Written evidence submitted by Lime
Lime is the world’s largest micromobility company. We have operated in the UK since 2018 and provide zero emission dockless, app-accessed, e-scooters and e-bikes in more than 100 cities globally, including in over 40 european cities.
Image 1. Lime’s European Operations
Since 2017, our users have made over 130 million journeys on our e-scooters, saving more than 12,000 tonnes of CO2 whilst helping to reduce congestion and air pollution.
Image 2: Step by step guide to using Lime.
In the UK, Lime operates a fleet of around 2,000 e-bikes in London and Milton Keynes. In just over 18 months, more than 200,000 members of the British public have used our e-bikes to make over 1.4 million journeys.
In future, we look forward to combining our e-bike and e-scooter products to provide users in the UK with two sustainable transport options through one app. We hope that our global acquisition of JUMP - when completed outside the USA - will further help us towards this goal.
At a time when the need for socially distanced transport options is high - and the public are increasingly faced with a limited choice between walking or cycling, and driving, we believe e-scooters will be a valuable addition to the transport mix of Britain’s towns and cities.
As the UK economy emerges from the Coronavirus crisis and people begin to start travelling in increased numbers, the government must guard against a widespread return to private car use as public transport capacity continues to be reduced.
The Department for Transport’s recent announcement of a £2bn package to encourage walking and cycling was a positive step in encouraging more people to travel sustainably. Towns and cities have also taken important steps such as traffic removal from key streets and repurposing street space for wider pavements and improved cycling infrastructure. Alongside these positive policy measures, Lime believes that innovation and private business will play an important role in offering new - more sustainable - ways to travel.
Shared E-scooters are already an established transport option in hundreds of cities across the world. The UK and Ireland remain two of only a handful of countries where their use on public roads is prohibited by law.
The time is now right to review these laws and begin to access the potential of zero emission micro mobility.
We therefore welcome this inquiry into e-scooters and the government’s recent announcement that e-scooter trials will be accelerated - with the first launching as early as this Summer. Lime has already expressed an interest in taking part in trials under the Government’s proposed approach and we look forward to taking an active role in the Committee’s Inquiry.
The remainder of this submission deals with the direct questions posed by the Committee, as well as offering Lime’s view of a future framework for regulation in the UK. In respect of the recent announcement of local authority trials, we also offer a set of outline principles for how these trials could be best designed for success.
We would be pleased to provide supplementary evidence or information to the Committee on any area and would welcome the opportunity to supply additional oral evidence to answer any questions.
Positive benefits of e-scooters
Legalising e-scooter use would bring a number of much needed benefits to the UK. A 2019 report commissioned by the Road Safety Agency in Ireland found that Personal Powered Transporters such as E-scooters “have potential to reduce traffic congestion, improve air quality, and promote active travel.”
In the short term, e-scooters can also deliver much needed additional socially-distanced transport capacity as the UK begins to recover from the Coronavirus pandemic. It is likely that social distancing will be necessary for some time, and whilst this is the case, public transport capacity is likely to remain significantly reduced.
Riding an e-scooter is - like walking and cycling - an inherently socially distanced means of one person travelling and can be used for journeys of a length consistent with peoples’ daily commute. They also provide an important alternative to people who would otherwise be forced to drive their car into a town or city centre.
Lime already offers weekly and monthly rider passes aimed at commuters which offer reduced cost rides when purchased in bulk. These products could quickly be made available in the UK and would provide a viable new alternative to driving to work.
Without new alternatives, it is likely that the UK quickly see increased traffic levels in urban areas. This would rapidly undo progress made in recent years in limiting congestion and reducing levels of harmful local air pollution in cities like London. For towns and cities already struggling with the need to implement Clean Air Zones in coming years, this would cause a significant long term problem.
Evidence of adoption rates from other global cities shows that there is likely to be significant demand for e-scooter use in the UK.
In Paris, shared e-scooters now account for between 0.8% and 1.9% of total trips taken inside of the Cityand Lime estimates that trips taken by our riders replaced more than 1.2 million vehicle journeys between Summer 2018 and Autumn 2019 . This prevented more than 330 tonnes of CO2 from entering the atmosphere and reduced emissions of harmful Nitrogen Dioxide (NOx) and Particulate Matter (PM) from vehicles.
Globally, around 25% of journeys made on a Lime scooter replace a trip that would otherwise have been made in a private car, taxi or minicab/rideshare service.
If these trends are repeated in the UK, e-scooters would have a significantly positive environmental impact.
As an e-scooter is fully electric, and has no gearbox, there are no associated tailpipe emissions and very low levels of particulate pollution from tyres and brake pads. To ensure Lime’s overall environmental impact is as low as possible, our e-bike service centres in the UK are already powered by 100% renewable energy and we use e-cargo bikes to service our operations where possible. We anticipate this being true in future for any Lime e-scooter service.
Beyond environmental impact, shared e-scooter schemes like Lime’s are also a flexible means of increasing transport capacity quickly in key areas. Crucially, this benefit is deliverable at zero cost to local authorities or the taxpayer.
In cities where Lime currently operates shared scooter services, e-scooters are usually subject to stringent regulation and minimum safety standards. Lime’s Generation 3 scooter (shown below) is certified for use across Europe - including in Germany which has some of the most stringent requirements of any country.
Typically, the top speed of the scooter is capped at 12.5mph or 15.5mph and provides a safe, comfortable and reliable riding experience for our users.
Lime’s Generation 3 scooter complies fully with the criteria for definition of an e-scooter presented in the Department for Transport’s consultation on e-scooter trials.
Image 3. Lime’s Generation 3 E-scooter Specification
Five Point Framework for safe e-scooter legislation
Since Lime’s launch in the UK in 2018, we have engaged in a large number of conversations with local authorities, transport bodies, stakeholder groups and central government on the subject of bringing e-scooters to the UK. These conversations showed that there was a clear need for a simple framework around which potential UK legislation could be discussed.
Lime therefore drew on our experience from operating e-scooters in a large number of countries around the world, alongside the latest research on safety and e-scooter usage, to develop a five point framework for UK e-scooter legalisation. This framework was first published in Autumn 2019 and has since been discussed during a series of roundtable events held by Lime in London, Manchester and most recently, online.
Lime believes the following framework would provide sensible and enforceable regulation for private scooters and shared e-scooter schemes both during trials, and in the longer term following any potential wider legislative change.
In busy areas of high pedestrian footfall, virtual or physical areas for parking e-scooters are useful and local authorities should work with operators to implement such zones. To be widely used, parking areas should be provided at a density of no less than 1 per 100m. In quieter residential areas, operators should be encouraged to show preferred parking locations to their users but the need for parking zones is generally reduced given the reduced pressure on street space.
To ensure safety and a high level of management of the scheme, cities should also work with operators to agree automatic GPS controlled ‘no operation zones’, ‘no parking zones’, and ‘‘low speed zones’ where scooters automatically lower their speed to walking pace if a user rides into a pre-defined area.
Suggested principles for UK e-scooter trials
In addition to presenting a potential framework for national legalisation of e-scooters, Lime has also recently been contacted by a number of Local Authorities interested in running e-scooter trials in their local area.
As a result of the welcomed acceleration of e-scooter trials, we know there are many local authorities interested in exploring the potential of e-scooters, but are only just beginning to consider how trials could be designed.
In our view, it is vital that all e-scooter trials are fully open to the general public and have a wide range of use cases. We believe this is the best way to collect useful data that can inform the design of future regulation - and ensure that the public view e-scooters as an exciting, useful and positive new transport mode.
Given the relative urgency of introducing e-scooter trials to help with socially distanced travel, we have developed a set of recommended principles for how local authorities can work closely with operators to design and run successful e-scooter trials. Our hope is that this will result in trials which play an important role in increasing socially-distanced and sustainable transport, whilst collecting useful data for future policy making.
In light of the government’s recent announcement, we believe these principles may be of interest to the Committee.
● Safety: Ensure all e-scooter journeys are safe and do not negatively impact on other users of roads, cycle lanes or pavements. Lime is supportive of the Government’s proposed minimum safety and technical requirements for e-scooters and proposed ban on riding on payments.
To reduce any potential risk or inconvenience for disabled people, or other vulnerable pavement users, from parked scooters local authorities should require operators to engage with groups and advocates representing these communities prior to starting a service.
● Simplicity & availability: For trials to succeed and provide a sustainable basis for scooter operations in future, they must closely replicate commercially-viable market conditions - and be usable by as many members of the public as possible. If trials are only available to small numbers of people, e-scooters are more likely to be seen as negative by those who are unable to use them - which could harm overall public sentiment.
In addition, limited, narrow trials – for example only offering e-scooters between a smaller, specific number of locations or cutting out large areas of operation – would also result in unrepresentative data and will not act as a genuine trial. To avoid this - and ensure broad public support for trials - e-scooters within trials should be publicly available to as many people as possible and positioned to encourage a high number of potential use cases.
● Multi modal options: Local authorities could consider using the opportunity of e-scooter trials to encourage operators to launch sustainable multi modal fleets - including e-bikes - within a single app. This will make low emission transport more accessible and encourage wider adoption of non-car travel as users can choose between e-bikes and e-scooters for different journeys.
● Number of operators and minimum service levels: To ensure a good consumer experience, local authorities could seek to work with a maximum of around three e-scooter operators at any one time. This would allow for consumer choice, without forcing the public to download multiple apps or regularly find their e-scooter app is incompatible with their nearest parked e-scooter.
To ensure a consistent service and sufficient scale, it would be appropriate to require a minimum number of scooters to be offered across a single geography by each operator, for example requiring that each company has at least 200 scooters available in any given area. Alongside this, operators should be required to meet high operational standards on scooter collection, distribution and responding to complaints.
● Geographical Considerations: Scooter trials should serve coherent geographies which can facilitate journeys to and from work, and for leisure. Where necessary, trial areas should transcend local authority boundaries – particularly in cities like London or Manchester where most journeys do not originate and end within a single authority. In most cases, a radial approach to defining trial areas, rather than designating boundaries around specific areas, would likely give e-scooter riders the most easily understood user experience.
● Parking: Parking zones - either virtual or physical - can serve a good purpose in areas of high density. To be widely used, they should be at a density of at least 1 per 100 metres. This is usually only required around busy areas of high footfall, such as around train stations, or busy shopping streets.
● Track Record of Operators: Authorities should prioritise scooter models and operators with the most extensive operational history and experience in operating in locations similar to the UK. As e-scooters are only currently in a trial phase, high levels of public support is crucial. This is most likely to be achieved through experienced operators running high quality trials.
● Data sharing: Under DfT guidance, operators will be required to share data with both the Department and local authorities. Operators and authorities should see this as a positive opportunity to iterate the design of trials once they’re underway. Agreements should be made over how data will help develop the trial over its lifetime prior to launch. For example, weekly data on demand could be used to agree the appropriate number of e-scooters to be deployed on streets by an operator. This could vary between operators and would allow operators to add more scooters to the service in the busiest months to ensure adequate supply and reduce numbers in quieter periods to ensure that high numbers of scooters do not go unused. In a scenario with multiple operators, this could also encourage healthy competition for users.
We are optimistic that trials following these principles will clearly demonstrate the benefits of legalising the e-scooters in the UK and provide a solid evidence base for future legislation.
 TRL, “Review of current practice and safety implications of electric personal mobility devices”, 2019, (https://assets.gov.ie/26565/104b462a29fe421284339210e86ebc73.pdf) p. 35
 6t-Bureau de recherche, 2019, (https://6-t.co/en/free-floating-escooters-france/) p.3
 Lime, “Lime for a Sustainable Paris”, 2019, (https://www.li.me/hubfs/Assets/LIME_ENG_Paris%20Sustainability%20Report_11OCT2019_RGB.pdf) p.4
 Ibid. p.10
 Kevin Fang, Asha Weinstein Agrawal, and Ashley Hooper (2019) How and Where Should I Ride This Thing? “Rules Of The Road” for Personal Transportation Devices. Mineta Transportation Institute Research Report. https://transweb.sjsu.edu/sites/default/files/1713-Fang-Agrawal-Hooper-Rules-Personal-Transportation-Devices_0.pdf p.28