4.3 Behind-the-Wheel Instruction Requirements

Before the Engine Starts

COMAR 11.23.02.34C-D establishes a hard gate:

• §C — a certified school shall conduct behind-the-wheel instruction of the driver education course curriculum only for a student that has a valid learner's permit.
• §D — "An instructor shall verify that the individual receiving the behind-the-wheel instruction has a valid learner's permit prior to providing the instruction."

Verification is a per-lesson duty resting on the instructor personally. An office intake check at enrollment does not satisfy §D, and a permit that expired mid-course ends the lesson. Maryland learner's permits are valid 2 years from issuance, which is long enough that a slow-moving student can genuinely age out mid-program.

COMAR 11.23.02.34F(1) requires the instruction to be conducted in an approved training vehicle as set forth in COMAR 11.23.02.33 — dual brake, dual clutch if manual, reflectors or emergency triangles, instructor mirrors, not more than 8 model years old, inspected annually, and signed.

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Route Documentation (COMAR 11.23.02.34F(2))

Behind-the-wheel instruction shall be conducted on routes that:

• (a) are preplanned, documented, and available at the driver education school office and in the training vehicle for review by the Administration;
• (b) allow a student to practice the concepts taught in the classroom; and
• (c) achieve the objectives of the approved curriculum of instruction.

Two copies, two locations. An MVA compliance officer can ask for the route file at the office or stop the vehicle and ask for it in the car. Improvising a route because traffic looked bad is a regulatory violation, not a judgment call — the school must have a documented alternative.

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Lesson Design (COMAR 11.23.02.34G)

Behind-the-wheel instruction shall:

1. Be based on a written lesson plan with routes that support the concepts and objectives in the approved curriculum;
2. Provide the student an opportunity to operate the training vehicle on a variety of traffic mixes and conditions;
3. Emphasize the knowledge, skills, and behavior needed to safely operate a motor vehicle;
4. Be scheduled in a manner that allows for:
   • (a) debriefing periods during the session for the instructor to review activities and evaluate performance;
   • (b) the student to complete the learning activities in the approved sequence; and
   • (c) the student to complete missed instruction in a reasonable time frame;
5. Include time for remedial and additional instruction as needed;
6. Include evaluation of a student's performance based on the learning objectives in the approved driver education curriculum; and
7. Include documentation of the evaluation results on a form approved by the Administration.

Items 4(a), 6, and 7 convert coaching into a documented assessment. The debrief is not optional courtesy — it is a scheduled element of the session, and its outcome is recorded on an MVA-approved form that becomes part of the student record retained for three years under COMAR 11.23.02.09A(4).

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Session Mechanics

Instructor seat ......... FRONT PASSENGER SEAT at all times  (§K)
Student driving time .... may not exceed 2 hours              (§J)
Rest / meal time ........ not counted toward the 6 hours      (§H)
Observation time ........ not counted toward the 6 hours      (§M)
Completion window ....... 6 hours schedulable within 18 weeks,
                          or longer on request of the student (§I)

§K is absolute: "An instructor shall be seated in the front passenger seat at all times during the behind-the-wheel instruction." The rule exists because every safety device in COMAR 11.23.02.33 — the dual brake, the dual clutch, the instructor mirrors — is engineered for the front right seat. An instructor coaching from the rear seat during a peer-observation drive is out of compliance and out of reach of the auxiliary controls.

§H and §M are the two exclusions that most often shortchange students. A two-hour session with a 20-minute meal break and 45 minutes spent in the back seat watching a classmate drive yields 55 minutes of creditable behind-the-wheel instruction, not two hours.

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Observers (COMAR 11.23.02.34L)

During an enrolled student's behind-the-wheel instruction, only two observers at a time may ride along, and they are limited to:

1. Students enrolled in the program;
2. Approved instructor trainers conducting instructor certification courses;
3. A certified instructor supervising an apprentice instructor;
4. An apprentice instructor;
5. Parents or guardians of students enrolled in the program;
6. A representative of the driving school management involved in a quality assurance function;
7. A representative from the Administration; or
8. An interpreter.

Two limits operate together: a numeric cap of two at a time, and a categorical list. A student's older sibling, a friend, or a prospective customer is not on the list regardless of how many seats are open.

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Coordinating with the Practice Hours

The curriculum guide is explicit that "schools and driver education instructors should ensure coaches know and understand that the six hours of behind the wheel instruction are designed to compliment and refine the 60 hours of practice new drivers are required to complete, not to substitute for them." The most effective use of the in-car lessons is for the instructor to identify a skill and hand the coach a specific refinement target for the practice sessions that follow.

That framing also answers a common parent question: six hours cannot teach a person to drive, and it was never designed to. It is professional instruction layered on top of the supervised practice requirement.

Worked scenario

Case. An instructor schedules a two-hour lesson with two enrolled students, alternating drivers every 30 minutes, and logs one hour of behind-the-wheel credit for each. During the drive the instructor moves to the rear seat so the two students can sit together up front.

Analysis. The hour-for-hour credit is correct — observation time does not count under §M, so each student earns the 60 minutes actually driven. The seating is not. COMAR 11.23.02.34K requires the instructor to be seated in the front passenger seat at all times during behind-the-wheel instruction, which is where the dual brake and the instructor mirrors are. Observers ride in the rear; the instructor does not.