I REFER to the letter from Michael W. H. Cole (Motoring Post, June 18) and wish to respond to the points made by him. Needless for me to emphasise, owing to the high density of traffic on our busy road system, we need high standards of driver training and driving skills. This is reflected in the requirements of driving tests, combined with road safety education and enforcement. While it may be more difficult to obtain a driving licence in Hongkong than in some other places, we need to maintain a sufficiently rigorous regime. With regard to waiting times, our driving examiners have to cope with a large number of applications for driving licences. Because of demand far exceeding supply, it is inevitable that waiting will be required. At present, the average waiting time for private car tests is six to seven months, though there are proposed measures to reduce it to the maximum of six months. Maximilian Cole applied to take his written test on October 30, 1992. He took and passed the test on December 23, 1992, but failed the road test on May 5, 1993. The two months waiting time for the written test and 41/2 months for the road test are within the current normal period for waiting. In the case of the waiting time for the re-test for Mr Cole's son, the appointment date of July 1, 1993, is less than two months since his last test date of May 5. This is also normal for this type of re-testing. Mr Cole considers that the existing driving licence application procedure inflexible. I presume that he referred to our being unable to accede to the request so that his son could take his driving test earlier. I wish to explain that the system of waiting time is equitably applied to all learner drivers. On the other hand, if Mr Maximilian Cole meets all the eligibility criteria for direct issue of a Hongkong driving licence, he may obtain the licence without a test. The eligibility criteria are prescribed in the Road Traffic (Driving Licence) Regulations, Cap 374, of the laws of Hongkong and are reproduced in TD Form 63A/3 which is available in every Transport Department licensing office and district office. Regarding the place of receiving driving instructions and costs, all candidates have a choice of two off-road driving schools operated by the Hongkong School of Motoring, or about 2,000 private driving instructors who give driving instructions on public roads. The driving test syllabus and standards required from students of both the school and private instructors are identical. Mr Cole said he had been ''strongly advised'' to use a particular driving instruction institution. I wish to emphasise that the Transport Department does not give advice on the choice of driving instructors. The costs of driving instructions would depend on the training time required, and the charges collected by the individual instructor(s) concerned, are not set by the Government. With regard to the driving test, Mr Cole said that his son was an ''experienced driver'' whose driving skill was ''well recognised'' by other people. I am afraid this point is irrelevant. If his son does not hold a valid driving licence in Hongkong, he has to take a proper driving test, just like anyone else. His driving skill will then be properly assessed by a qualified driving examiner. Mr Cole also states that the driving test system is biased. This is a broad allegation without any specific support in fact and hence difficult for me to comment, let alone accept. Mr Cole also considered the appointment time of two weeks in attending a complaint interview too long. Mr M. Cole failed the test on May 5 because he committed three serious mistakes (mostly related to road discipline). He lodged a complaint and was interviewed on May 18. Normally, verbal and telephone complaints are handled immediately unless the complaints officer is already engaged. But for appointments for detailed complaints or interviews, and depending on other commitments, a date of about two weeks' time is normally given. This will enable the complaints officer to be better equipped in explaining the problems to the complainant. E S W LEE for Commissioner for Transport