Written evidence submitted by the Brewery Logistics Group
The use of e-scooters in urban areas
Who is the Brewery Logistics Group (BLG)?
The BLG is a trade Association representing the key logistics companies servicing pubs, restaurants and bars in London.
We represent our members through several groups and forums in the Capital and are core members of the Central London Freight Quality Partnership
The BLG is a forum for the interchange of information of mutual interest to all aspects of brewery logistics operations in the Capital, with special emphasis on PCNs, loss of access to the kerbside and importantly our health and safety obligations for all parties when delivering, and cycling matters that are growing by the day and the subsequent congestion and emissions affecting the day to day operations
It currently represents 15 members who can make up to 22500 deliveries per week accounting for approximately 75% of all beer deliveries within the M25
Vehicles up to 10 tonnes account for 30% of deliveries with the remaining 70% being the conventional dray up to 26 tonnes this highlights the fact that whilst the most efficient vehicle is the large dray projects in London regarding cycling and pedestrians are reducing a day’s work thus requiring follow-up deliveries carried out on a smaller vehicle.
This move to smaller type vehicles is driven by a number of factors including the London Lorry Control Scheme, changes to the kerbside and competing with other schemes that all seem to need to be on the kerb, examples being the cycle super highway, cycle stands, charging points etc.
All the above put the delivery vehicles at the kerbside longer than was previously necessary and is affecting productivity in our sector.
This puts the cost of delivering into London to over £100+ per tonnes compared with outside the M25 being at nearer £71 per tonnes
Background to Brewery Logistics requirements
The brewing industry is subject to extensive Health and Safety regulations both on the highway and at the kerbside.
The HSE accept that deliveries and collections are essential to the brewery industry and to the businesses they supply, they also determine that delivering beer can be the most dangerous of activities if guidelines are not followed.
Every delivery point must be risk assessed and documented prior to the first delivery, often the safest time for delivery puts the operator at odds with parking restrictions and residents due to noise.
The HSE are extremely interested in other elements of the delivery procedure such as manual handing, power operated equipment including cellar hoists, working at height and load security, kegs are required to be strapped to the bed of the vehicle before the vehicle can move, hence at every delivery
H&S risk assessment will look at various elements of the delivery procedure
E-scooters and our concerns
The vast majority of work our members undertake is performed at the kerbside following the guidelines as listed above, they also spend an increasingly large amount of time circumventing the highway to get from A to B to make deliveries.
The journey times due to congestion and other factors such as kerbside cycle lanes are increasing causing our members to employ more and more vehicles even though delivery volumes are falling. The cycle lanes can increase delivery times by up to 50% as the delivery teams get their beer barrels across the lanes, in some circumstances they are required to fully close the cycleway for safety reasons, as per our industry code of practice with TfL.
We are concerned for the safety of our delivery teams if e-scooters become the norm and are allowed to use the footway to move around urban areas.
E-scooters can exceed 30mph and could pose a real safety threat to delivery teams working at the kerbside as they move almost silently at speed, they would also be a safety issue for pedestrians and the partially sighted.
If they are allowed to use pavements collisions will be sadly inevitable as it appears that no formal training will be required to ride this motorised vehicle, indeed how will a rider on their very first use of the vehicle know how to use the brakes, or how much they would turn the accelerator etc ?
In the likely event of any incident how would an e-scooter be identified, would they be required to carry a number plate, we believe that riders must be identifiable.
It must be mandatory for any e-scooters user to be covered by motor insurance as with any other motorised road user, they should also be required to pay road tax, all be it at a lower rate.
We also have concerns that maintenance could be an issue and would ask that the safety/service schedules be set by the DfT by the number of hours the scooter has been used, hence some form of meter will need to be fitted.
A standard must also be set for safety clothing with safety helmets and high visibility clothing mandatory.
There must be clear rules around the use and conversion of such vehicles as in other European countries there have been issues where passengers have been carried, and bikes altered to achieve greater speeds.
We need to look at countries where e-scooters have been given the green light and the issues those cities have faced and have due to poor behaviours have had to retrospectively change their rules around usage.
In Denmark since the introduction of e-scooters the increase of riders being stopped on suspicion of drink riding, and subsequently testing positive is presenting a problem, its reported that the problem is more acute later in the evening.
How would DfT legislate for drink riding offences, and would penalties include points on a driving licence where one is held by the rider, or indeed rider bans?
Singapore has banned the riding of e-scooters on pavements after a growing number of accidents involving e-scooters. From the start of 2020 they have been enforcing new laws and those riding a e-scooter on footpaths will be liable for a fine of £1,200 and, or, jail up to three months.
France have also banned electric scooters from its pavements, after locals grew frustrated with the vehicles congesting public areas and causing an increase in accidents.
Many of the complaints in Paris and other cities were aimed at the e-scooters being discarded indescrimitaly after thousands of e-scooters were introduced when several companies started to operate scooter-sharing systems in the capital.
Imagine the same scenario in London, more of the valuable kerbside taken up, e-scooters using the pavement or cycleways etc, all a recipe to increase accidents and injury.
A quote from France's transport minister Elisabeth Borne to Le Parisian newspaper is very telling of the issues we would be introducing to our urban areas should we give e-scooters the green light in the UK, and addresses many of our concerns, she said , "The development of these (scooters) was very rapid and a little anarchic. We didn't see it coming and it became the law of the jungle, and it is true that we are seeing an increase in accidents and but also an increasing sense of unease on our pavements."
Elisabeth Borne announced riders will be fined 135 euros from September 2019 if they use e-scooters on paved areas, she said
"Our main objective is that pedestrians no longer walk the pavements in fear of getting run down," she said, adding that operators were themselves calling for "good practice rules" and for clarifications about how the vehicles could be used.
We must learn the lessons from the cities that have introduced e-scooters, all have had difficulties, Paris is very interesting in terms of their pedestrians feeling a new unease when walking around the city, we are trying in our Urban areas to increase walking as being the healthy options, e-scooters could and given what we know would put people off choosing this mode of transport to move around cities.
So, before the UK takes the same leap into introducing e-scooters to our pavements and streets we need greater legislation to ensure they are safe, that the rider is identifiable both interms of visibility and identity of the rider.
E-scooters should never be allowed on paved areas or anywhere where pedestrians use, including parks etc, they must be subject to the same rules as other drivers of motorised vehicles, Highway Code maintenance periods etc, all laid out in our concerns above.