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
Option 3, Speed 1, seems like a sensible approach to address the benefits of PMD's, but also keep things safe, however speeds seem low. A max speed for PMD's capped at 25km/h on flat ground seems unrealistic considering the capability of the existing devices on the market, being able to reach speeds of 30km/h+ depending on rider weight e.g. Boosted skateboards. The issue here is that a large quantity of PMD's on the market would not qualify this requirement, which would leave existing devices in a legal grey area. Average speeds reached/used on a normal push skateboard and/or scooter can be in the range of 5km/h - 16km/h which are mainly used in pedestrian and shared pedestrian spaces. While 10km/h seems like a nice middle ground, if push skateboards and scooters are able to use these speeds safely already around pedestrians using common sense and safe use, PMD's should be able to be used safely around pedestrians as well at similar speeds, i.e. a maximum of 15km/h.
- 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 seems ok, potentially a little on the heavier side.
- 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
They should be able to use any device that complies with the proposed PMD framework. Being able to learn to ride any device safely should be allowable, as it encourages more efficient and environmentally friendly habits and behaviours from a younger age.
- Question 4: Do you agree with the criteria selected to assess the options? Are there any key impacts not covered by these criteria?
The criteria seem ok.
- 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 risk assessments seem ok.
- 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 flexibility of these devices means they are capable of being used across a broad range of road infrastructure, depending on the context of the situation and what is the safest and/or quickest route.
- 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/ 15 km/h b/ 30 km/h c/ 35 km/h Option 3, Speed 1, seems like a sensible approach to address the benefits of PMD's, but also keep things safe, however speeds seem low. A max speed for PMD's capped at 25km/h on flat ground seems unrealistic considering the capability of the existing devices on the market, being able to reach speeds of 30km/h+ depending on rider weight e.g. Boosted skateboards. The issue here is that a large quantity of PMD's on the market would not qualify this requirement, which would leave existing devices in a legal grey area. Average speeds reached/used on a normal push skateboard and/or scooter can be in the range of 5km/h - 16km/h which are mainly used in pedestrian and shared pedestrian spaces. While 10km/h seems like a nice middle ground, if push skateboards and scooters are able to use these speeds safely already around pedestrians using common sense and safe use, PMD's should be able to be used safely around pedestrians as well at similar speeds, i.e. a maximum of 15km/h.
- 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 4, Speed Approach 1, with a speed increase of 15 km/h for pedestrian infrastructure and 30km/h for bicycle infrastructure and roads. A max speed for PMD's capped at 25km/h on flat ground seems unrealistic considering the capability of the existing devices on the market, being able to reach speeds of 30km/h+ depending on rider weight e.g. Boosted skateboards. The issue here is that a large quantity of PMD's on the market would not qualify this requirement, which would leave existing devices in a legal grey area. Average speeds reached/used on a normal push skateboard and/or scooter can be in the range of 5km/h - 16km/h which are mainly used in pedestrian and shared pedestrian spaces. While 10km/h seems like a nice middle ground, if push skateboards and scooters are able to use these speeds safely already around pedestrians using common sense and safe use, PMD's should be able to be used safely around pedestrians as well at similar speeds, i.e. a maximum of 15km/h.