We welcome the publication of the SUMP Guide on safe use of micro- mobility devices in urban areas and appreciate having been consulted in the process of drawing up the guide. Also, MMfE gladly acknowledges that best practices and recommendations on the integration of micro-mobility in urban planning have been identified and that those recommendations, by encouraging safer use of such devices in urban areas, will help Europe in delivering its Vision Zero strategy.
MMfE is convinced that the guide can serve as a basis for the safe deployment of micro-mobility services in cities, making urban transport systems more accessible, affordable and sustainable. At the same time, MMfE remains open to exchange and discussion with policymakers and other actors.
The SUMP Guides recommendation acknowledges that improving the safe use of micro-mobility devices requires efforts and collaboration between providers, authorities on different levels and other actors. In particular with view to the upcoming Commission Recommendation to Member States on the national programme to support regions and cities in the roll-out of effective sustainable urban mobility plans as announced in the 2021 New Urban Mobility Framework, MMfE is sharing feedback on the SUMP Guide to constructively contribute to upcoming measures that promote micro-mobility in the EU.
Safety and infrastructure
We fully endorse the ambition of integrating micro-mobility into Vision Zero. Research reveals that reliance on the private car is a considerable barrier to achieving the vision for a safer future. As such, the modal shift away from cars is a key objective in achieving Vision Zero. Reducing fatalities and injuries across the EU, regardless of the means of transport, should be pursued by all cities. Most of them have realised the importance of allocating sufficient space to pedestrians, cyclists, and users of e-scooters, to contribute to the overarching goal of reducing the numbers and use of private cars. Making the step from realisation to implementation is often challenging for cities. MMfE, therefore, calls on the European Commission to support cities in creating more space for these user groups, through infrastructure investments, by welcoming shared mobility operators, and through cooperation with local mobility actors.
Infrastructure and speed
One way to rethink and reallocate urban space is by introducing pop-up bike lanes, which is one step towards redistributing urban space equitably. Ideally, these bike lanes are separated from traffic with more than just paint. After all, paint is not an infrastructure and does not protect vulnerable cyclists or users of e-scooters or e-bikes. Protected infrastructure empower urban dwellers to pursue sustainable mobility solutions. It is important to ensure that the speed set for e-scooters reflects the infrastructure available and who e- scooters share the road with. For example implementing a speed limit that is much slower than average bike speeds can cause risks by disrupting traffic flows. Also, excessively slow speeds can be dangerous for e-scooter riders and increase the likelihood of a safety incident occurring.
While we welcome the findings on safety and infrastructure in the guide, a greater emphasis should be made throughout the guide on the need for better infrastructure for micro-mobility. We strongly believe that the focus should be on prevention rather than protection. Cities can prioritise prevention through the creation of divided and stand-alone infrastructure which separates e-scooters, and other vulnerable road users from cars. Even though prevention is the most powerful way to protect vulnerable road users from harm, MMfE is aware that there will inevitably be situations where they and motor vehicles will need to interact.
As mentioned in the previous paragraph, due to the inevitability of some accidents, we strongly recommend our users wear a helmet. This should however not be made mandatory, as this is known to limit the uptake of shared and sustainable modes of transport, which in turn makes riding less safe due to the safety in numbers phenomenon.
It is common knowledge among cycling advocates that imposing a helmet requirement may do more harm than good. When municipalities implement a helmet requirement, ridership drops significantly. Fewer micro-mobility riders mean less safety for the fewer riders on the road, because less investment is made in safe infrastructure and cars do not learn or expect to share the road. Introducing a bikeshare program, for example, is associated with a decrease in the absolute number of bicycle accidents, even though the number of people riding bicycles increases and a smaller portion of those riders wear helmets (see here). The United Kingdom determined not to impose a helmet requirement for bicycles because it found that it was ineffective and negatively impacted ridership (see here); it is applying the same logic to e-scooters.
Driving under influence
We strongly support that intoxicated users of micro-mobility services should be treated in the same way as users of other vehicle types, which requires both awareness raising and enforcement by the police.
Importance of training
With the increasing availability of micro-mobility services, MMfE welcomes the recommendation to engage with vulnerable road users to understand their concerns and to offer a platform for exchange, for the benefit of the citizens and the urban mobility system. Beyond these exchange opportunities, we encourage the offer and promotion of training for micro-mobility and road users, to inform them about risks and rules. MMFE welcomes the recommendation to educate both micro-mobility users and other road users on how to safely interact with new modes of transport. This should be done by both national bodies as well as operators. This should start at the primary school level, to ensure that future road users are familiar with the different vehicle types that they will encounter when independently navigating our cities’ streets.
Micro-mobility data and insights
Data from micro-mobility services offers potential for cities and authorities to better understand mobility patterns and weaknesses of the local transport system.
It has the potential to support human-centric urban planning based on observed mobility patterns and demand. It is in this context that MMfE members share data with a large number of cities they operate in.
Nevertheless, based on MMfE’s experience, we have noted that the full potential stemming from micro-mobility data is still untapped. Cities do not consistently have the capacity to manage our data efficiently, which has resulted in our data primarily being used to monitor the micro-mobility operations instead of supporting cities’ urban planning and traffic management tasks to encourage the uptake of greener transport modes.
Furthermore, the absence of standardized framework or performance indicators for how micro-mobility data can support cities’ sustainability policy objectives has made data-sharing an inefficient task overall. Some member states and cities have initiated the design of tailored standards for micro-mobility data sharing instead of using existing industry-wide ones or have very specific data requirements. MMfE members also noted that the privacy safeguards needed to share micro-mobility data in a GDPR- compliant manner are not always fully clear to city authorities.
We strongly believe that the aforementioned points and challenges should be addressed at EU-level in order to leverage the potential that micro-mobilty data presents in shaping sustainable urban environments.
Finally, we also advocate for introducing a systematic and universal methodology to monitor accidents across Europe, with a clear distinction made to incidents that happen with privately owned and shared vehicles, for all vehicle categories.
We endorse the Guide’s recommendation that European institutions and standardisation bodies should agree on the classification and safety standards for micro-mobility devices. This would create consistent safety standards and provide micro-mobility providers with clarity as regards investment in new vehicles. In particular, vehicle standards should not be set at city level as this leads to a patchwork of different standards across the EU.
Requirements set out in tenders should be aligned with city goals, in particular with the objective of reducing the number of private cars, increasing accessibility and redesigning urban space. In addition, licenses should cover a period of at least 12 months, better 24-36 months, which is also reflected in the SUMP Guide. Moreover, limits to the fleet size do not allow providers to adjust to the changing and evolving need for additional supply of micro-mobility devices. Instead of imposing direct caps, alternatives such as dynamic caps and seasonal allotments could be more effective to match demand with supply.
It should ideally be left up to the cities to choose the instrument they want to apply in choosing operators, where a tender is merely one such instrument. Other solutions that cities can put in place are the introduction of memoranda of understanding, licenses, authorizations and letters of intent.
Finally, cities, regardless of the type of selection procedure chosen, should not include selection criteria based on the request to micro- mobility operators of economic contributions or revenue sharing schemes.
Solutions for fixed docking are not the best way to ensure compliant parking and the suggestions on parking and docking should and leave no room for flexibility at the city level, taking the specificities of the city into account. Physical docks are expensive and inflexible, and require significant city staff time to plan locations and coordinate build out. In neighborhoods with less space and more foot traffic, for which a city has particular concerns about micro-mobility parking, a combination of light touch infrastructure and virtual tech to ensure rider compliance is sufficient, as well as affordable and flexible. The Norwegian Institute of Transport Economics (TØI) analyzed the implementation of scooter parking infrastructure and found no difference in efficacy between heavy infrastructure, e.g. racks, and spaces that are indicated only with paint and geofencing5. The study also found parkings compliance is higher when parking spaces are located in places that correspond to common ride end areas.
Environmental impact and sustainability
In just a few years, micro-mobility operators have managed to significantly improve the environmental performance of their e- scooter vehicles. This has been achieved through improved vehicle design (i.e. robustness, repairability), the increased usage of recycled materials and, most importantly, by extending the lifespan of our vehicles. Whilst the SUMP guide points to a 3-6 months lifespan of e- scooters, our latest generation of vehicles have been redesigned in a way that their lifespan was extended to 5+ years. An article published in 2020 showed that the lifespan of e-scooters had already increased to 24 months; this has been extended further as we continue improving robust vehicle design and repairability, significantly reducing e-scooters’ environmental footprint.
These developments have made e-scooters a sustainable mobility choice that has a strong contribution to make in a diversified transport mix. As outlined in the SUMP guide, it is indisputable that e- bikes and bicycles generate important health benefits as an active way to travel. In this context, the value generated by e-scooters should not be benchmarked against other sustainable modes but rather looked at as one piece of a multimodal transport network that is able to meet the various mobility needs and use cases of urban citizens.
For example, our internal research indicates that whilst e-scooters are primarily used for shorter distances (i.e. to complement public transport journeys for the first and last mile), e-bikes tend to be used for longer, mid-range distances. This points to the need for a variety of sustainable choices to simultaneously exist and complement one another to meet evolving mobility needs.
The ITF confirms this finding by highlighting that ‘micromobility enriches urban mobility and has the potential to change behaviour and transition to low-carbon urban mobility’ and that widespread availability of e-scooters, particularly for first/last-mile connections, could improve access while shortening commuting time and reducing reliance on cars (ITF, 2021).
In light of the upcoming Commission Recommendation to Member States on the national programme to support regions and cities in the roll-out of effective sustainable urban mobility plans, MMfE calls on the European Commission to:
- Advocate for integrating micro-mobility in SUMPs as an enabler to cleaner, less congested, more inclusive and liveable cities;
- Substantiate the role that micro-mobility can play in moving away from cities’ and citizen’s dependency on private cars;
- Endorse micro-mobility as one component of a diversified urban mobility system;
- Emphasise the crucial role that micro-mobility can play in complementing public transport and suggest member states to put in place mechanisms that favor the integration of micro- mobility into the public transport system;
- Propose that member states adopt measures that discourage the use of cars, particularly in city centers;
- Encourage member states to use revenue from car parking and fines to invest in infrastructure for sustainable mobility.