Submission: The government recently launched a public consultation on how they should regulate electric scooters – which are currently illegal. The Greens have been calling for legalisation and regulation for some time.
Here’s what I sent in to the consultation. (“PPTs” is short for “Personal Powered Transport”, which is seemingly the preferred transport policy term for the broad scooter category.)
Question 1: What category of stakeholder do you represent (e.g. private, company, organization etc)?
Local councillor – Dublin City Council
Question 2: Do you think that the use of PPTs should be permitted in Ireland and why?
Yes. They offer a low-carbon, zero-local-emission, quiet alternative to car ownership, which would be useful for “last mile” journeys. Their size also means they will likely have a limited impact on congestion and they have been used successfully in other jurisdictions.
I would, however, bring in clear rules either regulating or banning on-street rental scooters, which cause serious accessibility problems when left scattered across footpaths. Perhaps this could be permissible only with the explicit license/permission of the relevant local authority.
Question 3: Are there any types of PPTs (e.g. Segways, eScooters, electric unicycles etc) that you think should not be permitted to be used and why?
No. I would support leaving the regulation open and impose restrictions should any vehicles be found to be unsafe. This avoids the problem which we currently have, where new vehicle types are reasonable yet illegal.
Question 4: If the use of PPTs on our roads is to be permitted do you think that they should have some form of identification (i.e. a registration plate/marking)?
No. This would likely have a negative impact on takeup of the vehicles. If needed, this could be introduced at a later date, but it is not clear what problem such a system would aim to solve.
The destructive capacity of a car is such that it needs some sort of marking system, but this is not the case generally for pedestrians, cyclists, speed-restricted e-scooters etc.
Question 5: If the use of PPTs on our roads is to be permitted do you think that users should (a) be of a minimum age (if yes – what age?) and (b) have some form of licence covering their use (e.g. category AM driving licence – mopeds)?
(a) A minimum age would be sensible, but it is not clear what that age should be. Perhaps a supervised age at a lower point (such as 12), with a higher age for unsupervised (such as 16) would be appropriate.
(b) No. Providing the vehicles are permanently speed limited, they should be treated as bicycles in this respect.
Question 6: If the use of PPTs on our roads is to be permitted do you think that their use should be covered by some form of insurance (i.e. liability cover)?
No. As with bicycles, insurance and safety gear is recommended, but should not be a legislative requirement. This, again, is due to the limited likely destructive potential of such vehicles compared with cars, trucks, etc.
Question 7: If the use of PPTs is to be permitted do you think that can be used on (a) footpaths, (b) cycle lanes (c) bus lanes (d) normal traffic lanes?(a) As with bicycles, it is inappropriate for these vehicles to be used on footpaths, as this clashes unfairly with pedestrians and will lead to accidents as pedestrians exit buildings. It would also be unfair to those with mobility issues or disabilities.
(b)(c)(d) Yes. As with bicycles, such vehicles should be able to use all roads and lanes bar motorways.
Question 8: If the use of PPTs is to be permitted do you think that they should be restricted to (i) a maximum speed (if yes – please suggest such a maximum speed) and (ii) only used on roads with a maximum speed limit of (a) 30kph, (b) 40kph or (c) 50kph?(i)
Yes, speed should be limited in the vehicles – perhaps to 25kph, but certainly no more than 30kph. This is both for safety of the user and other road users, and would match speeds with those of typical bicycles. It also aligns with the RSA’s suggested speed limit in urban areas (30kph), which is in place across much of Dublin city centre, for example.
Question 9: If the use of PPTs on our roads is to be permitted do you think that users should be required to wear (a) protective head-gear, (b) high-visibility clothing (i.e. be mandatory)?
No. There should be a requirement, as with bicycles, for clear front and rear lights at night, and recommendations for helmets and high-vis clothing.
However, they should not be legally required, as with bicycles. Doing so would make it less likely that people would take up PPTs, make it less “normal”, and shift safety expectations unduly away from car users to other road users.
Question 10: If the use of PPTs on our roads is to be permitted do you think that users should (a) have some form of training, (b) if so, by who?
Yes, but again, this should be as with bicycles. Training and common sense, without necessity for a state scheme. Again, this could be revisited if there are widespread problems. Current Irish and international experience shows that this is not a significant problem.
Question 11: If the use of PPTs on our roads is to be permitted do you think that it should be left to local authorities to decide whether or not to regulate their use in their respective functional areas?
Yes. This would allow different responses in different areas, perhaps allowing their use in specific streets which are closed to other motorised vechicles. By default, however, PPTs should be legal, on-street rental PPTs illegal, unless the local authority has a scheme in place.
Any thoughts? Let me know on firstname.lastname@example.org