ESC0010
Written evidence submitted by Taur Technologies Ltd
Introduction
- Taur Technologies Ltd is a British-owned engineering company which is in the final stages of developing a stand-on e-scooter. We are headquartered in London at Somerset House and led by a team with decades of experience in the automotive industry and in design and engineering, as well as in micromobility.
- We have a number of UK-based partners and suppliers, and we are actively considering on-shoring all of our manufacturing capability and locating it in the North East of England.
- Our vehicle design is intended for personal ownership and not for the rental market. It includes a number of safety features not seen in rental scooters, including larger diameter wheels, more highly visible rear lighting, and a different rider stance. We also intend to include a number of other innovations and improvements that will enhance the security, storage and rideability of our vehicle. We believe that the Taur e-scooter will be a great British success story.
Why e-scooters should be legalised
- Taur believes strongly that e-scooters are a highly convenient and environmentally friendly transport solution for people wanting to travel relatively short distances in an urban or suburban setting. E-scooters have the potential to replace journeys made by cars and taxis, and ultimately therefore to remove some motor vehicles from the road. The existing trend away from car ownership and use in urban areas would be accelerated while reducing congestion and delays to journeys. Whilst taxis and private hire vehicles have seen some growth, they often face new restrictions due to their environmental impact. Taking motor vehicles off the road will lead to improved air quality, reduced noise, less congestion and lower greenhouse gas emissions. E-scooters will therefore form part of the wider electrification of transport required if the UK is to achieve the 2050 net zero emissions target set by the Government and widely supported by the public.
- E-scooters can also play a role in addressing some of the challenges associated with urban public transport modes such as buses and metro rail. Many passengers consider public transport fares to be expensive; buses can move very slowly due to congestion; and during peak hours all public transport users can face significant problems of overcrowding. Moreover, it would seem reasonable to assume that after the current coronavirus outbreak has subsided passengers will be less willing to travel in close proximity to other people. E-scooters can provide an affordable and convenient way to overcome these issues and relieve pressure on the public transport network.
- The technology can in addition allow people with lesser mobility, as well as those living and working in areas poorly served by public transport, to get around more easily. A genuinely portable e-scooter such as that designed by Taur can be used either for the whole of a journey to and from work, or for travel to a public transport hub to be folded and carried whilst on board, and then used again at the other end. As such, it can easily be integrated with travel on buses, trams and trains, and generally the technology opens up better journey options and greater access to workplaces and other locations.
- Given the benefits associated with e-scooters, it is not surprising that demand for them is high. The evidence for this can be seen in public polling, significant recent increases in the use of bicycles and the growth of cycle rental schemes, as well as in the take-up of other micromobility vehicles such as electric skateboards and e-unicycles, and sales of e-scooters and their use in cities all over the UK. Yet riding e-scooters other than on private land is illegal, so the UK is missing out on the economic, environmental and social benefits they can bring.
- We therefore welcome moves by the Government to legalise this transport mode and allow users in the UK to use e-scooters freely. However, we acknowledge that before they can be introduced to our streets there are safety issues that must be addressed.
Why legalisation should be accompanied by regulation
- Experience from other countries suggests that there are a number of specific safety and other issues associated with e-scooters and other micromobility vehicles. We believe that all of them can be mitigated or overcome through regulations covering vehicle design, where they can be used, and the rental schemes that will inevitably be set up if e-scooters are legalised. It is also worth considering what requirements should be placed on riders.
Vehicle design and requirements to be placed on riders
- Although e-scooters are ridden very safely by many thousands of people around the world every day, a few accidents do occur (particularly to new users, often on rental scooters). These broadly relate to speed, the ability to brake effectively, the evenness of road surfaces and the visibility of riders, particularly in fading light. We believe that all of these can be addressed through regulations set at national level, covering:
- Speed limits: the nature of e-scooter technology means that an automatic upper limit can be placed on the speed of the vehicle. This should be low enough to reduce the risk of accidents occurring, but high enough to enable riders to move at a comparable pace to traffic around them, especially bicycles. Going too slowly can be just as dangerous as travelling too fast. A limit of 25 km per hour (15.5 mph) would be widely accepted, and we urge the Government to require that e-scooters meet this standard.
- Power limits: a related point is to set a total maximum continuous rated power limit for the vehicle. Under the Electrically Assisted Pedal Cycles (Amendment) Regulations 2015, e-bike motors are limited to 250 nominal watts. We agree that the total maximum continuous rated power of e-scooters should also be limited, but note that, unlike an e-bike, an e-scooter has no other source of power than its motor, and vehicle performance is significantly affected by rider weight and size as well as whether the vehicle is going up- or downhill. Given that, as already stated, it is dangerous for an e-scooter rider to travel too slowly in traffic, including on cycleways, we recommend that the total maximum continuous rated power of the motor or motors on an e-scooter should not exceed a maximum of 750 watts.
- Braking: many micromobility vehicles use their motor to slow down the wheels, which is an important element in regenerative braking as well as in controlling speed. However, some e-scooters can only slow themselves in this way, rather than having independent mechanical braking. This leaves them very exposed if the control system or motor fails. We believe that a minimum requirement for all micromobility vehicles should be a form of mechanical braking, and specifically that this should be a hub, disc or caliper brake, not one which is applied directly to the tyre.
- Uneven road surfaces: unless very newly laid, almost every road or cycleway surface has imperfections, whether these are potholes, drain covers, or other sorts of unevenness. A larger wheel size, proper tyres and a robust frame help when riding over such bumps in the road, and the Taur e-scooter has been designed accordingly. As a minimum, we urge the Government to set standards for tyre quality and require that wheels be at least 25 cm (10 inches) in diameter.
- Visibility: it is important that users of micromobility vehicles can be seen clearly by car and bus drivers as well as other road users, and that they are also able to see the road ahead of themselves. It is equally important that users should be able to draw attention to themselves if they need to. We therefore believe that suitably effective rear and front lighting, as well as a horn or sounder, should be a requirement for all e-scooters.
- Questions have been asked about whether e-scooter owners and riders should be required to conform with other requirements placed on some other transport users, such as competency testing and a driver’s licence, an annual vehicle safety check and needing to hold insurance. We believe that this would be unduly burdensome, and that any benefits would be far outweighed by the costs and inconvenience both for owners and riders and for the public authorities, who would presumably have to oversee such regulations. However, our view is informed by our proposal that e-scooters should be speed-limited: if they cannot move faster than a bicycle, we feel confident that they can be treated in the same way when it comes to these matters.
- Similarly, there are suggestions that e-scooter riders should be obliged to wear a helmet. Our view is that, just as with cycling, it would clearly be sensible to wear a helmet but it should not be a requirement to do so – again, provided the vehicle cannot move faster than a bicycle. It is worth noting that e-scooter rental schemes, just like similar bike rental schemes, will find it very hard to operate if helmets are obligatory.
- Another proposal is that there should be a minimum age for riding an e-scooter, given that it is a powered vehicle which could be operated in traffic. In the UK, users of e-bikes have to be at least 14 years old. We support the same requirement for e-scooter users.
- In short, we believe that e-scooters should be regulated in much the same way as electrically-assisted bicycles, with which they share many common characteristics.
Where they can be used
- There is general consensus that e-scooters should not be used routinely amongst pedestrians for two reasons. First, even with a restriction to a relatively low speed, a collision between a person on foot and an e-scooter rider could be dangerous. Second, pedestrians tend to move in less predictable directions than cyclists or motorists, increasing the likelihood of an accident. We would therefore agree that e-scooters should not be permitted on pavements; again, in the same way as cycling is not allowed there.
- Similarly, we believe that e-scooters should be allowed on roads, on cycleways and in areas of shared pedestrian and vehicle traffic. The model, once again, is what applies to bicycles. As with the regulations governing vehicle design and requirements placed on riders, these rules should be laid down at a national level and replicated in Scotland, Wales and Northern Ireland, to avoid any confusion about what is permissible amongst users and those who enforce these requirements.
Licensing e-scooter rental schemes
- As we have said, our e-scooter is not intended for rental. Nevertheless, how that part of the market is regulated is important to us, since it is likely to shape overall attitudes towards the technology. For example, although it is highly unlikely that the owner of a Taur e-scooter would abandon their vehicle in a position that blocks the pavement, public attitudes will be affected if rental scooters end up littering the streets, causing disruption and potentially injury to pedestrians.
- The experience of the United States and elsewhere demonstrates that the unrestricted proliferation of e-scooter dockless rental schemes brings many difficulties and ultimately undermines public support for the technology as a whole. We believe that authorities in the UK will wish to learn from the rest of the world and restrict rental schemes in the following ways:
- Number of operators in an area
- Number of vehicles in an area
- Hours of operation
- Area of operation (utilising so-called geofencing technology)
- Limiting where e-scooters can be left at the end of each journey to prevent clutter
This is not an exhaustive list and other restrictions may be applicable in some locations or at certain times.
- In our view, e-scooter rental schemes should be licenced and regulated at a local level by the relevant city council. Where multiple councils cover a single urban area, for example in London and Manchester, and where a broader transport body exists, such as Transport for London, it would make sense for that entity to be responsible for oversight and regulation.
In summary
- Taur believes strongly in the potential of e-scooters to provide a sustainable and flexible new urban and suburban transport mode, bringing significant environmental, economic and social benefits. They can play an important part of the UK achieving its 2050 new zero target. To do so, however, they must be appropriately regulated. We have set out what we consider to be proportionate and effective proposals for rules to govern all aspects of owning and using e-scooters. We look forward to discussing them with the Government and other stakeholders, and to seeing British-engineered Taur e-scooters on UK roads as soon as possible.
May 2020