NotherBen - we haven't dealt with a similar situation - our PE classes in high school are quite the opposite - open to any grade, the only caveat being that seniors register first, juniors next, etc, so freshmen/sophomore students sometimes aren't able to get into a class they want because it's already full. Our schools also give PE waivers for team sports etc or any extracurricular sport that a student participates in with a coach. Very few of the kids I know here take Drivers Ed in school either.
In your situation, I would check to see what district policy is, and I'd probably send an email to the counselor telling them to leave your ds' schedule as is and cc the principal on the email.
Good luck!
polarbear