Written evidence submitted by Bolt

 

I am delighted to enclose Bolt’s submission to the Transport Committee inquiry, ‘e-scooters: pavement nuisance or transport innovation’. Bolt welcomes this inquiry, and would like to request that its UK Manager, Sam Raciti, be called to give evidence in front of the committee when it hosts an oral evidence session in the coming weeks to share experiences of operating rental schemes across Europe.

 

By way of background, Bolt has accelerated the deployment of dockless electric scooters in Madrid, Malaga, Faro, Tallinn, Tartu, Riga, Vilnius, Kaunas, Klaipėda, Warsaw, Krakow and Bratislava. Bolt is proud to have worked in collaboration with regulators and governments to develop sound, evidence based transport policy across the world is excited to participate in trials across the United Kingdom.

 

As stated in our executive summary, this inquiry is now vital; the key mechanism by which MPs can scrutinise the upcoming expanded trial scheme announced by the Department for Transport (DfT) in May 2020. Bolt strongly believes that if regulated poorly, electric scooters do have the potential to become a pavement nuisance. Therefore it is essential the Committee deliberates on the future regulatory framework, which is likely to be considered over the 12 month trial period outlined by the Department to prevent this from occurring. This inquiry and its conclusions will also help to prevent the ‘cliff-edge’ scenario which may occur when trials finish and legislation for longer term legalisation has not been adequately investigated.

 

Bolt looks forward to the forthcoming evidence sessions to discuss this transformative transport policy innovation.


 


 

Bolt response to the Transport Select Committee inquiry ‘Electric scooters: pavement nuisance or transport innovation?’

 

  1. About Bolt

 

Bolt, founded in 2013 in Estonia, is the largest European, multi-modal, transport-on-demand platform; serving more than 30 million users in 35 countries and 150 cities around the world, mainly in Europe and Africa. Bolt is the largest European player in the urban mobility space and operates in ride-hailing, the rental of electric scooters and electric bikes, and the delivery of meals markets. Building on the experience of its first micromobility launch in Paris in 2018, Bolt has accelerated the deployment of dockless electric scooters in 13 cities including Madrid, Malaga, Faro, Tallinn, Riga, Vilnius, Warsaw, Krakow, Bratislava and Stockholm to name but a few. Bolt electric scooters are also expected to be launched in cities across Norway later this year.

 

Bolt has recently introduced a new custom-built electric scooter for extra durability, safety, sustainability and ease-of-use. Bolt owns the whole supply chain, manufacturing and testing, thus being able to control the highest quality of all components. Early evidence indicates that the life-span of the Bolt electric scooter is 36 months, which is well beyond the competition. Bolt’s goal is to ensure each electric scooter lasts up to 10,000 rides. In the UK, Bolt has operated Private Hire in London for a year — offering choice and competition to the established ride-hailing providers in the capital. Bolt has a long history of working in collaboration with regulators and governments to develop sound, evidence based transport policy across the world.

 

Bolt welcomes the Transport Select Committee’s inquiry review; and is keen to contribute to this groundbreaking body of work. This inquiry and the recently announced expansion of trials will ensure the UK captures the benefits of this urban mobility innovation, and remains at its forefront by introducing a modern, flexible regulatory regime for electric scooters in the UK.  Bolt is contributing by providing its expertise gleaned from operating electric scooter schemes across Europe.

 

  1. Executive summary

 

 

  1. Appropriateness of electric scooter legislation

 

Excluding the proposed legislative changes announced by DfT to facilitate trials in the UK[3], the current legislation is no longer appropriate in the UK. Electric scooters are now being taken up at four times the rate of e-bikes and a recent study[4] has shown there are over 20 million users of electric scooters across Europe. In the last two years alone, electric scooters have accumulated over 300 million trips globally in two years, reaching 626 cities across 53 countries. Yet they remain illegal for use in the UK, one of a handful of countries in Europe where this is the case. However, as a Sky News investigation has shown, there were over 1,600 offences recorded relating to their use between 2018 and September 2019[5]. In short, they remain popular, and their illegal use is likely to continue to grow. Bolt firmly believes that an evidence based regulatory framework is the best way of providing safety — by legalising electric scooters and introducing proper standards, requirements and regulation.

 

Electric scooters should be classified and regulated in the same manner as electrically-assisted bicycles. Any technical specifications should refer to the standard DIN EN 15194 “Cycles - Electrically power assisted cycles - EPAC Bicycles” and draft standard EN 17128 “Light motorized vehicles for the transportation of persons and goods and related facilities and not subject to type-approval for on-road use”. Furthermore, the European Union is currently in the process of developing FprEN 17128 ‘Light motorized vehicles for the transportation of persons and goods and related facilities and not subject to type-approval for on-road use”, a standard for personal light electric vehicles (PLEV), safety requirements and test methods. These international standards, both published and in draft status set the international benchmark for safety and quality. Bolt believes the UK should follow these standards when investigating its own requirements.

 

    1. Road Traffic Act 1988

 

Bolt believes that if an electric scooter meets the requirements below, they should be permitted for use subject to certain restrictions:

●      Powered by an electric motor only

●      maximum continuous rated power of the electric motor must not exceed 350 Watts

●      the top speed of the vehicle should be 15.5mph

●      electrical assistance must cut-off when the vehicle reaches 15.5mph

●      has 2 wheels, one front and one rear, aligned along the direction of travel

●      has a mass, excluding the rider, not exceeding 35 kilograms

●      has means of directional control via the use of handlebars

●      has means of controlling the speed via hand controls and its power control defaults to the ‘off’ position

●      Dual braking system, and the inclusion of lights front and back.

An electric scooter which complies with the above should not be considered to be a motor vehicle within the meaning of the ‘Road Traffic Regulation Act 1984’ and the ‘Road Traffic Act 1988’ and as a result, they should not be required to be registered, subject to vehicle excise duty (road tax), or be required to hold motor vehicle insurance or require the use of a driving licence. However, we urge the government to legislate that electric scooters must not be ridden by anyone under the age of 18 years. Bolt believes that exempting electric scooters in this way would be proportionate, by treating electric scooters as similar to EAPCs.

From a safety perspective, Bolt believes it is imperative the standards include a handlebar and for users to keep their hands on the handlebar as much as possible whilst riding. This allows users to give a warning signal, use the brakes quickly, and control manoeuvring easily. Under braking, users will naturally lean on the handlebar. Without this, it is difficult to brake quickly and safely, and the user is likely to fall off. However, Bolt disagrees with the suggestion electric scooters should be required to have indicators. None of the markets in Europe in which Bolt works in across Europe have made them mandatory, and Bolt believes the UK should follow suit. Requiring electric scooters to have indicators could lead to a shortage of electric scooters available, as many would need to be retrofitted.

 

    1. The Highways Act 1835

 

At present, electric scooters are also considered “powered transporters” and are prohibited from using public roads, cycle tracks, cycle lanes on roads, or other spaces dedicated to pedal cycle use only (section 21(1), under the Road Traffic Act 1988) and the Highways Act 1835 (Section 72). Bolt believes both should be amended to allow electric scooters meeting the requirements above to be used on public roads, cycle tracks and paths. This includes shared cycle/pedestrian paths — however the local highway authority should have discretion on their use in these areas.

 

    1. Traffic Signs Regulations and General Directions Act 2016

 

To allow use on roads and cycle laness, the Government should amend the Traffic Signs Regulations and General Directions 2016. With regard to the upcoming trials, local areas hosting trials would also have to update Traffic Regulation Orders to allow electric scooter use in cycle lanes and tracks. Bolt believes that should electric scooters be legalised completely, likely after 12 months, these amendments should remain unchanged or included in primary legislation the Government may wish to introduce.

 

 

    1. Use on pavements

 

Bolt supports the Government’s investigation into whether micromobility vehicles used as mobility aids by people with disabilities be permitted to use the footway. However, Bolt is against the permitting of electric scooters being used on the footway. This would cause a hazard for pedestrians, and particularly for those with disabilities. It would also cause greater congestion on the footway, and be difficult to enforce — taking up valuable time and resources of regulatory authorities.

 

 

 

  1. The extent to which electric scooters have positive benefits

 

    1. Encouraging modal shift away from internal combustion engine vehicles

 

Electric scooters are green-at-point-of-use and lightweight, and journeys by this transport mode will replace many that would otherwise be made by internal combustion engine vehicles, for both commuting and pleasure purposes. This will have a number of advantages for the UK including:

 

i) reducing particle emissions;

ii) easing congestion in cities; and

iii) connecting public transport networks to economic opportunities and homes.

 

Safe Micromobility, a report by OECD/ITF from 2019[6], suggests that micromobility can spur a mode shift from individual cars, taxis and motorcycles, indicating that potentially “two thirds of car trips made by London residents can be cycled in under 20 minutes” (GLA, 2015).[7] Recent data from the European Commission suggests the average trip length of a car journey overlaps with that of electric scooters. Similarly, a study in Chicago shows that where electric scooter hire schemes are not available, 34% of those surveyed would have used a private vehicle.[8] This highlights the potential for electric scooters to cannibalise some of those trips. If true, this may help to reduce carbon emissions from road transport and improve air quality in towns and cities.

 

 

    1. Bolt’s evidence of modal shift in Tallinn, Estonia

 

In Tallinn, Estonia, Bolt operates both ride-hailing services and electric scooter hire on its platform. Data from Bolt’s operations in Tallinn, Estonia (Figure 1) highlights shows that during the electric scooter season in the city, there was a 3% drop in ride-hailing journeys on Bolt’s platform among occasional electric scooter users (3+ journeys) and 5.7% drop in ride-hailing journeys among active electric scooter users (10+ journeys). For short journeys (less than 3 km, Figure 2) the drop is more significant - 5.8% for occasional riders and 8.8% for active riders. In this example, if Bolt were to manage 2000 electric scooters in a city, it could save up to 100.000 ride-hailing rides per year in a city, with a particular emphasis on saving short journeys (3km or less).

 

 

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Figure 1. Relative ride-hailing rides drop in 2019 electric scooter season, Tallinn Estonia

 

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Figure 2. Ride-hailing short rides drop in 2019 electric scooter season, Tallinn, Estonia

 

 

Data obtained from electric scooter sharing companies from Vilnius, Lithuania also shows that the distance for electric scooter rides tends to be 4–5 km with an estimated travel time of between 15 and 20 min. These values will differ from city to city due to factors including population density, but clearly show the value of electric scooters in connecting destinations within cities and the potential for driving modal shift away from ICE vehicles in urban areas.[9]

 

 

 

    1. Environmental benefits of electric scooter use

 

The reduction of ride-hailing trips and private vehicle use may not only reduce congestion, but also has significant environmental benefits. For example, using our hypothetical situation above of managing 2,000 electric scooters operating in a city and saving up to 100,000 ride-hailing journeys per year, Bolt’s analysis shows this would cumulatively prevent the emission of 85 tons of CO2 per year.

 

Operating under the same scenario, electric scooters would also reduce at least 2.5kg in exhaust emissions of PM2.5 and PM10 – both known to be carried deep into the lungs, causing inflammation and increasing the risk of heart attack. In addition, non-exhaust[10] PM, which constitutes 60% (by mass) of PM2.5 and 73% of PM10 of road transport emissions[11][12], would also be cut to zero due to electric scooter use.

 

In order to realise the congestion mitigation and environmental benefits and to further reduce unnecessary car journeys, Bolt will introduce functionality to its platform that when a user requests a ride-hailing trip shorter than 2 miles (more than 25% of our ride-hailing trips), the Bolt mobile app will automatically suggest using an electric scooter instead. Our analysis in Tallinn shows that users are enthusiastic about making this switch without encouragement during the electric scooter season, and therefore Bolt believes it can increase this number by suggesting an electric scooter for shorter trips. Electric scooters are much more efficient for transportation of a single person compared to cars in terms of energy use[13]. That way we can actively accelerate the shift to low emission transport modes. Bolt believes this can be replicated in the UK.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 3 - Example of Bolt’s app highlighting the option to use an electric scooter instead of a private hire vehicle or taxi in Tallinn, Estonia.

 

    1. Support for those who cannot use active travel modes

 

In response to the Covid-19 pandemic and the subsequent reduction in public transport capacity, the Department for Transport announced a £250 million emergency active travel fund[14] in May 2020. The DfT has suggested the money will help encourage more people to choose alternatives to public transport when they need to travel, and commit to strategies which increase the numbers of those cycling and walking in cities and towns.

 

Bolt would like to highlight to the committee that there are a great many people who will be unable to benefit from further investment in active travel and are not able to cycle or walk to work or for leisure. Therefore, electric scooters may be a solution for people experiencing minor physical mobility challenges, giving them an alternative to car use. Some users indeed reported that they would not have walked (8%) or cycled (7%) the last electric scooter trip they made, specifically because of their physical condition. (6t-bureau de recherche, 2019a).[15]

 

There is no evidence as of yet that the physical activity involved in the operation of an electric scooter provides health benefits. However, when car trips are replaced by electric scooters as demonstrated above, electric scooters have the potential to vastly improve community health by removing not only air pollution, but also noise and road danger sources from the streets.

 

  1. Electric scooters use in the urban environment and their impact on other road users, and pedestrians

 

As Bolt has highlighted above, there are a great many people unable to use active travel modes because they are disabled, or wish to but do not feel that facilities are adequate for them. A report by Sustrans has suggested that one third of disabled people in UK cities would like to start cycling[16]. However, whilst electric scooters may provide another mode of transport for them — they must not become a hazard to disabled individuals on the footway; or to other road users and pedestrians. Bolt is keenly aware of the need to identify these risks and provide proportionate controls to mitigate them.

 

    1. Use of electric scooters on the road, cycle lanes & tracks

 

Electric scooter sharing schemes are now widely available in most European countries with the majority of schemes allowing users to ride on both roads and cycle lanes and tracks. Major European cities served by electric scooters include: Madrid, Paris, Barcelona, Berlin, Milan, Rome, and Nice. The speed of electric scooters is broadly similar to that of pedal cycles and their maximum speed would be comparable to electrically-assisted pedal cycles (EAPCs). In addition, electric scooters possess both a handlebar and a physical braking system. As EAPCS are legally able to be ridden on public highways in the UK, and given their similarity — Bolt believes this be applied to electric scooters; provided that electric scooters meet standards outlined by Bolt above in Section 3a.  To ensure their responsible use on the road, Bolt would also urge that electric scooters be considered carriages and therefore subject to the same guidance in the highway code. Namely, that users be encouraged to use cycle routes, advanced stop lines, cycle boxes and toucan crossings unless it is unsafe to do so (rule 61)[17]. Bolt believes that users of electric scooters, as cyclists, are not allowed to cycle on a pavement (rule 64).[18] As with EAPCS, Bolt believes the UK Government should mandate that only electric scooters which are limited in speed to 15.5mph should be permitted on roads, and lower speed roads.

 

Bolt believes electric scooters are now a mature enough vehicle to be used on public roads in the United Kingdom. Their development means they are now the safest micromobility option, because they possess a physical braking system, and a handlebar which allows users to remain balanced whilst riding and under sudden braking.

 

With regard to electric scooters’ safe operation on UK public roads, many electric scooters will be used under the management of hire scheme operators such as Bolt. As a result, the electric scooters will often have better brakes and undergo regular maintenance by experienced Operators. Means they are likely to be tested more often for faults and ensure they are roadworthy at all times.

 

    1. Geofencing technology

 

Bolt is also a keen proponent of geofencing technology — and regularly works in tandem with city authorities to limit the speed or operation of electric scooters in certain ‘geofenced’ areas in the city to keep its users safe. As is the norm in many cities, this means electric scooters can have speed limits imposed or even be prevented from entering certain areas if necessary. Geo-fencing dockless electric scooters to provide safer speed zones in certain parts of the cities (geo-fencing reduces the speed of electric scooter automatically when it enters a certain area) can give city authorities comfort that electric scooters are not being ridden in dangerous areas, or on roads with high speed limits inappropriate for electric scooters such as higher than 30mph, or on flyovers for example.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 4. Example of Bolt’s geofencing technology in Paris, France

 

 

    1. Limitations of UK cycle network

 

Recently, with growing concerns about safety issues, the separation of bicycle lanes from vehicles is now accepted as a measure to reduce incidents involving vehicles and bicycles/ebikes[19]. From a practical point of view much of the existing cycle infrastructure in the UK does not provide for completely segregated cycle lanes. If electric scooters are only permitted on segregated cycle lanes and tracks, then this may significantly reduce the value of electric scooters as a first and last mile solution. Users would be forced to break up their journey multiple times to ensure they stick to designated segregated cycle routes, such as the example in Figure 4, which show the end of designated cycle lanes. In this example, electric scooter users would not be able to make a left or right turn onto the road, due to the end of a designated cycle lane. In many cases, roads may be the only way of reaching a final destination. For example, Figure 5 shows designated cycle lanes in London. Only permitting electric scooters to use these lanes would leave much of London inaccessible to electric scooters.