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 A city sidewalk with a row of electric scooters lined up on it.

CNIB Response to Government e-scooter announcement – December 2019

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On November 27, 2019 the Ontario Ministry of Transportation outlined their plans to introduce an e-scooter pilot, following the initial consultation, which took place in September. For CNIB's response to the original consultation, visit:

The government's most recent announcement brings uncertainty regarding accessibility and safety for vulnerable pedestrians and people with disabilities, including 681,000 Ontarians who are blind or partially sighted. 

Further analysis of the recent announcement 
We were disappointed to learn that the pilot will be a 5-year period. As mentioned in our original response, five years is unnecessary to gather data for a project of this scope. In its quest to be '"Open for Business", the length of this pilot puts commercial opportunity ahead of the safety of people who are blind or partially sighted. And, there is no mention of a midway evaluation process in the government's announcement, and how adaptations to the pilot will be made, if necessary. 

We are relieved that the government has reduced the maximum speed limit to 24km/hr, as opposed to 32km/hr It is more in line with the average speed of a regular cyclist with whom e-scooters will be sharing the road space. However, we still feel that 15 km/hr would be more reasonable, as it enables people to travel efficiently, but it reduces the risk of serious injury from collisions. 

The wording of the government's announcement regarding whether e-scooters will be permitted on the sidewalk is contradictory. On the list of provincial requirements within the e-scooter best practices document, it states that "E-scooters should not be allowed to operate on sidewalks – sidewalks are for pedestrians, including persons with disabilities." Yet, according to the Regulation, municipalities will have the ability to create exceptions and permit e-scooter usage on sidewalks within certain circumstances. The Regulation states:

3. No person shall operate an electric kick-scooter on a highway, sidewalk, trail, path or walkway or in a public park or exhibition ground unless,
(a) such operation is permitted by and in accordance with this Regulation; and
(b) where the highway, sidewalk, trail, path, walkway, public park or exhibition ground is under the jurisdiction of a municipality, such operation is permitted by and in accordance with a municipal by-law.

In our response to the original consultation, we recommended that e-scooters be parked in designated, permanent docking stations, similar to bike-share programs that exist in various municipalities. We were encouraged to hear that "municipalities should clearly define where e-scooters can park (e.g. setting up designated parking locations, using corrals). This will help prevent them from obstructing traffic on the road or being a nuisance on private property. Designated parking locations provide control over their use and reduces interference with the public. E-scooter parking locations should not block access to businesses, fire doors, or be located outside of restaurants and bars, etc. This will help prevent a hazardous situation." We commend the government's recommendation on this and hope that municipalities will adopt safe and sensible parking solutions for e-scooters that keep the pedestrian walkways clear and navigable. 

We continue to monitor this issue and work with stakeholders, including the provincial government, to advocate for accessible communities in Ontario. 

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

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