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Brief to: The City of Toronto Infrastructure and Environment Committee

Brief From: John Rae
Subject: Opposition to the Introduction of E-Scooters on Toronto Streets Date: July 29, 2020


My name is John Rae. I am totally blind, a long time human rights advocate, and a member of the Boards of three disability rights organizations, including the Alliance for Equality of Blind Canadians (AEBC). I live in downtown Toronto. I am opposed to the introduction of E-scooters onto the streets of Toronto or elsewhere in Canada.

Legal Arguments Against E-Scooters:

The Ontario Human Rights Code (OHRC) is designed to prohibit discrimination against various groups, including persons with disabilities. The Accessibility for Ontarians with Disabilities Act (AODA) was enacted to help remove barriers and prevent the introduction of new barriers.

Taken together, these two statutes argue against the introduction of e-scooters, which I maintain will represent a new barrier to the safe and unobstructed use of Torontos pathways.

Accessibility in Toronto:

Despite the AODA, Navigating throughout Toronto for persons who are blind, deafblind and partially sighted is becoming more of a struggle, and not less so. Blind pedestrians must navigate around construction sights, deal with paper boxes and sandwich boards on sidewalks, contend with quiet automobiles when crossing streets and deal with subways without fare collectors at booths, who not only collected fares but who also provided lots of information on the layout of subway stations and possibly even the area nearby the station. These obstructions to pedestrians are now being further exacerbated by the extension of space for patios. Again, I must emphasize the AODA was enacted to remove barriers and prevent the introduction of new barriers.

The Toronto Accessibility Advisory Committee, a body required under the AODA, recommended that City Council prohibit the use of e-scooters in public spaces, including sidewalks and roads.

The Staff Report states:

“On February 3, 2020, the Toronto Accessibility Advisory Committee recommended City Council prohibit e-scooters for use in public spaces including sidewalks and roads, and directed that any City permission granted to e-scooter companies be guided by public safety, in robust consultation with people living with disabilities, and related organizations serving this population.”

The World Blind Union Statement on E-Scooters:

The World Blind Union (WBU) has developed a statement on e-scooters, which acknowledges that E-Scooters can expand personal transport options by providing a relatively cheap mode of transport that can go where buses don’t.

At the same time, the WBU Statement lists a number of problems with the introduction of e-scooters, including:

  • The quiet nature of these devices,
  • Excessive speed on pedestrian pathways,
  • Randomly parked or abandoned scooters (particularly when lying down) as those can be obstacles for blind, partially sighted and older, frail people to fall over and trip on,
  • A lack of warning systems,
  • Lack of regulations and/or a piece-meal approach by local government/territorial authorities on where the use of E-Scooters is permitted creates unclarity among the public and has led to scooters are trafficking pedestrian pathways,
  • Lack of traffic rules for micro-mobility devices inflicts on the city’s possibilities to sanction users which are not abiding to traffic regulations or “common sense” of traffic behaviour


As the AODA Alliances brief to this Committee points out: “Even before the COVID-19 pandemic, our hospitals and emergency rooms were backlogged, resulting in the scourge of hallway medicine. The COVID-19 pandemic has imposed unprecedented added demands and pressures on our health care system, including our hospitals.”

The Staff Report’s analysis amply shows that if e-scooters are allowed, this will lead to an increase in personal injuries, both to e-scooter riders and innocent pedestrians. Of course, this will create additional demands and pressures on our already over-burdened hospital emergency rooms.

Our health care system is already over-burdened, and does not need additional cases resulting from additional injuries caused by e-scooters on our streets.

Conclusion and Recommendation:

E-scooters pose a risk to all pedestrians, but especially to persons with disabilities due to their faster speeds and lack of noise. I strongly recommend the Infrastructure and Environment Committee support the position of the Toronto Accessibility Advisory Committee and recommend that City Council prohibit e-scooters for use in public spaces including sidewalks and roads.