Written evidence submitted by Mr Peter Miller



I have used an electric unicycle regularly for commuting and local errands for nearly years and also have personal experience of eScooters and electric skateboards.


I am responding to this consultation using this wider definition of micro-mobility devices, rather than restricting my answers solely to eScooters, which I understand to refer specifically to devices with two small inline wheels used whilst standing.


Whether the legislation for e-scooters is up to date and appropriate

Clearly the legislation is not appropriate, and currently anyone using one of these devices on UK roads risk prosecutions under a raft of different regulations every time they go out. Micro-mobility devices have however already been legalised in many countries of the world, including many of our nearest neighbours.


I have also spoken to numerous police officers when out and about on my electric unicyle, who have almost always been supportive and encouraging. Messages have ranged from: ‘amazing, how does that work’ through ‘if you are sensible then we will leave you folk alone’ to ‘well, we couldn’t stop it even if we wanted to - there are just far too many of you now’.


On only one occasion recently I was told to not use it and threatened with prosecution if I continued, a week after the YouTube star had been killed using an eScooter in London. I did respect his instruction and have since cut back on my usage. It would however be faired on the police the the justice system, to regularise the position.


To what extent e-scooters have positive benefits, for instance relating to congestion and promoting more sustainable forms of transport

I bought my first electric unicycle out of curiosity and was very surprised that I took to it so well that I became a committed user and advocate for the devices.


In the past two years I have travelled 1,900 miles on the device, mainly in the UK, but also in France, Belgium and The Netherlands.


Key benefits of micro-mobility (as compared to a bicycle, which was my go-to mode of transport prior to purchasing the electric unicycle) are as follows:


Small, neat, clean and portable: My electric unicycle is small and light enough for me to carry it on trains, buses, in the boot or footwell of a car, up stairs, into the office or indoors at home, in a supermarket trolley and in a locker at a gym. It is much a easier in transport than a bicycle, with no oily chains or awkward protrusions to snag on things.


Of the micro-mobility devices in use, the smallest and lightest is the electric skateboard, but their very small wheels do create difficulties on all but the best quality road surfaces (more below).


eScooters are the largest and are more awkward to transport and store, but are far more compact than standard bicycles. eScooters do however make the best devices for use in sharing systems (more below).


Congestion busting: In use the device needs less space even than a bicycle and as such has huge potential to cut city congestion. They are also highly compatible with use of trains, trams and buses. Since the new trains were introduced on the Ipswich to London line space for bicycles is very limited indeed; my electric unicycle however can be stowed behind a seat, on the overhead racks or in the luggage areas of any carriage on the train.


Fast enough: My unit has a maximum speed of 14.5mph and in London I average about 11mph door to door (whilst obeying all traffic regulations) which similar to the average speed when using London Underground. 14.5mph is a slightly less than 25km/h which is the legal limit for these devices in many countries.


14.5mph is also compatible with other users of cycle lanes, it is a bit slower than many cyclists, but not so slow as to feel inappropriate. It is my view however that a slower maximum speed would start to create conflict with cyclists and remove a lot of the benefit of micromobility.


My average of 11 mph is 3 times faster than walking and provides access to more than 10 times the area within the same travel time and (area being 3.14 times the square of the distance). By way of example, in 10 mins I can walk about 0.5 miles and access approximately 0.78 sq miles; using micro-mobility I can travel 1.8 miles and access 10.5 sq miles. This huge difference and similar to the benefit provided by the bicycle in the Victorian period that revolutionised how we travelled, where we lived and worked, and how cities were organised.


But not too fast: 14.5mph is about as fast as I wish to travel on such a device in consideration of the risks to myself and others if I fell. Kinetic energy increases with the square of the speed (0.5 times mass times the square of the speed). As such at 14.5mph my kinetic energy is 3 times that of when I am running, resulting in 3 times the force in a fall. At a speed of 20 mph the kinetic energy doubles again – 6 times more than when running. The risk increases considerably above 25 kh/m without any great benefit in terms of distance travelled.


Sustainable: I have calculated that my unit uses some 30 watt hours of electricity per mile producing 6 grams of CO2 from electricity production. The 1,900 miles I have travelled have therefore consumed about 57kWh of electricity in total at a cost of £8.50 and been responsible for 11kg of CO2 (and no particulates or NOx). This can be compared to 280 kg of CO2 produced by a new car travelling the same distance. As the grid decarbonises the CO2 output will reduce further.


Affordable: The first electric unicycle that I bought new cost me £850 in June 2017. The price of this same unit was later reduced to £650 and is now available new for £450. This compares very favourable with the cost of a folding electric bicycle – the cheapest Brompton folding bicycle which currently costs more than £650 and the cheapest electric version costs £2,800. Prices of micro mobility devices such as these will fall further as production volumes increase as they are inherently simpler and cheaper to produce than folding bicycles.


Reliable: These devices are very simply with very few moving parts and the only maintenance I have had to is to pump the tyre up over the past 1,900 miles and 3 years. My previous unit had travelled 2,800 miles before I bought it, and is still in use by my neighbour now 500 miles later without any maintenance other than inflating the tyre and fixing one puncture. The Lithium Ion batteries seem to last many years of use.


Shareable: eScooters are particularly appropriate for shared on-demand services such as those offered by Lime and Bird. eScooters are the only devices that a new user can ride immediately using only the skills needed to ride a bicycle. Compared to a bicycle, they are simpler and have less to go wrong.


Importantly, they are also much more compact and are easier to transport than bicycles, which is of great significance when the are used for share services during commuting hours where there is a need to transport devices against the tidal flow of commuters. For instance… consider a rack full of devices outside London Bridge station which during the morning commute will soon all have been used to get to the city. A transit van can be used to transport only a small number of bicycles back to the station each trip, but the same vehicle can be used to transport many times that number of eScooters.


Regarding complaints about eScooters being left scattered across pavements, this is indeed an issue that must be addressed, but there are easily envisaged solutions. For instance, one response would to be mandate use of secure docking racks whenever leaving an eScooter within a defined dense urban area. Incidentally, this would also offer the benefit of allowing devices to be recharged via the dock between bookings. I would encourage legislation or local regulation of shared eScooter systems to avoid litter. In less dense areas the more casual storage approach may still be appropriate and acceptable.


Fun: I enjoy using it. Unlike riding a bicycle, which I find stressful, I find it calming. I can’t rush even if I wanted to, and I enjoy floating along. I am well known in the neighbourhood and have had nearly universal positive messages from the people I pass. Children to the local primary school call me ‘the wheel man’ and give me a wave as I go by. Shared eScooter systems have also proved to be very popular with the public. Covid-19 concerns will only increase their popularity as we come out of lock-down.


Effortless: I find it absolutely remarkable that a device with a 500 watt motor can propel a 85kg adult up the steepest hills in Ipswich without any effort at all on my part, and indeed I sometimes overtake cyclists on these hills. Note the motor sizes for electric skateboards seem to have to be larger to achieve the same performance.


Health: The only downside is that I don’t get as much exercise as I used to when I cycled more, however I do still have the option and do still choose to cycle at times. I am also very aware of the risk of falling off, which is why I believe 14.5mph is a sensible maximum speed. I will discuss the risk of colliding with other larger vehicles separately below. In light of the current Covid-19 pandemic, micro mobility is however probably of the best and least risky form of transport for use within a city, especially if otherwise people would be tempted to switch from public transport to private polluting and congesting cars.


All-weather (almost): I use my electric unicycle in the rain as well as when it is dry; it is more of a challenge to stay warm on the coldest days than riding a bicycle due to the lack of physical exercise, but this is not an issues for a 2 mile / 5 minute commute. Rain is less of an issue than on the bicycle because the wheel is fully enclosed with no spray from the wheel. In my office and at home I store the unit on a small rectangular fray that catches any drips and protects the carpet. The only time a unicycle is not a good idea – for obvious reasons – is in icy conditions.


Where in the urban environment e-scooters could be used (e.g. road, pavement, cycle lanes), and how this could impact on other road users and pedestrians, including people who have visual impairments or use mobility aids;


I believe that they should be classed in the same category as bicycles and therefore should only be used on the carriageway, in cycle lanes, cycle tracks and on share-use cycle paths. It should be born in mind that these devices can also be liberating for physically impaired people providing them with greater mobility as well as cause stress for those on foot.


The challenge, of course, is that the roads are often made dangerous to all vulnerable road users – including cyclists, mobility scooter users as well as users of micro-mobility devices –  due to inappropriate use of far larger, heavier and faster motor vehicles.


Many cities are converting large amounts of road-space over the vulnerable road users using the Covid-10 pandemic, and interestingly, some are talking about making these changes permanent. The lock-down has provided a unique and unexpected opportunity to us to experience our cities as we never have done in living memory. We should harness this to ensure that in future our carriageways are safe for cyclists and eScooters, and that our pavements are available to pedestrians (and also free of parked cars as recommended by your other recent inquiry).


One other consideration, is the road surface. These devices have smaller wheels that other road vehicles. My electric unicycle has the largest wheels of devices in the class at 18 inches (some unicycles have larger wheels). eScooters have smaller wheels and electric skateboard have smaller wheels still which is fine only if the road surface is maintained to a high standard.


The times I have been at most risk of injury has been when I have not spotted a road-imperfection in time. We could encourage councils to do reviews of their infrastructure and maintenance regimes to include considerable of eScooters.


Whether there should be advice or compulsory requirements to use specific safety equipment when using an e-scooter;


I always use a helmet and wear gloves. However if you really want micro-mobility users to be safe the focus should be on reducing the danger from larger and heavier vehicles for which a helmet offers little protection.


Please consider the following: Strict speed limit enforcement for motor vehicles; speed limiters for cars (which I understand are coming actually); strict liability (where user of motor vehicles are assumed to be responsible for an injury sustained by a vulnerable road user in a collision unless the motorist can prove otherwise); lower speed limits; and, weight-limits on passenger vehicles used in cities (to reverse the terrible injury toll following the trend towards use of heavy SUVs in cities).


Whether there should be safety and environmental regulation for the build of e-scooters, and what this might entail; and

There is an emerging new CEN product specification for micro-mobility devices: Personal Light Electric Vehicles (CEN - PREN 17128 - Non-approved light motorized vehicles for the transportation of persons and goods and related facilities - Personal light electric vehicles (PLEV) - Safety requirements and test methods). This would appear to be the standard to adopt.


My only comment relating to this standard is that I hope that any performance limits are based on the restricting maximum speed and maximum acceleration rather than restricting motor power as has been suggested. I say that because it is speed that kills and it is acceleration that intimidates and it is better to control these directly rather than indirectly by limiting the motor size that also reduces the utility of the devices for heavier users and for those how live in areas with steep hills. Small motor powers were would limit useage of these devices in some of our biggest cities, including Sheffield. Micromobility devices are uniquely capable of making these vertically challenged cities it should be possible to a100kg adult to buy and use a device that will transport them up a steep hill at a minimum of say 7 mph.


The experience of other countries where e-scooters are legal on the roads.


My experience has been limited, but it my electric unicycle served me well in Brussels to which I was able to travel on Eurostar with my unicycle as hand-luggage.


April 2020