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 proposed requirements are not entirely appropriate. As mentioned in the discussion paper PMDs are evolving rapidly. For many they are no longer considered 'last mile' transportation devices rather an alternative form of transport entirely. There should be requirement that PMDs are to be integrated into the road network.
- 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.
Although 60kg is heavy for a PMD I think the maximum weight should not be a consideration. As the need for innovation grows the legal framework should remain flexible and be able to adapt and include future transport requirements. There could be new devices in the near future which exceed this limit and become popular and viable.
- 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
I don't see why there should be an age restriction. Currently any child under the age of 16 can ride a bicycle on the road or footpath and at any speed they wish so long as they aren't travelling over the posted speed limit. A child can legally ride a skateboard down a hill at 40km/h or 50km/h without brakes. So why should they be limited 10km/h on the level using a device with brakes.
- Question 4: Do you agree with the criteria selected to assess the options? Are there any key impacts not covered by these criteria?
No I don't agree with criteria selected to assess options. PMD users should only be bound by rules used for cyclists. Although I can see some merit in looking at how weight and speed of PMD will effect injury severity, I think behaviour is the most important aspect to determine safety. Cyclists can be heavy and are often seen riding at or above the speed limit, if one was to use the same assessment criteria on the individual cyclist the risk would be just as bad (110kg rider and weight @60km/h). I noticed the study used made mention of the average speed of a cyclist in a city environment. If you consider averages then the same should be applied to all other forms of traffic to determine max speed. In most cities the average car travels at approximately 30km/h but can easily travel beyond 110km/h. So by using the same approach cars should be limited to 30km/h. Cyclists travelling through the city may average 25km/h but regularly meet or potentially exceed the speed limit of 50km/h. Using average speed is not a true representation of the dynamics of traffic. To better integrate PMDs into the road network allowance should be made for the PMD to be used as such. If a PMD can keep up with the ebb and flow traffic as cyclists are often seen then they will be better accepted. Crucially it minimises the speed differential between the two which is imperative to deconflict different modes of travel as it keeps the traffic flowing. If a PMD is forced to travel slowly it will inevitably be a traffic hazard forcing other much faster traveling road user including cyclists to veer around.
- 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 assessment criteria seemed to be based around the city where shared paths and bike lines are prevalent and can be used to get anywhere the rider pleases. However this is not always the case. In a lot of cases dare I say most, there is no option but to use the road with no designated cycle way or footpath. Unlike a car PMDs can be used as a form of transport for the purpose of moving a person anywhere and that capacity should remain. The idea is we transition people from single occupant in a car with all the associated emission and costs to a compact, light and extremely low or no emission vehicle that can be used to transport that person door to door. Being able to transition PMD use from the road to shared path to cycleway is key element of functionality of a PMD. They don't have to be locked into one lane or the other. That is what makes them so effective and efficient at getting people mobile. Think about what cyclists can do and where they can ride. What compliance and enforcement is there with regards to bicycles and their use? Cycling is embedded into the road network already as the study showed cyclists will naturally slow down around pedestrians. Cars can travel faster than speed limit if they want to. It boils down to behaviour. If the PMD user is riding recklessly then that is where the danger lies. Speeding drivers, distractions most road incidents is from the behaviour of the driver. People are taking up PMD use at such a rapid rate and some police are using light vehicle legislation to police their use but this is clearly the wrong approach. They need some rules but ultimately de restricted
- 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 per cyclists all road infrastructure should be made available for use. Cyclists ride at similar speeds and as the study showed cyclists slowed down when approaching pedestrians. As I have said the device should not be limited but there should be speed limits around pedestrians. A driver can buy the fastest car but the speed limit for the road changes. A capable PMD should be allowed to the speed limit on the road, and like a cyclist and appropriate speed on a shared path. Often you will find cyclists riding on a shared path in excess of 40km/h. If there is no risk to pedestrians (ie no pedestrians present) why not be allowed to travel faster? So the rider behaviour should be assessed on a case by case basis.
- 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) Around pedestrians 10km/h. (b) Bicycle areas an appropriate speed, if cyclists are travelling at 40km/h then keeping pace should be considered. (c) Not exceeding the speed limit. I find its safer to ride with the traffic and keep pace than be a mobile traffic hazard at a slow pace Excluded from using motorways where cyclists would also be excluded. I am a cyclist and I own a car and a few different PMDs. One of my PMDs is comfortable at 50km/h can reach 60km/h and has a range 100km. I would like to use it as a commuter. Which would mean using it on the road in traffic. Where the road is congested and deteriorates or becomes dangerous I will find safety slowly riding the footpath. Its a massive time saver being able to use shared paths and often it is a direct route to work.
- 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
No to Option 3. Because it limits the ability for the PMD user to travel at a pace particularly on the road, that make the PMD a viable alternative to a car or public transport. PMD users will have to slow down around pedestrians, everyone can agree to that. But in order for people to transition away from cars the use of PMDs and their freedom of movement and the speed at which they can carry the user must be considered a benefit. I agree with Option 5 unless safe to go faster. Or within the speed limit. Here is a device you can replace a car with but the legal framework will curtail its benefits and make it slower than riding a bike and limit which direction and what route you can take.