I would like to add the following comments for consideration in the 2019 periodic review on the Rules and Regulations on Accident Prevention Courses for Older Drivers (24VAC20-10-40).

           I provide these comments with the following assumption: That the ruling party (DMV) has mandated the current requirement for Virginia residences to attend an 8-hour course every three years for people 55+ to qualify for a saving on their insurance is not based upon statistical  data with supporting documentation dealing with cognitive and or motor skills of such drivers. I stand corrected if such data does supports the reasoning for Virginia’s DMV to be one of the few states (TN,IL,KS,WA) that require people to attend an 8-hour course in-leu of the rest of the countries jurisdictions that require shorter class attendance for the same benefits.

            In correspondence with Mr. Holcomb the commissioner of DMV  “ The current regulations require the course to provide eight-hours of training and shall be divided over at least a two-day period, in order to allow time for better integration and comprehension of safety concepts."  Admittedly as a layman I do not have the research capabilities as a state sponsored organization such as the DMV but I have not found any national safety or insurance documentation  that supports the reasoning to require participants to attend repetitive 8 hour in-depth classroom instructions every 3 years. 

            I concur that an eight-hour course allows for much more interaction but if the goal for this regulation is to improve overall senior driving safety at the state level then the additional allotted time does not enhance this goal.  I personally believe that the review of Courses for Older Drivers (24VAC20-10-40) should consider the reduction of course instructions hours, whether it be an initial eight-hour course and remittal three-year courses being four or six hours in duration (which could result in an administration nightmare) or reducing the training to either four or six-hour classes would not distort the States safety concepts.

            In closing may I give you a snap shot of how the regulation is being administrated: Most of the participants have been driving for over forty-years and have sat under the tutelage  of this exact eight-hour course material two and three times, so to say they are fully engaged in the training would be an extreme overstatement. Participants and instructors take two days at four-hours per day out of their time for  this instruction and some are required to pay tolls to attend these sessions. This scenario portrays the reason that less people and instructors are interested attending or teaching this eight-hour course. 

Yours Truly,

   Garrett Nolen

AARP Safe Driver Instructor

garrett.nolen48@gmail.com