Written evidence submitted by the Royal National Institute of Blind People


About RNIB: 

We are the Royal National Institute of Blind People (RNIB), the UK’s leading sight loss charity and the largest community of blind and partially sighted people. Everyday 250 people begin to lose their sight. RNIB has a crucial role to play in creating a world where there are no barriers to people with sight loss. We want society, communities and individuals to see differently about sight loss. 


Blind and partially consistently tell us that barriers to journey-making, including streets and transport, are one of the biggest issues they face. This is why RNIB campaign for the right of blind and partially sighted people to maintain independence and dignity in all journeys. 


Preliminary Evidence: 

In preparation to respond fully to the ‘Future of Transport Regulatory Review’ at the start of May 2020 we launched a travel survey (RNIB, Ongoing) to gather evidence on the views and experiences of blind and partially sighted people on new and developing forms of transport including micromobility. While we have presented some of the findings from this survey so far, it is still live and so the evidence presented in this response is preliminary and incomplete.  


We would welcome the opportunity to provide you with further evidence once our survey has been completed, and to come to present our findings to you in greater detail.


Overview and Summary: 

Blind and partially sighted people tell us that being able to make walking journeys is fundamental to maintaining independence, getting exercise, staying connected with family and community, and accessing work and key services such as healthcare.  


Indeed, 81 per cent of respondents to our travel survey told us that it is important or very important to them to be able to make walking journeys independently, without a sighted guide. 


“As a blind person I cannot drive or cycle and therefore need to walk to get anywhere independently. Even if part of my journey is by bus, I have to walk to and from bus stops.”  


“I don't always want someone to take me where I want to go. I like to maintain some kind of independence for my own sanity.” 


Given the clear importance of walking journeys for blind and partially sighted people, if micromobility vehicles such as e-scooters are legalised, the impact they will have on street accessibility must first be fully understood, and any problems posed must be fully addressed. 


This inquiry response looks at our key concerns around the impact of legalising e-scooters on street accessibility in the following key areas: 

  1. Detectability and danger of collision 
  1. Enforcement of where e-scooters can be used 
  1. Dockless hire of e-scooters 
  1. Speed limit and safety of e-scooters 
  2. Vehicle classification
  3. Trail evaluation and feedback.


1. Detectability and danger of collision

In our current survey, when we asked if anything made it harder or easier to make walking journeys, one of the key themes which consistently came up was the problems caused by silent vehicles.  For example, one respondent said “being unable to hear bicycles/e-scooters/electric cars” made walking journeys harder, while another  told us: “Electric cars have little sound, I stepped into the road and an electric car had to slam on the brakes, I was so upset. These silent killers might be good for the environment, but not for me.” 


As silent vehicles, it is extremely difficult for blind and partially sighted people to detect e-scooters and know they are coming. It may not always be obvious to someone using an e-scooter that they are approaching a pedestrian with sight loss. This increases the risk of collisions.  


The difficulties in these two groups detecting one another make interactions between the two potentially dangerous. This is backed by preliminary results of our survey, which show that there are already challenges with pedal bicycles. People are starting to have a similar experience with e-scooters, as even though they are still illegal, they are beginning to appear on our roads and pavements.  


In our survey, 76 per cent of respondents said that bicycles affected their ability to make walking journeys.  


“Bikes, [which] you can't hear as well as only having limited sight, makes it dangerous as well. I have already had one cyclist run into me.” 


“Bicycles and e-scooters, they make very little sound so that you are unable to hear them coming close to you. I have had a few of them knock me down in the past.” 


“It scares me when I see a bike as I don't know until last minute it's there and where do I move? Most of those people are not wearing high vis clothing either.” 


We therefore have serious concerns about the potential for increasing collisions with blind and partially sighted people, particularly as e-scooters may go faster and be heavier than cycles. 


Many of the comments that people made about bicycles were about them either being used on the pavement, on footpaths and in shared space areas (including bus bypasses). 


“They use pavement as a road. Collisions are frequent, ending with cuts and bruises.” 


“Pavement cycling (even on quiet side streets with no traffic) and cycling without bike lights. I have become scared to go out. Cyclists verbally abuse and threaten me when I challenge them - however politely. Repeated near misses with cyclists build up the fear and trauma I and other disabled people feel” 


“I feel unable to walk along the pavement near my home due to cyclists on the pavement who I cannot see until a moment before they are in front of me” 


“Bicycles overtake on the footpath, and because of my lack of peripheral vision I don't know they are there. I've stepped into a moving bicycle a few times now.” 


“The use of shared space areas is particularly confusing and frightening for blind people. There is no delineation between cyclists and visually impaired people, and we cannot hear when they are approaching. I would choose a walking route that avoided shared space areas if at all possible.” 


“Bike lanes going through pavements at bus stops. Have had some narrow escapes when bikes have appeared while trying to get from [where] you stand to where you actually get on the bus” 


“It could be the end of independent travel for me. It’s hard enough without powered vehicles whizzing around on pavements” 


Given the potentially devastating impact of e-scooters on the ability of blind and partially sighted people to feel confident in making walking journeys and maintaining their independence, it is essential that if e-scooters are to be legalised, their use must be restricted to the road and to cycleways. Under no circumstances must they be allowed on the pavement.  This also highlights the importance of enforcement. As demonstrated by the experiences of pavement cycling outlined above, simply stating certain vehicles are not allowed on pavements is not sufficient to prevent this from happening. How such rules are enforced needs careful consideration if e-scooter trails go ahead. 


In our survey, a number of blind and partially sighted respondents proposed making sure e-scooters were more detectable: 


“Like all electric vehicles there needs to be some form of noise/ alert that they are there” 


“If cyclists and e-scooter riders wear fluorescent jackets or armbands or belts so that visually impaired people who have limited vision can see them that would also help.” 


The Government must consider how we can ensure that e-scooters are detectable to blind and partially sighted people. One option would be to add sound, in line with electric vehicles. This was a suggestion made by many of the respondents to our survey. Example responses were: “All electric vehicles must have a sound”, and “They would need to be heard when approaching”.




As mentioned above, the lack of sound is one of the key problems blind and partially sighted people experience with bicycles, and adding sound would make micromobility vehicles more detectable, and therefore safer, for blind and partially sighted people. 


Moreover, it is our clear position that there needs to be ‘failsafe’ infrastructure in place to keep pedestrians and e-scooters apart. This means: 



2. Enforcement of where e-scooters can be used

If micromobility vehicles like e-scooters are legalised only for use on roads and cycleways, and banned from use on pavements, the issue of how this will be enforced must be fully addressed.  


Cycling on pavements is currently illegal. However, cyclists still ride on pavements, as has been reported by significant numbers of respondents to our survey. Unfortunately, it seems that police and local authorities do not see cycling on pavements as a serious issue, and the offence is often not enforced. If more small vehicles like e-scooters become widely available for use, this problem is likely to be further exacerbated. It is highly likely that people will drive e-scooters on pavements, even if this is illegal to do, unless robust enforcement is put in place to prevent this.  


As explained by a survey respondent:  

“The risk I, and other disabled people, already experience from pavement cyclists and cyclists without bike lights, would be increased 100%. The only way I could deal with this would be to get taxis. I would be prevented from walking and this would affect my health as I would not be able to get any exercise” 


In discussions RNIB has had with the Department for Transport, officials suggested that they may require people wanting to rent an e-scooter to hold a provisional driving licence. We agree that this is a minimum standard needed to provide accountability and enable proper enforcement of safety rules.  


However, it is likely that it will be much harder to regulate where private-use e-scooters are driven than rental e-scooters, which are likely to be fitted with GPS technology. It is therefore imperative that the following recommendations are proactively implemented for private-use e-scooters.


To address the issue of enforcement, if e-scooters are legalised for use on cycleways and roads, the Government should: 


3. Dockless hire of e-scooters

If e-scooters, are legalised for trials and/or long-term use in public spaces, it is very likely they will be adopted for ‘dockless’ hire. Rental dockless bike schemes have caused significant problems for disabled pedestrians because they are often left partly or entirely obstructing pavements. This has caused injury when people with sight loss walk into the bikes and has also forced people out into the road with other fast-moving traffic. Allowing e-scooters to also be rented in this way is likely to further compound this problem, as has been experienced in other countries.   


In our current survey, we asked respondents what, if any, experience they had of dockless bikes.  


A significant number of respondents commented on the hazard and nuisance and danger which dockless bikes present to blind and partially sighted people. For example:  


“Horrendous. Dockless bikes have significantly impacted on my ability to navigate independently around London. I now can't walk the 10 minutes from the train station to work and have to take a bus instead because I was constantly injuring myself on bikes left abandoned on the pavements.” 


“I have encountered one abandoned on a narrow pavement that caused myself and my guide dog to need to walk into a busy road to get around it. I was very nervous that myself and my guide dog would be injured by traffic.” 


Clear and accessible pavements are essential to blind and partially sighted people maintaining their independence in journey-making. Therefore, RNIB believes that in the long-term, all micromobility hire schemes (including bike and e-scooter hire schemes), must have fixed docking stations because of the dangers of physical injury and potential loss of independence presented by dockless hire vehicles. 


Bike hire schemes which use fixed docking stations, such as Santander Cycles, do not present the same problems of obstructing walkways that dockless hire schemes do. This is because:  


Pavements are essential to the active travel of disabled people and to maintain the accessibility of walking journeys docking stations should always have a detectable kerb between the pavement and the station. One way to achieve this is to repurpose part of the road for this purpose, for example by replacing car parking bays.  Where on-road docking is not possible, we think local authorities should work with local disabled people to consider whether a docking station on-pavement is acceptable and make sure adequate room is left on the pavement for pedestrians. 


However, although our position is that in the longer-term, all micromobility hire vehicles should be docked, we recognise that these may not be a viable solution for the purposes of any trial.  


In the circumstances, RNIB believes that in taking steps to legalise e-scooters for trial purposes, the DfT must include statutory/regulatory arrangements for their safe parking and associated guidance. We believe that the safest and most effective parking scheme for the purposes of the trial will be for them to be required to be parked in specified bays on the road. We would also recommend that any scooters not parked in these bays are immediately removed by local authorities enforcement officers on the basis that they have been unlawfully deposited on the pavement and constitute a hazard.


Leaving parking arrangements for rental e-scooters during the trial period (and in the longer-term) solely up to local authorities is likely to result in the arrangement of parked e-scooters varying significantly between areas. Guidance is an opportunity to ensure consistency in operation, and ensure every area avoids some of the potential pitfalls we have identified based on experiences with dockless bikes. 


We believe that a clear national guidance on rental e-scooter parking arrangements, with a statutory/regulatory status is essential. This guidance must:  


If a satisfactory parking arrangement is not implemented for short-term hire e-scooters while on trial, these vehicles, in RNIB’s view, are likely to constitute an unlawful obstruction of the highway. Local authorities taking park in the trial of rental e-scooters could be challenged for failing to take action to keep their highways free from obstruction. 


Given the serious impact which pavement obstructions have on blind and partially sighted people, as well as many others, we expect the DfT to continue to look at whether there are viable docking solutions for both short-term hire bikes and e-scooters. We would be keen to work with Government on this issue.


4. Speed limit and safety:

E-scooters are equipped with a motor that makes them fast-moving vehicles. They are able to go at much greater speeds than pedal bicycles and often weigh much more (DfT and BEIS, 2020). Concerns have been raised about the safety of micromobility vehicles. The Future of Transport Regulation Review Call for Evidence states:  


“A number of deaths have been reported, as well as concerns about the level of hospital admissions relating to e-scooter use, mostly in cities in America. A study of dockless electric scooter-related injuries in Austin, Texas from 2018 showed that the majority of injuries appear to involve the rider falling or losing control, and many riders were not wearing helmets.” (DfT and BEIS, 2020, p.20.) 


The use of e-scooters to date in the UK has already resulted in serious injuries and fatalities. Of particular concern is that injuries caused by e-scooters are not just being sustained by people who are choosing to drive these vehicles, but also pedestrians. The chief of neurosurgery at The Royal London Hospital confirmed that they have treated pedestrians hit by e-scooters, with “similar injury patterns to pedestrians hit by motorbikes” (Lydall, 2020).  


A significant number of the blind and partially sighted people who have so far responded to our survey have raised concerns about the potential speeds of micromobility vehicles. Concerns have particularly focused on how much faster these could go than a pedestrian, and the dangers of mixing street users of such different speeds.  


The difficulties blind and partially sighted people have detecting silent vehicles like e-scooters means the risks of collisions between the two groups is greater. Colliding with a vehicle going at a higher speed brings risk of more serious injury.  


Private-use e-scooters are currently widely available to buy in the UK, from high-street shops and online. The specifications such as speed, weight, and safety, of these vehicles are unknown. This in itself is a cause for concern because even if the Government do bring in restrictions on vehicle specifications, there are potentially thousands of e-scooter vehicles already in private ownership which may not comply with these.


Furthermore, there is the concerning trend of people removing speed restrictors on their private-use e-scooters. One such example can be found here: https://electricscootering.com/remove-limiter-restrictor/, but there are many such websites and videos online. It is imperative that that Government address this issue.


We recommend that maximum speed limits to micromobility vehicles including e-scooters be implemented and guaranteed (tamper-proof). Bearing in mind the experiences and collisions already happening we would recommend the maximum speed limit of e-scooter to be as close to average walking speed as possible (4mph), and certainly no more than 12.5mph. 


5. Vehicle classification

It is the view of RNIB that in the long-term, Government needs to look at classifying e-scooters as motor vehicles, with requirements for insurance, licence and type approval. This is also endorsed by the World Blind Union (2020).


The Government should consider:


6. Trial Evaluation and Feedback

We understand that the DfT are looking to conduct rental e-scooter trials in selected trial areas from the end of June 2020 lasting for 12 months. Introducing any new type of vehicle onto roads and cycleways will inevitably affect all other road users and pedestrians – even if that vehicle is prohibited from pavements. Given the evidence provided above about the significant potential for harm of e-scooters to disabled people such as those with sight loss, it is imperative that local disabled people are consulted about these decisions, and that there is a transparent and accessible process for feeding into the evaluation of these trials during and at the end of the 12 month trial period. 


The Government must:  



As outlined and evidenced above, silent vehicles are extremely difficult for blind and partially sighted people to see or hear, and it may not always be obvious to someone driving a micromobility vehicle that they are approaching a pedestrian with sight loss. This increases the risk of collisions between blind and partially sighted people and silent vehicles.  


The preliminary results of our survey show that this is already a reality with pedal bicycles, and we have serious concerns about the potential for increasing collisions with blind and partially sighted people and micromobility vehicles like e-scooters which may go faster and be heavier than cycles.  


The difficulties in these two groups detecting one another make interactions between the two potentially dangerous. Our recommendations above outline ways in which these schemes could potentially be made safer, but we remain concerned that even if all recommendations above are implemented, micromobility vehicles on our streets pose a threat to the confidence and independence of many blind and partially sighted people making walking journeys.


June 2020



DfT (2005) ‘Inclusive Mobility: Making transport accessible for passengers and pedestrians.’ Available from:  https://www.gov.uk/government/publications/inclusive-mobility (Accessed 01.06.20). 


DfT and BEIS (2020) ‘Future of transport regulatory review: call for evidence on micromobility vehicles, flexible bus services and mobility as a service.’ [online]. Available from: https://www.gov.uk/government/consultations/future-of-transport-regulatory-review-call-for-evidence-on-micromobility-vehicles-flexible-bus-services-and-mobility-as-a-service (Accessed 29.05.20) 


Lydall, R. (2020) ‘New safety alert on e-scooters as injury figures rocket in the US.’  The Evening Standard. [online]. Available from: https://www.standard.co.uk/news/world/new-safety-alert-on-escooters-as-injury-figures-rocket-in-the-us-a4330126.html (Accessed 29.05.20) 


RNIB (Ongoing) ‘Travel Survey’. Unpublished.  


TfL (2019) ‘Transport for London Developer Guidance for Santander Cycles.’ Available from:  

https://tfl.gov.uk/cdn/static/cms/documents/developer-guidance-for-santander-cycles.pdf (Accessed 31 January 2020) 


World Blind Union (2020) ‘World Blind Union Position on Electric Scooters.’ WBU. [online]. Available from:

http://www.worldblindunion.org/English/news/Pages/(WBU)-Position-Statement-on-electric-scooters-(E-Scooters)-and-other-forms-of-micro-mobility-devices.aspx (Accessed 01.06.20).