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

• 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.

  I believe this should accommodate all the PMDs I am familiar with.

• 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 any device that complies with the PMD framework. The premise of this rationale, as will be with most of my comments, is that the case that PMDs are of a different category to equivalent non-electric transport, such as bicycles, has not been made. Thus, the default position should be that PMDs are treated as the same category and subject to the same rules as bicycles. Where they are treated differently, a rationale should be provided to support this difference. We currently allow children to use other forms of transport and equivalent non-electric vehicles that have just as much, if not more, inherent risk. Children currently ride bicycles, non-electric scooters and skateboards, which can travel at much greater speeds (downhill), and without brakes and helmets in the case of skateboards, or be used in significantly more dangerous activities (skateparks, bmx tracks etc). The case that PMDs are of a significantly different category or risk to these devices is not made anywhere. If anything, the fact that these devices have brakes and you must be wearing a helmet, makes these safer. If PMD are to be subject to different rules, they should start with the premise that adults are responsible for supervising their own children, and the state should not intervene unless necessary. If children do use these devices dangerously, existing laws could no-doubt be utilised to deal with inadequate supervision.

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

  This looks well thought out.

• 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

  As above, this looks to be well thought out. These are new devices and it is good to see Australia taking a pro-active approach to the legal issues. This is not the case in most countries.

• 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

  As with my prior answers, PMDs should be treated as bicycles (as with the QLD laws, where bikes can ride on footpaths).

• 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

  The limit of 25 km/h is reasonable. That said, cyclists are not constrained to this low speed. I have been riding my electric skateboard at more than 30 km/h and have been overtaken by cyclists travelling significantly quicker. As before, the case has not been made as to why I should be treated as a different class of risk? A limit of 10 km/h could be set in particularly high foot traffic areas, as has been done in Brisbane (the CBD and Southbank). To have a limit of 10 km/h on footpaths, when there are no pedestrians, would be impracticable and unnecessary. An option not cited in the report is 25 km/h limit on empty footpaths, reduced to 10 km/h when the path is being actively shared with pedestrians.

• 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

  Option 3, speed approach 3, with some minor refinements would work best and is closely aligned with QLD's laws, which were recently introduced are working well: https://www.qld.gov.au/transport/safety/rules/wheeled-devices/personal-mobility-devices. As I noted on Question 7, artificially limiting the speed to 10km/h on an empty footpath is unrealistic. Ensuring the safety of walkers is very important to me, so including a modification such as: "reduced to 10 km/h when the path is being actively shared with pedestrians", and councils setting designated low speed zones (as in Brisbane) would achieve this. Further, I would suggest this be added to rules for bicycles, which often travel significantly faster and quieter than PMDs. I would also advocate strong enforcement of this by police, with a particular focus on the shared dockless PMDs, such a Lime Scooters (which in my experience, cause the majority of issues). Some further refinements and clarity are required if the QLD laws are used as a basis of a national approach. For example, the current QLD law states: that 'a rideable in Queensland must have a maximum speed of 25km/h" Nearly all privately owned rideables, such as Evolve electric skateboards (a QLD company) have higher maximum speeds. These boards need faster maximum speed on the flat to ensure they have enough power to ride up hills. This report does frame the upper speed in this way, so this is one aspect from this report that could feed back into QLD's existing rules.