Written evidence submitted by the Road Haulage Association Ltd (RHA)


The RHA represent 7,000 members operating around 100,000 lorries in the UK.  These vehicles deliver the food and essential goods we all depend upon every day. The majority of these deliveries are to business premises in urban areas, where the majority of two wheeled traffic operates.


We would like to thank the Transport Committee for the opportunity to voice the serious concern our members have expressed about the use of E Scooters.


The committee is calling for written evidence on:



  1. The current legislation forbids the use of e-scooters (and GoPeds, the petrol version of e-scooters) use on public roads and pavements.  The law is clear and straightforward.
  2. The RHA believes the law is up to date and appropriate as we do not believe the case has been made that the use of these vehicles on the roads is safe enough to justify their use.
  3. It is essential that the operation of any new vehicle is understood fully before it is allowed to be used alongside other vehicles already in use.  Understanding the safety for users and non-users is essential.  That work, looking at the UK operating environment, has not been done.
  4. We fear that allowing a new vehicle type, especially one which is used differently from other vehicle types will result in more deaths and injury. It is also worth noting that established alternatives exist.
  5. Given the alternatives, and the likely limited – if any – benefit of e-scooters, we believe the current ban is appropriate.
  6. Gopeds are mechanically powered with 50cc petrol engines. These are defined as Motor Vehicles by definition under the Road Traffic Act and currently need all the legal requirements of a motor cycle; Driving license, insurance, VED, MOT – if more than 3 years old, crash helmet, etc. Riders are also subject to Road Traffic Act legislation for Drug / Drink driving, Reckless / Careless driving and can have their driving license endorsed for non-compliance.
  7. The rules governing all two-wheel users, other than those applying to class DVLA License Category “A” / EU vehicle classification “L” motorcycles, must be reviewed.



  1. We see little or no benefit will arise from the use of e-scooters.
  2. To establish that there would be any benefit will require confirmation about the alternative mode of transport that would have been used.  If the alternative that would be used is walking, cycling or public transport (as is overwhelmingly likely) then there will be no congestion or sustainability benefit at all.
  3. The promoters of e-scooters will need to demonstrate that the alternative mode would have been cars if they wish to make congestion and sustainability claims.



  1. Road space is being significantly reduced in many urban areas, by Local Authority environmental measures. Roads are for all road users and structured long-term thinking must take into account the needs of all road users.
  2. Adding another vehicle type, especially one without credible benefits for congestion and sustainability, into the urban road environment will impact on other road users.   That impact must be carefully and thoroughly understood if we are not going to make roads, overall, more dangerous.
  3. The is a very real physical issue, e-cooters are fitted with small wheels. These are particularly vulnerable to undulating and poorly maintained road surfaces.  Current standards of road maintenance (even roads that are considered suitable for traffic) are incompatible with the safety of e-scooter riders.  We are aware that the London e-Scooter fatality was caused by the rider losing control, having collided with a pothole in the road. 
  4. Pavements are safe sanctuary for pedestrians, these vehicles move quickly and we believe are incompatible with the safety for pedestrians.  We see no road environment where these can be used.



  1. The RHA does not believe e-scooters should be used at all.
  2. We have serious concerns over compliance with road rules (current users are flouting the road rules).
  3. As to safety equipment, we do not believe all the safety equipment we can think of will overcome the problems of use of these on the road.
  4. IF, they were to be allowed on the road e-scooter users should be identifiable.  E-Scooters must be regulated making riders responsible for their actions.
  5. That would require e-scooter identification (a number plate) and riders should have to prove an understanding of the Highway Code .  Training so that riders of these vehicles know their responsibilities to other road users and the risks involved of riding a vehicle with rapid acceleration characteristics. The existing DVSA Theory Test would be a starting point.
  6. There must be a lower age restriction for the use of these vehicles.



  1. All motor vehicles should be required to meet specified safety standards.  This is especially so where we have a new vehicle type that is part toy and part transport.  All major components, brakes, steering, tyres, visibility should form part of any standard.
  2. Maintenance, over time needs to be addressed.  Tyres will wear out along with brake systems and other essential road safety components.
  3. We consider Type Approval should be in place for these vehicles. Braking, suspension and steering systems cannot be compromised. Otherwise toys will be used on roads with other motor vehicles which are tested and are type approved. Not to do so, would be irresponsible.
  4. Electric bicycles already exist, there are recorded cases of speed limiters being disabled, allowing these cycles to travel excessively fast. This puts riders, other road users and pedestrians at risk.  Standards should also be set for E-Bikes too so that non-compliant vehicles can be corrected or removed from the road.
  5. E-Scooters must be restricted in speed so other road users and particularly vulnerable pedestrians can judge speed accurately.
  6. The call for evidence only concerns electrically propelled scooters, there are petrol engine scooters which visually are the same as e-Scooters. Instead of referring to e-Scooters, consideration should be given to Electric Scooters, making it totally clear to those who think the E refers to Environment.
  7. It is mandatory for mechanically propelled vehicles to be fitted with a warning instrument and lights for use at night. The same must apply to e-Scooters.
  8. Some cities in Europe allow e-scooters.  We understand that the experience is mixed with some claiming that urban spaces have been plagued by abandoned scooters cluttering pavements, becoming trip hazards for pedestrians. The committee must investigate this aspect of the use of these in other countries.


June 2020