kiss engineering

From https://www.gov.ie/en/consultation/d1531c-public-consultation-on-personal-powered-transport/

I give my comments on whether Ireland should permit these transporters, based on my interest, and also my experience of using them in Helsinki, Finland for the summer of 2019.

Question 1: What category of stakeholder do you represent (e.g. private, company, organization etc)?
Private Individual

Question 2: Do you think that the use of PPTs should be permitted in Ireland and why?
Yes, because:
- They are a cost effective, relatively health & eco friendly means of getting around
- They reduce burden upon mass transport & private motor vehicles
- They can reduce harm to pedestrian due to motor vehicle crashes
- They are fun!

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, because:
- all of these types of PPTs are more eco & public health friendly than people sitting in private motor cars
- it will cause confusion to people if some categories are allowed and others aren't (not to mention that it would lead to the current situation we are in, where a modern technology is illegal)
- if there are infrastructural reasons to not permit certain PPTs, the root cause issue of infrastructure should be addressed, as the benefit of reduced car dependance / less public transport load is worth it

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)?
Not in the current understanding of such a registration plate (to be visible to other road users) in case of problems/hit-and-runs, however given the experience of many Irish people with their bicycles being robbed, serial numbers should be mandatory to aid with this situation

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) In general, no, as it would be difficult to police (using what ID card?), and in general these PPTs currently do not have much crashing force due to their low mass & speed. However, consideration should be given to having an age limit which one must be above to drive higher speed PPTs, such as those which can exceed a speed limit of 20kmh & above a particular weight, with a resultant higher impact inertia.
I am in favour of na Gardaí having the authority to fine, or seize & auction these PPTs if people, of any age, are "acting the maggot" - the experience in Helsinki suggests fines are effective ( https://yle.fi/uutiset/osasto/news/unlucky_foursome_slapped_with_first_e-scooter_fines_in_finland/10902305 )
(b) In general no, as the normal reason for considering licensing is to protect other road users. Experience in Helsinki, Finland suggests that most injuries are to the scooter users themselves ( https://yle.fi/uutiset/osasto/news/rent-a-scooter_injuries_increasingly_common_in_helsinki/10889946 ) so this is an unnecessary bureaucratic burden which might inhibit people from taking on these PPTs, which reduce use of combustion powered transport. Proper enforcement to facilitate users in using them in a safe route rather than a footpath would be more useful.
Consideration could be given to requiring licensing for users who wish to use PPTs which travel at a higher speed e.g. above 20kmh, as those types of PPTs would have a higher impact force were there an issue - technological developments in higher density batteries will likely lead to higher speed PPTs.

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, for three reasons:
- as these PPTs are generally quite light, and not too fast presently, their scope for causing damage to other people or property is limited by physics
- there is a strong incentive to the users' personal health to not crash, as they have practically no protection
- as a selling point to encourage a modal shift away from private motor vehicles, by making PPTs more attractive as the simpler choice

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, for parking & low speed use only
(b) Yes
(c) Yes
(d) Yes

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) I suggest that unrestricted use be permitted if the PPTs are limited to a speed such as 20kmh (which works well on e-scooters in Helsinki), and above that speed driver licensing (e.g. a rewording of the moped AM license) should be in place to give users basic skills / present a higher threshold to entry for a more dangerous vehicle.
Note that a function I have seen in Helsinki which might be useful in Ireland is to restrict the speed of for-hire PPTs in certain high trafficked areas, as detected by the GPS location of the user's mobile phone.
(ii) (c) 50kph, so that these can be used in all suburban areas, to facilitate users living in our low density neighbourhoods

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)?
No. The reason for this head-gear & high-visibility clothing is to make motor vehicle drivers aware of vulnerable road users. This shifts the responsibility to drive responsibly to the vulnerable party rather than the driver of the 2 ton death machine. Such a requirement might also reduce adoption of PPTs as personal owned vehicles, and certainly as for-hire vehicles, which would be a shame as it reduces people's use of private motor vehicles.
What is useful is to have lights integrated to the PPTs themselves that operate when the PPT is in use - this is a good safety feature that doesn't inhibit spontaneous use by the user. The burden for this should be put back upon the scooter manufacturers & for-hire operators.

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, (b) if so, by who?
(a) in the case of PPTs that can exceed a speed and mass rating, yes, or if below, no
(b) same methodology a moped AM license is acquired presently, for those vehicles which are above a mass and speed rating.

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?
A balance has to be achieved. Many local authorities will not be ready for PPTs, and change is hard. Carrot & stick will be necessary. One way of assisting the local authorities with this change is to make it clear they must accomodate PPTs, and if they do so, they can derive an income from them, by charging the for hire operators.
For their use in a normal sense, no I do not believe the local authorities should regulate the use of PPTs (as the tendency will be to ban them locally), however for parking the public hire PPTs, my experience in Helsinki suggests that properly allocated & regular parking spaces would be beneficial to prevent clutter. Additionally, I notice that some operators now preclude users from parking in certain locations to prevent street clutter and require users to take photographs to prove responsible parking - this is something local authorities should be empowered to decide upon with hire company providers (and this could be a profit centre for local authorities if implemented fairly).
Additionally, to decide on factors such as reducing speed of for hire PPTs in highly trafficked areas, local authorities should decide upon that.
On the whole, I recommend that local authorities treat the adoption of scooters as a highly iterative process of refining their provision of public services such as carriageways, laybys for charging, speed regulation, space usage regulation etc. New challenges will arise, and a spirit of improvement will be necessary in order to successfully integrate them to our towns and cities. Programmes such as http://dccbeta.ie/ could be helpful to tie in with this.

Please provide any other comments relating to the use of PPTs that have not be address above
- Permit people to use them for start of commute & end of commute, by allowing them to take PPTs on public transport if they are foldable
- For hire companies, bear in mind their need to recharge these PPTs at night, so they will need designated parking spaces at a certain density for the service to be effective, and a lay-by to collect the PPTs nearby
- Suggest requiring for hire companies to use Renewable Electricity only to recharge the PPTs
- Suggest requiring owners including for hire companies to uphold a minimum mechanical standard of scooter (e.g. working safety lights, minimum rigidity of joints, non sticking accelerator switches, operable brakes etc.)