CNIB Foundation Response: E-Scooter Consultation Ontario Ministry of Transportation – September 2019

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CNIB Ontario welcomes the opportunity to respond to the government regarding an e- scooter pilot project in Ontario. There are more than 681,000 Ontarians who are blind or partially sighted, and many more vulnerable pedestrian users who are living with other disabilities. 

Given the potential safety risks that e-scooters could pose to pedestrians with sight loss, we recommend against introducing e-scooters to Ontario roads. 

However, as the government is consulting on how, rather than if, e-scooters should operate in our province, we are providing our feedback based on the premise of how to mitigate the risks for Ontarians who are blind or partially sighted. Our comments fall into two broad categories – e-scooters on sidewalks and e-scooter regulations.

E-scooters on sidewalks
We agree with the government's proposal that e-scooters should only operate on roads similar to where bicycles can operate, as their speed is closer to that of a bicycle, compared to a car or pedestrian. However, cycling on sidewalks is a pervasive issue across the province, which poses a risk to pedestrians with sight loss who may not be able to see a cyclist or an e-scooter coming towards them on the sidewalk or hear an e- scooter approaching them from behind. This could lead to collisions, resulting in injuries.

It is unfortunate that some e-scooter users will choose to ride on the sidewalk rather than on the road. For this reason, we agree with other transportation stakeholders that are calling for a maximum 24 km/h cap on e-scooter speed, ideally 15km/h rather than the 32 km/h proposed by the Ministry of Transportation. This is in line with many jurisdictions in the United States that permit e- scooters and it's more in line with the average speed of a regular cyclist with whom e-scooters will be sharing the road space. It also means if someone operating an e-scooter does decide to ride on the sidewalk, it slightly reduces the risk of a more serious injury at the higher speed of 32 km/h. There is no reason for Ontario to introduce higher speed limits than other jurisdictions.

Our second concern with e-scooters is sidewalk parking, which is not addressed in the consultation. We are opposed to any system where riders can leave their e-scooter in any location once their trip is complete. For people who are blind or partially sighted, it is necessary to have a clearly defined path of travel that is free of obstruction for safe, independent travel. Allowing e-scooters to be parked anywhere creates a potential tripping hazard and risks injury to pedestrians, particularly people who can't see that the hazard is there. We recommend e-scooters be parked in designated, permanent docking stations, similar to bike-share programs that exist in various municipalities. A bicycle must be parked at bike parking and a car must be parked in a designated parking space, so e-scooters should follow similar regulations. 

E-scooter regulations
With regards to the specific items listed in the pilot, we recommend:

  • The proposed pilot period be reduced from five years to one year. This allows ample time for the data to be gathered and, if there are major concerns, they can be addressed in a timely manner. 
  • It should be explicitly stated that e-scooters are not permitted to ride on sidewalks, so there is no confusion. 
  • Minimum operating age should be 18, in line with other jurisdictions that permit e- scooters.
  • Regulations regarding the distracted operation of e-scooters are mitigated against and dealt with, as needed. 

Testimonial 
"I have had low vision for over 50 years and use a white cane. I’ve had many near misses with cyclists riding on sidewalks illegally. They often berate me for not getting out of their way. E-scooters present a far greater threat because of their speed. I am very concerned that e-scooters will threaten the safety of people who are blind or have low vision" –Fran, Ottawa.

Contact:
Kat Clarke
Manager, Advocacy and Government Affairs (Ontario & Quebec)
CNIB Foundation
T: 416-486-2500 ext. 7651
Kat.Clarke@cnib.ca

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