Written evidence submitted by Guide Dogs for the
Blind Association (ESF0023)

About Guide Dogs

Guide Dogs provides services that support the independence of people with sight loss in the UK. Alongside our services, we campaign to remove barriers that prevent blind and partially sighted people living their lives as they choose. Current estimates suggest over two million people with sight loss are living in the UK, of which around 360,000 are registered as blind or partially sighted.

Summary

Guide Dogs welcomes the Transport Select Committee revisiting the topic of e-scooters. In 2020 as the e-scooter trials were beginning, Guide Dogs conducted focus groups with blind and partially sighted people, including guide dog owners and long cane users, to discuss how e-scooters impact them. Since then, the popularity and use of e-scooters, both rental and private, has increased and we have continued to hear about the problems people with sight loss have experienced with e-scooters.

This submission includes research from Guide Dogs and the experiences of people with sight loss.

Guide Dogs calls on the Government to introduce:

• Mandatory docked parking for rental e-scooters so they do not obstruct pavements.
• Strict caps on speed, weight and power of e-scooters to make them safer for riders, pedestrians and other road users.
• A coherent and consistent approach to police enforcement on anti-social e-scooter use.
• A public information campaign on the legality of e-scooters so everyone understands the law.

Impact of e-scooters on people with sight loss

This submission focusses on the impact e-scooters are having on the lives of people with sight loss. However, we are also aware that the impact is not limited to this group. There are numerous reports on the problem caused by anti-social e-scooter use, with reports of them causing difficulties for wheelchair users, children and older people.

Research carried out on behalf of Guide dogs in January and February 2022 by Insight Angels found that anti-social e-scooter use is already having a negative impact on people with sight loss. Of people who had encountered an e-scooter:

• Almost 75% had already had a negative experience.
• 12% reported their guide dog had been disturbed, and another 12% said their mobility aid or cane had been hit by an e-scooter.
• Half of people with sight loss who encountered an e-scooter reported changing their behaviour as a result. Respondents reported feeling less safe, changing their routes, avoiding parts of town and cities and using public transport rather than walking to avoid e-scooters[1].

Guide Dog owner, Scott, and his guide dog, Milo, were hit by a private e-scooter being ridden on the pavement last year.

Scott said: “I am more anxious about going out on my own now, especially in city centres. I wouldn’t think twice about it before, but now I am constantly wondering what is around the corner. What if they are blocking the pavement? What if they hit me? I should be able to go anywhere with my guide dog Milo, but I can’t.”

The Department for Transport asked NatCen Social Research and Arup to conduct research and evaluate the e-scooter rental trials taking place in England. We welcome the evaluation report that was published in December 2022, following delays. However, we were disappointed that NatCen did not provide an accessible online survey for people using screen readers. We also don’t feel that NatCen took our feedback on board. This likely excluded people with sight loss and their views and experiences from the evaluation process.

Impact of e-scooters on working guide dogs

In recent months, guide dog trainers have been increasingly encountering problems with trainee and working guide dogs who are fearful of e-scooters after having negative experiences. We are looking at ways of adapting our training to mitigate this, but the unpredictability and frequent dangerous driving of e-scooters make this challenging.

Rental v private e-scooters

In July 2020, the Government launched rental e-scooter trials in 31 regions across England to “support a ‘green’ restart of local travel and help mitigate reduced public transport capacity”[2]. The trials were due to end on November 2021, but have now been extended to May 2024 with some local authorities withdrawing from the scheme before that deadline.

There are an estimated 23,000 rental e-scooters across England. But there are a further estimated 1.3 million privately owned e-scooters that have been imported into the UK since 2019[3]. While it is illegal to use a privately-owned e-scooter on public land without the permission of the landowner, private e-scooter use has become widespread, and enforcement against their use is very limited in most areas.

The existence of the trials of rental e-scooters has undoubtedly had a direct link to the dramatic escalation in the ownership and use of private e-scooters, and confusion around the law on e-scooters generally. Indeed, a recent survey commissioned by Guide Dogs found that when shown four statements[4] about the laws around e-scooters and asked to select the correct one, nearly two-thirds of these people (64%) got the answer wrong or said that they did not know the law around e-scooters. Even in areas where e-scooter trials exist, over half of people (55%) who have seen e-scooters in the last six months, still don’t know the correct law on e-scooters when shown the four statements[5].

Similarly, we are concerned that the Government are treating private and rental e-scooters as separate entities, whilst at the same time creating policies for private e-scooters from the evidence base of the rental trails. This is causing more confusion about the difference between rental and private e-scooters. For example, the “national evaluation of e-scooter trials findings report” by NatCen does not consider private e-scooters and therefore only provides part of the picture. Meanwhile, the e-scooter trial guidance on the Government’s webpage on e-scooters says, “the primary aim of the evaluation is to build robust evidence about the safety, benefits, public perceptions and wider impacts of e-scooters to inform legal changes that may be necessary after the trial period ends.”[6]

The majority of issues with e-scooters encompass both rental and private e-scooters and therefore any current or future evaluation of e-scooters should include both. We believe that private and rental e-scooters should be considered together and if legislation rules one thing for rental e-scooters (e.g. maximum weight, speed and power) then that should also apply to e-scooters being sold on the private market.

E-scooter trials have only been conducted in England. But it is our understanding that the Government intends to legalise private e-scooters in Scotland, Wales and Northern Ireland on the basis of trials that happened in England only. We are also concerned that the level of conversations with devolved Governments have been lacking[7].

Trials

Guide Dogs has been working with central government, the police, local authorities and with e-scooter operators to encourage responsible rider behaviour in e-scooter trial areas.

Since the introduction of the trials, we have experienced varied levels of activity in different trial areas. Some trial areas, such as the West of England Combined Authority, Taunton, Essex, the West Midlands and Gloucestershire, established regular stakeholder groups. These groups gave us the opportunity to provide feedback on the experiences of local people with sight loss. Working with other sight loss organisations, we have also arranged awareness events for e-scooter operators, councillors and council officers in some of these areas. In other trial areas engagement has been sporadic. We are disappointed that there has not been a consistent approach taken in many trial areas to engage with stakeholders on a regular basis.

Similarly, operators have responded to the substance of our asks with varying degrees of positivity. For example, some operators were receptive to our position that parking bays are required, whereas others have dismissed this out of hand.

In the event that rental schemes are permitted on a permanent basis, there should be a clear requirement for the operators to meaningfully engage with local communities and share data on their performance.

Safety

Guide Dogs continues to have concerns about the safety of e-scooters. These concerns are detailed below. We urge the Government to take action to resolve all of these concerns, as fixing just one won’t solve the issue of e-scooters.

Weight, power and speed of e-scooters

Research carried out on behalf of Guide Dogs in January and February 2022 by research consultancy Insight Angels found that 74% of respondents were concerned at the speed of e-scooters and 50% reported concern about the weight and power of e-scooters.

The maximum speed of trial e-scooters is 15.5mph, the same limit as e-bikes, but higher than the maximum speed for e-scooters set in other major European countries.

The power and weight permitted on the trial rental e-scooter schemes is also significantly higher than bicycles or e-bikes, which increases the risk to pedestrians, particularly people with sight loss. The maximum power, which affects acceleration, is double that of e-bikes, and the maximum weight of 55kg is almost three times the average weight of a standard e-bike. The combined effect of higher speed, power and weight means that these vehicles are significantly more dangerous in a collision.

In 2021, Guide Dogs commissioned research from UTAC, a leading crash test provider, to undertake an independent study on the impact of e-scooters. UTAC simulated a crash involving an e-scooter and its driver, colliding with a pedestrian at 15.5mph – the maximum speed of a rental e-scooter. This showed the initial impact could cause moderate injury such as lacerations or major bruising. If the pedestrian hit their head on the floor as a result of the collision, the injuries sustained were highly likely to be fatal. In addition, UTAC simulated an accident involving a pedestrian the same size and weight as a three-year-old child. Upon impact, the child travelled more than 21 feet (more than 6 times its body length) as a result of the impact.

We know however that many private e-scooters exceed these speed limits considerably. E-scooters that can reach speeds of 35 to 50mph are readily available in shops and online, and it is possible to purchase e-scooters that reach speeds of up to 68mph[8].

According to a survey by One Poll conducted for Guide Dogs[9], the average speed private e-scooter riders admit to driving at is over 16 mph. Nearly a third (31%) admitted to driving at speeds higher than 21mph.

At these increased speeds, it is possible that serious injury can be caused to riders and other road and pavement users. Guide Dogs is aware of and concerned by the number of deaths attributed to e-scooters, and expects the Government figure of 12 deaths related to e-scooter accidents in year ending June 2022 is a conservative estimate[10].

There have been numerous media headlines about e-scooters, including a four year old child being hit by an e-scooter that was riding on the pavement[11]; an e-scooter rider dragging a pram behind them on an A road[12]; and collisions with other vehicles such as trams[13], cars[14] and buses[15]. The safety of e-scooters and their interaction with other vehicles and pedestrians must be improved.

We were disappointed that the Department for Transport raised the proposed caps on weight, power and speed to a higher level than those initially proposed. We recommend that the limits on weight, power and speed be reviewed for both rental and private e-scooters, in light of the Government’s plans to legalise e-scooters.

Pavement riding

The principal concern about e-scooters for people with sight loss in 2022 were around pavement ridership and the potential for a collision (both at 82% of respondents)[16].

The characteristics of e-scooters previously mentioned, combined with the fact they are often driven on pavements, means they have had severe consequences for people with sight loss, including loss of confidence to navigate independently, changing routes and not going to some parts of their local area. We are aware of some guide dog owners, and their guide dog, being injured as a result of a collision with an e-scooter.

Whilst it is currently against the law to ride a private or rental e-scooter on the pavement, a recent survey commissioned by Guide Dogs found that of UK adults who had seen e-scooters in the past six months, almost all (93%) had seen them on the pavement at least some of the time[17]. Enforcement of the law is inconsistent and pavement riding is an unfortunate reality that must be tackled to ensure pedestrians can use the pavement safely.

The Government should introduce a public information campaign on the legality of e-scooters so everyone understands the law.

Blocking pavements

Linked to the issue of pavement riding is rental e-scooters that are parked or abandoned on the pavement, as these add to street clutter, which is often random and unpredictable, making it difficult for people with sight loss to navigate and avoid. 

In 2021, our research found that 81% of people with sight loss said that reducing obstacles on pavements and street clutter was important to improving their quality of life. In terms of priorities, this was one of the highest ranked quality of life issues, alongside an ability to maintain a decent income.

We have worked with rental e-scooter providers to encourage them to move to docked parking, with a detectable kerb of at least 60mm, and not occupy space that would otherwise be for pedestrians. We were also pleased to see recently the West of England Combined Authority require any new rental e-scooter provider use designated parking zones to be on the road, rather than on pavements[18].

If the Government is to legalise and extend rental e-scooters, they must include mandatory docked parking in the legislation to prevent street clutter.

Sound

Many with a vision impairment are reliant on auditory information to understand the environment around them, and to make important decisions such as when to cross the road. The almost silent nature of e-scooters presents a particular challenge and 74% of people with sight loss were concerned at how silent e-scooters are. The level of concern increased to 81% of the sample with a severe visual impairment[19].

We are aware that multiple e-scooter rental trial operators are exploring the feasibility of integrating AVAS into their models. These efforts are welcome, but any system needs to be thoroughly and expertly tested, and needs the support of national government to ensure that the standards are uniform and enforced. Varying AVAS systems could lead to greater confusion, and if there is no requirement for them to be installed and maintained then their benefit will be limited.

While AVAS may prove beneficial to people with sight loss, it will not fundamentally alter the key challenges that e-scooters possess in terms of their speed, power and the prevalence of pavement use.

Enforcement

It is currently illegal to use a privately owned e-scooter on public land without permission from the land owner. However, privately owned e-scooters are prevalent and often used illegally including speeding; double-riding and riding on the pavement. This is dangerous for e-scooter riders and other pavement/road users. Research from Guide Dogs found that a total of 6,321 privately owned e-scooters were confiscated by police in 2021 – an average of 17 a day[20]. That is just a drop in the ocean of the estimated 1.3 million private e-scooters that have been imported to the UK since 2019.

Our research also found that 21 police forces recorded at least 264 e-scooter offences, with offences relating to drink driving or careless or dangerous driving involving an e-scooter[21].

The enforcement of the current laws around e-scooters is inconsistent across police forces. The Department for Transport should work with police forces and introduce a coherent and consistent approach to police enforcement on anti-social e-scooter use.

Legislation

A Transport Bill was featured in the 2022 Queen’s Speech, however has since been delayed. A recent written answer says “The Department intends to create a Low-speed Zero Emission Vehicle (LZEV) category that is independent from the cycle and motor vehicle categories, when parliamentary time allows.”[22] Guide Dogs regrets the delay in legislation and fears that the issue of both rental and private e-scooters being used inappropriately and illegally will continue. That is why we are calling for the Government to introduce a public information campaign on the legality of e-scooters, so everyone understands the law. This information campaign can then be updated when new laws come into force, which we anticipate will be at least another 18 months.

We would welcome information on the scope of any future regulations on e-scooters. For example, there are an estimated 1.3 million privately owned e-scooters in the UK already. Will future regulations, for example speed caps, impact those existing devices and if so, will they be confiscated by police if they are used on public land.

It is our understanding that legislation will impact Scotland and Wales, making private e-scooters legal in those nations, despite no trials taking place there. Guide Dogs urges the Department for Transport to engage with devolved governments and local communities in the nations to get a better understanding of the impact e-scooters could have there.

Recommendations

E-scooters are a common feature on our roads. Trials and a lack of understanding of the current laws has led to an increase in the number of privately owned e-scooters used. If their popularity is to continue, they must be made safe for riders, pedestrians and other road users. Guide Dogs believes that this can only be done by the Government introducing:

• Mandatory docked parking for rental e-scooters, so they do not clutter the pavements.
• Strict caps on speed, weight and power of e-scooters to make them safer for riders, pedestrians and other road users.
• A coherent and consistent approach to police enforcement on anti-social e-scooter use.
• A public information campaign on the legality of e-scooters so everyone understands the law.

March 2023

Endnotes