Written evidence submitted by Sustrans


About Sustrans


Sustrans is the charity making it easier for people to walk and cycle. We connect people and places, create liveable neighbourhoods, transform the school run and deliver a happier, healthier commute.


We are engineers and educators, experts and advocates who work in partnership, bringing people together to find the right solutions. We make the case for walking and cycling by using robust evidence and showing what can be done. We are grounded in communities and believe that grassroots support combined with political leadership drives real change, fast.


We are pleased to respond to the Transport Committee’s call for evidence on e-scooters.


If you require any clarifications or further information on this response, please contact Daniel Gillett, Policy Officer at Sustrans, at


Headlines and Summary


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

Current legislation prevents the use of e-scooters on public roads, including footways. Given the rising sales of e-scooters, legislation can only be considered up to date and appropriate if the Government wishes for their use to remain illegal.


However, if the Government does wish to permit their use, legislation will need to be updated to ensure that they are designed, manufactured and used in a way that ensures the safety of e-scooter users and other road users.


Legislation must consider design standards, governance, and also which locations are most suitable for use; these will be covered in our response.


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

We believe e-scooters have several potential benefits including:


However, e-scooters also present several dis-benefits, which could outweigh their positive benefits if not properly anticipated and managed. These include:



Benefits of e-scooter use on roads

Sustrans recognises that e-scooters can provide an additional way for people to travel and widen consumer choice when it comes to choosing a transport mode.

Firstly, more people using e-scooters has the potential to improve congestion in cities as long as trips replace car journeys. Congestion costs the UK economy billions of pounds annually[1], so easing this is likely to create an economic benefit.

Secondly e-scooters tend not to emit harmful pollutants such as nitrous oxides and particulate matter, which are highly detrimental to local air quality and health, and therefore local air quality benefits may be made if vehicle journeys are replaced and reduced[2].

Finally, although any shift from car use is likely to be small (see data in discussion on risks, below), motorised vehicles are responsible for 99% of fatal collisions on the road[3], while collisions between e-scooters and pedestrians, and e-scooters and cyclists are comparatively very low. Accordingly, any replacement of private vehicles should account for a safer environment for vulnerable road users.

Risks of e-scooter use on roads

Replacing active journeys

Permitting e-scooters on roads will naturally increase the amount of destinations that are accessible to users and their use is likely to grow.

However, we are concerned that a growth in e-scooter trips will replace journeys made by active modes, such as walking and cycling.

Physical inactivity costs the NHS in the UK around £1 billion per year[4], and wider society £7.4 billion[5]. Increasing the number of active trips has the potential to prevent and manage over 20 chronic health conditions by building physical activity into daily activity.

However, evidence from cities where e-scooters are popularly used suggests that public e-scooter schemes have little impact on modal shift away from cars, and even where they do, such as in Portland, the shift away from walking is even greater.

Percentage of survey respondents in different cities who say they would have travelled by the following modes if e-scooters were not available:





Public Transport








Rosslyn, USA[7]













It is feasible to suggest that trips made by personal e-scooters (i.e. those owned by the user, rather than a shared scheme operator) would be even more likely to replace walking trips due to the convenience of door to door travel.

Therefore, Sustrans emphasises that we need to prioritise active forms of travel and do everything we possibly can to enable more people to walk, cycle or use a kick scooter for short journeys in the UK.

More needs to be done if e-scooters are permitted for use in the UK to ensure that, as a mode of transport, they replace driving as opposed to walking and cycling wherever possible.

Environmental impacts

We believe that the lifecycle of e-scooters, their efficiency and their redistribution, if used as part of a shared scheme, needs to be optimised, in order to ensure that their environmental impact is less than any vehicle journeys that they are used to replace.

Regular charging of e-scooters can have a negative environmental impact, as does their manufacture, materials, battery replacement and collection by vehicles if part of a fleet. There is also the environmental impact of vandalised or abandoned vehicles, similar to dockless shared cycle schemes.

Accordingly, we would like to highlight the recommendations from Hollingsworth et al which states that increasing scooter lifetimes, reducing collection and distribution distance, using more efficient vehicles, and less frequent charging strategies can reduce adverse environmental impacts significantly”[9].

Risk of injury to e-scooter users, predominantly through collisions with heavier vehicles such as cars

Just like cycling, there are dangers in sharing road space with other motor vehicles, with those using e-scooters the most likely to be injured in a collision with a vehicle than with a pedestrian or cyclist.

Sustrans believes if cycling and scooting are to become normal, everyday forms of transport for people we must improve infrastructure, and separate cars from people wherever necessary.

To achieve this, we must ensure that roads, streets and public spaces are prioritised as places where people of all ages and all abilities can get around conveniently, confidently and safely without a car.

We advocate the creation of a network of high-quality routes which adhere to the following five principles[10]:


Governance: Street clutter and hazards

We are also concerned that a proliferation of e-scooters could impact on pedestrians or other road users through increased street clutter and trip hazards.

Public concerns have arisen from street clutter from dockless bike schemes. This is exacerbated by multiple scheme providers operating in the same city competing for ridership. This can make space more hazardous and difficult to navigate for people walking, especially disabled people, children, older people and people with buggies.

For example, evidence from a study of e-scooter use in Richmond, USA, showed that 16% of 606 observed e-scooters were not parked properly, and 6% (36 e-scooters) were blocking pedestrian rights of way[11]. Furthermore even those parked ‘properly’ are found on pavement space therefore reducing available space for people. Considering the need for more space for physical distancing during the Covid-19 pandemic, every effort should be being made to increase and not reduce pavement space.

Governance must ensure that the rise of shared e-scooter schemes do not impact on pedestrians. ‘Dockless’ shared schemes must ensure users do not leave e-scooters in the way of people walking and people do not use scooters on pavements.

Supporting inclusivity, equality and social justice

E-scooters must promote inclusivity, equality and social justice for all people. Presently, it is relatively expensive to purchase an e-scooter or subscription, and services tend to be clustered in central areas, meaning that people living in more deprived or outer areas are unlikely to benefit from their proliferation.

People from more deprived social-economic background are more likely to live further away from high-quality services and transport infrastructure, and their transport choice is likely to be worse. In addition, more deprived communities suffer more from local air pollution, road safety and physical inactivity[12]. Sustrans therefore strongly supports models of e-scooter that offer genuine transport choice for everyone not just those that can afford it or live in wealthier neighbourhoods.

Shared cycle and e-scooter schemes often target urban or city centre journeys and richer areas. Schemes run in partnership with the local authority are often far cheaper than the cost of a car or the use of public transport. However, some schemes can also be potentially prohibitively expensive for many users. Schemes run for profit without public subsidy are unlikely to reduce transport inequality in cities, and may not even be financially sustainable.


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

On roads

We believe that if limited to 20kph (12.4mph), e-scooters should be permitted for use on roads.

As some e-scooters are, comparatively, less stable than cycles due to a higher centre of gravity and fewer contact points, they are more likely to pose a risk to the user and to other road users if used on the road, and so we believe that a lower maximum speed than e-cycles (that have a max speed of 25kph) is appropriate.


Cycle lanes and cycle tracks

We would support the use of e-scooters that are limited to 20kph (12.4mph) on cycle infrastructure, and which allow the user to slow quickly and make emergency stops.

If they are not properly designed and speed limited, the use of e-scooters on cycling infrastructure could potentially increase the risk of collision and injuries for both people cycling and people using e-scooters.

For example, failing to introduce maximum speeds for e-scooters could result in a mismatch in speed between cycles and e-scooters, potentially increasing the risk of collision.

Similarly, if e-scooter users are unable to maintain stability and control of their vehicle or cannot slow quickly or make an emergency stop due to compromised stability, this would present a risk to users themselves, along with other road users.

Pavements and footways

When considering the legalisation of e-scooters, the needs and safety of other vulnerable road users must be of paramount consideration. 

Given the speed differential between pedestrians and e-scooters, we do not believe it is appropriate for e-scooters to be permitted to use the footway, except where cycling is already legally permitted. If this is permitted, e-scooters should be limited to 20kph.

Should there be advice or compulsory requirements to use specific safety equipment when using an e-scooter?

We believe that the use of PPE, such as wearing a helmet, should be a personal choice made by the e-scooter user.

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

Safety regulation

When considering permitting e-scooters to be used on the road, the needs and safety of both users and other vulnerable road users, must be considered, for example setting limitations on speed and power.

On the road, e-scooter users are most likely to be injured in a lone fall or in collisions involving heavier vehicles[13], e.g. cars, so any work to introduce standards aimed at permitting e-scooters to use the roads should prioritise the mitigation of these risks.

E-scooters with a motor should always be speed limited to 20kph (12.4mph

We share the suggestions set out by the International Transport Forum’s comprehensive Safe E-scooter research paper[14], which reviews the causes of e-scooter user injuries and outlines the design and safety factors that will need to be explored in order to prevent and mitigate collisions and injuries to users.

Accordingly, when considering introducing standards for a given e-scooter with a view to permit its use on the road, the Select Committee should consider the following aspects of vehicle design:


Environmental regulation


As outlined above, in our summary of the potential disadvantages of e-scooter use, we believe that the lifecycle of e-scooters, their efficiency and their redistribution (if part of a shared scheme) needs to be optimised, in order to ensure that their environmental impact is less than any vehicle journeys that they are used to replace.


What are the experiences of other countries where e-scooters are legal on the roads?

Countries where e-scooters are legal on the roads have experienced problems with street clutter, as outlined above.

There are also reports of pedestrians feeling unsafe after some e-scooter users have ridden on pavements/footways. While there has not been a significant amount of collisions between e-scooter riders and pedestrians reported, their use on pavements increases risk for pedestrians, especially those who may be more vulnerable, and can create a perception of danger, which can put people off walking. As outlined above, e-scooters should only be used on pavements which have been designated as shared use cycling routes.

Finally, there have been instances of maximum e-scooter speeds being reduced following their introduction. In Paris, for example, the maximum speed for e-scooters has been lowered to 20kph, which has helped to inform our assertion that this should be the maximum speed in the UK.

June 2020


[1] Inrix, 2018, Congestion Costs U.K. Nearly £8 Billion in 2018

[2] DEFRA, 2019, Clean Air Strategy 2019

[3] Cycling UK, Cycling and Pedestrians Campaigns Briefing 

[4] The Kings Fund, 2014, Making the case for public health interventions

[5] NICE, 2018, Physical Activity and the Environment

[6] 6-t bureau de recherche, 2019, Uses and Users of Free-floating Electric Scooters in France

[7] James, Swiderski et al, 2019, Pedestrians and E-Scooters: An Initial Look at E-Scooter Parking and Perceptions by Riders and Non-Riders, Sustainability, 11(20)

[8] Portland Bureau of Transportation, 2018, 2018 E-scooter Findings Report

[9] Hollingsworth, Copeland and Johnson, 2019, Are e-scooters polluters? The environmental impacts of shared dockless electric scooters, Environmental Research Letters, Volume 14, Number 8

[10] Sustrans, 2019, Our policy position on walking and cycling routes

[11] Hollingsworth, Copeland and Johnson, 2019, Are e-scooters polluters? The environmental impacts of shared dockless electric scooters, Environmental Research Letters, Volume 14, Number 8

[12] European Environment Agency, 2019, More action needed to protect Europe’s most vulnerable citizens from air pollution, noise and extreme temperatures

[13] International Transport Forum, 2020, Safe Micromobility

[14] International Transport Forum, 2020, Safe Micromobility