Written evidence submitted by Guide Dogs


About Guide Dogs


Guide Dogs provides services that support the independence of people with sight loss in the UK. Alongside our services, we campaign to remove barriers that prevent blind and partially sighted people living their lives as they choose. Current estimates suggest over two million people with sight loss are living in the UK, of which around 360,000 are registered as blind or partially sighted.


In April, Guide Dogs conducted focus groups with blind and partially sighted people, including guide dog owners and long cane users, to discuss how e-scooters impact them. Their responses contributed to this submission.





Where in the urban environment could e-scooters could be used and could this impact on other road users and pedestrians, including people who have visual impairments?


E-scooters – impact on blind and partially sighted people

Like other electric vehicles, e-scooters are difficult for blind and partially sighted people to detect and avoid because they operate quietly, without the audible cues of a traditional motor. People with sight loss often rely on hearing to navigate safely when walking the streets. E-scooters can be both heavier and faster than both pedal cycles and e-bikes and therefore present a greater risk to people with sight loss than existing vehicles. The impact of a quiet approach at high speed can be alarming:


“It is scary, you don’t know what’s coming, and how fast it’s coming, and what kind of vehicle it is”Person with sight loss, Guide Dogs focus group, April 2020


We have already received reports from people with sight loss experiencing problems with e-scooters being used illegally on roads and pavements. As well as the risk of collisions, the uncertainty created by unexpected encounters with e-scooters can dramatically affect the ability of people with sight loss to walk the streets independently. The loss of confidence from a near miss with an e-scooter could mean people with sight loss are forced to change their routes, reduce unaccompanied travel, or indeed stay at home altogether, with knock-on effects on physical and mental health. The greatest impact comes when e-scooters are used on the pavement in pedestrian or shared use areas, but they can also affect people with vision impairment when crossing roads or cycle lanes.


The Government have accelerated the pace of work on legalising e-scooters to create alternatives to public transport during the coronavirus pandemic. We recognise the need to reduce reliance on traditional means of public transport in order to control transmission of coronavirus. However, this cannot come at the cost of making walking journeys more difficult for people with sight loss, who are already at risk because they may find it more difficult to keep a safe distance from others.


Use on roads and cycling infrastructure

We acknowledge that there would be safety advantages for riders if e-scooters were permitted to use cycle infrastructure. This is also likely to improve compliance with riders not using the pavement. However, we are concerned about the impact on people with sight loss if e-scooters are allowed in shared use areas on the pavement where both cyclists and pedestrians are permitted. Although this form of cycling infrastructure becomes inaccessible for people with sight loss even with low levels of cycle traffic, shared use areas are nonetheless very common.


“When you have a combined cycleway and pathway it becomes very dangerous because [e-scooters] do go quite quickly and you can’t judge how fast they’re coming, you can’t hear them coming” - Person with sight loss, Guide Dogs focus group, April 2020


Even where cyclists and pedestrians are accommodated on discrete areas of the pavement, the distinction between these areas is often purely visual, rather than the tactile indicator or change in height recommended by existing guidance. This means that people with sight loss cannot reliably remain in the pedestrian area, putting them at risk of collision with e-scooter users.


“When they just paint a white lane to separate bikes from pedestrians, it doesn’t help.” - Person with sight loss, Guide Dogs focus group, April 2020


We understand that upgrading inadequate and inaccessible cycling infrastructure is a wider issue than regulation of e-scooters. Nonetheless, allowing e-scooters to use these areas will make them still more inhospitable for people with sight loss. We recommend that DfT issue guidance to local authorities that they may need to restrict the use of e-scooters during the planned trial in shared use areas where pedestrian and cyclist zones are not adequately distinguished. These restrictions should remain in place until work to make inadequate cycling infrastructure safe for disabled pedestrians is completed.


We also recommend that if e-scooters are permitted, DfT should publish supplementary guidance to the planned Local Transport Note on cycling infrastructure reflecting the need to take these vehicles into account during the design process. Local authorities should be reminded of their responsibilities to consider the needs of disabled pedestrians before e-scooters are permitted to use inaccessible cycling infrastructure.


We strongly recommend that e-scooters should not be permitted on the pavement. This requirement must be adequately communicated to e-scooter users and local authorities should plan for appropriate enforcement activity if compliance is poor.


Hire schemes

DfT’s proposed trial of e-scooters would permit their use through public hire schemes. While these schemes may benefit riders, the experience of existing dockless bike and e-bike schemes in the UK shows that additional powers are needed to ensure parked e-scooters do not become a barrier for people with sight loss.


Unlike most permanent street furniture, which is situated and designed to minimise any trip hazard, dockless vehicles can be parked anywhere and can be difficult for people with sight loss to avoid without injury. Parked dockless vehicles can be a dangerous obstacle for a wide range of pedestrians, including older people, wheelchair users and people with sensory or cognitive disabilities. People with sight loss are at particular risk if they are forced out by obstacles into the road with traffic that they cannot see.


“People will leave them about and we won’t see them” - Person with sight loss, Guide Dogs focus group, April 2020


Local authorities have extremely limited powers to regulate this type of hire scheme, which makes maintaining clear pavements for pedestrians difficult. In the absence of any other effective powers, Transport for London and London boroughs have resorted to a byelaw to regulate existing dockless hire schemes. The proposed byelaw would allow TfL to fine operators who allow dockless vehicles to be parked outside of parking zones designated by each borough. However, it is not possible to effectively regulate these schemes with byelaws alone. We understand that it is not possible for local authorities to set standards for hire vehicles, or limit the numbers of companies operating hire schemes, or indeed the total number of vehicles on the streets.


We recommend that the Government consult with local authorities on the new powers that are needed to regulate dockless hire schemes. These powers should be ready for use before any permanent changes to the regulation of e-scooter hire schemes. We also recommend that the Government issue guidance to local authorities on the effective regulation of dockless hire schemes. Parking of e-scooters should be limited to designated zones. Ideally, these should be formed from space taken from the carriageway. Where this is not possible, parking zones should be detectable for people with sight loss and leave enough space for a pedestrian to safely navigate around if located on the pavement.


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


Steering and braking

We recommend that DfT should not consider legalising micromobility vehicles, such as hoverboards or powered unicycles, which do not feature handlebars for directional control and braking systems for use on the highway. We believe that without these essential safety features riders would not have sufficient control over speed and steering to operate these vehicles safely in a street environment.


Maximum speed and acceleration

We recommend that the maximum speed e-scooters should be able to reach is 12.5mph, in line with other countries such as France and Germany. Although e-bikes have a higher limit (15.5mph), this can be justified based on their potential contribution to public health goals by increasing physical activity. Unlike e-bikes, e-scooters are powered purely by the electric motor, with no physical effort from the rider. This rationale therefore does not exist for e-scooters.


We also believe that specifications for e-scooters should include a maximum motor power. Even if the maximum speed of e-scooters is limited, motor power affects acceleration and therefore the safety of their interaction with pedestrians. Both speed and acceleration must be limited to ensure the safety of people with sight loss, who may be unable to see or hear these vehicles approaching.


We believe that the maximum motor power should be broadly in line with e-bikes so that acceleration is similar to existing vehicles.


Requirement for bell and lights

We recommend that e-scooters are required to be fitted with a bell and lights used when dark to make them easier to see and hear, in line with requirements for cycles and e-bikes.


Age limit

We agree with the Department for Transport’s proposed rules for trials of e-scooters, which would require riders to hold a provisional driving licence, and therefore be aged 16 or over. We recommend that if this age limit is reviewed, this should be based on an assessment of the safety impact of permitting younger riders to use e-scooters.


Road traffic offences

DfT’s 2018 Cycling Safety Review was inconclusive on which regime of road traffic offences would apply to e-bikes and similar vehicles. Although e-bikes do not meet the definition of motor vehicle in the Road Traffic Act 1988, they may nonetheless be deemed “mechanically propelled vehicles” and therefore offences such as causing death by dangerous driving would be appropriate, rather than the separate regime which applies to pedal cycles.


We would welcome clarity from DfT on which road traffic offences would apply to e-scooters and similar vehicles, particularly where these can be powered both by a motor and by the rider’s own effort. Though the proposed new offence of causing death by dangerous cycling would bring the two regimes closer together, until this becomes law there is no equivalent offence.


Training, education and enforcement

If e-scooters are to be introduced for use on highways, this must be accompanied by a substantial programme of training, education and enforcement to embed safe and considerate behaviour while riding. User behaviour is already a recurring issue for people with sight loss.


“I find them really scary because they tend to just appear out of nowhere and wheel between people…I could feel that [my guide dog] wasn’t really sure where to go because the rider wasn’t even going in a straight line” - Person with sight loss, Guide Dogs focus group, April 2020


We recommend that DfT work with key stakeholders, including organisations representing people with sight loss, to support the development of a programme of training for e-scooter users, in a similar format to existing Bikeability training. A public information campaign would reinforce new rules for the use of e-scooters and highlight the impact of inconsiderate use on disabled pedestrians. In combination with targeted enforcement, this would be necessary to improve compliance at crossings and avoid use on pavements.


June 2020