From: 2019
Mobility Task Force September 16, 2019 To: City of Dallas Department of
Transportation Re. GDPC’s suggestions for the next round of rental bike and
scooter regulations:
We (the
Mobility Taskforce of GDPC) have been monitoring developments in the
micro-mobility space since our visit with City staff in May. Clearly, the
current pace of change is unprecedented, and warrants continued study. Our
taskforce is greatly encouraged by the resourcefulness and energy of the Dallas
Department of Transportation (DOT) staff. We’ve committed to add our voices –
as planners, architects, engineers and citizen-activists – to the many good
ideas that are already being considered by Dallas DOT. Please consider the
following comments in that context.
1. Micromobility or “mi-mo” (pronounced “my-mow”) is rapidly
emerging as a practical alternative to the automobile. In addition to walking,
scooters and bike--share rentals offer “first mile-last mile” connectivity to
the transportation mix, perhaps as viable alternatives to driving automobiles,
perhaps in many cases as a default form of close-in urban mobility. We applaud
Dallas DOT’s minimal regulatory approach in the 2018 extension of the Dockless
Mobility pilot. This allowed everyone to learn from experience, as the
technology and business models have evolved.
2. Dallas, along with numerous other cites that permit
dockless platforms, has experienced widespread flaunting of improper usage on
our urban sidewalks and streets. For mi-mo to function properly, Dallas will
need to adapt its street configurations and identify acceptable staging
locations to better accommodate them in an organized and predictable fashion.
Whatever course the city decides from here, most area leaders and stakeholders
are calling for alternative street designs. Concepts such as “complete streets”
and “micromobility (bike) lanes” (or mi-mo lanes) must be addressed in any
infrastructure redesigns, and the associated policies to accommodate wise
choices in both these areas will be critical to the success of accommodating
these modes.
It is apparent that the device operators (vendors) see
potential for substantial revenue from rentals. We believe the City should use
the permitting process to generate a revenue stream in order to fund mi-mo
infrastructure.
3. Free-for-all Device stationing, we believe, has far too
often left our sidewalks and public spaces cluttered if not obscured. The
elderly and disability communities are some of the most vulnerable when it
comes to getting from point A to point B, and e-scooters or bikes obstructing
their path can be real issues. Without proper device stationing, scooters
and bikes can become mobility barriers for these groups.
We believe that the device operators should be required to
seek the City’s approval for designated and enforced use of defined locations
for orderly rentals and check-ins at these locations. The network of such
stations must be sufficiently dense yet broad enough to provide practical
service. We recommend these be located within a 10- minute walk from most
trip-origins or destinations, and probably should be closer together throughout
the urban core, i.e. a 5-minute walk away. While you are at it, why not making
scooters available for free or low cost in exchange for being good ‘sidewalk
stewards?
4. Increase mi-mo availability in underserved communities.
This is not intended as exploitation; but is an acknowledgement of the city’s
underlying economic and social inequalities. We encourage a policy of requiring
operators to make devices available in underserved neighborhoods, and offer
some other option for the rental of these devices. You might look into
“supplemental currencies” offering user points through volunteer work or
picking up trash. The operators could perhaps partner with the city for certain
initiatives like this. I think this is particularly important for those with
disability who have difficulty making a steady income.
5. Establish time-of-day limitations and other safety
interventions. We appreciate Dallas DOT’s focus on public health and safety
aspects of these new forms of mobility, especially given the alarming incidence
of trauma arising from use of e-scooters in particular. Given recent rises in
hospital admittances due to e-scooter crashes, limiting nighttime use may help
reduce incidences of irresponsible use. Encouraging use of helmets while riding
is the most important of all interventions.
6. Consider requiring more ergonomically stable devices. We
believe the current scooter designs (operated while standing, on small diameter
wheels, at speeds exceeding 12 mph) may be inherently dangerous for all but the
most skilled riders. And even then, only on smooth pavement. Add to that, the
power capabilities, the exceedingly-high centers of gravity and short
wheelbases of current models – and this calls for replacing these with devices
that users can more safely operate. Wireless-controlled ‘speed governors’ and
applications of “geofencing” could also do much to hamper unsafe use. Links to
recent articles on e-scooter safety:
Centers for Disease Control and Prevention – November 2018 https://www.cdc.gov/eis/conference/dpk/Dockless_Electric_Scooter_Related_Injury.html
STREETSBLOG USA – May 2019 https://usa.streetsblog.org/2019/05/03/we-still-dont-have-a-very-good-read-on-e-scooter-safety/
ScienceDirect – September-October 2019 https://www.sciencedirect.com/science/article/abs/pii/S0735675719302153
7. Require access to dockless customer usage data,
preferably through access to the device vendors’ application programming
interface (API) data. Provision of this data is key to the City being able to
identify and program infrastructure improvements for inclusion in future
capital improvement bond programs.
8. Operations. Scooters as currently designed and used by
certain demographics are inherently unsafe on Dallas streets as designed. We
urge adoption of “complete streets”, lower design speeds and other “calming”
provisions to address this.
9. Finally,
the Mobility Taskforce believes that the device providers must do much more to
educate users as to risks and liability. Of major concern are the sweeping
“user agreements” that shelter operators from any substantial liability in the
case of crashes and/or injuries. Another is the repeated, improper and unsafe
use of devices by some renters. We believe a clear path to operator liability
must be ensured – even to barring rentals by repeated scofflaws. An appropriate service
area map maintained on City websites or Apps might also nhelp make usage
rules more clear and prevent further confusion as they City begins implementing
further regulation.
The City of
Dallas DOT, in its wisdom, has foreseen the possibility of a new transportation
hierarchy – one that could reverse some of those acknowledged adverse impacts.
But in order to better accommodate these devices, it’s imperative that City
leadership be aggressively proactive in implementing the necessary elements of
the Complete Streets and other current design manuals.
We, the
Mobility Taskforce of the Greater Dallas Planning Council, offer our emphatic
encouragement, and hope that City staff will achieve the political support for
making these changes going forward. We pledge to do all that we can to help the
City achieve these objectives. We look forward to continued collaboration as
the City staff prepares the next set of policies and regulations. Please advise
us of any specific steps we may take to be of further assistance.
Sincerely,
2019 GDPC Mobility Taskforce W.J. ‘Bud’ Melton III, Chairman WJM/JEC
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