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London Sight Loss Council: open letter on rental e-scooter trials

To Transport for London, London Councils, participating London Boroughs and appointed electric scooter providers

The London Electric Scooter trial

We are responding to the recently commenced electric scooter (E-scooter) trial that is set to run in selected London boroughs for the next 12months.

The London Sight Loss Council (LSLC) was established in January 2021 and our objective is to provide a platform and advocate for people living and working in the city who are blind and partially sighted. We aim to achieve this by campaigning on key issues that affect people who are blind and partially sighted in the capital and thereby seek to influence London’s stakeholders and authorities to deliver positive change. The LSLC comprises 14 members and we are representative of the diversity of the blind and partially sighted community across all regions of the city.

The LSLC believes London’s streets and pavements must provide a safe and unobstructed environment which enables all pedestrians to make their journeys with confidence and free from anxiety.

Antisocial practices such as on-pavement vehicle parking and abandoned dockless bicycles, are increasingly prevalent in London. Pavement obstructions such as these disproportionately compromise the safety of vulnerable groups including blind and partially sighted people.

It is in this context that the LSLC is keen to ensure the E-scooter trial does not introduce additional hazards for those with sensory disabilities such as visual and/or hearing impairments.

Evidence from use of E-scooters in other cities and regions suggests there is a material risk of injury and trauma to vulnerable pedestrians. While we welcome a commitment to include safety measures in the design of the operation of the trial in London, we would highlight the following risks that we are concerned may not be mitigated by the intended safeguards:

  • Conduct of e-scooter riders – The safety of pedestrians and other highway users is predominantly the responsibility of the E-scooter rider. It is not clear what credible sanctions and penalties will be in place to ensure riders do not ride on pavements and to ensure E-scooters are docked securely. We also seek assurance that sufficient resources have been secured to enforce rider misconduct during the trial;
  • E-scooter docking bays – It is essential that designated docking areas for E-scooters are located well away from pavements and pedestrian areas. Evidence from electric bicycle providers in London is unambiguous in relation to the hazards posed to blind and other disabled pedestrians. We understand the three selected providers will have responsibility for retrieving E-scooters not secured in designated docking areas, however, we would like to see detail on how this will be monitored and the regime for rectification of poor performance, including the sanctions for non compliance;
  • Obligations on E-scooter providers – We note the requirement on providers to ensure new riders complete a safety course, but it is not clear if there are minimum standards to ensure the content is of sufficient quality. For example, ensuring riders are fully aware that blind and partially sighted pedestrians may not see or hear E-scooters. There must be information exchange between the providers regarding sanctioned riders so repeat offending can be prevented. E-scooter technical specifications should include Acoustic Vehicle Alert Systems (AVAS) and most visible size and format specifications for registration plates;
  • Participating London Boroughs – At the launch of the trial 10 London Boroughs have been identified in scope of the trial. It is understood boroughs have the primary input into the design of the E-scooter operation in their areas including location of docking bays, “no go” and slow zones. We therefore would appreciate detail on the engagement process for individual participating boroughs and the criteria for admitting additional boroughs into the trial;
  • Private e-scooters – Use of private scooters on public highways is illegal yet continues largely unchecked, a likely consequence of the trial is to encourage use of private E-scooters on streets and pavements. The primary trial mitigation against this appears to be a communications and awareness campaign for the first 10 -12 weeks of the trial. We believe greater communications and stronger measures will be required to dissuade private E-scooter use including additional enforcement resources; and
  • Engagement, monitoring and complaint reporting – The channels of engagement for the duration of the trial are not transparent. Similarly, accountability between London Councils, TfL and participating boroughs is unclear. There should be flexible and accessible engagement opportunities for voluntary organisations like the LSLC who have limited time and resources. We would also like to understand what data and KPIs from the trial will be made available to external stakeholders and the availability of forums for interrogating and challenging the performance of the trial. Finally, there must be a simple, accessible and well publicised complaint reporting process facilitated by TfL. This must recognise that blind and partially sighted complainants will not have information such as the e-scooter registration number or the provider concerned, photographic evidence etc.

 

We look forward to engaging with TfL, London Councils and participating London boroughs throughout the progress of the trial. In the first instance we would like to invite a representative to discuss these matters with members of the LSLC at our next meeting.

 

Yours sincerely,

 

The London Sight Loss Council

Published 14 June 2021

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