ESC0031

Written evidence submitted by Pure Electric.

Executive summary

• E-scooters have the potential to play a vital and socially beneficial role in the UK’s transport ecosystem. They can help to deliver cleaner, quieter, less congested towns and cities and healthier lifestyles for residents and visitors. They can be a key component in the government’s strategy to deliver on its legally binding commitment on making the UK carbon neutral by 2050.

• E-scooters contribute to social mobility, providing low-cost accessible transport solutions for those who cannot afford to own and run a car or are unable to use a bicycle.

• E-scooters offer an alternative to public transport and where scooters are privately owned, they virtually eliminate any risk of transmission of infectious diseases such as Covid-19.

• E-scooters are as safe as bicycles and for many are a more accessible form of transport.

• E-scooters share many of the use and performance characteristics common to bicycles and should be treated in the same way; they should be used on roads and cycle paths but not pavements.

• The government should develop regulations specifying the approval requirements for the legal use of e-scooters on cycle paths and roads.

• The introduction of e-scooters should incorporate product specification and usage regulations to ensure high safety standards are met.

• E-scooters should be available for private ownership and not just shared on-street rental. The private ownership model opens up the potential for daily commuting and the ‘first and last mile’ journeys.

• Pure Electric has conducted research, including desk-based mathematical modelling and practical tests, on the relationship between power output, rider weight, hill gradient and vehicle speed. Imposing a maximum power output would be potentially dangerous for users.

About Pure Electric

Pure Electric’s mission is to help make journeys more convenient, cheaper and environmentally friendly. Pure Electric is a specialist electric mobility retailer, stocking market-leading ranges of electric scooters, electric bikes and accessories.  

We are driven by our desire to offer the best products, objective buying advice and unrivalled customer service, while making a real, meaningful positive impact on the way we all travel every day. Our goal is to lead a micromobility revolution, benefitting society for generations to come.

Our headquarters are in Glastonbury, Somerset, UK, with physical stores soon to be positioned all over the UK in key cities.

Is legislation on e-scooters up to date and appropriate?

No it is not; existing legislation is in urgent need of comprehensive reform. The combination of the Highway Act 1835 and the Road Traffic Act 1988 mean the use of e-scooters is not currently legal on either public roads or on pavements.

In reality, e-scooters are analogous in their design, performance characteristics and usage to bicycles rather than to motor vehicles and should be similarly accommodated for in legislation.

UK legislation should reflect the reality of vehicle design and usage as it exists today and for the foreseeable future. This means creating a new category of vehicle which encompasses bicycles, electric bicycles and e-scooters, all of which could be designated for legal use on cycle paths, bridle ways and roads.

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

E-scooters offer a number of significant benefits:

• Social
• Environmental
• Health
• Economic

Social benefits

E-scooters promote social mobility. Access to low-cost transport is a critical consideration in social mobility. Low income and disadvantaged households can be prevented from progressing due to poor access to public transport or high car ownership costs, which in turn can inhibit them from seeking out employment, education and training opportunities. Like bicycles, e-scooters are accessible at a cost of under £500; e-scooters are even easier to use than a bicycle. British Heart Foundation research in 2017 showed one in eight in the UK don’t know how to ride a bicycle and one in five hasn’t ridden a bike in more than 10 years.[1]

Scooters provide a low-cost alternative transport solution which could potentially be taken up by those who currently:

• Can’t afford to buy or run a car or can’t access car insurance
• Don’t have ready access to reliable public transport
• Are wary of or unable to ride a bicycle or e-bike
• Live too far from their destinations to be able to walk everywhere

Low cost mobility solutions increase individuals’ potential to take advantage of:

• Employment opportunities
• Education and training
• Social engagement
• Access to healthcare facilities
• Access to fitness opportunities such as swimming pools, gyms and public parks

E-scooters have the potential to be particularly useful for school transport. A large school, with for example over 1,000 pupils would struggle to provide cycle storage if a significant proportion of pupils wanted to travel to school on 2 wheels. By comparison, e-scooters take up less space and would therefore impose less of an infrastructure burden on schools.

The transport infrastructure around many schools has already been adapted to slow traffic and encourage cycling and would therefore be suitable for e-scooter usage.

Low cost mobility solutions help mitigate social inequalities for:

• Women
• Ethnic minorities
• Low income households

The following section is quoted from the report Inequalities in Mobility and Access in the UK Transport System produced by Foresight, The Government Office for Science in March 2019:

• Car owners and main drivers in households are the least mobility constrained across all social groups. They make more trips over longer distance for all journey purposes giving them higher levels of access to activity opportunities;
• Lowest income households have higher levels of non-car ownership, 40% still have no car access – female heads of house, children, young and older people, BMEs and disabled people are concentrated in this quintile;
• In addition, there are considerable affordability issues with car ownership for many low-income households;
• Gender differences in car use are declining, but women are still less likely to be the main driver in households. People with mobility difficulties remain at roughly 38% of households with car ownership, and they travel much less than the average population, but roughly twice the distance of their public transport counterparts.

• Public transport dependent groups in both rural and urban peripheral areas often have difficulties reaching key activities such as work, education and healthcare. For example, over half of the working-age population (57%) live in areas with low public transport access to jobs, i.e. within reach of 45 minutes travel time and 66% (7.8 million) of elderly people cannot reach a hospital within 30 minutes by public transport, with serious implications for a rapidly ageing society such as the UK.
• The 2003 Social Exclusion Unit report identified that two out of five job seekers could not get a job due to a lack of transport, 31% of people without cars could not access a hospital, 16% of households without cars found it difficult to access a supermarket, and 6% of 16- to 18-year-olds turned down training or further education because of travel costs.

People can’t always predict their travel needs, especially if they are on zero hours contracts or their journey routes change frequently. For some, the route to prosperity demands flexibility. Without a car this can be impossible to ever achieve.

A low cost, accessible alternative such as an e-scooter they can keep inside their front door can make all the difference. This is also why the UK should look beyond the current model common abroad of licensing on-street shared rental e-scooters. We should embrace private ownership, where for a few hundred pounds individuals can own a transport solution which gives them freedom to travel; this travel can be either local or in conjunction with public transport and at virtually zero cost.

Environmental benefits

Transport is the largest source of greenhouse gas (GHG) emissions in the UK.

The UK emitted 451 million tonnes of CO2 equivalent in 2018; the single largest contributor to this was transport, accounting for 28% of emissions and within transport, the largest contributor at 55% was cars and taxis[2]. 57% of all car journeys are under 5 miles; and nearly a quarter (24%) are under 2 miles.[3]

In terms of domestic travel in the UK, we take on average around 1,000 journeys a year by all forms of travel, from walking to driving to taking a train. Of these journeys, currently under a third are what could be called environmentally friendly journeys – E-journeys, such as walking or cycling[4].

The legislative accommodation of e-scooters, coupled with a widespread shift towards low environmental impact transport as a social norm, is essential if the UK is to meet its legally binding commitments on GHG emissions. This will not only help to address the climate challenge. It will also lead to cleaner, quieter and less congested cities.

It is also important to note, less than 25% of Particulate Matter air pollution is caused directly by petrol or diesel car tailpipe emissions: 60% of this air pollution is caused by road abrasion (20%), tyre wear (26%) and brake wear (14%).[5] Critically, this means even a wholesale shift to electric cars would not solve all our air quality challenges. The fewer motor vehicles there are in a city, the cleaner it will be.

Health benefits

Cleaner cities are healthier cities. Thanks to cleaner air, E-scooter usage will lead to reductions in a range of health impairments, such as coronary and respiratory illnesses. Users also burn more calories relative to sitting in a motor vehicle, thereby helping mitigate obesity risks and the associated health consequences such as type 2 diabetes.

Reduced car usage leads to fewer pedestrian and cyclist injuries and deaths; the more car usage is reduced, the fewer fatalities and serious accidents there are.

Economic benefits

Lack of social mobility, poor air quality and health problems, congestion and parking constraints can all undermine the UK’s economic performance. E-scooters can help to solve all these issues.

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

E-scooters should be treated in law and used in the same way as bicycles, though subject to additional legislative controls to ensure their speeds are appropriately restricted. They should not be sanctioned for use on pavements. Applying such restrictions would protect other more vulnerable road users such as pedestrians and those with physical impairments.

One of the issues experienced in other jurisdictions around the world has been hire service e-scooters being left in places hazardous to some pedestrians, such as those with visual impairments. The introduction of any e-scooter hire scheme in the UK should therefore be subject to suitable controls regarding docking and storage to ensure they do not become an obstruction or trip hazard.

The UK should also actively embrace and encourage the privately owned solution. Individuals who own their own e-scooter are very unlikely to leave their property lying around on the pavement.

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

E-scooters should be subject to the following use requirements:

1. Helmet use should be encouraged but shouldn’t be mandatory
2. The use of front and rear lights at night should be a legal requirement
3. A Scootability training course, similar to the Bikeability scheme should be developed. Scooter users should be encouraged to take such a course but it should not be mandatory
4. Sections 204 to 225 of the Highway Code should be amended to raise car drivers’ awareness of e-scooter users as vulnerable road users

There is strong opposition to the mandatory use of helmets for cyclists because of the unproven health benefits. Whilst in isolated cases, the wearing of a helmet can protect a user in the event of an accident and reduce the severity of any injuries, there are potential unintended consequences. Where mandatory helmet use has been tested in relation to cycling, it has led to a fall in cycling activity. There is no reason to anticipate a different outcome in relation to e-scooters[6].

Anecdotal evidence suggests people who own their own bicycle or e-scooter and who use them from home are more likely to wear a helmet than those using on-street rentals.

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

E-scooters should be subject to the following regulatory controls:

1. E-scooters should be subject to a manufacturing standards verification and registration system in order to be approved for use on public roads and cycle tracks
2. E-scooters should be sold with a bell or some other form of audible alert mechanism
3. E-scooters should be sold with reflectors
4. E-scooters should have a minimum wheel size of 10 inches
5. E-scooters should have fitted indicators
6. Where an e-scooter has an electric motor fitted, for safety reasons the overall power output should not be restricted
7. The maximum speed should be restricted: For e-bikes, the motor should cut out at 15.5 MPH; for e-scooters, any used on public highways should be speed limited to 15.5 MPH
8. All vehicles must be fitted with an independent mechanical braking system. Manufacturers should be subject to braking distance test verification
9. Any e-scooters made available for hire should be subject to the same design and testing standards
10. All e-scooters should be permitted for use on designated cycle paths and on highways but not pavements
11. The UK government should explore a nationwide insurance scheme for all bicycle, e-bike and e-scooter users. This scheme could indemnify them against third party claims and protect local authorities from pothole related accident claims

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

The United Kingdom is the last major European country where e-scooters are banned. They are also in widespread use elsewhere around the world, in countries including America, Australia and Israel.

Studies in Portland, Oregon, Denver, Colorado and by Lime across several other American cities have shown around a third of e-scooter journeys are replacement car journeys.[7]

Safety

The more people cycle or scoot, the lower the accident rate falls per mile travelled. This is because as their usage is normalised, road users become habituated to them, anticipate their presence and become more experienced at accommodating them safely.

Research studies in Portland Oregon, Austin Texas and British Columbia show accident and injury rates for e-scooters are broadly comparable in their frequency and severity to those for bicycle users.

Whilst the use of scooters causes an understandable concern for the safety of pedestrians this research shows they don’t currently present a significant risk to pedestrians. The government can further mitigate any residual risk by legislating to treat e-scooters the same as bicycles, so they should only be ridden on roads and cycle paths.

Power limits and speed limits

Electric bicycles are currently subject to a power output limit of 250 watts and a speed limit of 15.5 mph. Above this speed, the motor automatically cuts out. However thanks to the rider’s ability to keep pedalling and to propel the bike faster using their muscle power, cyclists still have some control over the speed at which they travel. This is not the case for scooter users, who rely solely on their electric motor.

These limits were imposed by regulation in 2015: The Electrically Assisted Pedal Cycles (Amendment) Regulations 2015 (SI 2015 No. 24).

It makes sense to impose a speed limit on e-scooters, to protect riders and other road users. The nature of their small wheels makes them more susceptible to disruption from variations in the road surface; limiting their speed and imposing a minimum wheel size help mitigate this risk. However limiting power output would pose a risk to users.

On flat ground, a 250 watt limit is fine, however on hills and particularly for heavier users, a power limit would present a significant safety risk.

Our research shows:

A rider weighing 110kgs (in total: they might be lighter, but also carrying a bag) riding a scooter with a 250 watt motor would find their speed dropping to around 9mph on a hill gradient of 5%, while on a hill of 10%, their speed would drop to less than 5mph. Even with a 300 watt motor, on a 10% hill their speed would drop to below 7mph.

If the user is travelling at the time on a road and in traffic with say a 30mph speed limit, they would be exposed to an unacceptable risk.

For a lighter user, weighing 75kgs, the risks are lower however on a 10% hill, they would still find their speed dropping to below 12mph.

We would be happy to share with the Committee more details of our research if this would be helpful.

May 2020