View the feedback we have received on the NTC Consultation RIS - Barriers to the safe use of personal mobility devices paper.

• Question 1: Are the requirements in the proposed regulatory framework appropriate? Are there any requirements that should be removed, included or modified? Please provide a rationale to support your position

  The requirements which describe the vehicle are appropriate in my opinion.

• Question 2: Is 60kg a suitable maximum weight for a PMD? If not, what is a more suitable weight and what other factors should be considered? Please provide a rationale to support your position.

  60kg is more than ample

• Question 3: Should children under the age of 16 years old continue to be permitted to use  a motorised scooter incapable of travelling more than 10km/h on level ground on roads and paths? Or should they be able to use any device that complies with the proposed PMD framework? (see Appendix A). Please provide a rationale to support your position

  Children should be able to use devices which comply with the framework. Applying an age limit to 10 km/hr is slightly under what would be considered reasonable for a child. For example a child is completely able to take a common skateboard, bike or scooter and ride it down a hill at around 35 kilometers an hour. In the situation with a regular skateboard in particular they have no brakes or control over how fast they are going. If they are riding their bike around the neighbourhood while peddling they will exceed speeds of 20km/hr with ease. Why would these forms of vehicles be regulated any differently to regular bikes and skateboards which are readily accessible to children of all ages and account for a wide range of injuries? Perhaps childrens speed may be limited to 15/20 kilometers an hour on local roads. Ensuring children are not driving these kinds of vehicles on busy roads would help avoid confusion of younger riders regarding road rules. Understandably however, this becomes difficult to enforce. In summary these devices pose a similar if not lesser risk to some forms of transport currently available to children. Not allowing speeds of over 10km/hr on footpaths for people of all ages however is reasonable. Speeds on footpaths which are not shared currently with bikes pose a significant risk to pedestrians in busy areas.

• Question 4: Do you agree with the criteria selected to assess the options? Are there any key impacts not covered by these criteria?

  I do agree with the criteria. I cannot think of any key impacts not covered.

• Question 5: When considering the safety risk assessment, access and amenity impacts, broader economic impacts, as well as compliance and enforcement impacts; has the impact analysis sufficiently considered all relevant variables and available evidence? What other factors could be included in the analysis? Please provide any additional evidence. (See Appendix E - Impact Analysis

  The analysis is sufficient and takes into account a range of factors.

• Question 6: What do you believe is the most appropriate road infrastructure for PMDs to access: footpaths, separated paths, bicycle paths and/or roads? Please  provide a rationale to support your position

  I believe PMDs should be able to access all areas bikes are currently allowed to access. Bikes are able to travel currently with an acceptable level of risk. On footpaths I agree the vehicles should be able to be used however at a speed limit similar to the recommendation. Bicycle paths should be 100% accessible as these are a key way for PMD's and traditional human powered transport to travel safely and without the risk of motor vehicles. Roads with bicycle lanes and local roads should be fully accessible as they are to bike riders as this provides a safe and efficient route of travel, which is already established infrastructure. Roads with speed limits above 60km/hr pose a risk for the driver and the rider as the speed of the motor vehicle cannot be matched in most cases by the PMD.

• Question 7: What is an appropriate and safe maximum speed that PMDs should be permitted to travel across the various infrastructure: (a) pedestrian areas,       (b) bicycle areas, and (c) roads? Please provide a rationale to support your position

  A) In pedestrian areas it is acceptable that there is a far reduced speed limit in order to prevent injury to riders and or pedestrians. (B) Most current PMD's can reach speeds of well over 25km/hr. For example the evolve GTR skateboards reach a maximum quoted speed of 42km/hr. Some devices such as the baja board made in melbourne can go up to 60km/hr. As technology improves the average speed of these devices will continue to increase. It is not unlikely for someone riding these kinds of devices to sit at an average speed of 30km/hr especially in a commuting situation while on bicycle paths and roads. The bicycle paths have been designed for bicycle riders to reach 30km/hr according to the report. Therefore I find it reasonable that PMD's are also able to reach this speed while using bike paths. C) On roads with speed limits below 60km/hr it would be likely that current high powered PMD's such as the brands mentioned above would be able to follow or exceed the speed limit. A common concern for drivers with push bike riders is that they hold up traffic when using roads without marked bicycle lanes. According to the australian transport safety bureau "being hit from behind was the crash type that resulted in the highest number of cyclist fatalities,”. These kind of incidents generally occur when a driver is trying to overtake a rider and poses a great risk to anything on the road which is not a motor vehicle. However if PMD's are able to use their maximal power on roads and meet the speed limit (or be within an acceptable range of the limit), this would reduce the need for cars to overtake such vehicles. Furthermore this would reduce the need for cars to travel at lower speeds when approaching these kinds of vehicles, increasing the flow of traffic. In other words by allowing PMD's to reach the speeds accepted by cars on roads there may be a reduced risk to the rider of these types of incidents. This presents an opportunity for the PMD's to become a part of the traffic rather than hinder it. I would most prefer that PMD's be allowed to follow motor vehicle speed limits on roads. There is a point where all vehicles become too dangerous to ride however so on roads above 60km/hr I believe the use of the devices should be somewhat limited to below the maximum speeds if they are able to exceed this limit. The risk of motor vehicles in these high speed areas also poses a high risk to the rider in the event of a collision. These areas are currently however available to bicycle riders so I believe they should still be accessible. When travelling at high speed the responsibility shifts to the rider and their capability. If licencing was to come into place to travel at speeds of above 50km/hr this would limit inexperienced riders from dangerous situations.

• Question 8: Do you agree with the overall assessment that Option 3, Speed Approach 1    is the option that best balances mobility and safety? If not, which option and speed approach do you prefer? Please provide a rationale to support your positio

  I do believe that option 3 is appropriate. Speed approach 1 is acceptable in principle however I would prefer to see the speed limit set to the motor vehicle speed limit on roads and the bicycle path designed speed (30km/hr) to be implemented on bicycle paths. I have further outlined the rationale for this in the above section. Of the options presented however speed approach 1 seems the most reasonable. I strongly agree with reducing the limit in pedestrian areas and having a higher limit on bicycle paths and roads.