DTTAS consultation on Personal Powered Transport (PPT)

Question 1: What category of stakeholder do you represent (e.g. private, company, organization etc)?  Non-governmental organisation: Cyclist.ie – the Irish Cycling Advocacy Network (https://cyclist.ie/)

Question 2: Do you think that the use of PPTs should be permitted in Ireland and why? Yes. The nature of mobility, and urban mobility in particular, is changing throughout Europe (and globally) in response to several structural shifts: the crippling economic effects of congestion arising from allowing too many cars (most of them single occupancy) into cities; the need to make cities and communities more liveable and safer, by reducing the volumes of motorised vehicles in them; the need to decarbonise transportation because of the sector’s very significant contribution to CO2 emissions (approx 20% of emissions in Ireland and higher elsewhere). 

The future of urban mobility, which we need to shape through policy and legislative interventions – as well as being shaped by quite rapid developments in (battery) technologies – must be characterised by:

  • high quality and high capacity public transportation (and electric in nature – i.e. moving away from diesel fueled vehicles)
  • active travel (walking, cycling, e-bikes and including various bike-sharing systems)
  • Powered Personal Transporters (PPTS). These are incredibly space efficient (both when moving and ‘parked’), do not contribute to noise pollution and use minimal energy when compared with the energy use of 2000 kg+ cars. 
  • Clever integration between all of the above. Intermodality is what we need to be thinking about in which using several (low carbon) vehicle types over the full length of a (longer) journey becomes the norm. 

The model of (generally single occupancy) cars and Sports Utility Vehicles driving into (historic) towns and cities is a fantasy notion from the 1950’s where unlimited motorised auto-mobility was assumed to be both desirable and possible. It is neither! The future of mobility needs to be very different from the models of the past – and the models still foisted on us through the all-pervasive car advertising that dominates our everyday media. 

Therefore, the starting point for this discussion needs to be around facilitating small, quiet, efficient vehicles – and radically de-prioritising the space provided for large, uneconomic, inefficient, 2000 kg+ single occupancy vehicles. The answers to the questions below follow on logically from this vision of the future.  

Question 3: Are there any types of PPTs (e.g. Segways, eScooters, electric unicycles etc) that you think should not be permitted to be used and why? No. These new technologies should generally be welcomed as incredibly space-efficient new mobility forms which, when used in combination with public transport in particular, offer smart solutions to decongesting towns and cities, and reducing the (thus far stubbornly high) carbon footprint from the transportation sector.  

Question 4: If the use of PPTs on our roads is to be permitted do you think that they should have some form of identification (i.e. a registration plate/marking)? No. We need to encourage their use and not create barriers. We need to make it easy to use smart sustainable transport – and hard to use space inefficient forms which cause proven dangers to people walking and cycling. 

Question 5: If the use of PPTs on our roads is to be permitted do you think that users should (a) be of a minimum age (if yes – what age?) and (b) have some form of licence covering their use (e.g. category AM driving licence – mopeds)? 

(a) Yes/No? Minimum Age ____  No. Non-electric scooters are already common and traditional modes of transport that have been used by people of all ages and e-scooters can be seen as an extension of this micro-mobility concept (albeit without the ‘active travel’ component).
(b) Yes/No? No. Once again, we need to make it easy to use space efficient forms of transportation and denormalise the notion that large individualised motorised mobility is a sensible way to organise our systems of mobility. We need to flip our existing assumptions and systems around. 

Question 6: If the use of PPTs on our roads is to be permitted do you think that their use should be covered by some form of insurance (i.e. liability cover)? No.  Similar to bicycles, this should not be a requirement.  The use of these PPTs, along with more active travel, will help to decongest our cities. However, it should be possible for users, who so wish, to insure themselves against liability for any damages they may cause.

Question 7: If the use of PPTs is to be permitted do you think that can be used on: (a) footpaths, (b) cycle lanes (c) bus lanes (d) normal traffic lanes? 

(a) Yes/No? No.
(b) Yes/No? Yes – but there is a need to widen and generally radically improve the quality of cycle-lanes and (off-road) cycle tracks.
(c) Yes/No? Yes, if there is no separate good quality cycle-lane / track provided on the route.
(d) Yes/No? Yes (in non-motorway contexts) but in the interest of safety for all, lower speed limits (particularly in urban areas) are needed and other progressive traffic management interventions which favour active travel and lower carbon modes. The definition of ‘normal traffic’ will need to change in transport discourses over the coming years so as to embrace these new mobility forms (including also e-bikes and e-cargo bikes for example). 

Question 8: If the use of PPTs is to be permitted do you think that they should be restricted to (i) a maximum speed (if yes – please suggest such a maximum speed) and (ii) only used on roads with a maximum speed limit of (a) 30kph, (b) 40kph or (c) 50kph? 

(i) Yes/No? Maximum Speed _____ Yes. 20-25km/hr.   

(ii) (a) 30kph? (b) 40kph? (c) 50kph? The broad approach here should be to reduce the speed limits on urban roads to 30km/hr so that walking, cycling and the use of PPTs is as safe as possible. 

Question 9: If the use of PPTs on our roads is to be permitted do you think that users should be required to wear (a) protective head-gear, (b) high-visibility clothing (i.e. be mandatory)? 

(a) Yes/No?  No. It should be similar to the existing requirements for cyclists in which helmets are non-mandatory.

(b) Yes/No?No. Referring back to the desired vision of the future as described earlier, the broad approach needs to be to reshape the urban environment so that those modes which we want to encourage are made to feel welcome and can operate in as safe an environment as possible – as opposed to a general approach of throwing ‘high hiz’ and helmets at the issue (and naively assuming this solves the problems) while leaving the hostile nature of the road environment largely unchanged. We would emphasise that these should not be necessary under daylight conditions, but that users need to take reasonable responsibility for their visibility to others (like cyclists). We do however think it should be a legal requirement to have lights on the vehicles/pilot at night-time. 

Question 10: If the use of PPTs on our roads is to be permitted do you think that users should (a) have some form of training

Mandatory training is not desirable here. However, training on the use of scooters and bicycles should be a standard component of the driving test so that the drivers of motorised cars, vans and trucks have a proper experiential understanding of moving in ways other than by being ‘behind the wheel’. However, it would be desirable for initial training in using the new vehicles to be made available for those who seek it because these vehicles will become part of the normal repertoire of transport options very soon. Additionally, we feel that the Rules of the Road should be introduced into the school curriculum so that school children leave school with a basic proven knowledge of the subject.    

(b) if so, by who? Ideally by the suppliers of the vehicles.  

Question 11: If the use of PPTs on our roads is to be permitted do you think that it should be left to local authorities to decide whether or not to regulate their use in their respective functional areas? Most broadly, we would support a national directive that LAs should support and cater for PPTs, but the LAs would have the authority to restrict use on some named roads on specific grounds. Local authorities are generally responsible for matters within their functional areas subject to nationally issued legislation, guidelines etc., so we would support a similar approach in planning for this new mobility form. 

Please provide any other comments relating to the use of PPTs that have not be address above.

How PPTs are legislated for and provided for in policy terms should follow on logically from the use of bicycles on our roads. I.e. they should be welcomed for all of the positive arguments about the efficient use of limited (urban) space, their broad alignment with the idea of making towns and communities more liveable and less noisy and, crucially, their low carbon footprint. 

We welcome the commissioning of the TRL research report (by the RSA). However we would urge DTTAS to explore the subject of PPTs more in terms of how they can form part of a low carbon new mobility system – as against one in which individualised motorised mobility in vehicles with a mass of (sometimes far greater than) 2000kg has, sadly, become the norm. Additionally we would urge DTTAS and the RSA to work with An Garda Síochána to develop more refined collision reporting forms/procedures so that the exact types of vehicles (SUVs, bike-share bike, e-bike, e-scooter etc.) are recorded at the time of collisions. 

Ultimately, the emergence of the new low carbon mobility forms we have already seen on our streets – and those which will emerge – must prompt a reshaping of our legislative, traffic management, infrastructural and street maintenance regimes, which in turn will bring about a paradigm shift in how people move above – i.e. mobility practices will evolve in response to the new regime. This positive, low carbon and more diverse vision of the future of mobility needs to be kept to the fore as we seek to recast our laws and regulations around transportation.