Response to the Queensland Parliamentary Committee Report on E-Mobility
The Sunshine Coast Bicycle User Group (SCBUG) welcomes the Queensland Parliament’s State Development, Infrastructure and Works Committee report on e-mobility safety and acknowledges that some recommendations – particularly around infrastructure investment, battery safety, and tighter import controls on non-compliant devices – are sensible and broadly consistent with our submission.
However, SCBUG has serious concerns raises that the report contains fundamental flaws which, if translated into law, would cause significant harm to disadvantaged communities and undermine the legitimate benefits of e-mobility in Queensland.
This response sets out our key concerns and calls on the Queensland Government to reject or substantially revise several of the committee’s core recommendations before proceeding with legislation.
1. The Report Fails to Distinguish Legal E-Mobility from Illegal Motor Bikes
The most serious deficiency in the committee’s report is its failure to differentiate between clearly and consistently:
Compliant, low-powered e-bikes and personal mobility devices (PMDs) that are already legal under Queensland law; and
High-powered, illegal electric motor bikes that exceed 250W output and 25km/h – devices that are already illegal and should simply be enforced against as motorcycles.
Much of the public concern driving this inquiry was fueled by media reports conflating the two categories. The committee has adopted this conflation rather than corrected it. The result is a report that punishes responsible users of legal, low-powered devices for the conduct of a small minority using illegal machines.
Recommendation 11, which proposes that all e-mobility devices with an electrical power source be defined as ‘motor vehicles’ to simplify enforcement, is particularly alarming.
Applied without careful qualification, this single recommendation could retrospectively criminalise the use of legally purchased, compliant e-bikes and e-scooters across Queensland.
The Queensland Government must insist on precise, evidence-based distinctions in any resulting legislation between compliant devices and illegal motor bikes.
2. Licensing for Legal E-Mobility Riders is Disproportionate and Harmful
Recommendation 13 proposes that riders of compliant e-bikes and PMDs be required to hold at least a Queensland Class C learner license. SCBUG opposes this recommendation strongly on the following grounds:
No evidence base
The committee was presented with no credible evidence that riders of legal, low-powered e-mobility devices pose a greater risk than conventional push bike riders – who require no license. The report does not establish this evidential threshold yet proceeds to recommend a major and unprecedented licensing regime.
Discriminatory impacts on vulnerable groups
The committee itself heard compelling evidence that e-mobility is particularly valuable to:
People with disabilities who cannot ride conventional bicycles.
Low-income earners who rely on e-mobility as affordable transport.
Women, who disproportionately benefit from e-mobility’s accessibility and safety features.
Requiring these groups to obtain a Class C learner license – a process designed for motor vehicle drivers – creates a significant practical and financial barrier. Many users in these categories do not hold or wish to hold a driver’s license; that is precisely why they use e-mobility. The recommendation was made without any assessment of this impact.
Perverse safety outcomes
Queensland road crash data consistently shows that motorists, not e-mobility riders, are the primary cause of crashes involving vulnerable road users. Requiring e-mobility riders to sit road rules test every three years while motorists who cause the overwhelming majority of such crashes never need to have their road rules knowledge retested is an outcome that is as perverse as it is unjust.
Damage to Queensland’s international reputation
With the 2032 Brisbane Olympics approaching, tens of thousands of international visitors will expect to use e-mobility to navigate the region. Requiring overseas visitors to produce a Queensland Class C learner license before riding a hire e-scooter would create an international embarrassment and generate significant negative publicity at precisely the moment Queensland is in the global spotlight.
International evidence on licensing
The experience of London’s shared e-scooter scheme is instructive. London’s scheme requires riders to hold a driving licence; Brisbane’s does not. Despite London’s far superior separated infrastructure for e-mobility, Brisbane’s e-scooters are used between twice and almost eight times more than London’s, depending on the metric applied. Licencing requirements directly suppress uptake.
3. A 10 km/h Footpath Speed Limit Would Make Legal E-Bikes Unviable
Recommendation 14 proposes a maximum 10 km/h speed limit for all e-mobility devices on all footpaths. This recommendation appears to have been made without any consultation with the Department of Transport and Main Roads (TMR) about minimum safe cycling speeds.
A 10 km/h limit would render riding a compliant e-bike for transport purposes unviable. Walking pace is approximately 5 km/h; a speed limit of 10 km/h on footpaths would mean e-bike riders are barely faster than pedestrians, making any meaningful journey impossible. The practical effect would be to ban legal e-bikes from footpaths entirely.
SCBUG recommends the Queensland Government consult properly with TMR and road safety experts before adopting any blanket footpath speed limit, and consider differentiated limits based on pedestrian traffic levels rather than a single impractical universal limit.
4. What the Committee Should Have Recommended
SCBUG’s original submission to the inquiry outlined a range of evidence-based measures to improve e-mobility safety that would not have required licensing or punitive restrictions on legal device users. We note with concern that the committee’s report has failed to engage with these proposals. Among the measures that deserve proper consideration:
Strict enforcement of existing laws against illegal, high-powered devices, treating them as motorcycles as they already should be under current law.
Tighter import and point-of-sale controls to prevent non-compliant devices entering the Queensland market (we support Recommendations 9 and 10 in this regard).
Mandatory road safety education targeting motorists on the rules for giving way to e-mobility riders and other vulnerable road users at intersections.
Investment in separated infrastructure – the single most effective safety intervention identified in academic research on e-mobility (Recommendation 4 is supported).
Community education campaigns, including programs such as the Sunshine Coast-developed ScootScool e-scooter education program, targeting young riders and their families.
Technology-based speed management in high pedestrian zones, using geofencing by shared scheme operators rather than blanket legislative limits (Recommendation 18 is supported).
5. SCBUG’s Call to the Queensland Government
The Sunshine Coast Bicycle User Group calls on the Queensland Government to:
Reject Recommendation 13 (licencing of legal e-mobility riders) unless and until a full regulatory impact assessment is completed demonstrating a clear safety case and assessment of impacts on disabled people, low-income earners, and other disadvantaged groups.
Reject or substantially revise Recommendation 14 (10 km/h blanket footpath limit) after proper consultation with TMR and road safety experts.
Ensure any legislation arising from Recommendation 11 contains explicit, unambiguous protections for riders of compliant, legal e-bikes and PMDs.
Direct enforcement resources at illegal high-powered motor bikes, not legal low-powered e-mobility users.
Implement the infrastructure, education and enforcement measures outlined above that do not create barriers to the beneficial use of legal e-mobility.
E-mobility, used responsibly and on compliant devices, is a safe, affordable, and sustainable transport option for Sunshine Coast residents – particularly those who face barriers to car ownership or conventional cycling. SCBUG will continue to advocate for policy that promotes and protects this growing and beneficial community.
For further information, contact:
Sunshine Coast Bicycle User Group (SCBUG)
www.scbug.org.au
