Written evidence submitted by Go-Ahead Group




Go-Ahead is a leading UK public transport operator, providing high quality services in the bus and rail sectors. We run bus companies across the country, from Plymouth to Newcastle, and a quarter of London’s buses for Transport for London (TfL). Go-Ahead operates a fleet of 5,200 buses, which carry more than two million passengers a day.


We have also led the call for the creation of a National Bus Strategy to revitalise a mode of transport which provides two-thirds of all public transport journeys in the UK. The Government’s stated commitment to a National Bus Strategy and investing in 4,000 new electric buses is now even more vital, and should be part of a green recovery from the Covid 19 pandemic.   


Internationally, we provide bus services in Singapore and Ireland, and rail services in Germany and Norway. Go-Ahead is responsible for nearly 30 per cent of all UK rail journeys through its Govia Thameslink Railway and Southeastern franchises. We employ over 30,000 people.



  1. Introduction


  1. Summary and recommendations


1.1.     Go-Ahead welcomes the TSC inquiry into e-scooters.  The UK’s regulatory framework for transport has not kept pace with changes in technology, and it is important that new forms of mobility are assessed for their benefits and downsides, and regulation is adapted accordingly.


1.2.     Inevitably policy discussion on e-scooters is currently framed within a Covid 19 context and the need for social distancing is particularly affecting the provision of public transport.  Within that context e-scooters could play a valuable complementary role, particularly during the summer months.  However, it is important to ensure that policies continue to embrace the longer term view, particularly recognising the value and necessity of mass transit to enabling high levels of employment in vibrant cities and towns.  Road space will continue to be a scarce resource. 


1.3.     E-scooters could provide a useful contribution to the UK transport mix, if used safely. With regard to public health more generally, e-scooters should not detract from growing the use of active travel.  Encouraging cycling and walking should rightly be a key policy aim both during and beyond the Covid 19 crisis. 


1.4.     Our recommendation is that trials are conducted on e-scooters in a manner that effectively assesses how the safety of all road users can be maintained, how they can complement and not detract from use of active travel, and how they can integrate with wider transport provision


B.              Answers to inquiry areas


  1. whether the legislation for e-scooters is up to date and appropriate; to what extent e-scooters have positive benefits, for instance relating to congestion and promoting more sustainable forms of transport;


2.1.     Current legislation means that e-scooters, along with several other forms of micro-mobility, cannot be used on the road as they cannot comply with the normal legal requirements associated with motor vehicles.


2.2.     It is right that the Government is taking a fresh look at legislation and regulation designed before the advent of micro-mobility to ensure it is fit for purpose.  In doing so, it needs to consider the social, environmental and safety considerations of new forms of mobility and ensure that the overall benefits of regulatory change outweigh the downsides.


2.3.     E-scooters potentially offer new options for economic and social opportunities.  However, their long term value in enhancing transport provision will lie in their ability to replace private car usage, thereby relieving congestion and not reducing the use of active travel for short journeys.  Research undertaken by French mobility consultancy 6-t around e-scooter usage found that 56% of journeys made using e-scooters would otherwise have involved some form of active travel (44% walking, 12% cycling)[1]. 


2.4.     The 6-t research also showed that 30% of journeys would have primarily involved public transport, and only 3% of journeys would have been made by private car[2]Whilst reduced use of public transport is a current policy aim due to Covid 19, moves towards a longer term dependency on e-scooters need to consider further external factors like safety (section 3 of our response), environmental impact, health impact, social inclusion and seasonality.


Environmental impact


2.5.     Information provided by e-scooter leasing company Bird to investors showed scooters were being used between 550 and 650 rides before needing replacement, which is about six months of use, assuming each scooter is ridden about three times per day[3].  With each journey averaging around two miles the total life mileage per scooter will not generally be much above 1,000 miles.


2.6.     Whilst e-scooters offer emission free transport at point of use, they do not have an environmentally friendly life cycle. A study by North Carolina State University found that the environmental impact of charging e-scooters was small relative to the materials and manufacturing burdens of e-scooters and the impacts associated with transporting the scooters to overnight charging stations.  The study concluded that unless scooter lifetimes could be increased, or other change made to collection/distribution and vehicle efficiency, e-scooters would generally lead to a net increase in emissions compared to transport methods being offset[4].


2.7.     For e-scooters to reduce carbon emissions and improve air quality it is important that their use and deployment is focused around ways that replace private car usage.


Public health impact


2.8.     Active travel provides people with health benefits as part of their normal daily routines.  Research commissioned by Go-Ahead showed that bus and train commuters typically accumulate 20-28 minutes of physical activity per day, with associated benefits through increased mental alertness, energy and positive mood, lower risk of depression and dementia[5]. It would be detrimental to public health to inadvertently encourage a shift away from this vital physical activity within people’s daily lives.


Social inclusion


2.9.     E-scooters are inherently inaccessible to children, the elderly, the infirm, many of those with disabilities, and those with baggage beyond a small backpack.


2.10. They also tend to be used by relatively young and wealthy professionals.  The French research of e-scooter users found use in Paris to be by those with a “standard of living” indicator is €2,500 compared to €2,202 for the total Parisian population*).  Cost barriers can affect various modes of transport and are not a reason in themselves to discourage use.  However, there is a need to be careful that policy on e-scooters is not determined by a relatively small but influential section of the community, to the detriment of the greater good of all users of our public spaces.




2.11. A particular characteristic of e-scooter use is seasonal variation, particularly in European cities that have inclement weather and extended hours of darkness in winter. In late 2018, e-scooter use fell by a third at the start of the winter, and e-scooter leasing company Lime admitted they were redistributing scooters to warmer regions[6]. In the quarter worst affected by the 2018/19 winter, Bird’s gross revenue fell to $15 million, down from $25 million the previous quarter[7].


2.12. The seasonality of e-scooter use could lead to revenue abstraction from public transport during the summer months, whilst public transport capacity has to be maintained at normal levels to ensure winter availability when e-scooters are less popular.




2.13. We support the policy view expressed in the DfT’s ‘Future of Transport Regulatory Review’ published March 2020, that, ‘New mobility services must be designed to operate as part of an integrated transport system combining public, private and multiple modes for transport users’[8].


2.14. Whilst the e-scooter trials announced more recently are being fast tracked against a background of advice not to use public transport, the longer term approach to e-scooters should be to view how best they can replace private car use as part of a wider transport policy. To that aim, we recommend that trials be carried out of e-scooter hire at railway stations, and we would look at the potential for stations managed by our train operating companies to participate in such trials.


2.15. Similarly, there could be potential in some locations forsuper shelters at bus stops which provide a charging dock and feed e-scooter use into a core bus route, another concept we would be willing to look at the potential for as part of e-scooter trials.


  1. 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;


3.1.     In considering the best allocation of space it is useful to consider the characteristics of e-scooters compared with ordinary pedal cycles.  E-scooters:


3.2.     Given the potential for conflict with pedestrians, we oppose the permitting of e-scooter use on pavements. Singapore (section 6) banned e-scooters from pavements following a large number of injuries and instances of e-scooters operating at speeds above 20mph.  


3.3.     The potential for pavement clutter and obstruction from e-scooters, particularly if they are dockless hire, is a serious concern.  It could be mitigated through designated parking areas, as is the case in Paris, and through limiting the number of hireable e-scooters allowed in a city, as done in Copenhagen and Los Angeles[9]. A recent e-scooter trial in Wellington, New Zealand resulted in a recommendation to provide e-scooter parking to avoid issues with scooters falling over and blocking pathways[10].


3.4.     In terms of road use, risks (compared with cycles) arise from the users being very low to the ground, often being less visible, and the unpredictable lateral movement presents a challenge to bus drivers and other road users.  The one e-scooter fatality in the UK involved a collision with a lorry at a roundabout in London[11].


3.5.     Consequently, we would propose that any permitted use of e-scooters in the UK is confined as far as possible to segregated cycle routes, given the potential for conflict or accidents with pedestrians on pavements, and the vulnerability of the vehicle type when sharing space with general road traffic.


3.6.     The introduction of e-scooters creates potential hazards to people with disabilities using other forms of transport. Brighton and Hove Buses has had issues where customers (without sight impairments) alighting the City Sightseeing buses on the seafront have been hit by cycles in the adjacent cycle lane.  The company has warned customers with its own signage but in the absence of raised tactile paving on the lanes visibly impaired people are not able to be advised in the same way.


3.7.     Should the use of e-scooters on general roads be permitted, then serious consideration should be given to required safety equipment, as highlighted in the next section of our response.


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


4.1.     Serious consideration should be given to the mandatory requirement to wear helmets if e-scooters are to be permitted on UK roads.  Whilst the French research into e-scooter usage showed that 71% of users would anticipate a decrease in frequency of use in the event of being required to wear a helmet, mandating helmet wearing could directly prevent some injuries and also remind users of the risks involved with e-scooters.


4.2.     A detailed study of 190 e-scooter injuries during September-November 2018 carried out by the Austin Public Health Department in Texas, USA, found that of them, nearly half (48%) involved injuries to the head with six persons (3%) having fractures involving the head.  Only one of 190 injured scooter riders was wearing a helmet[12].


4.3.     The wearing of high visibility clothing should be encouraged as with pedal cycling.


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


5.1.     Singapore introduced mandatory registration for e-scooters, following a rising number of safety incidents.  E-scooters are required to meet certain standards for compliance, backed up by an inspection regime (section 6).  The standards cover weight, size, speed and safety standards. The safety standards were specifically brought in to address the problem of fire incidents; the city had more than 90 incidents involving e-scooters and other micro-mobility since 2016


5.2.     Public liability insurance should also be mandatory for e-scooter use, and could be covered within the hire charge.  As well as ensuring recompense for those injured by e-scooter users, this could remind users of the safety risks involved.


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


6.1.     Singapore, a city state in which we operate bus services, has had to adapt its policy on e-scooters as a consequence of accidents taking place.  Many e-scooter users had been choosing to use them on pavements, often out of concern for their own safety in using them on the road.  Further to a number of incidents, the most serious of which was a fatal collision with a pedestrian, and amidst rising public concern[13], the regulations were changed in November 2019 to ban e-scooters from pavements and restrict their usage to the city’s extensive cycling network.


6.2.     The regulations were further tightened in January 2020 to introduce a minimum age limit, an inspection regime and penalties for retailers selling non-compliant devices.  High profile enforcement has been implemented since the ban.  As a consequence many takeaway food deliveries previously carried out by e-scooter have moved to bicycle or e-bikes, encouraged by a government grant scheme which has incentivised the switch.


6.3.     Singapore’s rules for use of e-scooters and other micro-mobility devices are helpfully summarised in the Land Transport Authority’s ‘Rules and Code of Conduct’[14].


6.4.     Safety challenges have been an issue in other countries. In the first three months of operation in Berlin electric scooters caused 74 accidents leading to 16 serious injuries, along with 233 traffic violations and 65 cases of drink driving[15]. Paris has had to take enforcement action against riding and parking on pavements, and more scooter accidents are occurring at night.


6.5.     A study by the University of California San Francisco found that the number of scooter-related injuries and hospital admissions in the U.S. grew by 222 per cent between 2014 and 2018 to more than 39,000 injuries, while the number of hospital admissions increased by 365 per cent to a total of nearly 3,300. The study also found that the rate of scooter accidents increased from six per 100,000 people in 2014 to 19 per 100,000 in 2018.[16]


June 2020





[2] Ibid


[4] Are e-scooters polluters? The environmental impacts of shared dockless electric scooters


[6] ‘Scooter start ups Lime and Bird fly south for the winter’


[8] page 21

[9] Ibid, page 22