NHTSA’s Final Report of the WA Driver Education Assessment, twelve priority recommendations were made, along with several others.
As we reviewed these proposed WAC changes, we noticed several missed opportunities in which the recommendations made in the Final Report have not been implemented. We are more concerned about what is missing in the proposed rules than the rules as written. We understand that this effort to change the WACs began a few years back, prior to the NHTSA Assessment. But, as this hearing is occurring after the Final Report was circulated in July, we are wondering why more of the recommendations are not reflected in this document? WTSEA supports all of the Final Report recommendations and wishes to see them reflected in this set of rules where possible.
At any rate, there has not been a discussion with DOL and any stakeholders, such as the PDSA and WTSEA, to review these proposed WACs in consideration of the Final Report’s recommendations. After we received this newest language in December, WTSEA reviewed the proposed WACs and has submitted suggested changes in policy that could reflect the Final Report recommendations. Where possible, we have provided references to the standards for each policy recommendation we make.
However, as the DOL and the PDSA have not had adequate time to digest and discuss our suggestions, we respectfully request that the brakes be put on to give more time and opportunity for discussion to consider these proposed rules, and to bring them in alignment with NHTSA’s Assessment Final Report recommendations. WTSEA would welcome an invitation to participate in a stakeholder’s group to study these rules further, which is one of the Final Report priority recommendations (1.1.1).
We thank you for the opportunity to share our suggestions, and appreciate your consideration.