Earlier this month Transport Malta issued a set of proposed regulations for Micromobility in the Maltese Transport System, referring to e-kickscooters and other Personal Light Electric Vehicles (PLEV).  

The current status quo on the Maltese roads, with the majority of infrastructure dedicated to the private car, and an ever increasing number of licenced cars on the road, is simply unsustainable. This has also been recognized in the government's own National Transport Master Plan for 2025 and Transport Strategy for 2050. We urgently need to prioritise a shift to modes of transport that are less polluting, use less space, and are less dangerous to vulnerable road users.

Instead of directly focusing on the challenges and dangers of e-kickscooters, why isn't there more consideration for the potential to shift transport from private car use to a cleaner and leaner mode of transport that could be a suitable solution for the many short trips that occur in Malta? The average trip distance in Malta is only 5.5km, with many of the shorter trips occurring in the congested urban core. While there is a risk of collisions between scooters and motorized vehicles, as well as between scooters and pedestrians and cyclists, these risks should not be inflated, especially in comparison with the risks that motorized vehicles present to vulnerable road users. If the aim is to increase road safety for all, the most effective measure is reducing vehicle speeds. Many European cities are currently in the process of further pedestrianizing their city centres, restricting vehicular access and reducing vehicle speeds in an effort to create safer urban areas, with less air pollution and increased liveability and quality of life. One would expect Transport Malta's Sustainable Mobility unit to also see the opportunities provided by micromobility solutions and promote their use, rather than seeking to regulate them to the extent that it becomes unlikely for people to make the switch.

The proposed regulations are disproportionate and overly burdensome on the e-kickscooter user. Demanding that a user is in possession of a driving licence means they have to be over 18 years of age (and most likely already in the possession of, or having access to, a private car), when a lower minimum age (such as 12 in France, 14 in Germany and 16 in the Netherlands) could allow teenagers to obtain more freedom and flexibility to move around, and kick-start the formation of mobility habits that are not necessarily centred on the ownership and use of a private car. The obligation to pay a registration tax and annual circulation licence goes completely contrary to the government's own electromobility policy (which exempts all electric vehicles from registration tax, as well as the first 5 years of circulation licence), and is higher than the circulation licence fee for a 125cc motorcycle, which is bigger, heavier and capable of higher speeds: €10 annually versus a proposed €25 for e-kickscooters. The fines are also disproportionate when compared to fines for contraventions by drivers of motorized vehicles.

Rather than over-regulating a mode of transport that could provide an alternative to the private car, this policy should seek to promote the use of smaller, cleaner and slower-moving vehicles and create safer streets for all road users through means that have been well-researched and implemented with positive results elsewhere:

• Create a network of traffic calmed roads, where vehicle speeds are reduced to 30km/h, so that roads can be shared by different transport users, including vulnerable road users. Where speed limits are higher, prioritise the creation of separated infrastructure for pedestrians and bicycles/scooters according to accepted standards, e.g. for cycling infrastructure.
• Adopt a transport policy hierarchy based on safety, vulnerability and sustainability: prioritising walking, cycling, micromobility and public transport over private car use.
• Protect vulnerable road users by adopting the system of 'presumed liability', which puts the onus on drivers to take responsibility to drive in a way that minimizes the risk of injury to vulnerable road users. Presumed liability has been adopted by the vast majority of EU countries.
• Invest in enforcement of illegal parking, over-speeding, driving under influence, and mobile phone use while driving, in order to promote road safety for all.