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 maximum speed that a PMD is capable of should not be part of the definition of a PMD. No other form of vehicle classification includes a criteria involving the maximum speed that a vehicle is capable of (eg cars, bikes). There are other parts of the regulatory frame work that address the real question, which is the speed that PMDs should be operated at in giving situations (just like cars and speed limits on given roads).

• 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.

  It seems artificially high, specifically to allow inclusion of one particular brand/form of PMD (Segway). While I have no objections, if it were an issue, then an alternative maximum weight of 20kg could easily be adopted while still accommodating the vast majority of PMDs in use today.

• 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

  Yes, they should be allowed to learn and ride PMDs, but only in safe settings like paths and other areas where they are not at risk of interacting with road-going vehicles. They should not be allowed to ride PMDs on roads due to their lack of skill, judgement and risk-taking maturity.

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

  Yes, the criteria are appropriate.

• 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 inadequately deals with the variable of privately owned and operated PMDs in comparison to rental scheme PMDs. Consideration ought to be given to the more careful and skillful operation of owned PMDs that is the result of a private owner's familiarity with their particular PMD and their vastly greater financial responsibility for the purchase, maintenance and repair of the device. Rental scheme PMD operation must factor in greater probability of malicious, unskilled, and improper use of those PMDs and provide framework to safely govern their use without adversely affecting the responsible use of privately owned PMDs.

• 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

  PMDs should be able to access footpaths, separated paths, bicycle paths and roadways with speed limits up to 60 kph. This most accurately reflects the general speeds and capabilities of these devices and places them in locations where they can integrate well (speed-wise) with surrounding pedestrians, bicycle and vehicle movements.

• 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

  Pedestrian Areas - 10-15 kph. This reflects efficient progress for the PMD rider and allows adequate time to brake and maneuver around pedestrians should unexpected behavior be encountered. Non-road bicycle areas - up to 25 kph, reflecting harmonious integration with general bicycle speed. Roads and on-road bicycle areas - Up to 60 kph, reflecting harmonious integration with general vehicle speeds.

• 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, Option 4 is the best option, such that local roads with speed limits up to 60 kph are permissible. None of the Speed options are optimal. Per previous question, the optimal speed option is 10-15 kph on footpaths, up to 25 kph on non road bicycle areas and up 60 kph on road and on-road bicycle areas.