Written evidence submitted by Transport for Greater Manchester





Transport for Greater Manchester (TfGM) is the public body responsible for co-ordinating transport services across Greater Manchester. TfGM is responsible for delivering the transport policies set by the Greater Manchester Mayor, the Greater Manchester Transport Committee (GMTC) and the Greater Manchester Combined Authority (GMCA) and the 10 Councils.

This response incorporates the views of the ten constituent highways authorities in Greater Manchester.

Do you consider the legislation for e-scooters to be up to date and appropriate?

As with similar highway legislation of this nature, it is our view that the policy does not take into account new and emerging mobility technology and the introduction of ‘smarter’, non-traditional mobility services such as bike-sharing. It is suggested that the legislation needs revisiting to recognise the role e-scooters can play in broadening travel choices, facilitating different types of journey and offering greater flexibility and integration. The COVID-19 pandemic has concentrated this requirement and therefore a review should be prioritised.

Though further work is required to understand the true environmental impact of e-scooters given their charging requirements and high disposal rate, they have the ability to play a key part in our wider priorities of reducing carbon emissions, improving air quality, and helping to reduce congestion, on the assumption that some car users may choose to make a shift to e-scooters for shorter journeys.

However, to ensure that transport/highway authorities are able to maximise the advantages of these new modes, there will need to be effective regulatory tools in place to manage the introduction and use of these modes in a careful manner, learning from valuable experience gained by cities in continental Europe and elsewhere. This should include both defined safety standards and a robust licensing regime which permits authorities to effectively manage the number of operators and units in local areas.

Despite multiple approaches by a number of micro-mobility companies, we have so far been unable to proceed with trials due to the current legislation which forbids their use anywhere on public land.  Trials on private land, such as business parks and universities, have also not been taken forward due to a lack of confidence that they could be managed on the borders between private and public land.  Similarly, we have identified several missed opportunities in deploying e-scooters to support the COVID-19 recovery, due to the lack of legislation or statutory guidance allowing for trials to be run. 

It is also unclear why e-scooter legislation does not match that of Electrically Assisted Pedal Cycles (EAPCs) given their similar speed and types of use.

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

On the proviso that safety standards are defined and attained, there is real potential for e-scooters to offer non-congesting and emission free mobility for use in urban areas where road space is at a premium. E-scooters can increase intermodal connectivity and help to resolve the first/last mile connectivity for getting to and from public transport hubs between initial and final destinations.

Greater use of e-scooters could also lead to less reliance and use of private motor vehicles, particularly for shorter journeys where currently a very large proportion are undertaken by car. They also have the potential to improve accessibility in less densely developed regional and local centres where public transport provision is less comprehensive.

There is, however, a need to assess the operation of any shared e-scooter scheme to consider if the retrieval of vehicles (in dockless schemes) and the manufacture of e-scooters (including lithium batteries and especially given their short lifespan) actually generates more carbon than is potentially saved by reducing reliance on car journeys.

The recently launched schemes to improve road conditions and make more space available for pedestrians and cyclists, such as Safe Street, Save Lives in Greater Manchester offer a unique opportunity for e-scooter use to be viewed as a viable alternative to driving for shorter journeys.  Given that the public are increasingly supportive of reducing car usage in urban centres (May 2020 YouGov poll finding that 54% of respondents were in favour of making town and city centres motor-vehicle free for one day a week), e-scooters could enhance this level of support by providing another transport alternative in these zones.

Though e-scooters will not offer the same extent of health benefits as active travel modes such as walking and cycling, their use in urban centres may lead to an increase in active travel of users when connecting with public transport, which tends to involve more walking than driving point-to-point.   E-scooters could also potentially act as an interim ‘stepping-stone’ for commuters as they move from motor vehicles to active travel. However, this must be balanced with the possibility of a reduction in active travel if people were to switch from walking and cycling. This would be contrary to national and local objectives and the shift we have seen in recent weeks to more active modes during the COVID-19 lockdown. The shift from public transport and active travel to e-scooters (as opposed to from car) has been observed in Paris and Madrid and so this must be carefully managed.

Given that rental e-scooter schemes are likely to involve the use of a smartphone-based application to rent the vehicle, there are also opportunities to use this movement data to better understand passenger movement and improve the monitoring of intermodal journeys – this may be of particular interest during the COVID-19 recovery. As referred to above, robust licensing regimes would be required to effectively regulate such rental schemes.

Additionally, e-scooters take up considerably less space both on a highway and when stored.

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

Given that cycles are not permitted on pavements due to the potential dangers posed to pedestrians, it is our view that e-scooter use should be restricted to roads and cycle lanes. Use on pavements has safety risks, is likely to intimidate pedestrians and reduces safe space for walking.

When considering the use of e-scooters within the transport network, we would recommend taking the same approach as Greater Manchester does for walking and cycling infrastructure as outlined in the Bee Network document. ‘Dedicated separate space should be provided for walking and for cycle traffic. Providing for cycling by converting footways to shared use is an approach that can deter people from both walking and cycling and it is an approach that we plan to avoid. However, it can be appropriate to encourage considerate cycling in existing shared public spaces.

Consideration could be given, therefore, to use of e-scooters in more open public areas where space is available, such as tracks in parks and large public squares or plazas.

It is also our view that e-scooter use should be restricted on roads with speed limits of 30mph or above as users are likely to have little to no protection from impacts with motor vehicles. 

Drivers of “traditional” vehicles would need to understand the types and characteristics of any vehicles newly permitted to use cycle lanes in order to reduce the risk of accidents. It is likely that this would require the broadening of any advertising/road awareness campaigns beyond cycle awareness campaigns, the use of new bespoke signage and other media. Despite this, segregation from cars through either marked or segregated lanes is the ideal type of use. As the usage of such modes increases, it will be important to investigate further development of a 'third lane' that can accommodate traditional vehicles such as bicycles and mobility scooters; as well as new mobility solutions such as e-scooters to enable more space efficient modes to thrive.

With regards to those with visual impairments, similar to cycles and motor vehicles, e-scooters should be equipped with the ability for users to sound an audible warning, such as an electronic tone or simple bell.

A further consideration is the enforcement of any misuse. It is suggested that local highway/transport authorities and local police are closely involved in the development of any e-scooter trials.

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

With regard to the vehicle; brakes, reflectors, bells (or similar) and speed limiters should be mandatory. Consideration should be given to built-in theft detection/deterrent, lights and a unique stamp/frame reference (which would improve on the current system for bicycles). 

Similar to bicycles, it is our view that helmets and other personal safety equipment, whilst encouraged, should be at the discretion of the user. If safety equipment such as helmets and pads were mandated, it is possible that this could reduce uptake. Particularly in the case of rental schemes, users ae unlikely to bring their own equipment in case they use e-scooter and may not wish to share equipment supplied by the provider, especially in the wake of COVID-19. The use of helmets, however, should be strongly encouraged by rental scheme providers and by manufacturers or at the point of sale to users who purchase their own e-scooter.

It is suggested that there needs to be a strong commitment to training and education as well as any legislative changes and physical infrastructure upgrades. In the longer term, as e-scooters and other such types of vehicles become more widely used, consideration should be given as to whether they should require insurance.

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

It is our view that e-scooters should be built with standards relating to the strength of construction, capability of braking systems, and with the inclusion of an audible warning for pedestrians or those with impaired vision. 

Consideration must also be given during construction of environmental regulations, including safe disposal or replacement of lithium batteries.

We suggest that e-scooters are speed limited to 12.5mph.  Even if use is not permitted on pavements, it is possible that some users may still do so.  A speed of 15-20mph would present a significant risk to pedestrians in this scenario.  Speeds of 20mph also pose a considerable risk to e-scooter users if they were to be involved in a collision, especially given e-scooters have no crash protection and are arguably less controllable than cycles.

Evidence on experience of other countries where e-scooters are legal on the roads?

N/A for TfGM. More applicable to multi-national service operators.

June 2020