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.

  Yes 60kg is more than adequate.

• 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

  Creating an age limit exclusion only adds to law/regulation complexity which makes it difficult for the community to understand and complex for compliance and enforcement. (Is that a 15 year old doing 12km on the footpath?) Speed management will have better shared outcomes for all footpath users. If children are allowed to ride electric assisted bikes through these locations then prohibiting them from PMD’s doesn’t make sense.

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

  I feel that whilst the intent is to assist with regulating PMD’s the result may be just another layer of overly complicated legislation. The assessment of location use is perfect, footpath, bikeways and local roads however the secondary assessment of speed when other not to dissimilar devices electric bikes) are already using these spaces without device specific speed regulations seems a little over the top. Applying speed limit/controls to the locations not the devices will uncomplicated everything for all users.

• 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

  Locality consistency could be considered for all devices. Different speeds for different devices is overly complicated. Electric bikes = no regulation/self regulated, Electric skate/scooter = 10km (footpath). Consistency by location not device would also help with management of future devices.

• 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

  The use of footpaths, bikeways/paths, seperate paths and local roads makes sense. Staying away from road use where speed limits exceed 60km at regular times. Otherwise school zones, roadworks and construction zones would all be accessible as they are 40km or lower. The same for some CBD areas where speed limits are continuing to come down. The definition of local road will undoubtedly confuse everyone.

• 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

  PMD’s should be permitted to travel at the same speed as bicycles in all of the various infrastructure. Variable speed for assorted devices and different aged users creates unnecessary complications. If a figure is to be applied it should be something that works for PMD’s, mobility devices, electric and traditional bicycles. My feeling is 15km footpaths and 30km on bikeways and local roads.

• 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 three is the preferred approach however I feel applying varied speed limitations to devices using footpaths only complicates community/user understanding and makes compliance virtually impossible. Simplified maximum footpath speed for PMD’s, bikes (including electric) and mobility devices can only improve sense of safety along footpaths. Perhaps a universal 15km maximum for all devices on footpaths would be smarter and also something the cycling community should be adhering to. A quite electric skateboard at 10km passing a pedestrian compared to a quite electric powered bicycle at unregulated speed seems illogical. Applying the 15km footpath (increase your suggested 10km up to 15km) and a 30km bikeway and road would have PMD’s behaving as close to bicycle behaviours as possible. Having electric scooter/skateboard riders stopped for speeding as electric bicycles travel past them on footpaths at unregulated speeds does not make sense. Confusing for pedestrians, all device users and police/compliance officers alike.